Roffman Testimony

Case 1:90-mc-00919-JBS Document 45-12 Filed 10/21/91 Page 1 of 5 PageID: 1647
fJ
1
UNITED
STATES
DISTRICT
DISTRICT
OF
NEW
COURT
JERSEY
2
CIVIL
ACTION
MDL
IN
DONALD
NO.
864
RE:
J.
TRUMP
SECURITIES
LITIGATION,
ORAL
DEPOSITION
MARVIN
OF
ROFFMAN
8
*
9
WEDNESDAY,
SEPTEMBER
25,
1991
10
*
TRANSCRIPT
12
AT
13
THE
STREET,
OFFICES
OF
A.M.
IN
THE
SCHWARTZMAN
PHILADELPHIA,
10:00
ABOVE
&
MATTER
HEPPS,
PENNSYLVANIA,
2033
COMMENCING
14
15
S:
16
17
BERGER
BY:
18
MONTAGUE,
S.
ESQUIRES
COLLINS,
ESQUIRE
AND
CLAY
19
&
TODD
W.
HAMLIN,
III,
ATTORNEYS
FOR
THE
CERTIFIED
SHORTHAND
ESQUIRE
PLAINTIFFS
20
21
22
23
24
25
REPORTING
SERVICES
ARRANGED THROUGH
MASTROIANNI
104
HADDON
&
FORMAROLI,
WHITE HORSE
HEIGHTS,
( 609)
NEW
INC.
PIKE
JERSEY
546-1100
TAKEN
WALNUT
08035
AT

18
OCCASION TO,
AT ANY TIME,
LOOK AT THE PROSPECTUS
FOR
A.
YES.
Q.
I'M GOING TO ASK YOU TO TAKE A
DOCUMENT THAT'S BEEN PREVIOUSLY MARKED AS
THAT OFFERING?
LOOK AT A
WEBB-2.
(OFF-THE-RECORD DISCUSSION)
BY MR.
Q.
HAVE YOU SEEN THIS DOCUMENT BEFORE?
A.
YES.
10
Q.
AND THIS
11
A.
YES.
12
Q.
DID YOU
13
HERRING IN
14
NOVEMBER,
15
A.
YES.
16
Q.
IN NOVEMBER,
17
RECOMMENDATIONS
TO
ANYONE
18
WAS A GOOD IDEA
TO
BUY THESE BONDS?
19
A.
YES.
20
Q.
AND DID YOU MAKE THOSE RECOMMENDATIONS
21
NOVEMBER OF
22
A.
IN
23
Q.
AND TO
24
RECOMMENDATIONS?
25
A.
COLLINS:
IS,
IN FACT,
A PROSPECTUS?
LOOK AT THIS DOCUMENT OR
SOME
AT SOME POINT
IN
1988,
MAKE
A RED
OR PRIOR TO
1988?
19
DID YOU
AS TO
WHETHER OR NOT
'88 OR BEFORE NOVEMBER OF

--
IN NOVEMBER OF
ANY
IN
'88?
1988.
WHOM DID YOU MAKE THESE
TO THE SALES FORCE OF
JANNEY,
MONTGOMERY,
IT

19
SCOTT.
Q.
AND
IN
A.
THE
SPOKEN
Q.
WHAT
A.
AVOID
Q.
DID
AVOIDED?
A.
YES.
Q.
WHAT
DID
10
A.
THEY
WERE
WHAT
WERE
FORM
WERE
THOSE
WORD.
THOSE
RECOMMENDATIONS?
THEM.
YOU
EXPLAIN
YOU
WHY
THESE
BONDS
JUNK
12
A.
13
PROPERTY
TO
14
WIN
15
ANY
16
RESERVATIONS
17
Q.
WHAT
18
A.
WELL,
19
20
Q.
21
SERIOUS
RESERVATIONS,
22
BELIEVE
THAT
23
A.
THAT'S
24
Q.
DID
25
COVERED
SAID
CASINO
CASINO
WAS
THAT
BREAK
--
WIN
DO
YOU
EVEN,
WIN
THAT
IT
IN
WOULD
--
HAD
---------------
ORDER
HAVE
SUBSTANTIALLY
THAT
FOR
TO
IN
THIS
GENERATE
EXCESS
OF
SERIOUS
THAT.
MEAN
THIS
SERIOUS
PROPERTY
RESERVATIONS?
WAS
ABOUT TO OPEN,
ABOUT THE ECONOMY.
ANSWERS
BY
BE
BONDS.
FELT
EVER,
WHEN
YOU
ABOUT
WORRIED
TWO
SHOULD
SAY?
1-1---Q-.----WHAT-- ELSE-D-IO---YO-U-- SAY?-------I
RECOMMENDATIONS?
THE
AGO
WHEN
DID
YOU
YOU
CASINO WOULD
SAID
MEAN
YOU
HAD
THAT
YOU
BREAK
DIDN'T
EVEN?
CORRECT.
BELIEVE
CASH
FLOW,
THAT
BY
DEBT
SERVICE
INTERNALLY
WOULD
GENERATED
BE
CASH

41
A.
Q.
IN
A.
SAINT
Q.
DO YOU KNOW WHERE HE
A.
NO.
Q.
VAN
A.
DAN.
Q.
DAN,
A.
HE
10
Q.
DO YOU KNOW WHERE HE
THINK HE WAS
WHAT
WITH
LEE,
EXCUSE
WITH DREXEL
12
Q.
AND
13
1988?
14
A.
PAINE
15
Q.
DO
16
A.
WITH
17
18
Q.
IS
19
A.
TO MY KNOWLEDGE.
__ .
LEE ISKER,
SMALL
VOGEL
AT
HAVE
Q.
25
WEXLER?
--- ---
NOW?
--------- -
YOU KNOW
---
--
__
___
___
__
WHERE HE WAS
IS
IN
BOUTIQUE
THE
NOW?
IN
SAN
FRANCISCO,
WITH
MERRILL-LYNCH?
COLLINS:
I HAVE
NO FURTHER
MR.
JUST HAVE A FEW.
BRADY:
MR.
YOU EVER
BUT
NAME.
THIS TIME AND
(EXAMINATION OF
24
DO
STILL
MR.
22
23
IS
WEBBER.
REMEMBER
QUESTIONS
NOW?
BURNHAM.
YOU KNOW WHERE HE
20
IS
ME.
F_IRS T_ BOSTON.._
21
FLORIDA.
WHERE WAS HE?
lL ___ A
CAN'T
JAMES.
CITY?
PETERSBURG,
WAS
RAYMOND
THANK YOU.
ROFFMAN BY
MET
MR.
LAWYER
BRADY:)
NAMED
STEWART

ROFFMAN
A.
I'VE
Q.
DO
A.
NO.
Q.
DO
A.
DURING
Q.
COULD
THE
TALKED
42
BRADY
HIM.
YOU
RECALL
HOW
YOU
RECALL
WHEN?
MANY
TIMES?
1990.
YOU
TELL
ME
WHAT
YOU
REMEMBER
ABOUT
CONVERSATION?
( OBJECTION )
9
10
TO
READ
THE
MR.
COLLINS:
THE
WITNESS:
HE
TRUMP
TAJ
MAHAL
OBJECT.
GO
WANTED
PROSPECTUS
TO
TO
AHEAD.
HAVE
SEE
ME
IF
l L_ CQ_UL_D_ ITND__S QME__THINCL IR-THERE--T HAT-- MIG H-'I'-- BE---ABLE12
TO
13
BY MR.
14
Q.
DID
15
A.
NO.
16
Q.
DID
17
KIND OF
18
A.
19
Q.
DO
20
YOU
WERE
21
HIM
BECAUSE
22
TRUMP?
23
A.
NO.
24
Q.
NO
25
SAY
GET
THE
PEOPLE
WHO WROTE
IT
IN
TROUBLE.
BRADY:
YOU
AGREE
YOU
EVER
TO
THAT?
YOU
YOU
WITH
HAD
MR.
WITH
WEXLER
DONALD
ANY
TRUMP?
REMEMBER.
RECALL IF
BARRED
OF
YOU
THAT?
DISCUSS
CONVERSATIONS
DON'T
DO
FROM
YOU
EVER
EXPRESSING
AN AGREEMENT
DON'T RECALL
YOU
THAT
TOLD
MR.
WEXLER
ANY
OPINIONS
HAD
WITH
DONALD
YOU
DIDN'T
OR
NO
TO

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Case 1:90-mc-00919-JBS Document 45-12 Filed 10/21/91 Page 1 of 5 PageID: 1647

Case 1:90-mc-00919-JBS Document 45-12 Filed 10/21/91 Page 2 of 5 PageID: 1648

LOOK AT THE PROSPECTUS

I'M GOING TO ASK YOU TO TAKE A

DOCUMENT THAT'S BEEN PREVIOUSLY MARKED AS

HAVE YOU SEEN THIS DOCUMENT BEFORE?

WAS A GOOD IDEA

BUY THESE BONDS?

AND DID YOU MAKE THOSE RECOMMENDATIONS

LOOK AT THIS DOCUMENT OR

'88 OR BEFORE NOVEMBER OF

WHOM DID YOU MAKE THESE

TO THE SALES FORCE OF

Case 1:90-mc-00919-JBS Document 45-12 Filed 10/21/91 Page 3 of 5 PageID: 1649

ABOUT THE ECONOMY.

1-1---Q-.----WHAT-- ELSE-D-IO---YO-U-- SAY?-------I

Case 1:90-mc-00919-JBS Document 45-12 Filed 10/21/91 Page 4 of 5 PageID: 1650

DO YOU KNOW WHERE HE

DO YOU KNOW WHERE HE

JUST HAVE A FEW.

THIS TIME AND

YOU KNOW WHERE HE

WHERE WAS HE?

Case 1:90-mc-00919-JBS Document 45-12 Filed 10/21/91 Page 5 of 5 PageID: 1651

l L_ CQ_UL_D_ ITND__S QME__THINCL IR-THERE--T HAT-- MIG H-'I'-- BE---ABLE12

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l L_ CQ_UL_D_ ITNDS QMETHINCL IR-THERE--T HAT-- MIG H-'I'-- BE---ABLE12