Allen Stanford Criminal Trial Transcript Volume 3 Jan. 25, 2012

560
1
2
UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF TEXAS
HOUSTON DIVISION
3
4 UNITED STATES OF AMERICA
*
*
*
*
*
5 VS.
6 ROBERT ALLEN STANFORD
7
VOLUME 3
9
11
January 25, 2012

10:08 a.m.
JURY TRIAL
8
10
09-CR-342
Houston, Texas
BEFORE THE HONORABLE DAVID HITTNER

UNITED STATES DISTRICT JUDGE
12 APPEARANCES: APPEARANCES:
13 FOR THE GOVERNMENT:
Gregg J. Costa
14 Assistant US Attorney
PO Box 61129
15 Houston, Texas 77208-1129
16 William Stellmach
Andrew Howard Warren
17 U.S. Department of Justice
1400 New York Avenue NW
18 Washington, DC 20005
19
20 FOR THE DEFENDANT:
Ali R. Fazel
21 Robert Scardino
Scardino & Fazel
22 1004 Congress Street
3rd Floor
23 Houston, Texas 77002
24
25
Johnny C. Sanchez, RMR, CRR - jcscourtreporter@aol.com
561
1 A P P E A R A N C E S: (Continued)
2 FOR THE DEFENDANT: (Continued)
John M. Parras
3 Attorney at Law
1018 Preston
4 Floor 2
Houston, Texas 77002
5
6 Kenneth W. McGuire
McGuire Law Firm
7 PO Box 79535
8
9
10 Court Reporter:
Johnny C. Sanchez, RPR, RMR, CRR
11 515 Rusk, #8016
12 713.250.5581
13 Proceedings recorded by mechanical stenography. Transcript
produced by computer-assisted transcription.
14
15
16 Johnny C. Sanchez, RPR, RMR, CRR
515 Rusk, #8016
17 Houston, Texas 77002
713.250.5581
18
Proceedings recorded by mechanical stenography. Transcript
19 produced by computer-assisted transcription.
20
21
22
23
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25
562
I N D E X
1
2
3 WITNESS
4
PAGE
MICHELLE CHAMBLIESS
DIRECT EXAMINATION BY MR. STELLMACH ...........
569
CROSS-EXAMINATION..............................
694
REDIRECT EXAMINATION...........................
762
RECROSS EXAMINATION............................
768
REDIRECT EXAMINATION BY MR. STELLMACH..........
773
10
RECROSS EXAMINATION............................
773
11
12
13
LEONEL MEJIA
14
DIRECT EXAMINATION BY MR. COSTA................
778
15
CROSS-EXAMINATION BY MR. FAZEL.................
857
16
17
18
19
20
21
22
23
24
25
563
(The following was held out of the presence of the jury)
THE COURT: All right. We're ready to go, but
3 I understand the government has a matter you want to bring

4 up. Again, this is the clock. The clock is starting right
10:08:12
5 now. Go right ahead.

6
MR. COSTA: Yes, Your Honor.
THE COURT: What's the problem?
MR. COSTA: Last Wednesday we had the pretrial
9 conference. There was this issue with the 17,000 defense

10:08:20
10 exhibits. The parties reached an agreement, which was they

11 would -- we would provide them the names of our witnesses
12 for the coming week, and sufficiently in advance of trial,
13 they would give us the exhibits from their list that they
14 were going to use for those witnesses. We got a few from
10:08:38
15 one witness, we got a few more this morning for a witness

16 today.
17
Basically, to cut to the chase, the
18 agreement has not been followed. I've been told they're

19 not going to be able to do it. So, now, we have a
10:08:46
20 situation where we gave them -- they had the advantage of

21 getting all our exhibits pretrial. Now, because of this
22 agreement, we're giving them the names of our witnesses
23 ahead of time, and we're just getting nothing in return.
24 There's still not a sufficient exhibit list, and it's an
10:08:59
25 issue that needs to get resolved somehow.

564
THE COURT: What's your response?
MR. SCARDINO: Your Honor, we've substantially
3 required and complied with -4

10:09:09
THE COURT: I'm not talking substantially. Did
5 you completely, you know, comply?

6
MR. COSTA: We got exhibits for one of the five
7 or six witnesses we listed for this week.
10:09:20
THE COURT: That's it?
MR. COSTA: Yes. Half of them we got this
10 morning, a few we got over the weekend.

11
MR. PARRAS: I can reply, Judge, to what we've
12 been working to do.
10:09:29
13
THE COURT: Go on.
14
MR. PARRAS: As the Court knows, we've been
15 informing the Court and everyone about our preparedness for

16 trial. We have worked as hard as possible to be prepared
17 and to comply with the Court's orders. I did -- when I
18 realized we were going to be unable to get all of the
19 exhibits for all of the potential witnesses to the
10:09:46
20 prosecutors, I asked them to let us know which few were

21 coming up first so that we could make an effort to get
22 those done. They let us know that. I appreciate it
23 greatly. We made an effort. We failed.
24
10:10:03
We did, however, get them the first two or
25 three witnesses. I believe we've been supplementing as

565
1 quickly as possible.
2
THE COURT: How many witnesses in advance can
3 you get done, three in advance?

4
10:10:13
MR. PARRAS: If we have a chicken and egg
5 problem, Judge, we can't start working until we know who's

6 coming next.
7
THE COURT: Well, you got that, you got six
8 people coming.
9
10:10:21
MR. COSTA: Well, now I've got six for this
10 week, and yesterday we told them two for next week. So

11 they have -12
THE COURT: Eight.
13
MR. COSTA: Basically that's half the witnesses
14 that we're going to call in this trial.

10:10:27
15
MR. PARRAS: And here's the issue, Judge, they
16 gave us the first five witnesses they were going to call

17 but not their specific order. We thought it was the order,
18 one through five. So when we started on one, went to two,
19 went to three, and then we learned that it wasn't that
10:10:40
20 particular order, so we had to go back and restart again.

21
THE COURT: Do you have them in correct order
22 at this time?
23
MR. COSTA: I think -- they know the first
24 three.
10:10:48
25
MR. PARRAS: And we've been able to do those.

566
MR. COSTA: Again, we only have
2 documents for -- I guess the first witness they're not

3 going to use any documents. We have the documents for the
4 second witness. We just got some today. The whole idea
10:10:57
5 was this would allow us to check in advance for

6 authenticity and things like that in the spirit of the
7 Rules. That's the whole -- getting them the morning of
8 doesn't accomplish anything.
9
10:11:07
THE COURT: All right. This is what I'm going
10 to do, I'll take this up after the noon break. Talk to

11 each other. If you can't work it out, then if they don't
12 identify exhibits by a certain date that I'll set, then
13 we'll be able to offer them. It would be that simple. No
14 other exhibits aside from what they've designated by a
10:11:26
15 certain deadline. Work together. Give me those deadlines.

16 I'm not going to preclude anything at this time. But you
17 work it out.
18
If you can't work it out, I'll decide, and
19 then at that point, if any other exhibits come in at the

10:11:40
20 last minute from the 17,000 they've identified, then I

21 won't allow them in. I'll just exclude it. But I'll give
22 them plenty of notice. That's why I'm doing it this way.
23 Work it out yourself over the noon hour, and if you can,
24 announce an agreement, and then I'll rule on it.
10:11:58
25
MR. STELLMACH: Your Honor, there was -Johnny C. Sanchez, RMR, CRR - jcscourtreporter@aol.com
567
THE COURT: Mr. Stellmach.
MR. STELLMACH: Thank you, Your Honor. There
3 was one other issue related to our first witness. We have

4 a pending motion in limine regarding two topics, and it was
10:12:08
10:12:14
5 granted.
6
THE COURT: Motion in limine was granted?
MR. STELLMACH: That's correct, Your Honor.
THE COURT: Okay.
MR. STELLMACH: But I was wondering if prior to
10 her testifying if we could just resolve an issue. I

11 understand from Mr. Fazel he intends to inquire into those
12 topics on cross-examination.
10:12:23
13
THE COURT: Well, was it in a motion in limine?
14
MR. STELLMACH: It was, Your Honor.
15
THE COURT: So they want to get around it now?
16
MR. STELLMACH: Well, they want to get into it
17 on cross-examination, and I was wondering if we could know

18 prior to calling the witness whether they were going to be
19 allowed to do so.
10:12:31
20
THE COURT: All right. What is it?
21
MR. FAZEL: If it pleases the Court -- I'm
22 sorry. I was just making sure my phone wasn't on.

23
If it pleases the Court, what I told the
24 government is it's just like any other motion in limine,

10:12:40
25 depending on what she does on direct, and where I want to

568
1 go with cross, if I want to approach the Court and be able

2 to inquire into that matter, then I will.
3
THE COURT: Government's request is denied at
4 this time. That's basically the ground rules that I have.

10:12:54
5 Every motion in limine is in effect absolutely unless you

6 approach the bench at that time. So I'm going to stay
7 consistent.
10:13:04
MR. STELLMACH: Yes, Your Honor. Thank you.
THE COURT: All right. Let's call the jury in,
10 please.
11
One attorney from the defense. Strictly
12 housekeeping, over here. Just for a second.

13 (A discussion was held at the bench without the reporter)
14
10:15:13
15
(The following was held before the jury)
THE COURT: Thank you. Be seated. If there's
16 any rain coming, I'm glad we all got here before it

17 arrived.
18
We're ready to proceed with our first
19 witness. The government, please, call your first witness.

10:15:22
20
MR. STELLMACH: Your Honor, the United States
21 calls Michelle Chambliess.

22
THE COURT: Yes, ma'am. Raise your right hand
23 to be sworn, please.
24
10:15:39
CASE MANAGER: Do you solemnly swear that the
25 testimony you are about to give in the case now before the
569
Direct-Chambliess/By Mr. Stellmach
1 Court will be the truth, the whole truth and nothing but
2 the truth?
10:15:53
THE WITNESS: I do.
THE COURT: Have a seat there, please. Pull
5 that microphone in.

6
Okay. Go right ahead.
MR. STELLMACH: Thank you, Your Honor.
MICHELLE CHAMBLIESS,
9 after having been first cautioned and duly sworn, testified

10 as follows:
11
DIRECT EXAMINATION
12 BY MR. STELLMACH :
10:16:02
13 Q.
Good morning, Ms. Chambliess.
14 A.
Good morning.
15 Q.
Could you please introduce yourself to the jury?
16 A.
My name is Michelle Chambliess. I've lived in
17 Houston for about 32 years now, but I was originally born

18 in Fort Worth. I've lived in Texas all my life. I'm not
19 married. I have three children, three boys, 25, 23 and 21
10:16:21
20 years old.
21
The oldest works for a company that does
22 mortgage work in the Oklahoma City area -- excuse me. Can

23 I get a glass of water?
10:16:35
24
THE COURT: I have some water.
25
THE WITNESS: And my second and first sons -Johnny C. Sanchez, RMR, CRR - jcscourtreporter@aol.com
570
THE COURT: Yes, sir.
Hold it.
MR. FAZEL: I object to the narrative answer.
4 I'd ask that it be question and answer.

10:16:40
THE COURT: Sustained.
6 BY MR. STELLMACH:
7 Q.
Ms. Chambliess, while we're getting your water, can
8 you tell us what you do for a living?

9 A.
10:16:51
10 Q.
I work in a doctor's office, at the front desk.

And do you have any other experience in the
11 healthcare field?
12 A.
I do. I actually got started in healthcare March of
13 last year when my sweetheart of ten years was diagnosed

14 with pancreatic cancer. And I took care of him until he
10:17:10
15 passed way in May of this year. I went to work for a home

16 health agency, went to school at night for medical
17 assisting, and that's how I got this doctor's office job.
10:17:26
18 Q.
Have you always been in the healthcare field?
19 A.
No. My primary experience is in the financial
20 services area for more than 28 years.

21 Q.
And we'll get to that experience.
22
But could you first tell us about your
23 educational background?
10:17:36
24 A.
Yes. Excuse me one second.
25 Q.
Sure.
571
10:17:43
THE COURT: How many years, did you say?
THE WITNESS: About 28 years.
THE COURT: Thank you.
THE WITNESS: Yes, sir.
I went to the University of Texas at
6 Austin, and I got my bachelor's degree in Latin American

7 studies. I took a couple of years off and worked, and then
8 I went back to work on my master's in Spanish from '77 to
9 '79. I did not finish. I came to work in Houston in 1979.
10:17:58
10 BY MR. STELLMACH:
11 Q.
And when did you go to work in the financial services
12 industry?
10:18:08
13 A.
In 1981.
14 Q.
And what was that position?
15 A.
I started as an administrative assistant at Capital
16 Bank. I was there three years and was promoted to banking

17 officer while I was there.
18 Q.
And what was your job as the -- as a banking officer
19 at Capital Bank?
10:18:22
20 A.
I helped take care of international clients and bring
21 new clients into the bank.

22 Q.
And what did you do after leaving Capital Bank?
23 A.
I went to work at Park Tower, which is now Prosperity
24 Bank. I was there for three years. They had

10:18:39
25 international clients as well and needed someone

572
1 bilingual. I speak Spanish and English. And I also

2 helped out in lobby services.
10:18:53
3 Q.
What are lobby services?
4 A.
That's opening new accounts, taking credit card
5 applications, issuing debit cards, helping people cash

6 their checks, that sort of thing.
7 Q.
And so, what did you do after leaving Park Bank -- or
8 Park Tower, I should say?

9 A.
10:19:07
While I was at Park Tower, the woman who had been my
10 manager and mentor when I first started at Capital Bank

11 called me and said that -12
MR. FAZEL: Objection, Your Honor. She's about
13 to go into hearsay.
14
10:19:16
MR. STELLMACH: It's just being offered for
15 background, Your Honor, not for the truth.

16
THE COURT: Overruled.
17
THE WITNESS: -- called me and said that she
18 had been approached by someone who was starting a new bank

19 offshore and they were recruiting international bankers.
10:19:30
20 She was not interested in the position but thought that I

21 might be, and so, I told her yes, that was okay to give
22 that person my phone number.
10:19:40
24 Q.
Who was that person that you ultimately met with?
25 A.
Robert Allen Stanford.

573
1 Q.
And do you see Mr. Allen Stanford in the courtroom
2 today?
3 A.
Yes. He's standing up at the table there on the
4 right.
10:19:54
MR. STELLMACH: I just ask, Your Honor, that
6 the record reflect the witness has identified Mr. Stanford

7 who stood up.
8
THE COURT: Record will so reflect.
9 BY MR. STELLMACH:
10:20:00
10 Q.
So what year did you start actually working for
11 Mr. Stanford?
12 A.
In 1987.
13 Q.
And did you meet with Mr. Stanford before you
14 accepted the job?

10:20:12
15 A.
I did. I went through about a month of interviews.
16 I met with him. I had lunch with him and his father,
17 James Stanford, and I met with everyone else that was
18 working in the Houston office at that time.
19 Q.
10:20:27
When you say everyone else, how many other people did
20 you meet with before accepting the job?

21 A.
There were, I believe, seven people with Guardian
22 International Investment Services and two people with

23 Guardian Development at that time, and I met all of them.
24 Q.
10:20:41
25
And we'll come to those different companies.

But for now, just focussing on the lunch
574
1 with Mr. Stanford and his father, James Stanford, can you
2 tell us what was discussed in that meeting?
3 A.
4
10:20:52
He told me about -THE COURT: "He" meaning? There were two
5 people that -6
THE WITNESS: Allen Stanford.
THE COURT: Okay. Mr. Stanford, the defendant
8 in this case?
9
10:20:58
10
THE COURT: All right. Go right ahead.
11
THE WITNESS: Yes, sir. Thank you.
12
Told me about the company here in Houston
13 and about the offshore bank that he had opened in

14 Montserrat, that it was dedicated to dealing with
10:21:11
15 international clients like the clients that I was currently

16 managing, and how the two companies related to one another,
17 that the Houston office handled the marketing duties for
18 the bank and some of the customer surface, helping them
19 with their issues, traveling down, meeting clients, and
10:21:28
20 that they were specifically recruiting people with

21 international banking experience and who were bilingual.
10:21:39
23 Q.
So who actually offered you the job?
24 A.
Mr. Allen Stanford.
25 Q.
And what was the job title when you started?

575
1 A.
My title was vice-president when I started.
2 Q.
And in general terms, what were your
3 responsibilities?
4 A.
10:21:54
I was to try and move my clients from the bank where
5 I had been working over to Guardian International Bank and

6 also to interface with people who expressed an interest in
7 becoming new clients of the bank.
8
MR. STELLMACH: And at this point, Your Honor,
9 I was going to use a demonstrative exhibit to discuss some

10:22:10
10 of these entities. If we could possibly have the screen

11 lowered.
12
13
Does that count against my time, Judge?

THE COURT: Sure does. Just keep talking.
14 We're all here mesmerized by the new screen. Go on.

10:22:38
15
MR. STELLMACH: If we could see the
16 demonstrative exhibit, Ms. Kroger.

18 Q.
While we're figuring out some of the technical
19 difficulties, Ms. Chambliess, if you could just clarify:

10:22:59
20 What was the name of the company you were working for?
21 A.
Guardian International Investment Services.
22 Q.
And what was that company's relationship to Guardian
23 International Bank?
24 A.
10:23:14
It was an affiliate company, and it handled the
25 marketing services for the bank.

576
1 Q.
So even though it handled marketing services and you
2 were involved in sales on behalf of the bank, you didn't

3 work for the bank? You weren't a bank employee?
10:23:25
4 A.
No, I was not.
5 Q.
And on the screen -- I don't know exactly what is
6 displayed over there, but the jury looks up on the other

7 monitor -- if you could tell us whether you recognize the
8 eagle or the symbol that's displayed, the logo on that
9 screen.
10:23:42
10 A.
Yes, I do.
11 Q.
How do you recognize it?
12 A.
That was the logo that was used on all of the
13 marketing and financial information published for all of

14 the Stanford family companies, and as employees, we had
10:23:55
15 lapel pins in that shape.

16 Q.
When you said you had lapel pins, did you have to
17 wear the lapel pins?

18 A.
Oh, absolutely, yeah. We were chastised if we were
19 ever caught without wearing it.

10:24:06
10:24:13
20 Q.
Who would chastise you?
21 A.
Mr. Allen Stanford.
22 Q.
Do you know who designed the logo?
23 A.
Mr. Stanford did. He chose that logo.
24 Q.
How do you know that?
25 A.
He told us. He showed it to us.

577
10:24:25
1 Q.
And so, you were working in Houston; is that correct?
2 A.
Yes, sir.
3 Q.
And the bank is based in Montserrat?
4 A.
Correct.
5 Q.
What did the office space in Houston, the office you
6 were working in, look like?

7 A.
We were on the 38th floor of the Milam Building. It
8 was set up as a regular office space, had green carpeting,

9 wooden furniture, computers, telephones, reception area
10:24:43
10 with a little Persian rug, artwork on the walls in the

11 offices that picked up the -- a British theme because
12 Montserrat was part of the British Commonwealth, and it
13 had particularly like the pictures with the fox and
14 hounds, the hunt, that sort of thing.
10:24:58
15
MR. FAZEL: Object to narrative.
16
18 Q.
Was there a vault or tellers or a counter like you
19 would see in a bank when you go into a bank on a street

10:25:10
20 corner?
21 A.
No. We were exclusively paperwork-type office,
22 phones and paperwork.

23 Q.
Who did you report to when you first started working
24 at Guardian International Investment Services?

10:25:18
25 A.
Allen Stanford.
578
1 Q.
You mentioned that James Stanford had also been
2 involved in the hiring process, his father?
10:25:28
3 A.
Yes.
4 Q.
What was his role when you first started working
5 there?
6 A.
He was the chairman of the board based out of Mexia,
7 Texas.
8 Q.
Who was actively involved in running the day-to-day
9 business then?
10:25:37
10 A.
Allen Stanford was based in Houston, and he -- he was
11 in charge of everything.
12 Q.
How frequently would you see James Stanford in the
13 office?
14 A.
10:25:51
Maybe on a quarterly basis or for quarterly meetings
15 or for special instances, if a special meeting was called.

16
MR. STELLMACH: And just so we're all oriented,
17 if I could see Government's Exhibit 1516.

18
MR. FAZEL: Excuse me. We hadn't ruled on that
19 yet.
10:26:09
20
MR. STELLMACH: I thought it was preadmitted.
21
THE COURT: Everything -- all the government's
22 exhibits were preadmitted.
10:26:16
23
MR. FAZEL: Yes, Your Honor.
24
THE COURT: And they're all admitted unless you
25 have an objection.
579
MR. FAZEL: I'd like to know which one he's
2 pulling up before I object.

3
MR. STELLMACH: It's 1516, as I think I
4 indicated. It's the map of Montserrat.

10:26:24
MR. FAZEL: If I could have the opportunity to
6 object to it, that's what I'm asking.

7
MR. STELLMACH: I offer 1516, Your Honor.
THE COURT: No. You don't have to offer it.
9 It's already in evidence. Okay? If you can, just say the

10:26:37
10 next exhibit we're going for offer is this number, and I'll
11 give you a chance to look it up.
12
MR. STELLMACH: Sure.
13
MR. FAZEL: Thank you, Your Honor. We have no
14 objection.
10:26:44
15
THE COURT: I don't need objections. In other
16 words, I don't need "no objections." If you have an

17 objection, I need to know it.
10:26:51
18
MR. FAZEL: Yes, sir.
19
THE COURT: All right. Let's go.
21 Q.
And just so we're oriented, Ms. Chambliess, on the
22 map, the location of Montserrat?

23 A.
Uh-huh. It's shows it's almost that line with the
24 arrow pointing to Montserrat and Antigua.

10:27:08
25
THE COURT: So what are they? Just next to

580
1 each other basically?

2
THE WITNESS: Yes, sir. They're line of sight.
3 We had to fly into Antigua, and there we'd take a little

4 boat or a puddle jumper over to Montserrat.
10:27:19
THE COURT: And what about Barbuda? That's
6 around there somewhere. It's another island, is it?

7
THE WITNESS: It's a giant rock sticking up out
8 of the water, yes, sir.

9
10:27:28
THE COURT: Okay. Anybody living on it?
10
THE WITNESS: Not to my knowledge.
10:27:39
12 Q.
Who regulated the bank on Montserrat?
13 A.
The local banking commission.
14 Q.
Did Mr. Stanford ever explain to you why the bank was
15 based offshore in the Caribbean?

16 A.
Yes, he did. He said it was for a number of reasons:
17 They offer bank secrecy, which means privacy for the

18 clients who were there, that no one can just call up and
19 find out who has money with the bank because it was a tax
10:27:56
20 haven, meaning the bank -21
MR. FAZEL: Judge, I'm going to object to
22 narrative.
23
10:28:01
25 Q.
Well, what did Mr. Stanford tell you about any tax
581
1 reasons for the bank being located offshore?

2 A.
It's a tax haven so the banks and clients are not
3 taxed there on the island.

4 Q.
10:28:17
When you first started, was there any restriction on
5 who could become a customer of the bank?

6 A.
Yes. By nature of an offshore bank means they cannot
7 do business with local citizens or residents, and also

8 it's a policy of Mr. Stanford's that we were not doing
9 business with U.S. business or residents.
10:28:36
10 Q.
Did he explain why?
11 A.
That -- because that could involve the U.S. banking
12 regulatory agencies.
13 Q.
When you say "involve U.S. banking regulatory
14 agencies," what did you understand him to be saying?

10:28:47
15 A.
That it would allow them to go in and perform audit
16 functions or inspect papers of the bank.

17 Q.
Did that change later? Did there come a point later
18 when U.S. citizens and residents were able to become

19 customers of the bank?
10:29:02
10:29:12
20 A.
Yes.
21 Q.
But not when you first started?
22 A.
Not when I first started, no.
23 Q.
And in the beginning, who were your clients?
24 A.
They were for the most part people that I was already
25 doing banking with, mostly from Mexico, some from other

582
1 countries, diverse background, administrative assistants,

2 small business owners, professionals, lawyers, doctors.
3 Some people were well educated; some had graduated high
4 school.
10:29:31
5 Q.
Were there any risks associated with becoming a
6 depositor or customer of Guardian Bank?
10:29:44
7 A.
Yes.
8 Q.
Could you explain what those were?
9 A.
Because the bank was based outside of the country, it
10 did not have FDIC insurance, which is exclusive to banks

11 here in the U.S., so the guarantee....
12 Q.
I'm sorry, Ms. Chambliess. Before you go on, can you
13 just explain what FDIC insurance is?

14 A.
10:29:58
It's an agency that was established back during the
15 depression when there were so many runs on banks to insure

16 deposits to prevent people from losing faith in the banks.
17 It used to be a hundred thousand dollars and was raised to
18 $250,000. So that if a bank does go under, then this
19 agency would reimburse the depositor up to that amount of
10:30:20
20 funds.
21 Q.
But Guardian International Bank, as an offshore bank,
22 was not a member of the FDIC? It wasn't covered by the

23 FDIC?
10:30:30
24 A.
Right. That's only for U.S. banks in the U.S.
25 Q.
So what was the ultimate guarantee for a customer of

583
1 the bank that they could get their money back?

2 A.
The health of the bank, the financial health of the
3 bank itself.
10:30:41
4 Q.
Did you ever actually visit Montserrat?
5 A.
Yes, I did.
6 Q.
Why?
7 A.
So that we could see the facilities and meet the bank
8 employees and tell our customers about that.

9 Q.
10:30:53
And did the bank have actual offices down in
10 Montserrat?
11 A.
Yes, it did.
12
MR. STELLMACH: Your Honor, at this point, I'm
13 going to offer Government's Exhibits 520 and 521.
10:31:03
14
THE COURT: The photos?
15
MR. STELLMACH: The photos, Your Honor.
10:31:20
17 Q.
Who took these photos, Ms. Chambliess?
18 A.
I did.
19 Q.
And if you could just tell us what this exterior shot
20 is.
21 A.
That's the front of the office of the bank there in
22 Montserrat. It was on the second story of a building near

23 the beach.
24 Q.
10:31:33
And toward the right-hand side, could you just read
25 for us what's beneath the eagle logo?

584
1 A.
Uh-huh. It says "Guardian International Bank,
2 Limited."
10:31:47
3 Q.
And turning to the second picture, 521.
4 A.
That was the reception area of the bank offices, and
5 you can see in the back it says "Guardian International

6 Bank, Limited, and it has the eagle on the wall.
7 Q.
When you went down to visit the bank's offices, how
8 many people actually worked in the Montserrat office?

9 A.
10:32:01
I believe they had three employees at that time,
10 three or four.
11 Q.
And could you just explain what the division of
12 responsibilities was between the office in Montserrat that

13 we're just seeing and the office you worked at in Houston?
14 A.
10:32:14
The office in Montserrat handled the actual business
15 of the bank. They processed deposits/withdrawal requests,

16 issued documents for new accounts, certificates to people
17 to open new accounts, processed the applications to open
18 new accounts, did all of the filing there and issued the
19 bank statements to the clients.
10:32:34
20 Q.
When you first started at Guardian International
21 Investment Services, what financial products were you

22 offering to your clients?
23 A.
The main product we had at that time was the express
24 account that was the most popular.

10:32:49
25 Q.
Later on was there a certificate of deposit program?

585
1 A.
2
Yes, that was added later on.

THE COURT: What are you saying? An "express
3 account," what's that?

4
10:33:00
THE WITNESS: It's like a money market account,
5 here in the U.S. where it pays a rate of interest, but you

6 have a limited number of withdrawals.
7
THE COURT: Okay.
8 BY MR. STELLMACH:
9 Q.
10:33:12
How did the interest rate paid on this money market
10 account at Guardian compare with interest rates at the

11 time for money market accounts from U.S. banks?
12 A.
It averaged between 2 to 4 percent higher than what
13 the U.S. paid.

14 Q.
10:33:26
Did Mr. Stanford, Allen Stanford, ever explain how
15 that was possible?

16 A.
Yes, he did.
17 Q.
What did he tell you about that?
18 A.
He told us that it was based on several factors: The
19 fact that the bank itself did not have to pay income tax
10:33:36
20 in Montserrat; that because it was based in Montserrat,

21 the bank was not required to hold a certain amount of
22 funds in reserve like U.S. banks are required to do. So
23 they could put up to 100 percent of the deposits to work
24 in investments, getting a higher yield and passing those
10:33:55
25 earnings on.
586
Because it was not a full-service bank,
2 meaning they didn't have tellers, they didn't do loans, it

3 was only the deposit function, they didn't have as many
4 employees, and so, their overhead was lower and that, in
10:34:09
5 turn, allowed them to have greater earnings and share that

6 with the depositors.
7 Q.
Did Mr. Stanford in the beginning ever discuss at all
8 how the bank, Guardian International Bank, was investing

9 the money it was collecting from these money market
10:34:23
10 accounts?
11 A.
Yes.
12 Q.
And what did he tell you regarding that?
13 A.
He told us that it was being placed in high quality,
14 conservative, easily liquidated instruments.

10:34:34
15 Q.
What do you mean, "easily liquidated"? Could you
16 explain the concept of liquidity in the finance world?

17 A.
Yes. This means that it was being placed in
18 instruments like bonds.

19
10:34:46
MR. FAZEL: I'm sorry, Your Honor, if I can
20 object to the form of the question. Is it the witness's

21 understanding of what liquidity is or is it her expert
22 opinion? Which one is it?
23
MR. STELLMACH: She's not testifying as an
24 expert, Your Honor. She's an experienced financial

10:34:59
25 professional, but I can -- I can clarify.

587
THE COURT: Okay. Tell you what. Hold -- one
2 second. Also pull the mike around toward you. So it will

3 pick up. So when you stand up, at least it will pick up
4 and amplify it better.
10:35:13
THE COURT: All right. Thank you.
7 BY MR. STELLMACH:
8 Q.
Did Mr. Stanford explain what liquidity was to you,
9 or did you understand -- have a previous understanding of

10:35:20
10 what that term meant?

11 A.
Both.
12 Q.
Oh. Could you tell us what Mr. Stanford told you he
13 meant by "liquidity"?
14 A.
10:35:29
These were instruments that they could sell and turn
15 into cash on short-term basis whenever clients needed to

16 make withdrawals.
17 Q.
Did Mr. Stanford give you a sense of how quickly they
18 could liquidate the bank's portfolio?

19 A.
10:35:43
Many of the instruments that we were told were being
20 held in portfolio could be sold within three business days

21 and turned into cash.
22 Q.
Did Mr. Stanford ever explain who was actually
23 managing the money on a day-to-day basis?

24 A.
10:36:01
He told us that he had set up relationships with
25 correspondent not banks and with money managers and it was

588
1 in contact with these people.

2 Q.
3
I just want to break that down a little bit.

Could you explain what Mr. Stanford had
4 told you about who these other money managers were that
10:36:14
5 were running the money or managing the money?

6 A.
They were internationally known, experienced money
7 managers, meaning companies like Merrill Lynch, could be a

8 bank in Switzerland like Union Bank or Credit Suisse,
9 where they provided services to other companies and
10:36:33
10 financial institutions such as the management of their

11 investment portfolios for a fee.
12 Q.
So were these money managers that were actually
13 managing the money day-to-day, were they employees of

14 Mr. Stanford or his bank?
10:36:46
15 A.
No, they were outside companies that provided a
16 service for a fee.

17 Q.
Did Mr. Stanford ever tell you who within the bank
18 was responsible for keeping an eye on these international

19 overseas money managers?
10:37:01
20 A.
It was my understanding that he was the person who
21 was handling those relationships.

22 Q.
What's that understanding based on?
23 A.
The information that he gave us as far as visits with
24 money managers and conversations with him.

10:37:14
25 Q.
Oh. Mr. Stanford, he would discuss visits to

589
1 different money managers?

2 A.
He told us of some trips that he had made, yes.
3 Q.
Were there any incentives or commissions that were
4 offered to you and other salespeople to open these money

10:37:30
5 market accounts?
6 A.
Yes. When I went to work for Guardian International
7 Investment Services, I was offered a base salary and then

8 a bonus on the funds that I brought into the bank.
9 Q.
10:37:47
Do you recall what the bonus structure was set up
10 like?
11 A.
It was 1 percent of the new funds.
12 Q.
So for every hundred dollars you brought in, you
13 could keep --
10:37:54
14 A.
I kept a dollar.
15 Q.
-- a dollar.
16 A.
Uh-huh.
17 Q.
And we mentioned earlier a certificate of deposit
18 program.
19
10:38:04
Approximately how long after you started
20 did the CD program get introduced?

21 A.
It was within a year of when I started.
22 Q.
Can you tell us how that topic came up, the idea of
23 the bank, Guardian International Bank, offering CDs?

24 A.
10:38:21
My co-workers and I, the other people who were doing
25 the marketing, met with him on a fairly frequent basis to

590
1 share with him the feedback that we were getting from

2 clients and prospects.
3
Many of our clients, because they were
4 coming out of banks in the U.S., were accustomed to having

10:38:36
5 certificates of deposit. And we thought that that would

6 be a good product for the bank, so he added it.
7 Q.
Could you explain what a certificate of deposit is?
8 A.
It is a deposit held at a bank for a fixed period of
9 time and guaranteed rate of interest.

10:38:54
10 Q.
So how did the certificate of deposit that the bank
11 was offering differ from the money market account that had
12 been the first product that was really being sold to
13 depositors?
14 A.
10:39:09
The -- it had a higher rate of returns on it because
15 it was a fixed deposit for a longer term. The more liquid

16 or more easily it is for the client to get to their funds,
17 the less interest it's going to pay.
18 Q.
So if somebody bought a 90-day CD, when could they
19 get their money out?

10:39:24
20 A.
After 90 days.
21 Q.
As opposed to the money market where they could take
22 money -- a limited number of transactions out per month?
10:39:37
23 A.
Right.
24 Q.
Was there any shift away from money markets to CDs
25 once the CD program started?

591
1 A.
The CD became the most popular product at the bank,
2 yes.
10:39:48
3 Q.
Why was that?
4 A.
Because of the rate of return, it was more
5 attractive. It was an instrument that the clients

6 understood. And it was just something that was offered to
7 them that became popular.
8 Q.
And once the CD program was introduced, did you
9 notice how the rates for Guardian's CDs compared with CD

10:40:11
10 rates that were offered by U.S. banks?

11 A.
They would average two to 4 percent above what the
12 U.S. banks were paying.

13 Q.
Again, we talked about this in connection with the
14 money market account, but did you ever discuss that with
10:40:23
15 Mr. Stanford, how that was possible?

16 A.
Yes.
17 Q.
And what did he tell you?
18 A.
We talked about it in meetings. It was the same as
19 with the express account. Because the bank didn't have to

10:40:33
20 maintain reserves, because it did not have to pay income

21 tax on the island on the bank earnings, because of the low
22 overhead, because it was just a -- it was basically a
23 single-service-type bank, that the higher interest rates
24 could be paid because they had higher earnings.
10:40:52
25 Q.
And again, did Mr. Stanford tell you who was managing
592
1 the CD money for the bank?

2 A.
It -- all the information that came to us was flowing
3 through him.
4 Q.
10:41:07
But in terms of managing the day-to-day investments
5 from the CD money?

6 A.
Oh. The money managers were doing that on a
7 day-to-day basis.
8 Q.
The international money managers you had talked about
9 previously?
10:41:16
10 A.
Correct, yes.
11 Q.
And what did Mr. Stanford tell you about how the bank
12 was investing the CD money?

13 A.
That it was the same strategy as had been used with
14 the funds in the express account, that it was going into

10:41:34
15 conservative, easily sold instruments such as high quality

16 bonds, well-known company stock shares, preferred stock
17 that paid higher dividends, things like that.
18 Q.
When you started, did Mr. Stanford tell you anything
19 about whether Guardian International Bank made loans?

10:41:56
20 A.
We were told that the bank did not make loans when I
21 first started. Sometime later, I don't know exactly how

22 long, they started allowing clients to borrow against
23 their own funds.
10:42:12
24 Q.
Could you explain what you mean by that?
25 A.
It's what they call -- in banking, they call it a

593
1 back-to-back. So let's say the client has $30,000 on

2 deposit. Instead of breaking their CD and paying a
3 penalty, they could actually take out a loan using that
4 account as the collateral, as the guarantee for it. And
10:42:29
5 then once the CD matured, they could use the funds to pay
6 the loan off, or they could send money from another bank
7 to pay it off.
8 Q.
We'll come to this a little bit later, but if
9 somebody had a hundred-thousand-dollar CD at Guardian

10:42:47
10 International Bank, so they had deposited a hundred

11 thousand dollars into a CD program, could they borrow the
12 full hundred thousand dollars from the bank?
13 A.
Usually it was up to maybe 97, 98,000 because they
14 wanted to leave a margin for accrued interest, which meant

10:43:01
15 that there would be no risk of loss to the bank.

16 Q.
Did Mr. Stanford ever discuss the importance of that
17 program, the fact that there was no risk of loss?

18 A.
Absolutely. That was one of the things that
19 contributed to the comfort level of the clients with the

10:43:17
20 bank, was minimizing the risk with the funds.

21 Q.
Once the CD program started, did Mr. Stanford ever
22 share with you his vision for its growth?

23 A.
Yes. He wanted to eventually be able to compete with
24 the large international banks like Citibank or a Credit

10:43:38
25 Suisse, Union Bank.

594
1 Q.
And as time went on, did Mr. Stanford ever discuss
2 whether he was also opening other companies and

3 businesses?
10:43:48
4 A.
Yes, he did.
5 Q.
And I wanted to turn, if we could, to the board chart
6 and talk about some of the other Stanford companies that

7 he discussed with you.
8
MR. STELLMACH: And if we could see the
9 first -- the next, Mark?

10:43:59
10:44:09
11 Q.
Guardian Development Company is listed there?
12 A.
Uh-huh.
13 Q.
Did Mr. Stanford ever discuss that company with you?
14 A.
That company was actually open when I went to work
15 for them, and I met the two gentlemen who were in charge
16 at the time.
17 Q.
The two gentlemen being Mr. Stanford and his father?
18 A.
No. It was Arnold Knoche and Larry -- and I can't
19 remember Larry's last name. But will they were the ones
10:44:21
20 who were actually going out and looking for real estate
21 investment opportunities.
22 Q.
What did Mr. Stanford tell you about Guardian
23 Development Company's business focus, its types of

24 investments?
10:44:36
25 A.
For Guardian Development?

595
1 Q.
Guardian Development, yes.
2 A.
This was during a time when the real estate market,
3 particularly in Texas, was bad. There were a lot of

4 opportunities to go out and buy houses, apartment
10:44:53
5 complexes. And they were looking for these opportunities

6 and setting them up as joint ventures with international
7 clients, some of whom were actually bank clients at the
8 time.
9 Q.
10:45:07
But Guardian Development Corporation was a separate
10 company from the bank?

11 A.
Exactly. It was an affiliate of the bank, just like
12 Guardian International Investment Services was.

13 Q.
And we've used that word before, but when you say an
14 affiliate of the bank, how were these companies related to

10:45:21
10:45:34
15 the bank?
16 A.
They were like siblings.
17 Q.
And who was the father?
18 A.
Allen Stanford.
19 Q.
What did Mr. Stanford tell you about how he was
20 financing Guardian Development Company or Guardian

21 Development Corporation?
22 A.
We were told that all of the companies had separate
23 financing and separate capital.

24 Q.
10:45:47
Did you ever ask Mr. Stanford whether any money from
25 the bank, from the CD program, was being used for the real
596
1 estate business in Guardian Development?

2 A.
We talked about the deposits at the bank and how they
3 were invested, and we were always told that they were

4 being put into liquid instruments.
10:46:03
5 Q.
When you say "we," who do you mean?
6 A.
I mean my co-workers and I, the other marketing
7 people.
10:46:14
8 Q.
With Mr. Stanford?
9 A.
Marketing people. Yes.
10 Q.
Are you familiar with an individual named James
11 Davis?
10:46:22
12 A.
Yes, I am.
13 Q.
Who is Mr. Davis?
14 A.
Mr. Davis was the CFO.
15 Q.
What does "CFO" stand for?
16 A.
Chief financial officer.
17 Q.
And just what does that title mean?
18 A.
It means that he was in charge of all of the
19 bookkeeping, accounting, financial reporting for the

10:46:36
20 companies.
21 Q.
How soon after you arrived did Mr. Davis start?
22 A.
He started a little less than a year after I did and
23 actually sat in the office next to mine.

24 Q.
10:46:51
And once Mr. Davis started, did you start reporting
25 to him -Johnny C. Sanchez, RMR, CRR - jcscourtreporter@aol.com
597
10:47:00
1 A.
No, I did not.
2 Q.
-- instead of Mr. Stanford?
3 A.
No, I never reported to him.
4 Q.
Well, after Mr. Davis arrived and became chief
5 financial officer, who was in charge of the business?

6 A.
Allen Stanford.
7 Q.
What makes you say that?
8 A.
Because we always had contact with him, our
9 information flowed from him and we reported to him.

10:47:14
10 Q.
Well, did Mr. Stanford ever say that Mr. Davis was
11 really responsible for the bank?

12 A.
No.
13 Q.
Or for Guardian International Investment Services,
14 the company you worked for?

10:47:24
15 A.
No.
16 Q.
Would you describe Mr. Stanford as an absentee owner?
17 A.
No. Quite the contrary. He was extremely involved
18 in everything.
10:47:37
19 Q.
What makes you say that?
20 A.
When the company was small, we had contact with him
21 on a daily basis. As the offices opened, he traveled a

22 lot more between the offices. But as we added
23 companies -- for instance, we had an inhouse publishing
24 company that put out the brochures and financial reports,
10:47:56
25 and we'd be waiting for the annual report to come out and
598
1 talked to someone over in publishing, and they'd say it's

2 still sitting on his desk waiting for his approval.
3
So both from what he told us, as well as
4 what we heard from our affiliate companies, we know that

10:48:13
5 he was -- he was very involved.

6 Q.
Well, when you first started, what was Mr. Stanford's
7 title at the bank?
10:48:22
8 A.
President.
9 Q.
But that changed. Somebody else became president.
10 Isn't that right?

11 A.
Yes.
12 Q.
So Mr. Stanford wasn't actually running the bank
13 then; right?
10:48:31
14 A.
Not sitting in the bank, no.
15 Q.
Did he ever discuss that with you, the fact that he
16 had given up the title of president?
10:48:41
17 A.
Yes.
18 Q.
19 A.
He told us that they were doing a restructuring for
20 legal purposes and that the title was going to be given to

21 someone who would be based there in -- on Montser -- well,
22 in Antigua at the time and would be running the day-to-day
23 operational side of it.
24 Q.
10:48:58
Did Mr. Stanford indicate whether that meant he was
25 stepping back from running the bank?

599
1 A.
On a day-to-day operational basis, he would no longer
2 be doing that; but he was still involved with and visited

3 the bank frequently.
4 Q.
10:49:14
Were there any particular areas of the business that
5 you observed Mr. Stanford being very directly involved in?

6 A.
The bank was always of great importance to him. And
7 I know that he visited there quite a bit.
10:49:30
8 Q.
Were there written marketing materials for the bank?
9 A.
Yes, there were.
10 Q.
What kinds of materials were there?
11 A.
There were brochures. There were rate sheets. Every
12 time the rates changed, we would get a new sheet. His

13 materials were in English and Spanish, and we would mail
14 them out or hand-carry them to clients and, prospects.
10:49:45
15
THE COURT: What was the language on that
16 island, predominant language?
10:49:55
17
THE WITNESS: English.
18
MR. FAZEL: I'm sorry. Which island?
19
THE COURT: Okay. Which island?
20
THE WITNESS: Both of them.
21
THE COURT: Both.
22
THE WITNESS: Uh-huh. They --
23
THE COURT: That's all right.
10:49:59
25 Q.
But just to be clear, right now we're still on

600
1 Montserrat. We haven't gotten to Antigua. Is that right?

2 A.
Yes.
3 Q.
Okay. So were the marketing materials, the
4 brochures, given to depositors or potential depositors?

10:50:15
5 A.
Yes.
6 Q.
Do you know whether Mr. Stanford was involved at all
7 in preparing those written materials?
10:50:23
8 A.
Yes, he was.
9 Q.
10 A.
Because he would review the materials with us for our
11 feedback, and on the English as well as when the Spanish

12 was translated, or we would even help with the Spanish
13 translation.
14 Q.
10:50:39
When you say he would review the materials, do you
15 mean he would review the finished product with you or he

16 would review drafts?
17 A.
Drafts, before they went to final publishing to make
18 sure all the punctuation was correct, the grammar was

19 correct, phraseology, that sort of thing.
10:50:52
20 Q.
Did Mr. Stanford ever discuss his own role in writing
21 the marketing materials for the bank?

22 A.
Not in great detail. He -- just the -- this was the
23 way, this was the message that he wanted to convey to

24 clients and to prospective clients.
10:51:14
25 Q.
And at this point I was going to turn to Government's

601
1 Exhibit 522. It's a Guardian Bank marketing brochure.
10:52:19
THE COURT: I put their time on.
MR. STELLMACH: Thank you.
MR. FAZEL: Thank you, Judge.
THE COURT: Any objection?
MR. FAZEL: No, Your Honor.
THE COURT: All right. Thank you. Go right
8 ahead.
9 BY MR. STELLMACH:
10:52:24
10 Q.
Ms. Chambliess, are you familiar with this document?
11 A.
Yes, I am.
12 Q.
How do you recognize it?
13 A.
It was one of the materials that we sent down and
14 carried to clients and prospects.

10:52:34
15
MR. STELLMACH: And if we could turn to the
16 third page of the marketing brochure.

18 Q.
Underneath the eagle, could you just read what it
19 says there?
10:52:44
20 A.
Which page?
21 Q.
It's also on our screen.
22 A.
"Eagle stands for financial strength."
23
MR. STELLMACH: And if you would turn to
24 Page 4.
10:53:00
25
THE WITNESS: Uh-huh.

602
1 BY MR. STELLMACH:
10:53:05
2 Q.
Who is that a picture of?
3 A.
James Stanford.
4 Q.
And at the time, what was his role?
5 A.
He was chairman of the board.
6 Q.
And in his lapel, he is wearing?
7 A.
The eagle pen.
MR. STELLMACH: If we turn to the next page.
9 BY MR. STELLMACH:
10:53:13
10 Q.
What's the title at the top of the document?
11 A.
"Message from the Chairman."
12
MR. STELLMACH: And if we could enlarge the
13 document.
10:53:21
15 Q.
And if I could just ask you to read that document to
16 us, the letter itself?

17 A.
"Our past success has enabled Guardian International
18 to build a reputation as a leader in delivering top

19 quality financial products to the inventor who is neither
10:53:35
20 a citizen nor a resident of the United States of America.

21
"Our multi-national organization is totally
22 committed to meeting the needs of a diverse group of

23 clients, clients who depend upon us for the quality of our
24 investment products, our high caliber of service and the
10:53:52
25 professionalism of every person and every department at

603
1 Guardian International.
2
"We decided early on that we should not seek
3 to be all things to all people, but to create a niche of

4 our own in the international financial services industry.
10:54:07
5 Though the market in which we have chosen to operate is

6 demanding, our commitment to investment safety, liquidity
7 and personal attention seldom found has resulted in
8 Guardian International's financial strength, stability and
9 continued growth.
10:54:23
10
"We invite you to enjoy the benefits of our
11 commitment to you by contacting one of our officers." And

12 it's signed James A. Stanford, chairman of the board.
13 Q.
In that description, was that consistent with your
14 understanding of the bank's strategy?

10:54:37
15 A.
16
Absolutely.
MR. STELLMACH: And if we could turn to Page 7.
18 Q.
And if we could go through the -- at the top of the
19 page, it reads: "The board of directors"?

10:54:49
20 A.
Uh-huh.
21 Q.
Before we turn to the text, could you just explain
22 what a board of directors is?

23 A.
Board of directors is a group of people who are
24 charged with ensuring that a company is being managed

10:55:03
25 properly and that it's financial accounting is correct.

604
1 It works on behalf of depositors when it's a bank or on

2 behalf of shareholders when it's a corporation.
3 Q.
And before we turn to the description of
4 Mr. Stanford's background, at the top of the page, could

10:55:22
5 we just -- could I just ask you to read that text to us?

6 A.
"The operating philosophy of Guardian International's
7 board of directors is the absolute safety of our client's

8 money and its short-term liquidity. We specialize in a
9 few select investment instruments that ensure the least
10:55:40
10 risk with the greatest return, providing a level of

11 personal service second to none."
12 Q.
Did it matter to you at all whether this bank had a
13 board of directors?
10:55:51
14 A.
Yes.
15 Q.
Why?
16 A.
Because it was more eyes and more expertise to ensure
17 that the bank was being properly managed.

18 Q.
And I just wanted to focus on the bio beneath
19 Mr. Stanford's name before we leave this page.

10:56:07
20 A.
James or Allen?
21 Q.
I'm sorry. Mr. Allen Stanford.
22 A.
"President and chief executive officer of Guardian
23 International. He is the third-generation family member

24 of the Stanford Financial Group. A graduate of Baylor
10:56:22
25 University with a BA degree in finance. Mr. Stanford

605
1 brings to the board of directors more than 15 years

2 experience in banking, insurance, investment real estate
3 and marketing. Mr. Stanford directs Guardian
4 International's activities outside the United States."
10:56:38
5 Q.
Did you ever discuss with Mr. Stanford, with Allen
6 Stanford -- and just so we're clear going forward, when I

7 refer to Mr. Stanford, I'm only referring to Mr. Allen
8 Stanford.
9 A.
10:56:48
10 Q.
Okay.
If we talk about James Stanford, I'll be specific
11 about that.
12 A.
Okay. Thank you.
13 Q.
With respect to Allen Stanford, did you ever discuss
14 with him any concerns you had about his description of his
10:57:00
15 background or the bank's existence?

16 A.
I can remember one instance with one of the
17 brochures. They were talking about -- I don't know if it

18 was in this one -- Stanford Financial Group and its 75
19 years of history, because the way that it was written, it
10:57:20
20 implied that the bank had been around for 75 years, and
21 the bank was a year and a half old or so at the time. And
22 I felt that that might be misleading to clients and
23 prospective clients.
10:57:35
24 Q.
What did Mr. Stanford say when you pointed that out?
25 A.
He wanted people to know that there was a history

606
1 behind the bank and that there was more experience, that
2 it wasn't just a brand-new organization started out by
3 people who didn't know anything about what they were
4 doing.
10:57:53
5 Q.
There's a company that's described there or an entity
6 called the Stanford Financial Group?
10:58:08
7 A.
Right.
8 Q.
Did Mr. Stanford ever tell you what that was?
9 A.
I know that his grandfather had started an insurance
10 agency, but I wasn't sure what the name of the insurance

11 agency was. That would be the only thing that I could
12 figure.
13 Q.
I want to turn to Page 11 of the brochure and ask you
14 to read the paragraph beneath time, certificate of

10:58:28
15 deposit -- the two paragraphs, I'm sorry.

16 A.
"This investment program offers maximum capital
17 growth. Deposits are invested in high-quality bonds,

18 securities, commercial paper, Eurodollar deposits and
19 foreign currency deposits placed with other banks.
10:58:45
20
"Interest is compounded daily based on a
21 365-day year. Rates are guaranteed for deposit periods of

22 3, 6, 12, 18, 24 or 36 months. The initial minimum deposit
23 is U.S. $25,000. The greater the amount invested and/or
24 the longer the term of the investment, the greater the
10:59:06
25 yield. Your private banking officer will provide you with

607
1 the current rates."

2 Q.
Before I move on, I was just wondering if you could
3 explain to us what Mr. Stanford told you about commercial

4 paper, the types of commercial paper investments that were
10:59:21
5 being made?
6 A.
Commercial paper is short-term investment. It could
7 be something as short as, say, 7 days, 30 days. When the

8 government does it, they call them treasury bills. These
9 are -10:59:35
10
MR. FAZEL: I'm sorry. Just to be clear, is
11 she testifying as to what Mr. Stanford said or what her

12 understanding of what commercial paper is?
13
MR. STELLMACH: I think I was clear in the
14 question, precisely to avoid the objection, that I was

10:59:47
15 asking her what Mr. Stanford told her.

16
MR. FAZEL: Well, I'm going to object unless
17 the Court can make it clear. Is it her opinion of what

18 Mr. Stanford said?
19
10:59:55
THE WITNESS: Let me see if I can be a little
20 more specific.
22 Q.
23
Thank you.
THE COURT: Well, did Mr. Stanford tell you
24 that or is it a combination of Mr. Stanford and you knowing

11:00:01
25 the business?
608
THE WITNESS: What I said is a combination of,
2 but I'll try and cut it back. Commercial paper is issued

3 on a very short-term basis by companies.
4 BY MR. STELLMACH:
11:00:13
5 Q.
And what did Mr. Stanford tell you about the types of
6 commercial paper that the CD money was going into?

7 A.
Large, well-established, well-known companies.
8 Q.
And regarding Eurodollar deposits, what are
9 Eurodollars?
11:00:31
10 A.
Those are deposits in U.S. dollars held at foreign
11 banks.
11:00:44
12 Q.
So actual cash on deposit?
13 A.
Yes.
14 Q.
And foreign currency deposits?
15 A.
Deposits in foreign banks in their currency or other
16 currency.
17
MR. FAZEL: If it pleases the Court, is this
18 her understanding or what Mr. Stanford -19

11:00:54
THE COURT: All right. Is it your
20 understanding? Do you know that -21
THE WITNESS: It --
22
THE COURT: Hold it. Wait a second. You've
23 been in the backing business for many years?
11:01:00
24
25
THE COURT: Are you stating from your

609
1 experience and your knowledge or just what Mr. Stanford

2 told you?
11:01:08
THE WITNESS: Both, Your Honor.
THE COURT: Well, you're going to have --
THE WITNESS: Mr. Stanford told that to us, and
6 I have had it confirmed through my years of experience in

7 banking.
8
THE COURT: All right. Do you have an
9 objection to that, or do you want a continuing objection?

11:01:21
10
MR. FAZEL: My objection is the record is
11 unclear as to who is saying what. That's my objection.

12
THE COURT: We have it now. It's a mixture of
13 both.
11:01:30
14
MR. FAZEL: All right.
15
THE COURT: If you want it broken down, then
16 ask, and I'll consider it.

17
18
Go on.
MR. STELLMACH: Yes, Your Honor.
11:01:35
20 Q.
I was going to turn to Page 14 of the brochure. And
21 the text at the top of the page.

22 A.
"Historical Review Banking Division."
23 Q.
And could you just read the text at the top of the
24 page to us?
11:01:53
25 A.
"Guardian International's private banking division

610
1 has seen consistent growth, growth in quality of products

2 and services in breadth of customer base, assets and
3 earnings. The ingredient most critical for this progress
4 has been our commitment to helping our clients reach their
11:02:11
5 goals."
6 Q.
What was the private banking division?
7 A.
That -- that was our area. We were considered
8 private banking as far as the marketing and customer

9 service.
11:02:24
10 Q.
When you say "our area," what are you referring to?
11 A.
We provided a contract service to the bank to assist
12 in the opening of accounts.

13 Q.
So Guardian International Investment Services, the
14 company you worked for, functioned as the bank's private

11:02:44
15 banking division?
16 A.
We were a contract extension. They added bankers on
17 the island after I joined who also did that function.

18
MR. STELLMACH: At if we go toward the bottom
19 of the page, under "deposits," looking at that chart, if we

11:03:08
20 just get it a little -- I was just looking at deposits.

22 Q.
If you could tell us what's shown there about the
23 growth of deposits at the bank.

24 A.
11:03:23
At the -- the bank showed with -- from quarter to
25 quarter and year-over-year consistent growth.

611
1 Q.
And some of the numbers are?
2 A.
The first quarter of '87 --
3 Q.
You don't have -- we don't have to go through all of
4 them.
11:03:36
5 A.
First quarter was, like, 140 percent, which was a
6 great deal. The first quarter of '89 was 11 percent.

7 Q.
And turning to the next page. Under assets, if we
8 could just look at that chart.

9 A.
11:03:57
That also showed consistent quarter to quarter and
10 year-to-year growth.
11 Q.
And this just shows growth. Is there any indication
12 of the dollar amounts on the side in this graph?
11:04:12
13 A.
I don't see dollar amounts on the side.
14 Q.
And, again, the type of growth that the bank reported
15 in its assets, what was -- what was it ranging in?

16 A.
First quarter was -- looks like 147 percent, 1363;
17 first quarter of 88, 27 percent; first quarter of 89 was

18 11 percent.
19 Q.
11:04:37
We're almost done. I want to jump to Page 31 of the
20 brochure.
21
Starting with the questions, the question
22 at the top. If you could just walk us through the

23 question and answers that are on that page.
24 A.
11:04:50
25
"Who founded the Guardian International companies?"

"The Guardian International companies were
612
1 formed by the Stanford Financial Group, which was founded

2 by Lodis B. Stanford in 1932. The group is composed of
3 noted businessmen and professionals whose careers reflect
4 a conservative, success-oriented philosophy."
11:05:09
Continue?
6 Q.
And the next -- yes, please, ma'am.
7 A.
"Does Guardian International Bank, Limited, provide
8 deposit insurance coverage similar to the FDIC?

9
11:05:22
"GIBL is a British crown colony chartered
10 bank and, therefore, does not participate in FDIC coverage

11 which is exclusive to United States banks. However, GIBL
12 maintains insurance covering the financial institutions in
13 which it holds deposits. The bank also carries a banker's
14 fidelity bond which provides coverage of up to $1 million
11:05:39
15 per incident against fraud, embezzlement or other similar

16 acts."
17 Q.
We're going to talk about insurance in a little bit,
18 but I was hoping to finish with this brochure and turn to

19 the next page.
11:05:49
20 A.
Okay.
21 Q.
And the question and answer at the top of that page.
22 A.
"How does Guardian International Bank, Limited, able
23 to pay interest rates considerably higher than other

24 commercial banks?"
11:06:01
25
"The bank does not make dividend payments

613
1 to shareholders; instead, it pays the bulk of all its

2 profits back to the depositors in the form of higher
3 interest payments. Maximum advantage is taken of the
4 bank's tax haven status in Montserrat. The bank's
11:06:17
5 overhead is small compared to that of other institutions

6 which offer a full range of financial services.
7
"GIBL has concentrated on a few select
8 investment products that yield the greatest profit for the

9 bank and, therefore, the greatest return to the
11:06:33
10 depositor."
11 Q.
And, again, were you ever told that this policy
12 changed at any point when you worked for Mr. Stanford?
11:06:48
13 A.
No, never.
14 Q.
Did Mr. Stanford ever discuss dividends with you? It
15 says there in the first bullet point, "the bank does not
16 make dividend payments to shareholders."
17
11:06:56
Who were the shareholders of the bank?
18 A.
He and his father.
19 Q.
20 A.
He told us.
21 Q.
Did he ever explain how the ownership was divided up
22 between his -- between him and his father?

23 A.
Originally what I was told was that his father had
24 put up $400,000 and Allen Stanford had put up $100,000,

11:07:15
25 that Montserrat required $500,000 minimum in order to open

614
1 a bank.
2 Q.
And in terms of dividend payments, what are
3 dividends?
4 A.
11:07:31
Dividends would be piece of earnings paid out to a
5 shareholder.
6 Q.
What did Mr. Stanford tell you about whether he took
7 dividends or profits out of the bank?

8 A.
That they were not taking the profits out at that
9 time, that they were putting the funds back in to grow the
11:07:45
10 bank.
11 Q.
And we talked a little bit about the FDIC earlier in
12 insurance. When you were trying to sell the CDs to new

13 customers, was the fact that the bank, Guardian
14 International Bank, wasn't insured by the FDIC ever a
11:08:05
15 source of concern?
16 A.
Yes, it was frequently a source of concern,
17 particularly for people who were banking with a U.S. bank

18 at the time, because that was their comfort, their
19 assurance that they weren't going to lose their savings.
11:08:18
20 Q.
What did you tell Mr. Stanford you were hearing from
21 your customers?
22 A.
Exactly that. Especially because it was a new bank,
23 it was a new business, and because it did not have any

24 kind of guarantee, that they were concerned about losing
11:08:32
25 their funds.
615
1 Q.
Did you ever discuss whether that concern was
2 affecting sales? You weren't -- in other words, you

3 weren't able to sell as many CDs because people were
4 concerned that there wasn't FDIC insurance at the bank?
11:08:45
5 A.
Yes.
6 Q.
What did Mr. Stanford say?
7 A.
He said that he was going to look into getting
8 insurance for the bank, that to be able to buy an

9 equivalent type policy through private insurance would be
11:09:00
10 so expensive that it would take away the advantage and

11 interest rates that the bank had at the time over what the
12 U.S. banks were paying. And so, they were going to look
13 for something that would provide if not identical type
14 coverage enough coverage that the depositors would feel
11:09:21
15 more comfortable.
16 Q.
Did there come a point, though, when Mr. Stanford
17 told you whether the bank had actually gone out and
18 purchased insurance?
19 A.
11:09:30
20
Yes.
MR. STELLMACH: I was going to turn, Your
21 Honor, to Government's Exhibit 502. This is the insurance

22 policy that purports to be from the British Insurance. Do
23 you need my copy?
11:09:44
24
MR. FAZEL: No. We would object to --
25
THE COURT: What grounds?

616
MR. FAZEL: Hearsay, and foundation.
MR. STELLMACH: Not offered --
THE COURT: All right. What's your response,
4 Counsel?
11:09:50
MR. STELLMACH: Not offered for the truth, Your
6 Honor. We don't believe this is a real document.
11:09:59
11:10:07
MR. FAZEL: Then in that case --
THE COURT: I can't hear you, Counsel.
MR. FAZEL: Then it's not relevant, Your Honor.
10
MR. STELLMACH: It's a fake insurance policy.
11
THE COURT: Wait a second.
12
MR. FAZEL: I object to that sidebar comment.
13
THE COURT: Let me just handle this.
14
15
THE COURT: Why do you object to it?
16
MR. FAZEL: Other than hearsay and foundation
17 and relevance, those are my objections.
11:10:14
18
19
20
THE COURT: You're offering it now for the
21 limited purpose only of what?

22
MR. STELLMACH: Of showing that it was shown to
23 Ms. Chambliess and she was told us that it was an actual

24 insurance policy.
11:10:25
25
THE COURT: For that limited purpose, overrule

617
1 the objection.
2
MR. FAZEL: Your Honor, I'd ask the Court to
3 instruct the jury to disregard counsel's sidebar comment.

4
11:10:32
THE COURT: I'm not going to do it at this
5 time. If it continues, I'll consider it. And raise it

6 again if you need to.
7
8 BY MR. STELLMACH:
9 Q.
11:10:50
Ms. Chambliess, if we could look at the top portion
10 of the document. If you could read the name of the

11 company and the address to us.
12 A.
"British Insurance Fund, Limited, First Floor, 35
13 Picadilly, London W1V9 PB England.
11:11:06
14 Q.
Who first showed you this document?
15 A.
Mr. Allen Stanford.
16 Q.
Was this before or after Mr. Davis arrived and
17 started working at the company?
11:11:22
18 A.
It was before Mr. Davis started.
19 Q.
And when Mr. Stanford showed it to you, were you
20 alone or were there other people there?

21 A.
No, we were in a group meeting with the other
22 marketing -23
THE COURT: Pull that mike in just a little
24 bit.
11:11:28
25
THE WITNESS: I'm sorry.

618
THE COURT: Just a little bit.
THE WITNESS: Okay. Thank you.
3 BY MR. STELLMACH:
11:11:35
4 Q.
What did Mr. Stanford tell you about this policy?
5 A.
That he had gone to London and that -- with this
6 company and acquired this insurance in order to help

7 protect the depositors at the bank and to protect the bank
8 itself.
9 Q.
11:11:53
And if you could just read for us under money
10 insurance policy, just the portion that's on the screen.

11 A.
"The insured having applied for the insurance
12 expressed herein and made a proposal and declaration which

13 shall be the basis of this contract and is deemed to be
14 incorporated herein and having paid or agreed to pay the
11:12:10
15 premium as consideration for the insurance.

16
"The company will indemnify the insured
17 against loss of money specified in the schedule occurring

18 during the period of insurance as related to: A, the loss
19 of money due to the failure, collapse or bankruptcy of a
11:12:28
20 redeposit or investment source as approved by the company

21 and only where a depositor liability exists.
22
"B, money in possession of the insured in
23 its strong room located in Montserrat, British West Indies,

24 as agreed by the insured not to exceed U.S. $300,000."
11:12:50
25 Q.
Did Mr. Stanford explain what this policy supposedly

619
1 protected the bank against?

2 A.
This was to cover deposits that the bank had with
3 other banks, its correspondent banks. For instance, the

4 Eurodollar deposits were foreign currency deposits, and
11:13:13
5 also certain investments that were being placed.

6 Q.
Had you ever heard of the British Insurance Fund,
7 Limited, before going to work --
11:13:24
8 A.
No.
9 Q.
-- for Mr. Stanford?
10 A.
No, I had not.
11 Q.
Did he tell you anything about this company?
12 A.
Just that it was one that he had found when he was on
13 his trip.
14 Q.
11:13:39
In Subpart A, there's a line, "Collapse or bankruptcy
15 of a redeposit or investment source as approved by the

16 company."
17
Did Mr. Stanford explain at all what that
18 term supposedly meant?

19 A.
11:13:55
Yes. He meant that in order to be able to get this
20 type of insurance, that the bank had to agree to allow the

21 insurance company to audit its banking relationships and
22 investments and that they set limits on the types or
23 quality of investments that could be made or that the
24 banks in which Stanford or Guardian International Bank
11:14:15
25 could make deposits.

620
1 Q.
And if we turn to the last page, the schedule, could
2 you tell us: According to this policy or this document,

3 what was the amount that was supposedly insured?
11:14:32
4 A.
Up to U.S. $50 million.
5 Q.
For what period?
6 A.
From the first of July 1987 to the first of
7 July 1988.
8 Q.
And going toward the lower right-hand corner of the
9 document, is there a renewal date?

11:14:45
10 A.
30th day of June 1988.
11 Q.
Did Mr. Stanford ever tell you whether the policy had
12 been renewed?
11:15:00
13 A.
Yes.
14 Q.
Did he ever tell you whether you could discuss this
15 policy with your clients?

16 A.
Yes, he did.
17 Q.
Did he say anything about whether an actual copy of
18 the document could be shown to clients?

19 A.
11:15:12
Under certain circumstances with approval, we could
20 show it to clients or prospects.

21
THE COURT: What does that mean?
22
THE WITNESS: We could actually -- for
23 instance, if I were going to Mexico City to meet with you,

24 I could take this and say, "See, we really have insurance."
11:15:19
621
1 Q.
Did Mr. Stanford ever tell you that the British
2 Insurance Fund, Limited, was a shell company he had set

3 up?
11:15:35
4 A.
No.
5 Q.
Would that have made any difference to you?
6 A.
Oh, absolutely, because then there wouldn't be
7 insurance.
8 Q.
And we've been on Montserrat, and we've talked a
9 little bit about Antigua.

11:15:47
10
MR. STELLMACH: We can take the document down.
11 Thank you.
11:16:03
13 Q.
When did the bank move from Montserrat to Antigua?
14 A.
I believe it was around 1990. It was about three
15 years or so after I started, '90, '91.

16 Q.
Did Mr. Stanford explain at all why the bank was
17 moving?
18 A.
There were several reasons: One was just
19 convenience. We had to go through Antigua to get to

11:16:17
20 Montserrat anyway. It was a better-known island. And he

21 said that the banking facilities and administration was
22 better there on Antigua than in Montserrat.
23 Q.
Did he tell you at all whether the Montserrat
24 authorities had indicated that they wanted to revoke the

11:16:38
25 bank's license to do business on the island?

622
1 A.
No.
2 Q.
And after the bank moved to Antigua, did anything
3 change in terms of its operations, or was it still the

4 same bank, just based somewhere else?
11:16:51
5 A.
Just based somewhere else, but the same function,
6 same people.
11:17:00
7 Q.
Did the name eventually change?
8 A.
Yes.
9 Q.
And what did the name change to?
10 A.
From Guardian to Stanford.
11 Q.
And do you recall whether the names of any other
12 companies changed?
13 A.
That it was a rebranding for all of the companies.
14 Every one -- all of the companies went to Stanford.

11:17:12
15 Q.
Are you familiar with a company called Stanford
16 Financial Group? We saw it mentioned earlier in the

17 marketing brochure.
11:17:23
18 A.
Yes.
19 Q.
What happened to Guardian Internation Investment
20 Services, the company you started out at?

21 A.
It was rolled into Stanford Financial Group.
22 Q.
And so, what's your understanding of the company that
23 you were then working for at that point?

24 A.
11:17:38
That company became the umbrella company for the
25 others. It provided marketing services, administrative

623
1 and accounting services for the other companies.

2 Q.
What's that understanding based on? Why do you think
3 that --
11:17:51
4 A.
What Mr. Allen Stanford told us.
5 Q.
Once the bank moved to Antigua, did Mr. Stanford ever
6 discuss with you at all his role in preparing regulations

7 that the government on Antigua issued about banks?
8 A.
He told us that Antigua was going through a process
9 of updating and improving their banking regulations both

11:18:14
10 for on island and offshore banks and that he was

11 participating in that committee.
12 Q.
Are you familiar with an organization called the
13 Financial Services Regulatory Commission on Antigua?
11:18:29
14 A.
Yes, I've heard of it.
15 Q.
How have you heard of it?
16 A.
Because that was the organization that oversaw the
17 offshore banks.
11:18:38
18 Q.
Does the name Leroy King sound familiar?
19 A.
Yes.
20 Q.
How do you recognize that name?
21 A.
He was a contact that was given to us in the case
22 that any of the clients or prospects wanted to get

23 independent information on the bank.
24 Q.
11:18:57
Once the bank moved to Antigua, did Mr. Stanford
25 discuss with you at all how strict the regulation was on

624
1 the island for banks like Stanford International Bank?

2 A.
He said that to be licensed and to maintain a
3 license, they had very strict requirements, and in some

4 cases, it was even more strict than the banking
11:19:16
5 regulations in the U.S.

6 Q.
Were you aware of Mr. Stanford ever making any
7 payments to Leroy King, the head of the Antiguan

8 regulatory body?
9 A.
11:19:39
No.
10
THE WITNESS: Your Honor, could I have a little
11 more water?
11:19:44
12
THE COURT: Pardon me?
13
THE WITNESS: Can I have a little more water.
14
THE COURT: Please. Yes.
16 Q.
And once the bank moved to Antigua -- let's see if I
17 can do two things at once. I'm a lawyer, so I can't.

18
Did Mr. Stanford ever discuss with you
19 whether you could tell clients about how strict regulation

11:20:03
20 was in Antigua?
21 A.
Yes.
22 Q.
And what did you tell clients about that?
23 A.
Exactly what Mr. Stanford had told us, that it was
24 strictly regulated, that they were very hands-on and aware

11:20:23
25 of maintaining high-quality banks on the island, that they

625
1 wanted to improve their standing in the international

2 financial community.
3 Q.
And once the bank moved from Montserrat to Antigua,
4 did customers ask you where the move had taken place?
11:20:38
5 A.
Yes.
6 Q.
And what did you tell them?
7 A.
The same thing that we had been told, because of the
8 advantages of basing on Antigua as opposed to Montserrat.

9 Q.
11:20:54
11:21:08
Moving into 1998, were you familiar with a company
10 called Stanford Group Company?

11 A.
Yes.
12 Q.
And what was Stanford Group Company?
13 A.
A brokerage firm.
14 Q.
And what is a brokerage firm? Could you just explain
15 what that is?

16 A.
It's a company that has financial advisors. They
17 help people set up portfolios to buy mutual funds, stocks

18 and bonds, investments other than what banks offer.
19 Q.
11:21:25
Did Mr. Stanford discuss with you at all the fact
20 that he was opening this brokerage firm?

21 A.
Yes, he told us that he was planning on doing it.
22 Q.
Did he tell you why he was opening a brokerage firm?
23 A.
Yes, he did. In those days, a lot of banks were
24 acquiring or affiliating with brokerage firms in order to

11:21:40
25 offer a wider range of financial products for their

626
1 clients to maintain more of the relationship inhouse, and

2 he wanted to be competitive for that.
11:21:56
3 Q.
So where was Stanford Group Company based?
4 A.
The first office was opened here in Houston.
5 Q.
And were there subsequently branch offices that
6 opened?
7 A.
There were other offices opened, yes.
8 Q.
Did you eventually become an employee of Stanford
9 Group Company?
11:22:06
10 A.
I did.
11 Q.
Could you explain how that happened?
12 A.
We were all given the Series 7 book, which is the
13 license that is required to be a financial advisor, and

14 they told us we had 90 days to study and then we would be
11:22:22
15 taking the test. So that's what we did.

16 Q.
And how did you do on the test?
17 A.
I passed, thank God, first time.
18 Q.
And once you passed the test and received your
19 license -11:22:34
20 A.
Uh-huh.
21 Q.
-- did you play any part in helping to set up
22 Stanford Group Company, this new brokerage firm?

23 A.
Actually, indirectly, I did, because they had hired
24 some people over from Merrill Lynch, but they were from
11:22:47
25 out of state. And my understanding was there was some

627
1 issue with transferring their license to Texas. Without a

2 Texas broker, they could not open an office. And since I
3 was the only one in my group to pass, my license was the
4 one that they used to open this -- the Houston office.
11:23:04
5 Q.
And what was your title once you switched over to
6 Stanford Group Company?

7 A.
A financial advisor.
8 Q.
Did the other salespeople who had previously been at
9 Stanford Financial Group also switch over?

11:23:16
10 A.
Two of them did. One passed the test and -- the
11 second time around, and she was a financial advisor. The

12 third one became a sales assistant because she could not
13 pass the test.
14 Q.
11:23:33
And what could this company, the brokerage firm,
15 Stanford Group Company, do that was different -- I'm

16 sorry. Are you okay?
17 A.
Yeah.
18 Q.
What could the new company do that was different than
19 what Stanford Financial Group had been doing?

11:23:45
20 A.
We could offer a much wider range of investment
21 products to our clients. They had specific products that

22 were for foreign investors, as well as for domestic
23 investors. And they eventually began to offer their
24 certificate of deposit to U.S. investors.
11:24:01
25 Q.
Do you remember when that happened, when the CD was

628
1 available for sale, approximately?

2 A.
Within a year or so after opening the brokerage firm.
3 Q.
Were there any limits on who in the United States
4 could buy a CD once it was available?

11:24:20
5 A.
Yes. They were referred to as qualified investors.
6 Q.
And just to be clear, your clients, were they U.S.
7 residents or were they international clients?
11:24:37
11:24:50
8 A.
Mine were international clients.
9 Q.
So this accredited investor requirement, did that
10 apply for the international clients of the bank?

11 A.
No, they did not.
12 Q.
I'm sorry. The brokerage firm?
13 A.
No.
14 Q.
And could you just explain what an accredited
15 investor is?
16 A.
The regulatory agencies that control the brokerage
17 firm -18
THE COURT: You need to speak up a little bit,
19 please.
11:24:59
20
21
THE COURT: By the way, I know if you're
22 running out of steam, pull it closer. It will pick it up.

23
24 A.
11:25:08
THE WITNESS: Yeah. Okay. Okay. Thank you.

The regulatory agencies that control the brokerage
25 firms define it as someone who has liquid assets, meaning

629
1 cash or easily sold assets, of a million dollars or more.

2 BY MR. STELLMACH:
3 Q.
Were there any incentives at Stanford Group Company
4 for selling the CD product -11:25:23
5 A.
Yes.
6 Q.
-- to clients?
7
8 A.
Could you tell us what those were?

There were special bonuses and commissions that were
9 paid out on the CDs.

11:25:31
10 Q.
Could you explain what the commissions were?
11 A.
I know in my case, when I was rolled over, my
12 contract was renegotiated. I was paid half a percent on

13 new money brought in and a quarter of a percent on money
14 under management at the bank -11:25:49
15 Q.
So how would that work?
16 A.
-- on an ongoing basis.
17 Q.
Just to give us example in dollars and cents, how
18 would that work if somebody bought a

19 hundred-thousand-dollar CD?
11:26:01
20 A.
A hundred-thousand-dollar CD, I would get $5,000.
21 And then, after it had been there six months, even, say,
22 two years down the road, I would still be paid an
23 additional $2,500 on that per year.
24 Q.
11:26:17
So long as the person didn't withdraw any money from
25 the account?
630
1 A.
Exactly.
2 Q.
Did the brokerage firm, Stanford Group Company, also
3 sell CDs that were issued by other banks other than

4 Mr. Stanford's bank?
11:26:29
5 A.
Yes, it did.
6 Q.
How did the commissions paid for Mr. Stanford CDs
7 differ from CDs that were issued by other banks that you
8 could sell?
9 A.
11:26:46
There was no bonus on selling those CDs, and the -- I
10 don't remember exactly what the commission on those were.

11 Q.
Were they better or worse than the Stanford bank CDs?
12 A.
Worse, lower.
13 Q.
Did Mr. Stanford ever discuss with you whether he was
14 tracking CD sales?
11:27:03
15 A.
Yes. Those always came up when we had our quarterly
16 meetings.
17 Q.
And could you tell us about that?
18 A.
We would have quarterly meetings and special meetings
19 whenever a new office was opened. Many times, we'd be

11:27:16
20 flown to Caracas or Mexico City whenever the marketing

21 affiliates came -- and Mr. Stanford would do award
22 ceremonies and give recognition to people who had brought
23 in the most funds over that quarter or for a year-to-date
24 basis. And in some cases, they got a bonus on top of a
11:27:39
25 bonus.
631
MR. STELLMACH: Your Honor, I was going to turn
2 to new document.
3
THE COURT: That's good. I'm going to raise
4 the screen right now, assuming it works. It does.

11:27:48
We'll take a break at this time. We're
6 going to take a break at this time. We'll take a 15-minute

7 break.
8
For those of you not familiar in the
9 audience and maybe even upfront, restrooms are, in effect,

11:28:02
10 right behind this wall. Go out, turn left and turn left.
11 There are some down the hall, all the way down by the
12 courtroom that we have the video in. Go all the way down
13 the hall until it dead-ends and turn left, and certainly,
14 if you want to go up a floor or down a floor.
11:28:18
15
So it's now just about 11:30. We'll see
16 you back ready to room in 15 minutes. So you may stand.

17
(Recessed at 11:29 a.m.)
18 (The following was held outside the presence of the jury)

19
11:49:10
20
THE COURT: Thank you. Be seated.

Let's call the jury in, please. Jury
21 ready to come in, Ellen?

22
23
24
11:50:24
CASE MANAGER: Yes, sir.

THE COURT: Thank you. Be seated. Go right
25 ahead.
632
2 BY MR. STELLMACH:
3 Q.
Ms. Chambliess, before the break, we were discussing
4 commissions on CD sales.
11:50:30
And I just wanted to clear up something that
6 you said.
7
If you sold a hundred-thousand-dollar CD,
8 what was the commission that you would be paid upfront on

9 that?
11:50:40
10 A.
$5,000.
11 Q.
$5,000?
12 A.
Half a -- half a percent.
13 Q.
5 percent. I think -- are you thinking of a
14 hundred-thousand-dollar CD or a million-dollar CD?

11:50:50
15 A.
I'm sorry. I'm used to thinking like a hundred
16 thousand dollars. Yeah.

17 Q.
So a hundred thousand dollars, what would the
18 commission be?
11:51:01
19 A.
$5,000. Half a -- well, 1 percent would be --
20 Q.
1 percent would be a thousand.
21 A.
$500. I'm sorry.
22 Q.
All right. And let's try one other -- one other math
23 problem.
24
11:51:13
If -- if you kept the C -- if the client
25 kept their money in the CD, then you would also be paid
633
1 what's called a trailing commission?

2 A.
Trailing tail, uh-huh.
3 Q.
And so, how frequently would you get paid that
4 subsequent commission?
11:51:22
5 A.
It would be a quarter of a percent annualized and
6 paid out monthly.

7 Q.
And so, over the course of a year, on a
8 hundred-thousand-dollar CD, if it's a quarter of a

9 percent, what would be?
11:51:35
10 A.
That's $250 a year.
11 Q.
Thank you.
12
And I was going to turn to Government's
13 Exhibit 121. It's the quarterly report for the first

14 quarter of 2001 at the bank.
11:51:50
15
16
And turning to the second page.

MR. FAZEL: Your Honor, I would renew my
17 objection as to foundation, hearsay.

18
THE COURT: What's your objection? What is
19 this?
11:52:14
20
MR. FAZEL: Both foundation and hearsay.
21
MR. STELLMACH: Well, as to hearsay, Your
22 Honor, we're not offering any of the marketing materials or

23 the annual reports for their truth, but we're offering them
24 to prove the falsity.
11:52:25
25
And as to foundation, this was a quarterly

634
1 report that the bank issued. I can establish a foundation

2 each time with the document.
3
THE COURT: Are you going to want him to do it
4 each time on foundation?

11:52:33
MR. FAZEL: Yes, Your Honor.
THE COURT: It's your time. If he has to
7 establish a foundation, it's on your time.

8
MR. FAZEL: I understand that. But I also need
9 to make a record, Your Honor, so, yes, I do object to that.

11:52:42
10
THE COURT: Every single object -- they've got
11 500 exhibits.
12
MR. FAZEL: Yes, Your Honor. And if Your
13 Honor --
11:52:47
14
THE COURT: I can't hear you.
15
MR. FAZEL: I'm sorry, Your Honor. If Your
16 Honor wants to admit them into evidence, then I have to

17 make a record of it. Our objection is to hearsay and
18 foundation. Additionally -19
11:52:57
THE COURT: It's on your time. Remember when
20 your time is up, that's it.

21
MR. FAZEL: Additionally, Your Honor, if the
22 Court is overruling our objection to hearsay, I tender the

23 Court an instruction that would ask the Court to give to
24 the jury regarding that matter and the case law that
11:53:08
25 follows it.
635
THE COURT: Did you show it to them?
MR. FAZEL: I sure did. I gave them a copy of
3 it.
4
11:53:14
MR. STELLMACH: He just gave me a copy, Your
5 Honor.
6
THE COURT: Have you got any more recent cases
7 than a 1974 and a 1984 case?

8
MR. FAZEL: I believe there are Supreme Court
9 cases there, Judge.

11:53:34
10
THE COURT: Where are they?
11
MR. FAZEL: Where are the cases?
12
THE COURT: Yes, where are they?
13
MR. FAZEL: We'd be happy to print them for
14 you.
11:53:39
15
THE COURT: These are U.S. Supreme Court cases?
16
MR. FAZEL: Yes.
17
THE COURT: All right. One is. I stand
18 corrected.
19
11:53:45
All right, Counsel, it's on their time.
20 If they want to object to everything. Go on.

21
MR. FAZEL: Also, Your Honor, there is multiple
22 documents in this exhibit, including e-mails, and I believe

23 they're going to introduce all those. Our objection is as
24 to those as well. This is not just a quarterly report. As
11:53:58
25 it rolls down, there will be other documents attached to

636
1 it.
2
THE COURT: You'll have to do it. The whole
3 packet -- is she familiar with the whole packet?

4
11:54:06
MR. STELLMACH: Well, we'll break it up, Your
5 Honor.
6
THE COURT: Make it quick.
MR. STELLMACH: I will.
8 BY MR. STELLMACH:
9 Q.
11:54:11
Ms. Chambliess, there are two e-mails as well as two
10 quarterly reports in that packet. One of the e-mails is

11 addressed to Mr. Stanford.
12
THE COURT: Excuse me. I think technically I'm
13 not going to charge it on them.

14
11:54:24
MR. STELLMACH: I appreciate the discount,
15 Judge.
16
THE COURT: I got to keep your time going.
17 Just make it quick. Go on.

18
MR. FAZEL: If it pleases the Court, as to our
19 objection to the instruction for the jury, if I could get a

11:54:31
20 ruling on that.
21
THE COURT: No.
22
MR. FAZEL: No ruling or --
23
THE COURT: No, sir. I'm not -- if you don't
24 hear it, you know what it is. Okay. I've read it. Now,
11:54:39
25 go on.
637
1 BY MR. STELLMACH:
2 Q.
The first e-mail, was that sent to Mr. Stanford?
3 A.
I'm sorry. I can't say see it. It's not on the
4 screen.
11:54:49
5 Q.
Do you see whether this e-mail was sent to Allen
6 Stanford?
7 A.
8
Yes, his name -MR. FAZEL: Your Honor, it's not been produced
9 to the jury without the foundation being laid.

11:54:57
10
THE COURT: Sustained. Off the screen, please.
12 Q.
11:55:03
And the two --
13
THE COURT: Hold it, Counsel.
14
15
THE COURT: You're going to have to now go
16 through everything -- and don't forget they've got 17,000

17 exhibits on the defense side. 17,000. That's why we have
18 the timer going. They're required to do it on their time.
19 And I've changing my mind. It's on their time. The same
11:55:20
20 thing will on there, 17,000 exhibits, and we'll take them

21 one exhibit at a time.
22
23
Go right ahead.
11:55:29
25 Q.
I'll make this even simpler. Are there two quarterly

638
1 reports bundled together in that exhibit?

2 A.
Yes.
3 Q.
Are you familiar with the monthly quarterly reports
4 of the bank?
11:55:43
5 A.
Yes.
6 Q.
How are you familiar with them?
7 A.
They were provided to us, some for -- were for
8 internal use and some were to be distributed to clients

9 and prospects.
11:55:55
10 Q.
And did you use them in the course of your job?
11 A.
Yes.
12
MR. STELLMACH: Your Honor, I offer the two
13 quarterly reports. We'll break this out separately as

14 121-A and 121-B, and we won't deal with the e-mails.
11:56:06
15 That's a separate issue.

16
THE COURT: Okay. You're admitting them for
17 what purpose?
18
MR. STELLMACH: Not for the truth, Your Honor,
19 merely for the fact that this is what the witness was shown
11:56:14
20 by the defendant regarding the bank.

21
THE COURT: All right. Any objection to that?
22
MR. FAZEL: Same objection. And if the Court
23 overrules us, I'd ask for the instruction.

24
11:56:23
THE COURT: I've already ruled. No
25 instruction. It's overruled for that limited purpose.

639
1 It's coming in for a limited purpose, not for all purposes.

2
Go on.
3 BY MR. STELLMACH:
4 Q.
11:56:33
Turning to the first page of the exhibit --
THE COURT: Let me put it this way: Unless you
6 want me to give this instruction, have you read it.

7
MR. STELLMACH: I have.
THE COURT: You read it.
9
11:56:41
10
Do you object to it.

MR. STELLMACH: I don't object to it. I'll
11 read it.
12
THE COURT: "You are the exclusive judges of
13 the facts. When you deliberate, you will be called upon to

14 decide if certain statements, which I will later identify,
11:56:53
15 are materially false statements. Evidence of what is said

16 to this witness such as a CD purchased by another person,
17 if anything was said, being introduced solely to establish
18 a foundation for a later showing if it can be approved
19 beyond a reasonable doubt that the statement was, in fact,
11:57:11
20 false."
21
Do you want that given? Do you agree with
22 that? Because you're entering it just for the limited

23 purpose -24
11:57:19
MR. STELLMACH: Just for the limited purpose,
25 Your Honor.
640
11:57:23
11:57:29
THE COURT: Well --
MR. STELLMACH: The instruction --
THE COURT: Hold it.
MR. STELLMACH: -- I wanted was --
THE COURT: Hold it. Take a look at it.
MR. STELLMACH: Yes.
THE COURT: You got a copy of it, right?
MR. STELLMACH: Yes, I do.
THE COURT: All right. What I'm going to do
10 just for this one, I'm going to stop the clock. Confer
11 with your counsels at the table. If you want it given,
12 it's already been given; if you don't, I'm going to
13 withdraw it and keep moving.
14
11:57:42
MR. STELLMACH: Or could we propose a different
15 instruction, Your Honor?

16
THE COURT: No. I can give the limited
17 instruction that I gave the last time. It's for the

18 limited purpose.
19
11:58:09
MR. STELLMACH: Your Honor, looking over the
20 entire instruction, we think it's confusing. We'd ask that

21 it not be given.
22
THE COURT: It's withdrawn. I agree after I
23 read it. There was no objection from either side. Because

24 it states here later, "If it can be approved beyond a
11:58:22
25 reasonable doubt that the statement was, in fact, false,"

641
1 and so forth, they can do that -2
MR. STELLMACH: Right.
THE COURT: -- on -- what is it -- on
4 cross-examination or impeachment, or if they elect to call

11:58:31
5 any witnesses by their own witness, but right now, I'm

6 admitting this for the purpose just to show that it was
7 shown to who?
8
MR. STELLMACH: Shown to this witness and other
9 people.
11:58:43
10
THE COURT: That's for that limited purpose
11 only, not for the truth of what was in there, but just
12 as -- that this document was shown to somebody else. So
13 that's a limited the purpose. Go on.
14
11:58:54
16 Q.
And turning to the quarterly report, Ms. Chambliess,
17 the first page, at the top, could you tell us what time
18 period this covered?
11:59:12
19 A.
January 1, 2001, through March 31, 2001.
20 Q.
What would you do with these documents, these
21 quarterly reports, when you received them?

22 A.
I would read them, digest the information, and if it
23 applied to any conversations I was having with clients or

24 prospects, share the information.
11:59:29
25 Q.
And beneath financial and economic highlights,

642
1 there's a line reading: "Interest rates and SIB fixed

2 CD."
3
11:59:42
Do you see those?
4 A.
Yes.
5 Q.
There's also a column for treasury bond yields, the
6 first column.
7
How did SIB's CD rates compare with
8 treasury bond yields and other interest rates?

9 A.
12:00:03
They were about 3, 3-1/2 higher than the treasury
10 bond and about the same to the interest rates.

11 Q.
And if we turn to the second page of this document.
12 There's a description there labeled "Portfolio

13 Adjustments." What did portfolio adjustments supposedly
14 disclose?
12:00:23
15 A.
This was basically a description of changes that had
16 been made from one quarter to another on the portfolio of

17 investments that the bank held.
18 Q.
And going to the pie charts in the lower half of the
19 document of the page, under asset allocation, March 2001,

12:00:45
20 the one in the lower right-hand corner, what was that

21 breakdown?
22 A.
Bonds fiduciary, which means funds being held by
23 other institutions on behalf of the bank, futures or

24 options, currency accounts and equity.
12:01:04
25 Q.
Did you have any understanding from Mr. Stanford

643
1 whether the bank was investing in any real estate?
12:01:15
2 A.
No, and it's not shown here.
3 Q.
And when you say here, you mean the pie chart?
4 A.
On this document, yes.
5 Q.
Or anywhere in the document?
6 A.
Nowhere in the document.
7 Q.
Do you recall any of these quarterly reports ever
8 disclosing real estate investments by the bank?

9 A.
12:01:25
No, not to my recollection.
10 Q.
Would that have concerned you at all?
11 A.
Yes.
12 Q.
Why?
13 A.
Because to start with, it's not something that's
14 easily liquidated, which is what we were always told, the

12:01:35
15 investments could be easily liquidated for the investors,

16 and because it would mean that we were being lied to and
17 that I was in turn lying to the clients and prospects.
18 Q.
It says at the bottom of that page, "For internal use
19 only."
12:01:54
20
Who within the company would receive the
21 quarter reports?
12:02:05
22 A.
The marketing departments.
23 Q.
So meaning everyone within the marketing department?
24 A.
The sales assistants would have access to it as well
25 as the sales representatives.

644
1 Q.
I wanted to turn to another type of document --
2 actually, before we move on. It says, "Allocations by

3 country" in the pie chart in the upper right-hand corner.
4 Do you see that?
12:02:21
5 A.
Yes.
6 Q.
Does it show any significant -- any investments --
THE COURT: Do you want to blow that up,
8 please.
9
12:02:35
MR. STELLMACH: Thank you, Your Honor. Yes.
11 Q.
There are a number of countries listed there. Are
12 any of them in the Caribbean?

13 A.
It has "other." I don't know what would fall under
14 "other." But none of the ones mentioned are in the

12:02:48
15 Caribbean, no.
16
THE COURT: Let me ask you this: It's not in
17 color. What was the United States? What percentage is the

18 United States?
12:02:58
19
THE WITNESS: Looks like 46 percent.
20
THE COURT: It is. Okay.
22 Q.
And what was your understanding about how diversified
23 the bank's assets were in terms of geography, whether they

24 were concentrated in a particular region or across
12:03:13
25 different regions?
645
1 A.
They were supposed to be diversified across different
2 regions and different continents --
12:03:21
3 Q.
Who told you that?
4 A.
-- was our understanding.
5
6 Q.
Mr. Stanford and Mr. Davis.

What's an annual report? I was going to turn to
7 another document.
8
9 A.
12:03:32
What's an annual report?

It is a financial report that is issued once a year,
10 either a calendar or a fiscal year, by a company to give a

11 snapshot of its financial condition at that time.
12:03:46
12 Q.
Did Mr. Stanford's bank issue annual reports?
13 A.
Yes.
14 Q.
Were you familiar with them at all?
15 A.
Absolutely, yes.
16 Q.
How did you become familiar with them?
17 A.
They were provided to us to share in turn with
18 clients and prospects.
12:03:58
19 Q.
And did you do that?
20 A.
Yes, frequently.
21 Q.
Did you ever discuss the annual reports with
22 Mr. Stanford himself?
12:04:04
23 A.
Yes.
24 Q.
How frequently would that come up, the issue of the
25 bank's latest annual report?

646
1 A.
Every year.
2 Q.
Do you know whether Mr. Stanford was involved at all
3 in preparing those documents?

4 A.
12:04:15
I know that he reviewed them before they were
5 released to us.
6 Q.
Well, how do you know that?
7 A.
Because he told us he had seen them. And I would
8 also hear from the inhouse publishing people if they were

9 delayed, that they were on his desk pending approval.
12:04:26
10 Q.
Did he ever tell you anything about his own role in
11 reviewing and preparing the annual reports?

12 A.
I know that he had -- always had a letter in it that
13 he wrote himself and that he looked to make sure that all

14 of the printing was correct and the information included
12:04:43
12:04:51
12:04:56
15 and it was correct before he signed off on it.

16 Q.
Were the annual reports always issued on time?
17 A.
No.
18 Q.
What were you told about why not?
19 A.
Because Mr. Stanford hadn't --
20
MR. FAZEL: Objection. Hearsay.
21
THE COURT: Hold it. Excuse me.
22
MR. FAZEL: Object to hearsay.
23
THE COURT: Ask your question again.
24
Don't answer the question.
25
Ask it or you can rephrase it, if you have

647
1 to.
2
MR. STELLMACH: I'll rephrase.
3 BY MR. STELLMACH:
4 Q.
12:05:03
Did Mr. Stanford ever explain why the annual reports
5 weren't coming out on time?

6
THE COURT: Yes or no.
THE WITNESS: Yes.
THE COURT: Next question.
9 BY MR. STELLMACH:
12:05:07
10 Q.
11 A.
That he had not signed off on them until he had the
12 opportunity to review them thoroughly.

13
MR. STELLMACH: And I'm showing the witness
14 what have been marked for identification -- or what are

12:05:20
15 Government's Exhibits 100 through 115. These are the

16 annual reports for the bank from 1987 through 2002. We're
17 only going to look at one or two.
18
MR. FAZEL: Your Honor, we have the same
19 objections as to the quarterly reports.

12:05:41
20
THE COURT: Now, are you saying that these are
21 not accurate, that these are not the annual reports of the
22 bank?
23
MR. FAZEL: I'm saying that they need to prove
24 foundation, and they're hearsay. It's out-of-court

12:05:52
25 statements brought into the court.

648
MR. STELLMACH: It's an out-of-court-statement,
2 Your Honor, not offered for the truth. We don't believe

3 those statements are accurate.
4
12:05:59
THE COURT: Wait a second. Now, you're
5 saying -- are you saying that these are not the bank
6 records -- that these are not the annual reports of the
7 bank's?
12:06:07
MR. FAZEL: What I'm saying --
THE COURT: Are you saying that? Yes or no.
10
MR. FAZEL: I'm saying I don't know until they
11 lay the proper predicate.

12
THE COURT: Have you taken a look at that?
13 They gave you all their exhibits, didn't they?
12:06:14
14
MR. FAZEL: It's --
15
MR. STELLMACH: Before the trial started.
16
MR. FAZEL: I object to the sidebar.
17
THE COURT: Sustained. Let him finish. He's
18 entitled.
19
12:06:22
20
Go on.
MR. FAZEL: My objection is to -- like any
21 other evidence, Your Honor, when they come in and want to

22 put in evidence in front of the jury, they need to go
23 through certain --
12:06:30
24
THE COURT: Well, let me ask you this, then --
25

649
THE COURT: -- are you telling me that you
2 object because those are not authentic documents?
12:06:37
MR. FAZEL: I think --
THE COURT: You know it. It's -- don't you?
5 You've had them. Did you file any formal objections to

6 that?
7
MR. FAZEL: Of course I did.
THE COURT: All right. Then we're going to do
9 it right now, prove it all up, because they'll have to do

12:06:46
10 the same thing.

11
Have a seat.
12
I'm saying you need to prove it up. Go
13 on.
14
12:06:54
MR. STELLMACH: Your Honor, I think I have
15 proper to basis for the documents coming in for a

16 nonhearsay purpose.
12:07:04
17
THE COURT: Say it again.
18
MR. STELLMACH: We're not offering --
19
THE COURT: Those are the annual reports. So
20 why do you have to qualify them?

21
MR. STELLMACH: Well, I'm just establishing --
22 there is no issue regarding authenticity. The witness has

23 established that she's familiar with them. She's reviewed
24 them in the course of doing her job. But in terms of
12:07:17
25 needing to -- meet a hearsay exception, we don't need to.

650
THE COURT: Okay. Offering it again for the
2 limited purpose; is that correct?

3
MR. STELLMACH: For the limited purpose of
4 showing that this is what was witness was shown. I think

12:07:25
5 I've also established a business records foundation if I

6 need to to the extent we were offering anything under
7 803.6.
12:07:34
THE COURT: 6.
MR. STELLMACH: I think the witness has
10 testified she reviewed these documents. She used them in

11 the course of performing her duties, and they were clearly
12 regularly -13
THE COURT: Have they proved it up in the
14 803.6, Counsel?
12:07:42
15
MR. FAZEL: No, sir.
16
THE COURT: Why not?
17
MR. FAZEL: I don't think they laid the proper
18 predicate.
12:07:49
19
MR. STELLMACH: I just explained the predicate.
20
MR. FAZEL: I'm sure this is not the first time
21 he's tried to put evidence in front of a jury. I'm going

22 to guess it's not. And he knows exactly what he needs to
23 do to lay a proper predicate. Ask the question.
24
12:08:00
25
THE COURT: Hang on a second.

Ladies and gentlemen, the clock will keep
651
1 running. I need you to take just a short break. Let me

2 get the screen up. It will be about five minutes, maybe.
3
4
12:09:06
THE COURT: Now, looking at the objections that
5 you filed on January 17th, 2012, it's a total of 34 pages,

6 and in almost every single one of their -- every single one
7 of their exhibits, no agreement on anything. It's all
8 whys. That means you object on authenticity and
9 admissibility. All you did, apparently, was run off every
12:09:40
10 single document they had and object to every single one.

11
Are you saying not one of these can be
12 agreed to as to authenticity or admissibility? Every

13 single one. That's what it says here.
14
12:09:54
MR. FAZEL: I recall very well, because, Your
15 Honor, we spent a lot of time doing that. First of all, I

16 would submit to the Court the characterization that we ran
17 it off is not correct. What we did -18
THE COURT: By the way, let the record reflect
19 the jury is out of the room.

12:10:04
20
21
I see almost no ends for no objection.

MR. FAZEL: There is a few, but this is a paper
22 intensive case, as the Court knows. Each one of -- all

23 their exhibits are paper related or picture related.
24 There's exhibits that we let in without objecting. The
12:10:18
25 Court heard us do it.

652
THE COURT: All right. Let me put it to you
2 this way: Both sides have pros on here. If you don't

3 agree to anything, that's your absolute right. But
4 apparently you're agreeing to nothing in this case. Do you
12:10:33
5 think that rises to obstruction just for the sake of being

6 obstructionist?
12:10:42
MR. FAZEL: Absolutely not.
THE COURT: All right. Government.
MR. COSTA: A few points. First of all, every
10 lawyer is bound to make objections in good faith. To say

11 these annual reports aren't authentic when they've had them
12 for years and they're their client's annual reports, it's
13 not in good faith.
14
12:10:54
Secondly, we followed the rules in this
15 case. We submitted a reasonable number of exhibits at the

16 deadline and gave them copies of exhibits. They filed
17 untimely objections. And this Court said at the hearing
18 last week that given that they didn't make any targeted
19 specified objections --
12:11:08
20
THE COURT: Nothing at all was --
21
MR. COSTA: -- objected to 98 percent of
22 everything, that everything was preadmitted, it's in

23 evidence, and they can on -- specify the occasions when
24 they really have a true issue with something and object to
12:11:16
25 it.
653
We have one side here following the rules.
2 They're not. I've never seen a case like this where one
3 side can just not follow the rules.
4
12:11:27
And this Court already said these are in
5 evidence, and I don't think that you should go back on

6 that.
7
THE COURT: Well, I'm not going back on it, but
8 I did state if they have -- that I believe they were not

9 timely filed, and it just looks like an across the board
12:11:37
10 that might rise -- and I'm not saying it does -- to

11 obstructionism, okay? And I'm not saying anything as far
12 as ethics go at this point. But what I'm saying is if we
13 don't reach a middle ground, I'm just going to make a
14 ruling across the board.
12:11:54
15
I think, though, you've got experienced
16 people here. I think you've been licensed with 13, 15

17 years. Mr. Scardino, 40 years. And I see here -- and the
18 record will speak for itself here and on appeal -19 objecting to almost every one of your 400 exhibits, almost
12:12:11
20 every one.
21
MR. COSTA: And if there's a good faith basis
22 for Mr. Scardino, as you said on that list, saying these

23 aren't authentic, I think we -- you should ask to hear it.
24
12:12:20
THE COURT: Absolutely. But he's saying he
25 wants everything proved up. And I can't get around that

654
1 without -2
MR. FAZEL: May I be heard --
THE COURT: Let's put it this way -- let's put
4 it this way: If I decide to do that, I need a little

12:12:34
5 briefing on it.
6
MR. FAZEL: May I be heard --
MR. SCARDINO: I want to say something --
THE COURT: And you characterized it, not me,
9 in one of your pleadings, as to a document dump on the

12:12:44
10 other side. Wasn't that the wording you used? One of your
11 writings, something like that.
12:12:51
12
MR. COSTA: I think that's their exhibits.
13
THE COURT: That's right, as to their exhibits.
14
MR. SCARDINO: Can I be heard on the matter,
15 Judge?
16
17
THE COURT: You will in a moment, all right?

Now, anything from the government on this
18 point?
19
12:13:00
MR. STELLMACH: Your Honor, only with respect
20 to the business records and the documents of the bank,

21 we've established, I think, authenticity, and we're not
22 offering them for the truth. We're offering them for their
23 falsity.
24
12:13:10
THE COURT: But then again you'll have to --
25 no, you haven't proved them all. They want document by

655
1 document. Or in here, the -2
MR. COSTA: The whole side.
THE COURT: -- they're objecting to their
4 own -- what is it -- their own annual reports.

12:13:20
MR. STELLMACH: And -- but the witness has
6 testified she's familiar with those 15 years of reports.

7
THE COURT: I understand. But what I'm doing
8 here is trying to shortcut it, because it's the last time

9 we're going to talk about it.
12:13:32
10
MR. STELLMACH: I would like to shortcut it,
11 Judge.
12
THE COURT: All right. Response now.
13
MR. SCARDINO: Your Honor, first of all, they
14 don't notify us that they plan to introduce these exhibits

12:13:41
15 not for the truth of the matter. So when we look at the

16 exhibits, we have no idea that that's going to be the basis
17 for offering the exhibits.
18
MR. COSTA: Our whole case is that these were
19 false, and that's what -12:13:51
20
MR. FAZEL: I'm sorry. If we can respond.
21
MR. COSTA: We have a whole --
22
THE COURT: Hold it. Let them respond.
23
MR. SCARDINO: The Court's right, we've got a
24 lot of experienced lawyers. We spent a lot of time going

12:14:01
25 over all these exhibits, and we just didn't think it was in

656
1 our client's best interest to let all of the government's,

2 exhibits, which is the basis for their case, just come in
3 without any objections.
12:14:10
THE COURT: But you're objecting to everything.
MR. SCARDINO: Because there was no real way to
6 separate one from the other. The way they presented it to

7 us, if we don't object to foundation and hearsay, then we
8 don't have objections.
9
12:14:20
12:14:26
THE COURT: He does.
10
MR. STELLMACH: We specifically categorized --
11
THE COURT: Hold it.
12
MR. STELLMACH: -- all the exhibits.
13
THE COURT: I want to hear him.
14
MR. STELLMACH: All of those 400 plus exhibits
15 proposed by the government were specifically categorized

16 precisely so they could conduct a targeted series of
17 objections. They didn't do that. And now --
12:14:36
18
MR. FAZEL: That's incorrect.
19
MR. STELLMACH: -- we're paying the price with
20 our time in front of the jury.

21
MR. FAZEL: That's incorrect. They were
22 characterized as to subject matter. They weren't

23 categorized as to what is hearsay or what is not as in what
24 is coming for the truth of the matter asserted and what is
12:14:44
25 not. If I can continue, Your Honor.

657
THE COURT: Let him go. Let him continue.
MR. FAZEL: I take severe umbrage as to the
3 ethics issue with the prosecutors. It seems like these

4 prosecutors -- every time they don't get their way or every
12:14:54
5 time we object, they have a ethics problem with us, and I

6 have a huge problem with that. That's number one. It was
7 timely filed.
8
And, number two, we did what we're
9 ethically bound to do, that is, we are to object to this

12:15:04
10 evidence coming in, specifically because their entire case

11 is paper related. And today there were photographs that
12 came in that we didn't object to, and there are certain
13 documents that we're not going to object to.
14
12:15:16
But for the Court to expect us not to
15 object or do our job like we're supposed to do just because

16 the government says so, I would take objection to that as
17 well.
18
MR. SCARDINO: Let me add a little something to
19 that, if I can.
12:15:25
20
21
MR. SCARDINO: Judge, this case is so different
22 that when you asked me one time about -- when we submitted

23 our exhibits, you asked me, in my experience, have you ever
24 had a case like this, and I said no.
12:15:33
25
And one of the problems that the defense

658
1 has always had is that we have not had access to the person
2 that might be able to tell us what the document meant or
3 whether or not we could formulate an objection to it or
4 whether or not it was something we agreed to and even
12:15:46
5 wanted in to help us present our case.

6
THE COURT: Did you -- did they timely file all
7 their 400-some-odd exhibits with you?
12:15:57
12:16:03
MR. SCARDINO: They did.
THE COURT: Did you timely file all of your
10 exhibits with them?

11
MR. SCARDINO: We did not.
12
THE COURT: All right.
13
MR. COSTA: And the objections were untimely.
14
THE COURT: The objections were under --
15
MR. COSTA: First of all, I will never used the
16 word "ethics." I said there wasn't a good faith basis for

17 challenging the authenticity of those documents sitting
18 right there.
12:16:09
19
THE COURT: Okay.
20
MR. COSTA: If Mr. Fazel wants to defend his
21 good faith basis, let's hear it.

22
THE COURT: This is what we're going to do.
23 We've got to get the case moving, get the jury back out.
24 They can object to each and every document, or in this case
12:16:22
25 with all the annual reports, and I'll rule on it, okay?
659
1 Lay the predicate on each one.

2
What I want you to do, if there is any --
3 what is it -- case law on this, let's see what some other

4 courts have stated in similar cases or what Appeals Court
12:16:37
5 or the U.S. Supreme Court, for that matter, in where

6 there's such an objection to everything.
7
I think somewhere, I don't know if it was
8 state court or federal court, there was something when in

9 effect objections were so broad as to almost everything,
12:16:52
10 that indeed it runs into a separate category of its own.

11 I've been doing this for 33 years, I've never come across
12 anything like -- where it's almost objection to everything,
13 and you filed yours timely and they didn't file theirs
14 timely. However, I don't need -- want to hear either side.
12:17:10
15 You're both advocates. As of now, prove everything up.

16 Every time they have an objection, make sure the predicate
17 is laid. If it's a limited offer, we'll do it until I see
18 if there's any other guidance you can give me. That's the
19 safest way to do it.
12:17:24
20
By the way, as far as I can see anything
21 else, they have an absolute right to object to every piece

22 of paper coming in.
23
MR. STELLMACH: And we don't question that,
24 Judge.
12:17:31
25
THE COURT: Okay.

660
MR. STELLMACH: Just with respect to this
2 category of documents, I think we have offered a limited -3 we're making a limited offer.
4
12:17:40
12:17:45
THE COURT: You can make it, and then we're
5 going to do again.
6
MR. STELLMACH: Yes, Your Honor. I understand.
MR. FAZEL: May I make a suggestion?
THE COURT: Yes.
MR. FAZEL: If the government agrees that it's
10 being offered for limited purposes, which they have not

11 agreed so far, as to a category of document, let him make
12 that agreement.
13
And let me say something else, also, that
14 there are documents that we are going to agree to. We just

12:17:56
15 haven't gotten to those documents yet.

16
And third of all, Your Honor, I don't know
17 of any other way to object ahead of time to paper documents

18 coming in other than saying predict and hearsay, because
19 that's where they are.
12:18:08
20
THE COURT: Oh, sure, I've seen it all the time
21 that you say you get down, and in the area it says reasons
22 for it, it's not just over and over foundation, hearsay,
23 confrontation clause; foundation, hearsay, confrontation
24 clause.
12:18:23
25
It's like what we used to do in state

661
1 court when you had -- before your time and just before my
2 time, every time you had an objection to a single issue
3 going to the jury, you object because it's -- there's no
4 evidence, insufficient evidence, it gives a great weight
12:18:41
5 and preponderance of the evidence. The next one that you

6 offer, you heard the same thing, the same thing. Then the
7 Court said you can go A, B, C; A, B, C, and you did it to
8 every single one -9
12:18:52
10
MR. FAZEL: The local rules -THE COURT: -- and the rules were modified.
11 That's in state court.

12
MR. FAZEL: The local rules require us to make
13 an objection according to Rules of Evidence, and so we did.
12:19:00
14
THE COURT: You got it. You're right.
15
MR. COSTA: Which were untimely. And if
16 Mr. Fazel says they didn't know we were offering these to

17 prove what investors were told, that's the whole
18 Section 100. It says that. If he doesn't understand that,
19 I don't even know where to start.
12:19:11
20
THE COURT: Well, no, stop.
21
MR. FAZEL: He needs to say it on the record
22 that it's being offered not for the truth of the matter but
23 for --
12:19:16
24
MR. STELLMACH: I did.
25
MR. FAZEL: Not for every single document.

662
1 It's not funny.
12:19:27
MR. COSTA: He's got it.
THE COURT: I know.
MR. COSTA: I don't read it from --
THE COURT: Counsel, everybody. That's it.
MR. FAZEL: I know how to read.
THE COURT: This is the only time we're going
8 to have this kind of a visit. He's entitled to do it. I'm

9 going to allow him to do it. Just keep in mind, because
12:19:38
10 when they get -- if they put a case on, they get a lot more
11 exhibits than you. The time is going to go, and at the end
12 of the time, each side do it.
13
And as far as the government is concerned,
14 tighten it up on proving up the reason you're doing it and

12:19:53
15 the basis for it. And he's entitled to get up and object
16 if they say you haven't laid the proper predicate. I'll
17 listen to each one, consider each exhibit. He has an
18 absolute right to do that. Aside from the heat that's
19 going on back and forth here, we've all -- you know, that's
12:20:09
20 what's unique about the trial practice, it's different than

21 any other area of the law.
22
But we're going to get the jury back in.
23 I'll entertain every objection he has, which is his right,

24 and then if we can narrow it down -- don't start visiting
12:20:24
25 with him. You can visit with him during the noon hour.
663
MR. FAZEL: He can visit with me during the
2 noon hour.
3
THE COURT: Let's call the jury back in, shall
4 we?
12:20:31
THE COURT: Thank you. Be seated.
Now, you may proceed. Go right ahead,
8 sir.
9
12:21:49
11 Q.
Ms. Chambliess, before the break, we were asking
12 about your familiarity with the annual reports issued by

13 the bank for 1987 through 2002, the years when you worked
14 there?
12:22:02
12:22:07
15 A.
Yes.
16 Q.
Or rather worked for Mr. Stanford?
17 A.
Yes, sir.
18 Q.
And were you familiar with the annual reports?
19 A.
Yes.
20 Q.
And you're familiar with each of the annual reports
21 for the years you were there?
12:22:20
22 A.
Yes. I received copies of each of these.
23 Q.
And who did you share them with?
24 A.
With my clients and prospects.
25
MR. STELLMACH: Your Honor, we offer those

664
1 documents for the limited purpose of showing what the

2 witness was told and what was communicated to clients.
12:22:28
MR. FAZEL: No objection.
THE COURT: No objection on those grounds, for
5 that limited purpose.

6
Go right ahead.
MR. STELLMACH: Thank you.
8 BY MR. STELLMACH:
9 Q.
12:22:39
Turning to Government's Exhibit 112, the annual
10 report for 1999, if we could turn to Page 26. I think it

11 may be Page 30 -- yes, that's right.
12
It reads, "Auditor's Report to the Members."
13
Can you tell us, Ms. Chambliess, what an
14 auditor is.
12:23:09
15 A.
An auditor can be an employee of a company or someone
16 who has contracted on the outside to review the accounting

17 of the company.
18 Q.
Did Guardian International Bank and later Stanford
19 International Bank have an outside auditor, an independent

12:23:29
12:23:37
20 accounting firm?
21 A.
Yes.
22 Q.
Do you know the name of the firm?
23 A.
CAS Hewlett.
24 Q.
And did Mr. Stanford ever explain to you why a bank
25 owned by one person had an auditor reviewing its financial

665
1 reports?
2 A.
It was standard practice for banks to have an outside
3 auditor.
4 Q.
12:23:47
And was that something you discussed with your
5 clients, the fact that the bank had an auditor checking

6 its books?
7 A.
Yes.
8 Q.
And if I could ask you to turn to the auditor's
9 report and just read that one for us.

12:23:59
10
THE COURT: Which one does it come from?
11
MR. STELLMACH: It's Government's Exhibit 112,
12 Your Honor.
12:24:09
13
THE COURT: Okay.
14
MR. SCARDINO: I'm sorry, Counselor. What
15 page?
16
MR. STELLMACH: 112. It's on Page -- it's
17 actually on Page 26 of the document.
12:24:13
18
MR. SCARDINO: Thank you.
19
20
THE WITNESS: Did you want just the first
21 section, I'm sorry, or the whole page?

12:24:18
23 Q.
Yes. Please, ma'am.
24 A.
"The Auditor's Report to the Members."
25
"We have audited the financial

666
1 statements" -- excuse me -- "on Pages 12 to 25.

2 Respective responsibilities of directors and auditors.
3
"As described on Page 27, the company's
4 directors are responsible for the preparation of the

12:24:36
5 financial statements. It is our responsibility to form an

6 independent opinion based on our audit of those statements
7 and to report our opinion to you."
8 Q.
And if we could go to the second page, to the portion
9 directly below that, "Basis of opinion."

12:24:52
10 A.
"We conducted our audit in accordance with
11 international auditing standards, which include

12 examination on a test basis of evidence relevant to the
13 amounts and disclosures in the financial statements. It
14 also includes an assessment of the significant estimates
12:25:08
15 and judgments made by the directors in the preparation of

16 the financial statements and of whether the accounting
17 policies are appropriate to the bank's circumstances
18 consistently applied and adequately disclosed."
19 Q.
12:25:25
In the first sentence there, it says they conducted
20 an examination on a test basis.

21
Did you have any understanding about what
22 that meant?
23 A.
"Test basis" means that they would take random
24 samples. In a commercial bank, it could be of the loans

12:25:37
25 on the books. In this case it would be investments,

667
1 statements from different money managers, to match them

2 against what they were being provided by the directors.
3 Q.
And if we could just turn to the paragraph
4 immediately next to it and jump to the conclusion, what

12:25:55
5 the opinion was of the auditor regarding the bank

6 statements.
7 A.
"In our opinion, the financial statements give a true
8 and fair value of the state of the company's affairs as of

9 31 December 1999, and of the results of its operation for
12:26:10
10 the year then ended. They have been prepared to comply

11 with international accounting and financially reporting
12 standards and the company's law of Antigua and Barbuda."
13 Q.
During the time that you worked for Mr. Stanford, was
14 CAS Hewlett, the name directly before below that.

12:26:29
15
MR. STELLMACH: If we could scroll down just a
16 little bit, please.

17
Thank you.
19 Q.
12:26:39
CAS Hewlett, chartered certified accountants and
20 registered auditors, based in St. John's and Antigua, was

21 that always the accounting firm for the bank?
22 A.
Yes.
23 Q.
And during the time that you worked there, did they
24 always sign off on the bank's financials?

12:26:49
25 A.
Yes.
668
MR. STELLMACH: And if we could take that down.
2 BY MR. STELLMACH:
3 Q.
Prior to working for Mr. Stanford, had you ever heard
4 of this CAS Hewlett accounting firm?

12:27:01
5 A.
No.
6 Q.
Did Mr. Stanford ever tell you anything about the
7 size of that firm?
12:27:07
12:27:14
8 A.
It was a very small firm.
9 Q.
How big?
10 A.
I believe just a couple of, two or three employees.
11 Q.
Do you know where it was based?
12 A.
In St. John's.
13 Q.
In Antigua?
14 A.
Uh-huh.
15 Q.
Was the fact that the Hewlett firm was auditing the
16 bank ever a source of concern with your clients?

17 A.
Yes, it was.
18 Q.
And what -- did you discuss those concerns with
19 Mr. Stanford?
12:27:27
20 A.
Yes, I did.
21 Q.
And what did you tell him you were hearing from your
22 clients?
23
MR. FAZEL: Objection to hearsay, Your Honor,
24 as to what she said her clients were saying.

12:27:35
25
MR. STELLMACH: It's being -Johnny C. Sanchez, RMR, CRR - jcscourtreporter@aol.com
669
THE COURT: Rephrase the question. Let me hear
2 it again. I'm sorry.

3
MR. STELLMACH: Sure, Your Honor. I asked:
4 What did you tell Mr. Stanford you heard from your clients?
12:27:44
5 It goes to the defendant's state of mind. It's not being

6 offered for the truth, just for the fact that the words
7 were repeated to Mr. Stanford.
8
THE COURT: I'm not talking -- I sustain as to
9 the form of question. Just give the essence of what was

12:27:54
10 said, rather than the words.

11
MR. STELLMACH: That's fine.
13 Q.
What did you tell -- what was -- what did you express
14 to Mr. Stanford regarding the CAS Hewlett accounting firm?

12:28:09
15 A.
It was not a firm that was recognized by the clients
16 as an Arthur Andersen or a similar company would have

17 been.
12:28:20
18 Q.
And what did Mr. Stanford say?
19 A.
That he was satisfied with the service that he was
20 receiving and did not see any reason to change.

21 Q.
Did he say anything else regarding the importance of
22 the bank to Mr. Hewlett?
12:28:34
23 A.
No.
24 Q.
In terms of whether the bank was a large client or a
25 small client?
670
12:28:51
1 A.
That the bank was his largest client.
2 Q.
Mr. Hewlett's largest client?
3 A.
Yes.
4 Q.
And if we turn to Page 10 of the annual report, it's
5 a letter -- it reads "Letter from the Chairman."

6
Who was the chairman of the board by this
7 point? We're in what year again?
12:29:06
8 A.
1999.
9 Q.
And by this time, who was the chairman? It had been
10 Mr. James Stanford.

11 A.
I believe it was now R. Allen Stanford. Allen
12 Stanford was now chairman.

13 Q.
In the section of the letter entitled "Financial
14 Review," could you turn to the paragraph beginning, "In

12:29:28
15 1999." I think it's a little further down. The one at

16 the very top.
12:29:37
17 A.
The right column?
18 Q.
Yes.
19 A.
"In 1999, professional management and administrative
20 fees increased 18.35 percent to $10.2 million.

21 Professional referral fees increased 23.29 percent to
22 $14.08 million. General expenses, which include
23 utilities, repairs and maintenance, increased
24 23.76 percent to 2.50 million."
12:30:00
25 Q.
What did you understand the bank was paying -- or who

671
1 the bank was paying professional management and

2 administrative fees to?
3 A.
Those were fees that went to Stanford Financial Group
4 to handle accounting, the marketing services and other

12:30:18
5 ancillary services.
6 Q.
What did Mr. Stanford tell you about whether he was
7 taking any money out of the bank other than the management
8 and administrative fees that were disclosed in the annual
9 reports?
12:30:30
10 A.
He told us that was the only money that was going out
11 and it flowed to Stanford Financial Group, that he was not

12 paid by the bank.
13 Q.
But what about his salary and any other earnings he
14 made?
12:30:43
15 A.
He was paid by Stanford Financial Group.
16 Q.
So the administrative fees that Stanford Financial
17 Group is charging the bank also included Mr. Stanford's

18 owner salary?
12:30:55
19 A.
Yes. A portion of it.
20 Q.
At some point, though, did you learn whether the bank
21 had ever made a loan to Mr. Stanford personally?
12:31:08
22 A.
Yes.
23 Q.
All right. Could you tell us how you learned that?
24 A.
When the annual report came out, there was a loan
25 disclosed in it.
672
1 Q.
And if we could turn -- and the annual report you're
2 referring to, if we could turn to Government's

3 Exhibit 109, the 1996 annual report.
4
12:31:21
THE COURT: Don't put it up yet. See if
5 there's any objection?

6
MR. STELLMACH: Oh. I --
THE COURT: It's a part of the --
MR. STELLMACH: Yes. This was the limited
9 offer.
12:31:26
10
THE COURT: Of the group of --
11
MR. STELLMACH: That entire stack of annual
12 reports, Judge.
13
THE COURT: I'm sorry. You may put it back up.
12:31:32
15 Q.
Turning to Page 13 of that annual report,
16 Ms. Chambliess -17 A.
Uh-huh.
18 Q.
And we're going to pull it up on the screen too. You
19 can follow along with the hard copy.

12:31:42
20
There's a section entitled "Advances to
21 Directors, Officers and Affiliated Entities.

22
MR. STELLMACH: If we could just blow up that
23 bottom paragraph.
12:31:58
25 Q.
Could you read that to us, please.

673
1 A.
"At 31 December 1996, the bank had extended credit to
2 R.A. Stanford, an officer and director, in the aggregate

3 amount of $13,582,579. Additionally, at year end, the
4 bank held notes due from two affiliates. At 31 December
12:32:21
5 1996, Stanford Development Corporation's note payable to

6 the bank was $5,655,795, and Stanford Financial Group,
7 Limited's note payable to the bank was $5,447,204. The
8 terms call for repayment in full in 24 months or less. In
9 the view of management, all credit transactions executed
12:32:47
10 between the bank and such related parties are in the

11 ordinary course of business and extended on equitable
12 terms and conditions as similar transactions with
13 unaffiliated persons."
14 Q.
12:33:02
12:33:12
12:33:22
How did you first learn that Mr. Stanford had
15 borrowed money from the bank?

16 A.
When I read the financial statement.
17 Q.
Were you surprised?
18 A.
Yes.
19 Q.
Did you discuss that disclosure at all with
20 Mr. Stanford about the loan?

21 A.
Yes. We -- we discussed it with him as a group.
22 Q.
When you say "we," who was in this group?
23 A.
The other marketing representatives and myself.
24 Q.
And what was said to Mr. Stanford?
25 A.
That we were concerned.

674
MR. FAZEL: I'm sorry. Objection to hearsay as
2 to anybody other than this witness.

3
MR. STELLMACH: Again, it goes to the words
4 were simply repeated to Mr. Stanford when she was present.

12:33:35
THE WITNESS: I said --
THE COURT: Hold it. Wait a second.
MR. STELLMACH: It's not being offered for the
8 truth, just for the fact that the words were said to
9 Mr. Stanford.
12:33:43
10
MR. FAZEL: There's a relevance issue.
11
12
MR. FAZEL: Then there's a relevance issue as
13 well. I object to that.

14
12:33:49
MR. STELLMACH: Well, it wouldn't be
15 irrelevant. It would go to his state of mind.

16
THE COURT: Overrule on irrelevant.
17
See if you can rephrase it. If you can't,
18 I'll rule on it.
12:33:56
19
MR. STELLMACH: Okay.
20
THE COURT: You know, parse it down a little
21 bit.
22
12:34:03
24 Q.
You were present in this meeting?
25 A.
Yes.
675
1 Q.
Other -- with the other financial advisors?
2 A.
Yes.
3 Q.
And this loan was a topic of discussion with
4 Mr. Stanford?
12:34:10
5 A.
Yes.
6 Q.
What did you say to Mr. Stanford about the loan?
7 A.
I didn't understand why we had not been told, I had
8 not been told about this loan, and that I only found out
9 about it through the report because it went against what
12:34:27
10 we had been told, that the funds were all being invested
11 in liquid assets, and that loans, commercial loans were
12 not being made.
13
THE COURT: All right. Next question. Go
14 question and answer.

12:34:37
15
17 Q.
What did Mr. Stanford say?
18 A.
He said that it was an exceptional case, that he had
19 put up his personal assets, liquid assets, to guarantee

12:34:48
20 this loan, and that there wasn't any risk, and that it
21 would be paid off in short-term before the 24 months.
22
THE COURT: Did you ever see any documents
23 supporting that?
12:34:56
24
THE WITNESS: No, sir.
25
THE COURT: Okay.

676
1 BY MR. STELLMACH:
2 Q.
And after the 1996 annual report, did the loan
3 continue to get reported?
12:35:04
4 A.
Yes.
5 Q.
And jumping ahead to 1999, so three years later --
MR. STELLMACH: So if we can go to
7 Government's 112, I'm looking at Page 21, which is Page 25

8 I think in the system.
9
12:35:32
And if we could enlarge that section in the
10 middle of the page entitled "Advances to Directors,

11 Officers and Affiliated Entities."
12:35:46
13 Q.
Do you see that, Ms. Chambliess?
14 A.
Yes, I do.
15 Q.
Could you read that for us?
16 A.
"On 31 December 1996, the bank extended to
17 R.A. Stanford, a director, a loan in the amount of

18 $13,582,579 for a period of 24 months. This loan had a
19 balance of 4,800,000" -12:36:01
20
THE COURT: Slow down a little bit, please.
21
THE WITNESS: Okay. I'm sorry.
22
THE COURT: People have a tendency to speed up
23 when they're read. The court reporter still has to take it

24 down.
12:36:08
25

677
THE COURT: Go right ahead.
THE WITNESS: "This loan had a balance of
3 $4,800,000 at 31 December 1998. During the bank's fiscal

4 year 1999, the note was paid in full. Interest paid on
12:36:27
5 this loan during 1999 totaled $480,000. In the view of

6 management, all credit transactions executed between the
7 bank and such related parties are in the ordinary course of
8 business and are extended on equitable terms and conditions
9 as similar transactions with unaffiliated persons."
12:36:48
11 Q.
So it states there that the loan was repaid in full
12 and the amount of the loan was a little north of

13 $13.5 million.
14
12:37:02
Were you ever told that the amount
15 Mr. Stanford had borrowed from the bank was actually

16 higher than that number?
17 A.
No.
18 Q.
And after that disclosure in 1999, was there ever any
19 other disclosure until you left in 2002 regarding any

12:37:17
20 loans by Mr. Stanford -- to Mr. Stanford from the bank?

21 A.
No, not to my recollection.
22 Q.
And what was your understanding about whether he took
23 out any other money from the bank, other than that one
24 loan that was reported?
12:37:29
25 A.
He was not taking money from the bank, was my

678
1 understanding.
2 Q.
Other than the fees that were being charged by
3 Stanford Financial Group?

4 A.
12:37:40
But that did not flow directly to him. It flowed to
5 Stanford Financial Group. And he was paid from Stanford

6 Financial Group, was my understanding.
12:37:57
7 Q.
Did any of your clients ever visit Antigua?
8 A.
Yes, I had a couple that went.
9 Q.
Could you tell us, when they went down to Antigua,
10 who paid for those trips?

11 A.
One couple went on a cruise ship. It was actually
12 part of one of the stops for the cruise. So they paid for
13 it.
12:38:09
14 Q.
And other clients who went down?
15 A.
And mine all paid their own way.
16 Q.
Were you aware of other clients going down and being
17 paid bay the bank or their trips being covered by the

18 bank?
19 A.
12:38:25
I had heard, but I did not have experience with it.
20
THE COURT: Hold it. Everybody's got -- same
21 point.
22
MR. STELLMACH: Yes, sir.
23
THE COURT: Rephrase the question. Go
24 step-by-step.
12:38:34
25
MR. STELLMACH: Actually, I'm going to -- we

679
1 don't even have to go down that route.

2
THE COURT: All right. We don't have to go
3 down that road.

4 BY MR. STELLMACH:
12:38:41
5 Q.
Did you discuss with Mr. Stanford what your clients
6 told you regarding their trips to Antigua?
12:38:51
7 A.
Yes.
8 Q.
What did you --
9 A.
He always wanted to hear feedback on it.
10 Q.
And as part of the feedback, what did you tell him
11 you had learned from your clients or heard from your

12 clients?
13 A.
The couple that went on the cruise said that they
14 really enjoyed the trip. They were impressed by the

12:39:05
15 facilities at the bank. The bank president actually met

16 them at the dock and gave them a tour himself. And it
17 made them feel better to see the facilities and meet
18 people there on the island.
19 Q.
12:39:22
What about real estate projects that Mr. Stanford had
20 on the island? Was that something you discussed with him

21 in talking about what clients had seen in Antigua?
22 A.
I don't remember if there was anything under
23 development at that time when these clients went down.

24 Q.
12:39:45
Fair enough. Were you aware, though, that
25 Mr. Stanford had any real estate projects going on, on

680
1 Antigua?
2 A.
Yes.
3 Q.
Did you ever ask him how he was paying for those
4 projects?
12:39:52
5 A.
No.
6 Q.
You did not?
7 A.
I did not ask him that point blank, no.
8 Q.
Did he ever tell you how he was paying for those
9 projects?
12:40:03
10 A.
In general discussions in meetings, when he would
11 discuss the projects, it was made clear to us that all of

12 the companies had their own funding and capital to work
13 with.
14 Q.
12:40:18
And what did you understand that to mean in terms of
15 the CD money and these real estate projects Mr. Stanford

16 had?
17 A.
That the bank money stayed at the bank and within the
18 liquid investment portfolio, and the other companies had

19 their own ways of raising funds. In some cases, I believe
12:40:33
20 loans were mentioned.

21 Q.
So did Mr. Stanford ever tell you whether he had any
22 projects, real estate projects, on Antigua that he was

23 funding with CD money?
12:40:44
24 A.
No.
25 Q.
When you told him about this couple that went down
681
1 there and saw things and was very impressed, did he tell
2 you whether, you know, there was a specific project or a
3 restaurant or anything like that that he had built on the
4 island with CD money?
12:40:57
5 A.
No.
MR. STELLMACH: And I wanted to turn back to
7 the org chart, the demonstrative exhibit that we saw just a

8 moment ago. And bring up any of the other companies that
9 are listed there.
12:41:13
11 Q.
So we've already talked about Stanford Development
12 Company.
13
Were you familiar with the other companies
14 that are listed there?

12:41:20
15 A.
Yes.
16
MR. SCARDINO: Which exhibit are you referring
17 to?
18
MR. STELLMACH: This is the demonstrative
19 exhibit.
12:41:28
21 Q.
How are you familiar with those other companies?
22 A.
We either knew people who worked for those companies.
23 Stanford Development Company was already up and running

24 when I joined, and I had interviewed with two of the
12:41:42
25 gentlemen there.
682
Idea Advertising was in Houston. I
2 interfaced with them. They did the financial statements

3 and marketing brochures for the bank.
4
12:41:55
Bank of Antigua, I actually saw that
5 facility when I went to Antigua and met some of the people

6 there.
7
8 Q.
Stanford Group Company.

I'm sorry. Before we move on, what was Bank of
9 Antigua?
12:42:04
10 A.
It was a commercial bank on the island that
11 Mr. Stanford bought. It was on the first floor, and

12 Stanford International Bank was on the second floor of the
13 same building when I went down.
14 Q.
12:42:22
And what was the Bank of Antigua? How did it differ
15 from a commercial bank?

16 A.
It did business on island with people who lived
17 there.
12:42:31
18 Q.
So actual --
19 A.
It had tellers and credit cards and made car loans,
20 that sort of thing.

21 Q.
And Stanford Group Company was the brokerage firm
22 which we've already discussed?
12:42:39
23 A.
Right.
24 Q.
What was the Antigua Sun?
25 A.
That was a newspaper there on the island that

683
1 Mr. Stanford bought.
12:42:53
2 Q.
And the Caribbean Star?
3 A.
Was a local airline that he bought.
4 Q.
Do you know where the Caribbean -- did he ever tell
5 you where the Caribbean Star flew?

6 A.
I'm sure that he did. I don't remember exactly what
7 islands, but I believe that they flew between Antigua and

8 Miami and then a few of the local -- they did island
9 hopping.
12:43:07
10 Q.
And finally, Stanford Coins and Bullion?
11 A.
Uh-huh.
12 Q.
What did Mr. Stanford tell you that business was?
13 A.
That was a business that they opened in order to
14 offer the opportunity to some of the Stanford family

12:43:22
15 companies' clients to be able to invest in precious metals

16 and coins.
17 Q.
Did Mr. Stanford tell you whether any of those
18 businesses that are listed there, the development company,

19 Idea Advertising, the Bank of Antigua, the brokerage firm,
12:43:40
20 the newspaper, the commercial airline, the coins and

21 bullion company, whether any of those companies were being
22 funded in any way with CD money?
12:43:52
23 A.
No.
24 Q.
Would that have surprised you?
25 A.
Yes.
684
1 Q.
Why would that have mattered?
2 A.
Because that goes against the whole philosophy of
3 having liquid assets so that clients could get to their

4 money rapidly if they ever needed to, and it would mean I
12:44:06
5 was misleading the clients.

6 Q.
And if we jump to Government's Exhibit 100, the 1987
7 annual report, I just want to focus very quickly on

8 Page 10 of that report.
9
12:44:24
1987 was the year you started. Is that
10 right, ma'am?
11 A.
Yes, sir.
12 Q.
And right there --
13
MR. STELLMACH: I'm sorry. Previous page.
12:44:40
15 Q.
Under "Total Assets," in the middle -- toward the
16 middle of the page --
12:44:53
17 A.
Uh-huh.
18 Q.
-- could you read the number that was reported there?
19 A.
$14,950,512.
20 Q.
So those were the bank's assets in '87 when you
21 started?
22 A.
Yes, at the end of the year.
23 Q.
And you left reason 2002, and I just wanted to jump
24 very quickly to Government's Exhibit 115, which is the

12:45:09
25 annual report for that year, and the line reading "Total
685
1 Assets" toward the top -- upper third, and the number

2 that's reported there.
12:45:38
3 A.
1,713,000 -- no. 1,713,755,342.
4 Q.
So you had mentioned before that Mr. Stanford, when
5 you started, talked about his vision for growth.

6 A.
Uh-huh.
7 Q.
Did that change at all over time once the bank did
8 reach, you know, the billion-dollar mark?

9 A.
12:45:48
10 Q.
No, never.
Well, toward the end of your tenure working for him,
11 how frequently were you seeing Mr. Stanford?

12 A.
On a quarterly basis, whenever he would come in or we
13 would fly out for quarterly meetings. Occasionally in

14 between, maybe every couple of months when he was in
12:46:07
15 Houston.
16 Q.
And when you did see him, what did Mr. Stanford
17 discuss with you?

18 A.
We would -- because we had been there so long and he
19 knew my family, he'd ask about the kids, how things were
12:46:19
20 going, my husband, or eventually my ex-husband, and then

21 we would discuss business, how the portfolio was going,
22 and how my production was doing.
12:46:32
23 Q.
"Production" meaning what?
24 A.
My sales.
25 Q.
Of?
686
1 A.
My -- of the bank products.
2 Q.
Did Mr. Stanford talk at all about your production in
3 sales of anything other than the CDs issued by his bank?
12:46:48
4 A.
That was predominantly what I sold, was the CD.
5 Q.
And what was that also predominantly what he wanted
6 to discuss?
7 A.
Yes.
8 Q.
In fact, did Mr. Stanford during these meetings ever
9 say anything to you that made you uncomfortable regarding

12:47:02
10 CD sales?
11 A.
The last year or two that I was there, after one of
12 the quarterly meetings, a group of us were standing with

13 him and talking about our sales trips and clients and the
14 challenges of producing, I don't recall who was speaking,
12:47:19
15 but someone was saying they had -16
MR. FAZEL: Objection to hearsay, Your Honor.
17
THE COURT: Well -- sustained as to being
18 nonresponsive. Go question and answer.

19
12:47:33
By the way, let me just ask you a question
20 since it was brought up during the break and I haven't had

21 a chance to visit.
22
Is it too warm in here? Everybody okay?
23 Because we said we'd let the jury decide. Some of us were

24 cool; some of us were warm. I said, well, we're here to -12:47:48
25 you know, see what the jury has to say.

687
MR. COSTA: We're standing.
3 BY MR. STELLMACH:
4 Q.
12:48:02
What did Mr. Stanford tell you that made you
5 uncomfortable?
6 A.
He made the comment in response to statements of
7 challenges and how hard it was finding the right way to

8 make people comfortable with depositing at the bank.
9
12:48:24
He said, "Do whatever you need to do. I
10 don't care how you do it, just do it, but don't tell me.
11 I don't want to know."
12:48:37
12:48:52
12 Q.
Did you challenge Mr. Stanford when he said that?
13 A.
No. I was flabbergasted.
14 Q.
What did you do once he said that?
15 A.
I started floating my resum.
16 Q.
And you left the bank in 2002?
17 A.
Yes.
18 Q.
Could you tell us under what circumstances you left?
19 A.
I was let go because my production was not meeting
20 the level it was expected.

21 Q.
Could you tell us how that came about?
22 A.
I had lost my three largest clients within a
23 six-month period, which was almost -- it was about

24 20 percent of the portfolio that I was managing, and it's
12:49:07
25 very difficult to find clients that are willing to deposit

688
1 5, $6 million at a time.
2
And I, for several things, including that
3 kind of comment, had lost my drive in what I was doing.

4 So one day, Mr. Stanford was in town. He came up to my
12:49:28
5 office and stepped in for five minutes or so, I guess, and

6 again, asked, you know, How are the boys? How are things
7 going? How are you doing?
8
And I told him I was very frustrated. I
9 was having trouble replacing the clients, that I was not

12:49:45
10 satisfied with the way I was doing, and I just -- I didn't

11 know what else to do, how to change it.
12
And he told me -- he said, "You know, I
13 would have expected -- might have expected this from Elsie

14 or Rocky," who were two of the ladies who started about
12:49:59
15 the same time that I did, he said, "But I never would have
16 expected it from you."
17
And we spoke a little bit after that, and
18 then he left.
19
12:50:11
The next day I got a call from a woman in
20 the HR department asking me to go over to her office, and

21 I did. And then she made a phone call and called the
22 gentleman that I was reporting to at that time who was
23 based out of Miami, and he let me go by phone.
24 Q.
12:50:28
So when you spoke to Mr. Stanford the day before, had
25 he said anything to you about your job being in jeopardy?

689
1 A.
No.
2 Q.
And after you were fired, how did you feel?
3 A.
I was upset. I was frustrated. I was a little
4 frightened. I had children that were financially

12:50:42
5 dependent on me, and I was needing to find a job as

6 quickly as I could. And I was really -- more than
7 anything, I was hurt, because he had been in my office, I
8 was a month short of my 15th anniversary, and I just
9 couldn't understand why he didn't give me the respect and
12:51:02
10 courtesy of telling me himself that I just -- I wasn't

11 cutting it anymore. It's a business decision. I
12 understand that companies do it all the time. But after
13 15 years, I just thought it should have been handled
14 differently. To be told over the phone that I was no
12:51:21
15 longer needed, I thought was pretty cold.

16 Q.
Is that coloring your testimony today?
17 A.
No, it's not. In hindsight and in view of everything
18 and where I am, I'm actually glad it happened when it did.

19
12:51:36
THE COURT: What did you do once you left the
20 Stanford financial organization.

21
THE WITNESS: I cried a lot and put out my
22 resum to as many people as I could. And within, I think

23 it was less than two months, I went to work for Bank of
24 America as a financial advisor.
12:51:51
25
THE COURT: Okay.

690
1 BY MR. STELLMACH:
2 Q.
And then you transitioned out of the financial -- out
3 of the financial sector into healthcare?
12:52:01
4 A.
Exactly.
5 Q.
So what did Mr. Stanford tell you concerning how much
6 of the bank's assets were being invested in the way

7 described in the marketing materials and the annual
8 report?
9 A.
12:52:11
It was --
10
THE COURT: What's the timeframe?
12 Q.
Throughout your tenure working for him.
13 A.
From the day I started till the day I left, it was
14 always my understanding that the financial reports were an

12:52:21
15 accurate record of the way that the funds were being

16 invested, and it was always emphasized to us that they
17 were liquid.
18
12:52:33
In fact, we heard -- I heard --
19
MR. FAZEL: Objection. Nonresponsive.
20
THE COURT: Sustained. Question and answer,
21 please.
23 Q.
What did Mr. Stanford tell you in the 15 years you
24 worked for him about whether he was taking any CD money

12:52:42
25 out of the bank to finance any of his other businesses?

691
12:52:50
1 A.
No, I was never told that.
2 Q.
Would any of that matter to you?
3 A.
Absolutely.
4 Q.
Why is that?
5 A.
Because I was assuring my clients, some of whom --
6 two of whom were godparents to my own children, that their

7 money was safe and it was liquid and they could get to it
8 whenever they needed to.
12:53:07
MR. STELLMACH: I pass the witness, Your Honor.
10
THE COURT: All right. I think this might be a
11 good time to take a break. Usually we take a break

12 until -- from 1:00 to 2:15. Let's do it this way, it's
13 almost 1:00 o'clock. I'm not going to go five minutes one
14 way or another. It's going to make a major difference. I
12:53:28
15 have now it's almost -- you got to remember there's another

16 courtroom here. It's now about five minutes until 1:00.
17 We'll see you back ready to resume at 2:15. We'll see you
18 at that time. You may stand.
12:54:44
19
Let me get that screen up.
20
All right. We'll see you back at 2:15.
21
(Recessed at 12:54 p.m.)
22
23
THE COURT: Thank you. Be seated for a moment,
24 please.
02:16:48
25
What have you discussed relative to

692
1 protection of exhibits for your forthcoming witnesses,

2 please?
3
MR. COSTA: We just had the last five minutes
4 to talk about it. Mr. Parras made a proposal that I think

02:17:00
5 if we would disclose four days before and then two days

6 before they'd give us the exhibits. We haven't had a
7 chance for our team to talk about that. So if he could
8 work at the next break, and maybe by the end of the day
9 raise that issue.
02:17:12
10
THE COURT: No problem.
11
MR. FAZEL: Also, Your Honor, we discussed with
12 the government that there are some exhibits on the

13 government list that we don't object to as well, so we'll
14 try to get that worked out as well.
02:17:20
15
16
MR. FAZEL: I know there's a smile on your
17 face.
02:17:25
18
THE COURT: Few exhibits.
19
MR. FAZEL: We're working on it.
20
THE COURT: Please, sir.
21
MR. SCARDINO: Your Honor, now that you have a
22 smile on your face, there's an issue -- I actually

23 dismissed it earlier. It's something that wasn't that
24 significant, but my client's been complaining that his
02:17:37
25 lunch is a strip of -- a little plastic thing with just

693
1 peanut butter in it and bread. And I wasn't real sure

2 about that, but I actually went and looked at it today, and
3 that is, in fact, what he's given. I respectfully suggest
4 that he needs more protein for a long trial, especially for
02:17:58
5 the afternoon session.

6
Now, I've talked to the marshals, and they
7 say they're absolutely prohibited from him having any

8 outside food. I've got no problem with that. But I
9 understand that the inmates over at the FDC get a regular
02:18:10
10 lunch. If we could just have that brought over, I think

11 the problem is solved.
12
THE COURT: Let me talk to my expert here.
13 We're going to inquire about it during -- as soon as we get

14 the jury in, Ellen will check and see what we can do.
02:18:30
15
MR. SCARDINO: We order in every day.
16
THE COURT: I understand. See what we can do.
17
MR. SCARDINO: If there was some way to share
18 that, it would be great. We share with the marshals.

19
02:18:45
20 about to push the screen down. It's the wrong time.

21
22
23
02:20:29
THE COURT: Okay. Let's call them in. I was
THE COURT: All right. Be seated. All right.

Cross-examination, go right ahead, sir.
24
MR. FAZEL: May I proceed, Your Honor?
25
THE COURT: Yes.

694
Cross-Chambliess/By Mr. Fazel
CROSS-EXAMINATION
2 BY MR. FAZEL:
02:20:34
3 Q.
Ms. Chambliess, good afternoon. How are you?
4 A.
I'll well, thank you. And you, sir?
5 Q.
I'm good. Thank you.
I'm going to assume you've never testified
7 before; am I right?
02:20:40
02:20:45
8 A.
Once.
9 Q.
Once.
10
It's kind of nerve-racking?
11 A.
Extremely, yes.
12 Q.
You're nervous?
13 A.
Yes.
14 Q.
I'm a little nervous, too.
15 A.
Okay.
16 Q.
All right.
17 A.
Good.
18
THE COURT: Don't worry about the noise from
19 time to time.
02:20:50
20
THE WITNESS: Okay.
21 BY MR. FAZEL:
22 Q.
23
Just duck.
If there's anything you don't understand
24 or any questions that I speak too fast, because I'm known

02:20:57
25 to do that, just let me know and I'll rephrase, all right?

695
1 A.
All right.
2 Q.
During your direct examination by the government, you
3 spoke about several things. Initially, you talked about

4 how you were hired, and you were hired for Guardian
02:21:14
5 International Bank or its subsidiary. Do you remember

6 talking about that?
7 A.
Its subsidiary.
8 Q.
Its subsidiary. Okay.
9
02:21:21
I want to talk to you about that briefly.
10 I want to talk to you about how it was set up. About what
11 year were you hired by Mr. Stanford?
12 A.
1987.
13 Q.
1987. All right.
14
02:21:35
I'm going to draw something up here for
15 you, if I can. Can you see that?

16 A.
Uh-huh.
17 Q.
Now --
18
THE COURT: By the way, just for your
19 information, we have lapel mikes available, but we need it

02:22:05
20 fine-tuned to the courtroom. We had it working, and the

21 technician will be here tomorrow. So bear with us just for
22 today, and the lawyers need to speak up. But tomorrow if
23 they do something like this, we'll have a microphone for
24 them. It's just that everything here is and then we need
02:22:21
25 some fine-tuning on that.

696
THE COURT: Hang on. Do you want the light on
3 in that area?
02:22:32
MR. FAZEL: Yes, please.
THE COURT: Wait a second. Hold it. I'm going
6 to switch it. That's new, too. There you go.

7
MR. FAZEL: Your Honor, the screen -- I guess
8 you can leave it down so it doesn't have to come back up

9 and down.
02:22:44
10
THE COURT: Fine.
11 BY MR. FAZEL:
12 Q.
So Stanford Financial Group is actually a company in
13 the United States. Would you agree with that?
02:22:52
14 A.
When I was hired?
15 Q.
Yes, correct.
16
THE COURT: Ma'am, pull the mike to you.
17
THE WITNESS: I'm sorry. Follow me around.
18 BY MR. FAZEL:
02:22:59
19 Q.
Are you good?
20 A.
Yes, I think so.
21 Q.
Stanford Financial Group -- I realize you didn't work
22 for it. My question is: Stanford Financial Group itself

23 was a company registered in the United States; correct?
24 A.
02:23:10
At that time I was not aware of Stanford Financial
25 Group, no.
697
1 Q.
Stanford Financial Group, Limited, was a subsidiary
2 of Stanford Financial Group, and that was incorporated in

3 Montserrat. Would you agree with that?
4 A.
02:23:39
I was not aware of that company when I was hired.
5 Everything -6 Q.
You were --
7 A.
-- was Guardian.
8 Q.
-- not.
9
02:23:43
Everything was Guardian?
10 A.
Uh-huh.
11 Q.
I thought in direct testimony, you testified about
12 the fact that Stanford Financial Group -- what company it

13 was, where it was incorporated, that you had knowledge
14 about that. Are you telling us that you don't now?
02:23:53
15 A.
After Guardian International -- I was hired into
16 Guardian Intentional --
02:24:01
17 Q.
Yes, ma'am.
18 A.
-- the companies went through a name change --
19 Q.
Yes, ma'am.
20 A.
-- and we were rolled into Stanford Financial. It
21 was my impression that Stanford Financial was a company

22 formed for that purpose at that time.
23
THE COURT: Mr. Fazel, hang on one sec. I'll
24 stop the time. Something is rattling around. Something

02:24:15
25 came loose on the easel.

698
Ellen, knows what it is.
MR. FAZEL: Wow, you've got good hearing, Your
3 Honor. You actually heard it?

4
02:24:31
THE COURT: I heard it. A lot of things get on
5 my nerve after all these years. I heard that rattling.

6
MR. FAZEL: Other than lawyers?
THE COURT: Yes.
I don't think you did that on purpose, so
9 I gave you the benefit of the doubt, and I asked Ellen, and
02:24:43
10 she knew exactly what it was.

11
All right, sir. Go right ahead.
12
MR. FAZEL: Thank you, Ms. Alexander.
13 BY MR. FAZEL:
14 Q.
02:24:50
So you have no knowledge of Stanford Financial Group
15 being a U.S. company?

16 A.
Only if it -- that was what the insurance agency was
17 called.
02:24:59
18 Q.
I don't want --
19 A.
In Mejia.
20 Q.
I don't want to testify for you, but you don't know?
21 A.
I don't know.
22 Q.
You don't know that Stanford Financial Group,
23 Limited, was a Montserrat company?
02:25:06
24 A.
No, I do not know that.
25 Q.
You don't know that either?

699
1 A.
No, sir.
2 Q.
Okay. Now, did you know that underneath that
3 hierarchy was two other companies? Now, I will tell you

4 I'm artistically challenged and I can't -- my handwriting
02:25:29
5 is terrible, so tell me if you can't read this.

6 A.
Okay.
7 Q.
Guardian Bank, Limited, Montserrat. You're familiar
8 with that?
9 A.
02:25:53
10 Q.
Guardian International Bank, Limited, yes, sir.

All right. I'm sorry. I stand corrected.
11
And there's Guardian International
12 Investment Services; correct?
02:26:13
13 A.
Yes, sir.
14 Q.
And that was limited as well; right?
15 A.
Yes, sir.
16 Q.
And we know limited is a British term. These are
17 British companies when they're limited. Do you know that?
02:26:21
18 A.
Yes.
19 Q.
So am I correct about that?
20 A.
Yes.
21 Q.
All right. Now, in its inception, that is, when it
22 was formed, were you aware that this did not exist, that
23 the bank did not exist. Did you know that?
02:26:33
24 A.
When?
25 Q.
When Stanford Financial Group, Limited, Montserrat

700
1 was created, did you know that the bank did not exist?
2 A.
I did not know that Stanford Financial Group,
3 Limited, existed.
02:26:43
4 Q.
You didn't know that either?
5 A.
No, sir.
6 Q.
Okay. Did you know what the primary purpose for
7 Guardian International Services, Limited, was?

8 A.
It was my understanding that it was to be the
9 marketing representative for the bank.

02:26:54
10 Q.
Did you know anything about the real estate limited
11 partnerships that were created underneath this?

12 A.
I knew there were some created through Guardian
13 Development.
02:27:07
14 Q.
That's not my question.
15 A.
No.
16 Q.
All right. You had no knowledge that this entity was
17 created in order to facilitate real estate limited

18 partnerships?
02:27:20
19 A.
No, I didn't know that.
20 Q.
Nobody told you about that at the bank?
21 A.
At -- the bank employees, no, sir, none of the bank
22 employees --
02:27:31
23 Q.
Mr. Stanford never told you about that?
24 A.
That that was created for real estate? No, sir.
25 Q.
You seem to know so much about the history of the

701
1 company. I'm just curious. Nobody ever told you about

2 this part of it?
02:27:39
3 A.
Apparently, he did not share that with me, no, sir.
4 Q.
He did not share that with you.
Isn't it true that you went to some of
6 these real estate openings?

7 A.
Not under Guardian International. Those were
8 Guardian Development real estate openings.

9 Q.
02:27:51
Could it be that you're just mistaken?
10 A.
Guardian International --
11 Q.
I'm sorry. The question was -- and I apologize. My
12 question was: Could it be that you're just mistaken?
02:28:21
13 A.
Highly improbable, but, yes, it's possible.
14 Q.
Now, this was during the '80s that this was created.
15 At some point in time when the real estate market started

16 drying up, the bank was created. Did you know that?
02:28:47
17 A.
I know that the bank was created in 1986.
18 Q.
All right. Do you know why it was created?
19 A.
In part, to hold funds for people who were interested
20 in doing entities.
21 Q.
22
I see.
So it was created in part to hold funds
23 for people who were interested in doing what? I'm sorry.

24 I didn't hear the last part?
02:28:59
25 A.
Real estate.
702
1 Q.
Real estate investing?
2 A.
Yes.
3 Q.
I see.
4
02:29:08
Do you know who Mr. Stanford went to to
5 set this up in a legally correct fashion? Do you know

6 what legal law firm?
02:29:20
7 A.
Not right offhand.
8 Q.
Baker & Botts ring a bell with you?
9 A.
I am aware of that law firm.
10 Q.
Did you know that they're the ones that set this up?
11 A.
No, I did not know that.
12 Q.
Now, this entity was created to hold a fund, correct,
13 to hold money, so that when people were interested in

14 it -- investing in real estate, limited partnerships, and
02:29:37
15 because it's real estate, it's not readily available,

16 while the search was going on for the partnerships, the
17 money was kept right here so it was safe; is that correct?
02:29:53
18 A.
I understand that was the original intent, yes.
19 Q.
While you were working there, was that not what
20 happened?
21 A.
No, sir.
22 Q.
It was not?
23 A.
No, sir. Most of the money that went on deposits
24 stayed at the bank.

02:29:59
25 Q.
I'm sorry. That wasn't my question.

703
At some point in time, Guardian
2 Services -- International Services, Limited, started

3 selling what you described as CDs; correct?
02:30:17
4 A.
The bank sold them.
5 Q.
The bank sold them?
6 A.
They were bank instruments.
7 Q.
I know they were bank instruments, but who sold them?
8 A.
We provided the information on that. The
9 certificates were issued out of the bank.

02:30:27
10 Q.
And then who was the sales force that sold the CDs?
11 A.
We were contracted to do that on behalf of the bank.
12 Q.
Who's "we"?
13 A.
The people who were working at Guardian International
14 Investment Services at the time.

02:30:40
15 Q.
So this company had an agreement with this company
16 where this company marketed the CDs, and this company was
17 the owner of the CDs that paid for it.
18
02:31:02
Would that be correct?
19 A.
And they held the funds, yes.
20 Q.
And they held the funds?
21 A.
Yes, sir.
22 Q.
So this company wars created to make sure it
23 preserved clients' funds.

24
02:31:09
25 A.
Would you agree with that?

Yes.
704
1 Q.
Now, in the inception, in the beginning, it was a
2 small company.
3
02:31:17
4 A.
Yes, sir.
5 Q.
When you got hired, how many people were involved in
6 the company?
02:31:24
7 A.
I believe who was the eighth employee --
8 Q.
Eighth employee?
9 A.
-- in Houston.
10 Q.
In Houston?
11 A.
Uh-huh.
12 Q.
And the investments were simple, as well.
13
02:31:32
02:31:45
14 A.
Yes.
15 Q.
There was a relationship with a larger bank; correct?
16 A.
Yes.
17 Q.
That larger bank with JPMorgan Chase?
18 A.
(No audible answer).
19 Q.
Are you familiar with Chase?
20 A.
Yes, I am.
21 Q.
Okay. Good. Where the money flowed to Chase Bank;
22 correct?
02:31:59
23 A.
Yes.
24 Q.
And then it was then invested in short-term
25 securities; correct?
705
1 A.
To my understanding, yes.
2 Q.
Is there any reason you -- do you doubt that? Do you
3 have any personal knowledge that that didn't take place?
02:32:09
4 A.
I do not.
5 Q.
All right. I'm going to kneel. I knew you'd like
6 that.
7
All right. Now, these investments included
8 30-day investments; correct?

9 A.
02:32:28
02:32:35
Once the CD program was brought on, yes.
10 Q.
Correct. They were investments?
11 A.
Uh-huh.
12 Q.
In currency; correct?
13 A.
Uh-huh.
14 Q.
Is that a "yes"? Sorry. He has to --
15 A.
Yes. Well, I'm not quite sure what you mean by
16 "currency."
17 Q.
Were they currency swaps or currency shorting,
18 investments like that?
02:32:44
19 A.
No.
20 Q.
No? What kind of investments were they?
21 A.
That the investments were placed --
22 Q.
Yes.
23 A.
-- according to the materials that I read and what I
24 was told -02:32:50
25 Q.
Yes.
706
1 A.
-- they were in treasury paper, commercial paper,
2 correspondent banks.
02:33:01
3 Q.
Well, this is the correspondent bank?
4 A.
Right.
5 Q.
Right? Okay. But once it want hit the correspondent
6 bank, what happened with the money?

7 A.
It would have flowed from there to the money
8 managers, which were companies other than Chase.

9 Q.
02:33:12
And where were those?
10 A.
Around the world.
11 Q.
Around the world. Switzerland?
12 A.
At one point, I believe they were working with money
13 managers in Switzerland.
14 Q.
02:33:24
And what kind of investments do they do in
15 Switzerland? Was it not currency?

16 A.
Well, a dollar is currency.
17 Q.
It sure is.
18 A.
That's why I'm asking. I don't understand your
19 question.
02:33:31
20 Q.
Were they not investing in currency-type
21 transactions, currency-type investments?

22 A.
They were investing in conservative investments,
23 currency swaps.
24 Q.
02:33:42
25
I understand that's what the government says.

What I'm asking you is your personal
707
1 knowledge. Is it not true you either don't know -- that's

2 fair. That's a good answer, "I don't know" --
02:33:51
3 A.
Uh-huh.
4 Q.
-- or that they were investing in currency
5 transactions in Switzerland?
6 A.
In different -- investing in different currencies?
7 Yes. You can have a CD in a different currency.

8 Q.
Is there anything about this chart that you disagree
9 with?
02:34:05
10 A.
The top two about Stanford Financial --
11 Q.
That --
12 A.
-- I'm not -- that is not part of my recollection.
13 But starting from Guardian International Bank across to

14 Guardian International, that's within my personal
02:34:16
15 experience.
16 Q.
So you have no knowledge of Stanford Financial Group
17 at all?
02:34:26
18 A.
I -- as subsequently, when I became part of it, yes.
19 Q.
Okay. When it was in its inception, you have no
20 knowledge of its formation or how it was formed?

21 A.
No, I do not.
22 Q.
And then I have that marked as 1.
23
Number 2, Stanford Financial Group,
24 Limited Montserrat, you have no information about that or

02:34:36
25 no personal knowledge?
708
02:34:45
1 A.
No, I do not.
2 Q.
But you agree with Level 3 and Level 4; correct?
3 A.
Yes, sir.
4 Q.
All right. And that's accurate? That is exactly
5 what the bank did; correct?

6 A.
To the best of my knowledge, yeah.
7 Q.
And that is exactly what Guardian International
8 Services, Limited, did; correct?

9 A.
02:34:55
As far as --
10 Q.
The CD program --
11 A.
-- offering the CDs on behalf of the bank and also
12 RLP.
02:35:08
02:35:14
13 Q.
The RLP is Real Estate Limited Partnership?
14 A.
We offered them, but we did not put them together
15 ourselves.
16 Q.
17 A.
I'm sorry.
18 Q.
That was offered by the company you were working for?
19 A.
Yes.
20 Q.
Now, let's talk about Montserrat in general.
21
02:35:38
Are you with me?
22 A.
Uh-huh.
23 Q.
Okay.
24 A.
I'm sorry.
25 Q.
That's all right.

709
1 A.
I'm waiting.
2 Q.
I'm doing the same thing.
The bank in Montserrat was a real bank;
4 correct?
02:35:47
5 A.
Yes.
6 Q.
The government put up an exhibit, and I forget the
7 exhibit number, but that's a picture you took of the bank;

8 correct?
9 A.
02:35:53
02:36:00
Uh-huh.
10 Q.
They had people working there?
11 A.
Uh-huh.
12 Q.
They had people taking in money there?
13 A.
Not face-to-face --
14 Q.
I understand.
15 A.
-- but yes, uh-huh.
16 Q.
People came in. People -- folks that wanted to
17 purchase CDs came in and they exchanged information and

18 did what was necessary on Montserrat itself; correct?
02:36:14
19 A.
To a small extent, yes.
20 Q.
All right. Now, do you remember talking about
21 leaving Montserrat and going to Antigua. Do you remember

22 talking about that?
02:36:24
23 A.
Yes, sir.
24 Q.
I'm jumping around a little bit because the
25 timeframe -- I'm trying to put together the timeframe for

710
1 the jury because we started out in Montserrat; correct?
02:36:32
02:36:38
02:36:43
2 A.
Correct.
3 Q.
And the company was real small; correct?
4 A.
Correct.
5 Q.
It was about eight or nine people?
6 A.
Uh-huh.
7 Q.
Is that a "yes"?
8 A.
In Houston, yes.
9 Q.
And how many people were in Montserrat?
10 A.
Two or three, I believe.
11 Q.
So what's the total of that?
12 A.
About 12.
13 Q.
About 12 --
14
THE COURT: What year did it move to Antigua?
15
THE WITNESS: I believe it was around 1990.
16
THE COURT: Okay.
17 BY MR. FAZEL:
18 Q.
When it moved to Antigua, how many people were in
19 Houston?
02:36:49
20 A.
Oh, gosh. Probably double that number.
21 Q.
What number is that?
22 A.
24 or 25 people.
23 Q.
24 or 25.
24
02:37:02
25 A.
And how many people were in Montserrat?

Seven, eight.
711
02:37:11
1 Q.
Okay. So how -- what's the total of that?
2 A.
33.
3 Q.
Okay. So it's a small company.
4 A.
Uh-huh.
5 Q.
Is that a "yes"?
7 A.
Yes, sir.
8 Q.
I'm sorry. You don't have to call me "sir." Just
9 make sure it's a "yes" so that the court reporter -02:37:18
10 A.
It's a southern thing. I can't help it.
11 Q.
I -- I'm with you.
12
And as a result, your interaction with
13 Mr. Stanford was more often; correct?
02:37:27
14 A.
Correct.
15 Q.
All right. As the company got bigger and bigger,
16 your interaction with Mr. Stanford lessened and lessened.

17 Is that correct?
02:37:38
18 A.
Yes.
19 Q.
All right. And then when Mr. Davis came on board, he
20 took on a lot of the responsibilities about investment and

21 the day-to-day activity of the investments of the company,
22 did he not?
02:37:48
23 A.
To my knowledge, yes.
24 Q.
All right. And he was the one that was making
25 decisions on investments. Is that correct?

712
02:38:04
1 A.
Exclusively? I don't know. I don't think so.
2 Q.
He was the one in charge of investments, was he not?
3 A.
He was charged with it, yes.
4 Q.
And while you were in Montserrat and while you were
5 working for the company at the time it was Guardian, you

6 had no reason to believe any graduated was ongoing, did
7 you?
02:38:12
8 A.
No, I did not.
9 Q.
Because if you did, you would have left?
10 A.
Absolutely.
11 Q.
Okay. Now, the government took the position that --
12 or I don't know.
13
Let me ask it to you this way: To your
14 knowledge, was the bank's license in Montserrat revoked?

02:38:28
15 A.
Not to my knowledge.
16 Q.
Not to your knowledge. Okay.
17
Do you recall what tragic event hit
18 Montserrat that was life-changing for the people in

19 Montserrat?
02:38:39
02:38:46
20 A.
They had a really bad hurricane.
21 Q.
Do you remember the came name of it?
22 A.
No I don't.
23 Q.
Could it be Hugo?
24 A.
Could be, yeah.
25 Q.
Do you remember the year that it hit?

713
02:39:04
02:39:12
1 A.
'88 or '89. '89.
2 Q.
Would it be '89?
3 A.
(Answered affirmatively).
4 Q.
When it hit, how bad did it hit the island?
5 A.
It pretty much wiped it out.
6 Q.
It wiped it out?
7 A.
It was very bad.
8 Q.
Did it wipe out the bank as well?
9 A.
It damaged all of the equipment and part of the
10 physical facility, from what I understand.

11 Q.
Was that one of the reasons that the bank was moved?
12 A.
I believe it was part of the reason, yes.
13 Q.
Now, so it wasn't that the government is making it
14 sound like, oh, their license was revoked.

02:39:30
15
There was a huge problem with Montserrat
16 at that time; correct?

17 A.
They had -- were hurt by the storm, yes.
18 Q.
Were you aware that there's a letter from the
19 Government of Montserrat to Guardian Bank asking them to

02:39:44
02:39:51
20 stay? Did you know that?

21 A.
No, sir.
22 Q.
You never saw that letter?
23 A.
No, sir.
24 Q.
Weren't you in some of the board meetings?
25 A.
No, sir.
714
1 Q.
No?
2 A.
No. I wasn't on the board.
3 Q.
I didn't say you were.
4
02:40:01
02:40:15
But what I'm curious. Were you aware that
5 there's notes from the board saying that you attended?

6
MR. STELLMACH: Objection.
MR. FAZEL: I said, "Were you aware?"
THE COURT: Excuse me. Overruled.
THE WITNESS: Now, see, you're making me think
10 back. It's been a long time.

11
It's possible that I may have been asked
12 to speak to the board regarding my work or whatever our

13 department was doing. I really don't recall any details.
14 BY MR. FAZEL:
02:40:43
15 Q.
Do you know who Dora Donnis (phonetic) is?
16 A.
Yes, sir.
17 Q.
Tell us who she is.
18 A.
She started out as administrative aide to
19 Mr. Stanford and then handled office operations for a

02:40:59
02:41:08
20 time.
21 Q.
Was she also not the auditor?
22 A.
Yes, she was, the internal auditor.
23 Q.
Do you have any problems with her being dishonest?
24 A.
25 Q.
Did she audit the bank?

715
1 A.
She performed internal audit.
2 Q.
Well, that included all the bank's functions, did it
3 not?
4 A.
02:41:18
I don't know in detail how she did her job, but that
5 would be -6 Q.
Well, you testified on direct about what auditors do.
02:41:25
Did she not internally audit the bank?
8 A.
To my knowledge, she did.
9 Q.
Do you have any reason to believe --
10
THE COURT: Hold it. Slow down, please. Go
11 on.
12
MR. FAZEL: Sorry.
13 BY MR. FAZEL:
14 Q.
02:41:30
Do you have any reason to believe she's a liar or
15 she's a cheat?
16 A.
I don't know that about her, no.
17 Q.
Now, when the bank moved -- and I'm pushing you
18 forward a little bit.

19
02:41:51
When the bank moved from Antigua -- excuse
20 me -- from Montserrat to Antigua, is it not your

21 understanding that Antigua actually had a more -- a
22 stronger, a more strengthened banking regulatory
23 commission?
02:42:03
24 A.
That was my understanding.
25 Q.
Is there any reason for you to doubt that?

716
1 A.
I have -- don't recall any reason, no.
2 Q.
Is it not called the FSRC?
3 A.
I believe so. Financial Services Review Committee?
4 I don't remember what it stands for.

02:42:25
MR. STELLMACH: Your Honor, I need a reference
6 under 612.
02:42:31
MR. FAZEL: 612.
MR. STELLMACH: 613.
MR. FAZEL: 613, I believe.
10
MR. STELLMACH: 613-A.
11
(Attorneys conferring.)
12
MR. STELLMACH: Do you have a copy for us to
13 follow along?
14
02:42:47
MR. FAZEL: I'm not going to introduce it into
15 evidence.
16 BY MR. FAZEL:
02:43:23
17 Q.
Take a look at this for me for a moment, please.
18 A.
Okay.
19 Q.
Let me know when you're done.
20 A.
Okay.
21 Q.
Ms. Chambliess, do you recall being at the board
22 meeting on August 17, 1987?

23 A.
Not specifically, no; but I know that I was
24 introduced to the board at some point.

02:43:44
25 Q.
Isn't that the time when the auditor, Hewlett and

717
1 company, was introduced to the board?

2 A.
I don't recall.
3 Q.
Isn't that when Mr. Allen -- one of the board members
4 asked that he be the auditor for the bank?

02:43:58
5 A.
I don't recall that.
6 Q.
You don't recall that?
7 A.
No, sir.
8 Q.
The one board meeting that you were -- that you're
9 mentioned, you just don't happen to remember that board

02:44:07
10 meeting? When Hewlett, the auditor, was introduced, you

11 don't remember any of that?
02:44:20
12 A.
Honestly, no, I don't.
13 Q.
You are Michelle Chambliess, are you not?
14 A.
To the best of my knowledge.
15 Q.
Do you know Mr. Peter J. Carr (phonetic)?
16 A.
No. Until I saw that name, I couldn't tell you what
17 he looks like.
02:44:31
02:45:01
18 Q.
How about Mrs. Ethridge, do you know her?
19 A.
Oh, absolutely, yes. We were together many years.
20 Q.
She was there as well, wasn't she?
21 A.
She was introduced to the board, yes.
22 Q.
Let's talk about CDs for a moment.
23 A.
Okay.
24 Q.
All right. Certificate of deposit, it is not a
25 security; correct?
718
02:45:09
02:45:19
1 A.
It can be a security.
2 Q.
It can?
3 A.
Yes.
4 Q.
Okay. Let's go through it. A certificate of deposit
5 is an instrument; correct?
6 A.
Yes.
7 Q.
Where there's a fixed rate of return; correct?
8 A.
Yes.
9 Q.
And that is a -- for a fixed period of time; correct?
10 A.
Yes.
11 Q.
Can you have ownership in a company when you own a
12 CD?
02:45:30
13 A.
No.
14 Q.
Do you have writing votes, in other words, right to
15 volt, when you own a CD?

16 A.
No.
17 Q.
So you're not an investor; you're a depositor;
18 correct?
02:45:38
19 A.
Correct.
20 Q.
CD owners were depositors, not investors?
21 A.
Correct.
22 Q.
Their right was only what was contractually given to
23 them under the CD agreement; correct?
02:45:49
24 A.
When it's directly with the bank, yes.
25 Q.
All right. And, therefore, their obligations and the

719
1 bank obligation is narrowly tailored within that

2 agreement. That is what the CD says they're going to do,
3 and that's it; correct?
02:46:04
4 A.
Directly issued, yes.
5 Q.
All right. Well, were the CDs not directly issued?
6 A.
In this case, but you're asking can it be a security.
7 And if it's sold through a secondary market, it becomes a

8 security.
9 Q.
02:46:16
02:46:28
Oh, I see. So you're saying just because the CD was
10 sold in a secondary market, it becomes a security?

11 A.
You could buy a --
12 Q.
Then I --
13 A.
-- Chase Bank CD, for example, through Merrill Lynch.
14 Q.
I see. And it becomes a security then?
15
MR. STELLMACH: Objection, Your Honor. I think
16 we're asking to ask the witness for a legal conclusion

17 about what instruments qualify --
02:46:33
18
THE WITNESS: Yeah.
19
MR. STELLMACH: -- as securities and which
20 don't.
21
THE COURT: All right. Sustained as to the
22 form of the question.

23 BY MR. FAZEL:
24 Q.
02:46:38
Ma'am, if you don't know the answer, just say "I
25 don't know."
720
1 A.
Well --
2 Q.
If you're not qualified, just say, "I'm not
3 qualified."
02:46:43
4 A.
I answered you to the best of my knowledge.
5 Q.
Fair enough.
6 A.
There are two kinds of CDs that I'm aware of.
THE COURT: Hold it. Next question.
9 BY MR. FAZEL:
02:46:51
10 Q.
Is it your testimony today that simply because a
11 third party sells a certificate of deposit, then it

12 becomes a security?
02:47:04
13 A.
It can become a security, yes.
14 Q.
And, therefore, it's easily tradeable?
15 A.
Not necessarily. They're private securities that are
16 not easily tradeable.
02:47:21
17 Q.
You testified that the CDs were the employees' idea?
18 A.
We shared that information with Mr. Stanford, yes.
19 Q.
Was it your idea to create the CDs?
20 A.
I was in agreement with it, yes.
21 Q.
Not my question.
22 A.
Was it exclusively my idea? Is that what you're
23 asking me?
02:47:30
24 Q.
Let me repeat my question.
25 A.
Please.
721
1 Q.
Was it your idea to create the instrument that we're
2 calling a CD here in court today?

3
MR. STELLMACH: Objection as to form, Your
4 Honor.
02:47:40
THE COURT: Hang on a second. I'm sorry. I
6 didn't pick it up. Pick up the -- stop the clock for a

7 moment.
8
All right. Sorry. Go right ahead. I'm
9 sorry.
02:48:31
10
Do you want to repeat the question or
11 rephrase it?
12
MR. FAZEL: I'll rephrase the question.
13 BY MR. FAZEL:
14 Q.
02:48:40
02:48:49
Did you yourself personally come up with the idea of
15 creating the CD?

16 A.
I proposed it as a product for the bank --
17 Q.
I see.
18 A.
-- if that's what you're asking.
19 Q.
You personally proposed it?
20 A.
I did speak to Mr. Stanford about it, that I thought
21 it was a good idea for the bank to offer a CD.
02:49:00
22 Q.
Okay.
23 A.
Yes, sir.
24 Q.
Anything about that that you thought was fraudulent,
25 misleading or inaccurate?
722
02:49:05
1 A.
About the product itself?
2 Q.
Right.
3 A.
Uh-huh.
4 Q.
It was your idea?
5 A.
No, because it was a product in existence. It's not
6 something that I created myself. It was like if one

7 department store sells shoes, another department store
8 might want for sell shoes to compete.
9 Q.
02:49:22
And the CDs that you wanted to sell in order to
10 compete in the market are fixed rate, fixed time; correct?

11 A.
Yes, sir.
12 Q.
All right. Now, when Guardian became Stanford Bank
13 International in Antigua -- do you remember that?
02:49:37
14 A.
Yes, sir.
15 Q.
-- did it -- and even before that, before you sold
16 these instruments to depositors, did you not ask them to

17 look at documents, review and sign certain agreements and
18 contracts?
02:49:54
19 A.
Yes.
20 Q.
For example, did you not ask them to sign disclosure
21 statements?
22 A.
I'm trying to recall in the paperwork if there was a
23 disclosure included in it.
02:50:22
24 Q.
Do you recall?
25 A.
If there was a disclosure of some kind included in

723
1 the paperwork, I don't remember the specific paperwork.

2 Q.
How many years did you sell these CDs,
3 Ms. Chambliess?
02:50:32
4 A.
About 15.
5 Q.
Of the 15 years, are you telling this jury that you
6 don't remember what documents you had your customers sign?

7 A.
I don't recall a specific document that was a
8 disclosure.
9 Q.
02:50:45
Isn't it a normal -- I'm sorry, ma'am.
10
Isn't it the normal practice when you sell
11 documents or instruments such as these that you have to

12 sign certain agreements? Isn't that normal?
13 A.
You sound -- you sign an account application and a
14 signature card.
02:50:59
15 Q.
That's for a bank account.
16 A.
This was a bank instrument.
17 Q.
I know what it was, but you're not opening a bank
18 account. You're selling a certificate of deposit that you

19 came up with.
02:51:10
20 A.
It's a bank account.
21
MR. STELLMACH: Objection.
22
THE COURT: Wait a second. I'll take care of
23 it. This happens from time to time.

24
02:51:19
Ma'am, if it's a yes-or-no answer, you
25 need to answer "yes" or "no"; but if you can't answer "yes"

724
1 or "no," state that you can't answer it "yes" or "no."
02:51:26
THE WITNESS: Okay. I can't answer --
THE COURT: Wait a second.
THE COURT: And the attorney will rephrase it;
6 okay?
7
THE WITNESS: Okay.
THE COURT: So ask your question again,
9 Counsel.
02:51:34
10 BY MR. FAZEL:
11 Q.
Yes, sir.
12
MR. SCARDINO: May I have just a second?
13 BY MR. FAZEL:
02:51:50
14 Q.
The American investors that you sold to --
15 A.
I did not sell to American investors.
16 Q.
Do you have any knowledge of the documents that were
17 used when selling to American investors?
02:52:03
18 A.
No, I do not.
19 Q.
Okay. You solely sold to foreign investors?
20 A.
Yes, sir.
21 Q.
Now, let's talk about the FDIC.
22
You talked about what FDIC insurance is;
23 correct?
02:52:15
24 A.
Yes, sir.
25 Q.
FDIC, if I'm correct, is insurance policies that are

725
1 provided by the government; correct?

2 A.
It's not directly by the government; it's a private
3 corporation.
4 Q.
02:52:27
Okay. But it's a quasi-governmental corporation?
5 Yes?
6 A.
Quasi, yes, sir.
7 Q.
And it insures at that time up to a hundred thousand
8 dollars; but after 2008 and that fiasco, it went up to

9 $250,000; correct?
02:52:37
10 A.
Correct.
11 Q.
All right. Now, because this is not -- "this" being
12 Guardian International Bank and Stanford International

13 Bank, its sales are not American banks; correct?
02:52:46
14 A.
Correct.
15 Q.
Is there anything illegal by not being an American
16 bank?
17 A.
No.
18 Q.
Is there anything untoward about not being an
19 American bank?
02:52:53
20 A.
I'm sorry. Did you say untoward.
21 Q.
Untoward?
22
THE COURT: Bad.
23 BY MR. FAZEL:
02:52:58
24 Q.
That is, bad?
25 A.
No.
726
02:53:08
1 Q.
Unusual?
2 A.
No.
3 Q.
Is it weird or bad for a bank to be in the Caribbean?
4 A.
No.
5 Q.
Are there many banks in the Caribbean?
6 A.
Many, many, many.
7 Q.
Is there a -- is there a person running for president
8 right now who has accounts in the Caribbean?

9 A.
02:53:17
10 Q.
Yes.
All right. Now, because it's not an American bank,
11 it doesn't have FDIC insurance; correct?

12 A.
Correct.
13 Q.
Now, you talked about this insurance policy,
14 Government's Exhibit 502.

02:53:34
15
16 A.
17
Do you remember talking about that?

Yes, sir.
MR. FAZEL: Okay. Can we blow up Exhibit 502.
18 Oh, we can. How cool is that. Okay.

19
02:53:51
02:53:56
THE COURT: Scroll -- could you move it a
20 little more -21
MR. FAZEL: I'm sorry.
22
THE COURT: I have it here, but I sometimes --
23
MR. FAZEL: Is that better? This way?
24
THE COURT: All the way into the wall.
25
MR. FAZEL: Right here?

727
Now, could you scroll all the way up to
4 the very bottom, so scroll all the way down, and highlight
02:54:07
5 that portion right there where it says "Definitions."

6
I'm sorry. Under "Exceptions." I
7 apologize.
8 BY MR. FAZEL:
9 Q.
02:54:18
02:54:26
Now, you went over this with the government.
10
Do you remember that?
11 A.
Yes, sir.
12 Q.
You didn't go over Exception A, did you?
13 A.
No.
14 Q.
What does it say?
15 A.
"Any individual or corporation who is an account
16 holder, depositor or client of the insured."
02:54:46
17 Q.
And what does it say right below that?
18 A.
"Loss or shortage due to error or omission."
19 Q.
Now look under "Definitions." Read that paragraph to
20 me.
21 A.
"Money shall be cash, bank notes, cashier's checks,
22 money orders, electronic transfers or postal orders all

23 belonging to the insured or for which the insured has
24 accepted responsibility and where a depositor liability
02:55:05
25 exists."
728
MR. FAZEL: Can you back out of that, please?
2 BY MR. FAZEL:
3 Q.
Now, do you see where it says, "The policy does not
4 cover"?
02:55:25
5 A.
Yes, sir.
6 Q.
Okay. What is the thing underneath that A, on the
7 very bottom? This policy does not cover what?

8 A.
"Any individual or corporation who is an
9 accountholder, depositor or client of the insured."

02:55:36
10 Q.
Now, you saw this document; right?
11 A.
Yes.
12 Q.
On its face, it's telling you it doesn't insure
13 anybody who is an accountholder, does it not?
02:55:50
14 A.
It does not insure them directly, no.
15 Q.
It insures the bank?
16 A.
Correct.
17 Q.
So anybody who looks at this knows that the money
18 that it's depositing is not insured as to the depositor

19 but only as to the bank?
02:56:02
20 A.
Correct.
21 Q.
So if something happens to a bank or its affiliate,
22 then there's insurance for it?
02:56:17
23 A.
Yes.
24 Q.
Anything misleading about that?
25 A.
Not on its face, no.

729
02:56:34
1 Q.
Do you know what a captured insurance company is?
2 A.
Captured, is that -- that's owned by.
3 Q.
Captive. I'm sorry.
4 A.
Yes, sir, yes.
5 Q.
Tell us what a captive insurance company is.
6 A.
A captive means one that is owned by the company or
7 by an umbrella company related to an existing company.

8 Q.
All right. So isn't it true that British Insurance
9 Fund is a company that belongs to the bank?

02:57:08
10 A.
11 Q.
You don't know that?
12 A.
No, sir, I was not told that.
13 Q.
All right. Is there anything illegal about being a
14 captive insurance company?

02:57:16
02:57:26
15 A.
No.
16 Q.
Is there anything untoward about it?
17 A.
I like that phrase.
18 Q.
You don't like that. Is there anything --
19 A.
I -- no. I said I like it.
20 Q.
You like it?
21 A.
I'm learning something new, yes.
22
I'm not an attorney to say one way or the
23 other, but I don't think so.

24 Q.
02:57:37
All right. As a matter of fact, it's smart business;
25 right? If you know. Not a trick question. You don't

730
1 know?
2 A.
I would not express an opinion.
3 Q.
Okay. A captive insurance company is one which
4 solely insures the bank; correct?

02:57:50
5 A.
Yes.
6 Q.
Monies are put into this company and kept there on an
7 annual basis for insurance purposes, and if not used,

8 they're brought back as the company; correct?
02:58:05
02:58:14
9 A.
Ideally.
10 Q.
Ideally?
11 A.
Yes.
12 Q.
All right. Anything -- anything untoward about that?
13 A.
In theory, no.
14 Q.
Is there -- well, what do you mean, "in theory"? Is
15 there anything untoward about that?

16 A.
I have heard of cases where it didn't function
17 exactly that way.

18 Q.
Is it not used thousands of times by companies all
19 over the world?

02:58:25
20 A.
I don't have personal knowledge of that.
21 Q.
Aren't the big accounting firms insured this way?
22 A.
I don't know about accounting firms.
23 Q.
Isn't the City of Houston insured thus way?
24
02:58:40
MR. STELLMACH: Objection, Your Honor, to
25 counsel testifying.
731
MR. FAZEL: I'm overruled.
3 BY MR. FAZEL:
02:58:44
02:58:50
4 Q.
Isn't the City of Houston insured this way?
5 A.
I don't know.
6 Q.
Isn't the U.S. Government insured this way?
THE COURT: You don't know.
THE WITNESS: I don't know.
THE COURT: Okay.
10 BY MR. FAZEL:
11 Q.
Now, this British Insurance Fund, was it bit replaced
12 by a Lloyd's of London insurance policy at some point?

13 A.
I'm not sure that Lloyd's was specifically the same
14 coverage, but I do know that the bank had a relationship

02:59:20
15 with Lloyd's.
16 Q.
Ms. Chambliess, let me ask you something: I've heard
17 you say "I'm not sure," "I don't know," a lot of times.
18
Would you agree with me that your
19 knowledge about this company just wasn't as robust as you

02:59:31
20 think it is?
21 A.
I'm sorry. Did I represent that I knew everything
22 about the company?

23 Q.
No. It's just on direct examination, you sure knew a
24 lot, and now you're not sure about a lot.

02:59:43
25
What I'm asking you -Johnny C. Sanchez, RMR, CRR - jcscourtreporter@aol.com
732
1 A.
I know a lot about my specific function.
2 Q.
Oh. Oh, I see.
3 A.
But I was not the accountant or the auditor, and it's
4 hard for me to speak to that.

02:59:54
5 Q.
Oh. So you know about selling CDs. But that's about
6 all you know?
03:00:09
7 A.
No.
8 Q.
No? Well, let's get to how much you know.
9 A.
Okay.
10 Q.
Now, did you know, are you aware, that Hewlett was
11 approved by the FSRC to do auditing?
03:00:23
12 A.
I was under that impression.
13 Q.
You do know that?
14 A.
It's talking about he's chartered, so I would assume
15 that would be correct.

16 Q.
No, ma'am.
17 A.
No, I do not know that for a fact.
18 Q.
"Chartered" is a British term regarding an accountant
19 who is chartered like a CPA.

03:00:31
20
MR. STELLMACH: Objection to counsel testifying
21 again.
22 BY MR. FAZEL:
23 Q.
24
Did you know that?

THE COURT: Overruled to that extent.
25
733
1 BY MR. FAZEL:
03:00:41
2 Q.
Did you know that?
3 A.
If I did, I don't recall it.
4 Q.
Okay. So being chartered has nothing to do with
5 being qualified by the governing board to audit a bank.

6 That's my question.
7
03:01:02
Did you know that?
8 A.
No, I didn't know that.
9 Q.
Did not know that.
10
Do you know the difference between
11 international financial reporting and GAAP?

12 A.
Specific differences? No.
13 Q.
You don't. All right. Let's go a little bit. GAAP
14 stands for generally accepted principles of accounting?

03:01:18
15 A.
Yes.
16 Q.
Okay. And then the FI -- IFRS --
17
MR. FAZEL: Sorry, Your Honor.
18 BY MR. FAZEL:
19 Q.
03:01:27
-- is the accounting system used internationally;
20 correct?
21 A.
To my knowledge, yes.
22 Q.
And the Bank of Antigua, Stanford International Bank,
23 and Guardian Bank were international banks; correct?
03:01:40
24 A.
Yes.
25 Q.
Therefore, their accounting standards are what, GAAP

734
1 or IFRS?
03:01:51
2 A.
It would be IFRS.
3 Q.
They would be IFRS?
4 A.
Yes.
5 Q.
To your knowledge, do you have to report loans under
6 IFRS?
7 A.
I do not know.
8 Q.
You don't know.
9
03:02:00
Wouldn't that be the something important
10 to know before you testify in front of this jury that you

11 didn't know about the loans to Mr. Stanford?
12 A.
No.
13 Q.
No?
14
03:02:14
In your testimony, did you not make it
15 sound like it was something, to use the term you like,

16 untowards about him not telling you about the loans to
17 Mr. Stanford?
03:02:27
18 A.
It is conflicting.
19 Q.
I'm sorry. My question was --
20 A.
I'm sorry. Would you say that again.
21 Q.
My question to you was very simple.
22 A.
Okay.
23 Q.
Was it not your connotation to this jury that it's
24 something untoward about him not declaring loans to

03:02:38
25 himself? Did you not just make that indication to this

735
1 jury?
2 A.
Yes, I did.
3 Q.
Now, would it not be fair to say perhaps under the
4 accounting standards, he didn't have to make those

03:02:50
5 declarations. Wouldn't that be important to tell this

6 jury?
03:02:58
7 A.
You're asking me apples and oranges.
8 Q.
No, I'm not.
9 A.
Yes, you are.
10 Q.
What I'm asking you is: Before you excuse somebody
11 of doing something wrong or illegal, shouldn't you at

12 least know what standards they're supposed to report
13 under?
14 A.
03:03:06
I don't think --
15
THE COURT: Hold it. Hold it. Attorney is up.
16
Yes, sir.
17
MR. STELLMACH: Objection to the argumentative
18 tone.
19
03:03:12
20 BY MR. FAZEL:
21 Q.
Would you like to be accused of something when it's
22 not wrong when you're doing something. Would you like

23 that?
24 A.
03:03:19
25
What you're asking me -THE COURT: Hold it.

736
1 BY MR. FAZEL:
2 Q.
03:03:25
Answer my question.
THE COURT: Yes or no.
THE WITNESS: No.
THE COURT: Okay. Now you got it; right?
6 That's how we're going to have to do it. If you need to

7 amplify an answer, then the government's attorney will make
8 a note of it and take it up on redirect -9
03:03:39
THE WITNESS: Redirect.
10
THE COURT: -- if necessary.
11
THE WITNESS: Okay. Thank you, Your Honor.
12 Keep me in line.
13 BY MR. FAZEL:
03:03:45
14 Q.
He keeps me in line, too.
15 A.
He's a good judge.
16
THE COURT: That's what I have the Court of
17 appeals for, they keep me in line.

18 BY MR. FAZEL:
19 Q.
03:03:58
So we know Hewlett was approved by the FSRC. We know
20 that; correct?
21 A.
Yes.
22 Q.
We know that under international rules, perhaps
23 you're somewhat unclear about it, certain things don't

24 have to be reported that they are under GAAP. We know
03:04:06
25 that; correct?
737
1 A.
Yes.
2 Q.
We know that Mr. Stanford's companies were under
3 international rules; correct?
03:04:12
03:04:29
03:04:35
4 A.
Yes.
5 Q.
All right. Bank of Antigua, commercial bank?
6 A.
Yes.
7 Q.
A bank that loans monies and holds accounts; yes?
8 A.
Yes.
9 Q.
That you sign, like you said, signature cards, to
10 open accounts, just like a commercial bank?

11 A.
Yes.
12 Q.
Also in Antigua?
13 A.
Yes.
14 Q.
Also purchased by Mr. Stanford?
15
THE COURT: Slow down a little bit, Your Honor.
16
MR. FAZEL: I'm sorry, Your Honor. This time
17 thing is throwing me off, Judge.

18
THE WITNESS: Yeah.
19 BY MR. FAZEL:
03:04:41
03:04:57
20 Q.
And is there anything untoward about that?
21 A.
No.
22 Q.
Anything wrong about him purchasing a bank?
23 A.
No.
24 Q.
By the way, on a side note, do you know Leo Mejia?
25 A.
We coincided in Houston.
738
03:05:06
1 Q.
If you do you do, if you don't you don't.
2 A.
Yes, I do. I'm sorry.
3 Q.
I'm setting this up.
4 A.
Yes.
5 Q.
Do you have an opinion as to him?
6 A.
I thought he was a nice guy. I got along well with
7 him.
8 Q.
Do you remember speaking to the government on
9 September 3, 2011?
03:05:22
10 A.
The government, meaning the prosecution?
11 Q.
Yes.
12 A.
I'm not sure about the date, but, yes, I've spoken to
13 them several times.

14 Q.
03:05:39
Do you remember making mention of his propensities to
15 do certain things in the office with females?

16 A.
I --
17
MR. STELLMACH: Objection, Your Honor.
18 Objection, Your Honor. We have a limine regarding this

19 subject.
03:05:47
20
THE COURT: I think we do. Sustained.
21
MR. FAZEL: Judge, may we approach on that?
22
THE COURT: Sure, come on up.
23
24
03:06:56
THE COURT: Yes, sir. I see it over on the
25 right side.
739
1
2
Go on.
MR. FAZEL: Judge, there's two reasons I came
3 up here. One is because I promised counsel that I would

4 come up here and talk about the motion in limine as to this
03:07:05
03:07:12
5 defendant.
6
THE COURT: Okay.
MR. FAZEL: I'm sorry, this witness.
There's a motion in limine regarding --
THE COURT: It was violated. Let me just --
10 let's first see what it is. I may agree.

11
MR. FAZEL: All right. There's two things.
12 One is about Leo Mejia, and one is about the investigation

13 in customs or somebody had on her, the witness. The
14 witness testified on direct examination that she would not
03:07:25
15 do certain things, that she put her credibility and also

16 her state of mind and the fact that she's an honest person
17 to the jury, and that was directed by the government. So I
18 think I can go into the fact that she was being
19 investigated by the government for money laundering.
03:07:43
20
MR. STELLMACH: There are actually two issues
21 here, Your Honor. The motion in limine with respect to

22 this witness and some money laundering investigation --
03:07:51
23
MR. FAZEL: Correct.
24
MR. STELLMACH: -- which we'll address.
25 There's also a motion in limine with respect to Mr. Mejia,

740
1 which they just violated.

2
THE COURT: Relative to?
MR. STELLMACH: Relative to potential sexual
4 harassment. They asked -- he asked in open court, and the

03:08:02
5 jury clearly heard, whether she was aware of allegations

6 against Mr. Mejia.
03:08:10
MR. FAZEL: I did not say that.
THE COURT: It was something about it.
MR. STELLMACH: It was clear what the gist of
10 it was. And so to say that he said he would raise it with

11 Your Honor before he went into it, he certainly may be
12 doing that now with the money laundering, but he didn't do
13 that with Mr. Mejia.
03:08:21
14
THE COURT: Okay.
15
MR. STELLMACH: I can address the money
16 laundering issue, Judge.

17
THE COURT: The money laundering.
18
MR. STELLMACH: He can only inquire under
19 608(b) if it's probed into prior conduct, if it's probative

03:08:32
20 the witness's credibility or truthfulness.

21
THE COURT: Hang on a second. I want to be
22 fair to everybody. Let me pull it. Which one?
03:08:44
23
MR. STELLMACH: 608(b).
24
MR. SCARDINO: Judge, is our time running?
25
THE COURT: No, I just switched to the

741
1 government's time. That's even better; right?

2
MR. SCARDINO: It is.
THE COURT: Okay. Don't look up here. You
4 have to look down here. You press this one here to start
03:08:57
5 this one here. It's very confusing.

6
Okay. Now, 608(b)?
MR. STELLMACH: That's right, Your Honor.
THE COURT: All right. Now, let's first get to
9 that -- to the first matter. It's gone beyond the motion

03:09:27
10 in limine. Do you want an instruction or just let it ride

11 for this one time?
03:09:32
12
MR. FAZEL: Judge, can I address that?
13
MR. STELLMACH: Let it ride, but we would --
14
THE COURT: What?
15
MR. STELLMACH: We would let it ride and bring
16 more attention to it, but sexual harassment does not go to

17 character. We filed a brief with evidence saying -18
MR. COSTA: And there's no substantiation for
19 it. There's no law saying -03:09:41
20
THE COURT: I understand it. Your position is
21 let it ride, let it ride. You're not going to go into that

22 anymore.
23
MR. FAZEL: I guess not, because in their
24 report -- and so, their motion in limine was to Mr. Mejia,

03:09:50
25 not to this witness, knowing Mr. Mejia -Johnny C. Sanchez, RMR, CRR - jcscourtreporter@aol.com
742
THE COURT: He can only take down one at a
2 time.
3
MR. STELLMACH: Clearly, it was related to the
4 subject matter in the motion in limine.

03:10:00
THE COURT: The objection to that is sustained.
Now, let's talk about this -- the money
7 laundering.
8
MR. STELLMACH: There were two incidents. In
9 1995, 17 years ago, Ms. Chambliess parked in front of a

03:10:11
10 automotive repair store here in Houston that was associated

11 with somebody who was the subject of a money laundering
12 investigation. She parked there, I think the reported, for
13 three hours. That was it. She was never interviewed. She
14 was never charged. She was never arrested.
03:10:25
15
THE COURT: How long ago was that?
16
MR. STELLMACH: 17 years by my math, which we
17 could check.
18
And the reason she landed on their radar,
19 on the radar of the Customs official doing the

03:10:35
20 surveillance, is because she was employed at Guardian,

21 which was under -- which had been flagged for potential
22 money laundering.
03:10:44
23
THE COURT: Now, the other matter?
24
MR. STELLMACH: The other matter occurred in
25 1997 when a potential client approached her with an

743
1 undercover Customs agent and said he had money offshore he

2 had inherited and he wanted to use it to buy two airplanes
3 and the FAA wouldn't let him use the money because it was
4 connected to the father's money laundering. And he asked
03:11:02
5 her, "Is there any way we can do this?"

6
And she said, "Well, the only way I know
7 to do this would be if we gave you a loan, you opened a CD,

8 and I don't understand why the money would be" -9
03:11:13
10
THE COURT: Why can't that come in?

MR. STELLMACH: Because it's not probative of
11 her credibility of truthfulness. Nothing ever came of it.

12 She was never charged. It leaves the impression with the
13 jury that she was accused of money laundering. It leaves
14 the false impression with the jury that she was somehow
03:11:25
15 implicated in a money laundering investigation, when, in

16 fact, she didn't do anything. The transaction never went
17 further. And so it's within the Court's discretion to cut
18 it off and not allow them go off into this irrelevant
19 tangent.
03:11:38
20
THE COURT: One occurred 13 years ago and the
21 other 17 years ago; correct?
03:11:47
22
MR. STELLMACH: '95 and '97, 15 years ago.
23
THE COURT: This is --
24
MR. STELLMACH: That's 17. The most recent one
25 is 15 years ago.
744
THE COURT: 15, '97.
MR. STELLMACH: '97; right?
THE COURT: 15 years ago.
4
03:11:57
And you -- so you object?
MR. STELLMACH: I object.
THE COURT: And your position is it's relevant
7 because?
8
MR. FAZEL: Because, Your Honor, she was trying
9 to facilitate the exact thing that he's talking about. She

03:12:04
10 was looking for a way to get money into the bank;

11 therefore, she was assisting in the laundering operation,
12 and Mr. Stanford had no knowledge of it or anything. It's
13 just purely her --
03:12:29
14
THE COURT: Let me read it one more time.
15
Sustain the objection at this time.
16
(The following was held in the presence of the jury)
17 BY MR. FAZEL:
18 Q.
All right. Let me talk to you about Mr. Davis for a
19 moment. When was the earliest -- I'm sorry.

03:12:58
20 A.
I'm trying to get it back in position. I hit this
21 globe over here.
03:13:06
22 Q.
Are you ready?
23 A.
I'm ready.
24 Q.
Okay. Do you remember testifying about Mr. Davis?
25 A.
Yes.
745
1 Q.
All right. Do you recall when was the earliest or
2 the first time that you met Mr. Davis?
03:13:15
3 A.
It was probably nine or ten months after I started --
4 Q.
Okay.
5 A.
-- when he came on board.
6 Q.
And his specific function was to take care of the
7 investments of the bank; correct?

8 A.
My understanding was he was in charge of the
9 accounting and financial reporting.

03:13:25
10 Q.
Which included the investments of the bank?
11 A.
I believe so.
12 Q.
Okay. Now, as time progressed, you saw Mr. Stanford
13 less and less, and Mr. Davis began to take care of that
14 important function more and more; is that correct?
03:13:39
15 A.
I wouldn't know in degrees as far as Mr. Davis's
16 function.
17 Q.
All right. Let's try it this way: When you first
18 started in the bank, you testified that there was what, 30

19 plus employees?
03:13:50
20 A.
After a couple of years there, yes.
21 Q.
Okay. And then when you were let go by the bank that
22 you testified about, how many employees did the bank have?
03:14:02
23 A.
Oh, I think it was in the hundreds globally.
24 Q.
How about thousands?
25 A.
Thousands.
746
1 Q.
Okay. Now, are you telling this jury that you saw
2 Mr. Stanford as often at --
03:14:08
3 A.
No.
4 Q.
-- the very end --
5 A.
No. You were asking me about Mr. Davis. I'm sorry.
6 Q.
Let me finish the question.
7 A.
Go ahead.
8 Q.
Are you telling this jury that you saw Mr. Stanford
9 as often in the beginning as you did at the end?

03:14:20
10 A.
No.
11 Q.
Are you telling this jury that Mr. Stanford was as
12 hands-on in the beginning as he was at the end?
03:14:37
13 A.
I didn't see him as often, so I don't know.
14 Q.
That's right. You weren't reporting to Mr. Stanford
15 anymore, were you?

16 A.
No, I was not.
17 Q.
At what point in time did you quit reporting to
18 Mr. Stanford?
03:14:46
03:14:55
19 A.
Probably three or four years into --
20 Q.
Your employment?
21 A.
-- my time with him, yes.
22 Q.
And you started reporting to who?
23 A.
Alvaro (phonetic) Moreno at one point.
24 Q.
And he was your direct report; correct?
25 A.
Yes.
747
1 Q.
So when you testified that Mr. Stanford was hands-on,
2 you're testifying that he was hands-on in the beginning;

3 correct?
03:15:06
4 A.
Yes.
5 Q.
Not at the end; correct?
6 A.
I don't know.
7 Q.
You don't know that's right.
Because he was -- if he was hands-on at
9 the end, you would know that; right?

03:15:12
10 A.
No. Because he had so many offices, to be hands-on,
11 he could be hands-on by phone from the air, I don't know.

12 Q.
Okay. So you don't know. At some point in time,
13 about three to four years into your employment, you were

14 not able to tell whether Mr. Stanford was hands-on or
03:15:27
03:15:41
15 whether he was wasn't anymore?

16 A.
I saw him less, yes, so I could not tell as well.
17 Q.
And you weren't reporting to him anymore?
18 A.
No, I was not.
19 Q.
And you had Mr. Davis; right?
20 A.
I had no relationship with Mr. Davis.
21 Q.
I never intimated that you did.
22 A.
Okay. I'm sorry.
23 Q.
What I'm saying is you had Mr. Davis there in charge
24 of the investments; correct?

03:15:48
25 A.
He was in charge of accounting and -Johnny C. Sanchez, RMR, CRR - jcscourtreporter@aol.com
748
1 Q.
And investments?
2 A.
And investing.
3 Q.
All right. And under his reign, if you will, the
4 investment strategy changed, it became more complicated,

03:16:07
5 more convoluted; correct?

6 A.
Yes.
7 Q.
It was under his tutelage, if you will, that Stanford
8 started, Stanford SGC, or Stanford Group Companies, which

9 was their broker dealer; correct?
03:16:19
10
MR. STELLMACH: Objection as to form, tutelage.
11
12
03:16:27
Can you answer that question?
13
MR. FAZEL: I like that word.
14
THE COURT: Do you remember it?
15
MR. STELLMACH: It's untoward.
16
THE COURT: Do you want it read back or do you
17 want it repeated?
03:16:34
18
THE WITNESS: Repeat, please.
19
THE COURT: Repeat it again.
20 BY MR. FAZEL:
21 Q.
Sure. Under -- I'm trying to think of a word that
22 the government approves.

23
THE COURT: Do you want to read the question
24 back?
03:16:42
25
MR. FAZEL: No, Your Honor, I'll just rephrase

749
1 it.
2 BY MR. FAZEL:
3 Q.
It was under his director -- his management that the
4 broker dealer commenced; correct?

03:16:51
5 A.
He was part of the organization at that time, yes.
6 Q.
And he was the one in charge of the investments at
7 that time; correct?
03:17:02
8 A.
I believe so.
9 Q.
So he was in charge of the broker dealer, correct,
10 indirectly he was in charge of it? You don't know?

11 A.
I don't know.
12 Q.
Fair enough.
13
Because you weren't -- I don't mean this
14 in a derogatory way -- you just weren't high enough in the

03:17:11
15 ladder to know; fair enough?

16 A.
To my knowledge --
17 Q.
Just answer my question. You weren't high enough in
18 the ladder to know; correct?

19 A.
03:17:18
20 told -21 Q.
Okay.
22 A.
-- and the structure that we saw.
23
24
03:17:22
Yes, actually, I was. I can tell you what we were
25
THE COURT: All right. Hold it.

Now, if you want to follow up.
MR. FAZEL: I will follow up.
750
THE COURT: Okay.
2 BY MR. FAZEL:
3 Q.
Was he not the CFO that everybody reported to,
4 including the broker dealer?

03:17:30
5 A.
Not to my understanding, no. The broker dealer
6 reported to Allen Stanford.
03:17:40
7 Q.
The broker dealer, to your understanding?
8 A.
That was my understandings, yes.
9 Q.
Could you be wrong about that?
10 A.
I might be, but I know he was very involved with the
11 broker dealer.
12 Q.
Okay. In the beginning, he was very involved with
13 the broker dealer?
03:17:48
14 A.
He was -- yes.
15 Q.
What about towards the end?
16 A.
Towards the end, he still had a relationship with
17 him. He had a personal relationship with the CEO of the

18 broker dealer.
19 Q.
03:17:57
He had a personal relationship with everybody in
20 his -21
THE COURT: Slow down, Counsel, slow down.
22 BY MR. FAZEL:
03:18:03
23 Q.
-- company. That's not my question.
24 A.
No --
25

751
THE WITNESS: -- he didn't. He couldn't --
THE COURT: Wait. Question, please. Answer it
3 yes or no.
03:18:08
THE COURT: If you can't answer it yes or no,
6 so state.
7
Ask it again, please.
8 BY MR. FAZEL:
9 Q.
03:18:14
He -- what I'm trying to get at, you made it sound
10 like on direct that he was involved on a very constant

11 basis with a broker dealer with the investment processes
12 of the company. Do you remember that?
03:18:28
13 A.
Yes.
14 Q.
And what I'm trying to show this jury, that's just
15 not accurate. Therefore, what I'm asking you is this:

16 Isn't it true that as Mr. Davis took the companies over,
17 that Mr. Stanford became less and less involved? Yes or
18 no.
03:18:49
19 A.
No.
20 Q.
All right. You talked about him being involved in
21 the reporting, in the annual reports; correct?

22 A.
Yes.
23 Q.
Were you there with him in the beginning when he was
24 involved with that?

03:18:57
25 A.
Yes.
752
1 Q.
What about four years in? Were you there with him
2 when he was involved in that?
03:19:06
03:19:13
3 A.
Yes.
4 Q.
What about five years? Were you there with him when
5 he was involved with that?

6 A.
Yes.
7 Q.
You watched him go through the annual reports?
8 A.
No.
9 Q.
When did you stop watching him go through the annual
10 reports?
11 A.
I did not watch him go through the annual reports.
12 Q.
I see. So he never went through the annual reports
13 with you?
03:19:23
14 A.
He reviewed them once they were published with us.
15 Q.
16
Did you ever see him go through the annual
17 reports with you? Were you ever in the room when he did
18 it?
03:19:32
03:19:37
19 A.
Yes.
20 Q.
You were?
21 A.
Yes.
22 Q.
Did he look at the numbers?
23 A.
Yes.
24 Q.
Was he given the numbers?
25 A.
That, I don't know.

753
1 Q.
Well, how --
2 A.
I'm assuming he did not, that someone else prepared
3 the numbers for his review.
03:19:47
03:20:03
4 Q.
Who would have prepared the numbers for his review?
5 A.
The accounting people, the money managers.
6 Q.
And who did they report to?
7 A.
The banker -- they were outside contractors.
8 Q.
And who did they report to in Stanford?
9 A.
Once Mr. Davis came on board, they interfaced with
10 Mr. Stanford and Mr. Davis.

11 Q.
And isn't it true at some point in time they only
12 reported to Mr. Davis?
03:20:10
13 A.
I do not know.
14 Q.
You don't know that?
15 A.
No, I do not know.
16 Q.
Do you have any understanding of the tax consequences
17 of loans to shareholder? Do you want me to rephrase that

18 question?
03:20:33
19 A.
I'm trying to recall my tax knowledge.
20 Q.
Okay. Do you know how the IRS would treat money
21 flowing from a company to the shareholder and how they

22 would tax that?
03:20:51
23 A.
No, I do not.
24 Q.
Do you know if there are tax consequences of flowing
25 money a certain way from the company to the shareholder

754
1 versus flowing from a company directly to another company?

2 Do you understand my question?
03:21:07
3 A.
Yes, I do, and, no, I do not.
4 Q.
Would it be fair to say that there are -- well --
5 A.
I don't know.
THE COURT: Hold it. I think he was rephrasing
7 it. You didn't complete the question.

8
MR. FAZEL: I didn't, Your Honor, because she
9 said she didn't know.

03:21:14
10 BY MR. FAZEL:
11 Q.
Is there anything illegal about the way the
12 commission system was set up at Stanford?
03:21:41
13 A.
Not that I am aware of.
14 Q.
Is there anything wrong with giving you a commission
15 for selling products?

16 A.
Not that I am aware of.
17 Q.
Isn't that done very regularly in the financial
18 industry?
03:21:46
19 A.
Yes.
20 Q.
Most banks do that?
21 A.
Banks don't pay commissions.
22 Q.
Let me rephrase that.
23
03:21:58
Most broker dealers do that?
24 A.
Broker dealers, yes.
25 Q.
As a matter of fact, that's the main way of people

755
1 getting paid at broker dealers; correct?

2 A.
Yes.
3 Q.
When you were at the company, did you feel like you
4 were doing something illegal?

03:22:08
5 A.
No.
6 Q.
Because if you did, you would have left?
7 A.
Yes.
8 Q.
Now, you also testified that Mr. Stanford looked at
9 the marketing materials; correct?

03:22:29
10 A.
Yes.
11 Q.
And you wouldn't make changes to verbiage of the
12 marketing material; correct?
03:22:36
13 A.
Yes.
14 Q.
But he wouldn't change the numbers?
15 A.
I don't know.
16 Q.
Have you ever seen him change the numbers?
17 A.
No.
18 Q.
Okay. Is there anything weird or unusual about
19 having both a Spanish version of marketing material and an

03:22:48
20 English version of marketing material?

21 A.
No.
22 Q.
Are you aware that there was a Stanford International
23 Bank in Venezuela?
03:22:57
24 A.
I knew there were offices in Venezuela.
25 Q.
Were you aware that there was a Stanford National

756
1 Bank in Panama?
2 A.
That was after I left.
3 Q.
Were you aware that if you were or were, I don't
4 know, were these profitable companies, to your knowledge?

03:23:07
5 A.
I have no idea.
6 Q.
Now, you met with the government on two occasions
7 prior to testifying today?
03:23:32
8 A.
Yes.
9 Q.
Did you ever meet with us?
10 A.
No, sir.
11 Q.
Did you have a lawyer when you met with the
12 government?
03:23:42
13 A.
No.
14 Q.
Has the receiver contacted you?
15 A.
No.
16 Q.
Has the receiver asked for any of your monies to be
17 sent back to the receiver?
03:23:53
18 A.
No.
19 Q.
Has the SEC contacted you?
20 A.
No.
21
MR. FAZEL: Your Honor, may I have a moment?
22
THE COURT: Sure.
23 BY MR. FAZEL:
24 Q.
03:25:17
Ms. Chambliess, let me work backwards. Do you
25 remember talking to the government in testimony -- direct

757
1 testimony regarding what Mr. Stanford told you that put

2 you back on your heels, and you were very fearful of that.
3 Do you remember that?
03:25:27
4 A.
Yes.
5 Q.
Just do whatever you need to do, I don't need to know
6 about it?
03:25:33
7 A.
Yes, sir.
8 Q.
Did you mention that to the government?
9 A.
Yes.
10 Q.
Do you know of any reason why they would fail to put
11 that in the report?

12
MR. STELLMACH: Objection, Your Honor.
13
14 BY MR. FAZEL:
03:25:47
15 Q.
Were you truthful with the government when you spoke
16 with them?
17 A.
Yes.
18 Q.
Did you tell the government at the time when you met
19 with them what you told this jury about what Mr. Stanford
03:26:02
03:26:10
20 said?
21 A.
The remark?
22 Q.
Yes.
23 A.
The last time that I met with them, yes.
24 Q.
You told them that?
25 A.
Yes.
758
MR. FAZEL: My law partner wants me to ask you
2 something. I almost want to give it to him.

3
THE WITNESS: I can kind of hear him.
4 BY MR. FAZEL:
03:26:37
5 Q.
When Mr. Stanford told you that, did you mention it
6 to anybody else?
03:26:49
7 A.
There were several of us present at the time.
8 Q.
Okay. Who was there?
9 A.
A couple of people from the Mexico City office.
10 Q.
Their names?
11 A.
I believe it was -- oh, gosh. I can see his -- a
12 Spanish guy. I can't think of his name right now. Keith

13 Vargas from Miami, and one of the brokers whose names I
14 didn't know from the international that I didn't have much
03:27:18
03:27:25
15 contact with.
16 Q.
Did you mention that to the government?
17 A.
Who else was present?
18 Q.
Yes.
19 A.
They didn't ask me.
20 Q.
They didn't ask you?
21 A.
Specific names, no.
22 Q.
When you said, "Stanford told me this thing and it
23 just blew me away," they didn't say, "Really, where were

24 you? When did he say this? Who was with you?" They
03:27:36
25 never made these inquiries?

759
1 A.
I said, when we were at a meeting, after a meeting
2 the last year or two that I was there --
03:27:45
03:27:55
3 Q.
And they didn't ask who was with you?
4 A.
-- like that --
5 Q.
Did they ask who was with you?
6 A.
No, sir, they did not.
7 Q.
Did they ask if you took notes of it?
8 A.
No, sir, they didn't ask if I took notes.
9 Q.
Nothing like, "Did you take notes of it"?
10 A.
(Answered negatively.)
11 Q.
No?
12 A.
It was like you and I are talking, so, no, I didn't
13 have -14 Q.
03:27:59
Did you say, "You know what, I'm turning in my papers
15 right now. I'm not going to work for this company

16 anymore"?
17
MR. STELLMACH: Objection as to the relevance
18 of this.
19
03:28:08
THE COURT: Overruled. But I think it's been
20 asked and answered.

21
22 BY MR. FAZEL:
03:28:11
23 Q.
Did you say, "I'm quitting right, Mr. Stanford"?
24 A.
No, sir.
25 Q.
Did you collect a paycheck after that?

760
03:28:19
03:28:23
1 A.
Yes, I did.
2 Q.
Did you continue to collect a paycheck after that?
3 A.
Yes, I did.
4 Q.
Did you feel like it was something untoward about
5 that?
6 A.
That I collecting a paycheck --
7 Q.
Right, because --
8 A.
-- after that?
9 Q.
-- this was so disconcerting to you.
10
THE COURT: You can only talk one at a time.
11
MR. FAZEL: I'm sorry.
12
THE COURT: Don't talk over each other, please.
13 Go on.
14 BY MR. FAZEL:
03:28:32
15 Q.
It was so disconcerting to you, did you not just
16 quit, then?
17 A.
No, I could not afford to quit then.
18 Q.
So you just decided to go forward with it because you
19 couldn't afford it?

03:28:39
20 A.
Basically, yes.
21 Q.
Didn't you testify that you got a job in two months
22 after they let you go?
03:28:51
23 A.
Yes, I did.
24 Q.
Wasn't it with a bank?
25 A.
It was with a brokerage firm.

761
1 Q.
It was with Bank of America?
2 A.
It was for Bank of America investments.
3 Q.
So couldn't you have quit and gotten a job two months
4 earlier?
03:29:03
5 A.
I probably could have, but it was a $2,000 a month
6 draw, and my overhead was more than that.

7 Q.
I see.
In your time at Stanford International
9 Bank, or Guardian, was there anybody you can tell this

03:29:18
10 jury, anybody, that did not get paid their money when the
11 CDs were due?
12 A.
Not during the time that I was there.
13 Q.
Any information in the booklets and pamphlets that
14 the government made you read out to the jury -- I'm not
03:29:34
15 going to make you do that again. Was there any

16 information in those booklets that you are aware of
17 personally that's inaccurate?
03:29:46
18 A.
Not that I am personally aware of.
19 Q.
Any of those numbers that you're personally aware of
20 they're inaccurate?
21 A.
Not to my personal knowledge.
22 Q.
Now, wasn't Mr. Davis running the bank in Montserrat?
23 Wasn't he living there?
03:30:09
24 A.
When?
25 Q.
Right before Hugo hit.

762
1 A.
I don't think so.
2 Q.
You don't know?
3 A.
He used sit in the office next to me, so I don't
4 remember him moving his family to Montserrat.

03:30:26
MR. FAZEL: Judge, may I have a moment --
MR. FAZEL: -- to consult?
Pass the witness, Your Honor.
9
03:30:42
10
Any redirect.
11
MR. STELLMACH: Yes, Your Honor. I'll be
12 brief.
13
REDIRECT EXAMINATION
03:30:49
15 Q.
Ms. Chambliess, you were asked a number of questions
16 regarding the corporate structure of Stanford Financial by

17 Mr. Fazel.
18
Do you remember being asked those
19 questions?
03:30:57
20 A.
Yes, I do.
21 Q.
And he drew some diagrams on the board for you?
22 A.
Yes, sir.
23 Q.
Did the corporate structure of Stanford Financial
24 Group and how it related to different subsidiaries, was

03:31:09
25 that something that mattered to the depositors that you

763
1 were dealing with?

2 A.
Ultimately, no.
3 Q.
One thing that Mr. Fazel did discuss was this idea of
4 a captive insurance company.

03:31:19
Do you recall being asked questions about
6 that?
7 A.
Yes.
8 Q.
And he showed you Government's Exhibit 502, which is
9 the insurance policy that we looked at before.

03:31:29
10
Is there anything in this document that
11 shows that British Insurance Fund, Limited, located in

12 London, England, was in any way connected to Mr. Stanford
13 or the Stanford Financial Group or Guardian International
14 Bank or Stanford International Bank?
03:31:47
15 A.
No.
16 Q.
Would that have concerned you if you learned that the
17 insurance policy that you had been told about by

18 Mr. Stanford and were, in turn, discussing with depositors
19 was, in fact, a shell company of Mr. Stanford's?
03:31:59
20 A.
Yes.
21 Q.
And if we look at Subsection B of this insurance
22 agreement and, in particular, the statement here -- I'm

23 sorry -- Subsection A, that the loss of money due to the
24 failure, collapse or bankruptcy of a redeposit or
03:32:14
25 investment source, as approved by the company, and only

764
1 where depositor liability exists. We talked about that

2 before on direct examination.
3
Could you remind us what Mr. Stanford told
4 you about that particular provision and the protection it

03:32:28
5 supposedly gave the depositors?

6 A.
That the insurance company was allowed to audit and
7 prove where the deposits and investments were being made.

8 Q.
So this was an independent check by the insurance
9 company on the bank?

03:32:43
10 A.
As I understood it, yes.
11 Q.
And if you had been told that the insurance company
12 and Mr. Stanford were one and the same, would that
13 provision have been made any sense to you?
03:32:56
14 A.
No.
15 Q.
You were also asked some questions about different
16 accounting standards, the IFRS.

17
Do you remember being asked questions
18 about that?
03:33:03
19 A.
Yes.
20 Q.
And Mr. Fazel asked whether you knew under those
21 particular accounting rules whether loans to shareholders

22 had to be disclosed.
23
03:33:12
Do you recall those questions?
24 A.
Yes, I do.
25 Q.
Now, if you look at Government's Exhibits 109, 110,

765
1 111, 112, these are the annual reports for the bank
2 covering the years from 1996 through 1999.
3
There's a disclosure in the 1996 annual
4 report that we saw earlier regarding a loan to

03:33:36
5 Mr. Stanford; right?

6 A.
Yes.
7 Q.
And that disclosure appears again in the 1997 and
8 1998, and then it's discussed in the 1999 annual reports

9 of the bank; right?
03:33:46
10 A.
Yes.
11 Q.
And could you remind us what it said in the 1999
12 report about what had happened to that loan, whether it

13 had been repaid or not?
03:33:56
14 A.
That it had been paid off.
15 Q.
Was there ever any disclosure in any of the annual
16 reports that the bank no longer felt itself obligated to

17 make disclosures about loans for Mr. Stanford?
03:34:10
18 A.
No.
19 Q.
Or any explanations why the bank was disclosing it in
20 the first place if it doesn't have to under these

21 accounting standards that Mr. Fazel talked about?
22 A.
No.
23 Q.
Was it ever disclosed to you by Mr. Stanford that he
24 was, in fact, continuing to take money out of the bank?

03:34:26
25 A.
No.
766
1 Q.
In fact, what did he tell you about that?
2 A.
That he was not, that the money was being invested.
3 Q.
Mr. Fazel also asked some questions about the fact
4 that the bank was selling CDs to people.

03:34:44
03:34:52
Do you recall those questions?
6 A.
Uh-huh.
7 Q.
And how that differed from selling securities?
8 A.
(Answered affirmatively).
9 Q.
And then you and he got into a discussion about
10 whether CDs can qualify as securities or not. Believe me,

11 we're not going there again.
12 A.
Yeah.
13 Q.
But when Mr. Stanford made disclosures about the CDs
14 to you and gave you these materials to then share with

03:35:07
15 depositors, did he ever tell you, Look, we don't have any

16 obligation to be as truthful as we would be if people were
17 buying stock in the bank?
03:35:21
18 A.
No.
19 Q.
Did he ever explain why he would be giving you the
20 financial statements for the bank if the people who were

21 buying CDs aren't actually buying stock in the bank, why
22 you'd tell him anything of the assets of the bank?
03:35:33
23 A.
No, he -- no.
24 Q.
Well, what did he tell you about why he was giving
25 you the annual reports and this other detailed financial

767
1 information describing the bank's assets and its

2 investment strategy?
3 A.
That it was part of providing information to the
4 clients so that they could see how healthy the bank was,
03:35:46
5 and also to perspective clients so that they would feel

6 more comfortable with having a relationship with the bank.
7 Q.
You were also asked some questions about banks paying
8 commissions for selling CDs.

9 A.
03:35:57
10 Q.
Right.
Are you aware of any banks who paid banker
11 commissions for selling CDs here in the United States?

12 A.
No. To my knowledge, they're not allowed to by law.
13 Q.
Finally, you were asked whether you felt like you
14 were ever doing anything illegal while you were employed

03:36:12
15 by Mr. Stanford during those 15 years.

16
03:36:21
And you didn't; that was your testimony?
17 A.
No.
18 Q.
You didn't feel like you were doing anything wrong?
19 A.
I didn't believe, no.
20 Q.
What if you had known that Mr. Stanford was borrowing
21 billions of dollars out of the bank and you weren't

22 disclosing that to your depositors? Would you have felt
23 differently as you were handing them those materials?
24 A.
03:36:32
25
Yes, I would.
MR. STELLMACH: I pass the witness Your Honor.
768
THE COURT: Okay. Limited redirect -- recross,
2 if you'd like.
3
RECROSS EXAMINATION
4 BY MR. FAZEL:
03:36:39
5 Q.
Are you aware that there was a mention in the annual
6 reports after 1999 that they're switching from GAAP to

7 IFRS? Were you aware of that?
03:36:52
8 A.
I'm sure it's in there. I don't recall it --
9 Q.
Wouldn't that be important to know?
10 A.
-- specifically.
11
Not being an accounting expert, I don't
12 really understand --
03:36:59
13 Q.
You don't understand?
14 A.
-- the differences between the two, other than what
15 you've told me.

16 Q.
Well, you keep talking about how important it is to
17 you for you to know things to disclose it to your clients

18 because it's important for you to do that, right? Right?
03:37:09
19 A.
Yes.
20 Q.
It's not important for you to know what accounting
21 standard that you're disclosing to your clients?
03:37:22
22 A.
Many of them probably would not know the difference.
23 Q.
They would not know the difference?
24 A.
Even if I disclosed it to them.
25 Q.
Oh, I see. Because they're so unsophisticated?

769
1 A.
Some of them were, yes.
2 Q.
Yet they had so much money to invest with Stanford
3 International Bank?
4 A.
03:37:34
03:37:43
03:37:54
Someone can win $30 million in the lottery and not be
5 sophisticated.
6 Q.
How many of those did you have, ma'am?
7 A.
Actually, I've only met one.
8 Q.
Did you have that person as your client?
9 A.
No, unfortunately.
10 Q.
Well, so let's talk about the clients you had?
11 A.
They were very --
12 Q.
Did you have any of them win lotteries?
13 A.
Small amounts, yes.
14 Q.
So are you telling me that they're so unsophisticated
15 that you can't explain to them, Oh, by the way, as of

16 1999, this company has switched the manner in which
17 they're reporting their annual income?
18 A.
I would not have been able to explain it all to them,
19 and some of them would not have understood the difference;

03:38:11
20 some would have.

21 Q.
Is it -- are you telling this jury that it's illegal
22 for Stanford, the broker dealer, to pay you a commission

23 for selling those CDs?
03:38:27
24 A.
No. Broker dealers can pay commissions.
25 Q.
Is there anything illegal about what Stanford did

770
1 about the commissions?

2 A.
3 Q.
Is there anything that you personally know about the
4 magazines, the quarterly reports, and all the annual

03:38:40
5 reports that you turned over to your clients to look at,

6 is there anything in there that you know is incorrect?
7 A.
That I know for a fact?
8 Q.
Correct. Forget what the government says.
9
03:38:56
Do you know for a fact that those numbers
10 are incorrect?
11 A.
No, I do not.
12 Q.
Now, you also talked about the structures of the
13 company. And you thought, It's not a big deal, it's not
14 important, I don't need to tell my client tell about that;
03:39:07
15 right?
16 A.
As far as all of the companies and the whole
17 corporate structure?
03:39:17
18 Q.
Sure. Sure.
19 A.
If they asked, I would provide information.
20 Q.
And -- but you didn't know about it?
21 A.
I wasn't aware of those, no.
22 Q.
Well, aren't they wanting to know if something goes
23 wrong, they need to sue somebody, who to sue? Isn't that

24 important to know?
03:39:29
25 A.
Yes.
771
1 Q.
Well, once you're -- if you're buying something like
2 that or investing money, wouldn't you want to know under

3 what laws you're going to use, what court system you're
4 going to use?
03:39:40
5 A.
To my knowledge, it was in the United States after
6 the broker dealer was opened.
03:39:48
7 Q.
8 A.
Yes, I would.
9 Q.
Would that be important to you?
10 A.
Yes.
11 Q.
Wouldn't it be important to your clients so they'd
12 know that this a Montserrat company, that they would have

13 to go to Montserrat to sue somebody?
14
03:39:56
MR. STELLMACH: Objection. I think we're
15 getting beyond the scope.

16
MR. FAZEL: No, it's --
17
THE COURT: Where was it? I noted everything
18 down, under what category?

19
03:40:03
MR. FAZEL: The first category, why it's not
20 important for the clients -21
THE COURT: The first one is the insurance
22 policy.
23
MR. FAZEL: No, sir. I was talking about --
24 the prosecutor talked about why it's not important to know

03:40:09
25 about the structure of the company.

772
03:40:14
THE COURT: Did he ask that on his --
MR. FAZEL: Yes, sir. Redirect.
THE COURT: -- redirect?
MR. STELLMACH: I only asked whether this, the
6 structures of the companies was something depositors asked

7 her about, and she said no.
03:40:22
THE COURT: All right. Overrule the objection.
MR. STELLMACH: All right.
10 BY MR. FAZEL:
11 Q.
Wouldn't you as a depositor want to know, Hey, I have
12 to go to Montserrat to sue somebody?
03:40:34
13 A.
Yes.
14 Q.
So it would be important for the depositor to know
15 that, would it not?

16 A.
Yes.
17 Q.
Wouldn't it be important for you as a salesperson
18 that had been in this company for 15 years to know what

19 the company structure is?
03:40:41
20 A.
If the customer had to go beyond the direct
21 relationship, yes.
03:40:58
22
MR. FAZEL: May I have a moment, Your Honor?
23
THE COURT: Yes.
24
MR. FAZEL: I pass the witness. Thank you.
25
THE COURT: Very limited -- what is it -Johnny C. Sanchez, RMR, CRR - jcscourtreporter@aol.com
773
Redirect-Chambliess/By Mr. Stellmach/Recross-Chambliess/By Mr. Fazel
1 redirect now?
2
THE COURT: Very limited. Cut it off right
4 there.
03:41:05
MR. STELLMACH: One question.
THE COURT: Sure.
REDIRECT EXAMINATION
8 BY MR. STELLMACH:
9 Q.
03:41:13
Regardless of the accounting standards, would loans
10 to Mr. Stanford have been consistent with the investment

11 strategy described in the marketing materials you
12 continued to give to clients?
13 A.
No.
14
03:41:24
MR. STELLMACH: Nothing else.
15
RECROSS EXAMINATION
16 BY MR. FAZEL:
17 Q.
In the marketing material, does it not say "Other
18 investments"?
03:41:34
19 A.
Yes, but I don't consider a loan to be an investment.
20 Q.
You don't?
21 A.
No.
22 Q.
Well, that's the problem. What if the loan was moved
23 from one to Mr. Stanford for tax purposes and then moved
24 to a company? Would that not be an investment?
03:41:43
25 A.
It would not be a liquid investment, no.

774
Recross-Chambliess/By Mr. Fazel
03:41:52
1 Q.
That's not my question. Would that be an investment?
2 A.
Not in my mind.
3 Q.
Not in your mind?
4 A.
No.
5 Q.
And is that the tell all, end all in your mind?
6 A.
As far as my clients are concerned, yes.
7 Q.
How about as far as financial folks are concerned?
8 How about the financial industry? Wouldn't that be the

9 place we'd go to determine what terminology means? That's
03:42:09
10 what lawyers do.

11 A.
If a loan is being offered as a security, yes, then
12 people know that they're being offered a loan as a

13 security.
14 Q.
03:42:19
No, ma'am. What I'm asking you: When in the
15 brochure, it clearly says, "and other investments," and it

16 doesn't say all our investments are liquid, nothing says
17 "all." It just says, "Our investments are liquid."
18
So there are some investments that are not
19 liquid; right?
03:42:32
20 A.
Is that implied?
21 Q.
I'm not asking -- I don't know whether it is or it's
22 not.
23
24 A.
03:42:41
It's in the documents, is it not?

Well, let me look again. Actually, I don't have any
25 of the brochures.
775
Recross-Chambliess/By Mr. Fazel
MR. STELLMACH: If there's a reference, but I
2 think we're -3 BY MR. FAZEL:

4 Q.
03:42:45
Pick any of the documents you want.
THE COURT: Let me ask you: Does it hurt you?
MR. STELLMACH: No, not really.
THE COURT: All right. Then go ahead and sit
8 down.
9 BY MR. FAZEL:
03:42:52
10 Q.
Ma'am, my point is that nowhere in those documents it
11 says, "All our investments are liquid," does it?
03:43:06
03:43:18
12 A.
I would have look back again to be able to answer.
13 Q.
Take through any one you want.
14 A.
These are not the brochures. These are not the
15 brochures. They're the annual reports.

16 Q.
Aren't they in the annual reports as well?
17 A.
Perhaps a limited amount.
18
MR. STELLMACH: It's really buried in there.
19
THE WITNESS: I have to take them out.
20
MR. STELLMACH: We could pull it up for you if
21 it would be helpful on the screen. We can do that.

22
MR. FAZEL: You know what, Your Honor, I pass
23 the witness.
24
03:43:27
THE COURT: Okay. Pass the witness. Anything
25 further? Not really?

776
MR. STELLMACH: No, Your Honor. That says it
2 all.
3
THE COURT: All right. All right, ladies and
4 gentlemen, now, it's almost -- well, we started at 2:15.

03:43:37
5 It's almost 3:45. We'll take an afternoon break at this

6 point. Please be ready to resume at 4:00 p.m. we'll see
7 you at that time. Is that correct? I see -- am I correct
8 with the time? I think so. Okay. See you then.
9
03:43:52
U.S. MARSHAL: Your Honor.
10
THE COURT: Oh, I'm sorry. Minor point.
11
12
THE COURT: Let me have the attorneys on the
13 side here.
14
04:04:23
We'll be with you in just a second. Be
15 seated.
16
17
(A sidebar was held without the court reporter)
THE COURT: Ladies and gentlemen -- get back on
18 the record. I did something a bit unusual. I have allowed

19 at least any of the attorneys -- if -- we're trying to
04:05:03
20 balance the temperature as best we can, okay? And I'm not

21 really attuned to it on this thing. So I have told the
22 attorneys that if they're really uncomfortable, you know,
23 by the atmosphere provided by the federal courthouse, they
24 may take their jackets off. So don't hold it against them.
04:05:23
25 It's just a matter -- it lets everybody be comfortable. We

777
1 don't have to stand on formal ceremony, okay?

2
By the way, occasionally, you may see -- I
3 don't know if we're going to do it, the -- make sure that's

4 off -- the attorneys in -- historically in state court may
04:05:37
5 sit while they cross-examine. So the attorneys know that I

6 don't have like they -- and some judges have a one-arm
7 rule, meaning you can't get further than one arm from a
8 podium.
9
04:05:52
In other words, I also say they can
10 approach the witness to bring documents up without asking

11 permission ahead of time, which is usual in federal court.
12 And I also allow them to examine witnesses however they
13 want to do, they can sit down, stand at their place, stand
14 in the front -- and we'll have -- lapel microphones should
04:06:09
15 be operative tomorrow -- or stand at the podium. So

16 whatever constitutes them is fine with me. They make
17 everybody comfortable.
18
We'll move it along. I will say this:
19 For whatever it's worth, that the estimated time for the
04:06:20
20 first witness is -- was far above what they actually took.

21 So that's been my experience with the timing order. We'll
22 see as it goes along.
23
All right. Counsel, call your next
24 witness.
04:06:32
25
MR. COSTA: Thank you, Your Honor. The United

778
Direct-Mejia/By Mr.Costa
1 States calls Leonel Mejia.

2
THE COURT: Yes, sir, raise your right hand.
CASE MANAGER: Do you solemnly swear that the
4 testimony you are about to give in the case now before the
04:06:51
5 Court will be the truth, the whole truth and nothing but
6 the truth?
7
THE WITNESS: I do.
THE COURT: Have a seat, please.
LEONEL MEJIA,
10 after having been first cautioned and duly sworn, testified

11 as follows:
12
DIRECT EXAMINATION
13 BY MR. COSTA:
04:07:05
14 Q.
Good afternoon, Mr. Mejia.
15 A.
Good afternoon.
16 Q.
Better.
17 A.
Sorry.
18 Q.
Would you please introduce yourself to the ladies and
19 gentlemen of the jury.

04:07:13
20 A.
My name is Leonel Mejia.
21 Q.
And could you spell that for the court reporter,
22 please?
04:07:27
23 A.
L-e-o-n-e-l and last name, M-e-j-i-a.
24 Q.
And is there a nickname you use for your first name
25 or shortened name?
779
04:07:37
04:07:52
1 A.
Yes, sir, Leo, L-e-o.
2 Q.
And where do you live, Mr. Mejia?
3 A.
In Spring, Texas.
4 Q.
How long have you lived in the Houston area?
5 A.
Since 1988 -- no. Sorry. '84.
6 Q.
Where were you worn?
7 A.
In El Salvador, Central America.
8 Q.
And is 1984 when you came to the United States?
9 A.
No. I came to the United States in 1980.
10 Q.
What brought you to the United States from
11 El Salvador?
04:08:02
12 A.
To continue my studying at Texas A&M.
13 Q.
And how many years did you study at Texas A&M?
14 A.
Four.
15 Q.
What subjects did you focus on?
16 A.
Environmental design/architecture.
17 Q.
When you came to the United States, did you speak
18 fluent English?
04:08:12
19 A.
No.
20 Q.
How did you learn English?
21 A.
I went at A&M to the ESL program, English as a second
22 language.
04:08:24
23 Q.
And did you graduate from Texas A&M?
24 A.
No.
25 Q.
What level were you when you left?

780
04:08:37
04:08:44
1 A.
Senior level, something in that area.
2 Q.
And why did you leave Texas A&M?
3 A.
To work here in Houston.
4 Q.
And where did you first work in Houston?
5 A.
At the Houston Chronicle.
6 Q.
The newspaper?
7 A.
Yes, sir.
8 Q.
What did you do for the Houston Chronicle?
9 A.
I was a graphic designer.
10 Q.
And just explain generally what that means?
11 A.
We put together ads for the paper so clients would
12 put -- would send us information how they want the ads,

13 and we put it together.
14 Q.
04:09:00
And you started at the Chronicle in '84. How long
15 did you work at the Chronicle?

16 A.
For four years, until 1988.
17 Q.
And what -- where did you go to work after the
18 Chronicle?
19 A.
04:09:14
I work with an advertising agency that it owns by the
20 Stanford group.
21 Q.
And what individual owned that advertising agency?
22 A.
Mr. Allen Stanford.
23 Q.
Do you see Mr. Allen Stanford in the courtroom here
24 today?
04:09:22
25 A.
Behind you. Behind you.

781
1 Q.
Could you describe what he's wearing?
2 A.
A dark suit with a light-blue shirt.
MR. COSTA: I ask that the record reflect he's
4 identified the defendant, Your Honor.

04:09:36
THE COURT: Record will so reflect.
6 BY MR. COSTA:
7 Q.
How did you first find out about a job opportunity
8 with Mr. Stanford?

9 A.
04:09:46
An ad in the paper, in the Houston Chronicle.
10 Q.
What type of ad?
11 A.
Employment ad that the Guardian International Bank
12 put out.
13 Q.
Do you recall what the ad said the company was
14 looking for?
04:09:57
15 A.
It talks about a need of an advertising marketing
16 person who helped them to do advertising in Latin America.
04:10:14
17 Q.
So is there a language requirement?
18 A.
Yes, a Spanish-speaking language requirement.
19 Q.
And how did you respond to the advertisement?
20 A.
Send my resum and my -- and a letter to whatever
21 they asked to send it to an address.

22 Q.
And on your resum, what did you say about your
23 educational background?
04:10:30
24 A.
That I finished my school.
25 Q.
At A&M?
782
04:10:38
1 A.
At A&M.
2 Q.
Was that true?
3 A.
No.
4 Q.
Do you regret having misstated or lied about your
5 college degree?
6
MR. FAZEL: Objection to bolstering, Your
7 Honor.
8
9 BY MR. COSTA:
04:10:43
10 Q.
You can go ahead and answer the question, sir, if you
11 remember it.
04:10:53
12 A.
Yes.
13 Q.
Did you actually get an interview with Mr. Stanford?
14 A.
After one or two, yes.
15 Q.
Who did you first meet with at Mr. Stanford's
16 company?
04:11:06
17 A.
With Mr. Alvarado first.
18 Q.
And what was Mr. Alvarado's position?
19 A.
He was a manager.
20 Q.
And what did you learn about this -- this position
21 would be asking you to do?

22 A.
To create advertising to promote an international
23 bank in Latin America.
04:11:25
24 Q.
And did -- who did you meet with after Mr. Alvarado?
25 A.
With Mr. Allen Stanford.

783
04:11:33
1 Q.
Just the two of you?
2 A.
Yes.
3 Q.
Where was that interview?
4 A.
In Mr. Allen Stanford offices.
5 Q.
In which -- were they in Houston?
6 A.
Yes. 1100 Milam, 38th floor.
MR. COSTA: Could we display what's already in
8 evidence 522, Page 22, on the screen, please. Thank you.

9 BY MR. COSTA:
04:12:01
10 Q.
And you can either look, Mr. Mejia, on the screen
11 that's coming down or the screen right there, the monitor

12 in front of you.
13
Do you recognize the building in the large
14 picture on that page?

04:12:09
15 A.
Yes, sir.
16 Q.
What is that?
17 A.
That's the building where I was interviewed.
18 Q.
And that's where Mr. Stanford had his office at the
19 time?
04:12:17
20 A.
Yes, sir.
21 Q.
What was the extent of the office space when you went
22 there to interview?
04:12:30
23 A.
I would say that -- one-third of one floor.
24 Q.
And what did Mr. Stanford tell you about this
25 advertising position he had advertised for?

784
1 A.
Could you be more specific?
2 Q.
What did he tell you about the job you were
3 interviewing for?
4 A.
04:12:42
That they need somebody who knows the -- had a
5 knowledge of the people in Latin America, speak Spanish

6 and help them to build the reputation and setting
7 products, banking products in Latin America.
8 Q.
And what bank was selling these products? Do you
9 remember the name of that bank?

04:12:59
10 A.
Yes, sir. Guardian International Bank.
11 Q.
And did he tell you where that bank was
12 headquartered?
13 A.
At one point, yes. I don't remember at what point,
14 but, yes, it was -- yes, he told me.

04:13:10
15 Q.
And when you heard where it was headquartered, where
16 was that?
17 A.
In Montserrat, West Indies.
18 Q.
And the West Indies, what part of the world does the
19 West Indies refer to?

04:13:21
20 A.
That is in the Caribbean, the bottom part of the
21 Caribbean toward the South America.

22 Q.
And what about this advertising agency? Was it going
23 to be a separate company or part of the bank?
04:13:34
24 A.
Oh, a separate company.
25 Q.
And what was -- what kind of services would the

785
1 advertising company perform?

2 A.
Create marketing materials for the companies that
3 they own at that time.
04:13:47
4 Q.
You said they owned. Who --
5 A.
Excuse me. That Mr. Allen Stanford owns.
6 Q.
Was this going to be an advertising company that you
7 could go out around Houston and solicit business from

8 anyone?
9 A.
04:13:59
No. We had an agreement that the first three --
10 first three years we would do marking and advertising for

11 the bank and the other companies that they have. They
12 have one or two more companies. After that one, we can go
13 and solicit business with other clients.
14 Q.
04:14:16
And what was your position going to be with this
15 advertising?
16 A.
President of the company.
17 Q.
Was there a name for the company?
18 A.
Yes. The name was Idea. Because in Spanish and in
19 English, they actually write and spell the same and means
04:14:30
20 the same.
21 Q.
So did Mr. Stanford -- did you just do this one
22 interview with Mr. Stanford or were there future

23 interviews before you started working?
24 A.
04:14:40
There were two interviews. First one was general,
25 and the second one he made an offer. He asked me what is

786
1 my requirements will be, and we discuss about salary and

2 vacation time and money, investment needed for -- to open
3 that agency.
04:14:59
4 Q.
And was he -- who was going to own the agency?
5 A.
After conversation, he will own the majority of that
6 over 96 percent, I think, or 94, and I will own 4 to

7 6 percent of the agency in paper.
8 Q.
And what about the salary? What kind of salary did
9 he offer you?
04:15:17
10 A.
If I remember at that time was at the high 40s, 48 or
11 something like that.
04:15:39
12 Q.
How did that compare to your Chronicle salary?
13 A.
It was better. Substantially better.
14 Q.
And did you accept the job offer from Mr. Stanford?
15 A.
Yes, sir.
16 Q.
And about when was it that you started working for
17 Mr. Stanford?
18 A.
Around two weeks after that, he wants me to start
19 right away. I said I need to give a two-week notice to

04:15:51
20 the Chronicle, and then I started.

21 Q.
How was the advertising agency -- if it was just
22 starting up, how was it funded initially?

23 A.
We -- Mr. Stanford gave me a check and said what is
24 the equipment that I need, and I give him a list of the

04:16:05
25 equipment. And then he say come in a couple of days to

787
1 pick up a check, and it was a check, and we started the

2 company.
04:16:21
3 Q.
Do you remember how much the check was for?
4 A.
It was over, like, $150,000, something like that, or
5 over $100,000, but I don't remember the exact amount. But

6 it was a substantial amount of money at that time.
04:16:37
7 Q.
Did Mr. Stanford say where he got that money from?
8 A.
No.
9 Q.
And where was the office for the advertising company
10 in relation to this office Mr. Stanford had where he

11 interviewed you?
12 A.
In the same floor but next to, separated by a
13 different entrance, but the same floor, in the same

14 building.
04:16:49
15 Q.
You said Mr. Stanford had a few companies. We've
16 talked about the bank was one of them?
04:16:56
17 A.
Yes, sir.
18 Q.
Guardian Bank?
19 A.
Yes, sir.
20 Q.
What were the other companies he had at that time in
21 1988?
22 A.
It was a development company. I don't know the name
23 at that time. I don't remember it was called Guardian

24 Development or Stanford Development. He also has another
04:17:13
25 investment company in Miami that he works with the bank.

788
1 Q.
You say works with the bank. What did the investment
2 company do for the bank?

3 A.
Promoted the bank products to the clients in Latin
4 America.
04:17:25
5 Q.
Once you started getting Idea Advertising off the
6 ground, what percentage of your work focused on the bank

7 if you can give an estimate?
04:17:40
8 A.
Over 90 percent. I mean, mostly with the bank.
9 Q.
And is the bank the company that Mr. Stanford spent
10 most of his time working on during that period?

11 A.
That was my impression, yes.
12 Q.
And you said you learned at some point the bank was
13 based in Montserrat?
04:17:52
14 A.
Yes, sir.
15 Q.
Did you ever visit Montserrat?
16 A.
Yes, sir.
17 Q.
Why did you go to Montserrat?
18 A.
After -- when I took the job, I talked to
19 Mr. Stanford. We talk it about that I will need to know

04:18:05
20 all the other -- they have offices in many cities, and I

21 would like to go and look at the offices. Because one of
22 the first objective was to create this brochure that you
23 you're showing me so when you show picture of the
24 different offices and the different places.
04:18:20
25 Q.
And this brochure, which is already in evidence as

789
1 Government 522, I'll hand you a -- an actual original

2 copy.
04:18:35
04:18:49
3 A.
Uh-huh.
4 Q.
Is that the brochure you've just been talking about?
5 A.
Yes, sir.
6 Q.
And it has the picture of the Milam building?
7 A.
Yes, sir.
8 Q.
And who published this promotional brochure?
9 A.
We did in the advertising.
10 Q.
How can you tell when you look at these brochures if
11 it's something that you produced at Idea or it was done

12 before or after?
13 A.
The kind of paper is -- emulates a very expensive
14 paper, but, actually, it only had a -- it's a printed

04:19:04
15 pattern that make it look like a very expensive paper, but

16 it's not. And I remember that that was one of the first
17 things that we implemented in all their marketing
18 products.
19 Q.
04:19:18
You said this brochure focused on the different
20 cities that Stanford had offices in?

21 A.
22
Yes, sir.
MR. COSTA: Can we go to the document camera,
23 please, Ellen.
24
04:19:28
25
Thank you.
CASE MANAGER: You're welcome.
790
1 BY MR. COSTA:
2 Q.
So if we look, there's the picture of that Houston
3 building, correct, from Milam?
04:19:45
4 A.
Yes, sir.
5 Q.
And then if we look here, which office does it
6 discuss?
04:19:58
04:20:12
04:20:17
7 A.
The Houston offices.
8 Q.
If we turn the page, which office is being discussed?
9 A.
El Paso.
10 Q.
Was there an El Paso office?
11 A.
Yes, sir.
12 Q.
Did that last a long time?
13 A.
No, not really.
14 Q.
And, actually, it says the El Paso/Juarez area. Is
15 that the focus of that office?

16 A.
Yes, sir.
17 Q.
Juarez is in Mexico?
18 A.
Yes, sir.
19 Q.
Then Miami?
20 A.
Yes, sir.
21 Q.
And for each of these, there's a picture. Is that --
22 what's that photo --
04:20:28
23 A.
That would be the Miami office.
24 Q.
So you went down to Montserrat to see what the
25 office -- the bank was like down there?

791
04:20:37
1 A.
Yes, sir.
2 Q.
What did you see in Montserrat?
3 A.
Mostly an empty building.
4 Q.
There was an office?
5 A.
It was an office with a name and a sign, but it was
6 three or four people there, and that's all. It's not -7 it doesn't seem to be a functioning office at all.
8 Q.
You said there were three or four people in there.
9 Did you try to interview those employees and find out

04:20:54
10 about the bank's operations?

11 A.
Yes. We talk, and they were not interested in having
12 any kind of conversation.

13 Q.
What did one of the employees want to do instead?
14
04:21:05
MR. FAZEL: Objection, Your Honor, asking for
15 hearsay.
16
THE COURT: How about hearsay.
17
MR. COSTA: Your Honor, I'm just asking -- I'm
18 not saying what she told him.

19
04:21:14
What did she want to -- where did she want
20 to show you -- what did the employee want to show you in

21 Montserrat.
22
THE WITNESS: The island, the tourism parts of
23 the island.
24 BY MR. COSTA:
04:21:21
25 Q.
Did she want to spend much time at the bank?

792
1 A.
I would prefer, but it was nothing there to see or to
2 talk. There were a couple of computers that were not

3 hooked into anything, but they were just there.
4 Q.
04:21:35
What do you mean when you said the computers weren't
5 hooked into anything?

6 A.
I remember looking at it, and they did not have
7 electricity. They were not plugged into the outlets or

8 anything like that.
9 Q.
04:21:45
Did you take many pictures when you were down there?
10 A.
No. I don't remember even taking any.
11 Q.
So when you got back to Houston, did you talk to
12 Mr. Stanford about what you had seen these unplugged

13 computers and a few employees in Montserrat?
14 A.
04:22:01
Not in that detail that I remember. I told him that
15 it was nothing in Montserrat that we can show in the

16 brochures.
04:22:14
17 Q.
And what did Mr. Stanford Say?
18 A.
That don't do it.
19 Q.
I want to show you still in that promotional brochure
20 where I showed you, El Paso, Miami, Houston. Showing you

21 another page that says at the top "Our headquarters" --
04:22:30
22 A.
Yes, sir.
23 Q.
-- "Montserrat, BWI." Is that British --
24 A.
British, West Indies.
25 Q.
And it talks here about the history of Montserrat,

793
1 about Columbus discovering it in 1493; is that right?

2 A.
Yes, sir.
3 Q.
And the corresponding picture on the left, is that a
4 picture of the Montserrat office from when you went down

04:22:47
5 to visit the island?

6 A.
No, sir. That's a picture of Houston.
7 Q.
But all the other -- all the other pages in this
8 brochure when they talk about a city actually show the

9 building for that particular city; is that right?
04:22:59
10 A.
Yes, sir.
11 Q.
Was work for the bank being done in the Houston
12 office?
04:23:18
04:23:27
13 A.
What do you mean with work?
14 Q.
Where did Mr. Stanford spend most of his time the
15 first few years you were at the company?

16 A.
In the Houston office.
17 Q.
Were there salespeople for the bank in Houston?
18 A.
Yes, sir.
19 Q.
Do you recall who some of those people were?
20 A.
Yes, there were -- you want the names?
21 Q.
Sure.
22 A.
Okay. Mr. Alvaro (phonetic) Moreno, Ms. Michelle
23 Chambliess, Elsie Etheridge, Maria Plumingdon (phonetic)

24 and the lawyers and the other that also act as a
04:23:42
25 salesperson or a banker under -- respective each one of

794
1 them have a -- an assistant.

2 Q.
Were there ever any issues about what kind of work
3 could be done in Houston versus what kind of work had to

4 be done in Montserrat in the Caribbean?
04:24:00
5 A.
I don't understand the question.
6 Q.
Well, was there ever -- did Mr. Stanford ever discuss
7 U.S. regulation?
8 A.
Oh, yes. He told me that they were not supposed
9 to -- what would be the right way? All the clients are

04:24:17
10 supposed to be outside of the United States, and they

11 cannot solicit money inside of the United States. They
12 have to do it outside. So the bankers travel constantly
13 to the different countries.
14 Q.
04:24:32
Did he say why he didn't want to sell the CDs in the
15 United States?
16 A.
Oh, he say that that was against the bank
17 regulations.
04:24:47
18 Q.
Which regulations, did he say?
19 A.
If I remember right -- what do you call it -- bank
20 and forwarding bank needs to have permission to do that,

21 and they do not have it.
22 Q.
He didn't try to get that operation to operate and
23 sell in the United States?
04:24:58
24 A.
Not at that time, no.
25 Q.
Did he have any -- did he express any views about

795
1 U.S. regulation and running the bank and selling the

2 product in the United States?
3 A.
Many times he say that the regulators here were too
4 strict, and he did not like it, but that's what the law
04:25:13
5 said.
6 Q.
As you started to do these promotional materials, who
7 was telling you about the bank's products?
04:25:28
8 A.
Mr. Allen Stanford.
9 Q.
Was he involved in giving you information for these
10 promotional brochures?
11 A.
Yes, he would write it and change it and revise it
12 constantly.
13 Q.
Did you know much about banking or finance when you
14 started there?
04:25:36
15 A.
No, sir.
16 Q.
So what was your job? If he's writing the
17 promotional brochures, what would your job entail?
04:25:49
04:25:59
18 A.
To make it look pretty.
19 Q.
And did you learn what the main product of the bank
20 was?
21 A.
CD.
22 Q.
And what does "CD" stand for?
23 A.
Termed certificate of deposits.
24 Q.
And you've already said they weren't sold in the
25 United States when you were working for Mr. Stanford?

796
1 A.
Yes.
2 Q.
Where were they sold during that time period?
3 A.
Mostly in Mexico and a little bit in Central America,
4 some countries in South America, like Peru and Venezuela,

04:26:15
5 and in the Caribbean. It was another person and another

6 office in Aruba, Mr. Frank Benderhood (phonetic), and he
7 would sell it in his area, but I didn't know much about
8 his -- what he did there.
9 Q.
04:26:35
And what did Mr. Stanford say about the bank's
10 interest rates versus other banks that were offering CDs?

11 A.
You're talking about the size, the amount --
12 Q.
Right, the interest rates he was offering.
13 A.
Oh, that he -- the strategy was to be always
14 2 percent over what a U.S. bank would offer in a CD.

04:26:53
15 Q.
And did he say why that 2 percent level was what he
16 wanted?
17 A.
He mentioned a couple of times that -- that he find
18 out that the people would be willing to risk -- and he say

19 risk their money for 2 percent. They're greedy, he says.
04:27:11
20 So for 2 percent, they're willing to invest in our bank

21 with no FDIC.
04:27:23
22 Q.
And he called that a -- risking their money?
23 A.
That's the way that I remember.
24 Q.
And what was his attitude when he was talking about
25 these people who would risk their money for an extra

797
1 2 percent?
2 A.
Well, usually we were -- the target was people who
3 had $100,000, around that amount of money. So he will

4 look at me and say, "Looking for $2,000 extra, they're
04:27:40
5 willing to put $100,000 in risk."

6 Q.
So he actually added up how much that 2 percent
7 difference would be --
04:27:50
8 A.
Yes, that it would be, $2,000.
9 Q.
-- for a typical CD purchaser?
10 A.
Yes, sir.
11 Q.
And what kind of attitude was he expressing when he
12 said the 2 percent was this number that would get people
13 to risk their money?
04:28:02
14 A.
Not very respectful to his clients, in my opinion.
15 Q.
Was that typical of what you saw from Mr. Stanford?
16 A.
Yes, sir.
17 Q.
And we've already talked about Mr. Stanford had a
18 sales force here in Houston?
04:28:18
19 A.
Yes, sir.
20 Q.
You said Michelle Chambliess and Elsie Etheridge and
21 folks like that?

22 A.
Yes, sir.
23 Q.
What did Mr. Stanford tell you about how he
24 compensated or paid his sales team?

04:28:29
25 A.
That he give them the best salary available possible

798
1 and give them some percentage out of the amount of money

2 that they bring into the bank.
04:28:44
3 Q.
Out of the CDs they sold?
4 A.
Yes, sir.
5 Q.
And did he compare that to how other banks paid their
6 banker who were selling CDs?

7 A.
He mentioned that that's very unusual to give -- at
8 that time to give a percentage, an incentive. They -9 usually bankers work for a salary.
04:29:02
10
THE COURT: Could you move the mike just a
11 little. You're carrying just fine.

12
THE WITNESS: Okay.
13 BY MR. COSTA:
14 Q.
04:29:13
And did you ever attend meetings Mr. Stanford had
15 with this group of salespeople that he employed?

16 A.
Sometimes.
17 Q.
Why would you be needed in those meetings?
18 A.
To learn what the bankers' needs, marketing needs
19 are, were.
04:29:25
20 Q.
Since you were the one publishing the brochures and
21 other promotional materials?
04:29:36
22 A.
And ads, ads and the -- yes.
23 Q.
You mentioned ads. Is that part of what you did?
24 A.
Yes, sir.
25 Q.
Where were the advertisements placed?

799
1 A.
In international -- the international versions of
2 Time magazine, Newsweek, and also Reader's Digest, some

3 financial local newspapers, and I think mostly that.
4 Q.
04:30:03
I'm going to show you what's marked as Government's
5 Exhibit 503 and ask you if you recognize these, Mr. Mejia.
6 A.
Yes, this is --
7 Q.
Where do you recognize them from?
8 A.
These are promotional pieces where it says the
9 amounts of returns for CDs and the terms and -04:30:22
10 Q.
And the three clips behind that first page?
11 A.
Yes. These are -- were ads placed in the
12 international version of the magazine that I'm telling

13 you.
04:30:36
14 Q.
And who created those ads?
15 A.
We created it in Idea Advertising.
16
MR. COSTA: Your Honor, Government offers 503
17 as advertisements for the CDs the bank is offering.
04:30:51
18
THE COURT: I don't hear any objection yet.
19
MR. FAZEL: Were they --
20
MR. COSTA: This is how the bank was
21 advertising the CDs.

22
MR. FAZEL: So it's not for the truth of the
23 matter, so I have no objection.
04:30:57
24
THE COURT: Just --
25
MR. COSTA: It's to show how -- I don't know

800
1 how they were treated. It's to show how they were

2 marketed.
3
THE COURT: All right. And that limited -- for
4 that limited offer, it's admitted.

04:31:04
MR. COSTA: Thank you.
THE COURT: Or in effect, there's no objection
7 for that limited matter because we put all the -- what is

8 it -- all the exhibits into evidence except for an
9 item-by-item objection. There's no objection for that
04:31:19
10 limited purpose. It's limited, but it's in. Go on.

11 BY MR. COSTA:
12 Q.
Mr. Mejia, if I can now direct you to the screen,
13 what is this first page showing?
04:31:37
14 A.
The interest rates for CD deposit of 30 days.
15 Q.
And what language is the writing in?
16 A.
In Spanish.
17 Q.
Was that typical of the bank's advertising during
18 that time period?
04:31:45
19 A.
Yes, sir.
20 Q.
Because these were these ads in Venezuela and Mexico
21 and other Latin American countries?

22 A.
Yes, sir.
23 Q.
So there it tells you -- or does it depend on the
24 dollar amounts what interest rate is paid?

04:31:57
25 A.
Yes, sir.
801
04:32:04
1 Q.
How much is deposited?
2 A.
Yes.
3 Q.
But it goes --
4 A.
Is the -- it's just for the amount in this case, yes.
5 Q.
And it goes all the way down to $10,000; right?
6 A.
Yes, sir. That was the minimum.
7 Q.
Do you think someone with $10,000 to invest is a very
8 rich person?
9
04:32:18
MR. FAZEL: Objection, Your Honor. Form of the
10 question.
11
12 BY MR. COSTA:
13 Q.
People were allowed -- who wanted to save $10,000
14 were allowed to buy a CD according to this advertisement;

04:32:26
15 right?
16 A.
Yes, sir.
17 Q.
And these are the interest rates, going from 8.75 up
18 to 9.75 percent?
19 A.
04:32:34
Yes, sir.
20
THE COURT: What year was that?
21
THE WITNESS: If you move it there, please. I
22 don't -- 1987.
23
THE COURT: Okay.
24 BY MR. COSTA:
04:32:44
25 Q.
If we go to the second page, do you recognize that,

802
1 Mr. Mejia?
2 A.
Yes, sir.
3 Q.
And that's one of the advertisements you've talked
4 about?
04:32:53
5 A.
Yes.
6 Q.
And what interest rate is being offered in big print
7 in that advertisement?
04:33:10
8 A.
10.75 percent.
9 Q.
And there's a photo. What does it say? Can you
10 translate that Spanish?

11
MR. FAZEL: Judge, may I have a moment?
12
(Conferring.)
13 BY MR. COSTA:
04:33:20
14 Q.
What does the ad say?
15 A.
"Enjoy the pleasures of life."
16
MR. FAZEL: I'm sorry, Your Honor, I don't
17 think he's asking him to -- I don't know what to tell you.

18 I'd object to him translating verbatim what it says on
19 there. That's my objection. Some jurors do speak Spanish,
04:33:37
20 I realize.
21
MR. COSTA: I just want to know what the
22 advertisement says, what are they telling the people.

23
THE COURT: What are they telling people?
24 Instead of an exact translation, what's the summation of

04:33:45
25 that advertisement?
803
THE WITNESS: That you can enjoy life with a
2 big return. If you deposit your money with us, you will
3 get a big return, and then you can enjoy the pleasures of
4 life.
04:34:03
5 BY MR. COSTA:
6 Q.
And there's some more writing there.
Is there any mention of security with this
8 investment in the bank?

9 A.
04:34:15
Yes, sir.
10 Q.
What's the Spanish words for security?
11 A.
Seguridad.
12 Q.
And in the bottom right here, there's a box with
13 dotted lines around it.

14
04:34:28
What's the purpose of that?
15 A.
That perspective clients can return this to the bank.
16 Q.
Fill out information on there?
17 A.
Asking for more -- there are actually two ways even:
18 Asking for more information and asking for instructions to

19 open an account.
04:34:44
20 Q.
So they can clip that out and mail it in?
21 A.
Yes, sir.
22 Q.
Did you discuss with Mr. Stanford expanding the
23 countries that he was targeting for his sales?
04:35:00
24 A.
Yes, sir.
25 Q.
And what other countries were discussed?

804
1 A.
Ecuador. We talk a little bit about Argentina, but
2 it was not a -- and Brazil, but they didn't seem that it

3 was right at that time. We talk about some European
4 countries that it didn't seems like it was -- you know,
04:35:19
5 that we were ready to do that. So we talk more in

6 Venezuela, more in Ecuador, and so in South America and in
7 Central America.
8 Q.
In addition to advertisements, I think you've said
9 you did some brochures?

04:35:40
10 A.
Yes, sir.
11 Q.
What was the purpose of these brochures?
12 A.
To provide information to the prospects, I mean to
13 the people interested in opening an accounts.

14 Q.
04:35:51
So who would -- after you printed these brochures,
15 who would receive them?

16 A.
Prospective clients in Latin America, and in some
17 case, clients also that would receive them.

18 Q.
Were there some brochures that were already produced
19 by the time you got to Guardian or to Idea Advertising?

04:36:09
20 A.
I think there were two or three already being
21 produced before I get there.

22 Q.
I'm going to hand you what's marked as
23 Government's 519 and ask if you recognize that.

24 A.
04:36:24
Yes, sir. This is one of the brochures that it was
25 made before I get there.

805
1 Q.
And did you use some of the information in those old
2 brochures when you were creating the brochures that Idea

3 Advertising was producing?
4 A.
04:36:37
I was told that all the information needed is here,
5 yes.
6 Q.
Who told you that?
7 A.
Mr. Allen Stanford.
MR. COSTA: Government offers 519 as another
9 example of what the depositors were being told.

04:36:45
10
MR. FAZEL: No objection as long as it's not
11 offered for the truth of the matter.

12
THE COURT: For the limited purpose --
13
MR. COSTA: We don't think it's true, so we're
14 fine with that.

04:36:51
15
MR. FAZEL: Judge, I object to the side bar.
16
17 BY MR. COSTA:
18 Q.
Mr. Mejia, I want to show you this page of this
19 brochure, and I want to direct your attention to the

04:37:12
20 question that's now at the top.

21
04:37:22
What does that say?
22 A.
"Does the bank make loans?"
23 Q.
And what is the answer?
24 A.
"Guardian International Bank, Limited, has never made
25 and will never make loans or offer credit instruments."

806
1 Q.
Is that consistent with what you were told about the
2 bank by Mr. Stanford?
04:37:35
3 A.
Yes, sir.
4 Q.
What did Mr. Stanford say -- if they weren't making
5 loans with the depositors' money, what did Mr. Stanford

6 say was being done with the depositors' money?
7 A.
What I remember it was mostly investment in currency
8 exchange, currency exchange and things like that.

9 Q.
04:37:55
And the information for questions like that, where
10 does that come from?

11 A.
Mr. Allen Stanford.
12 Q.
Would he just give you the information initially and
13 then you'd print them out and hand them out, or did he get
14 involved in another part of the process?
04:38:09
15 A.
No. Before we print it, he would go and revise,
16 correct it and approve it before we print anything.
04:38:30
17 Q.
What was the level of his revisions, typically?
18 A.
Very intense, I would say, very -- a lot.
19 Q.
What was the quality of the brochures Mr. Stanford
20 wanted in terms of the paper and the print?

21 A.
04:38:40
The best that we can.
22
MR. FAZEL: Excuse me. Object to relevance.
23
THE COURT: All right. What's the relevance?
24
MR. COSTA: It's all about Mr. Stanford's
25 promotional materials and how he marketed them and how he

807
1 tried to obtain clients.

2
THE COURT: Overruled. It's his time.
THE WITNESS: The best that we can produce.
4 BY MR. COSTA:
04:38:51
5 Q.
Did he say what he wanted it to look like?
6 A.
Very rich, that it belonged to a very rich company.
MR. COSTA: And I want to go to 522. If we
8 can -9
04:39:07
04:39:26
THE COURT: What do you need --
10
MR. COSTA: -- switch back to the sanctions.
11
THE COURT: Back down to your --
12
MR. COSTA: The computer, Your Honor.
13
THE COURT: Good work.
14
MR. COSTA: Worked. Very good. Thank you.
15
Could we go to Page 7?
16
THE COURT: See, Ellen was coming in. She
17 heard what was going on. I actually had done it, did it
18 myself.
04:39:35
19
MR. COSTA: And if we can look at that --
20
THE COURT: Go on.
21
MR. COSTA: May I proceed, Your Honor?
22
THE COURT: Yes.
23 BY MR. COSTA:
24 Q.
04:39:41
If we look at that top portion that's already
25 highlighted in yellow.
808
04:39:51
Can you read that, Mr. Mejia?
2 A.
"Our board of directors."
3 Q.
Underneath that where it says, "The operating."
4 A.
"The operating philosophy of Guardian International's
5 board of directors is the absolute safety of our clients'

6 money and its short-term liquidity. We specialize in a
7 few select investment instruments that ensures the least
8 risk with the greatest return; providing a level of
9 personal service second to no one."
04:40:12
10
MR. COSTA: And if we can back out now to the
11 full page.
12 BY MR. COSTA:
13 Q.
Does it list the members of the board of directors at
14 that time?
04:40:20
15 A.
Yes, sir.
16 Q.
Did you ever go and meet with the board of directors
17 during your time working with Mr. Stanford?
04:40:30
04:40:45
18 A.
Occasionally.
19 Q.
Where was -- where were the meetings taking place?
20 A.
In Mexia, Mexia.
21 Q.
Close to your last name; right?
22 A.
Well, the same, actually.
23 Q.
With an X instead of a J?
24 A.
Old Spanish, there were no Js, just X.
25 Q.
And what would you do when you met with the board of
809
1 directors?
2 A.
Present a marketing material.
3 Q.
Was there ever a time when you told Mr. Stanford, you
4 asked him if you could change the time of day your

04:40:58
5 presentation was scheduled for?

6 A.
Yes. He wants me to go there in the morning, and I
7 wanted to finish something or have another meeting. So I

8 asked if we can do it -- if I can present it in the
9 afternoon, and laughing, he said, "No, in the
04:41:12
10 afternoon" -11
MR. FAZEL: I'm sorry, Your Honor. Narrative,
12 relevance.
13
THE COURT: Sustained as to a narrative.
14 BY MR. COSTA:
04:41:19
15 Q.
You just said you wanted -- you were scheduled for
16 the morning?
17 A.
Yes, sir.
18 Q.
Did you want to switch the time you were meeting with
19 the board?
04:41:26
04:41:33
20 A.
Yes, sir.
21 Q.
When did you want to meet with the board?
22 A.
In the afternoon.
23 Q.
And did you tell Mr. Stanford that was your desire?
24 A.
Yes, sir.
25 Q.
And what did he say when you said, "I'd rather -- my

810
1 schedule won't -- allows me to meet in the afternoon"?

2 A.
"The afternoon is when we talk about numbers, so I
3 wanted to do it in the morning, your portion."

4 Q.
04:41:48
Did he say why -- was there was a reason he liked
5 talking about numbers in the afternoon?

6 A.
Yes. He joke and say that in the afternoon they're
7 all -- they were sleeping, so that's what he likes better,

8 talks numbers in the afternoon.
9 Q.
04:42:03
04:42:15
In addition to these promotional brochures, did the
10 bank produce something called an annual report?

11 A.
Yes, sir.
12 Q.
Whose idea was the annual report?
13 A.
Mr. Allen Stanford.
14 Q.
What did he say the purpose of the annual report was?
15 A.
Use it as a marketing material.
16 Q.
So who would receive it?
17 A.
Prospective clients and clients.
18 Q.
Would the private bankers receive it to use in
19 selling the CDs?

04:42:27
20 A.
Yes, the private bank -- give it to the private
21 bankers.
22 Q.
Was there one annual report that was already in the
23 works or being finalized by the time you started working

24 for Mr. Stanford?
04:42:38
25 A.
There was already one already finished or printed,

811
1 yes.
2
MR. COSTA: If could we go to Exhibit 100.
3 It's already in evidence.

4 BY MR. COSTA:
04:42:52
5 Q.
I'll hand you the original. I think it's hard to see
6 the way it's scanned, but what year is Exhibit 100.
04:43:06
7 A.
1987.
8 Q.
So what does it say in the bottom?
9 A.
"Annual Report 1987."
10 Q.
So if it says it's the 1987 report, when would that
11 actually have been printed?
04:43:19
12 A.
1988.
13 Q.
Explain that. Why is it the next year?
14 A.
You need to finish the year to actually be able to
15 print it.
16 Q.
Because this is reporting the bank's financial
17 numbers for the end of the year 1987?
04:43:26
18 A.
Yes, sir.
19 Q.
And did you print this one?
20 A.
No. It was not created by us, I mean the Idea
21 Advertising. I do not remember if we were -- oversee the

22 printing or not. That, I don't remember.
04:43:38
23 Q.
So this was already in the works by the time --
24 A.
Yes.
25 Q.
-- you arrived?
812
1 A.
Yes, sir.
2 Q.
I want to move ahead to the next year and show you
3 Government 101, also already in evidence.

4
04:43:51
Do you recognize that, Mr. Mejia?
5 A.
Do you have the original?
6 Q.
Yes.
7 A.
Yes. I create -- we create this idea.
8 Q.
Who was in -- who did you get information from to
9 create this 1988 annual report?

04:44:11
10 A.
Mostly from Mr. Allen Stanford.
11 Q.
And what year would the '88 annual report have been
12 published?
04:44:23
13 A.
1989.
14 Q.
And by that time, had Mr. Stanford hired someone
15 named Mr. Jim Davis?

16 A.
He was already working there when I arrived, yes.
17 Q.
Did you know what Mr. Stanford's past relationship
18 was with Mr. Davis?
04:44:34
19 A.
No.
20 Q.
Did you have any idea that they were friends?
21 A.
Well, that's -- yes, they were friends; but I --
22 personally, I didn't know.
04:44:45
23 Q.
Who was in charge? Mr. Davis or Mr. Stanford?
24 A.
Of what?
25 Q.
Of running Mr. Stanford's companies?

813
1 A.
Oh, Mr. Stanford.
2 Q.
And even for with Guardian Bank, was Mr. Stanford or
3 Mr. Davis in charge?
04:44:55
4 A.
Mr. Allen Stanford.
5 Q.
Was there even a question in your mind about which
6 one of them was in charge?

7 A.
No, sir.
8 Q.
Were you given -- when you started working on this
9 annual report, were you given any special instructions by

04:45:10
10 Mr. Stanford?
11 A.
Yes, sir.
12 Q.
Tell the jury about those special instructions.
13 A.
That I need to work during -- after hours in the
14 production of this annual report.

04:45:22
15 Q.
Had you ever been told that for any of the other work
16 you'd done for advertisements or brochures?

17 A.
No, sir.
18 Q.
Were you ever told that in the years following the
19 production of this annual report?

04:45:34
20 A.
No, sir.
21 Q.
And in addition to telling you to work on it after
22 hours, did Mr. Stanford give you any instructions about

23 your willingness to talk about this project with other
24 employees?
04:45:45
25 A.
No. He doesn't want anybody to see portions or parts

814
1 of this when I -- we were working on it. So that's what

2 he say, "Please work on after hours."
3
MR. COSTA: Let's go to Page 4, please.
4 BY MR. COSTA:
04:46:05
5 Q.
Do you recognize that page, Mr. Mejia?
6 A.
Yes, sir.
7 Q.
I don't want you to read it, but what is that page?
8 A.
It is the letter from the chairman, Mr. James
9 Stanford.
04:46:15
04:46:26
10 Q.
Who's Mr. James Stanford?
11 A.
Father of Mr. Allen Stanford.
12 Q.
And he was chairman of the board at that time?
13 A.
Yes, sir.
14 Q.
Who actually wrote this letter, from what you saw?
15 A.
I think it was by Mr. Allen Stanford, what I
16 remember.
17
MR. COSTA: If we can go to Page 7.
18 BY MR. COSTA:
19 Q.
04:46:40
When you started getting the numbers to put in this
20 annual report, did you notice anything that caused you to

21 have concerns about the numbers?
22 A.
On Page 7?
23 Q.
Or anywhere in your report. Was there an entry that
24 you thought didn't seem right to you?

04:46:56
25 A.
Yes. In the operating are expenses is an entry for

815
1 advertising for 147,114.

2 Q.
Advertising. And this is the expense page of the
3 annual report?
04:47:12
4 A.
Yes, sir.
5 Q.
And what did it say the expenses for advertising were
6 for that year?
04:47:27
7 A.
147,114.
8 Q.
And why did you notice that number?
9 A.
Because the expenses for the advertising agency was
10 way over that one, double that one at least.

11 Q.
You were running the Idea Advertising; right?
12 A.
Yes, sir.
13 Q.
And would the bank -- you were doing work for the
14 bank, would the bank pay Idea Advertising?

04:47:38
15 A.
Yes, sir.
16 Q.
And you thought the expenses were a lot higher for
17 the bank than 147,000?
04:47:46
18 A.
Yes, sir.
19 Q.
Did you tell Mr. Stanford that?
20 A.
Yes, sir.
21 Q.
What did he say?
22 A.
That a lot of the expenses were -- that this is okay
23 because most of the expenses for advertising was shared

24 with the office in -- and the company and office in Miami,
04:48:03
25 and that's what they -- this is okay.

816
1 Q.
Now, as you were continuing to work on this report,
2 were the numbers changed after you initially received

3 them?
4
04:48:15
I'm not talking about advertising anymore.
5 Just generally the numbers in the report?

6 A.
Yes, sir.
7 Q.
How were they first changed?
8 A.
I gave the first set of a proof, what we call it in
9 the industry, a printout of the said -- of the first set

04:48:31
10 of numbers, and they came back to me with a lot of changes

11 on the numbers.
04:48:45
04:48:51
12 Q.
Who is "they"?
13 A.
Mr. Davis and Mr. Allen Stanford.
14 Q.
Do you recall specifically which numbers they were
15 changing -16 A.
No.
17 Q.
-- 20-plus years later now?
18 A.
No, I don't remember.
19 Q.
But Mr. Stanford and Mr. Davis were in your office
20 doing this?
21 A.
At the beginning with Mr. Davis, and I give it to
22 him. And then he went back to his offices and came back
23 with changes. And they were different changes, different
24 ink and different things. Then I give it back. And I
04:49:11
25 don't remember we discussed that in Mr. Allen Stanford

817
1 office or in my office, but with the both of them, with

2 Mr. Davis and Mr. Allen Stanford.
3 Q.
And when Mr. Davis and Mr. Stanford were both with
4 you, what did they have with them when they were changing
04:49:25
5 the numbers?
6 A.
A calculator, an HP calculator, the one that you have
7 to input.
04:49:35
8 Q.
Who was typing into the calculator that you remember?
9 A.
Mr. Stanford.
10 Q.
Did he have a bunch of bank records or business
11 records that he was using to see what numbers to put into

12 that calculator?
04:49:50
13 A.
Not that I remember, sir.
14 Q.
Did you notice any problems with the numbers that
15 Mr. Stanford was getting by punching into the calculator?

16 A.
Yes. I was like here. I was working at the
17 computer, they were behind me. And when I was working, I

18 noticed very easily that some of those numbers, they did
19 not add up correctly. So I mentioned that this doesn't
04:50:09
20 add up. I don't remember where, but I remember seeing

21 that.
22
And so they laugh and they correct it and
23 they changed the numbers.
04:50:19
24 Q.
"They" being?
25 A.
Mr. Allen Stanford and Mr. Davis.

818
1 Q.
Now, were you checking the work with a calculator, or
2 are you, just with your own eyes, able to see that these
3 numbers didn't add up?
4 A.
04:50:31
No, it was an obvious mistake. Easy to -- you know,
5 like 9 plus 1 doesn't give you 5 or something like that.

6 Q.
And after you pointed out this error, what -- they
7 laughed and then what was done?

8 A.
They were actually to change it to this -- they
9 changed the numbers that they add up.

04:50:46
10 Q.
They corrected it?
11 A.
Yes, sir.
12
MR. COSTA: Can we go to Page 11 in the report,
13 please? Thank you.

14 BY MR. COSTA:
04:50:53
04:51:08
04:51:14
15 Q.
Does this look familiar, Mr. Mejia?
16 A.
Yes, sir.
17 Q.
What is that page of the annual report?
18 A.
It's auditors' report and --
19 Q.
Who was the bank's auditor for the entire period you
20 work for Mr. Allen Stanford?

21 A.
Mr. Hewlett.
22 Q.
Mr. Hewlett you said?
23 A.
Mr. Hewlett.
24 Q.
Do you know where his accounting firm was?
25 A.
In Antigua.
819
1 Q.
And that 1988 annual report, this one you worked on
2 where you just talked about Mr. Stanford and Davis

3 changing the numbers, do you recall how you obtained that
4 letter for Mr. Hewlett?
04:51:29
MR. COSTA: If you can scroll down, I think you
6 see his signature, him signing off on a letter.

7
THE WITNESS: How we obtained the signature,
8 you mean?
9 BY MR. COSTA:
04:51:40
10 Q.
Well, how did you get a -- Mr. Hewlett in that
11 letter's signing off in the financial statements; correct?

12 A.
Yes, sir.
13 Q.
What was the process you saw of Mr. Hewlett's
14 approving the numbers?

04:51:48
15 A.
When the numbers were approved, when the pages with
16 the numbers were approved, we faxed it from Idea

17 Advertising office to Mr. Hewlett's fax in Antigua, and we
18 get it back from him.
19 Q.
04:52:06
04:52:17
And how long did it take to get the approval back
20 from Mr. Hewlett for the numbers?

21 A.
No more than 15 minutes.
22 Q.
1-5?
23 A.
Yes, 1-5. 15.
24 Q.
What was your reaction to Mr. Hewlett signing off on
25 the numbers in 15 minutes?

820
1 A.
I was surprised. I mean, it took me more to do my
2 checkbook, so I thought that that was quick.

3 Q.
And this is the financial statements for an entire
4 bank; right?
04:52:28
5 A.
Yes, sir.
6 Q.
And the numbers had been changed in the previous
7 days; right?
04:52:36
8 A.
Yes, sir.
9 Q.
That's what you talked about was seeing the numbers
10 being changed, that had just happened; right?

11 A.
Yes, sir.
12 Q.
And then it was faxed off to Mr. Hewlett and the
13 15-minute approval?
04:52:46
14 A.
Yes, sir.
15 Q.
In future years, was it this same process with the
16 annual report where you were told to be up there at night

17 and do it without talking to any other employees?
04:52:58
18 A.
No, sir.
19 Q.
What changed after the 1988 annual report?
20 A.
I was told that this time I would get the -- only one
21 set of final numbers, and we would not go through what we

22 did this time.
23 Q.
So in later years, you weren't involved until there
24 was a final product, final set of numbers?

04:53:14
25 A.
No.
821
1 Q.
Did the bank -- according to this annual reports, did
2 the bank's assets grow over the time you were working
3 there?
04:53:23
4 A.
Yes, sir.
5 Q.
Do you recall generally what the bank reported its
6 assets to be when you started at Idea Advertising?

7 A.
It was something between five to $8 million in
8 deposits. And by the time that I left was 60-something

9 millions in deposits.
04:53:41
10 Q.
I want to show you what's in evidence as
11 Government 103.
12
MR. COSTA: Turn to Page 13. Go to Note 4 or
13 the investment portfolio. I think it's under Note 4.

14 BY MR. COSTA:
04:54:05
15 Q.
And this is the 1990 report, Mr. Mejia.
16
Is this one that you would have printed
17 but one where you explained you weren't involved in

18 putting the numbers together?
04:54:26
19 A.
Yes, sir.
20 Q.
And is this the type of information that was
21 typically in the annual reports information about the

22 investment portfolio?
04:54:38
23 A.
Yes, sir.
24 Q.
And it actually gives dollar amounts for bonds.
25
How much did it say was in bonds in that

822
1 year?
04:54:54
04:55:02
2 A.
19 million-plus.
3 Q.
Equities, what did it say was in equities?
4 A.
2 million-plus.
5 Q.
Commercial paper?
6 A.
Half-a-million plus.
7 Q.
Notes?
8 A.
Quarter of a million.
9 Q.
In these later years, was Mr. Stanford still involved
10 in approving the annual report before it was published and

11 sent out to clients?
12 A.
Yes, sir.
13 Q.
What was his level of involvement with the annual
14 report, even in '90, '91, '92?

04:55:14
15 A.
In control of the product.
16 Q.
Was it an important publication to him?
17 A.
That was my impression, yes.
18 Q.
You said earlier that -- you said earlier you
19 attended meetings with the private bankers and

04:55:31
04:55:40
20 Mr. Stanford?
21 A.
Yes, sir.
22 Q.
Was Mr. Davis typically in those meetings?
23 A.
No.
24 Q.
Did an issue about insurance ever arise in those
25 meetings?
823
1 A.
Yes, sir.
2 Q.
And what was Mr. Stanford being told about insurance
3 issues that the clients were raising?

4 A.
04:55:55
The bankers had a portfolio that they showed to
5 clients, and it was policy of an insurance policy there

6 that it was update -- I mean that was dated. It was
7 already not working anymore, so the bankers wanted to a
8 new one.
9 Q.
04:56:17
So there wasn't insurance policy in these binders the
10 bankers had to show clients?

11 A.
Yes, sir.
12 Q.
And you said it was not working anymore. Do you mean
13 it was expired?
04:56:22
14 A.
It was expired.
15 Q.
And so, what were the bankers asking Mr. Stanford to
16 do?
17 A.
To please renew the insurance policy, that it was
18 important for them and for the clients.
04:56:35
19 Q.
And what was Mr. Stanford's reactions?
20 A.
He would always say that they're not selling a U.S.
21 bank product, they were selling a different product, so an

22 insurance was not that important. They should not -- they
23 should sell the product without that insurance.
24 Q.
04:56:51
But did there come a time when you were actually
25 asked to create an insurance document?

824
1 A.
Yes, sir.
2 Q.
Who initially asked you to create the insurance
3 document?
4 A.
04:57:00
Mr. Davis.
MR. COSTA: I want to turn to 502, which is
6 already in evidence.
7 BY MR. COSTA:
04:57:14
8 Q.
Is this the document you created, Mr. Mejia?
9 A.
No, sir.
10 Q.
Is that name, the British Insurance Fund, Limited, is
11 that the name of the policy you were asked to create?

12 A.
Yes, sir.
13
MR. COSTA: And if we can go to Page 3 and look
14 at the date and the term in the middle.

04:57:24
04:57:39
15 BY MR. COSTA:
16 Q.
When did this document expire?
17 A.
In June of 1988 -- no.
18 Q.
July?
19 A.
No. July of 1988. I'm sorry.
20 Q.
Right. And was that around the time period when you
21 started working for Mr. Stanford?

22 A.
23
Yes, sir.
MR. COSTA: If we can go back to the first
24 page, please, and look at the top.

04:57:51
25 BY MR. COSTA:
825
1 Q.
What is the address on this document for British
2 Insurance Fund?
04:58:06
3 A.
First floor of 31st -- 35 Piccadilly, London.
4 Q.
During the course of your time with Mr. Stanford, did
5 you learn what existed at that address in London?

6 A.
Yes, sir.
7 Q.
What did you understand existed there?
8 A.
A P.O. box number only, not a physical address, but a
9 P.O. box.
04:58:19
10 Q.
How did you get that understanding?
11 A.
One of the banker -- I don't remember if Michelle
12 or -13
MR. FAZEL: I'm sorry, Your Honor. Asking for
14 hearsay.
04:58:28
15
THE COURT: Sir, I can't hear you.
16
MR. FAZEL: It's hearsay testimony.
17
THE COURT: Sustained if that's where it's
18 going. If you can get around it, do it.

19 BY MR. COSTA:
04:58:34
20 Q.
Did you understand that someone had actually visited
21 that location?
22 A.
Yes, sir.
23 Q.
You said Mr. Davis at some point asked you to create
24 an updated version of this policy?

04:58:45
25 A.
Yes, sir.
826
1 Q.
What did you say?
2 A.
No, that that would be not correct, you know, to
3 create an insurance policy for a company that I have no

4 knowledge of.
04:58:57
THE COURT: Where were you at the time? In
6 Houston?
7
THE WITNESS: Houston, sir.
8 BY MR. COSTA:
9 Q.
04:59:03
You always on officed in Houston. Is that correct?
10 A.
Yes, sir.
11 Q.
During the time you worked with Mr. Stanford?
12 A.
Yes, sir.
13 Q.
By the way, where was Mr. Davis's office in relation
14 to Mr. Stanford?
04:59:12
15 A.
Next to him.
16 Q.
So you told Mr. Davis you didn't think you could or
17 you should create a policy for the British Insurance Fund?
04:59:23
18 A.
Yes.
19 Q.
In those meetings you'd been in with Mr. Stanford and
20 the bankers when this expired policy was discussed, did

21 Mr. Stanford ever tell the bankers that he owned British
22 Insurance Fund?
04:59:35
23 A.
No, sir.
24 Q.
So what happened when you told Mr. Davis, I can't
25 create an insurance policy for a company that I don't work

827
1 for?
04:59:49
2 A.
He left the office.
3 Q.
Then what happened?
4 A.
He came back and said, What about if we get a --.
MR. FAZEL: I'm sorry. Your Honor, that's
6 hearsay.
7
THE COURT: Who was it that said that?
MR. COSTA: Not for the truth of the matter.
9 Again, we think that -- it's what Mr. Davis is telling him

04:59:56
10 about why he had the right to create this policy.

11
THE COURT: Well, come on up here for a second.
12 Get something on the record.

13
05:00:44
(The following was held at the bench)
14
THE COURT: Okay. How is it admissible?
15
MR. COSTA: Two reasons. First of all, it's
16 not for the truth, it's to show what Mr. Mejia did. Second
17 of all, if it is for the truth, it's a co-conspirator
18 statement Mr. Davis has pled guilty and is facing 30 years.
05:00:55
19
THE COURT: Response.
20
MR. FAZEL: I object to hearsay and
21 confrontation.
05:01:04
22
23
24
THE COURT: I didn't want to say that in front
25 of everybody.
828
05:01:20
MR. COSTA: What time is it?
MR. FAZEL: 5:00 almost.
MR. COSTA: I got at least 30 minutes.
THE COURT: Ladies and gentlemen -- let's see,
5 let me get this back working.

6
(The following was held in the presence of the jury)
THE COURT: Ladies and gentlemen, let me ask
8 you now, it's about 5:02 right now. We adjourn between

9 6:00 and 6:05. Do you want to take a short break at this
05:01:37
10 time?
11
What about the attorneys? Don't forget,
12 if you're not up, you can go in and out.

13
05:01:48
Is everybody okay? Johnny?
14
THE REPORTER: Yes, sir.
15
THE COURT: All right. Let's go, then. We'll
16 go on and right to 6:00 o'clock, then. If anybody ever

17 needs to take a break, let me know, but I'll ask you this
18 about every time if we're on our usual schedule, because it
19 gets close. That means we're pushing about an hour and
05:02:02
20 three-quarters without a break. If that's okay, we're

21 going to keep going, whatever the jury wants. Is that
22 okay, sir? Number one?
05:02:12
23
JUROR: Yes, sir.
24
THE COURT: All right. I couldn't see you
25 behind the screen.

829
05:02:17
All right. Go ahead, then.
MR. COSTA: May I proceed?
MR. COSTA: Thank you.
5 BY MR. COSTA:
6 Q.
Let's back up a little bit. Mr. Davis first asked
7 you to create a policy for the new time period for British
8 Insurance Fund; is that right? I'm just going through
9 what we've already talked about.
05:02:32
10 A.
The correct thing, he came out with a paper and asked
11 me: "Can you reproduce -- with all this equipment that

12 you have, can you reproduce something that just look like
13 this?"
14
05:02:45
And I looked into, and it was British
15 Insurance Fund insurance policy, and I look at it and

16 said, "Yes, we can do it."
17
18
And then he say -MR. FAZEL: I'm sorry, Your Honor. It's
19 nonresponsive.
05:02:52
20
THE COURT: Sustained. Question and answer.
21 BY MR. COSTA:
22 Q.
There was this issue with the insurance policy had
23 expired, correct, that the bankers rose with Mr. Stanford?
05:03:02
24 A.
Yes, sir.
25 Q.
Did there come a time when Mr. Davis asked you to

830
1 create a new policy?
05:03:12
2 A.
Yes, sir.
3 Q.
What did he bring into your office?
4 A.
An insurance policy.
5 Q.
And he asked you if you had the technical capability
6 to reproduce it?
05:03:20
05:03:27
7 A.
Yes, sir.
8 Q.
And what did you tell him?
9 A.
That, yes, it's possible.
10 Q.
Technically possible?
11 A.
Technically possible.
12 Q.
Did you raise another concern?
13 A.
Yes, I said I wouldn't do it.
14 Q.
Because?
15 A.
We cannot -- it looks like a legal document that I
16 will not have permission to reproduce, so it's -- like to

17 me it was falsifying something.
18 Q.
Who would you want permission from before you
19 reproduced an insurance policy from the British Insurance

05:03:41
20 Fund, Limited?
21 A.
From the owner of the companies or representative of
22 the company.
23 Q.
And up to that point, had you ever heard Mr. Stanford
24 say he owned the insurance company?

05:03:49
25 A.
No, sir.
831
1 Q.
So what happened after you told Mr. Davis, "I can't
2 reproduce this without permission from the company"?
05:03:57
3 A.
Yes, I say that.
4 Q.
And what happened next?
5 A.
He left the office.
6 Q.
Then what happened?
7 A.
And then he came back and saying, "What about if we
8 get the permission from the owner of the company?"

9 Q.
05:04:08
05:04:19
What did you say?
10 A.
Then, yes, it would get permission, we can do it.
11 Q.
Did he get permission from the owner?
12 A.
Yes, sir.
13 Q.
What happened?
14 A.
He came back to the office with Mr. Allen Stanford,
15 and they showed me papers that they owned the -- I mean,

16 that Mr. Allen Stanford owns the company, or his family.
17 I don't remember the actual owner in the documents.
05:04:30
05:04:37
18 Q.
Mr. Stanford came into your office?
19 A.
Yes, sir.
20 Q.
With Mr. Davis?
21 A.
Yes, sir.
22 Q.
And showed you these papers?
23 A.
Yes, sir.
24 Q.
What was your reaction?
25
MR. FAZEL: Object to relevance, Your Honor.

832
1 With all due respect, I don't know if he's got any

2 expertise and -3
THE COURT: Overruled as to that question. You
4 may keep going. You can ask or rephrase it, but as to the
05:04:49
5 wording, it's sustained.

6 BY MR. COSTA:
7 Q.
What was your reaction when Mr. Stanford said he
8 owned this British Insurance Fund?

9 A.
05:04:56
10 Q.
A surprise.
Because you hadn't heard any of that in these
11 meetings with the private bankers?

12 A.
Yes, sir.
13 Q.
At that point, once you saw that Mr. Stanford owned
14 it, did you reproduce the policy?

05:05:08
15 A.
Yes, sir.
16 Q.
And was there a new time period to extend the time so
17 it would be current?
05:05:20
18 A.
Yes, sir, but -- yes.
19 Q.
And what was done, then, with that new policy with
20 the updated timeframe?

21 A.
I'm not sure. I assume it was given to the bankers,
22 but I don't --
05:05:31
23 Q.
Who did you give it to?
24 A.
I give it to Mr. Allen Stanford or Mr. Davis. I
25 don't remember who.

833
1 Q.
Did you -- after that episode, did you tell anyone --
2 these other employees at the bank, like the salespeople,

3 that actually Mr. Stanford says he owns British Insurance
4 Fund?
05:05:43
5 A.
I do not remember telling anybody.
6 Q.
Were you given any instructions about whether you
7 should tell anybody?
05:06:00
8 A.
I do not remember if I was given instructions or not.
9 Q.
When Mr. Stanford said he owned the insurance policy,
10 at some point did you ask him what the policy meant if he
11 owned the insurance company?
12 A.
Yes. And he said that it was not really important,
13 that this is -- I forgot the term that he uses, but it's

14 an insurance of an insurance of an insurance, so it
05:06:18
15 doesn't have a real value, he told me, so I should not

16 worry about it.
05:06:29
17 Q.
He said it didn't have a real value?
18 A.
That's what he told me.
19 Q.
And what was his attitude or demeanor when he told
20 you that?
21
MR. FAZEL: Object to relevance, Your Honor.
22
THE COURT: Say again, his what?
23
MR. COSTA: What was his attitude when he was
24 telling Mr. Mejia that the policy had no real value.

05:06:37
25

834
THE WITNESS: That he knows better than
2 anybody.
3
THE COURT: Well, did you end up doing it or
4 not?
05:06:51
THE WITNESS: Could you, please --
THE COURT: Did you end up doing that,
7 reproducing that?
05:06:57
MR. COSTA: He said he did after --
THE COURT: He did. I'm sorry.
10
MR. COSTA: After they showed him Mr. Stanford
11 owned it.
12
THE COURT: I'm sorry.
13
14 BY MR. COSTA:
05:07:03
15 Q.
Let's move on to another topic. In these promotional
16 materials we've talked about, did Mr. Stanford want to

17 talk about the history of his family and of his
18 businesses?
05:07:16
19 A.
Yes.
20 Q.
Do you remember what he would say -- why did he want
21 to talk about the history, supposed history of his

22 business?
23 A.
We discussed the financial institution needs to show
24 some history, some background. And so he said, "Yes, that

05:07:34
25 that was important.

835
MR. COSTA: If we can go to 522.
2 BY MR. COSTA:
3 Q.
This is one of the brochures you've already said you
4 produced, Page 31, please?

05:07:46
THE COURT: That's still Guardian; is that
6 correct?
05:07:57
THE COURT: Okay.
MR. COSTA: The very first question and answer,
10 highlight that.
11 BY MR. COSTA:
12 Q.
Question is: "Who founded the Guardian International
13 Companies?"
14
05:08:05
And what is the answer that's provided in
15 that marketing brochure?

16 A.
"The Guardian International Companies were formed by
17 the Stanford Financial Group, which was founded by Lodis

18 B. Stanford in 1932."
19 Q.
05:08:18
20
That's good right there.

Who was Lodis B. Stanford?
21 A.
The grandfather of Mr. Allen Stanford.
22 Q.
And who provided this information to put in the
23 marketing brochures saying that Stanford Financial Group

24 was founded by Mr. Stanford's grandfather in 1932?
05:08:32
25 A.
Mr. Allen Stanford.

836
1 Q.
Was this in a lot of the materials?
2 A.
I think in almost all of them.
MR. COSTA: Can we go to 519. Page 4.
4 BY MR. COSTA:
05:08:53
5 Q.
Look at the first paragraph there. Next paragraph.
6 See that paragraph starting: "The bank was founded"?
05:09:08
7 A.
Yes, sir.
8 Q.
Can you read that?
9 A.
"The bank was founded in Montserrat, British West
10 Indies, by the Stanford Financial Group, which has been

11 active since 1932."
12 Q.
Did there come a time when you decided to look a
13 little bit more into Mr. Stanford's background of his

14 companies?
05:09:22
05:09:32
15 A.
I do not understand the question.
16 Q.
Did you ever travel to Mejia, Texas?
17 A.
Yes, sir.
18 Q.
Is that where his grandfather lived?
19 A.
Yes, sir.
20 Q.
Lodis Stanford?
21 A.
Yes, sir.
22 Q.
Why did you go to Mejia, Texas?
23 A.
I was told the Stanford Financial Group headquarters
24 was in Mejia, Texas, so we wanted to take pictures of the

05:09:43
25 buildings and learn more about that's where the chairman

837
1 of the board was, also. So, yes, I went one day there.
2 Q.
And who did you visit when you went to Mejia?
3 A.
Visit with Mr. James Stanford, his secretary and then
4 with the librarian of the city.

05:10:01
5 Q.
And how far is Mejia, in what direction, from
6 Houston?
7 A.
It's heading toward Dallas, a little bit to the east,
8 halfway to Dallas, a little bit to the east.

9 Q.
05:10:15
05:10:20
And when you visited, you said James Stanford --
10 there was an office there?

11 A.
Yes, sir.
12 Q.
James was Mr. Stanford's father?
13 A.
Yes, sir.
14 Q.
What did you see in his office?
15 A.
A small office. And we tried to take a picture of
16 it, but it didn't work. We have a photographer. I have a

17 photographer with me.
05:10:35
18
THE COURT: What do you mean didn't work?
19
THE WITNESS: We tried to make it look good,
20 and it looks just like a little house, so it was not -- it

21 didn't work for marketing materials.
22
THE COURT: Okay.
23 BY MR. COSTA:
05:10:45
24 Q.
Who decided not to use that picture?
25 A.
I decided that it was not a -Johnny C. Sanchez, RMR, CRR - jcscourtreporter@aol.com
838
1 Q.
Good quality?
2 A.
Not good quality. Compared with the other ones that
3 we showed.
05:10:54
4 Q.
And you said you also visited the library?
5 A.
Yes, sir.
6 Q.
Did you find anything -- how long did you spend in
7 Mejia?
05:11:00
8 A.
Six, 8 hours, top.
9 Q.
One day?
10 A.
One day.
11 Q.
Did you find anything from either visiting
12 Mr. Stanford, James Stanford's office, or visiting the

13 library to indicate that Stanford Financial Group has been
14 in existence since 1932?
05:11:15
15 A.
No, sir.
16 Q.
What did you find out about Mr. Stanford's
17 grandfather, Lodis Stanford?

18
MR. FAZEL: Objection, Your Honor, asked first
19 and hearsay. He's asking about what he found out, which

05:11:27
20 means that he has to talk about -21
MR. COSTA: I'll rephrase it, Your Honor.
22
THE COURT: All right. Go on.
23 BY MR. COSTA:
24 Q.
05:11:33
Did you learn what Mr. Lodis Stanford's occupation
25 was in the '30s?

839
05:11:39
1 A.
Yes, sir.
2 Q.
What did he do for a living?
MR. FAZEL: That's still hearsay.
THE WITNESS: He was a barber.
6 BY MR. COSTA:
05:11:46
7 Q.
And that's a good honest profession; right?
8 A.
Yeah.
9 Q.
But did it seem to you consistent with saying the
10 Stanford Financial Group was started in 1932?

11 A.
It was a surprise. I mean, it didn't look to me that
12 much, yes.
13 Q.
Before that time, Mr. Stanford told you his
14 grandfather had a barbershop?

05:11:57
15 A.
No, sir.
16 Q.
And before you went to Mejia to look into the
17 Stanford Financial Group, had Mr. Stanford ever -18 Mr. Allen Stanford told you that his father and
19 grandfather ran an insurance agency?
05:12:09
20 A.
No, sir.
21 Q.
What did he talk about them owning?
22 A.
A financial institution. My understanding was loans,
23 financial banking, that kind of stuff.

24 Q.
05:12:25
And what was the name of that supposed financial
25 company?
840
1 A.
Stanford Financial Group.
2 Q.
When you returned to Houston, did you talk to
3 Mr. Stanford about what you found out in Mejia?

4 A.
05:12:36
Just in the matter of I didn't think that the
5 pictures were marketing worth it.

6 Q.
You didn't mention any questions you had about
7 whether the Stanford Financial Group went back to 1932?

8 A.
We discussed that it was not a lot of -- to say about
9 it and that he had more, you know, to show me, because I

05:12:53
10 didn't found anything.

11 Q.
Explain that again. What did you tell -- you asked
12 for more?
13 A.
For more information, because you know, this is --
14 what you're showing me here is the brochure that was given

05:13:05
15 to me and say this is the information.

16
So I say -- when I went to Mejia, I didn't
17 found any substantial proof about all this. So I asked

18 him, you know, "Do you have something else?"
19
05:13:22
Or -- and he say that we should just keep
20 doing what we're doing and that's good enough.

21 Q.
Did he tell you at that point that actually it was an
22 insurance agency and we should put that in the marketing

23 brochures?
05:13:31
24 A.
No, sir, never mentioned that.
25 Q.
Did you ever hear at some point Mr. Stanford talk

841
1 about a family history with an insurance agency?
05:13:45
2 A.
No, sir, I never. I learn about that one --
3 Q.
After you worked there?
4 A.
A few days ago.
5 Q.
Okay. Now, we've been talking about Guardian Bank;
6 correct?
7 A.
Yes, sir.
8 Q.
And you say it was based in Montserrat, and you told
9 us about when you visited Montserrat?

05:13:55
10 A.
Yes, sir.
11 Q.
Did there come a time when the bank left Montserrat?
12 A.
Yes, sir.
13 Q.
How did you first hear there was an issue with
14 Montserrat?
05:14:04
15 A.
I was in my office very early, 6:00, something like
16 that in the morning, when a fax came into my office, the

17 advertising agency office, and in -- this fax has
18 five points, what they say that they were taking away
19 the -05:14:23
20
MR. FAZEL: Object as to hearsay.
21
THE COURT: It's also nonresponsive. Question
22 and answer, please.

23 BY MR. COSTA:
24 Q.
05:14:32
You said you received a fax early in the morning,
25 Mr. Mejia?
842
1 A.
Yes, sir.
2 Q.
If you can try to answer -- just try to answer my
3 question, and I'll do the work. I'll follow-up.
05:14:39
4 A.
Sorry.
5 Q.
And what office were you in when you received this
6 fax?
05:14:47
7 A.
In my office, Idea Advertising.
8 Q.
In Houston?
9 A.
Yes, sir.
10 Q.
Prior to receiving this fax, had you heard anything
11 about this bank leaving Montserrat?

12 A.
No, sir.
13 Q.
Had anyone said the bank was -- Mr. Stanford said the
14 bank was leaving Montserrat because of a hurricane?

05:15:00
15 A.
No, sir.
16 Q.
And who was the fax from that you received that day,
17 that morning?
05:15:16
18 A.
For a government agency in Montserrat.
19 Q.
I'm going to show you what's marked as Government's
20 Exhibit 511 and ask if the contents of that letter are

21 what you received on the fax machine that morning in your
22 office in Houston.
23 A.
Yes, sir.
24
05:15:32
MR. COSTA: Your Honor, at this time Government
25 offers 511.
843
MR. FAZEL: Your Honor, at this time I'd object
2 to 511 as being hearsay, foundation and confrontation.

3
THE COURT: Let me -- bring it on up. See the
4 attorneys up here. At least get it on the record.

05:16:00
MR. COSTA: Your Honor, it's the letter from
6 Montserrat revoking Mr. Stanford's banking license.

7
THE COURT: Okay.
MR. COSTA: And so, we're using it to show why
9 the bank left Montserrat, what Mr. Stanford was told about
05:16:08
10 the bank's problems. It is a public -- it's a public

11 record from the government agency in Montserrat.
12
THE COURT: You have to speak up -- let me just
13 read it first, okay? Hang on. The defense -- no -- yeah,

14 this is defense.
05:16:41
15
MR. COSTA: Just the first two pages being
16 offered.
17
THE COURT: All right. How do you get this in?
18
MR. COSTA: It's to show why they were kicked
19 out of Montserrat. It's also to show what Mr. Stanford was

05:16:51
20 told about the problems with the bank. Thirdly, it's a

21 record from Montserrat where they have a number of letters
22 and records from Montserrat that they have on their exhibit
23 list that they want to produce.
24
05:17:03
THE COURT: What's this -- it came to this
25 man -Johnny C. Sanchez, RMR, CRR - jcscourtreporter@aol.com
844
MR. COSTA: And he gives it to Mr. Stanford.
2 He walks in to Mr. Stanford's office and says, "Look at

3 this." It shows the bank -- I mean --
05:17:13
MR. FAZEL: It's still hearsay, Your Honor.
THE COURT: Hold it. At this time, based
6 upon -- there's evidence in that they shut them down in

7 Montserrat. You have another reason for it, okay?
05:17:26
MR. FAZEL: Actually --
THE COURT: Wait a second. Unless you want to
10 withdraw your objection.

11
MR. FAZEL: No, sir. I was just going to
12 submit to the Court there is no evidence that they shut it

13 down. There's just evidence that they moved.
05:17:32
14
THE COURT: Okay.
15
MR. COSTA: That letter is evidence, Your
16 Honor. They're saying it's because of a hurricane.

17
THE COURT: 511, the objection is sustained as
18 of this time through this witness.
05:17:42
19
MR. COSTA: He's the one --
20
THE COURT: All right. Wait --
21
THE COSTA: -- that wanted to show it to
22 Mr. Stanford.
05:17:48
23
THE COURT: But is he custodian of records?
24
MR. COSTA: We're not -- we're using it not for
25 the truth to show that -- what Montserrat told

845
1 Mr. Stanford, what they told him about the bank, what
2 Montserrat did, whether what they say about the bank is
3 true. We'd offer it for that limited purpose.
4
05:17:58
THE COURT: Sustain the objection -- I mean,
5 most of this stuff you can get in just for the purpose as
6 to somebody has notice, but beyond that, I'm just going to
7 not let it in. If you want, I'll allow him to say if you
8 bring this in to Mr. Stanford and it's concerning the
9 shutting down.
05:18:14
10
11
THE COURT: You don't agree with that?
12
MR. COSTA: Your Honor, they've offered on
13 cross-examination it was because of a hurricane. We need

14 to show that Mr. Stanford was given this document.
05:18:21
15
THE COURT: Wait a second. Not through this
16 witness. Sustained through this witness.

17
18 BY MR. COSTA:
19 Q.
05:18:46
So you mentioned you received a fax this morning --
20 that morning in the office in Houston?

21 A.
Yes, sir.
22 Q.
Prior to that, had you heard anything from
23 Mr. Stanford that the bank was planning to leave

24 Montserrat?
05:18:55
25 A.
No, sir.
846
05:19:12
1 Q.
After -- you said that fax was from Montserrat?
2 A.
Yes, sir.
3 Q.
Did you show the fax to Mr. Stanford?
4 A.
Yes, sir.
5 Q.
Did Mr. Stanford share the information in that fax
6 with the other bankers, the people selling the CDs at

7 Stanford?
05:19:23
8 A.
9 Q.
Did Mr. Stanford ever tell -- did you ever hear
10 Mr. Stanford tell any employees at the bank that he

11 received a letter from Montserrat saying that his banking
12 license was going to be revoked?
05:19:34
05:19:54
05:20:05
13 A.
No, sir.
14 Q.
Did the bank end up leaving -- after you received
15 that fax, did the bank end up leaving Montserrat?

16 A.
Yes, sir.
17 Q.
Where did the bank end up setting up shop?
18 A.
In Antigua.
19 Q.
When the bank moved to Antigua, did it keep the
20 Guardian name?
21 A.
Yes, sir.
22 Q.
Was -- when did you stop working for Mr. Stanford?
23 A.
In 1992.
24 Q.
Was it Guardian the whole time you worked there?
25 A.
I think so. There were talks about changing the

847
1 name, but it was -- I think it's still being Guardian,

2 yes, sir.
3 Q.
So even the first years at Antigua, it was still
4 called Guardian Bank?

05:20:15
5 A.
Yes, sir.
MR. COSTA: Ms. Gregory, if you could show
7 Government 106 and focus on the middle part.

8 BY MR. COSTA:
9 Q.
05:20:37
05:20:45
What document is this, Mr. Mejia?
10 A.
The annual report for 1993.
11 Q.
And when would this have been produced?
12 A.
1994.
13 Q.
So were you still working there?
14 A.
No, sir.
15 Q.
Okay. But what is the bank called in this report
16 that was issued in 1994?

17 A.
Guardian International Bank.
18 Q.
I think when you originally interviewed with
19 Mr. Stanford, you said that Idea Advertising for a certain

05:21:06
20 period of time had to just do work for Mr. Stanford?

21 A.
Yes, sir.
22 Q.
And what was that -- initially what did Mr. Stanford
23 tell you that period of time would be?
05:21:17
24 A.
Three years was the agreement.
25 Q.
After three years, were you allowed to take in the

848
1 outside customers like you had originally been told?
05:21:35
2 A.
Yes, sir.
3 Q.
He did allow you to do that?
4 A.
Yes, sir. I mean, we were trying to do that at the
5 time that I left.

6 Q.
Was it successful to bring in the outside customers?
7 A.
I think we have one, and we were close to get more,
8 yeah. I left the fourth year, so it was not a lot of time

9 for that.
05:21:49
10 Q.
And towards the end of your time at -- working for
11 Mr. Stanford, did he ask you to make a commitment at some

12 point that you weren't willing to make?
05:22:01
13 A.
Yes, sir.
14 Q.
Tell the jury about that commitment he asked for.
15
MR. FAZEL: Your Honor, I would object to this
16 as being completely irrelevant. I believe I know where

17 he's going with this. It's just not relevant.
05:22:12
18
THE COURT: What's the relevance?
19
MR. COSTA: I'm just explaining what happened
20 at the end of his tenure and what led to him leaving

21 Mr. Stanford's employment.
22
23
MR. COSTA: If they don't want to go into it,
24 we can just move on.

05:22:20
25
MR. FAZEL: I just don't think it's relevant.

849
1 I mean, I can approach and tell you what he's going to say.
2 I just don't think it's relevant.
05:22:29
THE COURT: Do you want to move on?
MR. COSTA: It's quicker just to go through a
5 couple of questions, Your Honor. It's not lengthy.

6
THE COURT: All right. You object?
MR. FAZEL: Relevance.
THE COURT: Overruled at this time.
9 BY MR. COSTA:
05:22:34
10 Q.
What commitment did Mr. Stanford ask you to make?
11 A.
That our job would be more important that family
12 religion or anything else.
05:22:50
13
MR. FAZEL: Objection. Relevance.
14
15 BY MR. COSTA:
16 Q.
Where were you -- who were you with when he made this
17 request?
18 A.
With another top executives of the group of
19 companies.
05:22:58
05:23:06
20 Q.
Was Mr. Stanford saying that he had new plans --
21 A.
Yes, sir.
22 Q.
-- for the bank?
23 A.
Yes, sir.
24 Q.
Generally, what were those new plans?
25 A.
To allow him to sell the products for U.S.

850
1 citizens -- to U.S. citizens.

2 Q.
And what did he say that was going to require
3 starting to market in the U.S.?
05:23:21
4 A.
It would require total commitment.
5 Q.
What did the other people on the -- who were with you
6 say to Mr. Stanford?
05:23:28
7 A.
Yes.
8 Q.
What did you say --
9 A.
Yes to him.
10 Q.
What did you say?
11 A.
No. That my wife was much better looking than him,
12 so I will not commit to that.

13 Q.
How would you explain your relationship with
14 Mr. Stanford towards the end of your time working for him?
05:23:42
15 A.
Tense after that and a little bit before.
16 Q.
And did there come a time when Mr. Stanford asked you
17 to resign from the company?
05:23:57
18 A.
Yes, sir.
19 Q.
Tell us how that happened.
20 A.
Up to the time or -- could you be more specific?
21 Q.
Well, how did you -- did Mr. Stanford call you into
22 his office one day?
05:24:08
23 A.
Yes, sir.
24 Q.
Had you been on vacation?
25 A.
Yes, sir.
851
1 Q.
What were you told about -- while you were on
2 vacation?
3 A.
That -- to take another week for vacation because it
4 would be an external auditing of the company.

05:24:19
THE COURT: It would be a what?
THE WITNESS: External auditing.
THE COURT: Okay.
8 BY MR. COSTA:
05:24:23
9 Q.
Of your advertising company?
10 A.
Of the advertising company.
11 Q.
And after that extra week, did you go back to the
12 office?
13 A.
Yes. And they asked me to come and -- go and talk
14 with Mr. Allen Stanford on that Saturday, not on a working

05:24:36
15 day.
16 Q.
And what happened when you met with Mr. Stanford on
17 Saturday?
18 A.
He told me that it was clear that we don't look
19 eye-to-eye anymore, and I agreed to that. And then he

05:24:49
20 told me that the external auditing showed that there was

21 an overpay me an X amount of money, that it was -- to me,
22 it was insignificant. If I remember, it was $750,
23 something like that. I make a check, personal check, and
24 give it to him for that amount of money.
05:25:06
25
And then he say that he wants me to

852
1 resign, and I agree, but I didn't want it -- to do it

2 right away. So he tried to convince me to resign.
3 Q.
Did you know this money he was asking you for was all
4 about?
05:25:22
5 A.
No. My understanding, I received some --
MR. FAZEL: I'm sorry. If he doesn't know what
7 it's about, then I object to any testimony.

8
THE COURT: If he doesn't know -- if he says
9 that he knows, then he may testify to it. Ask it again, if

05:25:35
10 you want.
11 BY MR. COSTA:
12 Q.
Did Mr. Stanford tell you what this money issue was
13 about?
14 A.
05:25:43
No, sir. He mentioned an overpayment.
15
THE COURT: You gave an answer, no. Move on.
16 BY MR. COSTA:
17 Q.
Did he just tell you that it was an overpayment to
18 you?
05:25:51
19 A.
Yes, sir.
20 Q.
Did he give you any more details about what that
21 meant?
22 A.
No, sir.
23 Q.
Are you angry at Mr. Stanford for forcing you to
24 resign?
05:26:06
25 A.
No, sir.
853
05:26:15
1 Q.
Why not?
2 A.
My life was much better when I left.
THE COURT: What are you doing right now?
THE WITNESS: I own an advertising agency.
THE COURT: Okay. So --
THE WITNESS: -- I'm very happy. It was very
7 stressful at the end.

8 BY MR. COSTA:
05:26:26
9 Q.
What was stressful about the job at the end?
10 A.
There are many indications, accumulation of
11 indications that things were not right, meaning

12 financially --
05:26:36
13
THE COURT: Hold it.
14
MR. FAZEL: Objection, Your Honor. The
15 question was: What was stressful in your job.

16
MR. COSTA: And he answered.
17
MR. FAZEL: I know.
18
THE COURT: And he kept going. He answered it
19 and then kept going. So it's sustained as to unresponsive,

05:26:46
20 and he was about to go somewhere else. So just ask a

21 question.
22 BY MR. COSTA:
23 Q.
Why were you stressed? Why was the job stressful at
24 the end?
05:26:53
25 A.
There were a lot of information that I accumulate

854
1 about the bank that make my job very stressful.

2 Q.
What was your feeling towards the end about whether
3 you could trust and rely on what you were producing in

4 these marketing materials based on what Mr. Stanford told
05:27:12
5 you?
6 A.
Could you repeat that, please?
7 Q.
By the end of your time there, you talked about all
8 these different indications?

9 A.
05:27:19
10 Q.
Yes.
Did you feel confident about the accuracy of the
11 information Mr. Stanford was giving you to put in these

12 materials by the end of your time there?
05:27:31
05:27:39
13 A.
No, sir.
14 Q.
Did you have family in El Salvador while you were
15 working for Mr. Stanford?

16 A.
Yes, sir.
17 Q.
Did they have money to invest?
18 A.
Yes, sir.
19 Q.
Did you ever tell them to invest with Mr. Stanford?
20
MR. FAZEL: Objection, Your Honor. It's
21 relevance.
22
THE COURT: What's the relevance?
23
MR. COSTA: What he thought of the bank after
24 his time there, what he thought whether it was a good

05:27:46
25 investment.
855
2 BY MR. COSTA:
3 Q.
Were you ever told, Mr. Mejia, to do anything with
4 your assets while you were working at the bank?

05:27:58
5 A.
Yes, sir.
6 Q.
What were you told?
MR. FAZEL: Objection, Your Honor, asked for
8 hearsay.
9
05:28:07
THE COURT: By who? Who was he told by?
10
MR. FAZEL: It was not from Mr. Stanford.
11
12
MR. FAZEL: It was not from Mr. Stanford.
13
THE COURT: I just need to know by whom he was
14 told, not what was said.

05:28:15
15 BY MR. COSTA:
16 Q.
Who told you you needed to do something with your
17 assets?
18 A.
Mr. Thomas Drake (phonetic), the head of the human
19 resources.
05:28:23
20
21 BY MR. COSTA:
22 Q.
Was that one of the reasons you were stressed -- you
23 were very stressed at the time during the end of your

24 time -05:28:30
25
MR. FAZEL: Based on hearsay.

856
1 BY MR. COSTA:
2 Q.
-- with Mr. Stanford?
MR. COSTA: Let him -- let me finish the
4 question.
05:28:33
5 BY MR. COSTA:
6 Q.
What were you told -- what was your understanding of
7 what you were supposed to do with your assets while you

8 were working at the bank based on these concerns that were
9 out there?
05:28:42
10
MR. FAZEL: Objection, asked for hearsay.
11
THE COURT: Overruled. Not who told you, what
12 was your understanding that they encouraged you to do with

13 your assets.
14
05:28:55
THE WITNESS: To put it in my wife's name, not
15 in my name.
16 BY MR. COSTA:
17 Q.
What was the concern that would lead you to put
18 assets in your wife's name and not your name?

19
05:29:03
MR. FAZEL: Objection, Your Honor. It's
20 hearsay.
21
THE COURT: Overruled. Not what you were told,
22 what was the concern.

23
THE WITNESS: That I will not be able to
24 continue my life because the -- my assets could be freeze

05:29:12
25 by a government entity.
857
Cross-Mejia/By Mr. Fazel
MR. COSTA: One moment, Your Honor.
Pass the witness, Your Honor.
THE COURT: Pass the witness.
4
05:29:39
Are you going to get another witness? I'm
5 going to stop the time. If you want to stand up and

6 stretch for 30 seconds, let's do it. If not, you can
7 remain seated.
8
9
05:30:30
(Brief pause.)
THE COURT: All right. Let's go. We've got
10 about a half hour left. Let's go.

11
MR. FAZEL: Your Honor, can we switch panels?
12
THE COURT: Yes. Hang on one sec. In other
13 words, switch -- which computer are we using?
05:30:43
14
MR. FAZEL: That one over there.
15
THE COURT: That's the back right, correct?
16 How is that?
05:31:07
17
MR. FAZEL: I think you're good to go.
18
19
20
THE COURT: Yes.
21
CROSS-EXAMINATION
22 BY MR. FAZEL:
05:31:13
23 Q.
Good afternoon, Mr. Mejia. How are you?
24 A.
Doing good. Not really, but --
25 Q.
Were they mean to you?

858
1 A.
Huh?
2 Q.
Were they mean to you?
3 A.
No, it's my granddaughter's birthday. I prefer to be
4 there.
05:31:19
5 Q.
I'm so sorry. Happy birthday to your granddaughter.
05:31:29
I have a few questions for you.
7 A.
Okay.
8 Q.
You and I have never met before, have we?
9 A.
No.
10 Q.
Have you and I ever chatted before?
11 A.
No, sir.
12 Q.
Okay. Now, you testified on direct that you went to
13 the University of A&M, but you did not graduate; correct?
05:31:41
14 A.
Yes, sir.
15 Q.
Now -- and your degree was in?
16 A.
In environmental design/architecture, something like
17 that.
05:31:49
18 Q.
So it was not a business degree?
19 A.
No, sir.
20 Q.
And you're not here testifying that you have an
21 understanding of accounting, finance or anything like

22 that?
05:32:00
23 A.
No, sir.
24 Q.
Okay. Would you agree with me that your expertise,
25 if you will, if at all, is in the area of marketing,

859
1 perhaps putting brochures together and that's about it?

2 A.
Yes, sir.
3 Q.
Okay. So your testimony today is based on what you
4 perceived happened with some very limited understanding of

05:32:18
5 finance; fair?
6 A.
Yes.
7 Q.
Give you an example: You talked about -- in the
8 middle of your testimony, you said, "Well, I was shocked

9 that it took them 10 minutes to do it. It takes me longer
05:32:30
10 to balance my checkbook."
11
05:32:35
12 A.
Yes, sir.
13 Q.
It's kind of common sense; right?
14 A.
Yes, sir.
15 Q.
Balancing a checkbook takes a little while; right?
16 A.
Yes, sir.
17 Q.
But you don't know, for example, if Mr. Hewlett and
18 Mr. Stanford and Mr. Davis were discussing numbers in the

19 other room, do you?
05:32:46
20 A.
No, sir.
21 Q.
You don't know if Mr. Hewlett, Mr. Stanford and
22 Mr. Davis had discussed this information two days prior,

23 do you?
05:32:53
24 A.
No, sir.
25 Q.
You have no idea what was going on other than they're

860
1 coming in and saying, Okay, we've got to change this

2 number, we've got to do this; right?
05:33:05
3 A.
You're right.
4 Q.
Okay. So you're just assuming things?
5 A.
Assuming what, sir?
6 Q.
That's my point. You're just assuming that it was
7 kind of odd for them to change those numbers; right?
05:33:15
8 A.
I never said -- they just changed the numbers.
9 Q.
Right.
10 A.
The numbers came different. That's the only thing
11 that I'm -12 Q.
But did it seem -- you said it seemed kind of
13 different and odd, didn't you?

14 A.
05:33:24
15
Pardon me. Try that again.

MR. COSTA: Object. Misstates the testimony.
16 I think he said it was odd that it took 15 minutes for

17 Hewlett to approve the numbers.
18
THE COURT: Rephrase it.
19 BY MR. FAZEL:
05:33:31
20 Q.
You thought it was odd for Hewlett to approve -- I'll
21 say it the way the prosecutor said it.

22
You said it was odd for Hewlett to approve
23 it in 15 minutes; right?
05:33:40
24 A.
It was -- I was surprised, yes.
25 Q.
You were surprised. But you don't know the

861
1 conversation, the background, that took place before

2 Hewlett got that stuff faxed to him, do you?
05:33:48
MR. COSTA: Object to foundation.
THE COURT: See if that mike is on.
MR. FAZEL: It's not. That's why I'm kind of
6 screaming. I didn't want to get in trouble.

7
THE COURT: How about that one. No, right
8 here, right here.

9
05:34:01
10
MR. FAZEL: That's on.

THE COURT: Pick it up and put it -- just pick
11 it up, if you would. It's about -- just aim it towards

12 you.
05:34:08
13
14
THE COURT: Sorry about that.
15
MR. FAZEL: That's quite all right.
16
THE COURT: And aim it up higher.
17
MR. FAZEL: Move this way. How about that?
18 Would that help?
05:34:18
19
THE COURT: Yes.
20
MR. COSTA: We made an objection, assuming
21 facts not in evidence, lack of foundation.

22
05:34:24
23
MR. FAZEL: I'll rephrase it.
24
MR. COSTA: There's no evidence of these phone
25 calls.
862
THE COURT: Rephrase the question, if you can,
2 Counsel.
3
4 BY MR. FAZEL:
05:34:29
5 Q.
Do you have any understanding or knowledge as to how
6 they came to these numbers?

7 A.
No, sir.
8 Q.
So what you're thinking --
9
05:34:40
THE COURT: It's back on.
10
MR. COSTA: Okay.
11
MR. FAZEL: You got it, Judge.
12 BY MR. FAZEL:
13 Q.
So what you're thinking as odd could be that you're
14 just not understanding the circumstances?

05:34:47
15 A.
That is possible.
16 Q.
It's possible, okay.
17
Now, I drew a very crude diagram over
18 here. Do you have any understanding -- and it's okay if

19 you don't. It's fine.
05:35:07
20
Do you have any understanding of how the
21 Stanford companies were set up?

22 A.
The way that he explain it to me -- that Mr. Stanford
23 explained it to me.
24 Q.
05:35:20
Okay. Great. Were you aware, and if you don't,
25 that's fine, but were you aware that the Stanford

863
1 Financial Group companies was created in Mexia, Texas?

2 Did you know that?
05:35:31
3 A.
That was what they told me.
4 Q.
Okay. And were you aware that Stanford Financial
5 Group, Limited, was a company in Montserrat?

6 A.
Yes, sir.
THE COURT: Angle that a little bit more --
8 just a little more.

9
05:35:39
MR. FAZEL: Oh, I'm sorry.
10
THE COURT: Just a little more towards the --
11
MR. FAZEL: I'm so sorry.
12
THE COURT: That's fine. Go on.
13 BY MR. FAZEL:
05:35:41
14 Q.
That's also accurate?
15 A.
That's what I understand, yes.
16 Q.
And you know that there's a bank in Montserrat and
17 then there's another company in Montserrat that was

18 involved in distributing the CDs.
19
05:35:52
Were you aware of that?
20 A.
No, sir.
21 Q.
You were not?
22 A.
I was aware about a bank, but not about another
23 company.
05:35:58
24 Q.
Well, who ws selling the CDs?
25 A.
The bank.
864
1 Q.
The bank was.
05:36:03
Are you sure about that?
3 A.
The way that it was told, yes.
4 Q.
Could you be --
5 A.
I'm not sure about it.
6 Q.
Well, that's my point. I guess what I'm trying to
7 explain to you is: Perhaps your understanding of the

8 Stanford entities is just not accurate.
9
05:36:14
Could that be possible?
10 A.
Of course. All is possible.
11 Q.
It's always possible?
12 A.
Yes.
13 Q.
You worked there for three years and you don't
14 remember who actually sold the CDs? What company?

05:36:25
15 A.
I remember that the people who saw -- sell the CD was
16 the financial services company.

17 Q.
Right. And who did the financial services company
18 work -- the brokers work for?

19 A.
05:36:38
They were located in Miami, and they worked for the
20 bank.
21 Q.
They worked for the bank?
22 A.
Yes, sir.
23 Q.
Okay. Well, would it be -- would you be mistaken?
24 Could they be working for Guardian International Services,

05:36:46
25 Limited?
865
1 A.
I have no knowledge of that.
2 Q.
Okay. But you were in charge of their marketing
3 materials.
4
05:36:52
Isn't that something you ought to know?
5 After all, that's what you're marking; right?

6 A.
I don't know.
7 Q.
You don't know. Okay. Now, you met Mr. Stanford,
8 what, three days and he gave you $150,000?

9 A.
05:37:08
05:37:33
Three times -- two times, yes.
10 Q.
And he wrote you a check for $150,000?
11 A.
Yes, sir.
12 Q.
In your name?
13 A.
It was in the company name, Idea Advertising.
14 Q.
I see. Now, do you remember speaking to the
15 government about Exhibit Number 503?

16
MR. FAZEL: And let me -- I don't want to do
17 this.
18
Your Honor, can I trouble you for the
19 ELMO?
05:37:48
20
THE COURT: Yes. Hang on. Give me a second.
21
MR. SCARDINO: You'll have to move the chart.
22
MR. FAZEL: I'll get it.
23
MR. SCARDINO: That's all right.
24 BY MR. FAZEL:
05:38:05
25 Q.
Now, do you see that highlighted portion? And I'm

866
1 not as fancy as everybody, I just use the hi-lighter.

2
THE COURT: If you have problems, sir, it's
3 also in that big screen.

4 BY MR. FAZEL:
05:38:16
5 Q.
Do you see that highlighted portion?
6 A.
Yes, sir.
7 Q.
Okay. That interest rate, number one, would you
8 agree with me that during that period of time that

9 interest rate was just simply a little bit higher than the
05:38:25
10 interest rates at that time? Do you understand my

11 question?
12
10.75 was just a smidgen higher than what
13 was being offered in the U.S.? The interest rates were

14 higher much higher than they are now; correct?
05:38:38
15 A.
Yes, they were much higher at that time.
16 Q.
Okay. And then you notice that the government -- the
17 government didn't go over this with you, but that

18 percentage is for a specific amount of money; right?
05:38:48
19 A.
Yes, sir.
20 Q.
If you invest for 36 months -- and I have to tell
21 you, I know a little Spanish, okay? So if you invest for

22 36 months, and it's for a 25,000-dollar investment; right?
05:39:02
23 A.
Yes, sir.
24 Q.
It's not for a 5,000 or a 10,000-dollar investment,
25 is it?
867
05:39:10
1 A.
Yes, it is.
2 Q.
Yes, it's not, or yes, it is?
3 A.
Yes, it is for $25,000.
4 Q.
Okay. All right. So that -- that interest rate is
5 for a certain type of investment. It's not for all

6 investments?
7 A.
Yes, sir.
8 Q.
Okay. Now, do you remember Exhibit Number 519? Let
9 me put it up here for you.

05:39:31
05:39:42
10
11 A.
Yes, sir.
12 Q.
What is this a picture of?
13 A.
I don't know. I did not do that brochure.
14 Q.
I know, but you said you went to Montserrat; right?
15 A.
Yes, sir.
16 Q.
Isn't that the picture of the bank in Montserrat?
17 A.
I do not remember. I cannot identify it.
18 Q.
You don't remember?
19
05:39:52
Do you remember this picture?
MR. FAZEL: Could you tell me what exhibit the
20 government put up as a pictures of the Montserrat bank?

21
MR. COSTA: I think it's 522.
22
MR. FAZEL: Can you pull up 522, please? Or
23 521.
05:40:18
24
MR. COSTA: Number 521.
25
MR. FAZEL: Oh. Judge, I need you to switch it

868
1 over to -- from the ELMO. I'm so sorry.

2
THE COURT: That's all right. No? Is that it?
3 BY MR. FAZEL:
05:40:37
4 Q.
Okay. How about that? Does that ring a bell?
5 A.
No, sir.
6 Q.
It doesn't?
7 A.
No.
8 Q.
Yet you testified that you went to the Montserrat
9 bank; remember?
05:40:42
10 A.
Yes, sir.
11 Q.
And you said that there's two people there and there
12 was computers that were unplugged?
05:40:49
13 A.
Yes, sir.
14 Q.
But you don't remember the bank itself?
15 A.
That was not what I remember, no.
16 Q.
How's your memory? Do you think your memory is a
17 little bad since it's been so long?
05:41:00
05:41:08
18 A.
No, sir.
19 Q.
Do you think it's good?
20 A.
Yes, sir.
21 Q.
Which one is it? Is it good or bad?
22 A.
I think it's good.
23 Q.
It's good. Yet you don't remember that photo?
24 A.
No, sir.
25
MR. COSTA: Objection. Asked and answered.

869
2 BY MR. FAZEL:
3 Q.
Now, let me ask you this: Do you remember on
4 Exhibit 519, where it says the bank was founded in

05:41:16
5 Montserrat BWI by Stanford Financial Group which was -6 has been active since 1932.
7
Do you remember the prosecutor talking to
8 you about that?

9 A.
05:41:24
10 Q.
Yes, sir.
Well, didn't I just show you on that chart that it
11 was Stanford Financial Group that was in Mexia? Isn't

12 that true?
13
MR. COSTA: Objection, Your Honor. What the
14 attorney writes on a chart is not evidence. I'd like you

05:41:39
15 to give that instruction to the jury.

16
MR. FAZEL: Well, sure. Let me ask it this
17 way. I apologize. Let me ask it this way.

18 BY MR. FAZEL:
19 Q.
05:41:46
05:41:58
Is it true that you just don't know that Stanford
20 Financial Group was actually created in Mexia?

21 A.
No, I don't know.
22 Q.
You don't know?
23 A.
No.
24 Q.
So any testimony you said about what was in Mexia was
25 just based on one day being in Mexia?

870
1 A.
Yes, sir.
2 Q.
Now, you talked about Allen Stanford and his
3 investment with these companies.

4
05:42:18
5 A.
Yes, sir.
6 Q.
And you talked about Mr. Davis.
05:42:24
8 A.
Yes, sir.
9 Q.
Okay. Wasn't Mr. Davis in charge of the numbers?
10 A.
I don't know.
11 Q.
You don't know. Would it be fair to say that your
12 involvement in the Stanford company was rather limited?

13 Would you agree with that?
05:42:35
14 A.
Yes, sir.
15 Q.
Would it be fair to say that your knowledge about the
16 Stanford companies is extremely limited? Would you agree

17 with that?
05:42:44
18 A.
I would say it's limited.
19 Q.
Okay.
20 A.
I don't know if "extremely" applies.
21 Q.
Well, let's go through it.
22
You don't understand how the company is
23 set up; correct?
05:42:50
24 A.
Correct.
25 Q.
You don't remember what the bank looks like; correct?

871
1 A.
I don't recognize that picture.
2 Q.
Right. Okay. Well, it's a government's exhibit of a
3 picture of the bank.
05:43:00
4 A.
Oh, okay.
5 Q.
Okay. So clearly, you don't remember what the bank
6 looked like; correct?
05:43:12
7 A.
I remember it looked different than that.
8 Q.
They had two different banks?
9 A.
No. My memory about the look of the bank is not --
10
MR. COSTA:
11
MR. FAZEL: I'm sorry. If you want to testify,
That's not what he said.
12 why don't you get on the witness stand and we can go after
13 it.
14
05:43:17
I object to the sidebar.
15
MR. COSTA: He's doing a good job of it
16 himself.
17
THE COURT: Sustained. Go on.
18 BY MR. FAZEL:
05:43:31
19 Q.
You don't remember the bank; correct, sir?
20 A.
I remember it differently.
21 Q.
You remember it differently. Okay.
22
What was the name of the product that was
23 sold by Stanford Guardian Bank?
05:43:50
24 A.
CD.
25 Q.
What else?
872
1 A.
That's all that I remember.
2 Q.
What if there were other products? You don't recall
3 that?
05:43:59
05:44:08
4 A.
I don't recall that.
5 Q.
What about real estate?
6 A.
That was not the bank product.
7 Q.
What was it the product of?
8 A.
Stanford Development Company.
9 Q.
What about before Stanford Development Company?
10 A.
What about what?
11 Q.
Before Stanford Development Company, what was it a
12 product of then?
05:44:15
13 A.
I don't know.
14 Q.
You don't know?
15 A.
That was before me.
16 Q.
When you were hired by Mr. Stanford, did you lie to
17 him about your education?
05:44:42
05:44:48
18 A.
Yes, sir.
19 Q.
Okay. Now, were you aware that there was a hurricane
20 that hit Montserrat?

21 A.
Yes, sir.
22 Q.
What year was that?
23 A.
I don't remember the year.
24 Q.
Did you go after the hurricane to Montserrat?
25 A.
No.
873
1 Q.
What were the duties and obligations of the people in
2 the bank that you went to take photographs of?
05:45:00
3 A.
Pardon me? I don't understand the question.
4 Q.
You said that the bank had two or three people in it.
6 A.
Yes, sir.
7 Q.
You said that when they were there, they were -- just
8 seemed like they were not doing anything and they were
9 more interested in showing you the island itself.
05:45:09
10
11 A.
Yes, sir.
12 Q.
What is your understanding of their job there? What
13 are they supposed to do?
05:45:17
14 A.
No, no understanding of what they do there.
15 Q.
So how can you testify that they didn't -- they
16 were -- well, let me ask it this way: So are you telling

17 us that you don't know what they had to do, what their job
18 was over there?
05:45:31
19 A.
I have no knowledge about what they do over is there.
20 Q.
So if you don't know what they were doing over there,
21 are you telling us that you thought that they weren't

22 doing anything over there?
23 A.
The whole time that I was there, they were just
24 sitting there and standing up, so that's what I was...

05:45:44
25 Q.
Okay. I guess that's my question.

874
What is it your understanding that what
2 they're supposed to be doing in Montserrat?
05:45:56
3 A.
I have no idea what they were doing in Montserrat.
4 Q.
So how do you know they're not doing what they're
5 supposed to be doing?
6 A.
05:46:00
I don't know.
THE COURT: You don't know; right?
THE WITNESS: I don't know.
THE COURT: You have no idea.
10 BY MR. FAZEL:
11 Q.
What is the main function of the people in Houston
12 that you worked with?
05:46:08
05:46:14
13 A.
There were two basic functions.
14 Q.
And what were they?
15 A.
One is to sell the product of the bank.
16 Q.
And who did that?
17 A.
That was the bankers.
18 Q.
And did they do that?
19 A.
Yes, sir.
20 Q.
And what were the other functions?
21 A.
There were some financial people who does financial
22 numbers and accounting kind of.
05:46:23
23 Q.
Okay. And did that take place?
24 A.
In Houston.
25 Q.
And did that take place? Did they do that?

875
1 A.
My understanding, yes.
2 Q.
Okay. And so, what was the functioning of the folks
3 that were on island? What are they supposed to do?
05:46:34
4 A.
I don't know.
5 Q.
You never asked?
6 A.
There was not an answer when I asked, What do you do
7 here?
05:46:42
8 Q.
Who did you ask?
9 A.
The people who was working there.
10 Q.
They just ignored your question?
11 A.
Yes. They say, you know, that just here.
12 Q.
They're just here.
13
The brochure that we went -- and the
14 government talked about, do you remember the brochure the

05:46:59
15 government put up where it was the Houston company, but

16 you had verbiage about Montserrat.
17
05:47:08
Do you remember that brochure?
18 A.
Yes, sir.
19 Q.
Do you remember that picture?
20 A.
Yes, sir.
21 Q.
Do you remember how the government made it look like
22 it was a little bit of a misrepresentation? Do you

23 remember that?
05:47:12
24 A.
Yes, sir.
25 Q.
Do you think it was a misrepresentation?

876
1 A.
Yes.
2 Q.
You do? Was that brochure created after the
3 hurricane?
05:47:24
4 A.
I don't remember.
5 Q.
You don't remember. What year was the hurricane?
6 A.
I don't remember the year of the hurricane.
7 Q.
The brochure was -- was that the picture you're
8 looking at?
9 A.
05:47:51
Yes, sir.
10 Q.
Okay. What year was that?
11 A.
I don't know.
12
MR. FAZEL: Can you go back to the cover. Go
13 to the next page. 522.

14 BY MR. FAZEL:
05:48:30
15 Q.
Let me show you something to refresh your memory as
16 to when the hurricane hit.

17
MR. FAZEL: Let me move on. I'll come back to
18 that. I'm just going to use this to refresh his memory.

19
05:49:08
MR. COSTA: Has he ever seen it before?
20
(Attorneys conferring)
21 BY MR. FAZEL:
22 Q.
I'm going to hand you this article. I want you to
23 look at it. I wonder if that's going to refresh your

24 memory as to when Hugo hit.
05:49:24
25 A.
I don't remember seeing this article before.

877
1 Q.
I know you probably haven't.
2 A.
Okay.
3 Q.
But I'm asking you to look at it, and if it reminds
4 you or tells you, refreshes your memory as to when Hugo

05:49:48
5 hit, because you know Hugo happened.

6 A.
7
Yes, sir.
THE COURT: I tell you, what date was it? What
8 date was the hurricane?
05:49:54
MR. COSTA: 1989.
10
THE COURT: 1989?
11
MR. FAZEL: Right.
12
THE COURT: Okay.
13 BY MR. FAZEL:
14 Q.
05:50:00
And wasn't it then the case that that picture was
15 taken in that photograph because the hurricane had

16 destroyed the office?
05:50:09
17 A.
I would not remember that.
18 Q.
Well --
19 A.
That's not the way that I remember.
20 Q.
-- you just said it was a fabrication.
21
Did you just say that you thought it was a
22 misrepresentation?
23 A.
I said that it seems to me that it was
24 misrepresentation, yes.
05:50:17
25 Q.
Well, is this still a misrepresentation when they had

878
1 to do it because the hurricane destroyed the bank?

2 A.
I don't remember that that was the reason why we took
3 it.
4 Q.
05:50:27
Well, we just said that you can take it as an
5 assumption that the hurricane hit that date.

6 A.
Okay.
7 Q.
So is this still a misrepresentation to you?
8 A.
I don't remember the date that that picture was
9 taken.
05:50:37
10 Q.
Do you understand the CD product at all? Do you
11 understand how it works?

12 A.
As much as you -- yes.
13 Q.
Okay. Well, let me come back to that. Let me ask
14 you something.
05:51:03
05:51:12
15
The insurance policy.
16 A.
Yes, sir.
17 Q.
When you printed it -- do you remember printing it?
18 A.
Yes, sir.
19 Q.
Do you have any problems with printing a document
20 where the owner tells you to print it?

21 A.
No.
22 Q.
Do you have any issues about the fact that
23 Mr. Stanford owned that company? Anything illegal about

24 that?
05:51:21
25 A.
No, sir.
879
1 Q.
Okay. Do you know what a capture insurance company
2 is?
3 A.
No, sir.
4
05:51:25
05:51:37
MR. FAZEL: Is it capture? Captive.
5 BY MR. FAZEL:
6 Q.
Captive insurance company. Do you know what that is?
7 A.
No, sir.
8 Q.
Do you have any clue what that is?
9 A.
I can imagine. We were a captive advertising agency,
10 so I don't know if it's the same or not.

11 Q.
What's a captive advertising agency?
12 A.
Just does business -- it does business for the people
13 who owns the company.

14 Q.
05:51:45
So captive insurance company, what do you think that
15 is?
16 A.
The same.
17 Q.
Same thing.
18
Board meetings. Let's talk about board
19 meetings.
05:52:12
20
Did you ever attend a board meeting?
21 A.
Portions of the board meeting, yes.
22 Q.
Did you attend board meetings when they were doing
23 budgets?
05:52:21
24 A.
No, sir.
25 Q.
You didn't?
880
1 A.
No, I didn't. I mean, you're talking about board
2 meetings of the Stanford?
05:52:32
3 Q.
Yes.
4 A.
Okay. No.
5 Q.
Were you there -- were you there when they discussed
6 an advertising budget for Stanford companies?

7 A.
I don't remember being there, no.
8 Q.
You don't remember being there?
9
05:52:54
MR. COSTA: Can I have a copy?
10
MR. FAZEL: Yeah, sure. I was just trying to
11 see how I was going to ask him.

12
(Attorneys conferring)
13 BY MR. FAZEL:
14 Q.
05:53:10
Could you tell us if you were employed with Stanford
15 companies in 1989?
16 A.
Yes, sir.
17 Q.
Were you employed in February -- excuse me --
18 November 14, 1988?
05:53:20
19 A.
I think so, sir, yes.
20 Q.
Do you know that the board approved a budget of
21 $250,000 for advertising for the year 1989?

22 A.
I don't remember that, sir.
23 Q.
Because they didn't clear that information with you,
24 did they?
05:53:38
25 A.
Pardon me?
881
1 Q.
They didn't clear that information with you, did
2 they?
05:53:46
3 A.
No.
4 Q.
They didn't come to you and say, Hey, Mr. Mejia, what
5 do you think about the budget?

6 A.
No, sir.
7 Q.
You weren't in charge of that; somebody else was;
8 correct?
9 A.
05:53:50
10 Q.
Yes, sir.
So you have no clue what thought went into it or how
11 the processes came about where numbers were put on these

12 reports? You have no clue, do you?
05:54:03
13 A.
Yeah, no clue at all.
14 Q.
No clue at all. You have no idea whether those
15 numbers are inaccurate; correct? You have no knowledge of

16 that?
17 A.
Correct.
18 Q.
What about the special instruction to do -- do you
19 remember talking about "I had a special instruction to do

05:54:20
05:54:31
20 it after hours"? Do you remember that?

21 A.
Yes, sir.
22 Q.
Did they -- did you do it after hours?
23 A.
Yes, sir.
24 Q.
Were the numbers approved by the board and --
25 according to the budget; do you know?

882
1 A.
I don't know. No, I don't know.
2 Q.
Anything -- maybe they -- do you know if it was a
3 time crunch? Maybe they needed it out at a certain time?
05:54:45
4 A.
5 Q.
Not to your knowledge?
I guess my question is why is it -- well,
7 let me rephrase it.

8
It seems to me that you think there's
9 something on -- and there's that word again -- untoward

05:54:55
10 going on at Stanford companies. You think there's

11 something weird going on; right? That's what you're
12 telling this jury; right?
05:55:04
13 A.
Just when I say that?
14 Q.
Just anytime. The numbers were weird and strange to
15 you; right? The fact that they were changing numbers

16 seemed strange to you; right?
05:55:14
17 A.
Oh, yeah, yeah.
18 Q.
You weren't at the board meetings; right?
19 A.
That's right.
20 Q.
You weren't making decisions as to how the numbers
21 should be applied; right?

22 A.
Yes, sir.
23 Q.
You weren't involved in the insurance process, were
24 you?
05:55:21
25 A.
No, sir.
883
05:55:31
05:55:37
1 Q.
You're just guessing?
2 A.
Yes, sir.
3 Q.
You're speculating?
4 A.
No. I'm saying my knowledge at that time. My
5 feelings at that time.

6 Q.
Your feelings?
7 A.
Yes, sir.
8 Q.
It's all speculation?
9 A.
Yes, sir, they are.
10 Q.
Your entire testimony is a speculation, isn't it?
11 A.
No, sir.
12
MR. COSTA: Objection. Argumentative.
13 Mischaracterization as to his testimony.

14
05:55:46
THE COURT: Objection. Rephrase it. I'll
15 overrule. "Speculation" may have a meaning that -- just

16 rephrase it -17
MR. FAZEL: Sure.
18
THE COURT: -- and use a different word for
19 "speculation."
05:55:52
20 BY MR. FAZEL:
21 Q.
You're just guessing?
22 A.
About what?
23 Q.
About what you're testifying about, about the fact
24 that you recall getting bad feelings about the fact that
05:56:00
25 anything bad was going on.

884
THE COURT: Hold it a second.
MR. COSTA: Also objection. I don't know what
3 event he's specifying.
05:56:06
MR. COSTA: He's talked about a number of
6 events about what he saw.

7
8 BY MR. FAZEL:
9 Q.
05:56:12
You're just guessing, aren't you?
10 A.
I'm telling you what I learn at that time.
11 Q.
No, sir. You're not telling us what you learned,
12 because if you had told us what you learned, you could

13 tell us how these numbers came about.
14
05:56:21
You can't do that; right?
15 A.
That's not --
16 Q.
You can't tell us anything about the insurance
17 company and how it was created or why it was created;

18 right?
05:56:28
19 A.
That's right.
20 Q.
You can't tell us when the board meetings were;
21 correct?
22 A.
Yes, sir.
23 Q.
You can't tell us how they came up with a budget
24 numbers, can you?

05:56:34
25 A.
I don't have idea.

885
1 Q.
You're speculating and guessing about everything?
2 A.
No, sir.
3 Q.
No?
4
05:56:40
MR. COSTA: Object. He's never said anything
5 about any of those things.

6
MR. COSTA: He said what he saw and what
8 Mr. Stanford told him.

9
05:56:45
THE COURT: It's cross-examination.
10 BY MR. FAZEL:
11 Q.
Hewlett.
12
THE COURT: The man is saying he's not
13 guessing, and he can hammer that down if he wants.

14 BY MR. FAZEL:
05:56:51
05:57:01
05:57:06
15 Q.
Hewlett. Do you remember anything about Mr. Hewlett?
16 A.
Could you be more specific what it --
17 Q.
Do you know --
18 A.
What do you mean?
19 Q.
-- anything about the qualifications of Mr. Hewlett?
20 A.
No.
21 Q.
Do you know where he's from?
22 A.
No, sir.
23 Q.
Do you know how long he went to school?
24 A.
No, sir.
25 Q.
Do you know if he went to school in London?

886
1 A.
No, sir.
2 Q.
Do you know if he's a certified accountant under the
3 British laws?
05:57:13
4 A.
No, sir.
5 Q.
Have you ever been to his office?
6 A.
I don't remember that. It could be quite possible
7 that later on -8 Q.
Do you have any recollection of ever being in his
9 office?
05:57:23
10 A.
No, sir. Not -- my recollection is not.
11 Q.
Okay. So let's recap real quick for the jury. All
12 right.
13
THE COURT: Excuse me. You can, anytime within
14 the next five minutes that you want to take a break for the
05:57:36
15 day, that's fine.

16
MR. FAZEL: Okay.
17
THE COURT: Next five minutes.
18
MR. FAZEL: Next five minutes.
19 BY MR. FAZEL:
05:57:38
20 Q.
You don't remember anything about Hewlett or his
21 pedigree or his prior credentials?

22 A.
Yes, sir.
23 Q.
You don't know anything about the insurance company,
24 when it was created, why it was created; correct?

05:57:48
25 A.
Yes, sir.
887
1 Q.
You don't know anything about the budget process of
2 Stanford International -- or excuse me -- Guardian

3 International Bank, how it was created, who created it,
4 when it was created; correct?
05:57:57
5 A.
Correct.
6 Q.
You don't know anything about when the numbers were
7 put in the annual report or whether they're accurate or

8 not; correct?
9 A.
05:58:03
10 Q.
Correct.
You have a very limited understanding of the CD
11 product; correct?
05:58:16
05:58:22
05:58:28
12 A.
I don't know what limited is in this case.
13 Q.
Did you know how the monies were invested?
14 A.
Oh, yes. Okay. Correct.
15 Q.
Do you know how the money was invested?
16 A.
No.
17 Q.
Do you know where they were invested?
18 A.
No, sir.
19 Q.
Do you know how rate of returns were determined?
20 A.
No, sir.
21 Q.
You don't know anything about investments?
22 A.
About the CDs?
23 Q.
Yes.
24 A.
Yes -- no.
25 Q.
So -- okay. So am I -- did I miss anything about the

888
1 fact that you're just guessing?

2 A.
You need to tell me what I was guessing in.
MR. COSTA: Objection. What he just
4 answered -05:58:39
THE COURT: Yes. He just answered now. I
6 sustain the objection.
05:58:45
MR. FAZEL: Judge, do you want me to stop?
THE COURT: It's up to you.
MR. FAZEL: Well, I mean, I don't want to pass
10 the witness, but I -11
THE COURT: No. Sure. Stop whenever you want
12 to within, you know, the next four minutes.

13
14
05:59:08

May have a moment, Your Honor?
15
THE COURT: Sure.
16
MR. FAZEL: My mother is calling me.
17
THE COURT: He says probably going to say
18 that's it for tonight. We'll see.
05:59:22
19
MR. FAZEL: I'll pass the witness.
20
THE COURT: Okay. Pass the witness.
21
MR. SCARDINO: Do you pass or --
22
MR. FAZEL: Oh, you don't want me to pass him.
23
THE COURT: Are you adjourning? You move to
24 adjourned for the night at this time?

05:59:33
25
MR. FAZEL: If I have such authority, I move to

889
1 adjourn.
2
THE COURT: Yes, you do, because it's within
3 that timeframe.
4
05:59:43
Ladies and gentlemen, by the way, I'm
5 looking at the clock. We got in basically the maximum -6 the maximum time -- let me do that first. Hang on -- the
7 maximum amount of time based upon 33 years of doing this
8 that we can get in a day. So the lawyers are doing fine.
9 We appreciate you doing fine. But I'm looking at the clock
06:00:06
10 based upon the elapsed time. We got in what I think in my

11 experience is the maximum per day. We're a few minutes
12 even more than that. So we're really getting it, it's
13 moving. I want to thank the attorneys, literally, for
14 that. It's moving. With their own preparation, a little
06:00:26
15 ^ producting, and your patience, we're doing fine. That's

16 all I can tell you as of the first day of testimony. Thank
17 you so much for your attention. Remember all of the
18 instructions I gave you in the past. You can take your
19 books back in there and bring them back out in the morning.
06:00:42
20
Thank you and good afternoon. You may
21 stand and walk into the jury room.

22
23
24
25
890
COURT REPORTER'S CERTIFICATE
2
3 I, Johnny C. Sanchez, certify that the foregoing is a
4 correct transcript from the record of proceedings in the
5 above-entitled matter.
6
7
/s/_________________________
Johnny C. Sanchez, CRR, RMR
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
891
#
#8016 [2] - 561:11, 561:16
1974 [1] - 634:7

1979 [1] - 570:9
1980 [1] - 778:9
1981 [1] - 570:13
1984 [2] - 634:7, 778:8
1986 [1] - 700:17
1987 [14] - 572:12, 619:6, 646:16,
662:13, 683:6, 683:9, 694:12, 694:13,
715:22, 800:22, 810:7, 810:9, 810:10,
810:17
1988 [12] - 619:7, 619:10, 778:5,
779:16, 786:21, 810:12, 811:9, 818:1,
819:19, 823:17, 823:19, 879:18
1989 [5] - 811:13, 876:9, 876:10,
879:15, 879:21
1990 [3] - 620:14, 709:15, 820:15
1992 [1] - 845:23
1993 [1] - 846:10
1994 [2] - 846:12, 846:16
1995 [1] - 741:9
1996 [7] - 671:3, 672:1, 672:5, 675:2,
675:16, 764:2, 764:3
1997 [2] - 741:25, 764:7
1998 [3] - 624:9, 676:3, 764:8
1999 [14] - 663:10, 666:9, 669:8,
669:15, 669:19, 675:5, 676:4, 676:5,
676:18, 764:2, 764:8, 764:11, 767:6,
768:16
1:00 [3] - 690:12, 690:13, 690:16
1 [7] - 588:11, 611:14, 631:19, 631:20,

640:19, 706:22, 817:5
1,713,000 [1] - 684:3
$
1,713,755,342 [1] - 684:3
1-5 [2] - 818:22, 818:23
$10,000 [3] - 800:5, 800:7, 800:13
10 [3] - 669:4, 683:8, 858:9
$100,000 [4] - 612:24, 786:5, 796:3,
10,000-dollar [1] - 865:24
796:5
10.2 [1] - 669:20
$13,582,579 [2] - 672:3, 675:18
10.75 [2] - 801:8, 865:12
$14,950,512 [1] - 683:19
100 [6] - 584:23, 646:15, 660:18,
$14.08 [1] - 669:22
683:6, 810:2, 810:6
$150,000 [3] - 786:4, 864:8, 864:10
1004 [1] - 560:22
$2,000 [3] - 760:5, 796:4, 796:8
101 [1] - 811:3
$2,500 [1] - 628:23
1018 [1] - 561:3
$25,000 [2] - 605:23, 866:3
103 [1] - 820:11
$250 [1] - 632:10
106 [1] - 846:7
$250,000 [3] - 581:18, 724:9, 879:21
109 [2] - 671:3, 763:25
$30 [1] - 768:4
10:08 [1] - 560:6
$30,000 [1] - 592:1
11 [4] - 605:13, 610:6, 610:18, 817:12
$300,000 [1] - 617:24
110 [1] - 763:25
$4,800,000 [1] - 676:3
1100 [1] - 782:6
$400,000 [1] - 612:24
111 [1] - 764:1
$480,000 [1] - 676:5
112 [5] - 663:9, 664:11, 664:16, 675:7,
$5,000 [4] - 628:20, 631:10, 631:11,
764:1
631:19
115 [2] - 646:15, 683:24
$5,447,204 [1] - 672:7
11:29 [1] - 630:17
$5,655,795 [1] - 672:6
11:30 [1] - 630:15
$50 [1] - 619:4
12 [4] - 605:22, 665:1, 709:12, 709:13
2
$500 [1] - 631:21
121 [1] - 632:13
$500,000 [1] - 612:25
121-A [1] - 637:14
$750 [1] - 850:22
2 [11] - 561:4, 584:12, 706:23, 795:14,
121-B [1] - 637:14
795:15, 795:19, 795:20, 796:1, 796:6,
12:54 [1] - 690:21
796:12, 821:4
'
13 [4] - 652:16, 671:15, 742:20, 820:12
2.50 [1] - 669:24
13.5 [1] - 676:13
20 [1] - 686:24
1363 [1] - 610:16
'30s [1] - 837:25
20-plus [1] - 815:17
14 [2] - 608:20, 879:18
'77 [1] - 570:8
20005 [1] - 560:18
140 [1] - 610:5
'79 [1] - 570:9
2001 [4] - 632:14, 640:19, 641:19
1400 [1] - 560:17
'80s [1] - 700:14
2002 [5] - 646:16, 662:13, 676:19,
147
[1]
610:16
'84 [2] - 778:5, 779:14
683:23, 686:16
147,000 [1] - 814:17
'87 [2] - 610:2, 683:20
2008 [1] - 724:8
147,114 [2] - 814:1, 814:7
'88 [2] - 712:1, 811:11
2011 [1] - 737:9
1493 [1] - 792:1
'89 [4] - 610:6, 712:1, 712:2
2012 [2] - 560:5, 650:5
15 [19] - 604:1, 630:16, 652:16, 654:6,
'90 [2] - 620:15, 821:14
21 [2] - 568:19, 675:7
688:13, 689:23, 722:4, 722:5, 742:22,
'91 [2] - 620:15, 821:14
22 [1] - 782:8
742:25, 743:1, 743:3, 766:15, 771:18,
'92 [1] - 821:14
23 [1] - 568:19
818:21,
818:23,
818:25,
859:16,
859:23
'95 [1] - 742:22
23.29 [1] - 669:21
15-minute [2] - 630:6, 819:13
'97 [3] - 742:22, 743:1, 743:2
23.76 [1] - 669:24
1516 [3] - 577:17, 578:3, 578:7
24 [6] - 605:22, 672:8, 674:21, 675:18,
15th [1] - 688:8
/
709:22, 709:23
17 [5] - 715:22, 741:9, 741:16, 742:21,
25 [6] - 560:5, 568:19, 665:1, 675:7,
742:24
709:22, 709:23
/s [1] - 889:6
17,000 [5] - 562:9, 565:20, 636:16,
25,000-dollar [1] - 865:22
636:17, 636:20
26 [2] - 663:10, 664:17
17th [1] - 650:5
0
27 [2] - 610:17, 665:3
18 [1] - 605:22
28 [2] - 569:20, 570:2
18.35 [1] - 669:20
09-CR-342 [1] - 560:4
2:15 [4] - 690:12, 690:17, 690:20,
19 [1] - 821:2
775:4
1932 [8] - 611:2, 834:18, 834:24,
835:11, 837:14, 838:10, 839:7, 868:6
892
accepting [1] - 572:20
access [2] - 642:24, 657:1
accomplish [1] - 565:8
3 [6] - 560:8, 605:22, 641:9, 707:2,
accordance [1] - 665:10
737:9, 823:13
according [6] - 619:2, 660:13, 704:23,
3-1/2 [1] - 641:9
800:14, 820:1, 880:25
30 [7] - 606:7, 663:11, 744:18, 799:14,
account [16] - 583:24, 584:3, 584:4,
826:18, 827:3, 856:6
584:10, 589:11, 590:14, 590:19,
30-day [1] - 704:8
591:14, 592:4, 628:25, 722:13, 722:15,
30th [1] - 619:10
722:18, 722:20, 726:15, 802:19
31 [8] - 610:19, 640:19, 666:9, 672:1,
accountant [3] - 731:3, 731:18, 885:2
7
672:4, 675:16, 676:3, 834:4
accountants [1] - 666:19
31st [1] - 824:3
accountholder [2] - 727:9, 727:13
7 [6] - 602:16, 606:7, 625:12, 806:15,
32 [1] - 568:17
accounting [29] - 595:19, 602:25,
813:17, 813:22
33 [3] - 658:11, 710:2, 888:7
622:1, 663:16, 663:20, 665:16, 666:11,
713.250.5581 [2] - 561:12, 561:17
34 [1] - 650:5
666:21, 667:4, 668:14, 670:4, 729:21,
75 [2] - 604:18, 604:20
35 [2] - 616:12, 824:3
729:22, 732:14, 732:19, 732:25, 734:4,
77002 [4] - 560:23, 561:4, 561:11,
36 [3] - 605:22, 865:20, 865:22
744:9, 746:25, 752:5, 763:16, 763:21,
561:17
365-day [1] - 605:21
764:21, 767:11, 767:20, 772:9, 817:24,
77208-1129 [1] - 560:15
38th [2] - 576:7, 782:6
857:21, 873:22
77279 [1] - 561:7
3:44 [1] - 775:11
accounts [13] - 571:4, 583:16, 583:17,
79535 [1] - 561:7
3:45 [1] - 775:5
583:18, 584:11, 585:10, 588:5, 609:12,
3rd [1] - 560:22
641:24, 725:8, 736:7, 736:10, 803:13
8
accredited [2] - 627:9, 627:14
accrued [1] - 592:14
4
accumulate [1] - 852:25
8 [2] - 820:7, 837:8
accumulation [1] - 852:10
8.75 [1] - 800:17
4 [9] - 584:12, 590:11, 600:24, 707:2,
accuracy [1] - 853:10
803.6
[2]
649:7,
649:14
785:6, 813:3, 820:12, 820:13, 835:3
accurate [8] - 646:21, 647:3, 689:15,
88 [1] - 610:17
4,800,000 [1] - 675:19
707:4, 750:15, 862:14, 863:8, 886:7
89 [1] - 610:17
40 [1] - 652:17
accused [2] - 734:21, 742:13
400 [2] - 652:19, 655:14
accustomed [1] - 589:4
400-some-odd [1] - 657:7
9
acquired [1] - 617:6
40s [1] - 785:10
acquiring [1] - 624:24
46 [1] - 643:19
9 [1] - 817:5
act [1] - 792:24
48 [1] - 785:10
9.75 [1] - 800:18
active [2] - 835:11, 868:6
4:00 [1] - 775:6
90 [3] - 589:20, 625:14, 787:8
actively [1] - 577:8
90-day [1] - 589:18
activities [1] - 604:4
5
94 [1] - 785:6
activity [1] - 710:21
96 [1] - 785:6
acts [1] - 611:16
97 [1] - 592:13
actual [8] - 582:9, 583:14, 607:12,
5 [3] - 631:13, 687:1, 817:5
615:23, 619:17, 681:18, 788:1, 830:17
98 [1] - 651:21
5,000 [1] - 865:24
ad [5] - 780:9, 780:10, 780:11, 780:13,
98,000 [1] - 592:13
500 [1] - 633:11
801:14
502 [5] - 614:21, 725:14, 725:17,
add [5] - 656:18, 816:19, 816:20,
762:8, 823:5
A
817:3,
817:9
503 [3] - 798:5, 798:16, 864:15
added [5] - 584:1, 589:6, 596:22,
511 [4] - 841:20, 841:25, 842:2, 843:17
A&M [8] - 778:12, 778:13, 778:21,
609:16, 796:6
515 [2] - 561:11, 561:16
778:23, 779:2, 780:25, 781:1, 857:13
addition [3] - 803:8, 809:9, 812:21
519 [5] - 803:23, 804:8, 835:3, 866:8,
a.m [2] - 560:6, 630:17
additional [1] - 628:23
868:4
able [18] - 562:19, 564:25, 565:13,
additionally [3] - 633:18, 633:21,
520 [1] - 582:13
567:1, 580:18, 592:23, 611:22, 614:3,
672:3
521 [4] - 582:13, 583:3, 866:23, 866:24
614:8, 618:19, 657:2, 682:15, 746:14,
address [8] - 616:11, 738:24, 739:15,
522 [8] - 600:1, 782:8, 788:1, 806:7,
768:18, 774:12, 810:14, 817:2, 855:23
740:12, 780:21, 824:1, 824:5, 824:8
834:1, 866:21, 866:22, 875:13
above-entitled [1] - 889:5
addressed [1] - 635:11
5:00 [1] - 827:2
absentee [1] - 596:16
adequately [1] - 665:18
5:02 [1] - 827:8
absolute [5] - 603:7, 651:3, 658:21,
adjourn [2] - 827:8, 888:1
661:18, 807:5
adjourned [1] - 887:24
6
absolutely [12] - 567:5, 575:18,
adjourning [1] - 887:23
592:18, 602:15, 620:6, 644:15, 651:7,
Adjustments [1] - 641:13
652:24, 690:3, 692:7, 711:10, 716:19
6 [4] - 605:22, 649:8, 687:1, 785:7
adjustments [1] - 641:13
accept [1] - 785:14
60-something [1] - 820:8
administration [1] - 620:21
accepted [3] - 572:14, 726:24, 732:14
608(b [2] - 739:19, 740:6

608(b) [1] - 739:23
61129 [1] - 560:14
612 [2] - 715:6, 715:7
613 [2] - 715:8, 715:9
613-A [1] - 715:10
6:00 [3] - 827:9, 827:16, 840:15
6:01 [1] - 888:22
6:05 [1] - 827:9
893
738:10, 844:11, 851:1, 857:24, 865:8,
774:17, 786:5, 786:6, 795:11, 796:3,
administrative [8] - 570:15, 581:1,
869:13, 869:16
797:1, 800:4, 850:21, 850:24, 865:18,
621:25, 669:19, 670:2, 670:8, 670:16,
888:7
713:18
agreed [6] - 617:14, 617:24, 650:12,
amounts [7] - 610:12, 610:13, 665:13,
657:4, 659:11, 850:19
admissibility [2] - 650:9, 650:12
768:13, 798:9, 799:24, 820:24
agreeing [1] - 651:4
admissible [1] - 826:14
amplify [2] - 586:4, 735:7
agreement [13] - 562:10, 562:18,
admit [1] - 633:16
ancillary [1] - 670:5
562:22, 565:24, 650:7, 659:12, 702:15,
admitted [2] - 577:24, 799:4
717:23, 718:2, 719:20, 762:22, 784:9,
Andersen [1] - 668:16
admitting [2] - 637:16, 640:6
846:24
Andrew [1] - 560:16
ads [8] - 779:11, 779:12, 797:22,
agreements [2] - 721:17, 722:12
angle [1] - 862:7
797:23, 798:11, 798:14, 799:20
agrees [1] - 659:9
angry [1] - 851:23
advance [4] - 562:12, 564:2, 564:3,
ahead [21] - 562:5, 562:23, 568:6,
anniversary [1] - 688:8
565:5
573:10, 600:8, 630:25, 636:22, 659:17,
Advances [2] - 671:20, 675:10
announce [1] - 565:24
662:7, 663:6, 675:5, 676:1, 692:23,
advantage [3] - 562:20, 612:3, 614:10
Annual [1] - 810:9
697:11, 720:8, 745:7, 774:7, 776:11,
advantages [1] - 624:8
annual [71] - 596:25, 632:23, 644:6,
781:10, 811:2, 828:1
644:8, 644:12, 644:21, 644:25, 645:11,
advertised [1] - 782:25
aide [1] - 713:18
645:16, 646:4, 646:16, 646:21, 647:6,
advertisement [5] - 780:19, 800:14,
aim [2] - 860:11, 860:16
648:19, 651:11, 651:12, 654:4, 657:25,
801:7, 801:22, 801:25
air [1] - 746:11
662:12, 662:18, 662:20, 663:9, 669:4,
advertisements [5] - 797:25, 798:17,
airline [2] - 682:3, 682:20
670:8, 670:24, 671:1, 671:3, 671:11,
801:3, 803:8, 812:16
airplanes [1] - 742:2
671:15, 675:2, 683:7, 683:25, 689:7,
Advertising [14] - 681:1, 682:19,
729:7, 750:21, 751:7, 751:9, 751:11,
Alexander [1] - 697:12
787:5, 798:15, 803:19, 804:3, 810:21,
751:12, 751:16, 764:1, 764:3, 764:8,
Ali [1] - 560:20
814:11, 814:14, 818:17, 820:6, 841:7,
764:15, 765:25, 767:5, 768:17, 769:4,
allegations [1] - 739:5
846:19, 864:13
774:15, 774:16, 809:10, 809:12,
Allen [49] - 571:25, 572:1, 573:6,
advertising [30] - 779:19, 779:21,
809:14, 809:22, 811:9, 811:11, 812:9,
573:24, 575:21, 576:25, 577:10,
780:15, 780:16, 781:22, 782:25,
812:14, 812:19, 813:20, 814:3, 817:17,
584:14, 594:18, 596:6, 603:20, 603:21,
783:22, 784:1, 784:6, 784:10, 784:15,
818:1, 819:16, 819:19, 820:1, 820:21,
604:5, 604:7, 604:13, 612:24, 616:15,
785:21, 786:9, 788:9, 798:21, 799:17,
821:10, 821:13, 846:10, 886:7
622:4, 636:5, 669:11, 716:3, 749:6,
814:1, 814:2, 814:5, 814:9, 814:23,
annualized [1] - 632:5
779:22, 779:23, 781:25, 782:4, 784:5,
815:4, 840:17, 850:9, 850:10, 852:4,
answer [31] - 569:3, 569:4, 611:21,
794:8, 804:7, 805:11, 809:13, 811:10,
878:9, 878:11, 879:6, 879:21
645:24, 674:14, 685:18, 689:20, 706:2,
812:4, 813:11, 813:15, 815:13, 815:25,
advisor [4] - 625:13, 626:7, 626:11,
718:24, 722:24, 722:25, 723:1, 723:2,
816:2, 816:25, 817:20, 830:14, 830:16,
688:24
735:2, 735:7, 747:12, 748:17, 750:2,
831:24, 834:21, 834:25, 838:18,
advisors [2] - 624:16, 674:1
750:5, 774:12, 781:10, 804:23, 828:20,
850:14, 869:2
advocates [1] - 658:15
834:9, 834:14, 840:22, 841:2, 851:15,
ALLEN [1] - 560:6
affairs [1] - 666:8
874:6
allocation
[1]
641:19
affecting [1] - 614:2
answer) [1] - 703:18
Allocations [1] - 643:2
affiliate [5] - 574:24, 594:11, 594:14,
answered [7] - 719:4, 758:20, 852:16,
allow [10] - 565:5, 565:21, 580:15,
597:4, 727:21
852:18,
867:25, 887:4, 887:5
618:20,
661:9,
742:18,
776:12,
844:7,
Affiliated [2] - 671:21, 675:11
Answered [3] - 712:3, 758:10, 765:8
847:3, 848:25
affiliates [2] - 629:21, 672:4
answers [1] - 610:23
allowed [8] - 566:19, 585:5, 763:6,
affiliating [1] - 624:24
Antigua [49] - 578:24, 579:3, 597:22,
766:12, 775:18, 800:13, 800:14, 846:25
affirmatively) [2] - 712:3, 765:8
599:1,
620:9, 620:13, 620:19, 620:22,
allowing
[1]
591:22
afford [2] - 759:17, 759:19
621:2, 622:5, 622:7, 622:8, 622:13,
allows [1] - 809:1
afternoon [15] - 692:5, 693:3, 775:5,
622:24, 623:16, 623:20, 624:3, 624:8,
almost [16] - 578:23, 610:19, 650:6,
777:14, 777:15, 808:9, 808:10, 808:22,
666:12, 666:20, 667:13, 677:7, 677:9,
650:20,
652:19,
658:9,
658:12,
686:23,
809:1, 809:2, 809:5, 809:6, 809:8,
678:6, 678:21, 679:1, 679:22, 681:4,
690:13, 690:15, 757:2, 775:4, 775:5,
856:23, 888:20
681:5, 681:9, 681:14, 681:24, 682:7,
827:2, 835:2
agencies [4] - 580:12, 580:14, 627:16,
682:19, 708:21, 709:14, 709:18,
alone
[1]
616:20
627:24
714:19, 714:20, 714:21, 721:13,
Alvarado [2] - 781:17, 781:24
agency [23] - 569:16, 581:14, 581:19,
732:22, 736:5, 736:12, 817:25, 818:17,
Alvarado's [1] - 781:18
605:10, 605:11, 697:16, 779:19,
845:18, 845:19, 846:3
Alvaro
[2]
745:23,
792:22
779:21, 783:22, 785:3, 785:4, 785:7,
Antiguan [1] - 623:7
America [16] - 601:20, 688:24, 760:1,
785:21, 814:9, 838:19, 839:22, 840:1,
anytime [2] - 881:14, 885:13
760:2, 778:7, 780:16, 781:23, 783:5,
840:17, 841:18, 842:11, 852:4, 878:9,
anyway [1] - 620:20
783:7,
783:21,
787:4,
795:3,
795:4,
878:11
apartment [1] - 594:4
803:6, 803:7, 803:16
agent [1] - 742:1
apologize [3] - 700:11, 726:7, 868:17
AMERICA [1] - 560:4
aggregate [1] - 672:2
appeal [1] - 652:18
American [9] - 570:6, 723:14, 723:15,
ago [9] - 680:8, 741:9, 741:15, 742:20,
Appeals [1] - 658:4
723:17, 724:13, 724:15, 724:19,
742:21, 742:22, 742:25, 743:3, 840:4
appeals [1] - 735:17
725:10, 799:21
agree [20] - 618:20, 638:21, 639:22,
APPEARANCES [2] - 560:12
amount [19] - 581:19, 584:21, 605:23,
651:3, 659:14, 695:13, 696:3, 702:24,
apples [1] - 734:7
619:3, 672:3,
675:17,
676:12,
676:14,
703:3, 703:13, 707:2, 710:5,Johnny
730:18, C. Sanchez,
RMR, CRR - jcscourtreporter@aol.com
894
581:1, 603:4, 604:15, 780:23, 833:24,
application [1] - 722:13
assuring [1] - 690:5
835:13, 860:1
applications [2] - 571:5, 583:17
atmosphere [1] - 775:23
backing [1] - 607:23
applied [4] - 617:11, 640:23, 665:18,
attached [1] - 634:25
backwards [1] - 755:24
881:21
attend [3] - 797:14, 878:20, 878:22
bad [11] - 594:3, 711:20, 712:4, 712:7,
applies [1] - 869:20
attended [2] - 713:5, 821:19
724:22, 724:24, 725:3, 867:17, 867:21,
apply [1] - 627:10
attention [4] - 602:7, 740:16, 804:19,
882:24, 882:25
appreciate [3] - 563:22, 635:14, 888:9
888:17
Baker [1] - 701:8
approach [5] - 567:1, 567:6, 737:21,
attitude [4] - 795:24, 796:11, 832:19,
balance [4] - 675:19, 676:2, 775:20,
776:10, 848:1
832:23
858:10
approached [2] - 571:18, 741:25
attorney [6] - 567:11, 723:5, 728:22,
balancing [1] - 858:15
734:15, 735:7, 868:14
appropriate [1] - 665:17
Bank [64] - 570:16, 570:19, 570:22,
Attorney [2] - 560:14, 561:3
approval [5] - 597:2, 619:19, 645:9,
570:24, 571:7, 571:10, 574:5, 574:23,
attorneys [11] - 715:11, 775:12,
818:19, 819:13
581:6, 581:21, 583:1, 583:6, 585:8,
775:19, 775:22, 776:4, 776:5, 827:11,
approve [4] - 805:16, 859:17, 859:20,
587:8, 588:23, 591:19, 592:10, 592:25,
842:4, 875:20, 879:12, 888:13
859:22
600:1, 611:7, 611:22, 613:14, 618:24,
attractive [1] - 590:5
approved [11] - 617:20, 618:15,
623:1, 663:18, 663:19, 681:4, 681:8,
attuned [1] - 775:21
638:18, 639:24, 731:11, 735:19,
681:12, 681:14, 682:19, 688:23, 694:5,
762:25, 818:15, 818:16, 879:20, 880:24
audible [1] - 703:18
698:7, 698:9, 703:21, 706:13, 712:19,
approves [1] - 747:22
audience [1] - 630:9
718:13, 721:12, 724:12, 724:13,
approving [2] - 818:14, 821:10
audit [9] - 580:15, 618:21, 665:6,
732:22, 732:23, 736:5, 754:23, 755:1,
area [14] - 568:22, 569:20, 576:9,
665:10, 713:25, 714:1, 714:7, 732:5,
760:1, 760:2, 760:9, 762:14, 768:3,
583:4, 609:7, 609:10, 659:21, 661:21,
763:6
780:11, 783:10, 786:18, 804:24, 812:2,
695:3, 778:4, 779:1, 789:14, 795:7,
audited [1] - 664:25
840:5, 846:4, 846:17, 870:23, 886:3
857:25
auditing [6] - 665:11, 667:15, 731:11,
bank [340] - 570:21, 571:18, 573:13,
areas [1] - 598:4
850:4, 850:6, 850:20
573:18, 574:4, 574:7, 574:25, 575:2,
Argentina [1] - 803:1
auditor [14] - 663:14, 663:15, 663:19,
575:3, 576:3, 576:19, 579:12, 579:14,
Argumentative [1] - 882:12
663:25, 664:3, 664:5, 666:5, 713:21,
579:17, 579:19, 579:20, 580:1, 580:5,
713:22,
715:25,
716:4,
716:10,
731:3,
argumentative [1] - 734:17
580:6, 580:16, 580:19, 581:9, 581:18,
817:19
arise [1] - 821:24
581:21, 582:1, 582:2, 582:3, 582:7,
Auditor's [2] - 663:12, 664:24
arm [2] - 776:6, 776:7
582:9, 582:21, 583:4, 583:15, 583:19,
auditor's [1] - 664:8
Arnold [1] - 593:18
584:19, 584:21, 585:1, 585:8, 587:8,
auditors [3] - 665:2, 666:20, 714:6
arrested [1] - 741:14
587:14, 587:17, 588:8, 588:23, 589:6,
auditors' [1] - 817:18
arrived [6] - 567:17, 595:21, 596:4,
589:8, 589:10, 590:1, 590:19, 590:21,
August [1] - 715:22
616:16, 810:25, 811:16
590:23, 591:1, 591:11, 591:20, 592:6,
Austin
[1]
570:6
arrow [1] - 578:24
592:12, 592:15, 592:20, 594:7, 594:10,
authentic [3] - 648:2, 651:11, 652:23
Arthur [1] - 668:16
594:11, 594:14, 594:15, 594:25, 595:2,
authenticity [6] - 565:6, 648:22, 650:8,
article [2] - 875:22, 875:25
596:11, 597:7, 597:12, 597:14, 597:25,
650:12, 653:21, 657:17
artistically [1] - 698:4
598:3, 598:6, 598:8, 599:21, 603:1,
authorities [1] - 620:24
artwork [1] - 576:10
603:12, 603:17, 604:20, 604:21, 605:1,
authority [1] - 887:25
Aruba [1] - 795:6
609:11, 609:23, 609:24, 610:14,
automotive [1] - 741:10
aside [2] - 565:14, 661:18
611:10, 611:13, 611:25, 612:9, 612:15,
available [5] - 627:1, 627:4, 694:19,
asserted [1] - 655:24
612:17, 613:1, 613:7, 613:10, 613:13,
701:15, 796:25
assessment [1] - 665:14
613:17, 613:22, 614:4, 614:8, 614:11,
Avenue [1] - 560:17
asset [1] - 641:19
614:17, 617:7, 618:1, 618:2, 618:20,
average [1] - 590:11
assets [22] - 609:2, 610:7, 610:15,
620:13, 620:16, 621:2, 621:4, 622:5,
averaged [1] - 584:12
627:25, 628:1, 643:23, 674:11, 674:19,
622:23, 622:24, 623:16, 624:3, 627:10,
avoid [1] - 606:14
683:3, 683:20, 689:6, 765:22, 766:1,
628:14, 629:4, 629:11, 632:14, 633:1,
820:2, 820:6, 854:4, 854:17, 855:7,
award [1] - 629:21
637:4, 637:20, 641:17, 641:23, 642:1,
855:13, 855:18, 855:24
aware [32] - 623:6, 623:24, 677:16,
642:8, 644:12, 646:16, 646:22, 647:5,
Assets [2] - 683:15, 684:1
678:24, 695:24, 696:4, 698:22, 701:9,
653:20, 662:13, 663:24, 664:5, 665:24,
712:18, 713:4, 713:7, 719:6, 731:10,
assist [1] - 609:11
666:5, 666:21, 667:16, 668:22, 668:24,
739:5, 753:13, 753:16, 754:22, 754:25,
assistant [3] - 570:15, 626:12, 793:1
669:1, 669:25, 670:1, 670:7, 670:12,
755:3, 760:16, 760:18, 760:19, 766:10,
Assistant [1] - 560:14
670:17, 670:20, 672:1, 672:4, 672:6,
767:5, 767:7, 769:21, 861:24, 861:25,
assistants [2] - 581:1, 642:24
672:7, 672:10, 672:15, 675:16, 676:7,
862:4, 862:19, 862:22, 871:19
assisted [2] - 561:13, 561:19
676:15, 676:20, 676:23, 676:25,
assisting [2] - 569:17, 743:11
677:17, 677:18, 678:15, 679:17, 681:3,
associated [2] - 581:5, 741:10
681:10, 681:15, 684:7, 685:1, 685:3,
B
assume [3] - 693:6, 731:14, 831:21
686:8, 686:16, 689:25, 698:23, 699:1,
699:9, 699:20, 699:21, 700:16, 700:17,
assuming [6] - 630:4, 752:2, 859:4,
BA [1] - 603:25
701:24, 702:4, 702:5, 702:6, 702:7,
859:5, 859:6, 860:20
bachelor's [1] - 570:6
702:9, 702:11, 703:15, 703:17, 705:3,
assumption [1] - 877:5
back-to-back [1] - 592:1
705:6, 707:5, 707:11, 708:3, 708:7,
assurance [1] - 613:19
background [9] - 569:23, 571:15,
895
712:8, 712:11, 713:25, 714:7, 714:17,
barber [1] - 838:5
big [7] - 667:9, 729:21, 769:13, 801:6,
714:19, 716:4, 717:24, 718:1, 720:16,
802:2, 802:3, 865:3
barbershop [1] - 838:14
720:21, 722:15, 722:16, 722:17,
bigger [2] - 710:15
Barbuda [2] - 579:5, 666:12
722:20, 724:16, 724:19, 725:3, 725:10,
bilingual [2] - 571:1, 573:21
base [2] - 588:7, 609:2
726:21, 727:15, 727:19, 727:21, 728:9,
billion [1] - 684:8
based [28] - 576:3, 577:6, 577:10,
729:4, 730:14, 732:5, 736:5, 736:7,
579:15, 581:9, 584:18, 584:20, 587:22,
billion-dollar [1] - 684:8
736:10, 736:22, 743:10, 744:7, 744:10,
597:21, 605:20, 621:4, 621:5, 622:2,
billions [1] - 766:21
744:18, 744:21, 744:22, 759:24,
625:3, 665:6, 666:20, 667:11, 687:23,
bills [1] - 606:8
760:22, 763:9, 764:1, 764:9, 764:16,
787:13, 840:8, 843:5, 853:4, 854:25,
binders [1] - 822:9
764:19, 764:24, 765:4, 765:17, 765:20,
855:8, 858:3, 868:25, 888:7, 888:10
bio [1] - 603:18
765:21, 765:22, 766:4, 766:6, 766:21,
basic [1] - 873:13
birthday [2] - 857:3, 857:5
781:23, 783:8, 783:9, 783:11, 783:23,
basing [1] - 624:8
bit [29] - 587:2, 592:8, 598:7, 611:17,
784:11, 786:16, 786:25, 787:1, 787:2,
Basis [1] - 665:9
613:11, 616:24, 617:1, 620:9, 627:18,
787:3, 787:6, 787:8, 787:9, 787:12,
basis [24] - 577:14, 586:15, 586:23,
666:16, 673:21, 675:20, 687:17,
789:25, 790:25, 792:11, 792:17,
588:25, 591:7, 596:21, 598:1, 607:3,
708:24, 714:18, 730:11, 732:13,
793:16, 793:19, 793:20, 794:1, 794:19,
617:13, 628:16, 629:24, 648:15,
736:15, 775:18, 795:3, 803:1, 828:6,
795:14, 795:20, 797:2, 798:17, 798:20,
652:21, 654:16, 655:2, 657:16, 657:21,
835:13, 836:7, 836:8, 849:15, 862:7,
802:8, 802:15, 804:22, 805:2, 809:10,
661:15, 665:12, 665:20, 665:23,
865:9, 874:22
809:20, 814:13, 814:14, 814:17,
684:12, 729:7, 750:11
blank [1] - 679:7
816:10, 819:4, 820:1, 820:5, 822:21,
bay [1] - 677:17
blew [1] - 757:23
832:2, 835:6, 835:9, 840:11, 841:11,
Baylor [1] - 603:24
blow [3] - 643:7, 671:22, 725:17
841:13, 841:14, 842:9, 842:20, 843:3,
beach [1] - 582:23
blue [1] - 780:2
844:1, 844:2, 844:23, 845:10, 845:14,
bear [1] - 694:21
board [48] - 577:6, 593:5, 601:5,
845:15, 845:17, 845:19, 846:15,
became [10] - 590:1, 590:7, 596:4,
602:12, 602:19, 602:22, 602:23, 603:7,
848:22, 853:1, 853:23, 854:4, 855:8,
597:9, 621:24, 626:12, 706:18, 721:12,
603:13, 604:1, 652:9, 652:14, 669:6,
862:16, 862:22, 862:25, 863:1, 863:20,
747:4, 750:17
710:19, 712:24, 713:2, 713:5, 713:12,
863:21, 866:16, 866:20, 867:9, 867:14,
become [5] - 580:5, 580:18, 625:8,
715:21, 715:24, 716:1, 716:3, 716:8,
868:4, 869:25, 870:3, 870:5, 870:9,
644:16, 719:13
716:9, 716:21, 732:5, 744:5, 752:9,
870:19, 871:6, 872:2, 872:4, 873:15,
becomes [4] - 718:7, 718:10, 718:14,
761:21, 807:2, 807:5, 807:13, 807:16,
877:1
719:12
807:25, 808:19, 808:21, 813:12, 836:1,
bank's [27] - 583:7, 586:18, 602:14,
878:18, 878:20, 878:21, 878:22, 879:1,
becoming [2] - 574:7, 581:5
604:15, 609:14, 612:4, 620:25, 643:23,
879:20, 880:24, 881:18, 883:20
BEFORE [1] - 560:10
644:25, 647:7, 665:17, 666:24, 676:3,
boat [1] - 579:4
began [2] - 626:23, 744:13
683:20, 689:6, 711:14, 714:2, 766:1,
body [1] - 623:8
beginning [10] - 580:23, 585:7,
790:10, 794:7, 795:9, 799:17, 810:16,
bolstering [1] - 781:6
669:14, 703:1, 745:9, 745:12, 746:2,
817:19, 820:2, 842:10
bond [4] - 611:14, 641:5, 641:8,
749:12, 750:23, 815:21
banker [5] - 752:7, 766:10, 792:25,
641:10
behalf [6] - 575:2, 603:1, 603:2,
797:6, 824:11
bonds [7] - 585:18, 591:16, 605:17,
641:23, 702:11, 707:11
banker's [1] - 611:13
624:18, 641:22, 820:24, 820:25
behind [7] - 605:1, 630:10, 779:25,
bankers [18] - 571:19, 609:16, 793:12,
bonus [5] - 588:8, 588:9, 629:9,
798:10, 816:17, 827:25
797:9, 809:18, 809:21, 821:19, 822:4,
629:24, 629:25
bell [2] - 701:8, 867:4
822:7, 822:10, 822:15, 825:20, 825:21,
bonuses [1] - 628:8
belonged [1] - 806:6
828:23, 831:11, 831:21, 845:6, 873:17
book [1] - 625:12
belonging [1] - 726:23
bankers' [1] - 797:18
bookkeeping [1] - 595:19
belongs [1] - 728:9
Banking [1] - 608:22
booklets [2] - 760:13, 760:16
below [3] - 665:9, 666:14, 726:17
banking [26] - 570:16, 570:18, 573:21,
books [3] - 664:6, 665:25, 888:19
bench [3] - 567:6, 567:13, 826:13
579:13, 580:11, 580:13, 580:25,
born [1] - 568:17
Benderhood [1] - 795:6
591:25, 604:2, 605:25, 608:7, 608:25,
borrow [2] - 591:22, 592:11
beneath [4] - 582:25, 603:18, 605:14,
609:6, 609:8, 609:15, 613:17, 618:21,
borrowed [2] - 672:15, 676:15
640:25
620:21, 622:9, 623:4, 714:22, 783:7,
benefit
[1] - 697:9
borrowing [1] - 766:20
794:13, 838:23, 842:6, 845:11
benefits [1] - 602:10
bottom [8] - 609:18, 642:18, 671:23,
bankruptcy [3] - 617:19, 618:14,
726:4,
727:7, 783:20, 802:12, 810:8
best
[8] - 655:1, 707:6, 716:14, 719:4,
762:24
Botts
[1] - 701:8
775:20,
796:25,
805:21,
806:3
banks [42] - 580:2, 581:10, 581:15,
better [14] - 586:4, 620:20, 620:22,
bought [5] - 589:18, 628:18, 681:11,
581:16, 581:24, 584:11, 584:22,
629:11, 678:17, 725:23, 740:1, 777:16,
682:1, 682:3
586:25, 589:4, 590:10, 590:12, 592:24,
785:13,
809:7,
833:1,
849:11,
852:2
bound [2] - 651:10, 656:9
605:19, 607:11, 607:15, 611:11,
better-known [1] - 620:20
box [3] - 802:12, 824:8, 824:9
611:24, 614:12, 618:3, 618:24, 622:7,
between [13] - 583:12, 584:12, 596:22,
Box [2] - 560:14, 561:7
622:10, 622:17, 623:1, 623:25, 624:18,
612:22,
672:10,
676:6,
682:7,
684:14,
boys [2] - 568:19, 687:6
624:23, 629:3, 629:7, 664:2, 705:2,
732:10, 767:14, 820:7, 827:8
branch [1] - 625:5
724:13, 725:5, 732:23, 753:20, 753:21,
beyond [6] - 638:19, 639:24, 740:9,
brand [1] - 605:2
766:7, 766:10, 795:10, 797:5, 870:8
770:15, 771:20, 844:6
brand-new [1] - 605:2
bar [1] - 804:15
896
Brazil [1] - 803:2
bundled [1] - 637:1
caliber [1] - 601:24
bread [1] - 692:1
buried [1] - 774:18
camera [1] - 788:22
breadth [1] - 609:2
business [32] - 577:9, 580:7, 580:9,
cancer [1] - 569:14
581:2, 583:14, 586:20, 593:23, 595:1,
break [19] - 565:10, 587:2, 630:5,
cannot [4] - 580:6, 793:11, 829:15,
596:5, 598:4, 606:25, 607:23, 613:23,
630:6, 630:7, 631:3, 635:4, 637:13,
866:17
620:25, 649:5, 653:20, 672:11, 676:8,
650:1, 662:11, 685:20, 690:11, 691:8,
capability [1] - 829:5
681:16, 682:12, 682:13, 684:21,
775:5, 827:9, 827:17, 827:20, 885:14
Capital [4] - 570:15, 570:19, 570:22,
688:11, 728:24, 784:7, 784:13, 816:10,
breakdown [1] - 641:21
571:10
833:22, 857:18, 878:12
breaking [1] - 592:2
capital [3] - 594:23, 605:16, 679:12
businesses [4] - 593:3, 682:18,
brief [3] - 740:17, 761:12, 856:8
captive [11] - 728:3, 728:5, 728:6,
689:25, 833:18
briefing [1] - 653:5
728:14, 729:3, 762:4, 878:4, 878:6,
businessmen [1] - 611:3
878:9, 878:11, 878:14
briefly [1] - 694:9
butter [1] - 692:1
capture [2] - 878:1, 878:4
bring [11] - 562:3, 570:20, 680:8,
buy [7] - 594:4, 614:8, 624:17, 627:4,
captured [2] - 728:1, 728:2
740:15, 776:10, 797:2, 829:3, 842:3,
718:11, 742:2, 800:14
844:8, 847:6, 888:19
car [1] - 681:19
buying [4] - 765:17, 765:21, 770:1
brings [1] - 604:1
Caracas [1] - 629:20
BWI [2] - 791:23, 868:5
British [27] - 576:11, 576:12, 611:9,
card [2] - 571:4, 722:14
BY [186] - 568:12, 569:6, 570:10,
614:22, 616:12, 617:23, 618:6, 620:1,
cards [3] - 571:5, 681:19, 736:9
571:23, 572:9, 573:22, 574:17, 576:17,
698:16, 698:17, 728:8, 730:11, 731:18,
care [6] - 569:14, 570:20, 686:10,
578:20, 579:11, 579:24, 582:16, 584:8,
762:11, 791:23, 791:24, 823:10, 824:1,
722:22, 744:6, 744:13
586:7, 593:10, 598:24, 600:9, 600:17,
825:17, 825:21, 828:7, 828:14, 829:19,
careers [1] - 611:3
601:1, 601:9, 601:14, 602:17, 606:21,
831:8, 832:3, 835:9, 885:3
Caribbean [13] - 579:15, 643:12,
607:4, 608:19, 609:21, 616:8, 617:3,
broad [1] - 658:9
643:15, 682:2, 682:4, 682:5, 725:3,
619:25, 620:12, 623:15, 628:2, 631:2,
brochure [24] - 600:1, 600:16, 605:13,
725:5, 725:8, 783:20, 783:21, 793:4,
635:8, 636:1, 636:11, 636:24, 638:3,
608:20, 610:20, 611:18, 621:17,
795:5
640:15, 643:10, 643:21, 646:3, 646:9,
773:15, 787:22, 787:25, 788:4, 788:8,
carpeting [1] - 576:8
662:10, 663:8, 664:22, 666:18, 667:2,
788:19, 791:19, 792:8, 804:19, 834:15,
carr [1] - 716:15
668:12, 671:14, 671:24, 673:23,
839:14, 866:13, 874:13, 874:14,
carried [1] - 600:14
674:16, 675:1, 675:12, 676:10, 678:4,
874:17, 875:2, 875:7
carries [1] - 611:13
680:10, 680:20, 683:14, 686:3, 689:1,
brochures [27] - 596:24, 598:11,
carry [1] - 598:14
689:11, 689:22, 693:2, 693:21, 695:11,
599:4, 604:17, 681:3, 773:25, 774:14,
carrying [1] - 797:11
695:18, 697:13, 709:17, 713:14,
774:15, 788:10, 791:16, 794:10,
CAS [5] - 663:23, 666:14, 666:19,
714:13, 715:16, 718:23, 719:9, 720:13,
794:17, 797:20, 803:9, 803:11, 803:14,
667:4, 668:14
723:10, 723:13, 724:23, 726:8, 727:2,
803:18, 803:24, 804:2, 805:19, 809:9,
CASE [4] - 567:24, 630:22, 777:3,
730:3, 730:10, 731:22, 732:1, 732:18,
812:16, 834:3, 834:23, 839:23, 858:1
788:25
734:20, 735:1, 735:13, 735:18, 736:19,
broken [1] - 608:15
case [29] - 567:25, 573:8, 615:7,
743:17, 747:20, 748:2, 749:2, 749:22,
broker [17] - 626:2, 747:9, 748:4,
622:21, 628:11, 633:24, 634:7, 650:22,
750:8, 753:10, 755:23, 756:14, 757:4,
748:9, 749:4, 749:5, 749:7, 749:11,
651:4, 651:15, 652:2, 654:18, 655:2,
758:22, 759:14, 761:14, 767:4, 771:10,
749:13, 749:18, 750:11, 753:23,
656:10, 656:21, 656:24, 657:5, 657:23,
772:8, 772:16, 774:3, 774:9, 777:13,
753:24, 754:1, 768:22, 768:24, 770:6
657:24, 658:3, 661:10, 665:25, 674:18,
780:6, 781:9, 782:9, 789:1, 790:24,
brokerage [15] - 624:13, 624:14,
718:6, 777:4, 800:4, 803:17, 876:14,
797:13, 799:11, 800:12, 800:24,
624:20, 624:22, 624:24, 625:22,
886:12
801:13, 802:5, 804:17, 806:4, 806:23,
626:14, 627:2, 627:12, 627:16, 627:24,
cases [9] - 623:4, 629:24, 634:6,
807:12, 808:14, 810:4, 813:4, 813:18,
629:2, 681:21, 682:19, 759:25
634:9, 634:11, 634:15, 658:4, 679:19,
817:14, 818:9, 820:14, 823:7, 823:15,
brokers [2] - 757:13, 863:18
729:16
823:25, 824:19, 825:8, 828:5, 828:21,
brought [10] - 588:8, 588:12, 628:13,
cash [6] - 571:5, 586:15, 586:21,
831:6, 833:14, 834:2, 834:11, 835:4,
629:22, 646:25, 685:20, 692:10, 704:9,
607:12, 628:1, 726:21
836:23, 837:23, 838:6, 840:23, 844:18,
729:8, 778:10
cashier's [1] - 726:21
846:8, 848:9, 848:15, 850:8, 851:11,
budget [6] - 879:6, 879:20, 880:5,
categorized [3] - 655:10, 655:15,
851:16, 852:8, 852:22, 854:2, 854:15,
880:25, 883:23, 886:1
655:23
854:21, 855:1, 855:5, 855:16, 856:22,
budgets [1] - 878:23
category [5] - 658:10, 659:2, 659:11,
859:19, 861:4, 861:12, 862:13, 864:24,
build [2] - 601:18, 783:6
770:18, 770:19
865:4, 867:3, 868:2, 868:18, 870:18,
Building [1] - 576:7
caught [1] - 575:19
873:10, 875:14, 875:21, 876:13, 878:5,
building [9] - 582:22, 681:13, 782:13,
caused [1] - 813:20
879:13, 882:20, 883:8, 884:10, 884:14,
782:17, 786:14, 788:6, 789:3, 790:3,
cautioned [2] - 568:9, 777:10
885:19
792:9
CD [62] - 588:20, 589:18, 589:25,
buildings [1] - 835:25
590:1, 590:8, 590:9, 591:1, 591:5,
C
built [1] - 680:3
591:12, 592:2, 592:5, 592:9, 592:11,
bulk [1] - 612:1
592:21, 594:25, 607:6, 626:25, 627:4,
bullet [1] - 612:15
calculator [6] - 816:6, 816:8, 816:12,
628:4, 628:19, 628:20, 629:14, 631:4,
Bullion [1] - 682:10
816:15, 817:1
631:7, 631:14, 631:25, 632:8, 638:16,
bullion [1] - 682:21
calendar [1] - 644:10
641:2, 641:7, 679:15, 679:23, 680:4,
bunch [1] - 816:10
897
682:22, 685:4, 685:10, 689:24, 704:9,
619:20, 622:22, 623:19, 623:22, 625:1,
characterization [1] - 650:16
706:7, 707:10, 717:12, 717:15, 717:20,
626:21, 627:6, 627:7, 627:8, 627:10,
characterized [2] - 653:8, 655:22
717:23, 718:2, 718:9, 718:13, 720:2,
628:6, 637:8, 640:23, 642:17, 644:18,
charge [18] - 577:11, 593:15, 595:18,
720:15, 720:21, 742:7, 794:21, 794:22,
662:24, 663:2, 664:5, 667:16, 667:22,
596:5, 635:13, 711:2, 744:8, 746:23,
795:14, 796:9, 799:14, 800:14, 863:15,
667:24, 668:4, 668:15, 677:7, 677:14,
746:25, 748:6, 748:9, 748:10, 811:23,
870:24, 877:10, 886:10
677:16, 678:5, 678:11, 678:12, 678:21,
812:3, 812:6, 864:2, 869:9, 880:7
678:23, 682:15, 683:3, 683:5, 685:13,
CDs [47] - 588:23, 589:24, 590:9,
charged [5] - 602:24, 677:2, 711:3,
686:22, 686:25, 687:9, 690:5, 766:4,
613:12, 614:3, 628:9, 629:3, 629:6,
741:14, 742:12
766:5, 767:17, 767:21, 768:10, 769:5,
629:7, 629:9, 629:11, 685:3, 702:3,
charging [1] - 670:17
770:11, 770:20, 772:12, 773:6, 779:11,
702:10, 702:16, 702:17, 707:11,
chart [10] - 593:5, 609:19, 610:8,
784:13, 787:3, 793:9, 796:14, 802:15,
708:17, 716:22, 718:5, 719:6, 719:17,
642:3, 643:3, 680:7, 706:8, 864:21,
803:16, 803:17, 806:1, 809:17, 821:11,
719:19, 721:9, 722:2, 731:5, 760:11,
868:10, 868:14
822:3, 822:5, 822:10, 822:18
765:4, 765:10, 765:13, 765:21, 766:8,
chartered [6] - 611:9, 666:19, 731:14,
clients' [2] - 702:23, 807:5
766:11, 768:23, 793:14, 795:10, 797:3,
731:18, 731:19, 732:4
797:6, 798:9, 798:17, 798:21, 809:19,
clip [1] - 802:20
charts [1] - 641:18
845:6, 862:18, 862:24, 863:14, 886:22
clips [1] - 798:10
Chase [5] - 703:17, 703:19, 703:21,
Central [3] - 778:7, 795:3, 803:7
clock [7] - 562:4, 639:10, 649:25,
705:8, 718:13
cents [1] - 628:17
720:6, 888:5, 888:9
chase [1] - 562:17
CEO [1] - 749:17
close [3] - 807:21, 827:19, 847:7
chastise [1] - 575:20
ceremonies [1] - 629:22
closer [1] - 627:22
chastised [1] - 575:18
ceremony [1] - 776:1
clue [5] - 878:8, 880:10, 880:12,
chatted [1] - 857:10
certain [17] - 565:12, 565:15, 584:21,
880:13, 880:14
cheat [1] - 714:15
618:5, 619:19, 638:14, 647:23, 656:12,
co [3] - 588:24, 595:6, 826:17
check [11] - 565:5, 692:14, 741:17,
721:17, 722:12, 735:23, 737:15,
co-conspirator [1] - 826:17
763:8, 785:23, 786:1, 786:3, 850:23,
738:15, 752:25, 846:19, 866:5, 881:3
co-workers [2] - 588:24, 595:6
864:10
certainly [2] - 630:13, 739:11
coincided [1] - 736:25
checkbook [3] - 819:2, 858:10, 858:15
CERTIFICATE [1] - 889:1
coins [2] - 682:16, 682:20
checking [2] - 664:5, 817:1
certificate [11] - 583:25, 588:17, 589:7,
Coins [1] - 682:10
checks [2] - 571:6, 726:21
589:10, 605:14, 626:24, 716:24, 717:4,
cold [1] - 688:15
chicken [1] - 564:4
719:11, 722:18, 794:23
collapse [2] - 617:19, 762:24
chief [3] - 595:16, 596:4, 603:22
certificates [3] - 583:16, 589:5, 702:9
Collapse [1] - 618:14
children [3] - 568:19, 688:4, 690:6
certified [2] - 666:19, 885:2
collateral [1] - 592:4
chose [1] - 575:23
certify [1] - 889:3
collect [2] - 758:25, 759:2
chosen [1] - 602:5
CFO [3] - 595:14, 595:15, 749:3
collecting [2] - 585:9, 759:6
Chronicle [8] - 779:5, 779:8, 779:14,
Chairman [2] - 601:11, 669:5
college [1] - 781:5
779:15, 779:18, 780:9, 785:12, 785:20
chairman [9] - 577:6, 601:5, 602:12,
colony [1] - 611:9
circumstances [4] - 619:19, 665:17,
669:6, 669:9, 669:12, 813:8, 813:12,
color [1] - 643:17
686:18, 861:14
835:25
coloring [1] - 688:16
Citibank [1] - 592:24
challenge [1] - 686:12
Columbus [1] - 792:1
cities [2] - 787:20, 788:20
challenged [1] - 698:4
column [3] - 641:5, 641:6, 669:17
citizen [1] - 601:20
challenges [2] - 685:14, 686:7
combination [2] - 606:24, 607:1
citizens [4] - 580:7, 580:18, 849:1
challenging [1] - 657:17
comfort [2] - 592:19, 613:18
City [6] - 568:22, 619:23, 629:20,
Chambliess [28] - 567:21, 568:13,
comfortable [5] - 614:15, 686:8,
729:23, 730:4, 757:9
568:16, 569:7, 574:19, 578:21, 581:12,
766:6, 775:25, 776:17
city [3] - 792:8, 792:9, 836:4
582:17, 600:10, 615:23, 616:9, 631:3,
coming [16] - 562:12, 563:21, 564:6,
clarify [2] - 574:19, 585:25
635:9, 640:16, 662:11, 663:13, 671:16,
564:8, 567:16, 589:4, 638:1, 646:5,
clause [2] - 659:23, 659:24
675:13, 693:3, 715:21, 716:13, 722:3,
648:15, 655:24, 656:10, 658:22,
clear [12] - 598:25, 604:6, 606:10,
730:16, 741:9, 755:24, 761:15, 792:23,
659:18, 782:11, 806:16, 859:1
606:13, 606:17, 627:6, 631:5, 679:11,
796:20
commenced [1] - 748:4
739:9, 850:18, 879:23, 880:1
CHAMBLIESS [1] - 568:8
comment [4] - 615:12, 616:3, 686:6,
clearly [5] - 649:11, 739:5, 741:3,
chance [3] - 578:11, 685:21, 691:7
687:3
773:15, 870:5
change [15] - 580:17, 621:3, 621:7,
commercial [17] - 605:18, 606:3,
client [12] - 589:16, 592:1, 631:24,
621:9, 668:20, 684:7, 687:11, 696:18,
606:4, 606:6, 606:12, 607:2, 607:6,
668:24, 668:25, 669:1, 669:2, 726:16,
754:14, 754:16, 794:11, 808:4, 817:8,
611:24, 665:24, 674:11, 681:10,
727:9, 741:25, 768:8, 769:14
859:1, 859:7
681:15, 682:20, 705:1, 736:5, 736:10,
client's [4] - 603:7, 651:12, 655:1,
changed [13] - 597:9, 598:12, 612:12,
821:5
691:24
621:12, 747:4, 815:2, 815:7, 816:23,
Commission [1] - 622:13
clients [97] - 570:20, 570:21, 570:25,
817:9, 819:6, 819:10, 819:19, 859:8
commission [10] - 579:13, 629:10,
573:15, 573:19, 574:4, 574:7, 579:18,
changes [5] - 641:15, 754:11, 815:10,
631:8, 631:18, 632:1, 632:4, 714:23,
580:2, 580:23, 583:19, 583:22, 586:15,
815:23
753:12, 753:14, 768:22
589:2, 589:3, 590:5, 591:22, 592:19,
changing [7] - 636:19, 711:18, 815:15,
commissions [10] - 588:3, 628:8,
594:7, 598:14, 599:24, 600:14, 601:23,
816:4, 818:3, 845:25, 881:15
628:10, 629:6, 631:4, 753:21, 766:8,
604:22, 604:23, 609:4, 619:15, 619:18,
character [1] - 740:17
898
766:11, 768:24, 769:1
compare [4] - 584:10, 641:7, 785:12,
constantly [2] - 793:12, 794:12
commit [1] - 849:12
797:5
constitutes [1] - 776:16
commitment [7] - 602:6, 602:11,
compared [3] - 590:9, 612:5, 837:2
consult [1] - 761:7
609:4, 847:11, 847:14, 848:10, 849:4
compensated [1] - 796:24
contact [5] - 587:1, 596:8, 596:20,
committed [1] - 601:22
compete [3] - 592:23, 721:8, 721:10
622:21, 757:15
Committee [1] - 715:3
competitive [1] - 625:2
contacted [2] - 755:14, 755:19
committee [1] - 622:11
complaining [1] - 691:24
contacting [1] - 602:11
common [1] - 858:13
complete [1] - 753:7
contents [1] - 841:20
Commonwealth [1] - 576:12
completely [2] - 563:5, 847:16
continents [1] - 644:2
communicated [1] - 663:2
complexes [1] - 594:5
continue [7] - 611:5, 655:25, 656:1,
community [1] - 624:2
675:3, 759:2, 778:12, 855:24
complicated [1] - 747:4
Companies [3] - 747:8, 834:13, 834:16
Continued [2] - 561:1, 561:2
complied [1] - 563:3
companies [55] - 572:24, 573:16,
continued [2] - 602:9, 772:12
comply [3] - 563:5, 563:17, 666:10
575:14, 587:7, 587:9, 587:15, 593:2,
continues [1] - 616:5
composed [1] - 611:2
593:6, 594:14, 594:22, 595:20, 596:23,
continuing [3] - 608:9, 764:24, 815:1
compounded [1] - 605:20
597:4, 607:3, 607:7, 610:24, 610:25,
contract [4] - 609:11, 609:16, 617:13,
computer [5] - 561:13, 561:19, 806:12,
621:12, 621:13, 621:14, 622:1, 679:12,
628:12
816:17, 856:13
679:18, 680:8, 680:13, 680:21, 680:22,
contracted [2] - 663:16, 702:11
computer-assisted [2] - 561:13,
682:21, 688:12, 696:18, 698:3, 698:17,
contractors [1] - 752:7
561:19
705:8, 729:18, 736:2, 750:16, 755:4,
computers [5] - 576:9, 791:2, 791:4,
contracts [1] - 721:18
769:16, 771:6, 784:2, 784:11, 784:12,
791:13, 867:12
contractually [1] - 717:22
786:15, 786:20, 811:25, 829:21,
concentrated [2] - 612:7, 643:24
contrary [1] - 596:17
835:14, 848:19, 861:21, 862:1, 869:3,
concept [1] - 585:16
contributed [1] - 592:19
869:16, 879:6, 879:15, 881:10
concern [7] - 613:15, 613:16, 614:1,
control [3] - 627:16, 627:24, 821:15
companies' [1] - 682:15
667:16, 829:12, 855:17, 855:22
convenience [1] - 620:19
Company [18] - 593:11, 594:20,
concerned [8] - 613:24, 614:4, 642:10,
conversation [3] - 785:5, 790:12,
624:10, 624:12, 625:3, 625:9, 625:22,
661:13, 672:25, 762:16, 773:6, 773:7
860:1
626:6, 626:15, 628:3, 629:2, 680:12,
concerning [2] - 689:5, 844:8
conversations [2] - 587:24, 640:23
680:23, 681:7, 681:21, 871:8, 871:9,
concerns [4] - 604:14, 667:18, 813:21,
convey [1] - 599:23
871:11
855:8
convince [1] - 851:2
company [142] - 568:21, 573:12,
conclusion [2] - 666:4, 718:16
convoluted [1] - 747:5
574:20, 574:24, 591:16, 593:13,
condition [1] - 644:11
cool [2] - 685:24, 725:18
593:14, 594:10, 596:14, 596:20,
conditions [2] - 672:12, 676:8
copies [2] - 651:16, 662:22
596:24, 602:24, 605:5, 609:14, 616:11,
conduct [2] - 655:16, 739:19
copy [9] - 614:23, 619:17, 634:2,
616:17, 617:6, 617:16, 617:20, 618:11,
conducted [2] - 665:10, 665:19
634:4, 639:7, 671:19, 715:12, 788:2,
618:16, 618:21, 620:2, 621:15, 621:20,
confer [1] - 639:10
879:9
621:22, 621:24, 624:9, 624:16, 626:14,
conference [1] - 562:9
corner [4] - 576:20, 619:8, 641:20,
626:18, 642:20, 644:10, 663:15,
conferring [4] - 715:11, 801:12,
643:3
663:17, 668:16, 682:18, 682:21,
875:20, 879:12
corporate [3] - 761:16, 761:23, 769:17
695:12, 695:23, 696:4, 696:12, 696:21,
confident [1] - 853:10
Corporation [2] - 594:9, 594:21
697:15, 697:23, 700:1, 702:15, 702:16,
confirmed [1] - 608:6
corporation [5] - 603:2, 724:3, 724:4,
702:22, 703:2, 703:6, 707:18, 709:3,
conflicting [1] - 733:18
726:15, 727:8
710:3, 710:15, 710:21, 711:5, 716:1,
confrontation [4] - 659:23, 826:21,
Corporation's [1] - 672:5
717:11, 728:1, 728:5, 728:6, 728:7,
842:2
correct [122] - 564:21, 566:7, 576:1,
728:9, 728:14, 729:3, 729:6, 729:8,
confusing [2] - 639:20, 740:5
576:4,
591:10, 599:18, 599:19, 602:25,
730:19, 730:22, 749:23, 750:12,
645:14, 645:15, 649:2, 650:17, 695:15,
Congress
[1] - 560:22
752:21, 752:25, 753:1, 754:3, 758:15,
695:23, 698:12, 698:19, 701:5, 701:12,
connected [2] - 742:4, 762:12
762:4, 762:19, 762:25, 763:6, 763:9,
701:17, 702:3, 702:18, 703:15, 703:22,
connection
[1] - 590:13
763:11, 768:16, 769:13, 770:12,
703:25, 704:8, 704:10, 704:12, 707:2,
connotation
[1]
733:23
770:25, 771:18, 771:19, 772:24,
707:5, 707:8, 708:4, 708:8, 708:18,
consequences
[2]
752:16,
752:24
780:13, 781:16, 783:23, 783:24, 784:1,
709:1, 709:2, 709:3, 709:4, 710:13,
conservative
[4]
585:14,
591:15,
784:6, 784:16, 784:17, 786:2, 786:9,
710:14, 710:17, 710:25, 712:16,
611:4, 705:22
786:22, 786:25, 787:2, 787:9, 792:15,
716:25, 717:5, 717:7, 717:9, 717:18,
consider [4] - 608:16, 616:5, 661:17,
806:6, 814:24, 825:3, 825:25, 829:22,
717:19, 717:21, 717:23, 718:3, 721:10,
772:19
829:24, 830:2, 830:8, 830:16, 832:11,
723:23, 723:25, 724:1, 724:9, 724:10,
considerably [1] - 611:23
838:25, 849:17, 850:4, 850:9, 850:10,
724:13, 724:14, 725:11, 725:12,
consideration [1] - 617:15
862:5, 862:17, 862:23, 863:14, 863:16,
727:16, 727:20, 729:4, 729:8, 731:15,
considered
[1]
609:7
863:17, 864:13, 869:12, 869:22,
732:20, 732:23, 735:20, 735:25, 736:3,
consistent [8] - 567:7, 602:13, 609:1,
874:15, 877:23, 878:1, 878:6, 878:13,
738:23, 742:21, 744:7, 744:14, 745:24,
609:25, 610:9, 772:10, 805:1, 838:9
878:14, 883:17, 885:23
746:3, 746:5, 746:24, 747:5, 747:9,
consistently [1] - 665:18
company's [4] - 574:22, 665:3, 666:8,
748:4, 748:7, 748:9, 748:18, 750:21,
conspirator [1] - 826:17
666:12
754:1, 754:9, 754:12, 769:8, 775:7,
constant [1] - 750:10
Company's [1] - 593:23
899
789:3, 805:16, 816:22, 818:11, 825:2,
848:5
709:16, 713:8, 714:10, 718:21, 719:7,
825:9, 828:10, 828:23, 834:6, 840:6,
720:5, 722:22, 723:3, 723:5, 723:8,
course [9] - 632:7, 637:10, 648:7,
856:15, 857:13, 865:14, 869:23,
724:22, 725:19, 725:22, 725:24, 726:1,
648:24, 649:11, 672:11, 676:7, 824:4,
869:24, 869:25, 870:6, 870:19, 880:8,
730:2, 730:7, 730:9, 731:24, 734:15,
863:10
880:15, 880:17, 883:21, 885:24, 886:4,
734:19, 734:25, 735:3, 735:5, 735:10,
Court [29] - 561:10, 563:14, 563:15,
886:5, 886:8, 886:9, 886:11, 886:14,
735:16, 736:15, 737:20, 737:22,
566:21, 566:23, 567:1, 568:1, 606:17,
889:4
737:24, 738:6, 738:9, 739:2, 739:8,
607:17, 616:2, 633:22, 633:23, 634:8,
739:14, 739:17, 739:21, 739:25, 740:3,
corrected [3] - 634:18, 698:10, 817:10
634:15, 635:18, 637:22, 650:16,
740:8, 740:14, 740:20, 741:1, 741:5,
correctly [1] - 816:19
650:22, 650:25, 651:17, 652:4, 656:14,
741:15, 741:23, 742:9, 742:20, 742:23,
658:4, 658:5, 660:7, 735:16, 777:5,
correspondent [5] - 586:25, 618:3,
743:1, 743:3, 743:6, 743:14, 747:11,
843:12
705:2, 705:3, 705:5
747:14, 747:16, 747:19, 747:23,
court [16] - 646:24, 646:25, 647:1,
corresponding [1] - 792:3
748:23, 749:1, 749:21, 749:25, 750:2,
658:8, 660:1, 660:11, 675:23, 710:9,
Costa [1] - 560:13
750:5, 753:6, 755:22, 756:13, 758:19,
720:2, 739:4, 770:3, 775:16, 776:4,
COSTA [161] - 562:6, 562:8, 563:6,
759:10, 759:12, 761:6, 761:9, 767:1,
776:11, 777:21
563:9, 564:9, 564:13, 564:23, 565:1,
770:17, 770:21, 771:1, 771:3, 771:8,
COURT [457] - 560:1, 562:2, 562:7,
651:9, 651:21, 652:21, 653:12, 654:2,
771:23, 771:25, 772:3, 772:6, 774:5,
563:1, 563:4, 563:8, 563:13, 564:2,
654:18, 654:21, 657:13, 657:15,
774:7, 774:24, 775:3, 775:10, 775:12,
564:7, 564:12, 564:21, 565:9, 566:1,
657:20, 660:15, 661:2, 661:4, 686:1,
775:17, 777:2, 777:8, 780:5, 781:8,
566:6, 566:8, 566:13, 566:15, 566:20,
691:3, 740:18, 776:25, 777:13, 780:3,
790:16, 797:10, 798:18, 798:24, 799:3,
567:3, 567:9, 567:15, 567:22, 568:4,
780:6, 781:9, 782:7, 782:9, 788:22,
799:6, 800:11, 800:20, 800:23, 801:23,
568:24, 569:1, 569:5, 570:1, 570:3,
789:1, 790:17, 790:24, 797:13, 798:16,
804:12, 804:16, 805:23, 806:2, 806:9,
571:16, 572:8, 573:4, 573:7, 573:10,
798:20, 798:25, 799:5, 799:11, 800:12,
806:11, 806:13, 806:16, 806:20,
574:13, 576:16, 577:21, 577:24, 578:8,
800:24, 801:13, 801:21, 802:5, 804:8,
806:22, 808:13, 824:15, 824:17, 825:5,
578:15, 578:19, 578:25, 579:5, 579:9,
804:13, 804:17, 805:24, 806:4, 806:7,
826:7, 826:11, 826:14, 826:19, 826:22,
579:23, 582:14, 584:2, 584:7, 586:1,
806:10, 806:12, 806:14, 806:19,
826:24, 827:4, 827:7, 827:15, 827:24,
586:6, 598:15, 598:19, 598:21, 598:23,
806:21, 806:23, 807:10, 807:12,
828:3, 828:20, 831:3, 832:22, 832:25,
600:2, 600:5, 600:7, 606:23, 607:19,
808:14, 810:2, 810:4, 813:3, 813:4,
833:3, 833:6, 833:9, 833:12, 834:5,
607:22,
607:25,
608:4,
608:8,
608:12,
813:17, 813:18, 817:12, 817:14, 818:5,
834:8, 836:18, 836:22, 837:22, 838:4,
608:15, 614:25, 615:3, 615:8, 615:11,
818:9, 820:12, 820:14, 823:5, 823:7,
840:21, 842:3, 842:7, 842:12, 842:17,
615:13, 615:15, 615:18, 615:20,
823:13, 823:15, 823:23, 823:25,
842:24, 843:5, 843:9, 843:14, 843:17,
615:25,
616:4,
616:23,
617:1,
619:21,
824:19, 825:8, 826:8, 826:15, 827:1,
843:20, 843:23, 844:4, 844:11, 844:15,
623:12, 623:14, 627:18, 627:21, 630:3,
827:3, 828:2, 828:4, 828:5, 828:21,
847:18, 847:22, 848:3, 848:6, 848:8,
630:19, 630:24, 632:18, 633:3, 633:6,
831:6, 832:23, 833:8, 833:10, 833:13,
848:14, 850:5, 850:7, 851:8, 851:15,
633:10, 633:14, 633:19, 634:1, 634:6,
833:14, 834:1, 834:2, 834:7, 834:9,
852:3, 852:5, 852:13, 852:18, 853:22,
634:10, 634:12, 634:15, 634:17, 635:2,
834:11, 835:3, 835:4, 836:23, 837:21,
854:1, 854:9, 854:11, 854:13, 854:20,
635:6, 635:12, 635:16, 635:21, 635:23,
837:23, 838:6, 840:23, 841:24, 842:5,
855:11, 855:21, 856:3, 856:9, 856:12,
636:10, 636:13, 636:15, 637:16,
842:8, 842:15, 842:18, 843:1, 843:15,
856:15, 856:18, 856:20, 859:18, 860:4,
637:21, 637:24, 638:5, 638:8, 638:12,
843:19, 843:21, 843:24, 844:12,
860:7, 860:10, 860:14, 860:16, 860:19,
639:1, 639:3, 639:5, 639:7, 639:9,
844:18, 846:6, 846:8, 847:19, 847:23,
861:1, 861:9, 862:7, 862:10, 862:12,
639:16, 639:22, 640:3, 640:10, 643:7,
848:4, 848:9, 848:15, 850:8, 851:11,
864:20, 865:2, 867:2, 868:1, 870:17,
643:16, 643:20, 645:21, 645:23, 646:6,
851:16, 852:8, 852:16, 852:22, 853:23,
873:7, 873:9, 876:7, 876:10, 876:12,
646:8, 646:20, 647:4, 647:9, 647:12,
854:2, 854:15, 854:21, 855:1, 855:3,
882:14, 882:18, 883:1, 883:4, 883:7,
647:17, 647:24, 648:1, 648:4, 648:8,
855:5, 855:16, 856:1, 859:15, 860:3,
884:6, 884:9, 884:12, 885:13, 885:17,
648:17, 648:19, 649:1, 649:8, 649:13,
860:20, 860:24, 861:10, 866:21,
887:5, 887:8, 887:11, 887:15, 887:17,
649:16, 649:24, 650:4, 650:18, 651:1,
866:24, 867:25, 868:13, 870:10,
887:20, 887:23, 888:2, 889:1
651:8, 651:20, 652:7, 652:24, 653:3,
870:15, 875:19, 876:9, 879:9, 882:12,
Court's [3] - 563:17, 654:23, 742:17
653:8, 653:13, 653:16, 653:24, 654:3,
883:2, 883:5, 884:4, 884:7, 887:3
courtesy [1] - 688:10
654:7, 654:12, 654:22, 655:4, 655:9,
Counsel [9] - 615:4, 615:8, 634:19,
courthouse [1] - 775:23
655:11, 655:13, 656:1, 656:20, 657:6,
636:13, 649:14, 661:5, 723:9, 749:21,
courtroom [5] - 572:1, 630:12, 690:16,
657:9, 657:12, 657:14, 657:19, 657:22,
861:2
658:25, 659:4, 659:8, 659:20, 660:10,
694:20, 779:23
counsel [4] - 729:25, 731:20, 738:3,
660:14, 660:20, 661:3, 661:5, 661:7,
courts [1] - 658:4
776:23
662:3, 662:6, 663:4, 664:10, 664:13,
cover [4] - 618:2, 727:4, 727:7, 875:12
counsel's [1] - 616:3
668:1, 668:8, 671:4, 671:7, 671:10,
coverage [6] - 611:8, 611:10, 611:14,
Counselor [1] - 664:14
671:13, 673:6, 673:11, 673:16, 673:20,
614:14, 730:14
counsels [1] - 639:11
674:13, 674:22, 674:25, 675:20,
covered [3] - 581:22, 640:18, 677:17
count [1] - 574:12
675:22, 676:1, 677:20, 677:23, 678:2,
covering [2] - 611:12, 764:2
counter [1] - 576:18
685:17, 688:19, 688:25, 689:10,
CPA [1] - 731:19
countries [8] - 581:1, 643:11, 793:13,
689:20, 690:10, 690:23, 691:10,
create [19] - 602:3, 719:19, 720:1,
795:4, 799:21, 802:23, 802:25, 803:4
691:15, 691:18, 691:20, 692:12,
781:22, 784:2, 787:22, 811:7, 811:9,
country [2] - 581:9, 643:3
692:16, 692:19, 692:22, 692:25,
822:25, 823:2, 823:11, 824:23, 825:3,
couple [13] - 570:7, 667:10, 677:8,
693:18, 694:18, 695:2, 695:5, 695:10,
825:17, 825:25, 826:10, 828:7, 829:1
677:11, 678:13, 679:25, 684:14,
695:16, 696:23, 697:4, 697:7, 709:14,
created [27] - 699:1, 699:11, 699:12,
744:20, 757:9, 785:25, 791:2, 795:17,
900
699:17, 699:24, 700:14, 700:16,
700:17, 700:18, 700:22, 701:12,
702:22, 721:6, 798:14, 798:15, 810:20,
823:8, 862:1, 868:20, 875:2, 883:17,
885:24, 886:3, 886:4
creating [2] - 720:15, 804:2
credentials [1] - 885:21
credibility [3] - 738:15, 739:20, 742:11
Credit [2] - 587:8, 592:24
credit [6] - 571:4, 672:1, 672:9, 676:6,
681:19, 804:25
cried [1] - 688:21
critical [1] - 609:3
cross [8] - 566:12, 566:17, 567:1,
640:4, 692:23, 776:5, 844:13, 884:9
CROSS [2] - 693:1, 856:21
cross-examination [6] - 566:12,
566:17, 640:4, 692:23, 844:13, 884:9
CROSS-EXAMINATION [2] - 693:1,
856:21
cross-examine [1] - 776:5
crown [1] - 611:9
CRR [3] - 561:10, 561:16, 889:7
crude [1] - 861:17
cruise [3] - 677:11, 677:12, 678:13
crunch [1] - 881:3
curious [2] - 700:1, 713:4
currencies [1] - 706:6
currency [19] - 605:19, 607:14,
607:15, 607:16, 618:4, 641:24, 704:12,
704:16, 704:17, 705:15, 705:16,
705:20, 705:21, 705:23, 706:4, 706:7,
805:7, 805:8
currency-type [2] - 705:20, 705:21
current [2] - 606:1, 831:17
custodian [1] - 843:23
customer [7] - 573:18, 580:5, 581:6,
581:25, 609:2, 609:8, 771:20
customers [8] - 580:19, 582:8, 613:13,
613:21, 624:4, 722:6, 847:1, 847:6
Customs [2] - 741:19, 742:1
customs [1] - 738:13
cut [4] - 562:17, 607:2, 742:17, 772:3
cutting [1] - 688:11
760:22, 811:15, 811:18, 811:23, 812:3,

dependent [1] - 688:5
815:13, 815:19, 815:21, 816:2, 816:3,
deposit [22] - 583:25, 585:3, 588:17,
816:25, 818:2, 821:22, 823:4, 824:23,
589:5, 589:7, 589:8, 589:10, 589:15,
825:16, 825:24, 826:9, 826:18, 828:6,
592:2, 605:15, 605:21, 605:22, 607:12,
828:25, 830:1, 830:20, 831:24, 858:18,
611:8, 626:24, 686:25, 716:24, 717:4,
858:22, 869:6
719:11, 722:18, 799:14, 802:2
Davis's [2] - 744:15, 825:13
deposited [2] - 592:10, 800:1
day-to-day [8] - 577:8, 586:23, 587:13,
depositing [2] - 686:8, 727:18
591:4, 591:7, 597:22, 598:1, 710:21
depositor [12] - 581:6, 581:19, 612:10,
days [14] - 586:20, 589:20, 606:7,
617:21, 717:17, 726:16, 726:24, 727:9,
624:23, 625:14, 691:5, 785:25, 799:14,
727:18, 763:1, 771:11, 771:14
819:7, 840:4, 858:22, 864:8
depositors [17] - 585:6, 589:13, 599:4,
DC [1] - 560:18
603:1, 612:2, 614:14, 617:7, 717:20,
dead [1] - 630:13
721:16, 761:25, 762:18, 763:5, 765:15,
dead-ends [1] - 630:13
766:22, 771:6, 804:9
deadline [2] - 565:15, 651:16
depositors' [2] - 805:5, 805:6
deadlines [1] - 565:15
deposits [23] - 581:16, 584:23, 595:2,
605:17, 605:18, 605:19, 607:8, 607:10,
deal [3] - 610:6, 637:14, 769:13
607:14, 607:15, 609:19, 609:20,
dealer [12] - 747:9, 748:4, 748:9,
609:23, 611:13, 618:2, 618:4, 618:25,
749:4, 749:5, 749:7, 749:11, 749:13,
701:23, 763:7, 794:23, 820:8, 820:9
749:18, 750:11, 768:22, 770:6
deposits/withdrawal [1] - 583:15
dealers [4] - 753:23, 753:24, 754:1,
depression [1] - 581:15
768:24
derogatory [1] - 748:14
dealing [2] - 573:14, 762:1
describe [2] - 596:16, 780:1
debit [1] - 571:5
described [5] - 605:5, 665:3, 689:7,
December [5] - 666:9, 672:1, 672:4,
702:3, 772:11
675:16, 676:3
describing [1] - 766:1
decide [4] - 565:18, 638:14, 653:4,
description [5] - 602:13, 603:3,
685:23
604:14, 641:12, 641:15
decided [5] - 602:2, 759:18, 835:12,
design/architecture [2] - 778:16,
836:24, 836:25
857:16
decision [1] - 688:11
designated [1] - 565:14
decisions [2] - 710:25, 881:20
designed [1] - 575:22
declaration [1] - 617:12
designer [1] - 779:9
declarations [1] - 734:5
desire [1] - 808:23
declaring [1] - 733:24
desk [3] - 569:9, 597:2, 645:9
dedicated [1] - 573:14
destroyed [2] - 876:16, 877:1
deemed [1] - 617:13
detail [3] - 599:22, 714:4, 791:14
defend [1] - 657:20
detailed [1] - 765:25
DEFENDANT [2] - 560:20, 561:2
details [2] - 713:13, 851:20
defendant [4] - 573:7, 637:20, 738:5,
determine [1] - 773:9
780:4
defendant's [1] - 668:5
determined [1] - 886:19
defense [6] - 562:9, 567:11, 636:17,
development [3] - 678:23, 682:18,
656:25, 842:13, 842:14
786:22
define [1] - 627:25
Development [19] - 572:23, 593:11,
D
593:23, 593:25, 594:1, 594:9, 594:20,
Definitions [2] - 726:5, 726:19
594:21, 595:1, 672:5, 680:11, 680:23,
degree [5] - 570:6, 603:25, 781:5,
daily [2] - 596:21, 605:20
699:13, 700:8, 786:24, 871:8, 871:9,
857:15, 857:18
Dallas [2] - 836:7, 836:8
871:11
degrees [1] - 744:15
damaged [1] - 712:9
diagnosed [1] - 569:13
delayed [1] - 645:9
dark [1] - 780:2
diagram [1] - 861:17
deliberate [1] - 638:13
date [9] - 565:12, 619:9, 629:23,
diagrams [1] - 761:21
delivering [1] - 601:18
737:12, 823:14, 876:7, 876:8, 877:5,
differ [3] - 589:11, 629:7, 681:14
demanding [1] - 602:6
877:8
differed [1] - 765:7
demeanor [1] - 832:19
dated [1] - 822:6
difference [7] - 620:5, 690:14, 732:10,
demonstrative [4] - 574:9, 574:16,
DAVID [1] - 560:10
767:22, 767:23, 768:19, 796:7
680:7, 680:18
davis [1] - 869:9
differences [2] - 732:12, 767:14
denied [1] - 567:3
Davis [50] - 595:11, 595:13, 595:14,
different [31] - 572:24, 588:1, 626:15,
department [6] - 601:25, 642:23,
595:21, 595:24, 596:4, 596:10, 616:16,
626:18, 639:14, 643:25, 644:1, 644:2,
687:20, 713:13, 721:7
616:18, 644:5, 710:19, 743:18, 743:24,
656:21, 661:20, 666:1, 706:6, 706:7,
Department [1] - 560:17
744:2, 744:13, 745:5, 746:19, 746:20,
761:24, 763:15, 786:13, 787:24,
departments [1] - 642:22
746:23, 750:16, 752:9, 752:10, 752:12,
901
788:19, 793:13, 815:23, 815:24,
822:21, 853:8, 859:10, 859:13, 870:7,
870:8, 882:18
differently [4] - 688:14, 766:23,
870:20, 870:21
difficult [1] - 686:25
difficulties [1] - 574:19
Digest [1] - 798:2
digest [1] - 640:22
direct [14] - 566:25, 694:2, 696:11,
714:6, 730:23, 738:14, 745:24, 750:10,
755:25, 763:2, 771:20, 799:12, 804:19,
857:12
DIRECT [2] - 568:11, 777:12
directed [1] - 738:17
direction [1] - 836:5
directly [10] - 598:5, 665:9, 666:14,
677:4, 717:24, 718:4, 718:5, 724:2,
727:14, 753:1
director [3] - 672:2, 675:17, 748:3
directors [15] - 602:19, 602:22,
602:23, 603:7, 603:13, 604:1, 665:2,
665:4, 665:15, 666:2, 807:2, 807:5,
807:13, 807:16, 808:1
Directors [2] - 671:21, 675:10
directs [1] - 604:3
disagree [1] - 706:8
disclose [3] - 641:14, 691:5, 767:17
disclosed [6] - 665:18, 670:8, 670:25,
763:22, 764:23, 767:24
disclosing [4] - 642:8, 764:19, 766:22,
767:21
disclosure [10] - 672:19, 676:18,
676:19, 721:20, 721:23, 721:25, 722:8,
764:3, 764:7, 764:15
disclosures [3] - 665:13, 764:17,
765:13
disconcerting [2] - 759:9, 759:15
discount [1] - 635:14
discovering [1] - 792:1
discretion [1] - 742:17
discuss [32] - 574:9, 585:7, 587:25,
590:14, 592:16, 593:1, 593:13, 597:15,
599:20, 604:5, 604:13, 612:14, 614:1,
619:14, 622:6, 622:25, 623:18, 624:19,
629:13, 644:21, 667:18, 672:19, 678:5,
679:11, 684:17, 684:21, 685:6, 762:3,
785:1, 789:6, 793:6, 802:22
discussed [17] - 573:2, 593:7, 664:4,
672:21, 678:20, 681:22, 690:25,
691:11, 764:8, 789:8, 802:25, 815:25,
825:20, 833:23, 839:8, 858:22, 879:5
discussing [3] - 631:3, 762:18, 858:18
discussion [3] - 567:13, 674:3, 765:9
discussions [1] - 679:10
dishonest [1] - 713:23
dismissed [1] - 691:23
display [1] - 782:7
displayed [2] - 575:6, 575:8
disregard [1] - 616:3
distributed [1] - 637:8
distributing [1] - 862:18
DISTRICT [3] - 560:1, 560:1, 560:10

drew [2] - 761:21, 861:17
diverse [2] - 581:1, 601:22
drive [1] - 687:3
diversified [2] - 643:22, 644:1
drying [1] - 700:16
divided [1] - 612:21
duck [1] - 693:22
dividend [3] - 611:25, 612:16, 613:2
due [6] - 617:19, 672:4, 726:18,
760:11, 762:23, 831:1
dividends [5] - 591:17, 612:14, 613:3,
duly [2] - 568:9, 777:10
613:4, 613:7
Division [1] - 608:22
dump [1] - 653:9
DIVISION [1] - 560:2
during [25] - 581:14, 594:2, 617:18,
661:25, 662:1, 666:13, 666:23, 676:3,
division [4] - 583:11, 608:25, 609:6,
676:5, 685:8, 685:20, 692:13, 694:2,
609:15
700:14, 760:12, 766:15, 787:10, 795:2,
dock [1] - 678:16
799:17, 807:17, 812:13, 824:4, 825:11,
doctor's [2] - 569:9, 569:17
854:23, 865:8
doctors [1] - 581:2
duties [3] - 573:17, 649:11, 872:1
document [43] - 600:10, 601:10,
601:13, 601:15, 615:6, 616:10, 616:14,
619:2, 619:9, 619:18, 620:10, 630:2,
E
633:2, 640:12, 641:11, 641:19, 642:4,
642:5, 642:6, 643:1, 644:7, 650:10,
e-mail [2] - 636:2, 636:5
653:9, 653:25, 654:1, 657:2, 657:24,
e-mails [4] - 634:22, 635:9, 635:10,
659:11, 660:25, 664:17, 722:7, 727:10,
637:14
762:10, 788:22, 822:25, 823:3, 823:8,
eagle [6] - 575:8, 582:25, 583:6,
823:16, 824:1, 829:15, 844:14, 846:9,
600:18,
600:22, 601:7
877:19
earliest [2] - 743:19, 744:1
documents [29] - 565:2, 565:3,
early [3] - 602:2, 840:15, 840:24
583:16, 634:22, 634:25, 640:20, 645:3,
earnings [7] - 584:25, 585:5, 590:21,
648:2, 648:15, 649:10, 653:20, 656:13,
590:24, 609:3, 613:4, 670:13
657:17, 659:2, 659:14, 659:15, 659:17,
easel [1] - 696:25
663:1, 674:22, 721:17, 722:6, 722:11,
easily [10] - 585:14, 585:15, 589:16,
723:16, 773:23, 774:4, 774:10, 776:10,
591:15, 628:1, 642:14, 642:15, 719:14,
830:17
719:16, 816:18
dollar [15] - 588:14, 588:15, 592:9,
east [2] - 836:7, 836:8
610:12, 610:13, 628:19, 628:20, 631:7,
easy [1] - 817:4
631:14, 632:8, 684:8, 705:16, 799:24,
economic [1] - 640:25
820:24
Ecuador [2] - 803:1, 803:6
dollars [11] - 581:17, 588:12, 592:11,
educated [1] - 581:3
592:12, 607:10, 628:1, 628:17, 631:16,
education [1] - 871:17
631:17, 724:8, 766:21
educational [2] - 569:23, 780:23
domestic [1] - 626:22
effect [4] - 567:5, 630:9, 658:9, 799:6
done [14] - 563:22, 564:3, 610:19,
effort [2] - 563:21, 563:23
715:19, 753:17, 788:11, 792:11, 793:3,
egg [1] - 564:4
793:4, 805:6, 806:17, 812:16, 817:7,
eight [3] - 564:12, 709:5, 709:25
831:19
eighth [2] - 703:7, 703:8
Donnis [1] - 713:15
either [9] - 639:23, 644:10, 658:14,
Dora [1] - 713:15
680:22, 697:25, 699:4, 706:1, 782:10,
dotted [1] - 802:13
837:11
double [2] - 709:20, 814:10
El [7] - 778:7, 778:11, 789:9, 789:10,
doubt [5] - 638:19, 639:25, 697:9,
789:14, 791:20, 853:14
704:2, 714:25
elapsed [1] - 888:10
down [54] - 573:19, 582:9, 583:7,
elect [1] - 640:4
587:2, 600:13, 608:15, 620:10, 628:22,
electricity [1] - 791:7
630:11, 630:12, 630:14, 634:25,
electronic [1] - 726:22
659:21, 661:24, 666:15, 667:1, 669:15,
Ellen [6] - 630:21, 692:14, 697:1,
673:20, 675:20, 675:24, 677:9, 677:14,
677:16, 678:1, 678:3, 678:23, 679:25,
697:9, 788:23, 806:16
681:13, 692:20, 695:8, 695:9, 714:10,
ELMO [2] - 864:19, 867:1
726:4, 736:15, 740:4, 741:1, 749:21,
Elsie [3] - 687:13, 792:23, 796:20
770:18, 774:8, 776:13, 782:11, 789:24,
embezzlement [1] - 611:15
789:25, 791:9, 792:4, 800:5, 806:11,
emphasized [1] - 689:16
818:5, 843:6, 843:13, 844:9, 884:13
employed [5] - 741:20, 766:14,
drafts [2] - 599:16, 599:17
797:15, 879:14, 879:17
Drake [1] - 854:18
employee [6] - 575:3, 625:8, 663:15,
draw [2] - 694:14, 760:6
703:7,
703:8, 790:20
902
679:15, 679:22, 699:10, 699:17,
661:17, 680:7, 680:16, 680:19, 708:6,
employees [17] - 575:14, 582:8, 583:9,
699:24, 700:6, 700:8, 700:15, 700:25,
708:7, 842:22, 866:19, 870:2
585:4, 587:13, 667:10, 699:21, 699:22,
701:1, 701:14, 701:15, 871:5
744:19, 744:22, 790:9, 790:13, 791:13,
Exhibit [19] - 577:17, 600:1, 614:21,
Estate [1] - 707:13
812:24, 819:17, 832:2, 845:10
632:13, 663:9, 664:11, 671:3, 683:6,
683:24, 725:14, 725:17, 762:8, 798:5,
employees' [1] - 719:17
estimate [1] - 787:7
810:2, 810:6, 841:20, 864:15, 866:8,
employment [4] - 745:20, 746:13,
estimated [1] - 776:19
868:4
780:11, 847:21
estimates [1] - 665:14
Exhibits [3] - 582:13, 646:15, 763:25
empty [1] - 790:3
Etheridge [2] - 792:23, 796:20
exhibits [37] - 562:10, 562:13, 562:21,
emulates [1] - 788:13
ethically [1] - 656:9
563:6, 563:19, 565:12, 565:14, 565:19,
enabled [1] - 601:17
ethics [4] - 652:12, 656:3, 656:5,
577:22, 633:11, 636:17, 636:20,
encouraged [1] - 855:12
657:16
647:13, 650:7, 650:23, 650:24, 651:15,
end [29] - 661:11, 672:3, 683:22,
Ethridge [1] - 716:18
651:16, 652:19, 653:12, 653:13,
684:10, 691:8, 745:4, 745:9, 745:12,
Eurodollar [3] - 605:18, 607:8, 618:4
654:14, 654:16, 654:17, 654:25, 655:2,
746:5, 746:9, 749:15, 749:16, 773:5,
Eurodollars [1] - 607:9
655:12, 655:14, 656:23, 657:7, 657:10,
810:17, 833:3, 833:6, 845:14, 845:15,
European [1] - 803:3
661:11, 691:1, 691:6, 691:12, 691:18,
845:17, 847:10, 847:20, 849:14, 852:7,
event [2] - 711:17, 883:3
799:8
852:9, 852:24, 853:2, 853:7, 853:12,
events [1] - 883:6
exist [3] - 698:22, 698:23, 699:1
854:23
eventually [5] - 592:23, 621:7, 625:8,
existed [3] - 699:3, 824:5, 824:7
ended [1] - 666:10
626:23, 684:20
existence [3] - 604:15, 721:5, 837:14
ends [2] - 630:13, 650:20
evidence [29] - 578:9, 633:16, 638:15,
existing [1] - 728:7
England [2] - 616:13, 762:12
647:21, 647:22, 649:21, 651:23, 652:5,
exists [3] - 617:21, 726:25, 763:1
English [9] - 571:1, 598:13, 598:17,
656:10, 660:4, 660:5, 665:12, 715:15,
expanding [1] - 802:22
599:11, 754:20, 778:18, 778:20,
740:17, 782:8, 787:25, 799:8, 810:3,
expect [1] - 656:14
778:21, 784:19
811:3, 820:10, 823:6, 843:6, 843:12,
expected [4] - 686:20, 687:13, 687:16
enjoy [4] - 602:10, 801:15, 802:1,
843:13, 843:15, 860:21, 860:24, 868:14
expense [1] - 814:2
802:3
Evidence [1] - 660:13
expenses [7] - 669:22, 813:25, 814:5,
enjoyed [1] - 678:14
ex [1] - 684:20
814:9, 814:16, 814:22, 814:23
enlarge [2] - 601:12, 675:9
ex-husband [1] - 684:20
expensive [3] - 614:10, 788:13, 788:15
ensure [2] - 603:9, 603:16
exact [3] - 743:9, 786:5, 801:24
experience [13] - 569:10, 569:19,
ensures [1] - 807:7
exactly [14] - 575:5, 591:21, 594:11,
569:21, 573:21, 604:2, 605:1, 608:1,
ensuring [1] - 602:24
613:22, 623:23, 629:1, 629:10, 649:22,
608:6, 656:23, 677:19, 706:15, 776:21,
entail [1] - 794:17
682:6, 689:4, 697:10, 707:4, 707:7,
888:11
entering [1] - 638:22
729:17
experienced [4] - 585:24, 587:6,
entertain [1] - 661:23
examination [12] - 566:12, 566:17,
652:15, 654:24
640:4, 665:12, 665:20, 692:23, 694:2,
entire [6] - 639:20, 656:10, 671:11,
expert [4] - 585:21, 585:24, 692:12,
730:23, 738:14, 763:2, 844:13, 884:9
817:19, 819:3, 882:10
767:11
EXAMINATION [8] - 568:11, 693:1,
entities [3] - 574:10, 700:20, 863:8
expertise [3] - 603:16, 831:2, 857:24
761:13, 767:3, 772:7, 772:15, 777:12,
Entities [2] - 671:21, 675:11
expire [1] - 823:16
856:21
entitled [7] - 647:18, 661:8, 661:15,
expired [4] - 822:13, 822:14, 825:20,
examine [2] - 776:5, 776:12
669:13, 671:20, 675:10, 889:5
828:23
example
[6]
628:17,
718:13,
721:20,
entity [4] - 605:5, 699:16, 701:12,
explain [33] - 579:14, 580:10, 581:8,
804:9, 858:7, 858:17
855:25
581:13, 583:11, 584:14, 585:16, 586:8,
exceed [1] - 617:24
entrance [1] - 786:13
586:22, 587:3, 589:7, 591:24, 602:21,
except [1] - 799:8
entry [2] - 813:23, 813:25
606:3, 612:21, 617:25, 618:17, 620:16,
exception [1] - 648:25
environmental [2] - 778:16, 857:16
624:14, 625:11, 627:14, 628:10, 646:4,
Exception [1] - 726:12
episode [1] - 832:1
663:24, 765:19, 768:15, 768:18,
exceptional [1] - 674:18
equipment [4] - 712:9, 785:24, 785:25,
779:10, 810:13, 839:11, 849:13,
Exceptions [1] - 726:6
828:11
861:22, 863:7
exchange [2] - 805:8
equitable [2] - 672:11, 676:8
explained [3] - 649:19, 820:17, 861:23
exchanged [1] - 708:17
equities [2] - 821:3
explaining [1] - 847:19
exclude [1] - 565:21
equity [1] - 641:24
explanations [1] - 764:19
exclusive [3] - 581:10, 611:11, 638:12
equivalent [1] - 614:9
express [7] - 583:23, 584:2, 590:19,
exclusively [3] - 576:21, 711:1, 719:22
error [2] - 726:18, 817:6
591:14,
668:13, 729:2, 793:25
excuse [14] - 568:22, 569:24, 577:18,
ESL [1] - 778:21
expressed
[2] - 574:6, 617:12
635:12,
645:21,
665:1,
713:8,
714:19,
especially [2] - 613:22, 692:4
expressing [1] - 796:11
734:10, 784:5, 805:22, 879:17, 885:13,
essence [1] - 668:9
extend [1] - 831:16
886:2
establish [3] - 633:1, 633:7, 638:17
extended [4] - 672:1, 672:11, 675:16,
executed
[2]
672:9,
676:6
established [5] - 581:14, 607:7,
676:8
executive [1] - 603:22
648:23, 649:5, 653:21
extension [1] - 609:16
executives [1] - 848:18
establishing [1] - 648:21
extent [4] - 649:6, 708:19, 731:24,
exhibit [17] - 562:24, 574:9, 574:16,
estate [21] - 593:20, 594:2, 595:1,
782:21
578:10, 634:22, 636:21, 637:1, 638:4,
604:2, 642:1, 642:8, 678:19, 678:25,
exterior [1] - 582:19
903
612:23, 813:11, 836:12, 838:18
885:19, 887:7, 887:9, 887:13, 887:16,
887:19, 887:22, 887:25
father's [1] - 742:4
Fazel [11] - 560:20, 560:21, 566:11,
fax [13] - 818:17, 840:16, 840:17,
657:20, 660:16, 696:23, 761:17, 762:3,
840:24, 841:6, 841:10, 841:16, 841:21,
763:20, 764:21, 765:3
844:19, 845:1, 845:3, 845:5, 845:15
FDC [1] - 692:9
faxed [3] - 818:16, 819:12, 860:2
FDIC [14] - 581:10, 581:13, 581:22,
FAZEL [283] - 566:21, 569:3, 571:12,
581:23, 611:8, 611:10, 613:11, 613:14,
576:15, 577:18, 577:23, 578:1, 578:5,
614:4, 723:21, 723:22, 723:25, 725:11,
578:13, 578:18, 579:21, 585:19, 586:5,
F
795:21
598:18, 600:4, 600:6, 606:10, 606:16,
fearful [1] - 756:2
607:17, 608:10, 608:14, 614:24, 615:1,
FAA [1] - 742:3
615:7, 615:9, 615:12, 615:16, 615:19,
February [1] - 879:17
fabrication [1] - 876:20
616:2, 616:7, 632:16, 632:20, 633:5,
federal [3] - 658:8, 775:23, 776:11
face [6] - 691:17, 691:22, 708:13,
633:8, 633:12, 633:15, 633:21, 634:2,
fee [2] - 587:11, 587:16
727:12, 727:25
634:8, 634:11, 634:13, 634:16, 634:21,
feedback [4] - 589:1, 599:11, 678:9,
face-to-face [1] - 708:13
635:18, 635:22, 636:8, 637:22, 645:20,
678:10
facilitate [2] - 699:17, 743:9
645:22, 646:18, 646:23, 647:8, 647:10,
feelings [3] - 882:5, 882:6, 882:24
facilities [4] - 582:7, 620:21, 678:15,
647:14, 647:16, 647:20, 647:25, 648:3,
fees [7] - 669:20, 669:21, 670:2, 670:3,
678:17
648:7, 649:15, 649:17, 649:20, 650:14,
670:8, 670:16, 677:2
facility [2] - 681:5, 712:10
650:21, 651:7, 653:2, 653:6, 654:20,
felt [4] - 604:22, 764:16, 766:13,
facing [1] - 826:18
655:18, 655:21, 656:2, 659:7, 659:9,
766:22
fact [33] - 584:19, 592:17, 597:15,
660:9, 660:12, 660:21, 660:25, 661:6,
females [1] - 737:15
613:13, 624:19, 637:19, 638:19,
662:1, 663:3, 667:23, 673:1, 673:10,
few [17] - 562:14, 562:15, 563:10,
639:25, 664:5, 667:15, 668:6, 673:8,
673:12, 685:16, 689:19, 691:11,
563:20, 603:9, 612:7, 650:21, 651:9,
685:8, 689:18, 692:3, 696:12, 728:24,
691:16, 691:19, 692:24, 693:2, 693:21,
682:8, 691:18, 786:15, 791:13, 792:15,
731:17, 738:16, 738:18, 742:16,
695:1, 695:4, 695:7, 695:11, 695:18,
807:7, 840:4, 857:6, 888:11
753:25, 762:19, 764:24, 765:1, 765:3,
697:2, 697:6, 697:12, 697:13, 709:17,
FI [1] - 732:16
769:7, 769:9, 877:22, 881:15, 882:23,
713:7, 713:14, 714:12, 714:13, 715:7,
fiasco [1] - 724:8
882:24, 887:1
715:9, 715:14, 715:16, 718:23, 719:8,
fidelity [1] - 611:14
factors [1] - 584:18
719:9, 720:12, 720:13, 723:10, 723:13,
fiduciary [1] - 641:22
724:23, 725:17, 725:21, 725:23,
facts [2] - 638:13, 860:21
field [2] - 569:11, 569:18
725:25, 726:2, 726:8, 727:1, 727:2,
fail [1] - 756:10
figure [1] - 605:12
730:1, 730:3, 730:10, 731:22, 732:1,
failed [1] - 563:23
figuring [1] - 574:18
732:17, 732:18, 734:20, 735:1, 735:13,
failure [2] - 617:19, 762:24
file [4] - 648:5, 657:6, 657:9, 658:13
735:18, 736:16, 736:19, 737:21, 738:2,
fair [12] - 666:8, 678:24, 706:2, 719:5,
filed [6] - 650:5, 651:16, 652:9, 656:7,
738:7, 738:11, 738:23, 739:7, 740:12,
734:3, 739:22, 748:12, 748:15, 753:4,
658:13, 740:17
740:23, 743:8, 743:17, 747:13, 747:20,
858:5, 869:11, 869:15
filing [1] - 583:18
747:25, 748:2, 748:25, 749:2, 749:22,
fairly [1] - 588:25
fill [1] - 802:16
750:8, 753:8, 753:10, 755:21, 755:23,
faith [6] - 581:16, 651:10, 651:13,
final [4] - 599:17, 819:21, 819:24
756:14, 757:1, 757:4, 758:21, 758:22,
652:21, 657:16, 657:21
finalized [1] - 809:23
759:11, 759:14, 761:5, 761:7, 767:4,
fake [1] - 615:10
finally [2] - 682:10, 766:13
770:16, 770:19, 770:23, 771:2, 771:4,
fall [1] - 643:13
finance [6] - 585:16, 603:25, 689:25,
771:10,
771:22,
771:24,
772:16,
774:3,
false [5] - 638:15, 638:20, 639:25,
794:13,
857:21, 858:5
774:9, 774:22, 781:6, 790:14, 798:19,
654:19, 742:14
Financial [51] - 603:24, 604:18, 605:6,
798:22,
800:9,
801:11,
801:16,
804:10,
falsifying [1] - 829:17
611:1, 621:16, 621:21, 622:13, 626:9,
804:15, 805:22, 808:11, 824:13,
falsity [2] - 632:24, 653:23
626:19, 669:13, 670:3, 670:11, 670:15,
824:16, 826:5, 826:20, 826:23, 827:2,
familiar [21] - 595:10, 600:10, 621:15,
670:16, 672:6, 677:3, 677:5, 677:6,
828:18,
830:25,
832:21,
837:18,
838:3,
622:12, 622:18, 624:9, 630:8, 635:3,
695:12, 695:21, 695:22, 695:24, 696:1,
840:20,
842:1,
843:4,
843:8,
843:11,
637:3, 637:6, 644:14, 644:16, 648:23,
696:2, 696:12, 696:20, 696:21, 697:14,
844:10, 847:15, 847:25, 848:7, 848:13,
654:6, 662:18, 662:20, 680:13, 680:21,
697:22, 698:25, 699:2, 706:10, 706:16,
851:6,
852:14,
852:17,
853:20,
854:7,
698:7, 703:19, 817:15
706:23, 761:16, 761:23, 762:13,
854:10, 854:12, 854:25, 855:10,
familiarity [1] - 662:12
834:17, 834:23, 835:10, 835:23,
855:19, 856:11, 856:14, 856:17,
family [10] - 575:14, 603:23, 682:14,
837:13, 838:10, 838:17, 839:1, 839:7,
856:19, 856:22, 859:19, 860:5, 860:9,
684:19, 761:4, 830:16, 833:17, 840:1,
862:1, 862:4, 868:5, 868:11, 868:20
860:13, 860:15, 860:17, 860:23, 861:3,
848:11, 853:14
financial [61] - 569:19, 570:11, 575:13,
861:4, 861:11, 861:12, 862:9, 862:11,
fancy [1] - 865:1
582:2, 583:21, 585:24, 587:10, 595:16,
862:13, 864:16, 864:22, 864:24, 865:4,
far [13] - 587:23, 609:8, 652:11,
595:19, 596:5, 596:24, 600:22, 601:19,
866:19, 866:22, 866:25, 867:3, 868:2,
658:20, 659:11, 661:13, 707:9, 744:15,
602:4, 602:8, 602:25, 611:12, 612:6,
868:16, 868:18, 870:11, 870:18,
769:16, 773:6, 773:7, 776:20, 836:5
624:2, 624:16, 624:25, 625:13, 626:7,
873:10, 875:12, 875:14, 875:17,
fashion [1] - 701:5
626:11, 640:25, 644:9, 644:11, 663:25,
875:21, 876:11, 876:13, 878:4, 878:5,
fast [1] - 693:24
664:25, 665:5, 665:13, 665:16, 666:7,
879:10, 879:13, 882:17, 882:20, 883:8,
father [11] - 572:16, 573:1, 577:2,
672:16, 674:1, 681:2, 688:20, 688:24,
884:10, 884:14, 885:16, 885:18,
593:17, 594:17, 612:18, 612:22,
689:2, 689:3, 689:14, 715:3, 732:11,
external [3] - 850:4, 850:6, 850:20
extra [3] - 795:25, 796:4, 850:11
extremely [4] - 596:17, 693:11,
869:16, 869:20
eye [3] - 587:18, 850:19
eye-to-eye [1] - 850:19
eyes [2] - 603:16, 817:2
904
744:9, 753:17, 765:20, 765:25, 773:7,
flowing [4] - 591:2, 752:21, 752:24,
front [10] - 569:9, 582:21, 647:22,
773:8, 798:3, 810:16, 818:11, 819:3,
753:1
649:21, 655:20, 733:10, 741:9, 776:14,
833:23, 838:22, 838:23, 838:24,
782:12, 826:24
flown [1] - 629:20
863:16, 863:17, 873:21
frustrated [2] - 687:8, 688:3
fluent [1] - 778:18
financially [3] - 666:11, 688:4, 852:12
FSRC [3] - 715:2, 731:11, 735:19
fly [2] - 579:3, 684:13
financials [1] - 666:24
full [7] - 585:1, 592:12, 612:6, 672:8,
focus [6] - 593:23, 603:18, 683:7,
financing [2] - 594:20, 594:23
676:4, 676:11, 807:11
778:15, 789:15, 846:7
fine [14] - 668:11, 694:20, 694:25,
full-service [1] - 585:1
focused [2] - 787:6, 788:19
695:10, 776:16, 797:11, 804:14,
function [9] - 585:3, 609:17, 621:5,
focussing [1] - 572:25
861:19, 861:25, 862:12, 885:15, 888:8,
729:16, 731:1, 744:6, 744:14, 744:16,
folks [4] - 708:16, 773:7, 796:21, 874:2
888:9, 888:15
873:11
follow [7] - 652:3, 671:19, 695:17,
fine-tuned [1] - 694:20
functioned [1] - 609:14
715:13, 748:24, 748:25, 841:3
fine-tuning [1] - 694:25
functioning [2] - 790:7, 874:2
follow-up [1] - 841:3
finish [7] - 570:9, 611:18, 647:17,
functions [4] - 580:16, 714:2, 873:13,
followed [2] - 562:18, 651:14
745:6, 808:7, 810:14, 855:3
873:20
following [15] - 562:1, 567:14, 630:18,
finished [3] - 599:15, 780:24, 809:25
fund [1] - 701:12
630:23, 650:3, 652:1, 662:5, 690:22,
fired [1] - 688:2
Fund [15] - 616:12, 618:6, 620:2,
692:21, 737:23, 743:16, 812:18,
Firm [1] - 561:6
728:9, 730:11, 762:11, 823:10, 824:2,
826:13, 827:6, 844:17
firm [25] - 624:13, 624:14, 624:20,
825:17, 825:22, 828:8, 828:15, 829:20,
follows [3] - 568:10, 633:25, 777:11
624:22, 625:22, 626:14, 627:2, 627:12,
831:8, 832:4
food [1] - 692:8
627:17, 629:2, 663:20, 663:22, 666:21,
funded [2] - 682:22, 785:22
FOR [3] - 560:13, 560:20, 561:2
667:4, 667:7, 667:8, 667:15, 668:14,
funding [2] - 679:12, 679:23
force [2] - 702:10, 796:18
668:15, 681:21, 682:19, 701:6, 701:9,
funds [22] - 581:20, 584:22, 588:8,
forcing [1] - 851:23
759:25, 817:24
588:11, 589:16, 591:14, 591:23, 592:5,
foregoing [1] - 889:3
firms [4] - 624:24, 627:25, 729:21,
592:20, 613:9, 613:25, 624:17, 629:23,
foreign [7] - 605:19, 607:10, 607:14,
729:22
641:22, 674:10, 679:19, 689:15,
607:15, 618:4, 626:22, 723:19
first [87] - 563:21, 563:24, 564:16,
700:19, 700:22, 702:19, 702:20, 702:23
forget [4] - 636:16, 708:6, 769:8,
564:23, 565:2, 566:3, 567:18, 567:19,
funny [1] - 661:1
827:11
568:9, 568:25, 569:22, 571:10, 576:23,
furniture [1] - 576:9
forgot [1] - 832:13
577:4, 580:4, 580:21, 580:22, 583:20,
future [2] - 784:22, 819:15
form [8] - 585:20, 612:2, 665:5, 668:9,
589:12, 591:21, 593:9, 597:6, 610:2,
futures [1] - 641:23
718:22, 720:3, 747:10, 800:9
610:5, 610:6, 610:16, 610:17, 612:15,
formal [2] - 648:5, 776:1
616:14, 619:6, 625:4, 625:17, 632:13,
formation [1] - 706:20
G
636:2, 638:4, 640:17, 641:6, 649:20,
formed [5] - 611:1, 696:22, 698:22,
650:15, 651:9, 654:13, 657:15, 664:20,
706:20, 834:16
GAAP [5] - 732:11, 732:13, 732:25,
665:19, 672:14, 681:11, 738:10, 740:8,
formulate [1] - 657:3
735:24, 767:6
740:9, 744:2, 744:17, 764:20, 770:19,
Fort [1] - 568:18
general [5] - 574:2, 669:22, 679:10,
770:21, 776:20, 777:10, 777:24, 779:4,
forth [2] - 640:1, 661:19
707:20, 784:24
780:7, 781:15, 781:17, 784:9, 784:10,
forthcoming [1] - 691:1
generally [5] - 732:14, 779:10, 815:5,
784:24, 787:22, 788:16, 792:15,
forward [3] - 604:6, 714:18, 759:18
820:5, 848:24
798:10, 799:13, 815:7, 815:8, 815:9,
forwarding [1] - 793:20
generation [1] - 603:23
823:23, 824:3, 826:15, 828:6, 834:9,
foundation [19] - 615:1, 615:16,
gentleman [1] - 687:22
835:5, 837:18, 840:13, 842:13, 842:15,
632:17, 632:20, 632:25, 633:1, 633:4,
gentlemen [10] - 593:15, 593:17,
846:3, 888:6, 888:16
633:7, 633:18, 636:9, 638:18, 646:24,
649:25, 680:25, 775:4, 775:17, 777:19,
First [1] - 616:12
649:5, 655:7, 659:22, 659:23, 842:2,
827:4, 827:7, 888:4
fiscal [2] - 644:10, 676:3
860:3, 860:21
geography [1] - 643:23
five [14] - 563:6, 564:16, 564:18,
founded [8] - 610:24, 611:1, 834:12,
giant [1] - 579:7
650:2, 687:5, 690:13, 690:16, 691:3,
834:17, 834:24, 835:6, 835:9, 868:4
GIBL [3] - 611:9, 611:11, 612:7
751:4, 820:7, 840:18, 885:14, 885:17,
four [10] - 583:10, 691:5, 745:19,
gist [1] - 739:9
885:18
746:13, 751:1, 778:14, 779:16, 790:6,
fixed [7] - 589:8, 589:15, 641:1, 717:7,
given [20] - 597:16, 597:20, 599:4,
790:8, 887:12
717:9, 721:10
622:21, 625:12, 638:21, 639:11,
fourth [1] - 847:8
639:12, 639:21, 651:18, 692:3, 717:22,
flabbergasted [1] - 686:13
fox [1] - 576:13
751:24, 812:8, 812:9, 831:21, 832:6,
flagged [1] - 741:21
frank [1] - 795:6
832:8, 839:14, 844:14
flew [2] - 682:5, 682:7
fraud [1] - 611:15
glad [2] - 567:16, 688:18
floating [1] - 686:15
fraudulent [1] - 720:24
glass [1] - 568:23
Floor [3] - 560:22, 561:4, 616:12
freeze [1] - 855:24
globally [1] - 744:23
floor [10] - 576:7, 630:14, 681:11,
frequent [1] - 588:25
globe [1] - 743:21
681:12, 782:6, 782:23, 786:12, 786:13,
frequently [7] - 577:12, 598:3, 613:16,
goals [1] - 609:5
824:3
632:3, 644:20, 644:24, 684:11
God [1] - 625:17
flow [1] - 677:4
friends [2] - 811:20, 811:21
godparents [1] - 690:6
flowed [5] - 596:9, 670:11, 677:4,
frightened [1] - 688:4
703:21, 705:7
gosh [2] - 709:20, 757:11
905
610:14, 684:5
governing [1] - 732:5
hard [5] - 563:16, 671:19, 686:7,
guarantee [4] - 581:25, 592:4, 613:24,
731:4, 810:5
GOVERNMENT [1] - 560:13
674:19
haven [3] - 579:20, 580:2, 612:4
government [46] - 562:3, 566:24,
guarantee... [1] - 581:11
head [2] - 623:7, 854:18
567:19, 606:8, 622:7, 651:8, 653:17,
guaranteed [2] - 589:9, 605:21
655:15, 656:16, 659:9, 661:13, 691:12,
heading [1] - 836:7
691:13, 694:2, 705:24, 708:6, 711:11,
Guardian [90] - 572:21, 572:23, 574:5,
headquartered [2] - 783:12, 783:15
712:13, 724:1, 724:2, 726:9, 737:8,
574:21, 574:22, 576:24, 581:6, 581:21,
headquarters [2] - 791:21, 835:23
737:10, 738:17, 738:19, 747:22, 755:6,
583:1, 583:5, 583:20, 584:10, 585:8,
health [3] - 569:16, 582:2
755:12, 755:25, 756:8, 756:15, 756:18,
588:6, 588:23, 591:19, 592:9, 593:22,
healthcare [4] - 569:11, 569:12,
757:16, 760:14, 769:8, 804:8, 841:18,
593:25, 594:1, 594:9, 594:12, 594:20,
569:18, 689:3
842:11, 855:25, 864:15, 865:16,
595:1, 596:13, 600:1, 601:17, 602:1,
healthy [1] - 766:4
865:17, 866:20, 874:14, 874:15, 874:21
602:8, 603:6, 603:22, 604:3, 608:25,
hear [17] - 615:8, 633:14, 635:24,
Government [8] - 712:19, 730:6,
609:13, 610:24, 610:25, 611:7, 611:22,
645:8, 652:23, 655:13, 657:21, 658:14,
788:1, 798:16, 811:3, 820:11, 841:24,
613:13, 618:24, 621:10, 621:19,
668:1, 678:9, 700:24, 757:3, 798:18,
846:7
663:18, 694:4, 696:7, 696:9, 696:15,
824:15, 839:25, 840:13, 845:9
696:16, 698:7, 698:9, 698:11, 699:7,
government's [6] - 567:3, 577:21,
heard [27] - 597:4, 618:6, 622:14,
699:12, 700:7, 700:8, 700:10, 702:1,
655:1, 735:7, 740:1, 870:2
622:15, 650:25, 653:2, 653:6, 653:14,
702:13, 706:13, 706:14, 707:7, 711:5,
Government's [18] - 577:17, 582:13,
660:6, 667:3, 668:4, 677:19, 678:11,
712:19, 721:12, 724:12, 732:23,
599:25, 614:21, 632:12, 646:15, 663:9,
689:18, 697:3, 697:4, 697:5, 729:16,
741:20, 760:9, 762:13, 780:11, 783:10,
664:11, 671:2, 675:7, 683:6, 683:24,
730:16, 739:5, 783:15, 806:17, 829:23,
786:18, 786:23, 803:19, 804:24, 807:4,
725:14, 762:8, 763:25, 798:4, 803:23,
831:10, 841:10, 844:22
812:2, 834:5, 834:12, 834:16, 840:5,
841:19
hearing [4] - 613:20, 651:17, 667:21,
845:20, 845:24, 846:1, 846:4, 846:17,
governmental [1] - 724:4
697:2
863:24, 870:23, 886:2
graduate [3] - 603:24, 778:23, 857:13
hearsay [34] - 571:13, 615:1, 615:16,
guardian [1] - 593:11
graduated [2] - 581:3, 711:6
632:17, 632:20, 632:21, 633:17,
Guardian's [1] - 590:9
grammar [1] - 599:18
633:22, 645:22, 646:24, 648:25, 655:7,
guess [8] - 565:2, 649:22, 687:5,
granddaughter [1] - 857:5
655:23, 659:18, 659:22, 659:23,
695:7, 740:23, 863:6, 872:25, 881:6
granddaughter's [1] - 857:3
667:23, 673:1, 685:16, 790:15, 790:16,
guessing [7] - 882:1, 882:21, 883:9,
grandfather [7] - 605:9, 834:21,
824:14, 824:16, 826:6, 826:20, 837:19,
884:1, 884:13, 887:1, 887:2
834:24, 835:18, 837:17, 838:14, 838:19
838:3, 840:20, 842:2, 843:4, 854:8,
guidance [1] - 658:18
854:25, 855:10, 855:20
granted [2] - 566:5, 566:6
guilty [1] - 826:18
Hearsay [1] - 645:20
graph [1] - 610:12
guy [2] - 737:6, 757:12
heat [1] - 661:18
graphic [1] - 779:9
heels [1] - 756:2
great [6] - 598:6, 599:22, 610:6, 660:4,
held [23] - 562:1, 567:13, 567:14,
692:18, 861:24
H
586:20, 589:8, 607:10, 630:18, 630:23,
greater [3] - 585:5, 605:23, 605:24
641:17, 641:22, 650:3, 662:5, 672:4,
greatest [4] - 603:10, 612:8, 612:9,
half [10] - 563:9, 564:13, 604:21,
690:22, 692:21, 702:19, 702:20,
807:8
628:12, 631:12, 631:19, 641:18, 821:6,
737:23, 743:16, 775:16, 826:13, 827:6,
greatly [1] - 563:23
856:10
844:17
greedy [1] - 795:19
half-a-million [1] - 821:6
help [7] - 599:12, 617:6, 624:17, 657:5,
green [1] - 576:8
halfway [1] - 836:8
710:10, 783:6, 860:18
Gregg [1] - 560:13
hall [2] - 630:11, 630:13
helped [3] - 570:20, 571:2, 780:16
gregory [1] - 846:6
hammer [1] - 884:13
helpful [1] - 774:21
ground [3] - 567:4, 652:13, 787:6
hand [12] - 567:22, 582:24, 598:14,
helping [4] - 571:5, 573:18, 609:4,
grounds [2] - 614:25, 663:4
619:8, 641:20, 643:3, 777:2, 788:1,
625:21
group [12] - 601:22, 602:23, 611:2,
803:22, 805:13, 810:5, 875:22
herein [2] - 617:12, 617:14
616:21, 626:3, 671:10, 672:21, 672:22,
hand-carry [1] - 598:14
Hewlett [30] - 663:23, 666:14, 666:19,
685:12, 779:20, 797:15, 848:18
handing [1] - 766:23
667:4, 667:15, 668:14, 668:22, 715:25,
Group [57] - 603:24, 604:18, 605:6,
handle [2] - 615:13, 670:4
716:10, 731:10, 735:19, 817:21,
611:1, 621:16, 621:21, 624:10, 624:12,
handled [6] - 573:17, 574:24, 575:1,
817:22, 817:23, 818:4, 818:10, 818:20,
625:3, 625:9, 625:22, 626:6, 626:9,
583:14, 688:13, 713:19
818:24, 819:12, 858:17, 858:21,
626:15, 626:19, 628:3, 629:2, 670:3,
handling [1] - 587:21
859:17, 859:20, 859:22, 860:2, 884:11,
670:11, 670:15, 670:17, 672:6, 677:3,
hands [8] - 623:24, 745:12, 746:1,
884:15, 884:19, 885:20
677:5, 677:6, 681:7, 681:21, 695:12,
746:2, 746:8, 746:10, 746:11, 746:14
Hewlett's [3] - 669:2, 818:13, 818:17
695:21, 695:22, 695:25, 696:1, 696:2,
hands-on [8] - 623:24, 745:12, 746:1,
hi [1] - 865:1
696:12, 697:14, 697:22, 698:25, 699:2,
746:2, 746:8, 746:10, 746:11, 746:14
hi-lighter [1] - 865:1
706:16, 706:23, 747:8, 761:24, 762:13,
handwriting [1] - 698:4
hierarchy [1] - 698:3
834:17, 834:23, 835:10, 835:23,
hang [9] - 649:24, 695:2, 696:23,
high [9] - 581:3, 585:13, 591:15,
837:13, 838:10, 838:17, 839:1, 839:7,
720:5, 739:21, 842:13, 856:12, 864:20,
862:1, 862:5, 868:5, 868:11, 868:20
601:24, 605:17, 623:25, 748:14,
888:6
748:17, 785:10
grow [2] - 613:9, 820:2
happy [3] - 634:13, 852:6, 857:5
high-quality [2] - 605:17, 623:25
growth [11] - 592:22, 602:9, 605:17,
harassment [2] - 739:4, 740:16
higher [17] - 584:12, 584:24, 589:14,
609:1, 609:23, 609:25, 610:10,
610:11,
906
590:23, 590:24, 591:17, 611:23, 612:2,
887:14
identify [3] - 565:12, 638:14, 866:17
641:9, 676:16, 814:16, 860:16, 865:9,
HONORABLE [1] - 560:10
IFRS [7] - 732:16, 733:1, 733:2, 733:3,
865:12, 865:14, 865:15
hooked [2] - 791:3, 791:5
733:6, 763:16, 767:7
highlight [2] - 726:4, 834:10
hoping [1] - 611:18
ignored [1] - 874:10
highlighted [3] - 806:25, 864:25, 865:5
hopping [1] - 682:9
illegal [9] - 724:15, 728:13, 734:11,
highlights [1] - 640:25
753:11, 754:4, 766:14, 768:21, 768:25,
hounds [1] - 576:14
highly [1] - 700:13
877:23
hour [5] - 565:23, 661:25, 662:2,
himself [6] - 644:22, 645:13, 678:16,
imagine [1] - 878:9
827:19, 856:10
688:10, 733:25, 870:16
immediately [1] - 666:4
hours [7] - 741:13, 812:13, 812:22,
hindsight [1] - 688:17
impeachment [1] - 640:4
813:2, 837:8, 880:20, 880:22
hired [10] - 625:23, 694:4, 694:11,
house [1] - 836:20
implemented [1] - 788:17
695:14, 696:4, 696:15, 703:5, 811:14,
housekeeping [1] - 567:12
implicated [1] - 742:15
871:16
houses [1] - 594:4
implied [2] - 604:20, 773:20
hiring [1] - 577:2
HOUSTON [1] - 560:2
importance [3] - 592:16, 598:6, 668:21
historical [1] - 608:22
Houston [57] - 560:4, 560:15, 560:23,
important [21] - 733:9, 734:5, 744:14,
historically [1] - 776:4
561:4, 561:7, 561:11, 561:17, 568:17,
767:9, 767:16, 767:18, 767:20, 769:14,
history [9] - 604:19, 604:25, 699:25,
570:9, 572:18, 573:12, 573:17, 576:1,
769:24, 770:9, 770:11, 770:20, 770:24,
791:25, 833:17, 833:21, 833:24, 840:1
576:5, 577:10, 583:13, 625:4, 626:4,
771:14, 771:17, 821:16, 822:18,
hit [12] - 705:5, 711:17, 711:25, 712:4,
681:1, 684:15, 703:9, 703:10, 709:8,
822:22, 832:12, 833:25, 848:11
743:20, 760:25, 871:20, 875:16,
709:19, 729:23, 730:4, 736:25, 741:10,
impressed [2] - 678:14, 680:1
875:24, 876:5, 877:5
778:4, 779:3, 779:4, 779:5, 779:8,
impression [6] - 696:21, 731:12,
780:9, 782:5, 784:7, 789:2, 789:7,
HITTNER [1] - 560:10
742:12, 742:14, 787:11, 821:17
791:11, 791:20, 792:6, 792:11, 792:16,
Hold [1] - 569:2
improbable [1] - 700:13
792:17, 793:3, 796:18, 825:6, 825:7,
hold [27] - 584:21, 586:1, 607:22,
improve [1] - 624:1
825:9, 836:6, 839:2, 841:8, 841:22,
636:13, 639:3, 639:5, 645:21, 654:22,
improving [1] - 622:9
844:20, 873:11, 873:24, 874:15
655:11, 673:6, 677:20, 695:5, 700:19,
inaccurate [4] - 720:25, 760:17,
Howard [1] - 560:16
700:22, 701:12, 701:13, 714:10, 719:7,
760:20, 880:15
HP [1] - 816:6
734:15, 734:25, 748:23, 753:6, 775:24,
incentive [1] - 797:8
HR [1] - 687:20
843:5, 852:13, 883:1
incentives [2] - 588:3, 628:3
holder [1] - 726:16
huge [2] - 656:6, 712:15
inception [3] - 698:21, 703:1, 706:19
holds [2] - 611:13, 736:7
Hugo [5] - 711:23, 760:25, 875:24,
incident [1] - 611:15
876:4, 876:5
home [1] - 569:15
incidents [1] - 741:8
human [1] - 854:18
honest [2] - 738:16, 838:7
include [2] - 665:11, 669:22
hundred [13] - 581:17, 588:12, 592:9,
honestly [1] - 716:12
included [7] - 645:14, 670:17, 704:7,
592:10, 592:12, 628:19, 628:20, 631:7,
Honor [143] - 562:6, 563:2, 565:25,
714:2, 721:23, 721:25, 744:10
631:14, 631:15, 631:17, 632:8, 724:7
566:2, 566:7, 566:14, 567:8, 567:20,
includes [1] - 665:14
hundred-thousand-dollar [6] - 592:9,
568:7, 571:12, 571:15, 572:5, 574:8,
including [3] - 634:22, 687:2, 749:4
628:19, 628:20, 631:7, 631:14, 632:8
577:23, 578:7, 578:13, 582:12, 582:15,
income [3] - 584:19, 590:20, 768:17
585:19, 585:24, 600:6, 608:3, 608:18,
hundreds [1] - 744:23
incorporated [3] - 617:14, 696:2,
614:21, 615:6, 615:9, 615:14, 616:2,
hunt [1] - 576:14
696:13
623:10, 630:1, 631:1, 632:16, 632:22,
hurricane [14] - 711:20, 841:14,
incorrect [4] - 655:18, 655:21, 769:6,
633:5, 633:9, 633:12, 633:13, 633:15,
843:16, 844:13, 871:19, 871:24, 875:3,
769:10
633:16, 633:21, 634:5, 634:21, 635:5,
875:5, 875:6, 875:16, 876:8, 876:15,
increased [3] - 669:20, 669:21, 669:23
636:8, 636:14, 636:23, 637:12, 637:18,
877:1, 877:5
indeed [1] - 658:10
638:25, 639:15, 639:19, 640:14, 643:9,
hurt [3] - 688:7, 712:17, 774:5
indemnify [1] - 617:16
646:18, 647:2, 647:21, 648:14, 650:15,
husband [2] - 684:20
independent [4] - 622:23, 663:19,
653:19, 654:13, 655:25, 659:6, 659:16,
665:6, 763:8
662:9, 662:25, 664:12, 667:23, 668:3,
I
indicate [2] - 597:24, 837:13
674:15, 685:16, 686:2, 690:9, 691:11,
indicated [2] - 578:4, 620:24
691:21, 692:24, 695:1, 695:7, 697:3,
indication [2] - 610:11, 733:25
Idea [16] - 681:1, 682:19, 784:18,
715:5, 718:15, 720:4, 729:24, 732:17,
indications [3] - 852:10, 852:11, 853:8
787:5, 788:11, 798:15, 803:19, 804:2,
735:11, 736:15, 736:16, 737:17,
Indies [6] - 617:23, 783:17, 783:18,
810:20,
814:11,
814:14,
818:16,
820:6,
737:18, 738:21, 739:11, 740:7, 743:8,
783:19, 791:24, 835:10
841:7,
846:19,
864:13
747:25, 753:8, 755:21, 756:12, 761:8,
indirectly [2] - 625:23, 748:10
idea [20] - 565:4, 588:22, 654:16,
761:11, 766:25, 771:22, 772:2, 774:22,
individual [4] - 595:10, 726:15, 727:8,
719:17,
719:19,
719:22,
720:1,
720:14,
775:1, 775:9, 776:25, 780:4, 781:7,
779:21
720:21,
721:4,
755:5,
762:3,
809:12,
790:14, 790:17, 798:16, 800:9, 801:16,
industry [5] - 570:12, 602:4, 753:18,
811:7, 811:20, 858:25, 873:3, 873:9,
806:12, 806:21, 808:11, 824:13, 826:5,
773:8, 815:9
880:14,
883:25
828:18, 830:25, 832:21, 833:13, 834:7,
information [39] - 575:13, 587:23,
ideally [2] - 729:9, 729:10
837:18, 837:21, 841:24, 842:1, 842:5,
591:2,
596:9, 622:23, 640:22, 640:24,
identical [1] - 614:13
843:4, 843:16, 844:12, 847:15, 848:5,
645:14,
694:19, 702:8, 706:24, 708:17,
identification [1] - 646:14
852:14, 853:20, 854:7, 855:19, 856:1,
719:18, 760:13, 760:16, 766:1, 766:3,
identified [3] - 565:20, 572:6, 780:4
856:2, 856:11, 856:19, 864:18, 868:13,
907
769:19, 779:12, 794:9, 802:16, 802:18,
617:22, 617:24, 619:3, 726:16, 726:23,
674:10, 689:6, 689:16, 703:24, 765:2,
803:12, 804:1, 804:4, 805:9, 805:12,
727:9, 727:18, 729:21, 729:23, 730:4,
886:13, 886:15, 886:17
811:8, 820:20, 820:21, 834:22, 839:13,
730:6
investigated [1] - 738:19
839:15, 845:5, 852:25, 853:11, 858:22,
insures [3] - 724:7, 727:15, 729:4
investigation [4] - 738:12, 738:22,
879:23, 880:1
intends [1] - 566:11
741:12, 742:15
informing [1] - 563:15
intense [1] - 805:18
investing [11] - 585:8, 591:12, 642:1,
ingredient [1] - 609:3
701:1, 701:14, 705:20, 705:22, 706:4,
intensive [1] - 650:22
inherited [1] - 742:2
706:6, 747:2, 770:2
intent [1] - 701:18
inhouse [3] - 596:23, 625:1, 645:8
Investment [11] - 572:22, 574:21,
Intentional [1] - 696:16
576:24, 583:21, 588:7, 594:12, 596:13,
initial [1] - 605:22
interaction [2] - 710:12, 710:16
609:13, 621:19, 698:12, 702:14
ink [1] - 815:24
Interest [1] - 641:1
investment [37] - 587:11, 593:21,
inmates [1] - 692:9
interest [27] - 574:6, 584:5, 584:9,
601:24, 602:6, 603:9, 604:2, 605:16,
input [1] - 816:7
584:10, 589:9, 589:17, 590:23, 592:14,
605:24, 606:6, 612:8, 617:20, 618:15,
inquire [4] - 566:11, 567:2, 692:13,
605:20, 611:23, 612:3, 614:11, 641:8,
626:20, 679:18, 710:20, 747:4, 750:11,
739:18
641:10, 655:1, 676:4, 795:10, 795:12,
762:25, 766:2, 772:10, 772:19, 772:24,
799:14, 799:24, 800:17, 801:6, 865:7,
inquiries [1] - 757:25
772:25, 773:1, 785:2, 786:25, 787:1,
865:9, 865:10, 865:13, 866:4
inside [1] - 793:11
802:8, 805:7, 807:7, 820:13, 820:22,
interested
[7]
571:20,
700:19,
insignificant [1] - 850:22
853:25, 865:22, 865:24, 866:5, 869:3
700:23, 701:13, 790:11, 803:13, 872:9
inspect [1] - 580:16
investments [41] - 584:24, 591:4,
interface [1] - 574:6
instance [4] - 596:23, 604:16, 618:3,
593:24,
606:4, 618:5, 618:22, 618:23,
interfaced
[2]
681:2,
752:9
619:23
624:18, 641:17, 642:8, 642:15, 643:6,
internal [4] - 637:8, 642:18, 713:22,
instances [1] - 577:15
665:25, 703:12, 704:7, 704:8, 704:10,
714:1
instead [6] - 592:2, 596:2, 612:1,
704:18, 704:20, 704:21, 705:14,
internally [1] - 714:7
790:13, 801:24, 807:23
705:21, 705:22, 710:21, 710:25, 711:2,
Internation [1] - 621:19
institution [2] - 833:23, 838:22
744:7, 744:10, 746:24, 747:1, 748:6,
International [60] - 572:22, 574:5,
institutions [4] - 587:10, 611:12,
760:2, 763:7, 772:18, 773:15, 773:16,
574:21, 574:23, 576:24, 581:21, 583:1,
612:5, 641:23
773:17, 773:18, 774:11, 866:6, 886:21
583:5,
583:20,
585:8,
588:6,
588:23,
instruct [1] - 616:3
investor [3] - 627:9, 627:15, 717:17
591:19, 592:10, 594:12, 596:13,
instruction [13] - 633:23, 635:19,
investors [11] - 626:22, 626:23,
601:17, 602:1, 603:23, 609:13, 610:24,
637:23, 637:25, 638:6, 639:2, 639:15,
626:24,
627:5, 642:15, 660:17, 717:20,
610:25,
611:7,
611:22,
613:14,
618:24,
639:17, 639:20, 740:10, 868:15,
723:14, 723:15, 723:17, 723:19
623:1, 663:18, 663:19, 681:12, 694:5,
880:18, 880:19
invite [1] - 602:10
696:15, 698:9, 698:11, 699:7, 700:7,
instructions [7] - 802:18, 812:9,
involve [2] - 580:11, 580:13
700:10,
702:2,
702:13,
706:13,
706:14,
812:12, 812:22, 832:6, 832:8, 888:18
involved [25] - 575:2, 577:2, 577:8,
707:7, 721:13, 724:12, 732:22, 754:22,
instrument [4] - 590:5, 717:5, 720:1,
596:17,
597:5, 598:2, 598:5, 599:6,
760:8, 762:13, 762:14, 768:3, 780:11,
722:16
645:2,
703:5,
749:10, 749:12, 750:10,
783:10,
804:24,
834:12,
834:16,
instruments [14] - 585:14, 585:18,
750:17, 750:20, 750:24, 751:2, 751:5,
846:17, 863:24, 886:2, 886:3
586:14, 586:19, 591:15, 595:4, 603:9,
794:9, 805:14, 819:23, 820:17, 821:9,
international [25] - 570:20, 570:25,
702:6, 702:7, 718:17, 721:16, 722:11,
862:18, 881:23
571:19,
573:15,
573:21,
587:18,
591:8,
804:25, 807:7
involvement [2] - 821:13, 869:12
592:24, 594:6, 602:4, 624:1, 627:7,
insufficient [1] - 660:4
irrelevant [4] - 673:15, 673:16, 742:18,
627:8, 627:10, 665:11, 666:11, 732:11,
insurance [76] - 581:10, 581:13, 604:2,
847:16
732:23,
735:22,
736:3,
757:14,
781:22,
605:9, 605:10, 611:8, 611:12, 611:17,
IRS [1] - 752:20
798:1, 798:12
613:12, 614:4, 614:8, 614:9, 614:18,
island [25] - 579:6, 580:3, 590:21,
International's [5] - 602:8, 603:6,
614:21, 615:10, 615:24, 617:6, 617:10,
598:16,
598:18, 598:19, 609:17,
604:4,
608:25,
807:4
617:11, 617:15, 617:18, 618:20,
620:20, 620:25, 622:10, 623:1, 623:25,
internationally [2] - 587:6, 732:19
618:21, 619:24, 620:7, 697:16, 723:22,
678:18, 678:20, 680:4, 681:10, 681:16,
interview [5] - 781:13, 782:3, 782:22,
723:25, 725:11, 725:13, 727:22, 728:1,
681:25, 682:8, 712:4, 790:22, 790:23,
784:22,
790:9
728:5, 728:14, 729:3, 729:7, 730:12,
792:5, 872:9, 874:3
interviewed [5] - 680:24, 741:13,
762:4, 762:9, 762:17, 762:21, 763:6,
islands [1] - 682:7
782:17, 786:11, 846:18
763:8, 763:11, 770:21, 821:24, 822:2,
issue [22] - 562:9, 562:25, 564:15,
interviewing
[1]
783:3
822:5, 822:9, 822:17, 822:22, 822:23,
566:3, 566:10, 626:1, 637:15, 644:12,
interviews [3] - 572:15, 784:23,
822:25, 823:2, 825:3, 825:25, 828:15,
644:24, 648:22, 651:24, 656:3, 660:2,
784:24
828:22, 829:4, 829:19, 829:24, 832:9,
673:10, 673:12, 691:9, 691:22, 739:16,
intimated
[1]
746:21
832:11, 832:14, 838:19, 839:22, 840:1,
821:24, 828:22, 840:13, 851:12
introduce [5] - 568:15, 634:23, 654:14,
877:15, 878:1, 878:6, 878:14, 881:23,
issued [15] - 583:16, 583:18, 607:2,
883:16, 885:23
715:14, 777:18
622:7,
629:3, 629:7, 633:1, 644:9,
Insurance [16] - 614:22, 616:12, 618:6,
introduced [7] - 588:20, 590:8,
645:16, 662:12, 685:3, 702:9, 718:4,
620:2, 728:8, 730:11, 762:11, 823:10,
638:17, 715:24, 716:1, 716:10, 716:21
718:5, 846:16
824:2, 825:17, 825:22, 828:8, 828:15,
inventor [1] - 601:19
issues [5] - 573:19, 738:20, 793:2,
829:19, 831:8, 832:3
invest [8] - 682:15, 768:2, 795:20,
822:3, 877:22
insure [3] - 581:15, 727:12, 727:14
800:7, 853:17, 853:19, 865:20, 865:21
issuing [1] - 571:5
insured [15] - 613:14, 617:11, 617:16,
investedRMR,
[11] - 595:3, 605:17, 605:23,
Johnny C. Sanchez,
CRR - jcscourtreporter@aol.com
908
item [2] - 799:9
item-by-item [1] - 799:9
itself [11] - 582:3, 584:19, 601:16,
617:8, 652:18, 695:22, 708:18, 721:1,
764:16, 867:14, 872:9
777:19, 812:12, 827:6, 827:21, 844:17,

847:14, 868:15, 881:12, 885:11, 888:21
Justice [1] - 560:17
Larry [1] - 593:18

Larry's [1] - 593:19
last [16] - 562:8, 565:20, 569:13,
593:19, 619:1, 639:17, 651:18, 654:8,
685:11, 691:3, 700:24, 756:23, 758:2,
K
777:23, 789:12, 807:21
latest [1] - 644:25
J
keep [13] - 574:13, 588:13, 635:16,
Latin [8] - 570:6, 780:16, 781:23,
639:13, 649:25, 661:9, 735:12, 735:17,
783:5, 783:7, 787:3, 799:21, 803:16
767:16, 827:21, 831:4, 839:19, 845:19
jackets [1] - 775:24
laugh [1] - 816:22
keeping [1] - 587:18
James [16] - 572:17, 573:1, 577:1,
laughed [1] - 817:7
keeps [1] - 735:14
577:12, 595:10, 601:3, 602:12, 603:20,
laughing [1] - 808:9
Keith [1] - 757:12
604:10, 669:10, 813:8, 813:10, 836:3,
laundering [12] - 738:19, 738:22,
836:9, 836:12, 837:12
Kenneth [1] - 561:6
739:12, 739:16, 739:17, 741:7, 741:11,
January [3] - 560:5, 640:19, 650:5
kept [7] - 588:14, 631:24, 631:25,
741:22, 742:4, 742:13, 742:15, 743:11
jeopardy [1] - 687:25
701:17, 729:6, 852:18, 852:19
law [10] - 633:24, 658:3, 661:21,
Jim [1] - 811:15
kicked [1] - 842:18
666:12, 701:6, 701:9, 740:19, 757:1,
job [28] - 569:17, 570:18, 572:14,
kids [1] - 684:19
766:12, 794:4
572:20, 573:23, 573:25, 637:10,
kind [21] - 613:24, 661:8, 687:3,
Law [2] - 561:3, 561:6
648:24, 656:15, 687:25, 688:5, 714:4,
693:10, 704:20, 705:14, 721:25, 757:3,
laws [2] - 770:3, 885:3
759:21, 760:3, 780:7, 783:2, 785:14,
783:25, 785:8, 788:13, 790:12, 793:2,
lawyer [3] - 623:17, 651:10, 755:11
787:18, 794:16, 794:17, 848:11, 852:9,
793:3, 796:11, 838:23, 858:13, 859:7,
lawyers [7] - 581:2, 654:24, 694:22,
852:15, 852:23, 853:1, 870:15, 872:12,
859:12, 860:5, 873:22
697:6, 773:10, 792:24, 888:8
872:17
kinds [2] - 598:10, 719:6
lay [3] - 647:11, 649:23, 658:1
John [1] - 561:2
King [2] - 622:18, 623:7
lead [1] - 855:17
John's [2] - 666:20, 667:12
kneel [1] - 704:5
leader [1] - 601:18
Johnny [5] - 561:10, 561:16, 827:13,
Knoche [1] - 593:18
learn [11] - 670:20, 672:14, 778:20,
889:3, 889:7
knowing [2] - 606:24, 740:25
781:20, 794:19, 797:18, 824:5, 835:25,
joined [2] - 609:17, 680:24
knowledge [44] - 579:10, 608:1,
837:24, 840:2, 883:10
joint [1] - 594:6
696:13, 697:14, 699:16, 704:3, 706:1,
learned [7] - 564:19, 670:23, 678:11,
joke [1] - 809:6
706:16, 706:20, 706:25, 707:6, 710:23,
762:16, 787:12, 883:11, 883:12
JPMorgan [1] - 703:17
711:14, 711:15, 711:16, 713:24, 714:8,
learning [1] - 728:21
716:14, 719:4, 723:16, 728:10, 729:20,
Js [1] - 807:24
least [8] - 586:3, 603:9, 734:12,
730:19, 732:21, 733:5, 743:12, 748:16,
Juarez [1] - 789:17
775:19, 807:7, 814:10, 827:3, 842:4
752:19, 755:4, 760:21, 766:12, 769:2,
judge [1] - 735:15
leave [5] - 592:14, 603:19, 695:8,
770:5, 783:5, 825:4, 845:8, 861:5,
JUDGE [1] - 560:10
779:2, 844:23
864:1, 869:15, 872:19, 880:15, 881:4,
Judge [25] - 563:11, 564:5, 564:15,
leaves [2] - 742:12, 742:13
881:5, 882:4
574:12, 579:21, 600:4, 634:9, 635:15,
leaving [8] - 570:22, 571:7, 708:21,
known [6] - 587:6, 591:16, 607:7,
653:15, 654:11, 656:21, 658:24,
841:11, 841:14, 845:14, 845:15, 847:20
620:20, 693:24, 766:20
671:12, 736:17, 737:21, 738:2, 739:16,
led [1] - 847:20
knows [8] - 563:14, 649:22, 650:22,
739:24, 740:12, 761:5, 801:11, 804:15,
left [24] - 630:10, 630:13, 676:19,
697:1, 727:17, 783:4, 833:1, 851:9
861:11, 866:25, 887:7
683:23, 686:16, 686:18, 687:18,
Kroger
[1]
574:16
judges [2] - 638:12, 776:6
688:19, 689:13, 711:9, 754:6, 755:2,
judgments [1] - 665:15
778:25, 792:3, 820:8, 826:2, 830:5,
July [4] - 619:6, 619:7, 823:18, 823:19
L
840:11, 842:9, 847:5, 847:8, 852:2,
jump [4] - 610:19, 666:4, 683:6,
856:10
683:23
legal [4] - 597:20, 701:6, 718:16,
L-e-o [1] - 778:1
jumper [1] - 579:4
829:15
labeled [1] - 641:12
jumping [2] - 675:5, 708:24
legally [1] - 701:5
lack [1] - 860:21
June [2] - 619:10, 823:17
lengthy [1] - 848:5
ladder [2] - 748:15, 748:18
JUROR [1] - 827:23
Leo [3] - 736:24, 738:12, 778:1
ladies [8] - 649:25, 687:14, 775:3,
jurors [1] - 801:19
Leonel [2] - 777:1, 777:20
775:17, 777:18, 827:4, 827:7, 888:4
JURY [1] - 560:7
LEONEL [2] - 777:9, 777:23
laid [4] - 636:9, 649:17, 658:17, 661:16
jury [58] - 562:1, 567:9, 567:14,
Leroy [2] - 622:18, 623:7
landed [1] - 741:18
568:15, 575:6, 616:3, 630:18, 630:20,
less [9] - 589:17, 595:22, 672:8,
language [6] - 598:15, 598:16, 778:22,
630:23, 633:24, 635:19, 636:9, 647:22,
688:23, 744:13, 746:16, 750:17
780:17, 780:18, 799:15
649:21, 650:3, 650:19, 655:20, 657:23,
lessened [2] - 710:16
lapel [6] - 575:15, 575:16, 575:17,
660:3, 661:22, 662:3, 662:5, 685:23,
Letter [1] - 669:5
601:6, 694:19, 776:14
685:25, 690:22, 692:14, 692:21, 709:1,
letter [15] - 601:16, 645:12, 669:5,
large [4] - 592:24, 607:7, 668:24,
722:5, 733:10, 733:23, 734:1, 734:6,
669:13, 712:18, 712:22, 780:20, 813:8,
782:13
737:23, 738:17, 739:5, 742:13, 742:14,
813:14, 818:4, 818:6, 841:20, 842:5,
larger [2] - 703:15, 703:17
743:16, 745:1, 745:8, 745:11, 750:14,
843:15, 845:11
largest
[3] - 669:1, 669:2, 686:22
756:19, 760:10, 760:14, 768:21,
909
letter's [1] - 818:11
living [4] - 569:8, 579:9, 760:23, 838:2
M
letters [1] - 842:21
Lloyd's [3] - 730:12, 730:13, 730:15
level [9] - 592:19, 603:10, 686:20,
loan [24] - 592:3, 592:6, 670:21,
M-e-j-i-a [1] - 777:23
778:25, 779:1, 795:15, 805:17, 807:8,
670:24, 672:20, 674:3, 674:6, 674:8,
ma'am [14] - 567:22, 611:6, 664:23,
821:13
674:20, 675:2, 675:17, 675:18, 676:2,
683:10, 695:16, 696:17, 696:19,
676:5, 676:11, 676:12, 676:24, 742:7,
Level [2] - 707:2
718:24, 722:9, 722:24, 731:16, 768:6,
764:4, 764:12, 772:19, 772:22, 773:11,
liability [3] - 617:21, 726:24, 763:1
773:14, 774:10
773:12
liar [1] - 714:14
machine [1] - 841:21
loans [22] - 585:2, 591:19, 591:20,
librarian [1] - 836:4
magazine [2] - 798:2, 798:12
665:24, 674:11, 676:20, 679:20,
library [2] - 837:4, 837:13
magazines [1] - 769:4
681:19,
733:5,
733:11,
733:16,
733:24,
license [10] - 620:25, 623:3, 625:13,
mail [4] - 598:13, 636:2, 636:5, 802:20
736:7, 752:17, 763:21, 764:17, 772:9,
625:19, 626:1, 626:3, 711:14, 712:14,
mails [4] - 634:22, 635:9, 635:10,
804:22, 804:25, 805:5, 838:22
842:6, 845:12
637:14
lobby
[2]
571:2,
571:3
licensed [2] - 623:2, 652:16
main [4] - 583:23, 753:25, 794:19,
local [7] - 579:13, 580:7, 660:9,
lie [1] - 871:16
873:11
660:12, 682:3, 682:8, 798:3
lied [2] - 642:16, 781:4
maintain [3] - 590:20, 623:2, 625:1
located [4] - 580:1, 617:23, 762:11,
life [7] - 568:18, 711:18, 801:15, 802:1,
maintaining [1] - 623:25
863:19
802:4, 852:2, 855:24
maintains [1] - 611:12
location [2] - 578:22, 824:21
life-changing [1] - 711:18
maintenance [1] - 669:23
Lodis [6] - 611:2, 834:17, 834:20,
light [2] - 695:2, 780:2
major [1] - 690:14
835:20,
837:17,
837:24
light-blue [1] - 780:2
majority [1] - 785:5
logo [5] - 575:8, 575:12, 575:22,
lighter [1] - 865:1
man [2] - 842:25, 884:12
575:23, 582:25
limine [13] - 566:4, 566:6, 566:13,
managed [2] - 602:24, 603:17
London [7] - 616:13, 617:5, 730:12,
566:24, 567:5, 737:18, 738:4, 738:8,
management [8] - 587:10, 628:14,
762:12,
824:3,
824:5,
884:25
738:21, 738:25, 740:10, 740:24, 741:4
669:19, 670:1, 670:7, 672:9, 676:6,
look [47] - 576:6, 578:11, 610:8, 614:7,
limited [44] - 584:6, 589:22, 615:21,
748:3
614:12, 616:9, 639:5, 646:17, 647:12,
615:25, 637:25, 638:1, 638:22, 638:24,
654:15,
715:17,
721:17,
726:19,
740:3,
MANAGER [4] - 567:24, 630:22, 777:3,
639:16, 639:18, 640:10, 640:13, 649:2,
740:4, 751:22, 762:21, 763:25, 769:5,
788:25
649:3, 658:17, 659:2, 659:3, 659:10,
773:24, 774:12, 782:10, 787:21,
manager [2] - 571:10, 781:19
663:1, 663:5, 671:8, 698:14, 698:16,
788:10,
788:15,
789:2,
789:5,
794:18,
managers [13] - 586:25, 587:4, 587:7,
698:17, 699:10, 699:17, 701:14, 767:1,
796:4, 806:5, 806:19, 806:24, 817:15,
587:12, 587:19, 587:24, 588:1, 591:6,
771:25, 772:3, 774:17, 799:3, 799:4,
823:13, 823:24, 828:12, 828:15, 835:5,
591:8, 666:1, 705:8, 705:13, 752:5
799:7, 799:10, 804:12, 844:3, 858:4,
835:12, 836:19, 838:11, 838:16,
managing [7] - 573:16, 586:23, 587:5,
869:12, 869:16, 869:18, 886:10, 886:12
850:18, 870:9, 874:21, 875:23, 876:3
587:13, 590:25, 591:4, 686:24
Limited [24] - 583:2, 583:6, 611:7,
Look [2] - 765:15, 843:2
manner [1] - 768:16
611:22, 616:12, 618:7, 620:2, 696:1,
looked [7] - 645:13, 692:2, 754:8,
map [2] - 578:4, 578:22
697:23, 698:7, 698:9, 698:25, 699:3,
762:9, 828:14, 870:6, 870:7
March [3] - 569:12, 640:19, 641:19
699:7, 702:2, 706:24, 707:8, 707:13,
looking [14] - 593:20, 594:5, 609:19,
margin [1] - 592:14
762:11, 804:24, 823:10, 829:20, 862:5,
609:20, 639:19, 650:4, 675:7, 743:10,
863:25
Maria [1] - 792:23
780:14, 791:6, 849:11, 875:8, 888:5,
Limited's [1] - 672:7
Mark [1] - 593:9
888:9
limits [2] - 618:22, 627:3
mark [1] - 684:8
Looking [1] - 796:4
line [8] - 578:23, 579:2, 618:14, 641:1,
marked [5] - 646:14, 706:22, 798:4,
looks [9] - 575:6, 610:16, 643:19,
683:25, 735:12, 735:14, 735:17
803:22, 841:19
652:9, 716:17, 727:17, 829:15, 836:20,
lines [1] - 802:13
market [15] - 584:4, 584:9, 584:11,
869:25
585:9, 588:5, 589:11, 589:21, 590:14,
liquid [14] - 589:15, 595:4, 627:25,
loose [1] - 696:25
594:2, 602:5, 700:15, 718:7, 718:10,
674:11, 674:19, 679:18, 683:3, 689:17,
lose [1] - 613:19
721:10, 849:3
690:7, 772:25, 773:16, 773:17, 773:19,
losing [2] - 581:16, 613:24
marketed [3] - 702:16, 799:2, 805:25
774:11
loss [6] - 592:15, 592:17, 617:17,
liquidate [1] - 586:18
marketing [46] - 573:17, 574:25,
617:18, 726:18, 762:23
575:1, 575:13, 588:25, 595:6, 595:9,
liquidated [4] - 585:14, 585:15,
lost [2] - 686:22, 687:3
598:8, 599:3, 599:21, 600:1, 600:16,
642:14, 642:15
lotteries [1] - 768:12
604:3, 609:8, 616:22, 621:17, 621:25,
liquidity [7] - 585:16, 585:21, 586:8,
lottery [1] - 768:4
629:20, 632:22, 642:22, 642:23, 670:4,
586:13, 602:6, 603:8, 807:6
low [1] - 590:21
672:23, 681:3, 689:7, 699:9, 754:9,
list [7] - 562:13, 562:24, 652:22,
lower [5] - 585:4, 619:8, 629:12,
754:12, 754:19, 754:20, 772:11,
691:13, 785:24, 807:13, 842:23
641:18, 641:20
772:17, 780:15, 784:2, 788:17, 797:18,
listed [6] - 563:7, 593:11, 643:11,
808:2, 809:15, 834:15, 834:23, 836:21,
lowered [1] - 574:11
680:9, 680:14, 682:18
839:5, 839:22, 853:4, 857:25, 864:2
lunch [4] - 572:16, 572:25, 691:25,
listen [1] - 661:17
markets [1] - 589:24
692:10
literally [1] - 888:13
marking [2] - 784:10, 864:5
lying [1] - 642:17
live [1] - 778:2
married [1] - 568:19
Lynch [3] - 587:7, 625:24, 718:13
lived [5] - 568:16, 568:18, 681:16,
MARSHAL [1] - 775:9
778:4, 835:18
910
839:3, 839:16, 840:25, 846:9, 854:3,
885:17, 885:18, 887:12, 888:11
marshals [2] - 692:6, 692:18
856:23, 880:4
mischaracterization [1] - 882:13
master's [1] - 570:8
MEJIA [1] - 777:9
misleading [4] - 604:22, 683:5,
match [1] - 666:1
member [2] - 581:22, 603:23
720:25, 727:24
material [6] - 754:12, 754:19, 754:20,
members [2] - 716:3, 807:13
misrepresentation [6] - 874:22,
772:17, 808:2, 809:15
874:25, 876:22, 876:24, 876:25, 877:7
Members [2] - 663:12, 664:24
materially [1] - 638:15
miss [1] - 886:25
memory [7] - 867:16, 870:9, 875:15,
materials [26] - 598:8, 598:10, 598:13,
misstated [1] - 781:4
875:18, 875:24, 876:4
599:3, 599:7, 599:10, 599:14, 599:21,
mention [7] - 737:14, 756:8, 757:5,
misstates [1] - 859:15
600:13, 632:22, 689:7, 704:23, 754:9,
765:14, 766:23, 772:11, 784:2, 794:6,
757:16, 767:5, 802:7, 839:6
mistake [1] - 817:4
797:21, 805:25, 833:16, 835:1, 836:21,
mentioned [14] - 577:1, 588:17,
mistaken [3] - 700:9, 700:12, 863:23
853:4, 853:12, 864:3
621:16, 643:14, 679:20, 684:4, 716:9,
mixture [1] - 608:12
math [2] - 631:22, 741:16
795:17, 797:7, 797:23, 816:19, 839:24,
modified [1] - 660:10
844:19, 851:14
matter [24] - 562:3, 567:2, 603:12,
moment [13] - 653:16, 680:8, 690:23,
mentor [1] - 571:10
633:24, 653:14, 654:15, 655:22,
715:17, 716:22, 720:7, 743:19, 755:21,
655:24, 658:5, 660:22, 690:2, 728:24,
merely [1] - 637:19
761:5, 771:22, 801:11, 856:1, 887:14
740:9, 741:4, 741:23, 741:24, 753:25,
Merrill [3] - 587:7, 625:24, 718:13
money [112] - 579:19, 582:1, 584:4,
775:25, 798:23, 799:7, 804:11, 826:8,
mesmerized [1] - 574:14
584:9, 584:11, 585:9, 586:23, 586:25,
839:4, 889:5
message [2] - 599:23, 601:11
587:4, 587:5, 587:6, 587:12, 587:13,
mattered [2] - 683:1, 761:25
587:19, 587:24, 588:1, 588:4, 589:11,
met [18] - 571:24, 572:16, 572:17,
matured [1] - 592:5
589:19, 589:21, 589:22, 589:24,
572:23, 588:25, 593:15, 678:15, 681:5,
maximum [6] - 605:16, 612:3, 888:5,
590:14, 591:1, 591:5, 591:6, 591:8,
744:2, 755:6, 755:11, 756:18, 756:23,
888:6, 888:7, 888:11
591:12, 592:6, 594:24, 603:8, 607:6,
768:7, 807:25, 850:16, 857:8, 864:7
McGuire [2] - 561:6, 561:6
617:9, 617:17, 617:19, 617:22, 628:13,
metals [1] - 682:15
628:24, 631:25, 666:1, 670:7, 670:10,
mean [35] - 585:15, 591:24, 595:5,
Mexia [8] - 577:6, 807:20, 862:1,
672:15, 676:23, 676:25, 679:15,
595:6, 595:17, 599:15, 619:21, 642:3,
868:11, 868:20, 868:24, 868:25
679:17, 679:23, 680:4, 682:22, 683:4,
642:16, 679:14, 683:4, 704:15, 729:14,
Mexico [7] - 580:25, 619:23, 629:20,
689:24, 690:7, 701:13, 701:17, 701:23,
748:13, 787:8, 791:4, 792:13, 803:12,
757:9, 789:17, 795:3, 799:20
703:21, 705:6, 705:7, 705:12, 708:12,
810:20, 818:8, 819:1, 822:6, 822:12,
Miami [9] - 682:8, 687:23, 757:13,
726:21, 726:22, 727:17, 738:19,
830:15, 836:18, 838:11, 843:3, 844:4,
786:25, 789:19, 789:23, 791:20,
738:22, 739:12, 739:15, 739:17, 741:6,
847:4, 848:1, 856:25, 857:2, 879:1,
814:24, 863:19
741:11, 741:22, 742:1, 742:3, 742:4,
884:18, 887:9
Michelle [6] - 567:21, 568:16, 716:13,
742:8, 742:13, 742:15, 743:10, 752:5,
meaning [11] - 573:4, 579:20, 585:2,
792:22, 796:20, 824:11
752:20, 752:25, 760:10, 762:23,
587:7, 627:25, 642:23, 684:23, 737:10,
MICHELLE [1] - 568:8
764:24, 765:2, 768:2, 770:2, 785:2,
776:7, 852:11, 882:15
microphone [2] - 568:5, 694:23
786:6, 786:7, 793:11, 795:19, 795:22,
means [13] - 579:17, 580:6, 585:17,
microphones [1] - 776:14
795:25, 796:3, 796:13, 797:1, 802:2,
595:18, 641:22, 650:8, 665:23, 728:6,
middle [7] - 652:13, 675:10, 683:15,
805:5, 805:6, 807:6, 850:21, 850:24,
773:9, 779:10, 784:19, 827:19, 837:20
683:16, 823:14, 846:7, 858:8
851:3, 851:12, 853:17, 865:18, 886:15
meant [10] - 586:10, 586:13, 592:14,
might [8] - 571:21, 604:22, 652:10,
monies [4] - 729:6, 736:7, 755:16,
597:24, 618:18, 618:19, 657:2, 665:22,
657:2, 687:13, 690:10, 721:8, 749:10
886:13
832:10, 851:21
mike [5] - 586:2, 616:23, 695:16,
monitor [2] - 575:7, 782:11
mechanical [2] - 561:13, 561:18
797:10, 860:4
month [5] - 572:15, 589:22, 686:23,
medical [1] - 569:16
mikes [1] - 694:19
688:8, 760:5
meet [12] - 572:13, 572:20, 582:7,
Milam [4] - 576:7, 782:6, 788:6, 789:3
monthly [2] - 632:6, 637:3
619:23, 648:25, 678:17, 755:9, 781:15,
million [15] - 611:14, 619:4, 628:1,
months [12] - 605:22, 628:21, 672:8,
781:24, 807:16, 808:21, 809:1
631:14, 669:20, 669:22, 669:24,
674:21,
675:18, 684:14, 688:23, 744:3,
meeting [16] - 573:2, 573:19, 577:15,
676:13, 687:1, 768:4, 820:7, 821:2,
759:21, 760:3, 865:20, 865:22
601:22, 616:21, 673:24, 686:19,
821:4, 821:6, 821:8
Montser [1] - 597:21
715:22, 716:8, 716:10, 758:1, 808:7,
million-dollar [1] - 631:14
Montserrat [98] - 573:14, 576:3,
808:18, 878:20, 878:21
million-plus [2] - 821:2, 821:4
576:12, 578:4, 578:22, 578:24, 579:4,
meetings [24] - 577:14, 590:18,
millions [1] - 820:9
579:12, 582:4, 582:10, 582:22, 583:8,
629:16, 629:18, 679:10, 684:13, 685:8,
mind [9] - 636:19, 661:9, 668:5,
583:12, 583:14, 584:20, 599:1, 612:4,
685:12, 712:24, 797:14, 797:17,
673:15, 738:16, 773:2, 773:3, 773:5,
612:25, 617:23, 620:8, 620:13, 620:20,
807:19, 821:19, 821:22, 821:25,
812:5
620:22, 620:23, 624:3, 624:8, 696:3,
825:19, 831:11, 878:18, 878:19,
mine [3] - 595:23, 627:8, 677:15
697:23, 698:7, 698:25, 706:24, 707:20,
878:22, 879:2, 881:18, 883:20
minimizing [1] - 592:20
708:3, 708:18, 708:21, 709:1, 709:9,
Mejia [39] - 697:19, 736:24, 738:12,
minimum [3] - 605:22, 612:25, 800:6
709:24, 711:4, 711:14, 711:18, 711:19,
738:25, 739:6, 739:13, 740:24, 740:25,
minor [1] - 775:10
712:15, 712:19, 714:20, 760:22, 761:4,
777:1, 777:14, 777:20, 778:2, 782:10,
minute [1] - 565:20
770:12, 770:13, 771:12, 783:17,
798:5, 799:12, 801:1, 804:18, 807:1,
minutes [17] - 630:16, 650:2, 687:5,
787:13, 787:15, 787:17, 789:24, 790:2,
811:4, 813:5, 817:15, 820:15, 823:8,
690:13, 690:16, 691:3, 818:21, 818:25,
790:21, 791:13, 791:15, 791:23,
826:16, 832:24, 835:16, 835:22,
827:3, 858:9, 859:16, 859:23, 885:14,
791:25, 792:4, 793:4, 835:9, 840:8,
835:24, 836:2, 836:5, 837:7, 838:16,
911
840:9, 840:11, 840:14, 841:11, 841:14,
638:24, 639:2, 639:4, 639:6, 639:8,
775:1, 776:25, 777:13, 780:3, 780:6,
841:18, 842:6, 842:9, 842:11, 842:19,
639:14, 639:19, 640:2, 640:8, 640:14,
781:6, 781:9, 782:7, 782:9, 788:22,
842:21, 842:22, 843:7, 843:25, 844:2,
640:15, 643:9, 643:10, 643:21, 645:20,
789:1, 790:14, 790:17, 790:24, 797:13,
844:24, 845:1, 845:11, 845:15, 862:5,
645:22, 646:2, 646:3, 646:9, 646:13,
798:16, 798:19, 798:20, 798:22,
862:16, 862:17, 866:14, 866:16,
646:18, 646:23, 647:1, 647:8, 647:10,
798:25, 799:5, 799:11, 800:9, 800:12,
866:20, 867:8, 868:5, 871:20, 871:24,
647:14, 647:15, 647:16, 647:20,
800:24, 801:11, 801:13, 801:16,
873:2, 873:3, 874:16
647:25, 648:3, 648:7, 648:14, 648:18,
801:21, 802:5, 804:8, 804:10, 804:13,
648:21, 649:3, 649:9, 649:15, 649:17,
804:15, 804:17, 805:22, 805:24, 806:4,
Moreno [2] - 745:23, 792:22
649:19, 649:20, 650:14, 650:21, 651:7,
806:7, 806:10, 806:12, 806:14, 806:19,
morning [15] - 562:15, 563:10, 565:7,
651:9, 651:21, 652:21, 653:2, 653:6,
806:21, 806:23, 807:10, 807:12,
568:13, 568:14, 808:6, 808:16, 809:3,
653:7, 653:12, 653:14, 653:19, 654:2,
808:11, 808:14, 810:2, 810:4, 813:3,
840:16, 840:24, 841:17, 841:21,
654:5, 654:10, 654:13, 654:18, 654:20,
813:4, 813:17, 813:18, 817:12, 817:14,
844:19, 844:20, 888:19
654:21, 654:23, 655:5, 655:10, 655:12,
818:5, 818:9, 820:12, 820:14, 823:5,
mortgage [1] - 568:22
655:14, 655:18, 655:19, 655:21, 656:2,
823:7, 823:13, 823:15, 823:23, 823:25,
most [13] - 580:24, 583:24, 590:1,
656:18, 656:21, 657:8, 657:11, 657:13,
824:13, 824:16, 824:19, 825:8, 826:5,
609:3, 629:23, 701:23, 742:24, 753:20,
657:15, 657:20, 658:23, 659:1, 659:6,
826:8, 826:15, 826:20, 826:23, 827:1,
753:23, 787:10, 792:14, 814:23, 844:5
659:7, 659:9, 660:9, 660:12, 660:15,
827:2, 827:3, 828:2, 828:4, 828:5,
mostly [7] - 580:25, 787:8, 790:3,
660:21, 660:24, 660:25, 661:2, 661:4,
828:18, 828:21, 830:25, 831:6, 832:21,
795:3, 798:3, 805:7, 811:10
661:6, 662:1, 662:9, 662:10, 662:25,
832:23, 833:8, 833:10, 833:13, 833:14,
mother [1] - 887:16
663:3, 663:7, 663:8, 664:11, 664:14,
834:1, 834:2, 834:7, 834:9, 834:11,
motion [12] - 566:4, 566:6, 566:13,
664:16, 664:18, 664:19, 664:22,
835:3, 835:4, 836:23, 837:18, 837:21,
566:24, 567:5, 738:4, 738:8, 738:21,
666:15, 666:18, 667:1, 667:2, 667:23,
837:23, 838:3, 838:6, 840:20, 840:23,
738:25, 740:9, 740:24, 741:4
667:25, 668:3, 668:11, 668:12, 671:6,
841:24, 842:1, 842:5, 842:8, 842:15,
move [21] - 574:4, 606:2, 620:13,
671:8, 671:11, 671:14, 671:22, 671:24,
842:18, 843:1, 843:4, 843:8, 843:11,
624:4, 643:2, 681:8, 709:14, 725:19,
673:1, 673:3, 673:7, 673:10, 673:12,
843:15, 843:19, 843:24, 844:10,
776:18, 797:10, 800:21, 811:2, 833:15,
673:14, 673:19, 673:22, 673:23,
844:12, 844:18, 846:6, 846:8, 847:15,
847:24, 848:3, 851:15, 860:17, 864:21,
674:15, 674:16, 675:1, 675:6, 675:12,
847:19, 847:23, 847:25, 848:4, 848:7,
875:17, 887:23, 887:25
676:10,
677:22,
677:25,
678:4,
680:6,
848:9, 848:13, 848:15, 850:8, 851:6,
moved [13] - 621:2, 622:5, 622:24,
680:10, 680:16, 680:18, 680:20,
851:11, 851:16, 852:8, 852:14, 852:16,
623:16, 624:3, 709:18, 712:11, 714:17,
683:13, 683:14, 685:16, 686:1, 686:2,
852:17, 852:22, 853:20, 853:23, 854:2,
714:19, 772:22, 772:23, 843:13, 845:19
686:3,
689:1,
689:11,
689:19,
689:22,
854:7, 854:10, 854:12, 854:15, 854:21,
moving [7] - 620:17, 624:9, 639:13,
690:9,
691:3,
691:11,
691:16,
691:19,
854:25, 855:1, 855:3, 855:5, 855:10,
657:23, 761:4, 888:13, 888:14
691:21, 692:15, 692:17, 692:24, 693:2,
855:16, 855:19, 856:1, 856:11, 856:14,
MR [697] - 562:6, 562:8, 563:2, 563:6,
693:21,
695:1,
695:4,
695:7,
695:11,
856:17, 856:19, 856:22, 859:15,
563:9, 563:11, 563:14, 564:4, 564:9,
695:18,
697:2,
697:6,
697:12,
697:13,
859:19, 860:3, 860:5, 860:9, 860:13,
564:13, 564:15, 564:23, 564:25, 565:1,
709:17, 713:6, 713:7, 713:14, 714:12,
860:15, 860:17, 860:20, 860:23,
565:25, 566:2, 566:7, 566:9, 566:14,
714:13,
715:5,
715:7,
715:8,
715:9,
860:24, 861:3, 861:4, 861:10, 861:11,
566:16, 566:21, 567:8, 567:20, 568:7,
715:10, 715:12, 715:14, 715:16,
861:12, 862:9, 862:11, 862:13, 864:16,
568:12, 569:3, 569:6, 570:10, 571:12,
718:15, 718:19, 718:23, 719:8, 719:9,
864:21, 864:22, 864:23, 864:24, 865:4,
571:14, 571:23, 572:5, 572:9, 573:22,
720:3,
720:12,
720:13,
722:21,
723:10,
866:19, 866:21, 866:22, 866:24,
574:8, 574:15, 574:17, 576:15, 576:17,
723:12, 723:13, 724:23, 725:17,
866:25, 867:3, 867:25, 868:2, 868:13,
577:16, 577:18, 577:20, 577:23, 578:1,
725:21, 725:23, 725:25, 726:2, 726:8,
868:16, 868:18, 870:10, 870:11,
578:3, 578:5, 578:7, 578:12, 578:13,
727:1,
727:2,
729:24,
730:1,
730:3,
870:15, 870:18, 873:10, 875:12,
578:18, 578:20, 579:11, 579:21,
730:10, 731:20, 731:22, 732:1, 732:17,
875:14, 875:17, 875:19, 875:21, 876:9,
579:24, 582:12, 582:15, 582:16, 584:8,
732:18, 734:17, 734:20, 735:1, 735:13,
876:11, 876:13, 878:4, 878:5, 879:9,
585:19, 585:23, 586:5, 586:7, 593:8,
735:18,
736:16,
736:19,
737:17,
879:10, 879:13, 882:12, 882:17,
593:10, 598:18, 598:24, 600:3, 600:4,
737:21, 738:2, 738:7, 738:11, 738:20,
882:20, 883:2, 883:5, 883:8, 884:4,
600:6, 600:9, 600:15, 600:17, 600:23,
738:23, 738:24, 739:3, 739:7, 739:9,
884:7, 884:10, 884:14, 885:16, 885:18,
601:1, 601:8, 601:9, 601:12, 601:14,
739:15,
739:18,
739:23,
739:24,
740:2,
885:19, 887:3, 887:7, 887:9, 887:13,
602:16, 602:17, 606:10, 606:13,
740:7, 740:12, 740:13, 740:15, 740:18,
887:16, 887:19, 887:21, 887:22, 887:25
606:16, 606:21, 607:4, 607:17, 608:10,
740:23,
741:3,
741:8,
741:16,
741:24,
multi [1] - 601:21
608:14, 608:18, 608:19, 609:18,
742:10,
742:22,
742:24,
743:2,
743:5,
multi-national [1] - 601:21
609:21, 614:20, 614:24, 615:1, 615:2,
743:8, 743:17, 747:10, 747:13, 747:15,
multiple [1] - 634:21
615:5, 615:7, 615:9, 615:10, 615:12,
747:20, 747:25, 748:2, 748:25, 749:2,
mutual [1] - 624:17
615:14, 615:16, 615:19, 615:22, 616:2,
749:22,
750:8,
753:8,
753:10,
755:21,
616:7, 616:8, 617:3, 619:25, 620:10,
755:23, 756:12, 756:14, 757:1, 757:4,
620:12, 623:15, 628:2, 630:1, 631:1,
N
758:17, 758:21, 758:22, 759:11,
631:2, 632:16, 632:20, 632:21, 633:5,
759:14, 761:5, 761:7, 761:11, 761:14,
633:8, 633:12, 633:15, 633:21, 634:2,
name [39] - 568:16, 574:20, 593:19,
766:25, 767:4, 770:14, 770:16, 770:19,
634:4, 634:8, 634:11, 634:13, 634:16,
603:19, 605:10, 616:10, 621:7, 621:9,
770:23,
771:2,
771:4,
771:5,
771:9,
634:21, 635:4, 635:7, 635:8, 635:14,
622:18, 622:20, 636:7, 663:22, 666:14,
771:10, 771:22, 771:24, 772:2, 772:5,
635:18, 635:22, 636:1, 636:8, 636:11,
696:18, 711:21, 716:16, 757:12,
772:8,
772:14,
772:16,
774:1,
774:3,
636:14, 636:23, 636:24, 637:12,
777:20, 777:23, 777:24, 777:25, 783:9,
774:6,
774:9,
774:18,
774:20,
774:22,
637:18, 637:22, 638:3, 638:7, 638:10,
784:17, 784:18, 786:22, 790:5, 807:21,
912
823:10, 823:11, 838:24, 845:20, 846:1,
nine [2] - 709:5, 744:3
objected [1] - 651:21
855:14, 855:15, 855:18, 864:12,
nobody [2] - 699:20, 700:1
objecting [4] - 650:24, 652:19, 654:3,
864:13, 870:22
655:4
noise [1] - 693:18
named [2] - 595:10, 811:15
objection [81] - 571:12, 577:25,
none [3] - 603:11, 643:14, 699:21
names [7] - 562:11, 562:22, 621:11,
578:14, 578:17, 600:5, 606:14, 608:9,
nonhearsay [1] - 648:16
757:10, 757:13, 757:21, 792:20
608:10, 608:11, 616:1, 632:17, 632:18,
nonresponsive [3] - 685:18, 828:19,
narrative [5] - 569:3, 576:15, 579:22,
633:17, 633:22, 634:23, 635:19,
840:21
808:11, 808:13
637:21, 637:22, 639:23, 645:20,
Nonresponsive [1] - 689:19
647:20, 650:20, 656:16, 657:3, 658:6,
narrow [1] - 661:24
noon [4] - 565:10, 565:23, 661:25,
658:12, 658:16, 660:2, 660:13, 661:23,
narrowly [1] - 718:1
662:2
663:3, 663:4, 667:23, 671:5, 673:1,
National [1] - 754:25
normal [3] - 722:9, 722:10, 722:12
685:16, 689:19, 713:6, 718:15, 720:3,
national [1] - 601:21
north [1] - 676:12
722:21, 729:24, 731:20, 734:17,
nature [1] - 580:6
note [5] - 672:5, 672:7, 676:4, 735:8,
737:17, 737:18, 741:5, 743:15, 747:10,
near [1] - 582:22
736:24
756:12, 758:17, 770:14, 771:8, 781:6,
necessarily [1] - 719:15
Note [2] - 820:12, 820:13
790:14, 798:18, 798:23, 799:6, 799:9,
necessary [2] - 708:18, 735:10
noted [2] - 611:3, 770:17
800:9, 801:19, 804:10, 837:18, 843:10,
need [38] - 578:15, 578:16, 578:17,
notes [7] - 672:4, 713:5, 726:21,
843:17, 844:4, 848:13, 853:20, 854:7,
614:23, 616:6, 627:18, 633:8, 646:23,
758:7, 758:8, 758:9, 821:7
855:10, 855:19, 860:20, 867:25,
647:22, 648:12, 648:25, 649:6, 650:1,
nothing [12] - 562:23, 568:1, 651:4,
868:13, 882:12, 882:14, 883:2, 887:3,
653:4, 658:14, 686:9, 694:19, 694:22,
651:20, 732:4, 742:11, 758:9, 772:14,
887:6
694:24, 715:5, 722:25, 735:6, 756:5,
773:16, 777:5, 791:1, 791:15
Objection [1] - 852:14
769:14, 769:23, 780:15, 783:4, 785:19,
notice [8] - 565:22, 590:9, 785:19,
objections [15] - 578:15, 578:16,
785:24, 787:19, 806:9, 810:14, 812:13,
813:20, 814:8, 816:14, 844:6, 865:16
615:17,
646:19, 648:5, 650:4, 651:10,
844:13, 854:13, 866:25, 887:2
noticed [1] - 816:18
651:17,
651:19, 655:3, 655:8, 655:17,
needed [10] - 570:25, 586:15, 683:4,
notify [1] - 654:14
657:13, 657:14, 658:9
688:15, 690:8, 785:2, 797:17, 804:4,
November [1] - 879:18
objective [1] - 787:22
854:16, 881:3
nowhere [2] - 642:6, 774:10
obligated [1] - 764:16
needing [2] - 648:25, 688:5
Number [3] - 864:15, 866:8, 866:24
obligation [2] - 718:1, 765:16
needs [10] - 562:25, 601:22, 649:22,
number [25] - 571:22, 578:10, 579:16,
obligations [2] - 717:25, 872:1
660:21, 692:4, 793:20, 797:18, 827:17,
584:6, 589:22, 643:11, 651:15, 656:6,
observed [1] - 598:5
833:23
656:8, 676:16, 683:18, 684:1, 706:23,
obstruction [1] - 651:5
negatively [1] - 758:10
708:7, 709:20, 709:21, 761:15, 796:12,
obstructionism [1] - 652:11
nerve [2] - 693:10, 697:5
814:8, 824:8, 827:22, 842:21, 859:2,
obstructionist [1] - 651:6
nerve-racking [1] - 693:10
865:7, 883:5
obtain [1] - 806:1
nervous [2] - 693:12, 693:14
numbers [55] - 610:1, 751:22, 751:24,
obtained [2] - 818:3, 818:7
never [27] - 596:3, 612:13, 652:2,
752:3, 752:4, 754:14, 754:16, 760:19,
obvious [1] - 817:4
657:15, 658:11, 684:9, 687:15, 690:1,
769:9, 809:2, 809:5, 809:8, 810:17,
occasionally [3] - 684:13, 776:2,
693:6, 699:23, 712:22, 741:13, 741:14,
813:19, 813:21, 815:2, 815:5, 815:10,
807:18
742:12, 742:16, 746:21, 751:12,
815:11, 815:14, 816:5, 816:11, 816:14,
occasions [2] - 651:23, 755:6
757:25, 804:24, 804:25, 839:24, 840:2,
816:18, 816:23, 817:3, 817:9, 818:3,
occupation [1] - 837:24
857:8, 859:8, 874:5, 884:4
818:14, 818:15, 818:16, 818:20,
occurred [2] - 741:24, 742:20
New [1] - 560:17
818:25, 819:6, 819:9, 819:21, 819:24,
occurring [1] - 617:17
new [28] - 570:21, 571:4, 571:18,
820:18, 858:18, 859:7, 859:8, 859:10,
odd [6] - 859:7, 859:13, 859:16,
574:7, 574:14, 583:16, 583:17, 583:18,
859:17, 861:6, 869:9, 873:22, 880:11,
588:11, 598:12, 605:2, 613:12, 613:22,
859:20, 859:22, 861:13
880:15, 880:24, 881:14, 881:15,
613:23, 625:22, 626:18, 628:13,
OF [2] - 560:1, 560:4
881:20, 883:13, 883:24, 886:6
629:19, 630:2, 695:6, 728:21, 822:8,
NW [1] - 560:17
offer [26] - 565:13, 578:7, 578:8,
828:7, 829:1, 831:16, 831:19, 848:20,
578:10, 579:17, 582:13, 612:6, 624:18,
848:24
624:25, 626:20, 626:23, 637:12,
O
newspaper [3] - 681:25, 682:20, 779:6
658:17, 659:3, 660:6, 662:25, 671:9,
newspapers [1] - 798:3
682:14, 720:21, 784:25, 785:9, 785:14,
o'clock [2] - 690:13, 827:16
795:14, 799:4, 804:25, 844:3
Newsweek [1] - 798:2
object [51] - 569:3, 576:15, 578:2,
offered [23] - 571:14, 573:23, 588:4,
next [30] - 564:6, 564:10, 578:10,
578:6, 579:21, 585:20, 606:16, 614:24,
588:7, 590:6, 590:10, 615:2, 615:5,
578:25, 593:9, 595:23, 601:8, 610:7,
615:12, 615:15, 633:9, 633:10, 634:20,
647:2, 659:2, 659:10, 660:22, 668:6,
611:6, 611:19, 646:8, 660:5, 666:4,
638:9, 638:10, 645:22, 647:16, 648:2,
673:7, 707:14, 707:18, 773:11, 773:12,
674:13, 687:19, 691:8, 719:7, 761:3,
650:8, 650:10, 651:24, 655:7, 656:5,
801:6, 804:11, 842:16, 844:12, 865:13
776:23, 786:12, 810:13, 811:2, 825:15,
656:9, 656:12, 656:13, 656:15, 657:24,
offering [17] - 583:22, 588:23, 589:11,
830:4, 835:5, 875:13, 885:14, 885:17,
658:21, 659:17, 660:3, 661:15, 673:13,
885:18, 887:12
615:20, 632:22, 632:23, 648:18, 649:1,
691:13, 743:4, 743:5, 801:18, 804:15,
649:6, 653:22, 654:17, 660:16, 707:11,
nice [1] - 737:6
805:22, 826:20, 830:25, 832:21,
795:10, 795:12, 798:17
niche [1] - 602:3
840:20, 842:1, 847:15, 848:6, 851:7,
offers [4] - 605:16, 798:16, 804:8,
nickname [1] - 777:24
859:15, 860:3, 870:14, 884:4
841:25
night [3] - 569:16, 819:16, 887:24
913
788:16, 790:13, 792:25, 797:20, 801:3,
offhand [1] - 701:7
overpay [1] - 850:21
803:24, 807:9, 809:22, 809:25, 810:19,
office [72] - 569:9, 569:17, 572:18,
overpayment [2] - 851:14, 851:17
812:6, 814:10, 816:6, 818:1, 819:20,
573:17, 576:5, 576:8, 576:21, 577:13,
overrule [4] - 615:25, 673:16, 771:8,
820:16, 820:17, 822:8, 824:11, 827:22,
582:21, 583:8, 583:12, 583:13, 583:14,
882:15
834:3, 836:1, 837:9, 837:10, 840:2,
595:23, 625:4, 626:2, 626:4, 629:19,
overruled [23] - 571:16, 615:18,
843:19, 847:7, 849:22, 854:22, 856:1,
687:5, 687:20, 688:7, 713:19, 737:15,
637:25, 713:8, 730:1, 730:2, 731:24,
856:12, 856:14, 860:7, 865:7, 867:21,
757:9, 761:3, 782:18, 782:21, 786:9,
747:11, 758:19, 781:8, 806:2, 826:22,
868:25, 873:15
786:10, 789:5, 789:8, 789:10, 789:15,
831:3, 832:25, 838:4, 847:22, 848:8,
one-arm [1] - 776:6
789:23, 789:25, 790:4, 790:5, 790:7,
848:14, 855:11, 855:21, 883:4, 883:7,
one-third [1] - 782:23
792:4, 792:12, 792:16, 795:6, 814:24,
884:6
815:19, 816:1, 818:17, 825:13, 826:2,
ones [4] - 593:19, 643:14, 701:10,
overrules [1] - 637:23
829:3, 830:5, 830:14, 830:18, 836:10,
837:2
overruling [1] - 633:22
836:14, 836:15, 837:12, 840:15,
ongoing [2] - 628:16, 711:6
oversaw [1] - 622:16
840:16, 840:17, 841:5, 841:7, 841:22,
open [11] - 583:17, 588:4, 593:14,
overseas [1] - 587:19
843:2, 844:20, 849:22, 850:12, 876:16,
612:25, 626:2, 626:4, 736:10, 739:4,
oversee [1] - 810:21
885:5, 885:9
785:2, 802:19
own [21] - 591:23, 599:20, 602:4,
officed [1] - 825:9
opened [9] - 573:13, 596:21, 625:4,
640:5, 645:10, 654:4, 658:10, 677:15,
officer [7] - 570:17, 570:18, 595:16,
625:6, 625:7, 629:19, 682:13, 742:7,
679:12, 679:19, 690:6, 717:11, 717:15,
596:5, 603:22, 605:25, 672:2
770:6
784:3, 785:4, 785:5, 785:6, 817:2,
Officers [2] - 671:21, 675:11
opening [8] - 571:4, 593:2, 609:12,
852:4, 888:14
officers [1] - 602:11
624:20, 624:22, 627:2, 722:17, 803:13
owned [14] - 663:25, 728:2, 728:6,
offices [17] - 576:11, 582:9, 583:4,
openings [2] - 700:6, 700:8
779:21, 784:4, 825:21, 829:24, 830:15,
583:7, 596:21, 596:22, 625:5, 625:7,
operate [2] - 602:5, 793:22
831:8, 831:13, 832:9, 832:11, 833:11,
746:10, 754:24, 782:4, 787:20, 787:21,
operating [4] - 603:6, 807:3, 807:4,
877:23
787:24, 788:20, 789:7, 815:22
813:25
owner [8] - 596:16, 670:18, 702:17,
official [1] - 741:19
operation [3] - 666:9, 743:11, 793:22
829:21, 830:8, 830:11, 830:17, 877:20
offshore [9] - 571:19, 573:13, 579:15,
operational [2] - 597:23, 598:1
owners [2] - 581:2, 717:20
580:1, 580:6, 581:21, 622:10, 622:17,
operations [3] - 621:3, 713:19, 790:10
ownership [2] - 612:21, 717:11
742:1
operative [1] - 776:15
owning [1] - 838:21
often [4] - 710:13, 745:2, 745:9,
opinion [10] - 585:22, 606:17, 665:6,
owns [5] - 779:19, 784:5, 830:16,
745:13
665:7, 665:9, 666:5, 666:7, 729:2,
832:3, 878:13
Oklahoma [1] - 568:22
737:5, 796:14
old [4] - 568:20, 604:21, 804:1, 807:24
opportunities [3] - 593:21, 594:4,
P
oldest [1] - 568:21
594:5
omission [1] - 726:18
opportunity [4] - 578:5, 646:12,
p.m [4] - 690:21, 775:6, 775:11, 888:22
once [26] - 589:25, 590:8, 592:5,
682:14, 780:7
P.O [2] - 824:8, 824:9
592:21, 595:24, 622:5, 622:24, 623:16,
opposed [2] - 589:21, 624:8
packet [3] - 635:3, 635:10
623:17, 624:3, 625:18, 626:5, 627:4,
options [1] - 641:24
Page [25] - 600:24, 602:16, 605:13,
644:9, 684:7, 686:14, 688:19, 693:8,
oranges [1] - 734:7
608:20, 610:19, 663:10, 663:11,
693:9, 704:9, 705:5, 751:14, 752:9,
order [13] - 564:17, 564:20, 564:21,
664:16, 664:17, 665:3, 669:4, 671:15,
770:1, 787:5, 831:13
612:25, 617:6, 618:19, 624:24, 682:13,
675:7, 683:8, 782:8, 806:15, 813:3,
one [148] - 562:15, 563:6, 564:18,
692:15, 699:17, 721:9, 776:21
813:17, 813:22, 817:12, 820:12,
566:3, 567:11, 569:24, 573:16, 578:1,
orders [3] - 563:17, 726:22
823:13, 834:4, 835:3
579:18, 585:22, 586:1, 592:18, 600:13,
ordinary [2] - 672:11, 676:7
page [40] - 600:16, 600:20, 601:8,
602:11, 604:16, 604:18, 618:12,
org [1] - 680:7
602:19, 603:4, 603:19, 608:21, 608:24,
620:18, 621:14, 626:3, 626:4, 626:10,
organization [6] - 601:21, 605:2,
609:19, 610:7, 610:23, 611:19, 611:21,
626:12, 631:22, 634:17, 635:10,
622:12, 622:16, 688:20, 748:5
619:1, 632:15, 638:4, 640:17, 641:11,
636:21, 639:10, 641:16, 641:20,
oriented [3] - 577:16, 578:21, 611:4
641:19, 642:18, 664:15, 664:21, 665:8,
646:17, 650:6, 650:10, 650:11, 650:13,
original [4] - 701:18, 788:1, 810:5,
675:10, 683:13, 683:16, 782:14, 789:8,
650:22, 652:1, 652:2, 652:19, 652:20,
811:5
791:21, 798:10, 799:13, 800:25,
653:9, 653:10, 655:6, 656:6, 656:22,
originally [4] - 568:17, 612:23, 846:18,
804:18, 807:11, 813:5, 813:7, 814:2,
656:25, 658:1, 660:5, 660:8, 661:17,
847:1
817:17, 823:24, 875:13
663:25, 664:9, 664:10, 669:15, 676:23,
ought [1] - 864:4
Pages [1] - 665:1
677:11, 677:12, 685:11, 687:4, 690:13,
ourselves [1] - 707:15
pages [4] - 650:5, 792:7, 818:15,
696:23, 705:12, 710:24, 711:2, 712:11,
out-of-court [1] - 646:24
842:15
716:3, 716:8, 721:6, 728:6, 728:22,
out-of-court-statement [1] - 647:1
paid [32] - 584:9, 584:13, 590:24,
729:3, 738:3, 738:12, 739:22, 740:4,
outlets [1] - 791:7
591:17, 613:4, 617:14, 628:9, 628:12,
740:5, 740:11, 741:1, 742:20, 742:24,
outside [13] - 581:9, 587:15, 604:4,
628:22, 629:6, 631:8, 631:25, 632:3,
743:14, 745:23, 748:6, 757:13, 759:10,
630:18, 663:16, 663:19, 664:2, 692:8,
632:6, 670:12, 670:15, 674:21, 676:4,
762:3, 763:12, 768:7, 770:21, 772:5,
752:7, 793:10, 793:12, 847:1, 847:6
677:5, 677:10, 677:12, 677:15, 677:17,
772:23, 774:13, 776:6, 776:7, 781:14,
overhead [4] - 585:4, 590:22, 612:5,
702:17, 754:1, 760:10, 764:14, 766:10,
782:23, 783:13, 784:12, 784:21,
760:6
796:24, 797:5, 799:24
784:24, 784:25, 786:16, 787:21,
914
766:7
811:22
pamphlets [1] - 760:13
payments [5] - 611:25, 612:3, 612:16,
persons [2] - 672:13, 676:9
Panama [1] - 755:1
613:2, 623:7
perspective [2] - 766:5, 802:15
pancreatic [1] - 569:14
pays [2] - 584:5, 612:1
Peru [1] - 795:4
panels [1] - 856:11
PB [1] - 616:13
Peter [1] - 716:15
paper [23] - 605:18, 606:4, 606:6,
peanut [1] - 692:1
606:12, 607:2, 607:6, 650:21, 650:23,
philosophy [4] - 603:6, 611:4, 683:2,
pedigree [1] - 885:21
656:11, 658:22, 659:17, 705:1, 779:11,
807:4
780:9, 785:7, 788:13, 788:14, 788:15,
pen [1] - 601:7
phone [7] - 566:22, 571:22, 687:21,
805:20, 821:5, 828:10
687:23, 688:14, 746:11, 860:24
penalty [1] - 592:3
papers [4] - 580:16, 758:14, 830:15,
phones [1] - 576:22
pending [2] - 566:4, 645:9
830:22
phonetic [7] - 713:15, 716:15, 745:23,
people [82] - 564:8, 571:5, 572:19,
paperwork [5] - 576:21, 576:22,
792:22, 792:23, 795:6, 854:18
572:21, 572:22, 573:5, 573:20, 574:6,
721:22, 722:1
photo [3] - 789:22, 801:9, 867:23
580:24, 581:3, 581:16, 583:8, 583:16,
paperwork-type [1] - 576:21
587:1, 588:24, 595:7, 595:9, 602:3,
photograph [1] - 876:15
paragraph [8] - 605:14, 666:3, 669:14,
602:23, 604:25, 605:3, 613:17, 614:3,
photographer [2] - 836:16, 836:17
671:23, 726:19, 835:5, 835:6
616:20, 621:6, 624:17, 625:24, 629:22,
photographs [2] - 656:11, 872:2
640:9, 645:8, 652:16, 675:22, 678:18,
paragraphs [1] - 605:15
photos [3] - 582:14, 582:15, 582:17
680:22, 681:5, 681:16, 686:8, 688:22,
pardon [6] - 623:12, 673:11, 854:11,
phrase [1] - 728:17
700:19, 700:23, 701:13, 702:13, 703:5,
859:14, 872:3, 879:25
phraseology [1] - 599:19
708:10, 708:12, 708:16, 709:5, 709:9,
Park [4] - 570:23, 571:7, 571:8, 571:9
physical [2] - 712:10, 824:8
709:18, 709:22, 709:24, 711:18, 752:5,
parked [2] - 741:9, 741:12
Picadilly [1] - 616:13
753:25, 757:9, 765:4, 765:16, 765:20,
Parras [2] - 561:2, 691:4
Piccadilly [1] - 824:3
773:12, 783:5, 790:6, 790:8, 792:19,
PARRAS [5] - 563:11, 563:14, 564:4,
pick [9] - 586:3, 627:22, 720:6, 774:4,
795:18, 795:25, 796:2, 796:12, 800:13,
564:15, 564:25
786:1, 860:10
801:22, 801:23, 803:13, 845:6, 849:5,
parse [1] - 673:20
picked [1] - 576:11
863:15, 867:11, 872:1, 872:4, 873:11,
part [22] - 576:12, 580:24, 625:21,
picture [23] - 583:3, 601:2, 650:23,
873:21, 874:9, 878:12
671:7, 677:12, 678:10, 700:2, 700:19,
708:7, 782:14, 787:23, 788:6, 789:2,
per [4] - 589:22, 611:15, 628:23,
700:22, 700:24, 706:12, 706:18, 712:9,
789:21, 792:3, 792:4, 792:6, 836:15,
888:11
712:12, 748:5, 766:3, 783:18, 783:20,
836:24, 866:10, 866:12, 866:16, 870:1,
perceived [1] - 858:4
783:23, 797:23, 805:14, 846:7
870:3, 874:19, 875:7, 876:14, 877:8
percent [35] - 584:12, 584:23, 588:11,
participate [1] - 611:10
pictures [5] - 576:13, 791:9, 835:24,
590:11, 610:5, 610:6, 610:16, 610:17,
participating [1] - 622:11
839:5, 866:20
610:18, 628:12, 628:13, 631:12,
particular [7] - 564:20, 598:4, 643:24,
pie [3] - 641:18, 642:3, 643:3
631:13, 631:19, 631:20, 632:5, 632:9,
762:22, 763:4, 763:21, 792:9
piece [2] - 613:4, 658:21
643:19, 651:21, 669:20, 669:21,
particularly [3] - 576:13, 594:3, 613:17
pieces [1] - 798:8
669:24, 686:24, 785:6, 785:7, 787:8,
parties [3] - 562:10, 672:10, 676:7
pins [3] - 575:15, 575:16, 575:17
795:14, 795:15, 795:19, 795:20, 796:1,
partner [1] - 757:1
place [9] - 624:4, 704:3, 764:20, 773:9,
796:6, 796:12, 800:18, 801:8
Partnership [1] - 707:13
776:13, 807:19, 860:1, 873:23, 873:25
percentage [5] - 643:17, 787:6, 797:1,
partnerships [4] - 699:11, 699:18,
placed [7] - 585:13, 585:17, 605:19,
797:8,
865:18
701:14, 701:16
618:5, 704:21, 797:25, 798:11
perform [2] - 580:15, 784:1
parts [2] - 790:22, 812:25
places [1] - 787:24
performed [1] - 714:1
party [1] - 719:11
plan [1] - 654:14
performing [1] - 649:11
Paso [3] - 789:9, 789:10, 791:20
planning [2] - 624:21, 844:23
perhaps [5] - 734:3, 735:22, 774:17,
Paso/Juarez [1] - 789:14
plans [2] - 848:20, 848:24
858:1, 863:7
pass [15] - 626:3, 626:13, 690:9,
plastic [1] - 691:25
period [17] - 589:8, 617:18, 619:5,
761:8, 766:25, 771:24, 774:22, 774:24,
play [1] - 625:21
640:18, 675:18, 686:23, 717:9, 787:10,
856:2, 856:3, 887:9, 887:19, 887:20,
pleadings [1] - 653:9
795:2, 799:18, 817:19, 823:20, 828:7,
887:21, 887:22
pleases [4] - 566:21, 566:23, 607:17,
831:16, 846:20, 846:23, 865:8
passed [4] - 569:15, 625:17, 625:18,
635:18
periods [1] - 605:21
626:10
pleasures [2] - 801:15, 802:3
permission [8] - 776:11, 793:20,
passing [1] - 584:24
pled [1] - 826:18
829:16, 829:18, 830:2, 830:8, 830:10,
past [3] - 601:17, 811:17, 888:18
plenty [1] - 565:22
830:11
patience [1] - 888:15
plugged [1] - 791:7
Persian [1] - 576:10
pattern [1] - 788:15
Plumingdon [1] - 792:23
person [14] - 571:22, 571:24, 587:20,
pause [1] - 856:8
plus [6] - 655:14, 744:19, 817:5, 821:2,
601:25, 628:24, 638:16, 657:1, 663:25,
pay [11] - 584:19, 589:17, 590:20,
821:4, 821:6
725:7, 738:16, 768:8, 780:16, 795:5,
592:5, 592:7, 611:23, 617:14, 753:21,
PO [2] - 560:14, 561:7
800:8
768:22, 768:24, 814:14
podium [2] - 776:8, 776:15
personal [13] - 602:7, 603:11, 674:19,
payable [2] - 672:5, 672:7
point [39] - 565:19, 574:8, 580:17,
704:3, 705:25, 706:14, 706:25, 729:20,
paycheck [3] - 758:25, 759:2, 759:6
582:12, 599:25, 612:12, 612:15,
749:17, 749:19, 760:21, 807:9, 850:23
paying [9] - 590:12, 592:2, 614:12,
614:16, 621:23, 652:12, 653:18, 669:7,
personally [8] - 670:21, 720:14,
655:19, 669:25, 670:1, 679:3, 679:8,
670:20, 677:21, 679:7, 700:15, 702:1,
720:19, 760:17, 760:18, 760:19, 769:3,
915
705:12, 715:24, 730:12, 745:17,
745:23, 746:12, 752:11, 774:10, 775:6,
775:10, 783:13, 787:12, 824:23,
829:23, 831:13, 832:10, 839:21,
839:25, 847:12, 859:6, 863:6
pointed [2] - 604:24, 817:6
pointing [1] - 578:24
points [2] - 651:9, 840:18
policies [2] - 665:17, 723:25
policy [42] - 580:8, 612:11, 614:9,
614:22, 615:10, 615:24, 617:4, 617:10,
617:25, 619:2, 619:11, 619:15, 725:13,
727:3, 727:7, 730:12, 762:9, 762:17,
770:22, 822:5, 822:9, 822:17, 823:11,
824:24, 825:3, 825:17, 825:20, 825:25,
826:10, 828:7, 828:15, 828:22, 829:1,
829:4, 829:19, 831:14, 831:19, 832:9,
832:10, 832:24, 877:15
popular [3] - 583:24, 590:1, 590:7
Portfolio [1] - 641:12
portfolio [10] - 586:18, 586:20, 641:13,
641:16, 679:18, 684:21, 686:24,
820:13, 820:22, 822:4
portfolios [2] - 587:11, 624:17
portion [9] - 616:9, 617:10, 665:8,
670:19, 726:5, 806:24, 809:3, 864:25,
865:5
portions [2] - 812:25, 878:21
position [10] - 570:14, 571:20, 711:11,
740:20, 743:6, 743:20, 781:18, 781:20,
782:25, 784:14
possession [1] - 617:22
possible [16] - 563:16, 564:1, 584:15,
590:15, 700:13, 713:11, 796:25, 829:9,
829:10, 829:11, 861:15, 861:16, 863:9,
863:10, 863:11, 885:6
possibly [1] - 574:10
postal [1] - 726:22
potential [5] - 563:19, 599:4, 739:3,
741:21, 741:25
practice [3] - 661:20, 664:2, 722:10
preadmitted [3] - 577:20, 577:22,
651:22
precious [1] - 682:15
precisely [2] - 606:14, 655:16
preclude [1] - 565:16
predicate [7] - 647:11, 649:18, 649:19,
649:23, 658:1, 658:16, 661:16
predict [1] - 659:18
predominant [1] - 598:16
predominantly [2] - 685:4, 685:5
prefer [2] - 791:1, 857:3
preferred [1] - 591:16
premium [1] - 617:15
preparation [3] - 665:4, 665:15,
888:14
prepared [4] - 563:16, 666:10, 752:2,
752:4
preparedness [1] - 563:15
preparing [4] - 599:7, 622:6, 645:3,
645:11
preponderance [1] - 660:5
presence [7] - 562:1, 630:18, 650:3,

profession [1] - 838:7
690:22, 737:23, 743:16, 827:6
professional [4] - 585:25, 669:19,
present [7] - 657:5, 673:4, 673:24,
669:21, 670:1
757:7, 757:17, 808:2, 808:8
professionalism [1] - 601:25
presentation [1] - 808:5
professionals [2] - 581:2, 611:3
presented [1] - 655:6
profit [1] - 612:8
preserved [1] - 702:23
profitable [1] - 755:4
president [8] - 574:1, 597:8, 597:9,
profits [3] - 612:2, 613:7, 613:8
597:16, 603:22, 678:15, 725:7, 784:16
program [13] - 583:25, 588:18, 588:20,
press [1] - 740:4
589:25, 590:8, 592:11, 592:17, 592:21,
Preston [1] - 561:3
594:25, 605:16, 704:9, 707:10, 778:21
pretrial [2] - 562:8, 562:21
progress [1] - 609:3
pretty [3] - 688:15, 712:5, 794:18
progressed [1] - 744:12
prevent [1] - 581:16
prohibited [1] - 692:7
previous [3] - 586:9, 683:13, 819:6
project [2] - 680:2, 812:23
previously [2] - 591:9, 626:8
projects [8] - 678:19, 678:25, 679:4,
679:9, 679:11, 679:15, 679:22
price [1] - 655:19
promised [1] - 738:3
primary [2] - 569:19, 699:6
promote [1] - 781:22
principles [1] - 732:14
promoted [2] - 570:16, 787:3
print [9] - 634:13, 801:6, 805:13,
805:15, 805:16, 805:20, 810:15,
promotional [10] - 788:8, 791:19,
810:19, 877:20
794:6, 794:10, 794:17, 797:21, 798:8,
805:25, 809:9, 833:15
printed [6] - 788:14, 803:14, 809:25,
proof [2] - 815:8, 839:17
810:11, 820:16, 877:17
printing [4] - 645:14, 810:22, 877:17,
propensities [1] - 737:14
877:19
proper [5] - 647:11, 648:15, 649:17,
printout [1] - 815:9
649:23, 661:16
privacy [1] - 579:17
properly [2] - 602:25, 603:17
private [13] - 605:25, 608:25, 609:6,
proposal [2] - 617:12, 691:4
609:8, 609:14, 614:9, 719:15, 724:2,
propose [1] - 639:14
809:18, 809:20, 821:19, 831:11
proposed [3] - 655:15, 720:16, 720:19
probative [2] - 739:19, 742:10
pros [1] - 651:2
probed [1] - 739:19
prosecution [1] - 737:10
problem [10] - 562:7, 564:5, 631:23,
prosecutor [3] - 770:24, 859:21, 868:7
656:5, 656:6, 691:10, 692:8, 692:11,
prosecutors [3] - 563:20, 656:3, 656:4
712:15, 772:22
prospective [4] - 599:24, 604:23,
problems [7] - 656:25, 713:23, 816:14,
803:16, 809:17
842:10, 842:20, 865:2, 877:19
prospects [11] - 589:2, 598:14,
proceed [7] - 567:18, 662:7, 692:24,
600:14, 619:20, 622:22, 637:9, 640:24,
695:1, 806:21, 828:2, 856:19
642:17, 644:18, 662:24, 803:12
Proceedings [2] - 561:13, 561:18
Prosperity [1] - 570:23
proceedings [1] - 889:4
protect [2] - 617:7
process [7] - 577:2, 622:8, 805:14,
protected [1] - 618:1
818:13, 819:15, 881:23, 886:1
protection [2] - 691:1, 763:4
processed [2] - 583:15, 583:17
protein [1] - 692:4
processes [2] - 750:11, 880:11
prove [7] - 632:24, 646:23, 648:9,
produce [3] - 806:3, 809:10, 842:23
648:12, 658:15, 660:17, 763:7
produced [8] - 561:13, 561:19, 636:8,
proved [3] - 649:13, 652:25, 653:25
788:11, 803:18, 803:21, 834:4, 846:11
provide [6] - 562:11, 605:25, 611:7,
producing [3] - 685:14, 804:3, 853:3
614:13, 769:19, 803:12
product [23] - 583:23, 589:6, 589:12,
provided [12] - 587:9, 587:15, 609:11,
590:1, 599:15, 628:4, 720:16, 721:1,
621:25, 637:7, 644:17, 666:2, 702:8,
721:5, 794:2, 794:19, 819:24, 821:15,
724:1, 775:23, 834:14, 834:22
822:21, 822:23, 870:22, 871:6, 871:7,
provides [1] - 611:14
871:12, 873:15, 877:10, 886:11
providing [3] - 603:10, 766:3, 807:8
producting [1] - 888:15
proving [1] - 661:14
production [6] - 684:22, 684:23,
provision [2] - 763:4, 763:13
685:2, 686:19, 812:14, 812:19
public [2] - 842:10
products [18] - 583:21, 601:19,
publication [1] - 821:16
601:24, 609:1, 612:8, 624:25, 626:21,
published [5] - 575:13, 751:14, 788:8,
685:1, 753:15, 783:7, 783:8, 787:3,
811:12, 821:10
788:18, 794:7, 848:25, 871:2
publishing [5] - 596:23, 597:1, 599:17,
916
645:8, 797:20
puddle [1] - 579:4
pull [9] - 568:4, 586:2, 616:23, 627:22,
671:18, 695:16, 739:22, 774:20, 866:22
pulling [1] - 578:2
punching [1] - 816:15
punctuation [1] - 599:18
purchase [1] - 708:17
purchased [3] - 614:18, 638:16,
736:14
purchaser [1] - 796:9
purchasing [1] - 736:22
purely [1] - 743:13
purports [1] - 614:22
purpose [26] - 615:21, 615:25, 637:17,
637:25, 638:1, 638:23, 638:24, 639:18,
640:6, 640:10, 640:13, 648:16, 649:2,
649:3, 663:1, 663:5, 696:22, 697:8,
699:6, 799:10, 802:14, 803:11, 804:12,
809:14, 844:3, 844:5
purposes [5] - 597:20, 638:1, 659:10,
729:7, 772:23
push [1] - 692:20
pushing [2] - 714:17, 827:19
put [43] - 584:23, 595:4, 596:24, 600:2,
612:24, 638:5, 647:22, 649:21, 651:1,
653:3, 661:10, 671:4, 671:13, 674:19,
688:21, 707:14, 708:6, 708:25, 729:6,
738:15, 756:1, 756:10, 779:11, 779:12,
779:13, 780:12, 796:5, 799:7, 813:19,
816:11, 834:22, 839:22, 853:11,
855:14, 855:17, 860:10, 866:9, 866:20,
874:15, 880:11, 886:7
putting [3] - 613:9, 820:18, 858:1
quicker [1] - 848:4

quickly [5] - 564:1, 586:17, 683:7,
683:24, 688:6
quit [4] - 745:17, 759:16, 759:17,
760:3
quite [5] - 596:17, 598:7, 704:15,
860:15, 885:6
quitting [1] - 758:23
realize [2] - 695:21, 801:20

realized [1] - 563:18
Really [1] - 757:23
really [18] - 589:12, 596:11, 619:24,
651:24, 678:14, 688:6, 711:20, 713:13,
767:12, 774:6, 774:18, 774:25, 775:21,
775:22, 789:13, 832:12, 856:24, 888:12
reason [15] - 661:14, 668:20, 683:23,
704:2, 711:6, 712:12, 714:9, 714:14,
714:25, 715:1, 741:18, 756:10, 809:4,
R
843:7, 877:2
reasonable [3] - 638:19, 639:25,
R.A [2] - 672:2, 675:17
651:15
racking [1] - 693:10
reasons [8] - 579:16, 580:1, 620:18,
radar [2] - 741:18, 741:19
659:21, 712:11, 738:2, 826:15, 854:22
rain [1] - 567:16
rebranding [1] - 621:13
raise [7] - 567:22, 616:5, 630:3, 691:9,
recap [1] - 885:11
739:10, 777:2, 829:12
receive [5] - 642:20, 803:15, 803:17,
raised [1] - 581:17
809:16, 809:18
raising [2] - 679:19, 822:3
received [12] - 625:18, 640:21, 662:22,
ran [2] - 650:16, 838:19
815:2, 840:24, 841:5, 841:16, 841:21,
random [1] - 665:23
844:19, 845:11, 845:14, 851:5
range [3] - 612:6, 624:25, 626:20
receiver [3] - 755:14, 755:16, 755:17
ranging [1] - 610:15
receiving [2] - 668:20, 841:10
rapidly [1] - 683:4
recent [2] - 634:6, 742:24
rate [14] - 584:5, 584:9, 589:9, 589:14,
reception [2] - 576:9, 583:4
590:4, 598:11, 717:7, 721:10, 799:24,
Recessed [4] - 630:17, 690:21,
801:6, 865:7, 865:9, 866:4, 886:19
775:11, 888:22
rates [19] - 584:10, 590:9, 590:10,
recognition [1] - 629:22
590:23, 598:12, 605:21, 606:1, 611:23,
recognize [12] - 575:7, 575:11, 600:12,
614:11, 641:1, 641:7, 641:8, 641:10,
622:20, 782:13, 798:5, 798:7, 800:25,
795:10, 795:12, 799:14, 800:17,
803:23, 811:4, 813:5, 870:1
865:10, 865:13
recognized [1] - 668:15
rather [4] - 662:16, 668:10, 808:25,
recollection [5] - 642:9, 676:21,
869:12
706:12, 885:8, 885:10
rattling [2] - 696:24, 697:5
record [17] - 572:6, 572:8, 608:10,
Q
reach [3] - 609:4, 652:13, 684:8
633:9, 633:17, 650:18, 652:18, 660:21,
reached [1] - 562:10
689:15, 775:18, 780:3, 780:5, 826:12,
qualifications [1] - 884:19
reaction [3] - 818:24, 830:24, 831:7
842:4, 842:11, 842:21, 889:4
qualified [4] - 627:5, 719:2, 719:3,
reactions [1] - 822:19
recorded [2] - 561:13, 561:18
732:5
read [33] - 582:24, 600:18, 601:15,
records [7] - 647:6, 649:5, 653:20,
qualify [3] - 648:20, 718:17, 765:10
603:5, 605:14, 608:23, 616:10, 617:9,
816:10, 816:11, 842:22, 843:23
quality [11] - 585:13, 591:15, 601:19,
635:24, 638:6, 638:8, 638:11, 639:23,
recross [1] - 767:1
601:23, 605:17, 609:1, 618:23, 623:25,
640:22, 661:4, 661:6, 664:9, 671:25,
RECROSS [2] - 767:3, 772:15
805:19, 837:1, 837:2
672:16, 675:15, 675:23, 683:18, 698:5,
recruiting [2] - 571:19, 573:20
quarter [18] - 609:24, 609:25, 610:2,
704:23, 726:19, 743:14, 747:16,
redeposit [3] - 617:20, 618:15, 762:24
610:5, 610:6, 610:9, 610:16, 610:17,
747:23, 760:14, 807:1, 813:7, 835:8,
REDIRECT [2] - 761:13, 772:7
628:13, 629:23, 632:5, 632:8, 632:14,
842:13
redirect [7] - 735:8, 735:9, 761:10,
641:16, 642:21, 821:8
Reader's [1] - 798:2
767:1, 771:2, 771:3, 772:1
quarterly [19] - 577:14, 629:15,
readily [1] - 701:15
refer [2] - 604:7, 783:19
629:18, 632:13, 632:25, 634:24,
reading [2] - 641:1, 683:25
reference [2] - 715:5, 774:1
635:10, 636:25, 637:3, 637:13, 640:16,
reads [3] - 602:19, 663:12, 669:5
referral [1] - 669:21
640:21, 642:7, 646:19, 684:12, 684:13,
ready [9] - 562:2, 567:18, 630:16,
referred [1] - 627:5
685:12, 769:4
630:21, 690:17, 743:22, 743:23, 775:6,
referring [4] - 604:7, 609:10, 671:2,
quarters [1] - 827:20
803:5
680:16
quasi [2] - 724:4, 724:6
real [30] - 593:20, 594:2, 594:25,
reflect [6] - 572:6, 572:8, 611:3,
quasi-governmental [1] - 724:4
604:2, 615:6, 642:1, 642:8, 655:5,
650:18, 780:3, 780:5
questions [15] - 610:21, 693:24,
678:19, 678:25, 679:15, 679:22, 692:1,
refresh [3] - 875:15, 875:18, 875:23
761:15, 761:19, 762:5, 763:15, 763:17,
699:10, 699:17, 699:24, 700:6, 700:8,
refreshes [1] - 876:4
763:23, 765:3, 765:5, 766:7, 805:9,
700:15, 700:25, 701:1, 701:14, 701:15,
regarding [19] - 566:4, 585:12, 607:8,
839:6, 848:5, 857:6
708:3, 709:3, 832:15, 832:17, 832:24,
633:24, 637:20, 648:22, 666:5, 668:14,
quick [4] - 635:6, 635:17, 819:2,
871:5, 885:11
668:21, 676:19, 678:6, 685:9, 713:12,
885:11
Real [1] - 707:13
917
731:18, 737:18, 738:8, 756:1, 761:16,
875:25, 876:17, 876:19, 877:2, 877:8,
represent [1] - 730:21
764:4
877:17, 879:7, 879:8, 879:22, 880:19,
representative [2] - 699:9, 829:21
880:20, 884:15, 885:6, 885:20, 888:17
regardless [1] - 772:9
representatives [2] - 642:25, 672:23
remind [2] - 763:3, 764:11
region [1] - 643:24
reproduce [6] - 828:11, 828:12, 829:6,
reminds [1] - 876:3
regions [2] - 643:25, 644:2
829:16, 830:2, 831:14
renegotiated [1] - 628:12
registered [2] - 666:20, 695:23
reproduced [1] - 829:19
renew [2] - 632:16, 822:17
regret [1] - 781:4
reproducing [1] - 833:7
renewal [1] - 619:9
regular [2] - 576:8, 692:9
reputation [2] - 601:18, 783:6
renewed [1] - 619:12
regularly [2] - 649:12, 753:17
request [2] - 567:3, 848:17
repaid [2] - 676:11, 764:13
regulated [2] - 579:12, 623:24
requests [1] - 583:15
repair [1] - 741:10
regulation [4] - 622:25, 623:19, 793:7,
require [3] - 660:12, 849:2, 849:4
794:1
repairs [1] - 669:23
required [6] - 563:3, 584:21, 584:22,
regulations [5] - 622:6, 622:9, 623:5,
repayment [1] - 672:8
612:25, 625:13, 636:18
793:17, 793:18
repeat [5] - 719:24, 720:10, 747:18,
requirement [3] - 627:9, 780:17,
regulators [1] - 794:3
747:19, 853:6
780:18
Regulatory [1] - 622:13
repeated [3] - 668:7, 673:4, 747:17
requirements [2] - 623:3, 785:1
regulatory [6] - 580:12, 580:13, 623:8,
Rephrase [1] - 882:14
reserve [1] - 584:22
627:16, 627:24, 714:22
rephrase [19] - 645:25, 646:2, 668:1,
reserves [1] - 590:20
reign [1] - 747:3
673:17, 677:23, 693:25, 720:11,
resident [1] - 601:20
720:12, 723:5, 747:25, 752:17, 753:22,
reimburse [1] - 581:19
residents [4] - 580:7, 580:9, 580:18,
831:4, 837:21, 859:18, 860:23, 861:1,
related [12] - 566:3, 573:16, 594:14,
627:7
881:7, 882:16
617:18, 650:23, 656:11, 672:10, 676:7,
resign [4] - 849:17, 851:1, 851:2,
rephrasing [1] - 753:6
728:7, 741:3, 761:24
851:24
replaced [1] - 730:11
relation [2] - 786:10, 825:13
resolve [1] - 566:10
replacing [1] - 687:9
relationship [12] - 574:22, 625:1,
resolved [1] - 562:25
reply [1] - 563:11
703:15, 730:14, 746:20, 749:16,
resources [1] - 854:19
749:17, 749:19, 766:6, 771:21, 811:17,
report [60] - 576:23, 596:25, 632:13,
respect [7] - 604:13, 653:19, 659:1,
849:13
633:1, 634:24, 640:16, 644:6, 644:8,
688:9, 738:21, 738:25, 831:1
relationships [3] - 586:24, 587:21,
644:9, 644:25, 663:10, 664:9, 665:7,
respectful [1] - 796:14
618:21
669:4, 670:24, 671:1, 671:3, 671:15,
respectfully [1] - 692:3
674:9, 675:2, 683:7, 683:8, 683:25,
relative [3] - 690:25, 739:2, 739:3
respective [2] - 665:2, 792:25
689:8, 733:5, 734:12, 740:24, 745:24,
released [1] - 645:5
respond [3] - 654:20, 654:22, 780:19
752:6, 752:8, 756:11, 764:4, 764:12,
relevance [13] - 615:17, 673:10,
response [5] - 563:1, 615:3, 654:12,
809:10, 809:12, 809:14, 809:22,
673:12, 758:17, 805:22, 805:23,
686:6, 826:19
810:10, 811:9, 811:11, 812:9, 812:14,
808:12, 830:25, 832:21, 847:18, 848:7,
responsibilities [4] - 574:3, 583:12,
812:19, 813:20, 813:23, 814:3, 815:1,
853:21, 853:22
665:2, 710:20
815:5, 817:12, 817:17, 817:18, 818:1,
Relevance [1] - 848:13
responsibility [2] - 665:5, 726:24
819:16, 819:19, 820:15, 821:10,
relevant [6] - 615:9, 665:12, 743:6,
responsible [3] - 587:18, 596:11,
821:14, 846:10, 846:15, 886:7
847:17, 847:25, 848:2
665:4
Report [3] - 663:12, 664:24, 810:9
religion [1] - 848:12
restart [1] - 564:20
reported [13] - 596:3, 596:9, 610:14,
rely [1] - 853:3
restaurant [1] - 680:3
675:3, 676:24, 683:18, 684:2, 735:24,
remain [1] - 856:7
restriction [1] - 580:4
741:12, 749:3, 749:6, 752:12, 820:5
remark [1] - 756:21
restrooms [1] - 630:9
REPORTER [1] - 827:14
remember [110] - 593:19, 604:16,
restructuring [1] - 597:19
Reporter [1] - 561:10
626:25, 629:10, 633:19, 678:22, 682:6,
result [1] - 710:12
reporter [5] - 567:13, 675:23, 710:9,
690:15, 694:5, 708:20, 708:21, 711:21,
resulted [1] - 602:7
775:16, 777:21
711:25, 715:4, 716:9, 716:11, 721:13,
results [1] - 666:9
REPORTER'S [1] - 889:1
722:1, 722:6, 725:15, 726:10, 737:8,
resume [2] - 690:17, 775:6
reporting [13] - 595:19, 595:24,
737:14, 743:24, 747:14, 750:12,
resum [4] - 686:15, 688:22, 780:20,
666:11, 687:22, 732:11, 744:9, 745:14,
755:25, 756:3, 761:4, 761:18, 763:17,
780:22
745:17, 745:22, 746:17, 750:21,
781:11, 783:9, 783:13, 785:10, 786:3,
return [9] - 562:23, 590:4, 603:10,
768:17, 810:16
786:5, 786:23, 788:16, 791:6, 791:10,
612:9, 717:7, 802:2, 802:3, 802:15,
reports [49] - 596:24, 632:23, 635:10,
791:14, 793:19, 795:23, 805:7, 810:21,
807:8
637:1, 637:3, 637:13, 640:21, 642:7,
810:22, 813:16, 815:18, 815:25, 816:8,
returned [1] - 839:2
642:21, 644:12, 644:21, 645:11,
816:13, 816:20, 824:11, 830:17,
returns [3] - 589:14, 798:9, 886:19
645:16, 646:4, 646:16, 646:19, 646:21,
831:25, 832:5, 832:8, 833:20, 850:22,
Review [3] - 608:22, 669:14, 715:3
647:6, 648:19, 651:11, 651:12, 654:4,
858:11, 863:14, 863:15, 864:14, 866:8,
review [9] - 599:10, 599:14, 599:15,
654:6, 657:25, 662:12, 662:18, 662:20,
866:10, 866:17, 866:18, 867:9, 867:14,
599:16, 646:12, 663:16, 721:17, 752:3,
664:1, 670:9, 671:12, 689:14, 750:21,
867:15, 867:23, 868:3, 868:7, 869:4,
752:4
751:7, 751:10, 751:11, 751:12, 751:17,
869:7, 869:25, 870:5, 870:7, 870:19,
reviewed [4] - 645:4, 648:23, 649:10,
764:1, 764:8, 764:16, 765:25, 767:6,
870:20, 870:21, 871:1, 871:23, 872:5,
751:14
769:4, 769:5, 774:15, 774:16, 820:1,
872:10, 874:14, 874:17, 874:19,
reviewing [2] - 645:11, 663:25
820:21, 880:12
874:21, 874:23, 875:4, 875:5,
875:6,
918
revise [2] - 794:11, 805:15
revisions [1] - 805:17
revoke [1] - 620:24
revoked [3] - 711:14, 712:14, 845:12
revoking [1] - 842:6
rich [3] - 800:8, 806:6
ride [5] - 740:10, 740:13, 740:15,
740:21
right-hand [4] - 582:24, 619:8, 641:20,
643:3
ring [2] - 701:8, 867:4
rise [1] - 652:10
rises [1] - 651:5
risk [11] - 592:15, 592:17, 592:20,
603:10, 674:20, 795:18, 795:19,
795:25, 796:5, 796:13, 807:8
risking [1] - 795:22
risks [1] - 581:5
RLP [2] - 707:12, 707:13
RMR [3] - 561:10, 561:16, 889:7
road [2] - 628:22, 678:3
Robert [2] - 560:21, 571:25
ROBERT [1] - 560:6
robust [1] - 730:19
rock [1] - 579:7
Rocky [1] - 687:14
role [5] - 577:4, 599:20, 601:4, 622:6,
645:10
rolled [3] - 621:21, 628:11, 696:20
rolls [1] - 634:25
room [6] - 617:23, 630:16, 650:19,
751:17, 858:19, 888:21
rose [1] - 828:23
route [1] - 678:1
RPR [2] - 561:10, 561:16
rug [1] - 576:10
rule [4] - 565:24, 657:25, 673:18,
776:7
ruled [2] - 577:18, 637:24
Rules [2] - 565:7, 660:13
rules [10] - 567:4, 651:14, 652:1,
652:3, 660:9, 660:10, 660:12, 735:22,
736:3, 763:21
ruling [3] - 635:20, 635:22, 652:14
run [1] - 650:9
running [14] - 577:8, 587:5, 597:12,
597:22, 597:25, 627:22, 650:1, 680:23,
725:7, 739:24, 760:22, 794:1, 811:25,
814:11
runs [2] - 581:15, 658:10
Rusk [2] - 561:11, 561:16
sales [16] - 575:2, 614:2, 626:12,

secretary [1] - 836:3
629:14, 631:4, 642:24, 642:25, 684:24,
Section [1] - 660:18
685:3, 685:10, 685:13, 702:10, 724:13,
section [4] - 664:21, 669:13, 671:20,
796:18, 796:24, 802:23
675:9
salespeople [5] - 588:4, 626:8,
sector [1] - 689:3
792:17, 797:15, 832:2
securities [6] - 605:18, 703:25,
salesperson [2] - 771:17, 792:25
718:19, 719:15, 765:7, 765:10
Salvador [3] - 778:7, 778:11, 853:14
security [12] - 716:25, 717:1, 718:6,
samples [1] - 665:24
718:8, 718:10, 718:14, 719:12, 719:13,
Sanchez [4] - 561:10, 561:16, 889:3,
773:11, 773:13, 802:7, 802:10
889:7
See [1] - 619:24
sanctions [1] - 806:10
see [78] - 572:1, 574:15, 576:19,
sat [1] - 595:23
577:12, 577:17, 582:7, 583:5, 593:8,
606:19, 610:13, 623:16, 630:15, 636:3,
satisfied [2] - 668:19, 687:10
636:5, 641:3, 643:4, 650:20, 652:17,
Saturday [2] - 850:14, 850:17
658:3, 658:17, 658:20, 668:20, 671:4,
save [1] - 800:13
673:17, 674:22, 675:13, 678:17,
savings [1] - 613:19
684:16, 685:25, 690:17, 690:20,
saw [20] - 621:16, 680:1, 680:7, 681:4,
692:14, 692:16, 694:15, 700:21, 701:3,
712:22, 716:16, 727:10, 744:12, 745:1,
713:9, 718:9, 718:14, 720:17, 727:3,
745:8, 746:16, 748:22, 764:4, 796:15,
731:2, 737:24, 738:10, 745:13, 751:12,
813:14, 818:13, 831:13, 863:15, 883:6,
751:16, 757:11, 760:7, 766:4, 767:25,
884:7
775:6, 775:7, 775:8, 776:2, 776:22,
scanned [1] - 810:6
779:23, 789:24, 790:2, 791:1, 806:16,
SCARDINO [22] - 563:2, 653:7,
810:5, 812:25, 816:11, 817:2, 818:6,
653:14, 654:13, 654:23, 655:5, 656:18,
827:4, 827:24, 835:6, 836:14, 842:3,
656:21, 657:8, 657:11, 664:14, 664:18,
860:4, 864:14, 864:25, 865:5, 879:11,
680:16, 691:21, 692:15, 692:17,
887:18
723:12, 739:24, 740:2, 864:21, 864:23,
seeing [5] - 583:13, 684:11, 816:20,
887:21
819:9,
875:25
Scardino [4] - 560:21, 560:21, 652:17,
seek [1] - 602:2
652:22
seem [6] - 699:25, 790:7, 803:2,
schedule [4] - 617:17, 619:1, 809:1,
813:24, 838:9, 859:12
827:18
Seguridad [1] - 802:11
scheduled [2] - 808:5, 808:15
seldom [1] - 602:7
school [5] - 569:16, 581:4, 780:24,
select [3] - 603:9, 612:7, 807:7
884:23, 884:25
sell [17] - 586:14, 613:12, 614:3, 629:3,
scope [1] - 770:15
629:8, 721:8, 721:9, 722:2, 722:10,
screaming [1] - 860:6
723:15, 793:14, 793:23, 795:7, 822:23,
screen [21] - 574:10, 574:14, 575:5,
848:25, 863:15, 873:15
575:9, 600:21, 617:10, 630:4, 636:4,
selling [20] - 628:4, 629:9, 702:3,
636:10, 650:2, 671:18, 690:19, 692:20,
722:18, 723:17, 731:5, 753:15, 765:4,
695:7, 774:21, 782:8, 782:10, 782:11,
765:7, 766:8, 766:11, 768:23, 783:8,
799:12, 827:25, 865:3
794:1, 797:6, 809:19, 822:20, 822:21,
scroll [5] - 666:15, 725:19, 726:3,
845:6, 862:24
726:4, 818:5
sells [2] - 719:11, 721:7
search [1] - 701:16
send [4] - 592:6, 779:12, 780:20,
seat [3] - 568:4, 648:11, 777:8
780:21
seated [8] - 567:15, 630:19, 630:24,
senior [1] - 779:1
662:6, 690:23, 692:22, 775:15, 856:7
sense [3] - 586:17, 763:13, 858:13
SEC [1] - 755:19
sent [5] - 600:13, 636:2, 636:5, 755:17,
sec [2] - 696:23, 856:12
821:11
second [35] - 565:4, 567:12, 568:25,
sentence [1] - 665:19
569:24, 582:22, 583:3, 586:2, 603:11,
S
separate [8] - 594:9, 594:22, 594:23,
607:22, 615:11, 626:11, 632:15,
637:15, 655:6, 658:10, 783:23, 783:24
641:11, 647:4, 649:24, 665:8, 673:6,
separated [1] - 786:12
safe [2] - 690:7, 701:17
681:12, 695:5, 720:5, 722:22, 723:3,
separately [1] - 637:13
safest [1] - 658:19
723:12, 739:21, 775:14, 778:21,
September [1] - 737:9
784:25, 800:25, 807:9, 826:11, 826:16,
safety [3] - 602:6, 603:7, 807:5
Series [1] - 625:12
843:9, 844:15, 864:20, 883:1
sake [1] - 651:5
series [1] - 655:16
secondary [2] - 718:7, 718:10
salary [9] - 588:7, 670:13, 670:18,
service [9] - 585:1, 587:16, 590:23,
secondly [1] - 651:14
785:1, 785:8, 785:12, 796:25, 797:9
601:24, 603:11, 609:9, 609:11, 668:19,
seconds [1] - 856:6
sale [1] - 627:1
807:9
secrecyRMR,
[1] - 579:17
Johnny C. Sanchez,
CRR - jcscourtreporter@aol.com
919
649:4, 663:1, 787:23, 791:20, 799:13,
someone [12] - 570:25, 571:18, 597:1,
839:14, 872:9
597:21, 627:25, 663:15, 685:15, 752:2,
shown [9] - 609:22, 615:22, 619:18,
768:4, 800:7, 811:14, 824:20
637:19, 640:7, 640:8, 640:12, 642:2,
sometime [1] - 591:21
649:4
sometimes [2] - 725:22, 797:16
shows [4] - 578:23, 610:11, 762:11,
somewhat [1] - 735:23
843:3
somewhere [5] - 579:6, 621:4, 621:5,
shut [2] - 843:6, 843:12
658:7, 852:20
shutting [1] - 844:9
sons [1] - 568:25
SIB [1] - 641:1
soon [2] - 595:21, 692:13
SIB's [1] - 641:7
sophisticated [1] - 768:5
siblings [1] - 594:16
sorry [75] - 566:22, 581:12, 585:19,
side [16] - 582:24, 597:23, 610:12,
598:18, 603:21, 605:15, 606:10,
610:13, 636:17, 639:23, 652:1, 652:3,
616:25, 626:16, 627:12, 627:20,
653:10, 654:2, 658:14, 661:12, 736:24,
631:15, 631:21, 633:15, 636:3, 654:20,
737:25, 775:13, 804:15
664:14, 664:21, 668:2, 671:13, 673:1,
sidebar [5] - 615:12, 616:3, 647:16,
675:21, 675:25, 681:8, 683:13, 695:17,
775:16, 870:14
698:10, 700:11, 700:23, 701:25,
704:14, 707:17, 707:24, 710:8, 714:12,
sides [1] - 651:2
720:5, 720:8, 720:9, 722:9, 723:4,
sight [1] - 579:2
724:20, 725:21, 726:6, 728:3, 730:21,
sign [8] - 666:24, 721:17, 721:20,
732:17, 733:19, 733:20, 736:16, 737:2,
722:6, 722:12, 722:13, 736:9, 790:5
738:7, 743:19, 745:5, 746:22, 759:11,
signature [4] - 722:14, 736:9, 818:6,
762:23, 775:10, 777:17, 778:5, 801:16,
818:7
808:11, 823:19, 824:13, 826:5, 828:18,
signed [3] - 602:12, 645:15, 646:11
833:9, 833:12, 841:4, 851:6, 857:5,
significant [3] - 643:6, 665:14, 691:24
860:14, 862:9, 862:11, 867:1, 870:11
signing [3] - 818:6, 818:11, 818:24
sort [4] - 571:6, 576:14, 599:19,
similar [6] - 611:8, 611:15, 658:4,
681:20
668:16, 672:12, 676:9
sound [5] - 622:18, 712:14, 722:13,
simple [3] - 565:13, 703:12, 733:21
733:15, 750:9
simpler [1] - 636:25
source [6] - 613:15, 613:16, 617:20,
simply [3] - 673:4, 719:10, 865:9
618:15, 667:16, 762:25
single [10] - 590:23, 633:10, 650:6,
South [3] - 783:21, 795:4, 803:6
650:10, 650:13, 660:2, 660:8, 660:25
SOUTHERN [1] - 560:1
single-service-type [1] - 590:23
southern [1] - 710:10
sit [4] - 761:3, 774:7, 776:5, 776:13
space [3] - 576:5, 576:8, 782:21
sitting [4] - 597:2, 597:14, 657:17,
Spanish [16] - 570:8, 571:1, 598:13,
872:24
599:11, 599:12, 754:19, 757:12,
situation [1] - 562:20
780:18, 783:5, 784:18, 799:16, 801:10,
six [6] - 563:7, 564:7, 564:9, 628:21,
801:19, 802:10, 807:24, 865:21
686:23, 837:8
Spanish-speaking [1] - 780:18
six-month [1] - 686:23
speaking [4] - 685:14, 737:8, 780:18,
size [2] - 667:7, 795:11
864:14
sleeping [1] - 809:7
special [8] - 577:15, 628:8, 629:18,
slow [5] - 675:20, 714:10, 736:15,
812:9, 812:12, 880:18, 880:19
749:21
specialize [2] - 603:8, 807:6
small [11] - 581:2, 596:20, 612:5,
specific [15] - 564:17, 604:10, 606:20,
667:8, 668:25, 703:2, 708:19, 709:3,
626:21, 680:2, 722:1, 722:7, 731:1,
710:3, 768:13, 836:15
732:12, 744:6, 757:21, 783:1, 849:20,
smart [1] - 728:24
865:18, 884:16
smidgen [1] - 865:12
specifically [8] - 573:20, 655:10,
smile [2] - 691:16, 691:22
655:15,
656:10, 715:23, 730:13,
snapshot [1] - 644:11
767:10,
815:14
sold [20] - 586:20, 589:12, 591:15,
specified [2] - 617:17, 651:19
628:1, 631:7, 685:4, 702:4, 702:5,
specify [1] - 651:23
702:7, 702:10, 718:7, 718:10, 721:15,
specifying [1] - 883:3
723:14, 723:19, 794:24, 795:2, 797:3,
speculating [2] - 882:3, 884:1
863:14, 870:23
speculation [4] - 882:8, 882:10,
solely [3] - 638:17, 723:19, 729:4
882:15,
882:19
solemnly [2] - 567:24, 777:3
speed [1] - 675:22
solicit [3] - 784:7, 784:13, 793:11
spell [2] - 777:21, 784:19
solved [1] - 692:11
spend [3] - 790:25, 792:14, 837:6
Services [18] - 572:22, 574:21, 576:24,

583:21, 588:7, 594:12, 596:13, 609:13,
621:20, 622:13, 698:12, 699:7, 702:2,
702:14, 707:8, 715:3, 863:24
services [17] - 569:20, 570:11, 571:2,
571:3, 574:25, 575:1, 587:9, 602:4,
609:2, 612:6, 621:25, 622:1, 670:4,
670:5, 783:25, 863:16, 863:17
session [1] - 692:5
set [18] - 565:12, 576:8, 586:24, 588:9,
618:22, 620:2, 624:17, 625:21, 694:10,
701:5, 701:10, 753:12, 815:8, 815:9,
819:21, 819:24, 861:21, 869:23
setting [4] - 594:6, 737:3, 783:6,
845:17
seven [2] - 572:21, 709:25
several [6] - 584:18, 620:18, 687:2,
694:3, 737:13, 757:7
severe [1] - 656:2
sexual [2] - 739:3, 740:16
SGC [1] - 747:8
shall [3] - 617:13, 662:3, 726:21
shape [1] - 575:15
share [12] - 585:5, 589:1, 592:22,
640:24, 644:17, 662:23, 692:17,
692:18, 700:3, 700:4, 765:14, 845:5
shared [2] - 719:18, 814:23
shareholder [4] - 613:5, 752:17,
752:21, 752:25
shareholders [5] - 603:2, 612:1,
612:16, 612:17, 763:21
shares [1] - 591:16
sheet [1] - 598:12
sheets [1] - 598:11
shell [2] - 620:2, 762:19
shift [1] - 589:24
ship [1] - 677:11
shirt [1] - 780:2
shocked [1] - 858:8
shoes [2] - 721:7, 721:8
shop [1] - 845:17
short [11] - 586:15, 603:8, 606:6,
606:7, 607:3, 650:1, 674:21, 688:8,
703:24, 807:6, 827:9
short-term [7] - 586:15, 603:8, 606:6,
607:3, 674:21, 703:24, 807:6
shortage [1] - 726:18
shortcut [2] - 654:8, 654:10
shortened [1] - 777:25
shorting [1] - 704:17
shot [1] - 582:19
show [32] - 619:20, 634:1, 640:6,
643:6, 750:14, 787:23, 790:20, 791:15,
791:19, 792:8, 798:4, 798:25, 799:1,
804:18, 811:2, 820:10, 822:10, 826:16,
833:23, 839:9, 841:19, 842:8, 842:18,
842:19, 843:21, 843:25, 844:14, 845:3,
846:6, 868:10, 875:15
showed [13] - 575:25, 609:24, 610:9,
616:14, 616:19, 762:8, 791:20, 822:4,
830:15, 830:22, 833:10, 837:3, 850:20
showing [10] - 615:22, 638:18, 646:13,
920
710:16, 713:19, 719:18, 720:20,
605:2, 605:9, 616:17, 616:18, 620:15,
spent [3] - 650:15, 654:24, 787:9
721:12, 724:12, 732:22, 733:11,
621:20, 647:15, 683:9, 683:21, 684:5,
spirit [1] - 565:6
733:17, 736:14, 743:12, 744:12, 745:2,
686:15, 687:14, 689:13, 700:15, 702:2,
spoken [1] - 737:12
745:8, 745:11, 745:14, 745:18, 746:1,
709:1, 713:18, 744:3, 744:18, 745:22,
Spring [1] - 778:3
746:14, 747:7, 747:8, 749:6, 750:17,
747:8, 775:4, 779:14, 784:23, 785:16,
St [2] - 666:20, 667:12
752:8, 752:10, 753:12, 754:8, 754:22,
785:20, 786:1, 787:5, 794:6, 794:14,
stability [1] - 602:8
754:25, 756:1, 756:19, 757:5, 757:22,
809:23, 812:8, 813:19, 820:6, 823:21,
stack [1] - 671:11
758:23,
760:8,
761:16,
761:23,
762:12,
838:10
stand [14] - 586:3, 595:15, 630:16,
762:13, 762:14, 762:18, 763:3, 763:12,
starting [7] - 562:4, 571:18, 610:21,
634:17, 690:18, 698:10, 776:1, 776:13,
764:5, 764:17, 764:23, 765:13, 766:15,
706:13, 785:22, 835:6, 849:3
776:15, 794:22, 856:5, 870:12, 888:21
766:20, 768:2, 768:22, 768:25, 772:10,
state [12] - 625:25, 652:8, 658:8,
standard [2] - 664:2, 767:21
772:23, 779:20, 779:22, 779:23, 780:8,
659:25, 660:11, 666:8, 668:5, 673:15,
standards [8] - 665:11, 666:12,
781:13, 781:25, 782:4, 782:18, 782:24,
723:1, 738:16, 750:6, 776:4
732:25, 734:4, 734:12, 763:16, 764:21,
784:5, 784:21, 784:22, 785:14, 785:17,
statement [6] - 638:19, 639:25, 647:1,
772:9
785:23,
786:7,
786:10,
786:15,
786:24,
672:16,
762:22, 826:18
standing [5] - 572:3, 624:1, 685:12,
787:9, 787:19, 788:20, 791:12, 791:17,
statements [19] - 583:19, 638:14,
686:1, 872:24
792:14, 793:6, 794:8, 794:25, 795:9,
638:15, 646:25, 647:3, 665:1, 665:5,
stands [3] - 600:22, 715:4, 732:14
796:15,
796:17,
796:23,
797:14,
665:6, 665:13, 665:16, 666:1, 666:6,
STANFORD [1] - 560:6
802:22, 804:7, 805:2, 805:4, 805:5,
666:7, 681:2, 686:6, 721:21, 765:20,
Stanford [452] - 571:25, 572:1, 572:6,
805:11, 805:19, 807:17, 808:3, 808:23,
818:11, 819:3
572:11, 572:13, 572:17, 573:1, 573:6,
809:13, 809:24, 811:10, 811:14,
States [22] - 567:20, 601:20, 604:4,
573:7, 573:24, 575:14, 575:21, 575:23,
811:23, 812:1, 812:2, 812:4, 812:10,
611:11, 627:3, 643:17, 643:18, 695:13,
576:25, 577:1, 577:10, 577:12, 579:14,
812:22, 813:9, 813:10, 813:11, 813:15,
695:23, 766:11, 770:5, 777:1, 778:8,
579:25, 584:14, 585:7, 586:8, 586:12,
814:19, 815:13, 815:19, 815:25, 816:2,
778:9, 778:10, 778:17, 793:10, 793:11,
586:17, 586:22, 587:3, 587:14, 587:17,
816:3, 816:9, 816:15, 816:25, 817:20,
793:15, 793:23, 794:2, 794:25
587:25, 590:15, 590:25, 591:11,
818:2, 821:9, 821:20, 822:2, 822:15,
STATES [3] - 560:1, 560:4, 560:10
591:18, 592:16, 592:21, 593:1, 593:6,
823:21, 824:4, 825:11, 825:14, 825:19,
states [2] - 639:24, 676:11
593:13, 593:17, 593:22, 594:18,
825:21, 828:23, 829:23, 830:14,
stating [1] - 607:25
594:19, 594:24, 595:8, 596:2, 596:6,
830:16, 830:18, 831:7, 831:13, 831:24,
status [1] - 612:4
596:10, 596:16, 597:12, 597:24, 598:5,
832:3, 832:9, 833:10, 833:16, 834:17,
stay [2] - 567:6, 712:20
599:6, 599:20, 601:3, 602:12, 603:21,
834:18, 834:20, 834:21, 834:23,
stayed [2] - 679:17, 701:24
603:24, 603:25, 604:3, 604:5, 604:6,
834:25, 835:10, 835:20, 835:23, 836:3,
steam [1] - 627:22
604:7, 604:8, 604:10, 604:13, 604:18,
836:9, 837:12, 837:13, 837:17, 838:10,
STELLMACH [227] - 565:25, 566:2,
604:24, 605:6, 605:8, 606:3, 606:11,
838:13, 838:17, 838:18, 839:1, 839:3,
566:7, 566:9, 566:14, 566:16, 567:8,
606:15, 606:18, 606:23, 606:24, 607:5,
839:7, 839:25, 841:13, 842:9, 842:19,
567:20, 568:7, 568:12, 569:6, 570:10,
607:18, 608:1, 608:5, 611:1, 611:2,
843:1, 843:22, 844:1, 844:8, 844:14,
571:14, 571:23, 572:5, 572:9, 573:22,
612:12, 612:14, 612:24, 613:6, 613:20,
844:23, 845:3, 845:5, 845:7, 845:9,
574:8, 574:15, 574:17, 576:17, 577:16,
614:6, 614:16, 616:15, 616:19, 617:4,
845:10, 845:22, 846:19, 846:20,
577:20, 578:3, 578:7, 578:12, 578:20,
617:25, 618:9, 618:17, 618:24, 619:11,
846:22, 847:11, 848:10, 848:20, 849:6,
579:11, 579:24, 582:12, 582:15,
620:1, 620:16, 621:10, 621:14, 621:15,
849:14, 849:16, 849:21, 850:14,
582:16, 584:8, 585:23, 586:7, 593:8,
621:21, 622:4, 622:5, 622:24, 623:1,
850:16, 851:12, 851:23, 853:4, 853:11,
593:10, 598:24, 600:3, 600:9, 600:15,
623:6, 623:18, 623:23, 624:10, 624:12,
853:15, 853:19, 854:10, 854:12, 855:2,
600:17, 600:23, 601:1, 601:8, 601:9,
624:19, 625:3, 625:8, 625:22, 626:6,
858:18, 858:21, 861:21, 861:22,
601:12, 601:14, 602:16, 602:17,
626:9, 626:15, 626:19, 628:3, 629:2,
861:25, 862:4, 863:8, 864:7, 868:5,
606:13, 606:21, 607:4, 608:18, 608:19,
629:6, 629:11, 629:13, 629:21, 635:11,
868:11, 868:19, 869:2, 869:12, 869:16,
609:18, 609:21, 614:20, 615:2, 615:5,
636:2, 636:6, 641:25, 644:5, 644:22,
870:23, 871:8, 871:9, 871:11, 871:16,
615:10, 615:14, 615:22, 616:8, 617:3,
645:2, 645:19, 646:4, 662:16, 663:18,
877:23, 879:2, 879:6, 879:14, 881:10,
619:25, 620:10, 620:12, 623:15, 628:2,
663:24, 666:13, 667:3, 667:6, 667:19,
884:8, 886:2
630:1, 631:1, 631:2, 632:21, 634:4,
668:4, 668:7, 668:14, 668:18, 669:10,
Stanford's [23] - 580:8, 597:6, 603:4,
635:4, 635:7, 635:8, 635:14, 636:1,
669:11, 669:12, 670:3, 670:6, 670:11,
603:19, 629:4, 644:12, 670:17, 736:2,
636:11, 636:14, 636:23, 636:24,
670:15, 670:16, 670:21, 672:2, 672:5,
762:19, 781:15, 805:24, 811:17,
637:12, 637:18, 638:3, 638:7, 638:10,
672:6, 672:14, 672:20, 672:24, 673:4,
811:25, 822:19, 834:24, 835:13,
638:24, 639:2, 639:4, 639:6, 639:8,
673:9, 674:4, 674:6, 674:17, 675:17,
836:12, 837:12, 837:16, 837:24, 842:6,
639:14, 639:19, 640:2, 640:8, 640:14,
676:15, 676:20, 677:3, 677:5, 678:5,
843:2, 847:21
640:15, 643:9, 643:10, 643:21, 646:2,
678:19, 678:25, 679:15, 679:21,
Star [2] - 682:2, 682:5
646:3, 646:9, 646:13, 647:1, 647:15,
680:11, 680:23, 681:7, 681:11, 681:12,
start [9] - 564:5, 572:10, 595:21,
648:14, 648:18, 648:21, 649:3, 649:9,
681:21, 682:1, 682:10, 682:12, 682:14,
595:24, 642:13, 660:19, 661:24, 740:4,
649:19, 653:19, 654:5, 654:10, 655:10,
682:17, 684:4, 684:11, 684:16, 685:2,
785:18
655:12, 655:14, 655:19, 658:23, 659:1,
685:8, 686:4, 686:12, 687:4, 687:24,
started [58] - 564:18, 569:12, 570:15,
659:6, 660:24, 662:9, 662:10, 662:25,
688:20, 689:5, 689:23, 694:11, 695:12,
571:10, 573:25, 574:1, 576:23, 577:4,
663:7, 663:8, 664:11, 664:16, 664:19,
695:21, 695:22, 695:24, 696:1, 696:2,
580:4, 580:21, 580:22, 583:20, 588:19,
664:22, 666:15, 666:18, 667:1, 667:2,
696:12, 696:20, 696:21, 697:14,
588:21, 589:25, 591:18, 591:21,
667:25, 668:3, 668:11, 668:12, 671:6,
697:22, 698:25, 699:2, 699:23, 701:4,
591:22, 592:21, 595:22, 595:24, 597:6,
671:8, 671:11, 671:14, 671:22, 671:24,
706:10, 706:16, 706:23, 710:13,
921
673:3, 673:7, 673:14, 673:19, 673:22,
741:11
T
673:23, 674:15, 674:16, 675:1, 675:6,
subjects [1] - 778:15
675:12, 676:10, 677:22, 677:25, 678:4,
submit [2] - 650:16, 843:12
table [2] - 572:3, 639:11
680:6, 680:10, 680:18, 680:20, 683:13,
submitted [2] - 651:15, 656:22
tail [1] - 632:2
683:14, 686:2, 686:3, 689:1, 689:11,
Subpart [1] - 618:14
tailored [1] - 718:1
689:22, 690:9, 713:6, 715:5, 715:8,
Subsection [2] - 762:21, 762:23
talks [4] - 780:15, 791:25, 809:8,
715:10, 715:12, 718:15, 718:19, 720:3,
subsequent [1] - 632:4
845:25
722:21, 729:24, 731:20, 734:17,
subsequently [2] - 625:5, 706:18
tangent [1] - 742:19
737:17, 738:20, 738:24, 739:3, 739:9,
subsidiaries [1] - 761:24
739:15, 739:18, 739:23, 740:7, 740:13,
target [1] - 796:2
subsidiary [4] - 694:5, 694:7, 694:8,
740:15, 741:3, 741:8, 741:16, 741:24,
targeted [2] - 651:18, 655:16
696:1
742:10, 742:22, 742:24, 743:2, 743:5,
targeting [1] - 802:23
substantial [2] - 786:6, 839:17
747:10, 747:15, 756:12, 758:17,
tax [11] - 579:19, 579:25, 580:2,
substantially [3] - 563:2, 563:4,
761:11, 761:14, 766:25, 770:14, 771:5,
584:19, 590:21, 612:4, 752:16, 752:19,
785:13
771:9, 772:2, 772:5, 772:8, 772:14,
752:22, 752:24, 772:23
substantiation [1] - 740:18
774:1, 774:6, 774:18, 774:20, 775:1
taxed [1] - 580:3
success [2] - 601:17, 611:4
Stellmach [2] - 560:16, 566:1
team [2] - 691:7, 796:24
success-oriented [1] - 611:4
stenography [2] - 561:13, 561:18
technical [2] - 574:18, 829:5
successful [1] - 847:6
step [2] - 677:24
technically [3] - 635:12, 829:10,
sue [4] - 769:23, 770:13, 771:12
step-by-step [1] - 677:24
829:11
sufficient [1] - 562:24
stepped [1] - 687:5
technician [1] - 694:21
sufficiently [1] - 562:12
stepping [1] - 597:25
telephones [1] - 576:9
suggest [1] - 692:3
sticking [1] - 579:7
tellers [3] - 576:18, 585:2, 681:19
suggestion [1] - 659:7
still [18] - 562:24, 597:2, 598:2,
temperature [1] - 775:20
Suisse [2] - 587:8, 592:25
598:25, 621:3, 628:22, 675:23, 749:16,
ten [2] - 569:13, 744:3
suit [1] - 780:2
791:19, 821:9, 834:5, 838:3, 843:4,
tendency [1] - 675:22
summation [1] - 801:24
846:1, 846:3, 846:13, 876:25, 877:7
tender [1] - 633:22
Sun [1] - 681:24
stock [4] - 591:16, 765:17, 765:21
tense [1] - 849:15
supplementing [1] - 563:25
stocks [1] - 624:17
tenure [3] - 684:10, 689:12, 847:20
supporting [1] - 674:23
stood [1] - 572:7
term [16] - 586:10, 586:15, 589:15,
supposed [12] - 644:1, 656:15,
stop [9] - 639:10, 660:20, 696:24,
603:8, 605:24, 606:6, 607:3, 618:18,
734:12, 793:8, 793:10, 833:21, 838:24,
720:6, 751:9, 845:22, 856:5, 887:7,
674:21, 698:16, 703:24, 731:18,
855:7, 872:13, 873:2, 873:5, 874:3
887:11
733:15, 807:6, 823:14, 832:13
supposedly [5] - 617:25, 618:18,
stops [1] - 677:12
termed [1] - 794:23
619:3, 641:13, 763:5
store [3] - 721:7, 741:10
terminology [1] - 773:9
Supreme [3] - 634:8, 634:15, 658:5
storm [1] - 712:17
terms [13] - 574:2, 591:4, 613:2, 621:3,
surface [1] - 573:18
story [1] - 582:22
643:23, 648:24, 668:24, 672:8, 672:12,
surprise [2] - 831:9, 838:11
strange [2] - 881:14, 881:16
676:8, 679:14, 798:9, 805:20
surprised [5] - 672:17, 682:24, 819:1,
strategy [6] - 591:13, 602:14, 747:4,
terrible [1] - 698:5
859:24, 859:25
766:2, 772:11, 795:13
test [8] - 625:15, 625:16, 625:18,
surveillance [1] - 741:20
Street [1] - 560:22
626:10, 626:13, 665:12, 665:20, 665:23
sustain [4] - 668:8, 743:15, 844:4,
street [1] - 576:19
testified [15] - 568:9, 649:10, 654:6,
887:6
strength [2] - 600:22, 602:8
693:6, 696:11, 714:6, 719:17, 738:14,
sustained [24] - 569:5, 576:16, 579:23,
strengthened [1] - 714:22
744:18, 744:22, 746:1, 754:8, 777:10,
636:10, 647:17, 685:17, 689:20,
stressed [3] - 852:23, 854:22, 854:23
857:12, 867:8
718:21, 734:19, 737:20, 741:5, 756:13,
stressful [5] - 852:7, 852:9, 852:15,
testify [6] - 697:20, 733:10, 759:21,
800:11, 804:16, 808:13, 824:17,
852:23, 853:1
851:9, 870:11, 872:15
828:20, 831:5, 843:17, 844:16, 852:19,
stretch [1] - 856:6
testifying [10] - 566:10, 585:23,
854:1, 868:1, 870:17
606:11, 729:25, 731:20, 743:24, 746:2,
strict [5] - 622:25, 623:3, 623:4,
swaps [2] - 704:17, 705:23
755:7, 857:20, 882:23
623:19, 794:4
swear [2] - 567:24, 777:3
testimony [18] - 567:25, 688:16,
strictly [2] - 567:11, 623:24
sweetheart [1] - 569:13
696:11,
719:10, 733:14, 755:25, 756:1,
strip [1] - 691:25
switch [7] - 626:9, 695:6, 806:10,
766:16, 777:4, 824:16, 851:7, 858:3,
strong [1] - 617:23
808:18, 856:11, 856:13, 866:25
858:8, 859:15, 868:24, 882:10, 882:13,
stronger [1] - 714:22
switched [3] - 626:5, 739:25, 768:16
888:16
structure [7] - 588:9, 748:22, 761:16,
switching [1] - 767:6
TEXAS [1] - 560:1
761:23, 769:17, 770:25, 771:19
Switzerland [5] - 587:8, 705:11,
Texas [22] - 560:4, 560:15, 560:23,
structures [2] - 769:12, 771:6
705:13, 705:15, 706:5
561:4, 561:7, 561:11, 561:17, 568:18,
studies [1] - 570:7
sworn [3] - 567:23, 568:9, 777:10
570:5, 577:7, 594:3, 626:1, 626:2,
study [2] - 625:14, 778:13
symbol [1] - 575:8
778:3, 778:12, 778:13, 778:23, 779:2,
studying [1] - 778:12
system [4] - 675:8, 732:19, 753:12,
835:16, 835:22, 835:24, 862:1
stuff [3] - 838:23, 844:5, 860:2
770:3
text [4] - 602:21, 603:5, 608:21, 608:23
subject [4] - 655:22, 737:19, 741:4,
THE [534] - 560:10, 560:13, 560:20,
922
561:2, 562:2, 562:7, 563:1, 563:4,
563:8, 563:13, 564:2, 564:7, 564:12,
564:21, 565:9, 566:1, 566:6, 566:8,
566:13, 566:15, 566:20, 567:3, 567:9,
567:15, 567:22, 568:4, 568:24, 568:25,
569:1, 569:5, 570:1, 570:2, 570:3,
570:4, 571:16, 571:17, 572:8, 573:4,
573:6, 573:7, 573:9, 573:10, 573:11,
574:13, 576:16, 577:21, 577:24, 578:8,
578:15, 578:19, 578:25, 579:2, 579:5,
579:7, 579:9, 579:10, 579:23, 582:14,
584:2, 584:4, 584:7, 586:1, 586:6,
598:15, 598:17, 598:19, 598:20,
598:21, 598:22, 598:23, 600:2, 600:5,
600:7, 600:25, 606:19, 606:23, 607:1,
607:19, 607:21, 607:22, 607:24,
607:25, 608:3, 608:4, 608:5, 608:8,
608:12, 608:15, 614:25, 615:3, 615:8,
615:11, 615:13, 615:15, 615:18,
615:20, 615:25, 616:4, 616:23, 616:25,
617:1, 617:2, 619:21, 619:22, 623:10,
623:12, 623:13, 623:14, 627:18,
627:20, 627:21, 627:23, 630:3, 630:19,
630:24, 632:18, 633:3, 633:6, 633:10,
633:14, 633:19, 634:1, 634:6, 634:10,
634:12, 634:15, 634:17, 635:2, 635:6,
635:12, 635:16, 635:21, 635:23,
636:10, 636:13, 636:15, 637:16,
637:21, 637:24, 638:5, 638:8, 638:12,
639:1, 639:3, 639:5, 639:7, 639:9,
639:16, 639:22, 640:3, 640:10, 643:7,
643:16, 643:19, 643:20, 645:21,
645:23, 646:6, 646:7, 646:8, 646:20,
647:4, 647:9, 647:12, 647:17, 647:24,
648:1, 648:4, 648:8, 648:17, 648:19,
649:1, 649:8, 649:13, 649:16, 649:24,
650:4, 650:18, 651:1, 651:8, 651:20,
652:7, 652:24, 653:3, 653:8, 653:13,
653:16, 653:24, 654:3, 654:7, 654:12,
654:22, 655:4, 655:9, 655:11, 655:13,
656:1, 656:20, 657:6, 657:9, 657:12,
657:14, 657:19, 657:22, 658:25, 659:4,
659:8, 659:20, 660:10, 660:14, 660:20,
661:3, 661:5, 661:7, 662:3, 662:6,
663:4, 664:10, 664:13, 664:20, 668:1,
668:8, 671:4, 671:7, 671:10, 671:13,
673:5, 673:6, 673:11, 673:16, 673:20,
674:13, 674:22, 674:24, 674:25,
675:20, 675:21, 675:22, 675:25, 676:1,
676:2, 677:20, 677:23, 678:2, 685:17,
688:19, 688:21, 688:25, 689:10,
689:20, 690:10, 690:23, 691:10,
691:15, 691:18, 691:20, 692:12,
692:16, 692:19, 692:22, 692:25,
693:18, 693:20, 694:18, 695:2, 695:5,
695:10, 695:16, 695:17, 696:23, 697:4,
697:7, 709:14, 709:15, 709:16, 713:8,
713:9, 714:10, 718:18, 718:21, 719:7,
720:5, 722:22, 723:2, 723:3, 723:4,
723:5, 723:7, 723:8, 724:22, 725:19,
725:22, 725:24, 726:1, 730:2, 730:7,
730:8, 730:9, 731:24, 734:15, 734:19,
734:25, 735:3, 735:4, 735:5, 735:9,
735:10, 735:11, 735:16, 736:15,

592:12, 628:19, 628:20, 631:7, 631:14,
736:18, 737:20, 737:22, 737:24, 738:6,
631:16, 631:17, 631:20, 632:8, 724:7
738:9, 739:2, 739:8, 739:14, 739:17,
thousands [3] - 729:18, 744:24,
739:21, 739:25, 740:3, 740:8, 740:14,
744:25
740:20, 741:1, 741:5, 741:15, 741:23,
three [32] - 563:25, 564:3, 564:19,
742:9, 742:20, 742:23, 743:1, 743:3,
564:24, 568:19, 570:16, 570:24, 583:9,
743:6, 743:14, 747:11, 747:14, 747:16,
583:10, 586:20, 620:14, 667:10, 675:5,
747:18, 747:19, 747:23, 748:23, 749:1,
686:22, 709:10, 741:13, 745:19,
749:21, 749:25, 750:1, 750:2, 750:4,
746:13, 784:9, 784:10, 790:6, 790:8,
750:5, 753:6, 755:22, 756:13, 757:3,
798:10, 803:20, 827:20, 846:24,
758:19, 759:10, 759:12, 761:6, 761:9,
846:25, 863:13, 864:8, 864:9, 872:4
767:1, 770:17, 770:21, 771:1, 771:3,
three-quarters [1] - 827:20
771:8, 771:23, 771:25, 772:3, 772:6,
throughout [1] - 689:12
774:5, 774:7, 774:19, 774:24, 775:3,
throwing [1] - 736:17
775:10, 775:12, 775:17, 777:2, 777:7,
tighten [1] - 661:14
777:8, 780:5, 781:8, 790:16, 790:22,
timeframe [5] - 689:10, 708:25,
797:10, 797:12, 798:18, 798:24, 799:3,
831:20, 888:3
799:6, 800:11, 800:20, 800:21, 800:23,
timely [6] - 652:9, 656:7, 657:6, 657:9,
801:23, 802:1, 804:12, 804:16, 805:23,
658:13, 658:14
806:2, 806:3, 806:9, 806:11, 806:13,
timer [1] - 636:18
806:16, 806:20, 806:22, 808:13, 818:7,
timing [1] - 776:21
824:15, 824:17, 825:5, 825:7, 826:7,
title [8] - 573:25, 574:1, 595:17, 597:7,
826:11, 826:14, 826:19, 826:22,
597:16, 597:20, 601:10, 626:5
826:24, 827:4, 827:7, 827:14, 827:15,
today [12] - 562:16, 565:4, 572:2,
827:24, 828:3, 828:20, 831:3, 832:22,
656:11, 688:16, 692:2, 694:22, 719:10,
832:25, 833:1, 833:3, 833:5, 833:6,
720:2, 755:7, 779:24, 858:3
833:9, 833:12, 834:5, 834:8, 836:18,
together [9] - 565:15, 637:1, 707:14,
836:19, 836:22, 837:22, 838:4, 838:5,
708:25, 716:19, 779:11, 779:13,
840:21, 842:3, 842:7, 842:12, 842:17,
820:18, 858:1
842:24, 843:5, 843:9, 843:14, 843:17,
tomorrow [3] - 694:21, 694:22, 776:15
843:20, 843:21, 843:23, 844:4, 844:11,
tone [1] - 734:18
844:15, 847:18, 847:22, 848:3, 848:6,
tonight [1] - 887:18
848:8, 848:14, 850:5, 850:6, 850:7,
took [18] - 569:14, 570:7, 582:17,
851:8, 851:15, 852:3, 852:4, 852:5,
613:6, 676:22, 708:7, 710:20, 711:11,
852:6, 852:13, 852:18, 853:22, 854:1,
750:16, 758:7, 758:8, 776:20, 787:18,
854:9, 854:11, 854:13, 854:20, 855:11,
819:1, 858:9, 859:16, 860:1, 877:2
855:14, 855:21, 855:23, 856:3, 856:9,
top [20] - 601:10, 601:18, 602:18,
856:12, 856:15, 856:18, 856:20,
603:4, 608:21, 608:23, 610:22, 611:21,
859:18, 860:4, 860:7, 860:10, 860:14,
616:9, 629:24, 640:17, 669:16, 684:1,
860:16, 860:19, 861:1, 861:9, 862:7,
706:10, 791:21, 804:20, 806:24,
862:10, 862:12, 864:20, 865:2, 867:2,
823:24, 837:8, 848:18
868:1, 870:17, 873:7, 873:8, 873:9,
topic [3] - 588:22, 674:3, 833:15
876:7, 876:10, 876:12, 882:14, 882:18,
topics [2] - 566:4, 566:12
883:1, 883:4, 883:7, 884:6, 884:9,
total [4] - 650:5, 709:11, 710:1, 849:4
884:12, 885:13, 885:17, 887:5, 887:8,
Total [2] - 683:15, 683:25
887:11, 887:15, 887:17, 887:20,
totaled [1] - 676:5
887:23, 888:2
totally [1] - 601:21
theirs [1] - 658:13
tour [1] - 678:16
theme [1] - 576:11
tourism [1] - 790:22
theory [2] - 729:13, 729:14
toward [9] - 582:24, 586:2, 609:18,
therefore [7] - 611:10, 612:9, 717:25,
619:8,
683:15, 684:1, 684:10, 783:21,
719:14, 732:25, 743:11, 750:15
836:7
they've [6] - 565:14, 565:20, 633:10,
towards [7] - 749:15, 749:16, 847:10,
636:16, 651:11, 844:12
849:14,
853:2, 860:11, 862:10
thinking [4] - 631:13, 631:15, 861:8,
Tower
[3] - 570:23, 571:8, 571:9
861:13
town
[1] - 687:4
third [7] - 600:16, 603:23, 626:12,
tracking [1] - 629:14
659:16, 684:1, 719:11, 782:23
tradeable [2] - 719:14, 719:16
third-generation [1] - 603:23
tragic [1] - 711:17
thirdly [1] - 842:20
trailing [2] - 632:1, 632:2
Thomas [1] - 854:18
transaction [1] - 742:16
thoroughly [1] - 646:12
transactions [7] - 589:22, 672:9,
thousand [13] - 581:17, 592:9, 592:11,
923
672:12, 676:6, 676:9, 705:21, 706:5
626:10, 628:22, 635:9, 636:12, 636:25,
UNITED [2] - 560:4, 560:10
637:12, 646:17, 656:8, 667:10, 672:4,
transcript [1] - 889:4
University [3] - 570:5, 603:25, 857:13
680:24, 685:11, 687:14, 688:23, 690:6,
Transcript [2] - 561:13, 561:18
unless [5] - 567:5, 577:24, 606:16,
691:5, 698:3, 706:10, 709:10, 719:6,
transcription [2] - 561:13, 561:19
638:5, 843:9
738:2, 738:11, 738:20, 741:8, 742:2,
transferring [1] - 626:1
unplugged [2] - 791:12, 867:12
755:6, 758:2, 759:21, 760:3, 767:14,
transfers [1] - 726:22
unresponsive [1] - 852:19
781:14, 782:1, 784:12, 784:24, 785:18,
transitioned [1] - 689:2
unsophisticated [2] - 767:25, 768:14
785:19, 802:17, 803:20, 826:15,
translate [1] - 801:10
untimely [3] - 651:17, 657:13, 660:15
842:15, 858:22, 864:9, 867:11, 870:8,
translated [1] - 599:12
untoward [11] - 724:18, 724:20,
872:4, 873:13
724:21, 728:16, 729:12, 729:15,
translating [1] - 801:18
two-week [1] - 785:19
733:24, 736:20, 747:15, 759:4, 881:9
translation [2] - 599:13, 801:24
type [12] - 576:21, 590:23, 610:14,
untowards [1] - 733:16
travel [2] - 793:12, 835:16
614:9, 614:13, 618:20, 643:1, 705:20,
unusual [4] - 725:1, 754:18, 775:18,
traveled [1] - 596:21
705:21, 780:10, 820:20, 866:5
797:7
traveling [1] - 573:19
types [4] - 593:23, 606:4, 607:5,
up [125] - 562:4, 563:21, 565:10, 572:3,
treasury [5] - 606:8, 641:5, 641:8,
618:22
572:7, 575:6, 576:8, 576:11, 578:2,
641:9, 705:1
typical [3] - 796:9, 796:15, 799:17
578:11, 579:7, 579:18, 581:19, 584:23,
treat [1] - 752:20
typically [3] - 805:17, 820:21, 821:22
586:3, 586:24, 588:9, 588:22, 592:13,
treated [1] - 799:1
typing
[1] - 816:8
594:6, 597:16, 611:14, 612:21, 612:24,
trial [6] - 562:12, 563:16, 564:14,
619:4, 620:3, 624:17, 625:21, 627:18,
647:15, 661:20, 692:4
627:22, 629:15, 630:14, 631:5, 633:20,
U
TRIAL [1] - 560:7
635:4, 643:7, 644:24, 648:9, 648:12,
trick [1] - 728:25
649:13, 650:2, 652:25, 658:15, 661:14,
tried [5] - 649:21, 806:1, 836:15,
U.S [37] - 560:17, 580:9, 580:11,
661:15, 671:4, 671:13, 671:18, 671:22,
836:19, 851:2
580:13, 580:18, 581:11, 581:24, 584:5,
674:19, 675:22, 680:8, 680:23, 685:20,
trip [2] - 618:13, 678:14
584:11, 584:13, 584:22, 589:4, 590:10,
687:4, 690:19, 694:10, 694:14, 694:22,
trips [5] - 588:2, 677:10, 677:17,
590:12, 605:23, 607:10, 613:17,
695:8, 700:16, 701:5, 701:10, 708:6,
678:6, 685:13
614:12, 617:24, 619:4, 623:5, 626:24,
720:6, 720:14, 722:19, 724:7, 724:8,
trouble [3] - 687:9, 860:6, 864:18
627:6, 634:15, 658:5, 697:15, 730:6,
725:17, 726:3, 734:15, 735:8, 737:3,
true [12] - 651:24, 666:7, 700:5, 706:1,
775:9, 793:7, 794:1, 795:14, 822:20,
737:22, 738:3, 738:4, 740:3, 748:24,
728:8, 750:16, 752:11, 781:2, 804:13,
848:25, 849:1, 849:3, 865:13
748:25, 753:12, 774:20, 776:10,
844:3, 868:12, 868:19
ultimate [1] - 581:25
785:22, 786:1, 796:6, 800:17, 816:19,
trust [1] - 853:3
ultimately [2] - 571:24, 762:2
816:20, 817:3, 817:9, 819:16, 826:11,
truth [24] - 568:1, 568:2, 571:15,
umbrage [1] - 656:2
827:12, 828:6, 829:23, 833:3, 833:6,
615:5, 632:23, 637:18, 640:11, 647:2,
umbrella [2] - 621:24, 728:7
841:3, 842:3, 842:4, 842:12, 845:14,
653:22, 654:15, 655:24, 660:22, 668:6,
unable [1] - 563:18
845:15, 845:17, 849:20, 856:5, 860:10,
673:8, 777:5, 777:6, 798:22, 804:11,
unaffiliated [2] - 672:13, 676:9
860:11, 860:16, 861:21, 866:9, 866:20,
826:8, 826:16, 826:17, 843:25
unclear [2] - 608:11, 735:23
866:22, 869:23, 872:24, 874:15,
truthful [2] - 756:15, 765:16
uncomfortable [3] - 685:9, 686:5,
883:23, 887:8
truthfulness [2] - 739:20, 742:11
775:22
update [1] - 822:6
try [10] - 574:4, 607:2, 631:22, 691:14,
under [38] - 581:18, 609:19, 610:7,
updated [2] - 824:24, 831:20
744:17, 790:9, 793:22, 841:2, 859:14
617:9, 619:19, 628:14, 641:19, 643:13,
updating [1] - 622:9
trying [14] - 613:12, 654:8, 708:25,
649:6, 657:14, 678:22, 683:15, 686:18,
upfront [2] - 630:9, 631:8
721:22, 743:8, 743:20, 747:21, 750:9,
700:7, 715:6, 717:23, 726:6, 726:19,
upper [2] - 643:3, 684:1
750:14, 752:19, 775:19, 847:4, 863:6,
731:12, 733:5, 734:3, 734:13, 735:22,
upset [1] - 688:3
879:10
735:24, 736:2, 739:18, 741:21, 747:3,
US [1] - 560:14
tuned [1] - 694:20
747:7, 747:21, 748:3, 763:20, 764:20,
uses [1] - 832:13
tuning [1] - 694:25
770:2, 770:18, 792:25, 820:13, 885:2
usual [2] - 776:11, 827:18
turn [37] - 585:5, 586:14, 593:5,
undercover [1] - 742:1
utilities [1] - 669:23
599:25, 600:15, 600:23, 601:8, 602:16,
underneath [5] - 600:18, 698:2,
602:21, 603:3, 605:13, 608:20, 611:18,
699:11, 727:6, 807:3
V
614:20, 619:1, 630:1, 630:10, 630:13,
understandings [1] - 749:8
632:12, 641:11, 642:17, 643:1, 644:6,
understood [3] - 590:6, 763:10,
644:17, 663:10, 664:8, 666:3, 669:4,
768:19
vacation [4] - 785:2, 849:24, 850:2,
669:14, 671:1, 671:2, 680:6, 762:18,
unfortunately [1] - 768:9
850:3
789:8, 820:12, 823:5
Union [2] - 587:8, 592:25
value [4] - 666:8, 832:15, 832:17,
turned [2] - 586:21, 769:5
unique [1] - 661:20
832:24
turning [8] - 583:3, 610:7, 632:15,
uNITED [1] - 560:1
Vargas [1] - 757:13
638:4, 640:16, 663:9, 671:15, 758:14
United [22] - 567:20, 601:20, 604:4,
vault [1] - 576:18
tutelage [2] - 747:7, 747:10
611:11, 627:3, 643:17, 643:18, 695:13,
Venezuela [5] - 754:23, 754:24, 795:4,
two [59] - 563:24, 564:10, 564:18,
695:23, 766:11, 770:5, 776:25, 778:8,
799:20, 803:6
566:4, 572:22, 573:4, 573:16, 590:11,
778:9, 778:10, 778:17, 793:10, 793:11,
ventures [1] - 594:6
593:15, 593:17, 605:15, 623:17,
793:15, 793:23, 794:2, 794:25
verbatim [1] - 801:18
924
verbiage [2] - 754:11, 874:16
version [4] - 754:19, 754:20, 798:12,
824:24
versions [1] - 798:1
versus [3] - 753:1, 793:3, 795:10
vice [1] - 574:1
vice-president [1] - 574:1
video [1] - 630:12
view [3] - 672:9, 676:5, 688:17
views [1] - 793:25
violated [2] - 738:9, 739:1
vision [2] - 592:22, 684:5
visit [11] - 582:4, 583:7, 661:8, 661:25,
662:1, 677:7, 685:21, 787:15, 792:5,
836:2, 836:3
visited [6] - 598:2, 598:7, 824:20,
836:9, 837:4, 840:9
visiting [3] - 661:24, 837:11, 837:12
visits [2] - 587:23, 587:25
volt [1] - 717:15
VOLUME [1] - 560:8
votes [1] - 717:14
VS [1] - 560:5
well-known [2] - 591:16, 607:7

world [5] - 585:16, 705:10, 705:11,
729:19, 783:18
West [6] - 617:23, 783:17, 783:18,
worn [1] - 778:6
783:19, 791:24, 835:9
whole [15] - 565:4, 565:7, 568:1,
worry [2] - 693:18, 832:16
635:2, 635:3, 654:2, 654:18, 654:21,
worse [2] - 629:11, 629:12
660:17, 664:21, 683:2, 769:16, 777:5,
worth [2] - 776:19, 839:5
845:24, 872:23
Worth [1] - 568:18
whys [1] - 650:8
wow [1] - 697:2
wider [2] - 624:25, 626:20
write [2] - 784:19, 794:11
wife [1] - 849:11
writes [1] - 868:14
wife's [2] - 855:14, 855:18
writing [5] - 599:20, 717:14, 794:16,
William [1] - 560:16
799:15, 802:6
willing [5] - 686:25, 795:18, 795:20,
writings [1] - 653:11
796:5, 847:12
written [3] - 598:8, 599:7, 604:19
willingness [1] - 812:23
wrote [3] - 645:13, 813:14, 864:10
win [2] - 768:4, 768:12
ws [1] - 862:24
wipe [1] - 712:8
wiped [2] - 712:5, 712:6
Y
withdraw [3] - 628:24, 639:13, 843:10
withdrawals [2] - 584:6, 586:16
year [47] - 569:13, 569:15, 572:10,
withdrawn [1] - 639:22
588:21, 595:22, 604:21, 605:21,
witness [45] - 562:15, 565:2, 565:4,
609:25, 610:10, 627:2, 628:23, 629:23,
566:3, 566:18, 567:19, 572:6, 637:19,
632:7, 632:10, 644:9, 644:10, 645:1,
638:16, 640:5, 640:8, 646:13, 648:22,
666:10, 669:7, 672:3, 676:4, 683:9,
649:4,
649:9,
654:5,
663:2,
673:2,
W
683:22, 683:25, 685:11, 694:11,
690:9, 718:16, 738:7, 738:13, 738:14,
709:14, 711:25, 758:2, 800:20, 810:6,
738:22, 740:25, 761:8, 766:25, 771:24,
810:13, 810:14, 810:17, 811:2, 811:11,
W1V9 [1] - 616:13
774:23, 774:24, 776:10, 776:20,
814:6, 821:1, 847:8, 871:22, 871:23,
wait [11] - 607:22, 615:11, 647:4,
776:24, 843:18, 844:16, 856:2, 856:3,
875:5, 875:6, 875:10, 879:21
673:6, 695:5, 722:22, 723:3, 750:2,
856:4, 870:12, 887:10, 887:19, 887:20
year-over-year [1] - 609:25
843:9, 843:20, 844:15
WITNESS [74] - 568:3, 568:25, 570:2,
year-to-date [1] - 629:23
waiting [3] - 596:25, 597:2, 708:1
570:4, 571:17, 573:6, 573:9, 573:11,
year-to-year [1] - 610:10
walk [2] - 610:22, 888:21
579:2, 579:7, 579:10, 584:4, 598:17,
years [60] - 568:17, 568:20, 569:13,
walks [1] - 843:2
598:20, 598:22, 600:25, 606:19, 607:1,
569:20, 570:1, 570:2, 570:7, 570:16,
wall [3] - 583:6, 630:10, 725:24
607:21, 607:24, 608:3, 608:5, 616:25,
570:24, 604:1, 604:19, 604:20, 607:23,
walls [1] - 576:10
617:2, 619:22, 623:10, 623:13, 627:20,
608:6, 620:15, 628:22, 651:12, 652:17,
wants [9] - 633:16, 652:25, 657:20,
627:23, 643:19, 646:7, 664:20, 673:5,
654:6, 658:11, 662:13, 662:21, 675:5,
757:1, 785:18, 808:6, 827:21, 850:25,
674:24, 675:21, 675:25, 676:2, 688:21,
688:13, 689:23, 697:5, 716:19, 722:2,
884:13
693:20, 695:17, 709:15, 713:9, 718:18,
722:5, 741:9, 741:16, 742:20, 742:21,
warm [2] - 685:22, 685:24
723:2, 723:4, 723:7, 730:8, 735:4,
742:22, 742:25, 743:3, 744:20, 745:19,
Warren [1] - 560:16
735:9, 735:11, 736:18, 747:18, 750:1,
746:13, 751:1, 751:4, 764:2, 766:15,
wars [1] - 702:22
750:4, 757:3, 774:19, 777:7, 790:22,
771:18, 778:13, 779:16, 784:10,
797:12, 800:21, 802:1, 806:3, 818:7,
was. [1] - 872:24
792:15, 812:18, 815:17, 819:15,
825:7, 833:1, 833:5, 836:19, 838:5,
Washington [1] - 560:18
819:23, 821:9, 826:18, 846:3, 846:24,
850:6, 852:4, 852:6, 855:14, 855:23,
watch [1] - 751:11
846:25, 863:13, 888:7
873:8
watched [1] - 751:7
yellow [1] - 806:25
witness's [2] - 585:20, 739:20
watching [1] - 751:9
yes-or-no [1] - 722:24
witnesses [12] - 562:11, 562:14,
water [6] - 568:23, 568:24, 569:7,
yesterday [1] - 564:10
562:22,
563:7,
563:19,
563:25,
564:2,
579:8, 623:11, 623:13
yield [3] - 584:24, 605:25, 612:8
564:13, 564:16, 640:5, 691:1, 776:12
ways [2] - 679:19, 802:17
yields [2] - 641:5, 641:8
woman [2] - 571:9, 687:19
wear [1] - 575:17
York [1] - 560:17
wonder
[1]
875:23
wearing [3] - 575:19, 601:6, 780:1
yourself [4] - 565:23, 568:15, 720:14,
wondering [3] - 566:9, 566:17, 606:2
Wednesday [1] - 562:8
777:18
wooden [1] - 576:9
week [8] - 562:12, 563:7, 564:10,
word [6] - 594:13, 657:16, 747:13,
651:18, 785:19, 850:3, 850:11
747:21, 881:9, 882:18
weekend [1] - 563:10
wording [2] - 653:10, 831:5
weeks [1] - 785:18
words [10] - 578:16, 614:2, 668:6,
weight [1] - 660:4
668:10, 673:3, 673:8, 717:14, 776:9,
weird [4] - 725:3, 754:18, 881:11,
802:10, 856:13
881:14
workers [2] - 588:24, 595:6
welcome [1] - 788:25
works [8] - 568:21, 603:1, 630:4,
well-established [1] - 607:7
786:25,
877:11
Johnny C. Sanchez,787:1,
RMR,809:23,
CRR -810:23,
jcscourtreporter@aol.com

Allen Stanford Criminal Trial Transcript Volume 3 Jan. 25, 2012

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Allen Stanford Criminal Trial Transcript Volume 3 Jan. 25, 2012

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560

UNITED STATES DISTRICT COURT

January 25, 2012

BEFORE THE HONORABLE DAVID HITTNER

DIRECT EXAMINATION BY MR. STELLMACH ...........

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

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

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

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

THE COURT: All right. We're ready to go, but

3 I understand the government has a matter you want to bring

5 now. Go right ahead.

MR. COSTA: Yes, Your Honor.

THE COURT: What's the problem?

MR. COSTA: Last Wednesday we had the pretrial

9 conference. There was this issue with the 17,000 defense

10 exhibits. The parties reached an agreement, which was they

15 one witness, we got a few more this morning for a witness

Basically, to cut to the chase, the

18 agreement has not been followed. I've been told they're

20 situation where we gave them -- they had the advantage of

25 issue that needs to get resolved somehow.

THE COURT: What's your response?

MR. SCARDINO: Your Honor, we've substantially

3 required and complied with -4

THE COURT: I'm not talking substantially. Did

5 you completely, you know, comply?

MR. COSTA: We got exhibits for one of the five

7 or six witnesses we listed for this week.

THE COURT: That's it?

MR. COSTA: Yes. Half of them we got this

10 morning, a few we got over the weekend.

MR. PARRAS: I can reply, Judge, to what we've

12 been working to do.

THE COURT: Go on.

MR. PARRAS: As the Court knows, we've been

15 informing the Court and everyone about our preparedness for

20 prosecutors, I asked them to let us know which few were

We did, however, get them the first two or

25 three witnesses. I believe we've been supplementing as

THE COURT: How many witnesses in advance can

3 you get done, three in advance?

MR. PARRAS: If we have a chicken and egg

5 problem, Judge, we can't start working until we know who's

THE COURT: Well, you got that, you got six

MR. COSTA: Well, now I've got six for this

10 week, and yesterday we told them two for next week. So

THE COURT: Eight.

MR. COSTA: Basically that's half the witnesses

14 that we're going to call in this trial.

MR. PARRAS: And here's the issue, Judge, they

16 gave us the first five witnesses they were going to call

20 particular order, so we had to go back and restart again.

THE COURT: Do you have them in correct order

MR. COSTA: I think -- they know the first

MR. PARRAS: And we've been able to do those.

MR. COSTA: Again, we only have

2 documents for -- I guess the first witness they're not

5 was this would allow us to check in advance for

THE COURT: All right. This is what I'm going

10 to do, I'll take this up after the noon break. Talk to

15 certain deadline. Work together. Give me those deadlines.

If you can't work it out, I'll decide, and

19 then at that point, if any other exhibits come in at the