郭文贵破产案 · EXHIBIT · ECF #440-24

元数据

当事人: 郭文贵 (Guo Wengui / Miles Guo / Ho Wan Kwok)
法院: CTB
案号: 22-50073
ECF #: 440
类型: EXHIBIT
立案日: 2022-05-25

原始法庭文件为英文，下方为英文全文。

全文

# **EXHIBIT PAX 26**

Transcript of Craig Jalbert Deposition

| | | 22-50073 | | | |--------|-----|----------------------------|----|--| | IN RE: | | Ho Wan Kwok | | | | | | | | | | | PAX | | 26 | | | | | | | | | | | 5/25/2022 Admitted in Full | | | | | | P.E. | | | | | | | | | | | | | | |

1 2 UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT 3 BRIDGEPORT DIVISION ------------------------------------------X 4 IN RE: 5 Chapter 11 HO WAN KWOK, 6 Case No. 22-50073(JAM) 7 Debtor. 8 ------------------------------------------X 9 10 DATE: April 8, 2022 11 TIME: 10:17 A.M. 12 13 14 VIDEO-RECORDED DEPOSITION OF CRAIG 15 JALBERT of VERDOLINO & LOWEY, P.C., in the 16 above entitled matter, at the above date 17 and time, held at the offices of O'Melveny 18 & Myers LLP, 7 Times Square, New York, New 19 York 10036, by Lenaya Lynch, a Notary 20 Public and Shorthand Reporter of the State 21 of New York. 22 23 24 25 Page 1 85

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

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

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| 1 | C. JALBERT | 1 | C. JALBERT | |----|---------------------------------------------|----|---------------------------------------------| | 2 | testify accurately or truthfully? | 2 | been designated to testify about each topic | | 3 | A. No. | 3 | listed here? | | 4 | Q. Are you taking any medications | 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 | Q. Is there any reason why you | 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 | Q. Do you understand that you are | | 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? | | 17 | Exhibit 1 for identification as of | 17 | A. Yes. | | 18 | this date by the Reporter.) | 18 | Q. Do you understand that you were | | 19 | Q. All right, Mr. Jalbert. Do you | 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 | of Verdolino and Lowey PC pursuant to Rule | 25 | before. | | | Page 10 | | 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 | Q. What, if anything, did you do | | 4 | Q. Is it your understanding that | 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 | Q. Can you please turn to Page 6 | 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 | Q. Did you collect the documents | | 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.) | 17 | 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 | Q. I'm asking -- taking a step | | 20 | record. You may proceed. | 20 | back, just asking about your preparation | | 21 | Q. Can you turn to Page 6 to the | 21 | for today's deposition. | | 22 | heading Rule 30(b)(6) deposition topics? | 22 | A. I just looked at my own | | 23 | You see that? | 23 | documents and my own e-mails on the | | 24 | A. Yes. | 24 | Verdolino and Lowey server. | | 25 | Q. Do you understand that you have | 25 | Q. Generally, what were the | | | Page 11 | | Page 13 |

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Page 14 1 C. JALBERT 2 subject matters of those e-mails? 3 A. It was looking at the -- all of 4 -- not all of them. Many of my e-mails, 5 the SOFA's -- the statement of financial 6 affairs -- the schedules, the global notes, 7 the global notes and specific notes, most 8 of the pleadings to employ professionals, 9 particularly ours, the motion for the DIP 10 financing, many of the objections, not all 11 of them. I'm trying to think if there's 12 anything else. I can't think of anything 13 off the top beyond that -- 14 Q. Thank you. That's helpful. So 15 you mentioned that you spoke to your 16 attorneys, Ben and Ken? 17 A. Yes. 18 Q. When did you speak to them? 19 A. Well, we were delayed a little 20 bit so I had a few minutes this morning 21 with Ken. I spoke with Ben briefly last 22 night. Again, this morning on -- unrelated 23 to the deposition and I had previously 24 spoken to Ken probably one or two times 25 over the last few days, give or take. Page 15 1 C. JALBERT 2 Q. Were each of these interactions 3 over the phone? 4 A. Until today, yes. 5 Q. About how long did you spend 6 preparing with your attorneys in connection 7 with your preparation for this deposition? 8 A. I would have to hazard a guess. 9 I don't have my time records in front of 10 me. 11 Q. Like two hours, ten hours? 12 A. My guess is in the two to four 13 hour range. No more than that. 14 Q. Did you speak to anyone else 15 other than the folks that you mentioned at 16 Verdolino and Lowey and your attorneys 17 regarding this deposition? 18 A. Our IT person, Tim McDonald who 19 assisted in the search -- the electronic 20 search of e-mails and records and worked 21 with the Brown Rudnick IT person to send 22 everything over. Aside from having him try 23 and get the records, we didn't have any 24 discussion of the case facts and 25 circumstances or anything. Page 16 1 C. JALBERT 2 Q. Anyone else besides the people 3 that we've talked about? 4 A. Regarding the -- just regarding 5 the deposition? 6 Q. Yes. 7 A. No. 8 Q. You haven't spoke to the 9 debtor? 10 A. About the deposition? 11 Q. About the deposition. 12 A. No. 13 Q. Have you ever met the debtor? 14 A. Yes. 15 Q. When did you meet the debtor? 16 A. The continued meeting of 342 -- 17 or 341 meeting which was I think Wednesday, 18 the first time I met him. 19 Q. Is that the only time you met 20 the debtor? 21 A. Yes. 22 Q. Outside of the 341 proceeding, 23 did you interact with the debtor? 24 A. No. 25 Q. I just want to cover a little Page 17 1 C. JALBERT 2 bit of your background. Can you talk about 3 your educational history since high school? 4 A. I graduated from Western 5 Connecticut High School in 1979. I went to 6 Boston College. Graduated Boston College 7 with a bachelor of science and degree in 8 accountancy in 1983. I went to work for 9 Arthur Andersen from June of '83 till 10 August 31 of '87. On September 1 of 1987, 11 I started at the precursor of what is now 12 Verdolino and Lowey and I've been there in 13 the 35 years since and during that time, I 14 I've gone to many, many, many professional 15 CPE type courses of all sorts of flavors. 16 Q. What do you mean by CPE? 17 A. A continuing professional 18 education. 19 Q. Is that a required procedure 20 for any type of certification that you 21 have? 22 A. It's -- some of it is required 23 for my certification as a certified 24 insolvency restructuring advisor. The rest 25 are just to maintain my professional 85

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| 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 Verdolino and Lowey? | 23 A. Yes. | 24 Q. Generally, what services does | 25 Verdolino and Lowey offer its clients? | | Page 18 | | 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, | 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 | 17 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, | 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 | | Page 20 | | | | | | 1 C. JALBERT | | 2 in Chapter 11 cases? | | 3 A. I've been in over 500 Chapter | | 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 | is Page 19 | 25 and the like that spreads over a little bit Page 21 |

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| | 85 | | | | |----------|--------------------------------------------------------------|----------|--------------------------------------------------------------|---------| | 1 | C. JALBERT | 1 | C. JALBERT | | | 2 | to taxation. I don't run the department or | 2 | generally regarding the engagement? | | | 3 | anything but I certainly interact and then | 3 | A. There was a little bit with | | | 4 | litigation support and the like, you know, | 4 | Steven Pohl and with -- I believe it was | | | 5 | the types of things you would do in the | 5 | Ben Silverberg. | | | 6 | context of a bankruptcy. | 6 | Q. Anyone else at Brown Rudnick? | | | 7 | Q. What is meant by litigation | 7 | A. I don't remember. | | | 8 | support, generally? | 8 | Q. Besides Brown Rudnick, did you | | | 9 | A. Well, it can be pretty broad | 9 | speak to anyone else regarding the | | | 10 | but for us, it's -- whether it be business | 10 | potential engagement? | | | 11 | litigation or bankruptcy litigation, to the | 11 | A. I probably mentioned something | | | 12 | extent that there are areas that whoever | 12 | to my -- my own staff to clear conflicts | | | 13 | the law firm -- we've also been appointed | 13 | and I think I had someone help me prepare | | | 14 | by judges, anyone that's looking or | 14 | some -- I shouldn't say prepare, they're | | | 15 | interested in obtaining financial | 15 | already prepared. Send some individual | | | 16 | information in a form that they're looking | 16 | information about myself and the firm. | | | 17 | for, which could be anything, we would | 17 | Q. Did Verdolino and Lowey speak | | | 18 | provide it. That would include doing | 18 | to anyone else besides Brown Rudnick in | | | 19 | expert reports, expert testimony and work | 19 | connection with the engagement? | | | 20 | at just advising lawyers as they approach | 20 | MR. AULET: Objection. You can | | | 21 | areas in accounting and auditing and the | 21 | answer. | | | 22 | like. | 22 | A. At the time we're being | | | 23 | Q. You mentioned here that you're | 23 | engaged? | | | 24 | a principal at Verdolino and Lowey? | 24 | Q. Yes. | | | 25 | A. Yes. Page 22 | 25 | A. No. | Page 24 | | | | | | | | | | | | | | 1 | C. JALBERT | 1 | C. JALBERT | | | 2 | Q. What other roles have you held? | 2 | Q. Who are the main points of | | | 3 | A. I've been a principal since I | 3 | contact between -- who are the main | | | 4 | started. | 4 | contacts for -- strike that. Who do you | | | 5 | Q. Turning to the engagement here, | 5 | generally speak to regarding this | | | 6 | who contacted Verdolino and Lowey about | 6 | engagement besides internal folks at | | | 7 | this engagement? | 7 | Verdolino and Lowey? | | | 8 | A. Well, it was contacted me | 8 | A. Mostly the attorneys at Brown | | | 9 | personally and it was an attorney, Steven | 9 | Rudnick. | | | 10 | Pohl at Brown Rudnick. | 10 | Q. Do you speak to anyone else? | | | 11 | Q. Sorry, I missed what you said. | 11 | A. I've been on phone calls with | | | 12 | MR. HARBACH: Spell that name. | 12 | other lawyers but I've not initiated | | | 13 | Q. Can you spell that name, | 13 | anything. | | | 14 | please? | 14 | Q. Which other lawyers have you | | | 15 | A. The name was Steven Pohl. Last | 15 | been on phone calls with? | | | 16 | name P-O-H-L at Brown Rudnick. | 16 | A. The other debtor lawyers that | | | 17 18 | Q. Mr. Pohl reached out to who at Verdolino and Lowey? | 17 18 | I'm aware of are an Aaron Mitchell and a Melissa Francis. | | | 19 | A. Me. | 19 | Q. Who do you understand Aaron | | | 20 | Q. You. Do you recall when that | 20 | Mitchell to be? | | | 21 | was? | 21 | A. Counsel to Mr. Kwok, the | | | 22 | A. Somewhere around March 1, 2 or | 22 | debtor. | | | 23 | 3. | 23 | Q. You mentioned Melissa Francis? | | | 24 | Q. After Steven Pohl reached out, | 24 | A. Also counsel to Mr. Kwok. | | | 25 | who did Verdolino and Lowey speak to Page 23 | 25 | Q. Besides Aaron Mitchell and | Page 25 |

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

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| | 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 | C. JALBERT Melissa Francis. Did she represent to you that she was Mr. Kwok's counsel? A. No. Q. How did you learn about what Ms. Melissa Francis -- who Mr. -- strike that. How did you learn who Ms. Francis' client was? A. From Brown Rudnick. Q. We've talked about the folks at Verdolino that you communicate with this engagement. Do you know of anyone else that Verdolino and Lowey communicates with regarding this engagement besides the folks that we've talked about? A. I don't think there were others but it is possible that one of my colleagues met Flynn. Might have had e-mail contact. You're aware -- because I think you objected to -- there's a large number of ordinary course professionals. We needed to get information about liabilities to them for the schedules. There might have been some information and stuff because we needed -- it's possible | 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 | C. JALBERT sure I wasn't missing anything. Q. Besides the attorneys at Brown Rudnick, did you circulate drafts of that engagement letter to anyone else? A. I don't recall anyone else being on it but I'm pretty sure they then did circulate it with -- at a minimum, Ms. Melissa Francis and probably Aaron Mitchell as well. MS. ARONSSON: Tab 11. The Court Reporter is going to hand you what is being marked as Jalbert Exhibit 2. This document -- for the record, this document bears the Bates Number Kwok 00001646. (Whereupon, E-mail Chain was marked as Jalbert Exhibit 2 for identification as of this date by the Reporter.) Q. Before we get to the exhibit, what is a post-petition retainer? A. My understanding would be a retainer paid to whoever, after the filing of a bankruptcy, intended to be a retainer. | | | 1 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 30 C. JALBERT that he spoke with them but I think really what he did is he got all the information from Aaron Mitchell and Melissa Francis. I don't think he went outside of that but it's possible. Q. Do you know where Aaron Mitchell and Melissa Francis retrieved their information from? A. No. Q. Did you ask them where they retrieved their information from? A. No. Q. Who negotiated -- who, from Verdolino and Lowey, negotiated the engagement letter? A. It would be me. I don't know that I would call it a negotiation but it was me that drafted it and prepared it and sent it to Brown Rudnick. Q. Anyone else involved in drafting that engagement letter? A. Well, from a QPC perspective, I'm sure I had one of my colleagues, Mary Jo Schindler take a look at it just to make Page 31 | 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 | C. JALBERT Q. Can you please turn to Page 2 of this document? Take a minute. At the top of Page 2, Mr. Silverberg says that there's no post-petition retainer expected. Do you see that? A. Yes. Q. Do you recall whether you had a preference about receiving a post-petition retainer? A. Well, every professional would rather have a retainer but frankly, under the circumstances, it wasn't expected. Q. Starting with your preference, why would you prefer to have a post-petition retainer? A. Security against the payment of the fees. Q. Do you know whether you received a post-petition retainer in connection with this case? A. I do. Q. Did you? A. No. Q. And why not? | Page 32 Page 33 |

9 (Pages 30 - 33)

| 1 | C. JALBERT | 1 | C. JALBERT | |----|-------------------------------------------------|----|-------------------------------------------------| | 2 | A. I didn't ask for one. | 2 | A. Yep. | | 3 | Q. Turning back to the e-mail, Mr. | 3 | Q. Did you ask for a post-petition | | 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 | A. No. | | 7 | financial advisor". Do you recall that | 7 | Q. Do you know if Verdolino and | | 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 | Q. What's the answer? | | 12 | question. I can read the statement and | 12 | A. No. | | 13 | understand but I don't know what you're | 13 | Q. You also write, "but I think if | | 14 | asking. | 14 | we are going to hold the cash, we will need | | | | | | | 15 | Q. He says, "big Q", do you | 15 | to be employed by the debtor". So does | | 16 | understand that to be a big question? | 16 | that refresh your recollection about | | 17 | 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 | Q. Generally, can you explain your | | 25 | bottle? It's coming up in the frame. Page 34 | 25 | view in connection with the question 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 | Q. What is the basis for the | | 15 | Q. Please take a look at this | 15 | understanding that you just explained? | | 16 | document. | 16 | MR. AULET: Objection to form. | | 17 | A. Okay. | 17 | A. Of what part? | | 18 | Q. You're responding to Mr. | 18 | Q. Where, turning to your e-mail, | | 19 | Silverberg's e-mail that we were just | 19 | "if we 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 | Q. Turning to your response, you | 23 | If me, as a principal of Verdolino 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? | 25 | debtor in possession bank account, it would | | | Page 35 | | 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 | Q. Thank you. Just for my own | 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 | A. Well, if I was employed by | 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 | | 19 | So -- but if I was right and there wouldn't | 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 | Q. Thank you. That's helpful. | 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 | with that determination of who would be | 3 | what knowledge we have as privileged. I | | 4 | retaining Verdolino and Lowey? | 4 | don't know that that's relevant here. | | 5 | MR. AULET: Objection to form. | 5 | Q. 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. | | 17 | 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 25 | Q. What do you mean by for purposes of the privilege? | 24 25 | versus an operating business case? A. So operating business cases |

11 (Pages 38 - 41)

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

12 (Pages 42 - 45)

Page 46 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 47 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 17 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 48 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 of the 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 49 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

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 | Q. What is Matt Flynn's role? | 7 | and the crises that materialize. | | 8 | A. A manager. | 8 | Q. What about staff, what sort of | | 9 | Q. Is Mindy Jo Schindler a | 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 | Q. What is her role? | 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 | Q. Do you anticipate other | 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 | A. I think of it as partner, | 3 | should file an income tax return for the | | 4 5 | director, managing director, any of those, the lead person on the case from the firm. | 4 5 | Estate. So we'll have tax people involved 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 | A. I assisted in preparation of | 9 | accustomed. We know all of our fees are | | 10 | the SOFA'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 | Q. Is it fair to say your answer | | 17 | 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 | Q. So the answer that you just | | 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 1 C. JALBERT 2 aren't going to do reporting but they're 2 A. From my firm? 3 going to maintain receipts and 3 Q. Who at V&L? 4 disbursements. A staff person would 4 A. Myself, Matthew Flynn and Mary 5 probably work on the form of the -- of a 5 Jo Schindler. 6 financial statement or whatever report 6 Q. Who else was involved in 7 that's going to be issued. The staff are 7 preparing these filings? 8 going to work on claims objections. Tax 8 A. There might have been a 9 professionals are going to work on tax 9 technical question for someone related to 10 returns. 10 the best case but I can't think of anything 11 Q. Are you finished with your 11 else -- anyone else that had any -- that 12 answer? 12 did work on it. 13 A. Yes. 13 Q. Did Brown Rudnick work on the 14 Q. You mentioned receipts and 14 SOFA and schedules? 15 disbursements. What sorts of receipts and 15 A. You asked me for my firm. Of 16 disbursements do you anticipate in this 16 course they worked on them, as did Melissa, 17 case? 17 as did -- that's Melissa Francis. As did 18 A. I would imagine if things were 18 Aaron Mitchell. So it was clearly not all 19 to go the way the debtor planned, there was 19 Verdolino and Lowey. It was -- the whole 20 a proposed DIP financing arrangement where 20 team was involved in the preparation. I 21 money will come into the Estate and then 21 thought you asked me -- and if I 22 would presumably be used to pay various 22 misunderstood, I apologize -- you asked 23 professionals and United States Trustee 23 who, at Verdolino, did and that was myself, 24 fees and whatever other disbursements are 24 Matt Flynn and Mary Jo Schindler. 25 required of the debtor as ordered by the 25 Q. Thank you. Yes, I did ask Page 54 Page 56 1 C. JALBERT 1 C. JALBERT 2 Court or otherwise generally required to 2 Verdolino and Lowey and was then moving on. 3 pay Chapter 11 bills as they become due. I 3 So you mentioned Melissa Francis, Aaron 4 think that's it. 4 Mitchell, Brown Rudnick. Generally, anyone 5 Q. The last item is clerical. 5 else? 6 What sort of duties do you anticipate a 6 A. While I never spoke to them, 7 clerical member of your team to do in this 7 there must have been the existence of help 8 case? 8 from individuals that translated documents 9 A. I don't have anything that I 9 and words from the various professionals to 10 have presupposed for them to do in this 10 the debtor and the debtor. 11 case. 11 Q. Did you communicate with the 12 Q. Turning back in the document to 12 debtor about this SOFA and schedules? 13 the retention agreement, this is on Page 13 A. No. 14 13. We've talked generally about the 14 Q. You mentioned some translated 15 engagement -- Verdolino and Lowey's 15 documents. Did you receive those 16 engagement in this case. I want to walk 16 translated documents in connection with 17 through these bullet points on the first 17 your work on the SOFA and schedules? 18 page. The first one reads, "assistance 18 A. No. I don't read Mandarin. 19 with preparation of the statement of 19 Q. Did you see any translated 20 financial affairs and the schedules and all 20 documents? 21 support thereto and any amendments". These 21 A. I don't recall seeing them. 22 have been filed, right? 22 MR. AULET: Objection to form. 23 A. Yes. 23 Q. Do you know whether Golden 24 Q. Who was involved in preparing 24 Spring was involved in preparing the SOFA 25 the SOFA and the schedules? 25 and schedules? 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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 | Q. What is it? | 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 | Q. Neither you nor anyone at | 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 SOFA's and -- SOFA's and the | | 20 | Q. Can you describe what work | 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 | Q. So is it fair to say it's like | | 23 | A. We participated with several | 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 | 25 | A. Or QuickBooks or -- you know. | | | Page 58 | | Page 60 | | | | | | | | | | | | 1 | C. JALBERT | 1 | C. JALBERT | | 2 | going to remember were on the phone and | 2 | Q. So that software is essentially | | 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 | Q. Turning to the second bullet | | 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 11 | Brown Rudnick team and Melissa and Aaron on the phone and then numerous e-mails. | 10 11 | of cash flow and related budget projections 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 | Q. So is it fair to say you took | 20 | this line item? | | 21 | their word regarding the representations | 21 | A. Anticipate doing this if we're | | 22 | contained in the SOFA and the schedule? | 22 | in the case and there's a DIP. | | 23 | A. That's fair. | 23 | Q. So it includes budget | | 24 | Q. Is there any outstanding work | 24 | projections. Budget projections for who? | | 25 | that Verdolino and Lowey will anticipate Page 59 | 25 | A. I imagine we will try and Page 61 |

16 (Pages 58 - 61)

| | 85 | | | |----------|---------------------------------------------|----------|----------------------------------------------------| | 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 64 | | | | | | | | Page 62 | | | | 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 24 | there's a DIP loan here? A. No. | 23 24 | structured? 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 |

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

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| 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 | Q. So is it fair to say that | | 17 | of those funds. Is that right? | 17 | 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 | A. I don't know if it's listed in | | 20 | that. The -- the accrual of the -- of 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 | Q. You prepared one monthly | 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 | Q. Is another monthly operating | 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 | Q. Did you also prepare -- scratch | 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 | Q. We can come back to that. | 16 | "assistance with preparation and/or review | | 17 | A. Okay. | 17 | of estate federal and state income tax | | 18 | Q. Have you or Verdolino and Lowey | 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 | Q. Yes. | 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 | Q. What is a quarterly report? Page 71 | 25 | in this case? Page 73 |

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| | 85 | | | |----------|-----------------------------------------------------------------------------------------|----------|-------------------------------------------------------------------------------------| | 1 | C. JALBERT | 1 | 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 | Q. Do you anticipate that multiple | | 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 | | 17 | 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 22 | the Estate. So there really shouldn't be a separate one but technically, there could | 21 22 | your understanding that the debtor has no income in this case? | | 23 | be. The Estate is -- the Estate return is | 23 | A. Correct. | | 24 | generally assigned to be December 31, | 24 | Q. What work do you anticipate | | 25 | unless you elect otherwise. There are | 25 | Verdolino and Lowey will do in connection | | | Page 74 | | Page 76 | | | | | | | | | | | | 1 2 | C. JALBERT reasons to elect otherwise but the most | 1 2 | C. JALBERT 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 if there 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 22 | then they got another 120 days. I want -- I recommend it in every single case, | 21 22 | case may be. They are treated in different 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 |

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

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| | 85 | | | |----------------------------------------|-------------------------------------------------------|----|-----------------------------------------------| | 1 | C. JALBERT | 1 | C. JALBERT | | 2 | A. No. | 2 | someone to do work on a preference | | 3 | Q. What experience does Verdolino | 3 | analysis. We certainly participated in | | 4 | and Lowey have in analyzing the likelihood | 4 | preparing that because we filed them. | | 5 | of success in pending litigation claims? | 5 | Q. Do you know how many | | 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 | Q. Does 21 sound about right? | | 10 | such as preference and fraudulent transfer | 10 | A. I don't know. | | 11 | claims". Do you see that? | 11 | Q. So the line item refers to | | 12 | A. Yes. | 12 | debtor books and records for possible | | 13 | Q. Can you explain to me, | 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. | | 17 | allows 90 days prior to the filing for | 17 | Q. Has Verdolino and Lowey | | 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 | Q. Is it fair to say that | | 22 | the statute happens to be for whatever the | 22 | Verdolino 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 | 25 | MR. AULET: Objection to form. | | | Page 82 | | 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 -- | | | specifics. | 10 | THE WITNESS: No, let's get the | | 10 11 | MS. ARONSSON: Sorry, what do | 11 | -- let's do it all at once. I would | | | you mean? | 12 | like to get out of here before | | | MR. AULET: That if he has done | 13 | tonight. | | | any work, it would be covered by the | 14 | MR. GOLDMAN: We are going to | | | work/product privilege. Not to | 15 | break at 12. | | | disclose those specifics. | 16 | MR. HARBACH: Yes, sir. | | 12 13 14 15 16 17 | Q. Setting aside the work/product | 17 | Q. Okay, turning to the next line | | | protection that Brown Rudnick is alleging | 18 | item, "assistance with any necessary | | | in connection with this line item, can you | 19 | litigation support". I think we covered | | | answer the question? | 20 | this previously. Do you have anything to | | | A. Well, one of the questions in | 21 | add about potential services in connection | | | the SOFA's is payments made in the 90 days | 22 | with this line item that we haven't already | | | prior to bankruptcy. I don't know if | 23 | discussed? | | 18 19 20 21 22 23 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 |

22 (Pages 82 - 85)

| 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 | A. If we did, it would be awfully | | 5 | Q. The next -- turning to the next | 5 | small. | | 6 | line item is "assistance with plan | 6 | Q. Understood. Are you aware of | | 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. AULET: He can answer if | | 17 | 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 | Q. Turning to -- turning to the | | 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 | Q. The line item says feasibility | 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 | Q. What analysis has Verdolino and | 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 | Q. Are you familiar with a company | | 22 | A. None. | 22 | called Stretto? | | 23 | Q. Would Verdolino and Lowey have | 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 |

23 (Pages 86 - 89)

| | 85 | | | |----------|-------------------------------------------------------|----------|-----------------------------------------------------------------------------| | 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 | Q. You mentioned before that you | | 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 | Q. Are you aware that Stretto was | 8 | two of the same cases that we're in. | | 9 | involved in this matter? | 9 | Q. Do you have an understanding as | | 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 | Q. Generally, what is your | 12 | A. No. | | 13 | understanding of the scope of work that | 13 | Q. Do you have an understanding | | 14 | Stretto would potentially be employed to | 14 | about whether Stretto could monitor | | 15 | do? | 15 | disbursements in connection with a DIP | | 16 | A. I have not read their motion to | 16 | account? | | 17 | employ. No idea what their -- | 17 | A. No. | | 18 | MS. ARONSSON: Let's go off the | 18 | Q. Turning to the books and | | 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 Page 90 | 25 | provide analysis with respect to those Page 92 | | | | | | | 1 | C. JALBERT | 1 | C. JALBERT | | 2 3 | the record. Q. Just wrapping up the questions | 2 3 | payments. Why is it necessary for 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. | | 7 | an escrow agent could open and maintain a | 7 | A. 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 | | | | | | | | | | | A. I don't have any knowledge of | 10 | MS. ARONSSON: The Court | | 11 12 | why they couldn't but I'm certainly not an expert. | 11 12 | Reporter is going to hand you what is being marked as Jalbert Exhibit 5. | | 13 | Q. What about monitoring | 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 | A. The bank doing it? | 16 | by the Reporter.) | | 17 | Q. Yes. | 17 | MS. ARONSSON: I'll say for the | | 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 | Q. Or an escrow agent. | 20 | this case. | | 21 | A. An escrow agent would have more | 21 | Q. Do you recognize this document, | | 22 | obligation, whatever the escrow agreement | 22 | Mr. Jalbert? | | 23 | says. I don't -- | 23 | A. Yes. | | 24 | Q. But an escrow agent could be | 24 | Q. What is it? | | 25 | employed to perform those duties? Page 91 | 25 | A. The first page is the official Page 93 |

24 (Pages 90 - 93)

| | 85 | | | |----------|---------------------------------------------------|----------|--------------------------------------------| | 1 | C. JALBERT | 1 | C. JALBERT | | 2 | form 106Sum which is the summary of assets | 2 | Q. Item 58 refers to Line 36? | | 3 | and liabilities and certain statistical | 3 | A. Okay. | | 4 | information for the debtor, Ho Wan Kwok. | 4 | Q. So 36, just up the page, the | | 5 | Q. I think we've discussed earlier | 5 | total amount here is 3,850 dollars. Do you | | 6 | that Verdolino and Lowey had a role in | 6 | see that? | | 7 | preparing the SOFA and schedule. Is that | 7 | A. Yes. | | 8 | right? | 8 | Q. So 36 wraps up into one number. | | 9 | A. Yes. | 9 | Part 4 of this filing, is that fair? | | 10 | Q. Verdolino and Lowey had a role | 10 | MR. AULET: Objection to form. | | 11 | in preparing this document? | 11 | A. Well, when you mean this | | 12 | A. Yes. | 12 | filing, are you talking about Part 4 of | | 13 | Q. I just want to walk through | 13 | Schedule A/B. | | 14 | this at a high level. The first line item | 14 | Q. I am, yes. Thank you for the | | 15 | is -- item one relates to property. What | 15 | clarification. | | 16 | does this line item include? | 16 | A. I would agree that Line 36 is | | 17 | A. What specific -- A, B or C or | 17 | the sum of Part 4 which starts at question | | 18 | all of them? | 18 | 16. | | 19 | Q. Sorry, fair question. 1A. | 19 | Q. What analysis, if any, did | | 20 | A. Well, it reads "Schedule A/B | 20 | Verdolino and Lowey perform in connection | | 21 | Property official form 106A/B", question or | 21 | with these line items? | | 22 | 1A, "copy Line 55. Total real estate from | 22 | A. Whatever we did, we did working | | 23 | schedule A/B". | 23 | with the lawyers. | | 24 | Q. Thank you. And it reads zero? | 24 | Q. I'm going to ask you to turn to | | 25 | A. Correct. | 25 | Page 3 of the document. | | | | | | | | Page 94 | | Page 96 | | 1 | C. JALBERT | 1 | C. JALBERT | | 2 | Q. What analysis, if any, did | 2 | MR. AULET: Just for | | 3 | Verdolino and Lowey do to prepare this line | 3 | clarification, every time you're | | 4 | item? | 4 | refer to Page 3, you're referring to | | 5 | A. I worked with the lawyers. | 5 | the top numbers? | | 6 | Q. Did you do any independent | 6 | MS. ARONSSON: Yes. I'm | | 7 | investigation with respect to the line item | 7 | referring to the docket numbering at | | 8 | 1A? | 8 | the top. Page 3 of 23. | | 9 | MR. AULET: Objection to form. | 9 | Q. Starting with Part 1 here, did | | 10 | A. No. | 10 | Verdolino and Lowey perform any work in | | 11 | Q. Turning to 1B, this reads, | 11 | connection with this line item? | | 12 | "total personal property from Schedule A/B" | 12 | A. If we did, we did with counsel. | | 13 | and I think this refers us to Line 36? | 13 | Q. In Part 2, Item 3 and 4 | | 14 | A. I would have thought it related | 14 | referring to cars, vans, trucks, etcetera, | | 15 | to Line 62. | 15 | watercraft, aircraft, did Verdolino and | | 16 | Q. It does and then 62. Sorry -- | 16 | Lowey perform any work in connection with | | 17 | so 62 refers back to 56 to 61. Do you see | 17 | this section? | | 18 | that, that's on Page 7 of the PDF? | 18 | A. All with counsel. | | 19 | A. Lines 56 to 61, is that what | 19 | Q. So it's fair to say, when you | | 20 | you're referring to? | 20 | say you performed work with counsel, you | | 21 | Q. That's right. | 21 | didn't perform any independent | | 22 23 | A. Yep. Q. The only item populated in 55 | 22 23 | investigation? A. Correct. | | 24 | to 61 is Item 58? | 24 | Q. Part 3, Items 6 through Items | | 25 | A. Correct. | 25 | 15 refer to personal and household items, |

25 (Pages 94 - 97)

| 1 | C. JALBERT | 1 | C. JALBERT | |----------|---------------------------------------------|----------|-----------------------------------------------------------| | 2 | is that right? | 2 | EXAMINATION BY | | 3 | A. Yes. | 3 | MR. HARBACH: | | 4 | Q. Without walking through each of | 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 | Q. Just to be clear about your | 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 | A. The specific part of the | | 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 | A. Not the general -- | | 16 | A. We keypunched into the forms | 16 | Q. Understood. | | 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 | Q. The specific notes are -- | | 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 | 1 | 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 | Q. Did you communicate or did | 4 | fitting the personal and household | | 5 | Verdolino and Lowey communicate with anyone | 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 | of them 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 if I | 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 | if I investigated whether the spatulas and | | 23 | MR. AULET: I don't have any | 23 | the pots and pans existed and who bought | | 24 25 | objection. MR. HARBACH: Thank you. | 24 25 | them and how much they were and are they at the house? |

26 (Pages 98 - 101)

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

27 (Pages 102 - 105)

| | 85 | | | |----------|------------------------------------------------------------------------------|----------|---------------------------------------------------------------------------------------| | 1 | C. JALBERT | 1 | C. JALBERT | | 2 | scratch that. What was Verdolino and | 2 | operating report is a different report and | | 3 | Lowey's role in connection with this | 3 | that's a completely different question than | | 4 | section? | 4 | what's on here. | | 5 | A. We had discussions with the | 5 | Q. Can you explain to me the | | 6 | legal team, which is Brown Rudnick team | 6 | difference? | | 7 | plus Aaron Mitchell, plus Melissa Francis, | 7 | A. And I don't remember what | | 8 | probably more than one time, probably | 8 | question it is, is it like 4 or 5 or 6E or | | 9 | orally, probably in e-mail and it was a | 9 | whatever it is, the request is to report | | 10 | discussion. | 10 | the expenses paid by others on the debtor's | | 11 | Q. Turning to the next page, the | 11 | behalf. That's not what this asks. So in | | 12 | estimated monthly operating expenses reads | 12 | the schedule, we listed some funds and we | | 13 | zero. Is that fair? | 13 | will, going forward, be listing and | | 14 | A. Yes. | 14 | reporting, as required by the MOR, the | | 15 | Q. Did you anticipate the debtor's | 15 | expenses paid by others on behalf of the | | 16 | monthly operating expenses to remain zero | 16 | debtor which is again different from what | | 17 | after this point? | 17 | this asks. | | 18 | MR. AULET: Objection to form. | 18 | Q. Focusing on what this asks, | | 19 | A. It certainly was discussed with | 19 | it's your understanding that the debtor's | | 20 | the attorneys. I don't think it's a | 20 | ongoing monthly expenses is zero? | | 21 | secret. There was lots of discussion | 21 | MR. AULET: Objection to form. | | 22 | yesterday. So my expectation is yes, as to | 22 | A. The debtor's payment of the | | 23 | his expenses, his payment of his expenses | 23 | ongoing expenses is zero. | | 24 | is going to remain I think zero. | 24 | Q. You did no investigation into | | 25 | Q. I think you said his -- his | 25 | whether that is correct? | | | | | | | | Page 106 | | Page 108 | | 1 | C. JALBERT | 1 | C. JALBERT | | 2 | expenses. In your view, what does his | 2 | A. Correct. | | 3 | expenses cover? | 3 | Q. Turning just to the Excel | | 4 | A. There's a whole list of them | 4 | sheets at the end of this document, | | 5 | here. You want to go down them? It looks | 5 | starting just broadly, was Verdolino and | | 6 | like about 30 of them. Real estate taxes, | 6 | Lowey involved in preparing these | | 7 | property and homeowners and renters' | 7 | documents? | | 8 | insurance, home maintenance repair and | 8 | A. Well, we were certainly | | 9 | upkeep expenses, home ownership association | 9 | involved with others, yes. | | 10 | and condo dues. Don't even know if those | 10 | Q. What -- generally, what work | | 11 | are applicable. Electricity, heat and | 11 | did Verdolino and Lowey do in connection | | 12 | natural gas. Want me to keep going? | 12 | with these documents? | | 13 | Q. So we can just agree that Items | 13 | A. Reviewed them for | | 14 | 4 through 21 would include monthly | 14 | reasonableness, assisted in putting them in | | 15 | expenses? | 15 | a form that would normally be seen in a | | 16 | A. Again, as it relates to him | 16 | SOFA and schedule. I think some of this | | 17 | paying them, I would agree. My | 17 | was uploaded into the actual Schedule F | | 18 | understanding is they're going to remain | 18 | because I think Schedule F -- well, maybe | | 19 | zero. | 19 | it doesn't. I don't know. I don't | | 20 21 | Q. So this -- the analysis contained in this document is separate from | 20 21 | remember whether this was uploaded or not but it could be. So that -- so it starts | | 22 | the monthly operating report, the reports | 22 | with D. So all of these, we worked with | | 23 | that you, Verdolino, draft in connection | 23 | the attorneys and that's again, all three, | | 24 | with this case? | 24 | the Brown Rudnick team, Aaron Mitchell and | | 25 | A. Correct, because the monthly | 25 | Melissa Francis. |

28 (Pages 106 - 109)

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

29 (Pages 110 - 113)

| | 85 | | | |----------|--------------------------------------------------------------------------|----------|----------------------------------------------------------------------------------------| | 1 | C. JALBERT | 1 | 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 | Q. So beyond what this says here | | 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? | 17 | Q. Do you know what kind of car it | | 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 | Q. Is this -- strike that. Is -- | | 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 | Q. Why? | | 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. | 8 | the vehicles -- you know, I don't know if | | 9 | Q. Any involvement in those | 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 | Q. What about the purchase of the | | 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 21 | Q. Do you have any understanding of what vehicles the debtor uses? | 20 21 | maybe it shows up. I don't know. On the 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)

| | 85 | | | |----------|---------------------------------------------------------|----------|-----------------------------------------------------------------------------------------| | 1 | C. JALBERT | 1 | C. JALBERT | | 2 | Q. Does that answer apply to the | 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 | of 50 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 | Q. Beyond what's written on the | | 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 | Q. The second sentence notes that | | 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 | Q. You performed no valuation of | | 11 | A. Nothing that's not printed on | 11 | these items in connection with your work? | | 12 | this page. | 12 | A. Correct. | | 13 | Q. Did you do any independent | 13 | Q. Do you know if any valuation | | 14 | investigation into this? | 14 | was performed? | | 15 | A. No. | 15 | A. None to my knowledge. | | 16 | Q. Items 6 and 7, household goods | 16 | Q. Question 31 asks for interest | | 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 | Q. Is it standard practice that a | | 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 25 | to Mr. Kwok versus some other third-party or entity? | 24 25 | where a health insurance policy has a cash value except for to the beneficiary of -- |

31 (Pages 118 - 121)

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

32 (Pages 122 - 125)

Page 126 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 127 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. 17 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 128 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 -- 17 A. The litigation funding 18 agreements? 19 Q. Yes. Thank you. Have you seen 20 them before? 21 A. Not to my knowledge. 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 129 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. 17 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

33 (Pages 126 - 129)

| | 1 C. JALBERT | 1 | C. JALBERT | |----|---------------------------------------------|----|--------------------------------------------------------| | | 2 and direct him the Witness to answer | 2 | Q. Is this the monthly operating | | | 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 | Q. Turning to the filing 120-1, | | | 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 | Q. Is it fair to say that this is | 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 | | 17 | A. As to the one particular | 17 | behalf of the debtor, on February 16th, the | | 18 | question, yes. | 18 | day after the filing, made these two | | 19 | Q. Sorry. What do you mean? | 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 off hand 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 | Q. Understood. Thank you. So the | | | 5 MS. ARONSSON: No. | 5 | total expenses \$161,323 here, if we | | | 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 | A. The amount of the payments that | | 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 | | | that we looked at on Exhibit Number 7? | | | marked as Jalbert Exhibit 8 for | 16 | | | | 17 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 | Q. Is anything else included in | | 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 | document filed in this case as Docket | 24 | final total dollars were, there was a | | 25 | 120 and document 120-1. Page 131 | 25 | payment made February 10 pre-petition that Page 133 |

34 (Pages 130 - 133)

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

35 (Pages 134 - 137)

Page 138 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. 17 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 Page 139 1 C. JALBERT 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 140 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. I think it is. 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 Page 141 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 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 85

36 (Pages 138 - 141)

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

37 (Pages 142 - 145)

| | 85 | | | |----------|-----------------------------------------------|----------|---------------------------------------------------------------------------------| | 1 | C. JALBERT | 1 | C. JALBERT | | 2 | A. Yes. | 2 | THE WITNESS: Okay. | | 3 | Q. I do want to talk about the | 3 | Q. Turning to Page 2, Melissa | | 4 | insurance changed to zero percent from 30 | 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 | Q. Yes. Before I show you the | 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 | A. I recall talking with my | 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 | Q. What do you remember about that | 16 | entries as his monthly expenses and she's | | 17 | interaction? | 17 | asking what type of insurance. | | 18 | A. Well, I think he found out the | 18 | Q. What is your view, if any, on | | 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 | Q. You would like to answer the | | 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 | Q. Substantively, what is your | | 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 | | 17 | matter with the Bates Kwok 00001691. | 17 | Connecticut house so these expenses that | | 18 | Q. I understand you're not on this | 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 25 | MR. HARBACH: Give him a minute to read it. | 24 25 | expenses ascribed to him in the monthly operating report in that Question 8. |

38 (Pages 146 - 149)

| | 85 | | | |----------|-------------------------------------------------------|----------|---------------------------------------------------------------------------------| | 1 | C. JALBERT | 1 | C. JALBERT | | 2 | Q. Mr. Flynn continues, "I have a | 2 | A. I don't know. | | 3 | question regarding the insurance as well | 3 | Q. The original allocation to this | | 4 | since this is insurance on the apartment of | 4 | line item I think is -- | | 5 | the Sherry". Do you understand what issue | 5 | MR. HARBACH: Right here | | 6 | hes referring to here? | 6 | (indicating). | | 7 | A. Yes. | 7 | Q. -- at 13 thousand and that's | | 8 | Q. Can you explain it for me? | 8 | reflected on Page 2. \$13,611. Besides Ms. | | 9 | A. Well, in the Number 8 -- no, | 9 | Francis' e-mail, do you have any | | 10 | Number 9, the original version of this had | 10 | independent knowledge of that information? | | 11 | insurance. We didn't know what it was | 11 | MR. AULET: Objection to form. | | 12 | insurance on. Frankly, when we got it, we | 12 | A. No. It came from Melissa | | 13 | assumed it was on the Greenwich residence | 13 | Francis. I don't know where she got that | | 14 | where the debtor and his spouse actually | 14 | number from or why. | | 15 | reside. We factually found out that it's | 15 | Q. Did you look into insurance for | | 16 | actually insurance on the Sherry and when | 16 | the Greenwich property? | | 17 | we found out it's insurance on the Sherry, | 17 | A. No. | | 18 | since the debtor doesn't live there and | 18 | Q. Why not? | | 19 | doesn't own it, by review of materials from | 19 | A. We asked for someone in the -- | | 20 | the lawyers, it should be eliminated and | 20 | with the correct knowledge to give us all | | 21 | that's what we proposed, to eliminate it. | 21 | of the expenses paid cash, check, wire | | 22 | Q. It was ultimately eliminated? | 22 | transfer, HCH, any other method, February | | 23 | A. Yes. | 23 | 15th to February 28th on behalf of the | | 24 | Q. Mr. Flynn continues "I am not" | 24 | debtor. We didn't leave any -- we didn't | | 25 | I am not sure it should be included here? | 25 | ask for -- we didn't leave any | | | | | | | | Page 150 | | Page 152 | | 1 | C. JALBERT | 1 | C. JALBERT | | 2 | I think that's what he means -- "in this | 2 | restrictions. We just said give us all of | | 3 | calculation but interested on your thoughts | 3 | that information. We got a summary chart. | | 4 | and also asking Craig". Do you recall him | 4 | You saw it and it wasn't till we started | | 5 | asking your opinion on this? | 5 | asking questions to understand some of the | | 6 | A. Yes. | 6 | background and what is behind the numbers | | 7 | Q. Is your opinion the same as | 7 | that we started making assessments and | | 8 | Mr. Flynn's here -- | 8 | changing what we think the legal group and | | 9 | A. Yes. | 9 | us thought it was appropriate. | | 10 | Q. Do you recall speaking with | 10 | CONTINUED EXAMINATION | | 11 | Mr. Flynn about that? | 11 | BY MR. HARBACH: | | 12 | A. I do. | 12 | Q. You said a moment ago that | | 13 | Q. Turning to the top e-mail here | 13 | originally, you and your team thought that | | 14 | on this chain, on Page 1, Mr. Flynn asks, | 14 | the 13 -- excuse me, I think you said you | | 15 | "how much was paid during this period for | 15 | assumed that the \$13,611 was for the | | 16 | the Sherry". Do you see that? | 16 | Greenwich property because that's where he | | 17 | A. Yes. | 17 | was living. I got that right? | | 18 | Q. Do you know the answer to that | 18 | A. Yes, sir. | | 19 20 | question? A. I have no idea. Also, I don't | 19 20 | Q. Then you were told that the 13,611 was actually for the Sherry, right? | | 21 | know why he asked it. | 21 | A. Correct. | | 22 | Q. That was going to be my | 22 | Q. And at that point, you did not | | 23 | question. Why would it matter whether -- | 23 | inquire about was there actually any | | 24 | how much it was as to whether it should be | 24 | insurance money paid for the Greenwich | | 25 | included in the monthly operating report? Page 151 | 25 | property during this period, you didn't ask Page 153 |

39 (Pages 150 - 153)

| 1 | C. JALBERT | 1 | C. JALBERT | |----------|-------------------------------------------------------|----|-------------------------------------------------------| | 2 | that question? | 2 | with the Brown Rudnick firm and Melissa | | 3 | A. No, we assumed -- actually, | 3 | Francis and Aaron Mitchell to determine | | 4 | Matt had confirmed this is a list of all | 4 | what the accrual of professional fees. All | | 5 | the payments made during this time frame. | 5 | professionals, state professionals, | | 6 | So we had the universe that wasn't another | 6 | committee professionals, debtor | | 7 | insurance payment and you know, most -- | 7 | professionals, ordinary course -- alleged | | 8 | many of us have owned homes. My own | 8 | ordinary course professionals, everybody | | 9 | empirical knowledge is you typically pay | 9 | because we need to record the accrual. So | | | | | | | 10 | your homeowner's insurance once a year. | 10 | it's not just -- the operating report is | | 11 | It's usually -- in the Sherry, this 13 | 11 | not just asking for what was paid during | | 12 | thousand dollars might have been just a | 12 | that period. It's asking for what's the -- | | 13 | payment for the year on a 2.5 million | 13 | the new form is asking what are the unpaid | | 14 | dollar entity. They didn't tell us it was | 14 | amounts and we couldn't get it in time to | | 15 | a payment so I didn't ask. | 15 | get the February one. So we're going to | | 16 | CONTINUED EXAMINATION | 16 | catch up in this March one, we're going to | | 17 | BY MS. ARONSSON: | 17 | establish what the February accrual was and | | 18 | Q. So I think we've covered the | 18 | we're going to find out what the March | | 19 | work that you have done in connection with | 19 | accrual was and then we'll have the correct | | 20 | the monthly operating report for the period | 20 | information and it will have to be | | 21 | February 15th to February 28th. We've been | 21 | maintained as we go along and obviously, as | | 22 | looking at that document. Is that right? | 22 | time goes on, if things go according to the | | 23 | A. Yes. | 23 | way the debtor would like, there will be | | 24 | Q. Can you think of anything else | 24 | payment on those fees. So there'll be more | | 25 | that we haven't talked about with the work | 25 | accruals and then payments and the same | | | Page 154 | | Page 156 | | 1 | C. JALBERT | 1 | C. JALBERT | | 2 | that you've done, in connection with | 2 | thing is true of the estate professionals | | 3 | preparing that document? | 3 | and the committee and its professionals. | | 4 | A. Off the top of my head, no. | 4 | It will be a roll forward of what the | | 5 | Q. I think you referenced you're | 5 | liability is and the cash will be reported | | 6 | preparing the next reporting cycle? | 6 | on Page 1. It will create liability to the | | 7 | A. Yes. | 7 | United States Trustee for their fee -- | | 8 | Q. Can you describe your general | 8 | their -- their -- it's a fee. It's not a | | 9 | process and how that defers, if it does, | 9 | commission. Their fee for -- which is | | 10 | with your reporting cycle for the February | 10 | entirely predicated on cash disbursements | | 11 | 15th to February 28th period? | 11 | during the time of the monthly operating | | 12 | A. So the monthly operating report | 12 | report. | | 13 | is basically presenting information and the | 13 | Q. Do you anticipate -- strike | | 14 | two buckets of information that are in the | 14 | that. Besides information that you'll | | 15 | monthly operating report as for this debtor | 15 | receive from Brown Rudnick, from Aaron | | 16 | is that Question E, the funds disbursed on | 16 | Mitchell, from Melissa Francis and an | | 17 | his behalf in the 31 day period, March 1 to | 17 | unknown person, do you anticipate doing any | | | March 31, we're going to -- we're going to | | | | 18 | | 18 | investigation in connection with future | | 19 20 | | | | | | figure out -- we're going to get a list. | 19 | monthly operating reports? | | | This time, we're going to get a list so we | 20 | MR. AULET: Objection to form. | | 21 | can see what there was and we can have -- | 21 | A. I don't know what you | | 22 | we can have more educated discussion with | 22 | consider -- I'm not going to -- we're going | | 23 | the lawyers about what was paid. That will | 23 | to get a report from someone. That report | | 24 | be summarized and categorized and put in | 24 | is going to list out all of the payments | | 25 | Schedule E and in addition, we're working Page 155 | 25 | made during a specific time period. We're Page 157 |

40 (Pages 154 - 157)

| | 85 | | | |----------------------------------|-----------------------------------------------------------------------------------------|----------|-----------------------------------------------------------------------------------------| | 1 | C. JALBERT | 1 | C. JALBERT | | 2 | going to review that with our own | 2 | they paid post-petition pre-petition. Here | | 3 | professional knowledge and with the lawyers | 3 | they paid pre-petition, pre-petition but | | 4 | to make sure it all makes sense. We might | 4 | should have been excluded from the monthly | | 5 | ask questions based on what shows up on the | 5 | operating report. Legitimate charge. It | | 6 | spreadsheet but I'm not going to ask for a | 6 | wasn't an overpayment or anything. It just | | 7 | copy of the cancelled check, a bank | 7 | didn't belong reported in the February | | 8 | statement or the invoice that was paid. So | 8 | monthly operating report. | | 9 | no investigation of that, just a sanity | 9 | Q. So is it fair to say you later | | 10 | check or a reasonableness check and confer | 10 | received a more detailed breakdown of these | | 11 | with counsel to be sure that we understand | 11 | items that was included in this -- | | 12 | what's on that sheet and what we're going | 12 | A. I believe we got a more | | 13 | to report. | 13 | detailed -- but it was -- it was | | 14 | Q. So essentially, you'll rely on | 14 | significantly past that time. Everything | | 15 | the rolled up numbers that are provided to | 15 | at that time was done by reviewing, | | 16 | you from the individuals we've talked | 16 | talking, Melissa and Aaron talking with | | 17 | about? | 17 | whoever and Matt talking to whoever. It | | 18 | A. Again, except for some queries | 18 | was all done by e-mail and orally. We | | 19 | that we'll make depending on what the | 19 | didn't get a spreadsheet of the detail | | 20 | information we get. If we get -- if | 20 | until sometime later, long after it was | | 21 | insurance shows up again, we're going to | 21 | filed and actually, after the time that we | | 22 | ask insurance on what. If repairs and | 22 | made available our records that we got -- | | 23 | maintenance shows up again, we're going to | 23 | the detail listing which is when we figured | | 24 | confirm it's not the maid. So we'll use | 24 | out oh we got a problem with the monthly | | 25 | some common sense and we'll confer with the | 25 | operating report. It's just a matter of, | | | | | | | | Page 158 | | Page 160 | | 1 | C. JALBERT | 1 | C. JALBERT | | 2 | lawyers based on what we see but I won't | 2 | you know, whoever is preparing these things | | 3 | know what we're going to do until we see | 3 | isn't used to the rules, isn't used to | | 4 | what -- and I hope it's soon. What's | 4 | what's got to be displayed -- disclosed and | | 5 | today, April 8th? | 5 | what's not going to be disclosed. We try | | 6 | Q. Thank you. Okay, just quickly | 6 | and give them guidance and they just made a | | 7 | turning back to Exhibit 8 which is I think | 7 | minor error. We'll fix it next month. | | 8 | the final living expense report for the | 8 | Q. Thank you. You can set that | | 9 | period February 15th, 2022 to February | 9 | aside. Do you recall receiving an inquiry | | | 28th, 2022. I think you had referenced an | 10 | from someone at U.S. DOJ regarding the | | 10 11 | erroneous amount included in here. Can you | 11 | monthly operating report? | | | just explain again what you meant by that? | 12 | A. I think I actually reached out | | | A. I don't remember exactly what | 13 | to them first and my reaching out to them | | | the number is but on the security line, | 14 | first was -- and that's how -- was -- I | | | Line Number 9, the amount referenced her 43 | 15 | don't know if anyone's ever prepared a | | | thousand dollars. That 43 thousand dollars | 16 | monthly operating report, is there one | | 12 13 14 15 16 17 | included a payment of -- my memory is | 17 | here? So the monthly operating report, up | | | something like 12 or 14 thousand dollars | 18 | until December 31 or January 31 was one, | | | that was paid February 10 and so we got | 19 | two -- these two pages (indicating), Page 8 | | | this report, the original one, and didn't | 20 | which is now Page 8 and Page 9 and there | | | know the back -- the background and when | 21 | might have been one more -- I thought it | | 18 19 20 21 22 | they -- when they showed us the background | 22 | was five pages. It might have been four. | | 23 | and the list of -- we saw February 10. So | 23 | And I filed these monthly operating reports | | 24 25 | we realized we had the opposite mistake of the time with the two professionals where | 24 25 | in several cases and it had been driving me crazy for three months that I would -- I |

41 (Pages 158 - 161)

| | 85 | | | |----------|-------------------------------------------------------|----------|---------------------------------------------------| | 1 | C. JALBERT | 1 | C. JALBERT | | 2 | would -- the way the monthly operating | 2 | have done anyway's. | | 3 | reports, the bottom, for the first page, it | 3 | Q. We've talked about your | | 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 22 | looked at? A. No. We wanted to do that | 21 22 | A. Advisor. Q. Advisor, for how long? | | 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 |

42 (Pages 162 - 165)

| 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 | Q. Do you typically call on that | 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 of bankruptcy. | | 8 | A. Certainly some of it, yes. | 8 | The schedules, the SOFA's, the -- the | | 9 | Q. What aspects of the debtor's | 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 -- | | 17 | 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 | Q. Do you view it as in need of | 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 | Q. You don't? | 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 | debt. Maybe work with payables, all | 24 | 11 case here. | | 25 | sorts of -- that isn't the case here Page 167 | 25 | Q. What you just described were Page 169 |

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 SOFA's and | 5 | pre-petition payments, which we ordinarily | | 6 | preparing the MOR'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 | Q. All right, I won't argue with | 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 | | 10 | that you -- you view that is in need of | 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 | Q. Do you know where the debtor's | | 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 | Q. Do you know if the debtor had a | | 20 | Q. So how would they be | 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 | Q. Who was the accountant? | | 24 25 | wrong guy but if there's ongoing litigation, I suspect there's going to be | 24 25 | A. Accountant? Q. Yeah, I asked you -- | | | Page 170 | | Page 172 | | | | | | | | | | | | 1 | C. JALBERT | 1 | C. JALBERT | | 2 | -- you would hope there would be settlement | 2 | A. Oh actually, I take that back. | | 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 | 5 | tax return they prepare. So there was -- | | 6 | into cash with which to pay the creditors. | 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 | Q. Okay, what was the name of the | | 9 | Q. As part of your -- the scope of | 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 16 | Q. Provide assistance with reviewing debtor books and records for | 15 16 | in an e-mail. So they would have been produced as it relates to this I think. I | | 17 | possibly avoidable transactions such as | 17 | 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 | York or a Connecticut accountant. I don't | | 20 | the debtor's books and records, correct? | 20 | know who. | | 21 | A. Currently, so far, yes. | 21 | Q. You just don't -- you obviously | | 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 if I looked at it. I don't know Page 173 |

44 (Pages 170 - 173)

Case 22-50073 Doc 440-24 Filed 05/25/22 Entered 05/26/22 15:30:37 Page 46 of

| | 85 | | | | |----------|-----------------------------------------------------------------------------------------|----------|-----------------------------------------------------------------|--| | 1 | C. JALBERT | 1 | C. JALBERT | | | 2 | if, at the time when we were trying to do | 2 | I don't know. | | | 3 | everything, we were using those because we | 3 | Q. What information, if any, did | | | 4 | needed some of the information on there. | 4 | you rely on in getting comfortable taking | | | 5 | We were referred to them by Melissa for | 5 | this case without a post-petition retainer? | | | 6 | certain issues that the lawyers thought | 6 | A. I've been doing this for 35 | | | 7 | were important and we went and took a look | 7 | years. I'm not sure. I don't remember | | | 8 | at them but I would have looked at | 8 | ever getting a post-petition retainer but | | | 9 | something besides the name of the preparer. | 9 | my firm works with -- | | | 10 | At the time, it didn't matter. | 10 | (Whereupon, a cellphone rang.) | | | 11 | Q. Have you ever spoken to the | 11 | THE WITNESS: Shit, I'm sorry. | | | 12 | debtor? | 12 | Now it's off. We -- we're a | | | 13 | A. Yes. | 13 | practitioner in Massachusetts and we | | | 14 | Q. When? | 14 | do cases in Delaware, New York, | | | 15 | A. Wednesday at the 341 hearing to | 15 | Connecticut, Rhode Island, | | | 16 | introduce myself. | 16 | Massachusetts, New Hampshire, | | | 17 | Q. Is that the only occasion, to | 17 | Vermont, Maine. We represent Chapter | | | 18 | your knowledge, that you've spoken to the | 18 | 7 trustees in virtually all of those | | | 19 | debtor? | 19 | states. We probably represent and do | | | 20 | A. I don't speak Mandarin and he | 20 | work for virtually ever Chapter 7 | | | 21 | apparently doesn't speak English. So I | 21 | trustee in Rhode Island, every | | | 22 | have not spoken to him. Or Chinese. I'm | 22 | Chapter 7 trustee in Massachusetts, a | | | 23 | not sure which it is. Excuse me. | 23 | couple in Maine, a couple in New | | | 24 | Q. You did not receive a | 24 | Hampshire and it's not unheard of for | | | 25 | post-petition retainer, correct? | 25 | us to go and do 50, 60, 70, 80 | | | | | | | | | | Page 174 | | Page 176 | | | 1 | C. JALBERT | 1 | C. JALBERT | | | 2 | A. Correct. | 2 | thousand dollars of work before we | | | 3 | Q. Are you confident that your | 3 | even know the case will ever have any | | | 4 | fees will be paid? | 4 | money. It's an investment that we | | | 5 | A. I don't know if I'm confident. | 5 | make. Now I didn't make an | | | 6 | I'm hoping. | 6 | investment in this case. Whatever we | | | 7 | Q. What source do you believe your | 7 | incurred -- and I don't know what | | | 8 | fees will be paid, from what source? | 8 | that is, I'm hoping I'm going to | | | 9 | A. It will come from the Estate. | 9 | collect it but if I don't, then I'll | | | 10 | If we're going to be paid, as I understand | 10 | have a write-off like I've had many, | | | 11 | it, it will come from the Estate. I don't | 11 | many, many, many times in the past. | | | 12 | -- I have not thought of or have any | 12 | Q. Again, I don't think you | | | 13 | agreement on any other source of payment. | 13 | answered my question. | | | 14 | Q. Do you mean the litigation | 14 | A. Oh all right -- | | | 15 | claims or recoveries? | 15 | Q. If you -- if you relied just on | | | 16 | A. I would expect the only people | 16 | your experience in engagements in | | | 17 | that have a retainer in this case are Brown | 17 | bankruptcy cases and that's it for taking | | | 18 | Rudnick. Everybody else will be looking to | 18 | this case without a pre or post-petition | | | 19 | be paid -- that is a debtor's professional | 19 | retainer, is that what you mean -- | | | 20 | or a committee professional, professionals | 20 | A. I don't understand your | | | 21 | that file an application with the Court and | 21 | question. | | | 22 | the Court allows their retention will be | 22 | Q. What information, if any, did | | | 23 | looking to get funds. We're all going to | 23 | you rely on in taking this case without a | | | 24 25 | be looking from the same place. What that source is going to be, if it will ever be, | 24 25 | pre or post-petition retainer? MR. AULET: Objection to form. | |

45 (Pages 174 - 177)

| | 85 | | | |----------|----------------------------------------------------------------------------------|----------|-------------------------------------------------------------------------------------| | 1 | C. JALBERT | 1 | C. JALBERT | | 2 | A. I do work with lots and lots of | 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 | Q. Have you had any communications | | 5 | the case, I work on the case. | 5 | with any representative from Golden Hill? | | 6 | Q. So you relied on being asked to | 6 | MR. HARBACH: Golden Spring. | | 7 | get involved by Brown Rudnick? | 7 | Q. Golden Spring. | | 8 | A. Yep. | 8 | A. I was on e-mails with someone | | 9 | Q. That's it? | 9 | from -- well, first of all, Melissa Francis | | 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 | Q. You didn't look at the | 13 | contact -- | | 14 | financial profile of this debtor at all in | 14 | Q. She's counsel for the debtor or | | 15 | determining -- | 15 | Golden Spring? | | 16 | A. I think -- I think I knew he | 16 | A. Debtor. | | 17 | 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 | A. Correct. They were in all of | | 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 of me. | | 24 | we respond because if I don't respond, | 24 | Q. She's counsel for the debtor is | | 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 | A. I've been told emphatically by | | 3 | that you think a normal person should have | 3 | her and by Brown Rudnick that she is | | 4 | done to protect themselves on payment. | 4 | counsel to the debtor, as is Aaron | | 5 | Q. Did you rely on any degree on | 5 | Mitchell. As is Brown Rudnick. | | 6 | the financial profile of Golden Spring? | 6 | Q. Okay. Are they part of the | | 7 | A. No. | 7 | application to retain ordinary course | | 8 | Q. You didn't do any due diligence | 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 | | 17 | 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 | Q. -- before getting involved? | 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 25 | would be paid from Golden Hill or Lamp Capital before agreeing to take on the | 24 25 | speak to that person. I had -- I was on the e-mail exchanges and I wrote exactly |

46 (Pages 178 - 181)

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

47 (Pages 182 - 185)

| 1 | | 1 2 C E R T I F I C A T E | |----------|----------------------------------------------------------------------|--------------------------------------------------------------------------------------| | 3 | 2 D E C L A R A T I O N | 3 | | | 4 I hereby certify that having been | STATE OF NEW YORK ) | | 5 | first duly sworn to testify to the truth, I | 4 : SS.: COUNTY OF KINGS ) | | 6 7 | gave the above testimony. | 5 | | | 8 I FURTHER CERTIFY that the foregoing | 6 I, LENAYA LYNCH, a Notary Public for | | 9 | transcript is a true and correct transcript | 7 and within the State of New York, do hereby | | 10 | of the testimony given by me at the time | 8 certify: 9 That the witness whose examination is | | 11 | and place specified hereinbefore. | 10 hereinbefore set forth was duly sworn and | | 12 13 | | 11 that such examination is a true record of | | 14 | | 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 | CRAIG JALBERT | 15 action by blood or by marriage and that I | | 16 | | 16 am in no way interested in the outcome of | | 17 18 | Subscribed and sworn to before me | 17 this matter. | | 19 | this _____ day of ________________ 20___. | 18 IN WITNESS WHEREOF, I have hereunto | | 20 | | 19 set my hand this 8th day of April 2022. 20 | | 21 | | 21 <%24350,Signature%> | | | _________________________ | LENAYA LYNCH | | 22 | NOTARY PUBLIC | 22 | | 23 24 | | 23 24 | | 25 | | 25 | | | Page 186 | Page 188 | | 1 | | | | 2 | E X H I B I T S | | | | 3 JALBERT EXHIBITS 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 | | | 15 | 14 Exhibit 10 E-mail Chain 147 | | | | (Exhibits retained by Court Reporter.) | | | 16 | | | | 17 | I N D E X 18 EXAMINATION BY PAGE | | | | 19 MS. ARONSSON 5 | | | | MR. HARBACH 100 | | | | 20 MS. ARONSSON 103 MR. HARBACH 153 | | | | 21 MS. ARONSSON 154 | | | | MR. GOLDMAN 165 | | | 22 23 | | | | 24 | | | | 25 | | | | | Page 187 | |

[& - 373]

| & | 86:10,22,24 | 132:20 134:13 161 | 24350 188:21 | |----------------------------------|---------------------------------|----------------------|-----------------------| | દિદ 1:15,18 2:3,12 | 103:13 115:4,4,8 | 135:13,17 140:18 | 26 120:3,12 | | 0 | 119:21 124:25 | 162:21 | 183:23 28 | | | 164:4 166:7,18 | 161,323 132:23 | 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 | ી રિટે 187:21 | 140:14 152:23 | | 140:8 00001684 | 11:53 90:21 | 132:17 16th | 154:21 155:11 | | 00001691 147:17 | 2:18 34:22 12 | 17 119:19,21 | 159:10 | | 00001752 129:3 | 85:15 159:18 | 18 48:22 127:22 | 29 183:24 | | 02035 6:9 | 75:21 131:25 120 | 19 131:3 | 2:00 167:11 | | 06103 2:18 | 120-1 131:25 | 19,488 125:6,15 | 2:18 185:5,8 | | 2:14 06601 | 132:6 | 17:5 1979 | 3 | | 1 | 122b 125:3,14,19 | 1983 17:8 | | | 1 3:16 10:14,17 | 124 6:8 | 1987 17:10 | 3 23:23 35:8,12 | | 17:10 23:22 72:10 | 129 187:11 | 1999 165:24,24 | 96:25 97:4,8,13,24 | | 97:9 113:14.18 | 12:22 90:25 | 1:22 139:21 | 115:13 116:21 | | 114:14 118:3 | 19:8 42:12 13 | 1:28 140:4 | 144:12 187:7 | | 132:21 151:14 | 55:14 103:14 | 1:56 165:8 | 3,850 96:5 | | 155:17 157:6 | 126:5 146:19 | 1:58 165:12 | 30 7:5,19 11:2,22 | | 187:5 | 152:7 153:14 | 94:19,22 95:8 1 a | 107:6 144:4,6,14 | | | | 1 b 95:11 | 145:11 146:4,11 | | | 154:11 | | | | 133:25 147:10 10 | 13,611 152:8 | | 166:4 | | 147:15 159:19,23 | 153:15,20 | 2 | 30th 2:4 | | 187:5,14 | 131 187:12 | 2 23:22 32:14,18 | 17:10 72:10 31 | | 100 2:18 142:15,18 | 187:13 139 | 33:2,4 41:6 97:13 | 74:24 77:7 121:16 | | 143:8 187:19 | 14 19:8 98:7 146:7 | 105:21 142:14 | 155:17,18 161:18 | | 1:19 2:5,10 10036 | 159:18 | 148:3 152:8 187:6 | 161:18 | | 100th 44:7 | 147 187:14 | 154:13 2.5 | 32 187:6 | | 6:9 101 | 15 77:6 89:10 | 20 45:8 186:19 | 341 16:17,22 45:13 | | 103 187:20 | 97:25 145:4 | 79:18 2019 | 45:14,17 46:14,15 | | 106a 94:21 | | 2020 79:19 | 46:19,24 47:8,12 | | 106sum 93:14 | 183:22,24 187:20 153 | 2021 127:24 | 47:13,18 51:15 | | 94:2 187:9 | 154 187:21 | 1:10 3-5 2022 | 69:5 116:2 123:15 | | 109 132:22 135:18 | | 125:4 159:9,10 | 123:18 126:13 | | 140:17 | 15th 63:14 72:9 125:4 129:23 | 188:19 | 127:10,18 174:15 | | 109,827 133:7 | 133:11 134:3 | 45:8 49:9 84:9 21 | 342 16:16 | | 109,827.12 132:13 | | 92:21 107:14 | 17:13 176:6 35 | | 10:17 1:11 3:4 | 140:14 152:23 154:21 155:11 | 22 45:0 | 187:7 | | 10:24 11:15,19 | | 22-50073 1:6 3:22 | 36 95:13 96:2,4,8 | | 11 1:5 21:2,4 | 1 રેતેન્ત્વે | 22nd 3:4 | 96:16 | | 32:11 55:3 70:3 74:19 81:6,11 | 16 96:18 105:18 126:5 | 23 97:8 | 373 113:19 164:12 |

[4 - advisor]

| 4 | 95:17,19,24 61 | ਰਤੋ 187:9 | 172:24 173:9,19 | |------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------|--------------------|-------------------------------------| | 47:24 48:3 91:4 ব | 62 95:15,16,17 | 2 | 173:23 179:2 | | 96:9,12,17 97:13 | 39:10 6:49 | 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 | 1:18 2:4,9 81:6 7 | 26:10 31:4,7 32:9 | 63:21 168:17 | | 144:20 187:8 | 86:25 95:18 | 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 | | 43 159:15,16 | 133:16 135:14 | 104:12,16 105:3 | 156:4,9,17,19 | | 138:16 43,655.44. | 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 | accrued 78:23,25 | | | 6:19 7:16 169:2 70 | 139:8 143:14 | 79:6 | | ട് 93:12,15 108:8 | 176:25 | 156:3 157:15 | 10:6 accurate | | 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 | | 20 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 | | 141:14 142:7,8,9 142:12 144:13 | | 79:11 136:13 | 19:15 act | | 145:11 176:25 | 1:10 119:21 8 | 138:3 144:25 | 4:8 188:15 action | | 500 21:3 126:6 | 120:3 131:16,21 | 163:11 | activity 63:22 | | રે રેણવાડી તેમ જ દૂધની ડેરી જેવી સવલતો પ્રાપ્ય થયેલી છે. આ ગામનાં પ્રાથમિક શાળા, પંચાયતઘર, આંગણવાડી તેમ જ દૂધની ડેરી જેવી સવલતો પ્રાપ્ય થયેલી છે. આ ગામનાં પ્રાથમિક શાળા, પંચ 75:13,17 76:2 | 134:7 135:11,18 149:25 150:9 | absolutely 82:6 | 80:12 | | 75:5 505b | 159:7 161:19,20 | 167:3 180:3 | actual 109:17 | | 50th 44:6 | 181:22 187:12 | abundance 132:20 | 137:7 165:23 | | 140:17 51.495.67 | 7:16 176:25 80 | 142:21 | 173:3 | | 53 122:11 | 83 17:9 | accepted 102:23 | add 85:21 140:16 155:25 | | 94:22 95:23 રેરે | 2:13 850 | 115:23 access | addition additional 163:18 | | 56 95:17,19 | 87 17:10 | 119:6 124:16 | | | 95:24 96:2 રજ | 3:5 127:24 8th | accidently 125:13 | address 6:6,7,8 | | | 159:5 188:19 | account 37:25 | 169:4 180:10,19 addresses 162:20 | | 6 | | 38:24 52:15 63:19 | administer 4:6 | | 6 7:5 11:2,8,21,22 | 9 | 64:17 65:3 66:19 | administrative | | 97:24 98:7 111:4 | 9 119:21 139:24 | 72:6991:6,8 92:11 | 77:17 78:7,10 | | 111:8 117:5 | 140:7 146:20 | 92:16 147:2 | 81:8 | | 119:16,18,21 | 150:10 159:15 | 172:20 | advising 22:20 | | 181:22 187:10 | 161:20 181:22 | accountancy 17:8 | 53:261:11 | | 6:19 7:14 75:11 60 | 187:13 | accountant 18:16 | advisor 17:24 18:7 | | 75:19 176:25 | 48:10 82:17 90 | 70:22 80:6 168:4 | 21:5,6 34:7 36:23 | | 183:25 | 83:22 92:23 | 169:9,10 172:23 | |

# [advisor - aronsson]

| 37:7 39:8 40:20 | allocations 145:25 | 121:17 122:12 | applicable 107:11 | |-----------------------|-----------------------|---------------------|----------------------| | 41:20 43:2 48:9 | allow 12:20 38:23 | 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 | 118:2 apply | | affect 184:19 | amend 89:7 125:3 | 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 | | 4:13 affiliations | 55:21 112:6 | 55:6 59:25 61:19 | 113:8 114:7 153:9 | | afternoon 165:16 | amount 13:9 | 61:21 63:25 67:16 | approval 70:16 | | agent 90:2 91:7,20 | 81:22 96:5 118:12 | 76:4,24 79:21 | approved 62:10 | | 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 | | agreements 128:8 | analyzing 80:18 | 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 | | 97:15 aircraft | 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 | 93:10,1797:6 | | alleged 81:5 156:7 | 28:12 29:11,11,13 | apparently 28:19 | 99:22 103:5,6 | | 83:18 alleging | 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]

| arrange 163:15 | 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 | | 17:9 arthur | 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 | | 144:2,15 ascribe | 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 | 112:3171:12,15 | 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 | 66:20 associated | 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 | 107:9 association | 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 | ૪૨નત awhile | | 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 b | | 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 | | aspects 166:9 | attend 45:13 | 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 | | 153:7 assessments | 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 | | 88:2 94:2 assets | 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 | 1:3 bridgeport | |-------------------|-----------------------|---------------------|--------------------| | 159:21 162:10 | bearing 76:9,9 | big 34:4,15,16 | 2:14 3:21 | | 165:12 167:14 | 32:15 140:8 bears | 35:20 52:23 | brief 90:22 | | 173:2 181:15 | 42:18 beast | biggest 19:4 | 14:21 briefly | | background 17:2 | beautiful 164:20 | bill 45:19 72:12,23 | 65:24 128:5 | | 153:6 159:21,22 | 4:16 beginning | 73:6 | 163:24 bring | | 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 38:21 108:11 | 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 | | 91:18 bank's | 132:17 133:12 | 14:20 17:2 bit | brown 2:8 5:4 | | bankruptcies | 144:10 145:15 | 21:25 24:3 46:17 | 15:21 23:10,16 | | 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 | 131:13 blue | 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 | 102:23 belong | 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 | | 39:11 155:13 | 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 | 96:1 97:1 98:1 | 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 | camera 8:11 | 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 | 177:17 | | 2:2 3:1 4:1 5:1,21 C 6:17:18:19:1 | 129:1 130:1 131:1 | 179:14,15,25 | 36:14 37:10 cash | | | 132:1 133:1 134:1 | 116:3,17 117:9 car | 37:19 42:12,13 | | 10:1 11:1 12:1 13:1 14:1 15:1 | 135:1 136:1,7 | 67:679:4 care | 61:10 62:12,13,23 | | | 137:1 138:1 139:1 | career 47:12 | 63:15,15,22 69:9,9 | | 16:1 17:1 18:1 19:1 20:1 21:1 | 140:1 141:1 142:1 | 97:14 117:19 cars | 69:21 78:18 79:2 | | | 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 31:1 32:1 33:1 | 152:1 153:1 154:1 | 43:3,4 44:3,13,14 | 171:6 | | 34:1 35:1 36:1 | 155:1 156:1 157:1 | 48:10 49:15 50:22 | catch 88:25 89:2 | | 37:1 38:1 39:1 | 158:1 159:1 160:1 | 50:23 51:2,5,20 | 89:14,15 156:16 | | 40:1 41:1 42:1 | 161:1 162:1 163:1 | 52:10 54:17 55:8 | categories 7:21 | | 43:1 44:1 45:1 | 164:1 165:1 166:1 | 55:11,16 56:10 | 118:24 136:2,23 | | 46:1 47:1 48:1 | 167:1 168:1 169:1 | 59:7 60:9,14 | 137:25 | | 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 | | 61:1 62:1 63:1 | 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 | cats 89:12 | | 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 | | 73:174:1,9,10 | 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 | cc'd 26:12 27:10 | | 78:1 79:1 80:1 | 19:10 31:18 call | 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 - concurring]**

| 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 75:4 80:13,14 | 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 | 54:21 71:16 74:18 | 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 3:21 17:5 | 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 | 153:21 156:19 | 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 | 8:11 10:13 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 | | 66:11 68:15 73:19 | continue 3:13 74:8 | 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 | 9:12,21 13:6,15 | 89:8 103:9 119:17 | | 110:11 112:21 | | 25:21,24 30:3 | 154:18 | | | | | |

[cpe - description]

| 17:15,16 cpe | 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 1 રેરને તે | | 186:15 | 143:2 | 126:23 130:25 | 82:19 define | | 161:25 crazy | david 2:6 4:21 | 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 | 17:7 18:16 degree | | 133:22 | 45:14,16 46:24 | 145:18 147:2 | 45:13 179:5 | | 141:19,20 creator | 47:8 51:13,14,15 | 148:13 150:14,18 | degrees 18:19 | | 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 | 14:25 72:11 days | 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 | | curious 88:14 | 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 | | cycle 155:6,10 | 54:19,25 57:10,10 | 175:19 187:8 | 49:21 137:20 | | d | 57:12 58:16 62:15 | 20:18 42:4 debtors | 187:5 | | 81:14 109:22 て | 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 | deposits 42:9 | | 187:17 | 79:23,25 80:4 | 77:7 161:18 | describe 46:17 | | data 162:5,7 | 82:8 84:12,14 | decide 103:10 | 58:20 155:8 | | 1:10,16 10:18 date | 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 | 106:10,21 126:11 | 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 | 113:11 137:21 | 51:8 60:2 61:19 | | 160:19,23 | directly 104:15 | dismissed 70:12 | 61:21 78:17 88:17 | | 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 138:17 | | 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 | 61:2 essentially | |------------------------------|-----------------------|----------------------|----------------------| | 5:22 186:5 duly | 91:14 | 23:7 24:2,10,19 | 158:14 | | 188:10 | efficient 53:8 | 25:6 26:4,11 | establish 62:2 | | 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 | 104:22 110:17 | 51:25 52:2 55:15 | 70:24 73:17 74:3 | | e | 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 | 131:13 eliminate | 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 | 71:13 estimated | | 131:15 132:22 | emphatically | 42:3 entities | 106:12 | | 139:23 141:2 | 181:2 183:7 | 179:19 | estimates 73:11 | | 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 | 125:23 erroneous | 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 94:5 100:7 | 29:2,5 42:5,23 | 125:14 | everybody's 45:2 | | | 50:20 182:11 | 110:22 error | 69:8 | | easy 73:2 | employment 38:14 | 161:7 184:13 | everyone's 46:2 | | edits 135:15,16 140:23 | 89:7,8 | 136:4 errors | 147:3 162:15 | | | endeavor 124:10 | escrow 91:7,20,21 | evidence 87:11 | | educated 155:22 | ended 183:23 | 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 - file]

| 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 | expected 33:5,13 | 65:4 78:3 83:8 | 87:3,7,9 | | 165:14 185:9 | 123:20 | 113:6 137:12 | 87:16 feasible | | 187:18 188:9,11 | expense 136:18 | 143:17,18 146:23 | february 45:8 | | examined 5:24 | ી રેતેઃ 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 | 81:14 109:17,18 ﺎ | 133:11,12,25 | | exchanges 181:25 | 105:22 106:12,16 | 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 | 102:24 face | 154:21 155:10,11 | | excuse 11:10 | 108:15,20,23 | 115:25 182:21 fact | 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 | | fee 73:13 123:3 | | 35:8,12 41:6 43:6 | 148:7,16 149:17 | factually 150:15 42:25 53:16 fair | 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 | 175:4,8 | | 147:10,15 159:7 | 91:12 165:20 | fairly familiar 7:23 | felt 132:24 | | 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 | | figure 136:5 | | 187:13,14 | expired 69:15 | family 19:15 58:8 103:13 118:9 | 155:19 | | exhibits 187:3,15 | 36:24 explain | 129:8 132:16 | figured 160:23 | | existed 101:23 | 41:22 70:2 82:13 | | 162:16 | | 179:12 | 108:5 132:8 148:6 | 143:18 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 | | exists 172:7 | 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 | 13:7 30:18 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 | firm 4:3,5 21:24 | 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 | focusing 46:6 | forms 98:16 | | files 80:10 | 112:15 139:14,14 | 108:18 | forth 101:7 112:13 | | filing 32:24 61:11 | 156:2 172:13 | folks 15:15 25:6 | 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 | 186:8 foregoing | 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 | 102:19 forget | foxboro 6:9 | | 144:8 159:8 | 122:21 129:23 | 11:10 forgot | frame 34:25 | | 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 | fit 89:13 | 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 | 2:4 floor | 102:8 103:24 | 109:25 112:15 | | 64:22 111:17 | flow 61:10 62:13 | 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 |

## [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 | goes 7:18 43:19 | 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 | 5:6 6:20 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 | | fuel 163:24 | 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 | | 70:17 funds | 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 | gtv 120:20 | | 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 | 111:23 114:4 | 159:3 161:5 163:3 | 170:24 guy | | garbage 61:3,3,5,6 107:12 | 122:3,20 124:18 | 163:14 168:21 | h | | gas 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 | hearings 46:15 | 149:3 175:6 177:8 | 118:9 123:2,5 | | 110:9 111:3 | 21:13 | 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 | 9:25 impair | | 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 | 14:14 helpful | house 101:25 | 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 | hereinbefore | 102:5119:16,19 | inappropriate | | harassment 27:21 | 186:11 188:10 | housekeeping | 29:9,16 | | 28:5,6 | hereunto 188:18 | 144:20,23 | include 22:18 | | harbach 2:6 4:21 | 163:14,24 hev | huh 8:25 | 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 | 90:5 hired | 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 | 11:694:4 111:18 | 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 | 119:5 154:8 homes | 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 | 61:25 66:22 | | | | | | |

#### **[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 97:21 114:10 | 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 | 31:21 49:15,17,20 | | 43:4 70:4 74:3,4,6 | inputting 162:4 | interest 20:22 | 50:21 52:24 53:4 | | 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 3:11 10:5 | 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 - know] | |--|---------------| |--|---------------|

| 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 | | 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 | 188:4 kings | | 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 | 62:1 63:1 64:1 | 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 | 71:1 72:1 73:1 | 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 | | 89:16 96:21 items | 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 | joint 86:13 | 58:12 60:4,9,25 | | 102:5,22 103:22 | 94:1 95:1 96:1 | 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 | | J | 111:4,8 112:1 | 102:4 136:15 | 86:14 89:9,11,20 | | 2:10,15 5:21 6:5 I | 113:1 114:1 115:1 | 17:9 june | 89:25 90:4 103:25 | | jalbert 1:15 3:1,18 | 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 | | 7:1 8:1 9:1 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 | | 18:1 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 | 122:13 124:4 lago | 160:5 legitimate | 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 | 20:20 21:7 lenders | 64:22 87:6 90:4 | | 173:20,25 175:5 | 179:15,24 | lengthy 58:24 | 107:4 154:4 | | 176:2 177:3,7 | land 113:16 | letter 31:16,22 | 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 aura | 94:14 149:23 | 108:12 111:25 | | knowing 29:4 | 6:12 103:3,6 | રેતે રહ્યારે રહ્યા હતા. આ ગામના પાકની ખેતી કરવામાં આવે છે. આ ગામના લોકોનો મુખ્ય વ્યવસાય ખેતી ખેતી કરવામાં આવેલું એક ગામના લોકોનો મુખ્ય વ્યવસાય ખેતી ખેતી કરવામાં આવેલું એક levels | 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 | lawyer 43:18 46:8 | 164:10,12 | listened 123:15 | | 91:10 102:10 | 86:20 102:17 | liability 157:5,6 | 108:13 listing | | 121:15 122:7 | 113:25 138:20 | life 169:23 | 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 | 77:9881:25 82:5 | | 140:12 152:10,20 | 25:12,14,16 39:21 | 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 | | 32:16 35:9 94:4 | 158:3 159:2 | 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 | lives 118:15 | | 104:9 111:18 | 174:6 | 89:16,19 91:5 | 149:16,22 | | 119:24 122:16 | lead 51:5 | 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 | | - | 105:9 106:6 | 146:12 152:4 | llc 2:12 75:24 | | 5:21 6:5 23:16 - | 113:15 114:7,25 | 159:14,15 163:6 | 126:21 | | 186:2 | 153:8 | 163:19 | llp 1:18 2:3,4,8 | | lack 63:5 | legally 76:2 | lines 95:19 104:4 | 3:24 | | 119:7,10 lady | 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 | 21:21 22:24 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 | mail 26:9,13,13 | 167:13 184:10,16 | | lodge 101:17 | 37:3,24 38:21 | 30:19 32:17 34:3 | manager 50:8,13 | | long 15:5 137:18 | 39:4,17 43:7 48:8 | 35:11,19 37:18 | managers 50:16 | | 139:15 160:20 | 48:20 49:4,18 | 38:6 39:7,9 41:17 | 51:19 | | 165:22 | 50:2,15,20 56:19 | | 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 | | 163:21 173:22,25 | 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 main 2:13 25:2,3 | 128:24 129:11 | | losses 78:12 | 136:22 144:21 | 163:12 | 131:7,16,20 | | lot 42:10 47:11 | 149:11 163:17 | maine 176:17,23 | 139:24 140:7 | | 68:18 69:24 | lowey's 12:15,22 | maintain 17:25 | 147:10,15 | | 104:25 112:13,14 | 44:13 55:15 67:9 | 54:3 91:7 92:10 | markedly 41:20 | | 122:3 127:8 | 106:3 111:20 | maintained | marking 10:13 | | 168:23,24 178:18 | 112:8 134:21 | 156:21 | marriage 188:15 | | lots 99:13,14 | 135:16 140:23 | maintaining 63:19 | married 142:25 | | 106:21 113:10 | lp 4:20 | 64:16 91:5 | mary 13:8 31:24 | | 167:19 169:21 | lunch 123:4 | maintenance | 49:16 56:4,24 | | 178:2,2 | luxury 115:16,23 | 107:8 144:22 | 112:17 | | low 53:12 | 116:13 | 145:6 158:23 | massachusetts 6:9 | | | | | 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 | 152:22 method | 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 | 113:14 middle | 143:14 156:3 | | 50:21 51:6 53:12 | 59:10,17 99:2,7 | midnight 162:14 | 157:16 181:5 | | 67:13 76:5 81:25 | 102:11,18 103:17 | million 126:8 | 148:4 mk | | 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 | | mcdonald 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 50:9 | 72:15 month | | 144:15 | member 55:7 | 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 | minutiae 89:14 | 106:12,16 107:14 | | 144:3 151:2 | mentioned 14:15 | miscommunicati | 107:22,25 108:20 | | meant 22:763:12 | 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 32:2 81:9 | 123:7 124:6,11 | | 120:23,24 | 54:14 57:3,14 | 110:15 | 125:5,16 130:14 | | mediation 171:3 | 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 | | 16:15 45:22 meet | 165:18 | 56:22 | 147:8 148:7,16,24 | | 72:5 | | | 149:3,24 151:25 | | | | | |

# [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 | natural 107:12 | 78:7 nol s | 112:24 | | months 72:7 | 52:21 nature | 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 | | 170:6 mor's | 12:20 necessary | notary 1:19 5:23 | | | morning 3:3 6:10 | 63:21 75:25 80:18 | 186:22 188:6 | o'melveny 1:17 2:3 3:24 4:19,22 | | 14:20,22 | 85:18 93:2 100:23 | note 3:5 29:20 | 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 | 4:77:25 oath | | motion 14:9 28:25 | 36:14 37:11,20 | noted 29:18 | object 129:25 | | 38:15,20 89:7 | 40:12,15,23 42:10 | 14:6,7,7 notes | objected 30:20 | | 90:10,16 168:6 | 47:4 85:9 124:19 | 51:10,11 100:9,13 | objecting 80:19 | | motions 6:24 | 127:4 143:3 156:9 | 100:14,19 101:3 | 12:4,24 objection | | 181:12 | 163:14 166:20,23 | 111:7,14,24 | 24:20 26:16 27:15 | | 119:5 motor | 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 | 6:22,25 7:5 notice | 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 | 84:25 88:3,8 91:9 | | multiple 19:14 | 169:19 | noticing 4:17 | 92:2 93:5 95:9 | | 42:4 76:4 | 31:14 negotiated | 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 n | 115:2 | 150:9,10 152:14 | 132:11 133:18 | | 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 | 2:5,10,10,18 3:25 | 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 | 7:8 11:8,21 page | |----------------------|--------------------|--------------------------|---------------------| | 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 | | 9:18 objects | 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 | | obtain 12:19 | operating 41:21 | 86:9,21 105:5 | 113:13,14 115:12 | | obtained 59:17 | 41:24,25 42:11,20 | 54:25 ordered | 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 | | 174:17 occasion | 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 | 153:13 originally | 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 | | occur 68:3 | 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 | owed 81:18,19,20 | 153:24 155:23 | | offset 78:7 | 160:25 161:11,16 | 114:3 owned | 156:11 158:8 | | oh 45:10 160:24 | 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 | owns 115:5 116:5 | 183:8,14 | | 103:2 131:11 | 151:5,7 | p | 122:14 palm | | 148:2 149:14 | opportunity 2:4 | 2:2,2 23:16 | pans 101:23 | | 159:6 173:8 181:6 | 4:20 6:14 10:24 | p 69:20 p&l | paper 168:23 | | 169:3 old | 38:20 75:20 81:4 | 1:15 2:17 | papers 43:17,19 | | once 85:11 144:24 | 29:6 oppose | p.c. 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 51:11 69:9 | 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 | 66:11 91:25 93:3 | 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 | 133:11 140:13 | 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 | 15:18,21 26:15,17 | 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 - process]

| planned 54:19 | 120:17 | prepare 13:4 | previously 6:10 | |----------------------|--------------------|-----------------------|---------------------| | 86:14 88:7 plans | possibly 118:9 | 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 | prior 82:17 83:23 | | 3:5,9 4:15 please | posted 120:8,19 | 136:9 173:4 174:9 | priority 81:7 | | 5:10,19 6:3 8:19 | potential 24:10 | 8:12 preparing | 29:2 privacy | | 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 | 66:678:17 90:14 | 66:20,21 84:4 | privileged 41:3 | | plus 72:10 106:7,7 | 101:23 pots | 86:18 94:7,11 | probably 14:24 | | 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 | problem 80:3 | | 106:17 123:23 | 183:16 | presidential 19:19 | 146:25 160:24 | | 124:13 130:14 | precursor 17:11 | 54:22 presumably | 162:16 | | 153:22 166:3 | predicated 72:3 | 68:20 | procedure 11:3 | | 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 | 33:15 prefer | 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 | | 37:2 poses | 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 | | 31:635:25 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 - reasoning]

| 8:13 produce | 152:16 153:16,25 | q | r | |-----------------------|----------------------|---------------------|----------------------| | produced 128:25 | proponent 118:12 | 31:23 qpc | 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 | 167:8 176:10 rang | | product 46:22 | 139:3 150:21 | quarterly 68:7 | 15:13 range | | 83:15,17 | protect 75:9 89:16 | 71:19,21,25 72:18 | 29:5 rank | | profession 166:3 | 179:4 | | | | professional 17:14 | 29:14 protected | 158:18 queries | rarely 42:21 81:18 | | 17:17,25 18:8,12 | protection 83:18 | question 8:20 9:5 | rate 67:10,11 | | 33:11 37:22 77:17 | protective 29:15 | 9:7,11,19,20 27:4 | reached 23:17,24 | | 92:21 156:4 158:3 | 86:22 prove | 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 | | 14:8 professionals | 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 | 92:21 providers | 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 | | | | 120:3,12 121:16 | 113:18 115:15 | | profile 166:10,19 | public 1:20 5:23 | 122:11 124:13 | ready 137:21 | | 178:14 179:6,18 | 186:22 188:6 | 126:5 127:22 | real 42:20 77:20 | | program 69:12 | pulling 134:14 | 130:18,20 148:19 | 94:22 107:6 | | 70:11 | pullman 2:12 5:7 | 149:6,12,25 150:3 | 113:19,22 114:2,4 | | 71:9 progress | 165:17 | 151:19,23 154:2 | 147:6 167:20 | | 50:22 progresses | 99:11 punching | 155:16 163:10,12 | realized 159:24 | | projections 61:10 | punitive 164:9 | 163:12 166:14 | really 31:2 74:21 | | 61:24,24 86:18 | purchase 117:12 | 177:13,21 181:15 | 133:2 165:4 | | 87:10 | 118:19 | 184:10,12 | 10:8 76:15 reason | | prominent 60:18 | 117:13 purchased | questions 47:17 | 78:13 89:4 138:22 | | promised 179:23 | 39:23,25 purposes | 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 | 144:8,11 145:10 | | 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 | 90:21 91:2 93:18 | 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 133:14 | 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 | 49:21 56:9 61:10 | 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 | 20:21 21:10,12 | 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 | restructured | 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 | 143:11 187:15 | 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 | | 144:13 176:17,19 | 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 | 10:25 11:22 rule | 155:25 | 184:3 | | 126:19 130:11 | 11:2117:5 rules | scheduled 81:14 | 11:23 28:21 see | | 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 | 22:258:9 run | 51:10 55:20,25 | 82:11,25 88:11 | | 165:20 169:16 | 67:10.11 178:21 | 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 | 178:22 runs | 111:16 112:2,5 | 148:9 151:16 | | 113:20 road | 2:6 4:24,24 russo | 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 | 2:274:10 187:2 | schindler 13:8 | seeing 57:21 | | 53:18 94:6,10 | S | 31:25 49:16 50:9 | 127:19 | | 98:11 102:3 | safe 123:10 | 56:5,24 112:18 | 124:10,12 seek | | 105:25 106:3 | safety 138:24 | school 17:3.5 | 79:8,12 seen | | 112:9 134:21 | 144:10 182:11 | science 17:7 | 109:15 121:23 | | 168:11 169:17,20 | 42:7 sales | 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 | 162:4 save | 164:22 scotch | 164:13 | | 157:4 roll | 62:22 79:13 SAW 79:15 126:13 | scrambling 69:4 | select 75:20 | | rolled 158:15 | 128:4 153:4 | 71:11 scratch | 122:6 sell | | 4:11 127:12 room | | 99:16 106:2 | semantics 39:13 | | rudnick 2:8 5:4 | 159:23 162:19 163:13 173:3 | search 15:19,20 | 19:19 senators | | 15:21 23:10,16 | | 49:21 82-25 | 15:21 24:15 send | | 24:6,8,18 25:9 | saying 37:9 149:20 149:21 162:13 | second 45:16 61:7 | 162:7 | | 26:5,6,11 30:9 | | 114:16 121:6 | sense 38:2 158:4 | | 31:20 32:4 38:10 | 33:4 34:15 says 87:7 91:23 116:6 | 125:2 | 158:25 | | 38:12 39:2,16 | | secret 106:21 | sensitive 3:6 | | 43:23 49:24 56:13 | 116:7 162:7,15 | 120:14 secrets | sent 13:17 31:20 | | 57:4 58:25 59:7 | 184:9,10 scared 143:16,18 | section 75:597:17 | 49:24 | | 59:10,17 64:20 | 143:19 | 105:23 106:4 | 121:6 sentence | | 83:18 98:25 99:7 | scenarios 20:14 | 114:19 | 125:2 | | 102:12,18 103:18 | 59:22 schedule | 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 33:17 | september 17:10 | | 112:14 124:2 | 103:23 104:8 | 115:24 118:8,25 | 7:5 served | | 126:7 139:7 156:2 | 108:12 109:16,17 | 133:23 138:16,22 | 13:24 49:22 server | | 157:15 175:18 | 109:18 114:2 | 138:24 142:14,18 | | | | | | |

**[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 13:5,7 14:15 | | 21:21 85:21 90:4 | significant 13:9 | son 58:9,11,13 | 14:21 16:8 31:2 | | set 101:7 161:8 | 59:5 | soon 159:4 | 57:6 | | 188:10,19 | significantly | sorry 3:5 7:14 | spoken 14:24 | | setting 47:5 83:17 | 160:14 | 23:11 35:3 41:7 | 174:11,18,22 | | settlement 78:6 | silverberg 13:6 | 83:11 94:19 95:16 | 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 35:19 | 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 85:16 100:6,14 | 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 | 174:20,21 181:24 | 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 | somebody 183:7 | 165:25 | started 17:11 23:4 | | 66:18 | | | 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 37:21 54:6 | 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 1:2 3:19 | suggesting 142:12 | 173:25 174:23 | 104:4 138:19 | | 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 | t 5:21 6:5 186:2 | 80:8,10 168:9 | | step 13:19 46:2 | sun 59:14 | 187:2 188:2,2 | 169:9 173:3,5,6,11 | | 69:25 | supplement | tab 10:12 32:11 | 173:18 | | stepping 49:13 | 132:24 | 34:22 131:2 146:7 | taxation 19:9 22:2 | | steven 23:9,15,24 | support 19:6 22:4 | | taxes 42:7,7 53:5 | | 24:4 | 22:8 40:6 49:2 | table 49:9,10 50:4 taconic 113:20 | 73:24 74:17 77:20 | | street 2:13,18 6:8 | 51:24,24 55:21 | 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 | | technically 74:22 | 157:2 162:15 | 183:21 184:20 | 116:13 117:18 | | technology 169:6 | 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 | 184:2 thirds | 160:14,15,21 | | 7:17 15:11 ten | 24:13 28:25 30:16 | thought 37:12 | 162:6 165:7,11 | | 85:3,3,4 tense | 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 | | th 70:24 | 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 | three 19:272:7 | 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 |

**[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 14:11 21:9 | 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 | undisclosed 139:9 | | transaction 126:9 | 170:14 174:2 | u | 139:11,12 | | transactional | turbotax 60:23 | u.s. 72:6,12 73:13 | unheard 176:24 | | 80:12 | turn 3:9 11:8,21 | 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 | | | | | |

[uses - witness]

| 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 | 36:25 107:2 view | 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 | we've 16:3 20:16 | | V | 72:17 73:18 76:10 | 170:10 | 20:20 21:4,10,10 | | | 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 | | 88:12 v&l's | 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 | | 121:10 valuation | 94:6,10 95:3 | volunteered 184:8 | 132:3 134:10 | | 121:13 | 96:20 97:10.15 | | 154:18,21 158:16 | | value 67:15 | 98:5 99:5 100:8 | W | 162:16 163:20 | | 102:24 120:22 | 101:13 102:3 | wait 8:19 | 164:3 | | 121:7,19,22,25 | 106:2 107:23 | walk 55:16 94:13 | wealthy 19:13 | | 122:3,5 | 109:5,11 111:20 | walked 110:16 | website 162:8 | | vans 97:14 | 112:8,16,17,20 | walking 98:4 | wednesday 16:17 | | various 18:2 20:3 | 122:15 124:9 | 141:7 | 45:17 116:2,16 | | 42:2.5.6 51:16 | 125:22 128:10 | 1:5 2:9 3:18 wan | | | 54:22 57:9 58:24 | | 5:5 11:6 94:4 | 123:16,18 126:12 174:15 182:23 | | 59:6 69:22 75:11 | 134:21 135:15,19 136:22 140:23 | 111:18 | week 42:13 | | 118:24 120:8,13 | 144:21 149:11 | 16:25 40:21 want | | | 120:19 183:13 | | 40:22 44:17 45:18 | weekly 66:24 | | 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 | | 116:9,13 117:2,8 | veritext 4:3,5 | 146:3 147:19 | 122:23,24,25 | | 118:25 | vermont 176:17 | 149:8 168:18 | 123:5 174:7 | | verdolino 1:15 7:9 | version 79:16 | 172:3 | 17:4 western | | 10:25 12:14,22 | 127:13 133:15 | wanted 45:21 | whatsoever | | 13:24 15:16 17:12 | 137:17,24 140:12 | 105:10 110:14 | 123:22 | | 18:22,25 19:25 | 140:20,22 150:10 | 144:7 163:22 | whereof 188:18 | | 20:10,15 21:15,20 | versus 38:9 41:24 | wants 69:20 172:2 | whispering 3:7 | | 22:24 23:6,18,25 | 119:24 | 172:3 | 138:25 wife | | 24:17 25:7 26:3 | video 1:14 3:13,17 | washington 6:8 | 141:13 142:8,24 | | 30:11.13 31:15 | videographer 2:22 | water 34:24 | 145:14 | | 36:7,18 37:3,23 | 3:2 4:4 5:9,18 | watercraft 97:15 | willing 64:20 | | 38:21 39:4,17 | 8:10 11:14,18 | 119:5 | 67:18,20 wip | | 43:7 44:13 48:8 | 34:23 35:4 90:20 | watermark 162:6 | wire 152:21 | | 48:20 49:4,14,18 | 90:24 139:20 | way 47:21 54:19 | witness 5:11,20,22 | | 49:25 50:15,20 | 140:3 164:25 | 62:10 67:3 75:14 | 26:21 27:8 28:15 | | | | | |

[witness - zero]

| 29:10,11,16 35:3 | wrapping 91:3 | Z | |----------------------|-----------------------|---------------------| | 46:21 59:12 78:11 | 96:8 wraps | 67:14 79:20 zero | | 83:8 85:10 116:12 | write 36:13 41:18 | 82:21 94:24 | | 130:2 131:4,12 | 177:10 | 106:13,16,24 | | 148:2 164:20 | 34:4 39:6 writes | 107:19 108:20,23 | | 167:9 176:11 | writings 113:9 | 146:4,11 | | 185:9 188:9,12,18 | 8:12 65:18 written | | | word રતઃ રેતે રો | 119:8 121:2 | | | words 27:9 | 126:10 | | | work 17:8 19:9,11 | wrong 73:5 162:13 | | | 22:19 40:4 42:10 | 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 | y | | | 68:14 70:14 73:3 | | | | 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 | youtube 120:20 | | | 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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