10-18-19 - USA V Jean Boustani - 18CR681 (SFK) - Criminal Jury Trial - MI PDF

Proceedings 496
1 (In open court - jury not present.)

494
2 THE COURTROOM DEPUTY: All rise. All rise.
1 UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF NEW YORK 3 The Honorable William F. Kuntz, II, is now
2
- - - - - - - - - - - - - - X 4 presiding.
3
UNITED STATES OF AMERICA, : 18-CR-00681(WFK)(WFK) 5 Criminal cause for trial, Docket Number 18-CR-681,
4 :
:
5 : 6 USA versus Boustani.
-against- : United States Courthouse
6 : Brooklyn, New York 7 Counsel, please state your appearances for the
:
7 : 8 record.
: Friday, October 18, 2019
8 JEAN BOUSTANI, : 9:30 a.m.
: 9 MR. BINI: Mark Bini, Hiral Mehta, Margaret Moeser,
9 Defendant. :
: 10 Lillian DiNardo, Katherine Nielsen, and we'll have Special
10 - - - - - - - - - - - - - - X
11 Agent Tessone in a moment, for the United States.
11
TRANSCRIPT OF CRIMINAL CAUSE FOR JURY TRIAL
12 BEFORE THE HONORABLE WILLIAM FRANCIS KUNTZ, II
12 Good morning, Your Honor.
UNITED STATES DISTRICT JUDGE
13 13 (Defendant entered courtroom.)
14 14 THE COURT: Good morning.

15 A P P E A R A N C E S: 15 You may be seated. We have the spellings. You may
16 For the Government: RICHARD P. DONOGHUE, ESQ.
United States Attorney 16 be seated, ladies and gentlemen, and the public as well.
17 Eastern District of New York
271 Cadman Plaza East 17 Thank you.
18 Brooklyn, New York 11201
BY: MARK E. BINI, ESQ. 18 MR. JACKSON: Randall Jackson on behalf of
19 HIRAL D. MEHTA, ESQ.
Assistant United States Attorneys
20 19 Mr. Boustani.
21 DEPARTMENT OF JUSTICE 20 Good morning, Your Honor.

CRIMINAL DIVISION
22 1400 New York Avenue 21 THE COURT: Good morning.
Washington, D.C. 20001
23 BY: MARGARET MOESER, ESQ.
KATHERINE NIELSEN, ESQ. 22 MR. SCHACHTER: Good morning, Your Honor.
24
23 Michael Schachter on behalf of Mr. Boustani.
25
24 THE COURT: Good morning.
25 Mr. Boustani, I note your presence. Good morning,

SAM OCR RMR CRR RPR
SAM OCR RMR CRR RPR
495
Proceedings 497
1 A P P E A R A N C E S: (Continued)
1 sir.
2
2 THE DEFENDANT: Good morning.
3 For the Defendant:WILLKIE FARR & GALLAGHER, LLP 3 THE COURT: Go ahead.
787 Seventh Avenue
4 New York, New York 10019-6099 4 MS. DONNELLY: Good morning.
BY: MICHAEL S. SCHACHTER, ESQ.
5 RANDALL W. JACKSON, ESQ. 5 Casey Donnelly on behalf of Mr. Boustani.
CASEY E. DONNELLY, ESQ. 6 THE COURT: Good morning.
6 PHILIP F. DISANTO, ESQ.
RAYMOND MCLEOD, ESQ. 7 MR. DiSANTO: Good morning.
7
8 Philip DiSanto on behalf of Mr. Boustani.
8 9 THE COURT: Good morning.
9 10 MR. McLEOD: Good morning.
11 Ray McLeod on behalf of Mr. Boustani.

10
ooo0ooo 12 THE COURT: Good morning. Please be seated as well.
11
13 All right, do we have any procedural issues to
12 14 address before the jury comes in?
13 15 Anything from the Government?
16 MR. BINI: Not for the United States.

14
17 THE COURT: Thank you.
15
Court Reporter: Stacy A. Mace, RMR, CRR, RPR, CCR 18 Anything from defense?
16 Official Court Reporter
19 MR. JACKSON: No, Your Honor.
E-mail: SMaceRPR@gmail.com
17 Proceedings recorded by computerized stenography. Transcript 20 THE COURT: All right, would you have the CSOs bring
produced by Computer-aided Transcription.
18 21 in the jury.
19 22 And you can have the witness resume the witness
20
21 23 stand, please.
22
24 MR. BINI: Thank you, Your Honor.
23
24 25 THE COURT: Thank you.
25
SAM OCR RMR CRR RPR SAM OCR RMR CRR RPR
Page 494 to 497 of 681

Proceedings 498 Pearse - direct - Bini 500
1 (Jury enters.) 1 ANDREW P E A R S E,
2 THE COURT: Remember, when the light is on we can 2 called as a witness by the Government, having been
3 hear you. Just click that little oval space and then you 3 previously duly sworn/affirmed, was examined and
4 won't be heard. 4 testified further as follows:
5 (Pause.) 5 DIRECT EXAMINATION (CONTINUING)
6 THE COURT: Good morning, ladies and gentlemen of 6 BY MR. BINI:
7 the jury. Again, I appreciate your promptness. We are at the 7 Q Yesterday, Mr. Pearse, you discussed your financial
8 end of the week. We don't sit on Saturdays and Sundays, 8 incentive in maximizing the loan financing for these
9 unlike some cases I used to try in the old days. So thank 9 transactions.
10 you. 10 I'd like to ask you: Did the defendant have a
11 Please be seated. And ladies and gentlemen of the 11 financial incentive in getting larger loans?
12 public, be seated as well. 12 A Yes, he did.
13 You can have the witness come back to the witness 13 Q How is that?
14 stand, and then we will resume. 14 A Two reasons. He was an employee at the company that was
15 (Witness entered the courtroom and resumed the 15 benefiting from the size of the -- the max -- the bigger the
16 stand.) 16 loan was, the bigger the contract for his employer.
17 THE COURT: Welcome back, Mr. Pearse. Good morning, 17 He was also a partner in Palomar. And in relation
18 sir. 18 to monies I received for the EMATUM and MAM transactions,
19 And I am going to ask you the same question: Have 19 which totaled just under $35 million, that was one-third of
20 you spoken with anyone about your testimony since leaving that 20 the distribution that was made by that company from its
21 chair? 21 profits. Mr. Boustani was a one-third owner, so he received
22 THE WITNESS: I have not, Your Honor. 22 the same amount of money as I did in relation to those two
23 THE COURT: Thank you, sir. Please be seated. 23 projects. So $34 million that I'm aware of were paid to him.
24 Counsel, please continue your inquiry. 24 By maximizing the size of the loans, I maximized the
25 MR. BINI: Thank you, Your Honor. 25 amount of money that I received to get to the 34 million. If
Proceedings 499 Pearse - direct - Bini 501

1 Your Honor, at this time, the Government would seek 1 the loans had been smaller, I would have received less money.
2 the admission of Government's Exhibit -- before I do that, 2 Consequently, so would Mr. Boustani.
3 I'll ask a question about something else. 3 Q What did you mean by the contractor benefited?
4 4 A In all three -- for all three projects the contractor was
5 (Continued on the following page.) 5 the same company, whether it was building naval vessels or
6 6 fishing boats or infrastructure for shipyards in Mozambique.
7 7 So the larger the loan, the larger the contract was that was
8 8 awarded to the contractor.
9 9 As I mentioned yesterday, the original tuna fleet
10 10 concept was for a $250 million project. Ultimately, through
11 11 the ability to raise more money, the project was finalized at
12 12 $850 million.
13 13 So what I am trying to say, sir, is that the size of
14 14 the project was dictated by the amounts of money the banks
15 15 were prepared to lend. The bigger the project, the more money
16 16 was paid to the contractor, and the more money that was paid
17 17 to myself.
18 18 Q And the defendant?
19 19 A And the defendant, sir.
20 20 MR. BINI: At this time, I would seek to move in
21 21 Government's Exhibit 2373.
22 22 THE COURT: Any objection?
23 23 MR. SCHACHTER: No objection, Your Honor.
24 24 THE COURT: It's admitted. You may publish.
25 25 (Government's Exhibit 2373 was received in
Page 498 to 501 of 681

Pearse - direct - Bini 502 Pearse - direct - Bini 504
1 evidence.) 1 stage by another 100 million to 472 million. Again, the
2 (Exhibit published.) 2 $372 million loan to Proindicus had just been increased by
3 BY MR. BINI: 3 $100 million in June with the same contractor, Privinvest.
4 Q If we can look to the bottom e-mail, Mr. Pearse. What is 4 And now, Credit Suisse was being asked to consider
5 the date of this e-mail? 5 another project in Mozambique with the same contractor for
6 A The 31st of July of 2013. 6 even more vessels. And I knew as a former banker -- or still
7 Q Who is it from, and who is it to? 7 current banker, that one of the questions I would have asked
8 A It's from Jean Boustani to Surjan Singh. 8 was, why Privinvest? Why did Mozambique choose Privinvest
9 Q What did the defendant indicate to Surjan Singh? 9 again for another project so soon after the first one?
10 A He says: "Hi, we will need to make the loan 825, please. 10 MR. BINI: Ms. DiNardo, can we go to the first page?
11 25 on top of the 50 to the borrower. Is that possible?" 11 BY MR. BINI:
12 Q How did you receive this e-mail, Mr. Pearse? 12 Q And, Mr. Pearse, I'll ask you to read the defendant's
13 A It was forwarded to me by Mr. Boustani. 13 response to your e-mail.
14 MR. BINI: If we can now go to Government's 14 A "I'd really prefer that price to be done by CS. We are
15 Exhibit -- or let me ask the Court if I can move into evidence 15 very, very comfortable. The trimaran and trawler are pretty
16 Government's Exhibit 2375? 16 much unique designs. Can't benchmark them to other products."
17 THE COURT: Any objection? 17 Q Let me stop you right there.
18 MR. SCHACHTER: No, Your Honor. 18 What did you understand the "trimaran and trawler"
19 THE COURT: You may publish. It's admitted. 19 to refer to?
20 MR. BINI: Thank you, Your Honor. 20 A The -- at this stage, the project was designed to include
21 (Government's Exhibit 2375 was received in 21 fishing trawlers and three offshore patrol vessels. Those
22 evidence.) 22 offshore patrol vessels were trimarans.
23 (Exhibit published.) 23 Q Okay.
24 BY MR. BINI: 24 A They had three hulls.
25 Q What's this e-mail, Mr. Pearse? 25 Q Three hulls?

1 A (No response.) 1 A It's a boat with three -- three hulls, yes.
2 Q If we can go to the second page, the e-mail July 31st, 2 Q Okay. If you could read the rest of the defendant's
3 2013, at 10:42 a.m., from you to Mr. Boustani. 3 response.
4 Could you read that e-mail to the jury, Mr. Pearse. 4 A "Let's say they contacted South African yards and Spanish
5 A "Can we name a couple of shipyards that borrower would 5 and Portuguese. Without naming."
6 have contacted? And are there price comparisons we can show?" 6 Q What did you understand the defendant to mean when he
7 Q What were you writing about, Mr. Pearse? 7 wrote: "Let's say they contacted South African yards and
8 A The background was -- to this question was that I was 8 Spanish and Portuguese"?
9 aware that Credit Suisse, as part of their diligence process, 9 A He was suggesting that Credit Suisse be told that EMATUM
10 would inquire whether or not Privinvest had been awarded the 10 had contacted South African shipyards, Spanish shipyards, and
11 contract for the fishing boats as part of a competitive tender 11 Portuguese shipyards, prior to awarding the contract to
12 process. 12 Privinvest.
13 Q What's a "competitive tender process"? 13 Q How did you respond?
14 A Where there are multiple companies that provide quotes; 14 A "Can you let me know when you are free to speak?"
15 or offer to supply the ships, in this case. And they -- the 15 Q And how did the defendant respond?
16 government of Mozambique has a choice to choose from a number 16 A "Bro, the three names of shipyards, FYI, Damen: Holland;
17 of different options and potentially by reference to what was 17 Fincantieri: Italy; and Navantia: Spain."
18 the cheapest or the most efficient, but they would have had 18 Q Do you know if -- well, let me ask first, what did you
19 more than one option to look at. 19 understand the defendant to be putting here with these three
20 Q Why would that be important to Credit Suisse in 20 names of shipyards?
21 considering the EMATUM loan and bond? 21 A He was providing details of competitor shipyards, whose
22 A Because the time period, it was the end of July, 2013. 22 names could be provided to Credit Suisse as shipyards that had
23 This was three months after Credit Suisse had made the 23 been involved in tendering for the EMATUM fishing boat
24 original $372 million loan to Proindicus involving Privinvest 24 project.
25 as a contractor. The Proindicus loan had increased by this 25 Q Do you know if it was true?
Page 502 to 505 of 681

1 A It wasn't true. 1 cost is 11.8 million" -- is that euro or pound?
2 Q How do you know that? 2 A Euro.
3 A I discussed it with the defendant. 3 Q -- "euro and the cost of the trimaran is 23.8 million
4 Q Was this information important to Credit Suisse in 4 euro"?
5 considering this loan and bond? 5 Do you know what the defendant meant in point 4?
6 A It was one of the important pieces of information. 6 A That this was the cost price for building each of the
7 Q Why would that information be important? 7 vessels. The trawlers were 11.8 million euro, and the
8 A Because it would justify why -- that Mozambique has 8 trimaran cost was 23.8 million euros, I believe was indicated
9 chosen Privinvest, and would take away a concern that was in 9 the price to build.
10 their mind as to what would -- what would motivate Mozambique 10 Q What would that be in dollars?
11 to do another project with the same contractor so soon after 11 A I believe at the time, and the exchange rates at the
12 the previous one. 12 time, that would have been approximately 14-1/2, $15 million
13 MR. BINI: Thank you. You can take that down, 13 for the trawler, and 26, $27 million for the trimarans.
14 Ms. DiNardo. 14 Q And what did you understand point 5 to mean?
15 Your Honor, at this time, the Government would offer 15 If you can read that to the jury first.
16 Exhibit 2377. 16 A "The ToT cost is 150,000 euro for the trawler and 300,000
17 THE COURT: Any objection? 17 euro for the trimaran."
18 MR. SCHACHTER: No, Your Honor. 18 Q What did you understand "ToT cost" to mean?
19 THE COURT: It's admitted. You may publish. 19 A "ToT" stands for transfer of technology.
20 (Government's Exhibit 2377 was received in 20 As part of the contract, Privinvest were providing
21 evidence.) 21 technical specification of the vessels to EMATUM to allow, in
22 (Exhibit published.) 22 theory, EMATUM to be able to build the same vessels, itself.
23 BY MR. BINI: 23 And that transfer of technology, that was valued by Privinvest
24 Q I am going to ask you, Mr. Pearse, if you can look at the 24 at 150,000 euros per trawler, and 300,000 euros per trimaran.
25 e-mail from the defendant to you on the first page on 25 Q What would that be, approximately, in United States

1 July 31st, 2013, at 00:11. 1 dollars, Mr. Pearse?
2 And take a moment to read that, and then tell the 2 A Approximately $180,000 for the trawlers, and $360,000 for
3 jury what the defendant was setting out. 3 the trimarans.
4 A This is an e-mail to me asking for my comments on what 4 Q Now, I want to ask you about point 6. The defendant
5 would ultimately be sent by Mr. Boustani to Surjan Singh, who 5 said: "Adding all of that, you are at a 480M$ cost."
6 was at Credit Suisse running the due diligence process. And 6 What did you understand the defendant to mean?
7 it was in response to a question from Credit Suisse as to why 7 A Taking all of the above costs, the cost per trawler and
8 had ADM been appointed by EMATUM as the contractor, and -- 8 the cost per trimaran, plus the cost of the transfer of
9 Q What's "ADM"? 9 technology, if you multiplied those numbers by the number of
10 A Abu Dhabi MAR, the subsidiary and contractor for -- a 10 trawlers and trimarans being supplied, he arrived at a total
11 subsidiary of Privinvest and contractor for the EMATUM 11 cost of $480 million.
12 project. 12 Q What does that represent?
13 So the items listed in this e-mail are designed to 13 A I believe that is representing the cost to Privinvest of
14 help justify why Abu Dhabi MAR was chosen, and it -- also to 14 building those vessels.
15 give broad details as to the profitability of the project for 15 Q Is this the 24 fishing boats and the three trimarans that
16 Privinvest. 16 would be the EMATUM deal?
17 Q What did you understand the defendant to mean when he 17 A Excuse me. Yes, that's right. Twenty-four fishing
18 wrote: "Let me know if we put all info into one doc and we 18 trawlers and three trimarans or offshore vessels.
19 send it to Surj"? 19 Q What does the defendant set out in point 7?
20 A He was asking whether or not, after I commented on these 20 A He sets out the elements, which are built into pricing
21 points, he should then write a separate document, which 21 via any contractor for its goods. So the previous values of
22 included everything that was in here or any other further 22 4 -- Items 4 and 5 of his e-mail have been the cost to
23 comments, and send it to Surjan Singh at Credit Suisse. 23 Privinvest of building the vessel.
24 Q I am going to ask you about point 4. 24 And then on top of that, he was adding costs for
25 Do you see where the defendant writes: "The trawler 25 insurance, for management, for overhead, for various other
Page 506 to 509 of 681

1 expenses of running a business, to arrive at a additional cost 1 (Exhibit published.)
2 over and above the pure cost to build the vessels. 2 BY MR. BINI:
3 Q What was that additional percentage that he indicated 3 Q If we can look to 2384, and look to the top portion of
4 would be required? 4 the first page of the e-mails.
5 A 36.5 percent. 5 What's the date of these e-mails, Mr. Pearse?
6 Q Can you tell me, Mr. Pearse, looking at point 8, what 6 A August 2nd, 2013.
7 does the defendant then set out? 7 Q Looking to the top e-mail, who is that from?
8 A He then sets out a calculation, whereby he is trying to 8 A It's from Jean Boustani.
9 multiply 480 million, that's -- which was the cost to 9 Q Who is it to?
10 Privinvest of construction, by -- to add to the 36 percent 10 A Detelina Subeva and myself.
11 margin or profit, cost provision, to arrive at $754 million. 11 Q Is that using your private e-mails?
12 Q Is his math right? 12 A Yes.
13 A It doesn't appear to me to be correct, no. 13 Q What did the defendant forward you?
14 Q Why don't you think it's right? 14 A He was forwarding me documents that he'd received from
15 A Because if I multiplied 485 by 136 percent, which I think 15 employees at Credit Suisse.
16 is the correct math, I don't arrive at 754. 16 Q Is that the e-mail one below?
17 Q What do you arrive at, approximately? 17 A Yes.
18 A 640. 18 Q Who are those employees?
19 Q $640 million? 19 A Edward Kelly, Surjan Singh, and Galina Barakova.
20 A So, yes, $640 million. 20 Q What were the materials related to?
21 Q After you received this e-mail, what did you do? 21 A These were the documents that set out the due diligence
22 A I responded -- sorry, excuse me. 22 questions and due diligence areas that Credit Suisse was going
23 I forwarded that e-mail to an e-mail address called 23 to focus on when they came to Mozambique for their due
24 Dilawar Property Limited, a Gmail address. 24 diligence trip, which was scheduled to be around about the
25 Q Whose Gmail address was that? 25 same time.

1 A That's the personal Gmail address of Surjan Singh. 1 Q Why was the defendant sending you, to your personal
2 Q Why were you sending this information to Surjan Singh's 2 e-mail, the due diligence questions for EMATUM?
3 personal e-mail address? 3 A So that we were aware of the questions, that I was aware
4 A So that he had the information to be able to convey to 4 of the questions. And in order to be able to assist in
5 Credit Suisse as to how the -- how Privinvest were pricing the 5 preparing the answers to some of the questions.
6 project, and to be able to describe the profit margin. 6 Q Did the defendant know you were going to do that?
7 Q Why didn't you send it to his Credit Suisse e-mail? 7 A Yes, that's why he sent it to me.
8 A At this point in time, Surjan Singh's primary role in the 8 MR. BINI: If we can look to 2384-A.
9 scheme was to ensure that the due diligence process for EMATUM 9 (Exhibit published.)
10 was -- went as seamlessly as possible. 10 BY MR. BINI:
11 I was providing this information to him in advance 11 Q What's that, Mr. Pearse?
12 of it being sent to Credit Suisse, so that he was aware and he 12 A This is the first page of the due diligence questions
13 was able to position the transaction as favorably as possible 13 that was referred to in the previous e-mail that were to be
14 within Credit Suisse. 14 asked of the Ministry of Finance of Mozambique.
15 MR. BINI: Thank you. You can take that down, 15 MR. BINI: And if we can go to 2384-B.
16 Ms. DiNardo. 16 (Exhibit published.)
17 At this time, the Government would seek the 17 BY MR. BINI:
18 admission of Exhibit 2384 and 2384-A. 18 Q What's that, Mr. Pearse?
19 THE COURT: Any objection to the admission of those 19 A This is the second document, which addresses questions
20 exhibits? 20 which are more specific to the actual project, rather than to
21 MR. SCHACHTER: No, Your Honor. 21 the financial position of the Government of Mozambique.
22 THE COURT: They are admitted. You may publish. 22 The previous -- excuse me. The previous document
23 MR. BINI: Thank you, Your Honor. 23 had focused on the economic situation of Mozambique, who was
24 (Government's Exhibits 2384 and 2384-A were received 24 to be the guarantor. These questions relate to the underlying
25 in evidence.) 25 project that was being developed.
Page 510 to 513 of 681

1 MR. BINI: Your Honor, at this time, I would ask to 1 this time?
2 admit -- oh, Your Honor, I just want to be clear. 2 A On this day, yes.
3 I am not sure that I mentioned 2384-B. I would ask 3 Q Yesterday I had asked you about when you left Credit
4 its admission with 2384-A and 2384. 4 Suisse. When was that again?
5 THE COURT: Any objection to 2384-B being admitted? 5 A Approximately the 13th of September of 2013.
6 MR. SCHACHTER: No, Your Honor. 6 Q Do you know when Ms. Subeva left Credit Suisse?
7 THE COURT: It's admitted. You may publish. 7 A I do not know her termination date, no.
8 MR. BINI: Thank you. 8 Q Do you know the approximate time period?
9 (Government's Exhibit 2384-B was received in 9 A To the best of my knowledge, it was approximately the
10 evidence.) 10 same as mine.
11 MR. BINI: Your Honor, at this time, I would request 11 Q How did you respond to the defendant, Jean Boustani?
12 permission to admit 2391. 12 A "John, do you know if the fishing lady and Isaltina are
13 THE COURT: Any objection? 13 up to speed with the project?"
14 MR. SCHACHTER: May I have just a moment, Your 14 Q What did you mean to refer to -- who did you mean to
15 Honor? 15 refer to when you said "the fishing lady"?
16 THE COURT: 2391. 16 A The Deputy Minister of Fisheries in the Government of
17 (Pause.) 17 Mozambique.
18 MR. SCHACHTER: No objection. 18 Q Who did you mean to refer to when you said "Isaltina"?
19 THE COURT: It's admitted. You may publish. 19 A That was a reference to Isaltina Lucas, the National
20 MR. BINI: Thank you, Your Honor. 20 Director of Treasury at the Ministry of Finance of Mozambique.
21 (Government's Exhibit 2391 was received in 21 Q Were they the people who would be involved in the
22 evidence.) 22 approval process for EMATUM on the Mozambican side?
23 (Exhibit published.) 23 A In this context, the -- they were -- they were to be
24 BY MR. BINI: 24 involved in the due diligence process for the EMATUM project.
25 Q I'd like to ask you to look to the e-mail from Surjan 25 Q Who was going to ask questions of them?

1 Singh on the bottom of the first page that also is on the top 1 A Credit Suisse.
2 of the second page. 2 Q Why would they ask the Ministry of Fisheries in
3 MR. BINI: If you could blow that up, Ms. DiNardo, 3 Mozambique about this tuna fishing project?
4 for Mr. Pearse. 4 A Because it was a fishing project sponsored by the
5 BY MR. BINI: 5 Government of Mozambique, the most logical ministry to have
6 Q What's the date of this e-mail, Mr. Pearse? 6 oversight was the Ministry of Fisheries.
7 A The 2nd of August, 2013. 7 Q How did the defendant respond regarding whether Ms. Lucas
8 Q Who is it from, and who is it to? 8 and the head of the Ministry of Fisheries would be ready for
9 A It's from Surjan Singh to Jean Boustani. 9 due diligence questions regarding this loan?
10 Q What's the subject? 10 A "I am sure they're not. They just completed today EMATUM
11 A "DD Trip." 11 papers. Tony signed as chairman and we have contract in
12 Q What does "DD Trip" refer to? 12 30 min. Will start crocodiling from Sunday."
13 A Due diligence trip. 13 Q Who did you understand "Tony" to refer to?
14 Q What was going on at this time period? 14 A Antonio do Rosario.
15 A Credit Suisse was doing the background work, the due 15 Q As chairman -- when the defendant writes: Tony signed as
16 diligence, to understand the EMATUM fishing project; and was 16 chairman, we have contract in 30 minutes, what did you
17 about to arrive in Mozambique to ask the questions that were 17 understand him to mean?
18 referred to in those previous documents we've looked at. 18 A That he was referring to the fact that Antonio do Rosario
19 Q Looking up to the next e-mail in the chain, what did the 19 was chairman of EMATUM and was in the process of signing the
20 defendant do? 20 contract for the supply of the -- of the fishing vessels with
21 A He forwarded that to myself and Detelina Subeva. 21 Abu Dhabi MAR.
22 Q Why? 22 Q How much is this loan going to be for at this point?
23 A In order that we had the information Surj had provided in 23 A I don't recall whether it's 800 or $850 million.
24 his e-mail to Mr. Boustani. 24 Q And is he indicating that do Rosario has signed-off on
25 Q Are you and Ms. Subeva still Credit Suisse employees at 25 the contract, but the Ministry of Fisheries is not ready to
Page 514 to 517 of 681
1 answer questions about it? 1 MR. SCHACHTER: Your Honor, I just don't -- I don't
2 A That is how I read that e-mail, yes. 2 think I have them.
3 Q What did you understand the defendant to mean when he 3 MR. BINI: I can walk over and provide a copy.
4 wrote: "Will start crocodiling from Sunday"? 4 THE COURT: Yes. Do you have them or do you need
5 A I understood that to mean that he would start discussing 5 counsel to provide a copy to you now?
6 the project with Armando Guebuza, the son of the President -- 6 MR. SCHACHTER: I don't believe that we have them.
7 the then President of Mozambique. 7 THE COURT: All right, would you provide a copy to
8 Q "Crocodiling," what does that mean? 8 your adversary, so he can take a look at them and advise the
9 A The defendant had a nickname for Armando Guebuza, the 9 Court if he has any objection.
10 son, which was "crocodilo." "Croco" means crocodile. 10 MR. BINI: Yes.
11 Q How did you respond to the defendant's e-mail? 11 (Pause.)
12 A "I spoke to him. I told him to focus questions relating 12 MR. SCHACHTER: No objection, Your Honor.
13 to the project on Antonio and generic stuff specific to 13 THE COURT: Fine. They're admitted. You may
14 fishing to fishing lady. He understands." 14 publish.
15 Q Who were you referring to? 15 (Government's Exhibits 2393 and 2393-A through C
16 A The reference to "him" is to Surjan Singh. 16 were received in evidence.)
17 Q Why had you spoken to Surjan Singh? 17 (Exhibit published.)
18 A I had spoken to Surjan Singh to make him aware that the 18
19 Ministry of Fisheries -- the Deputy Minister of Fisheries was 19 (Continued on the following page.)
20 potentially unaware of the project. And to ensure that when 20
21 he spoke to her, as the Credit Suisse representative, he ask 21
22 questions that reflected the fact she may not know about the 22
23 project. 23
24 Q What did you write next to the defendant? 24
25 A "Antonio needs just to be prepared and you can help him, 25

1 so no worries." 1 DIRECT EXAMINATION
2 Q What did you mean by that? 2 BY MR. BINI: (Continuing)
3 A I meant that Antonio do Rosario needed to be provided 3 Q What is Government Exhibit 2393?
4 with full information relating to the project, but it wasn't 4 A This is an e-mail from Mr. Boustani to Surjan Singh,
5 so important in relation to Antonio. Because Jean Boustani 5 Edward Kelly, and Galina Barakova, which attaches the signed
6 could be in that meeting and correct any mistakes that 6 procurement contract for EMATUM and various corporate
7 Antonio do Rosario might make in answering due diligence 7 documents that relate to EMATUM as a company.
8 questions. 8 Q What is attached to the e-mail? If we go to 2393A,
9 Q Why would that be important? 9 What's this?
10 A It was important to convey to Credit Suisse that all 10 A This appears to be the front page of the contract that
11 parts of Mozambican government were aware of, supported, and 11 was referred to in the previous e-mail.
12 understood the need for the fishing project. 12 Q Who are the parties to the contract?
13 If in the process of asking the questions it was 13 A Abu Dhabi MAR and Empresa Mozambicana de Atum.
14 clear to the bank that one of the key personnel was unfamiliar 14 THE COURT: Would you spell that for the reporter,
15 with the project or didn't support it, it would have -- it 15 please?
16 would have materially undermined the due diligence process. 16 THE WITNESS: Of course, Your Honor. E-M-P-R-E-S-A.
17 Antonio do Rosario was the chairman, so he would have been 17 Next word, M-O-C-A-M-B-I-C-A-N-A. Next word D-E, and the
18 expected to know everything about the project. 18 final word is A-T-U-M.
19 MR. BINI: Thank you. You can take that down, 19 Q If we can go to -- is that the name for EMATUM?
20 Ms. DiNardo. 20 A EMATUM is the acronym.
21 Your Honor, at this time, the Government would offer 21 Q If we can go to second page of the contract. If you can
22 Government's Exhibit 2393 and 2393-A through C. 22 take a look at the preamble, I would ask you to take a moment
23 THE COURT: Any objection to those documents? 23 to review that, and if you would, explain it to the jury in
24 MR. SCHACHTER: One moment, Your Honor, please. 24 your own words.
25 THE COURT: Do we need to take them seriatim? 25 A This sets out the reasons why Mozambique has created
SAM OCR RMR CRR RPR MDL RPR CRR CSR
Page 518 to 521 of 681
1 EMATUM, the assets that have been approved by Mozambique to be 1 Q Is that what you're indicating in this e-mail?
2 purchased by EMATUM, namely the vessels, the boats we 2 A Yes, I'm conveying that information to the defendant.
3 discussed before and sets out the fact that Abu Dhabi MAR is 3 Q What's the last sentence about?
4 going to provide those vessels under the terms of this 4 A The Proindicus loan, which by this date was now had $472
5 contract. 5 million was increased again in August by Credit Suisse by a
6 Q If we go down to assets, are those defined in the 6 further $32 million. This is the reference to -- so the
7 definitions on the bottom of page 1? 7 reference to Proindicus upsize is the reference to the fact
8 A Yes. 8 that the Proindicus loans to be increased again.
9 Q And is that similar to the preamble? 9 MR. BINI: Thank you. You can take that down.
10 A Yes, it's the same vessels. 10 At this time the Government would ask to admit
11 Q And then if we go to the next page, is there a Roman 11 Government Exhibit 2396.
12 numeral II subject to the contract? 12 THE COURT: Any objection?
13 A Yes, there is. 13 MR. SCHACHTER: Your Honor, I don't believe I have
14 Q And what is set out there? 14 that one either.
15 A A description of the same vessels. 15 THE COURT: Would you walk it over to him, please?
16 Q If we can go to the page that has Roman numeral VII. 16 MR. SCHACHTER: No objection, Your Honor.
17 What does this cost? 17 THE COURT: You may publish. It is admitted.
18 A This is the price to be paid by EMATUM to Abu Dhabi MAR 18 (Government's Exhibit 2396 received in evidence.)
19 and is described as 785,400,000 U.S. dollars. 19 MR. BINI: It's on the screen.
20 MR. BINI: Can we side by side that with 2377, Ms. 20 Q Do you recognize this document, Mr. Pearse?
21 DiNardo, and over on the left, with respect to the contract, 21 MR. BINI: If you can blow up the top e-mail.
22 could you go back to that price in Roman numeral VII. 22 Q Who is it from and who is it to?
23 Q What was the price in the contract? 23 A This is from Detelina Subeva to Antonio do Rosario
24 A 785,400,000 U.S. dollars. 24 copying Jean Boustani and myself.
25 Q In that e-mail that we looked at earlier today in 8, what 25 Q And what is Ms. Subeva setting out in this e-mail?
MDL RPR CRR CSR MDL RPR CRR CSR
1 was the price? 1 A This e-mail is a briefing paper, a document which is
2 MR. BINI: Can you make that bigger, Ms. DiNardo. 2 being sent to Antonio do Rosario in his capacity as the
3 A Based on the calculation made by the defendant, the price 3 chairman of EMATUM, which sets out the questions that Credit
4 was 754 million U.S. dollars. 4 Suisse would be likely to ask of Mr. Rosario in that meeting
5 Q Was that the calculation that you explained earlier you 5 and it suggests answers to those questions.
6 thought was off by about $100 million too high? 6 Q And what were the -- what was the reason for sending this
7 A It's in my opinion that calculation is incorrect. 7 e-mail?
8 Q If we can just go back to the contract. 8 A It was to ensure that Antonio do Rosario was briefed on
9 And now I would like to ask you, Ms. DiNardo, if you 9 the details of the project, particularly the elements which
10 could side by side 2393A with 2391, the top of 2391, just the 10 had been used by Ms. Subeva to build a financial model and
11 top e-mail where the CS is speaking to investors. 11 business plan for EMATUM.
12 Q Mr. Pearse, what did you indicate to the defendant at the 12 MR. BINI: Your Honor, would this be an appropriate
13 bottom of that e-mail that we read? 13 time for a short break?
14 I just want you to read the last two sentences that 14 THE COURT: Yes. Why don't we take a short
15 you wrote to the defendant. 15 15-minute break. That will be our mid-morning break.
16 A "CS is speaking to investors early next week, so expect 16 Again, do not talk about the case amongst yourselves
17 to have a strong view by the end of the week. Proindicus 17 and we will see you in 15 minutes. Thank you.
18 upsize for Friday is fine - size to be determined Tuesday." 18 (Jury exits the courtroom.)
19 Q Was the defendant aware that you were going to outside 19 THE COURT: You may step down, Mr. Pearse. The jury
20 investors in order to finance this EMATUM contract? 20 has left the courtroom. You may be seated, ladies and
21 A I was not going to outside investors. 21 gentlemen.
22 Q Was the defendant aware that Credit Suisse was going to 22 Do we have any issues that we need to address
23 outside investors in order to market the EMATUM contract loan? 23 outside the presence of the jury? From the Government?
24 A Yes. The defendant was aware that Credit Suisse was 24 MR. BINI: Not from the Government.
25 talking to investors in order to market the money. 25 THE COURT: From the defense?
Page 522 to 525 of 681

1 MR. JACKSON: No, Your Honor. 1 A It was a spreadsheet which included a projection of the
2 THE COURT: Thank you. We will take our 15-minute 2 expected financial performance of EMATUM as a project.
3 break. I will see you in 15 minutes. 3 Q Who prepared that spreadsheet?
4 (Recess.) 4 A Ms. Subeva.
5 (In open court - jury not present.) 5 Q Why was it prepared?
6 THE COURTROOM DEPUTY: Judge Kuntz presiding. 6 A It was prepared to be provided to Credit Suisse to show
7 THE COURT: You may be seated. They are producing 7 that the EMATUM project was expected to generate significant
8 the defendant. 8 revenue over the lifetime of the project.
9 Do we have any procedural issues to address before 9 Q Did that, in fact, occur?
10 we bring the jury in? 10 A Yes, the model was sent to Credit Suisse.
11 MR. BINI: Not from the United States. 11 Q Did EMATUM actually generate significant revenue over the
12 MR. JACKSON: No, Your Honor. 12 life of its project?
13 THE COURT: Mr. Jackson, let the CSO know and we can 13 A No, it did not.
14 have the witness come back to the witness stand, please. 14 Q What did Ms. Subeva write in her e-mail?
15 MR. BINI: Yes, Your Honor. 15 A "Hi. By the way, does Antonio know not to mention me or
16 THE COURT: Thanks. 16 you at all? Because obviously he thought I was from Credit
17 Have a seat, sir. 17 Suisse. Has Jean spoken to him and that lady from fisheries
18 THE WITNESS: Thank you, Your Honor. 18 should treat them as a separate team?"
19 THE COURT: Again, feel free to move that microphone 19 Q What did you understand Ms. Subeva to be concerned about?
20 closer to you and tilt it so Madam Reporter can hear you. 20 A She was concerned that Credit Suisse did not discover
21 THE WITNESS: Thank you. 21 that she had been working on the EMATUM project behind the
22 (Jury enters the courtroom.) 22 scenes when meeting Mozambican officials for their diligence.
23 THE COURT: Welcome back, ladies and gentlemen of 23 Q Why would that be a problem?
24 the jury. Again, I thank you for your continued promptness. 24 A Neither she nor I were allowed, under the terms of our
25 Please be seated and we will continue with the examination of 25 contracts with Credit Suisse, to work during our garden leave.
1 the witness. 1 THE COURT: Go ahead. Continue your answer.
2 MR. BINI: Your Honor, at this time, the Government 2 A Plus, had Credit Suisse been aware that she and I were
3 would offer Government Exhibit 2397. 3 working behind the scenes, it is unlikely that they would have
4 THE COURT: Any objection? 4 approved the loan.
5 MR. SCHACHTER: No objection, Your Honor. 5 Q Why?
6 THE COURT: You may publish. It is admitted. 6 A They would not -- as I understood it, from my experience
7 (Government's Exhibit 2397 received in evidence.) 7 at working at Credit Suisse, that fact would have been a red
8 (Exhibit published.) 8 flag, which would have prevented them from moving forward.
9 BY MR. BINI: 9 Q Was Credit Suisse aware, as far as you know, that Ms.
10 Q Mr. Pearse, when this e-mail comes up, I would like to 10 Subeva had prepared the financial model for EMATUM?
11 direct your attention to the second from the top e-mail, the 11 A They were not as far as I'm aware.
12 e-mail from Ms. Subeva. What is the date of this e-mail, Mr. 12 Q How did you respond to Ms. Subeva?
13 Pearse? 13 A I told them, but you never know.
14 A 4th of August, 2013. 14 Q What did you mean by that?
15 Q Who is it from? Who is it to you? 15 A I was responding to her e-mail and telling her that I had
16 A It's from Detelina Subeva to myself. 16 told the relevant Mozambican parties and Mr. Boustani that I
17 Q What's the subject? 17 was not in a position to control what they said.
18 A Financial model. 18 MR. BINI: At this time, Your Honor, the Government
19 THE COURT: Just again, pull the microphone closer 19 would seek to admit Government Exhibit 2398?
20 to you and keep your voice up and I'm sure Madam Reporter is 20 THE COURT: Any objection?
21 able to hear you. Go ahead. 21 MR. SCHACHTER: No objection, Your Honor.
22 Q Do you know what the financial model referred to, Mr. 22 THE COURT: You may publish. It's admitted.
23 Pearse? 23 MR. BINI: Thank you, Your Honor.
24 A Yes. 24 (Government's Exhibit 2398 received in evidence. )
25 Q What was it? 25 Q Looking to the bottom e-mail from Ms. Subeva, what's the
Page 526 to 529 of 681
1 date of that e-mail, Mr. Pearse? 1 this portion, the why ADM portion of the due diligence?
2 A 4th of August, 2013. 2 A Yes.
3 Q Who did she write to? 3 Q If we go back to 2398 BY itself and I will ask you to
4 A Jean Boustani and myself. 4 look at the top portion of the e-mail. Actually, let's go to
5 Q What did she write? 5 the middle e-mail from the defendant Jean Boustani. How did
6 A "Hi, just spoke with Antonio to set a time to speak later 6 he respond to Ms. Subeva?
7 today to discuss the model. He confirmed all meetings are 7 A I will do why ADM with Tony, no worries, hayeti habibi.
8 set." 8 Q What did you understand the defendant to mean?
9 Q Let me stop you there. What did you mean -- what did you 9 A I understood him to mean that he would answer the
10 understand Ms. Subeva to mean when she wrote just spoke with 10 questions as to why ADM had been appointed by EMATUM if asked
11 Antonio to set a timeframe to speak later today to discuss the 11 by Credit Suisse.
12 model? 12 MR. BINI: If we can go to the very top e-mail.
13 A She was reporting a conversation she had with Antonio do 13 Q How did Ms. Subeva respond?
14 Rosario where she set up a time to discuss the financial model 14 A "Aww. Please remind Antonio not to mention Andrew and
15 for EMATUM. 15 myself to Credit Suisse team. They cannot know we are
16 Q What did Ms. Subeva write in the third sentence? 16 involved in this project. If there is a slipup, say he knows
17 A "He said that" -- I'm sorry, that's the fourth. 17 us from the previous deal. Thank you. Habibi.
18 "I also told him that if there are any questions 18 Q What was Ms. Subeva concerned with in that e-mail?
19 that are too specific, he can say he will revert in writing." 19 A She was concerned that Antonio do Rosario would disclose
20 Q Do you know why she wrote that? 20 to Credit Suisse that she was working on the EMATUM project
21 A Yes. 21 behind the scenes.
22 Q Why? 22 MR. BINI: Okay. You can take that exhibit down.
23 A Because the information that was required to prepare the 23 Your Honor, at this time, the Government would offer
24 financial model as detailed. Antonio do Rosario may not have 24 Government's Exhibit 2406.
25 been aware of all those details. So she was providing Antonio 25 THE COURT: Any objection?
1 do Rosario with a response in order to delay having to answer 1 MR. SCHACHTER: No objection.
2 any difficult question or any question he could not answer 2 THE COURT: You may publish. It's admitted.
3 that came from Credit Suisse. 3 MR. BINI: Thank you, Your Honor.
4 Q What's the next thing that Ms. Subeva wrote? 4 (Government's Exhibit 2406 received in evidence.)
5 A He said that Isaltina, the Minister of Finance and HE all 5 Q If we can go to the e-mail that's on the bottom of page 1
6 have the feasibility study. 6 and most of page 2. Let's just look starting with the who it
7 Q What did you understand that to mean? 7 is from and to.
8 A I understood that to mean that the feasibility study for 8 A It is from myself to Jean Boustani copying Detelina
9 the EMATUM project had been provided to Isaltina Lucas, who 9 Subeva.
10 was the National Director of Treasuries; Minister of Finance, 10 Q What is the date?
11 Manuel Chang, and his Excellency, the President of Mozambique, 11 A 17th of August, 2013.
12 Armando Guebuza. 12 Q And if you would now look to the email, take a look at it
13 Q What is the last sentence in the email from Ms. Subeva? 13 and if you can explain, summarize to the jury what you were
14 A "Jean, just ant to confirm if you've had a chance to send 14 writing to the defendant and Ms. Subeva?
15 to, discuss with Antonio the answers to why ADM?" 15 A I'm providing an update how much Credit Suisse was
16 Q What did you understand Ms. Subeva to be referring to 16 expected to underwrite of the EMATUM bonds, together with an
17 there? 17 estimate of the timetable and the price of the bonds.
18 A She was referring to the discussion we showed the Court 18 Q And if we look to item B, the one that says CS needs to
19 earlier as to the justification for why EMATUM had appointed 19 involve Morgan Stanley to sell the bonds. What are you
20 Abu Dhabi MAR and the process EMATUM had gone through in order 20 setting out there, Mr. Pearse?
21 to appoint Abu Dhabi MAR through a competitive process. 21 A When an investment bank is an underwriter of bonds, it is
22 MR. BINI: If we can set this side by side to 2375. 22 common to involve another bank or a series of banks.
23 If you can blow up the top of that e-mail, 2375, it says why 23 Q Let me ask you, what is an underwriter of bonds, what
24 ADM? 24 does that mean?
25 Q Was Ms. Subeva indicating that the defendant could handle 25 A It is the bank that is responsible for -- has the
Page 530 to 533 of 681

1 agreement with the company that will -- or Government that's 1 sidebar. Do you have an objection?
2 going to issue the bond and is primarily responsible for 2 MR. SCHACHTER: Yes, Your Honor.
3 finding investors for that bond. 3 THE COURT: We will take it at the sidebar.
4 Q Was Morgan Stanley being considered as joining the group 4 Sorry, ladies and gentlemen.
5 of banks that would offer and underwrite the bond? 5 (Sidebar held outside the hearing of the jury.)
6 A Yes. In the context of -- in a normal market condition, 6
7 the lead underwriting bank would tend to involve -- normally 7
8 involved other banks in order to -- for those banks to help 8
9 find investors, particularly if the other bank had an 9
10 expertise in finding investors for certain types of companies 10
11 or Governments. In this case, at this point in time, Credit 11
12 Suisse had indicated that they were going to involve Morgan 12
13 Stanley. 13
14 Q Where is Morgan Stanley located? 14
15 MR. SCHACHTER: Objection. 15
16 A It is a U.S. investment bank with an office in London. 16
17 Q Was there a significance of potentially involving a U.S. 17
18 investment bank? 18
19 MR. SCHACHTER: Objection. 19
20 THE COURT: Read the question back. 20
21 (Record read.) 21
22 THE COURT: You may answer. 22
23 A In my opinion, yes. Morgan Stanley, as a U.S. investment 23
24 bank, had better access to U.S. investors than Credit Suisse. 24
25 Credit Suisse had its own expertise in investors in Europe and 25
Pearse - direct - Bini 535 Sidebar 537
1 other parts of the world. But my understanding of why Credit 1 (The following occurred at sidebar.)
2 Suisse wanted to involve Morgan Stanley at this point in time 2 THE COURT: May I have the document, please?
3 was to maximize the number of investors it could show the 3 MR. BINI: Yes, Your Honor.
4 transaction to and would potentially be interested in buying 4 THE COURT: 2427; is that right.
5 and that included U.S. investors. 5 MR. BINI: Yes, Your Honor.
6 Q Did Morgan Stanley ultimately underwrite this bond? 6 THE COURT: You have an objection to the admission
7 A No. 7 of Government Exhibit 2427. It is a two-page document,
8 MR. BINI: Now, I would ask to admit Government 8 e-mails. What is your objection?
9 Exhibit 2427. 9 Do you have 2427 in front of you?
10 THE COURT: Any objection? 10 MR. SCHACHTER: Your Honor, I apologize. I withdraw
11 If you can't find it, you can publish to him 11 the objection.
12 electronically. 12 THE COURT: That's fine. Thank you.
13 MR. SCHACHTER: No objection. 13 MR. SCHACHTER: I'm sorry, Your Honor. One more --
14 THE COURT: It is admitted. You may publish it to 14 THE COURT: We are back on 2427. Do you have an
15 the jury. 15 objection?
16 MR. BINI: Thank you, Your Honor. 16 MR. SCHACHTER: Yes, Your Honor. I apologize. We
17 (Government's Exhibit 2427 received in evidence.) 17 just got this from the Government.
18 (Exhibit published.) 18 MR. BINI: We provided this before.
19 Q If we can go to the bottom e-mail from you to the 19 THE COURT: Please. Please.
20 defendant and Detelina Subeva. 20 MR. BINI: I'm sorry.
21 MR. SCHACHTER: May I have a moment with Mr. Bini? 21 THE COURT: Quit trying the case. I assume
22 THE COURT: I'm sorry, you said you had no 22 everything was produced. I assume given the amounts of paper,
23 objection? Why don't you sit down and use the microphone. No 23 occasionally one, in good faith, forgets, or perhaps it wasn't
24 speaking objection. 24 copied. I did this for 33 years. Now we can deal with what's
25 If you have an objection, we will take it at the 25 the issue?
Page 534 to 537 of 681
Sidebar 538 Pearse - direct - Bini 540
1 MR. SCHACHTER: Your Honor, we would ask that the 1 are you referring to?
2 line on the bottom of Mr. Boustani's e-mail at the top be 2 A This is the launch of the EMATUM bond.
3 redacted. 3 Q What do you mean by if there is a big move in the
4 THE COURT: Will strip for you online though. To 4 financial markets on Monday?
5 entertain your guests, okay? Mr. Boustani said that in this 5 A I meant that if there was a big move in interest rates on
6 e-mail. 6 Monday or credit market that Credit Suisse could delay the
7 MR. SCHACHTER: Yes, Your Honor. 7 launch.
8 THE COURT: Overruled. It comes in. 8 Q Why is that important?
9 (Sidebar concluded.) 9 A Because the bonds, the success of issuing the bonds is
10 (Continued on the following page.) 10 dependent on the price, which is a function of the interest
11 11 rate on that day, potentially, and also the credit appetite
12 12 for the Government of Mozambique risk at the time.
13 13 Q "Credit appetite," does that mean desire of outside
14 14 investors to purchase?
15 15 A Excuse me, sir. Yes, that's correct.
16 16 Q Okay. What did you write after you wrote that, about the
17 17 financial markets?
18 18 A "I believe this is unlikely given this is Labor Day in
19 19 U.S., so U.S. markets are closed and U.K. Parliament voted
20 20 against military action against Syria yesterday."
21 21 Q Why are the U.S. markets important when you are launching
22 22 a bond?
23 23 A It was a U.S. dollar-denominated bond. So U.S. interest
24 24 rates and markets were relevant to the launch of the bond.
25 25 Q What did you write after that?

1 (In open court - jury present.) 1 A "If it doesn't launch on Tuesday, 3rd, it will be the
2 THE COURT: The objection is overruled. You may 2 following week."
3 publish it. 3 Q If we can go to the next page. What did you write?
4 MR. BINI: Thank you, Your Honor. 4 A "They will launch a 500 million to 750 million size with
5 THE COURT: The "it" being 2427 in evidence. Go 5 a price of 8.25 percent."
6 ahead. 6 Q Let me stop you there. Can you explain that to the jury?
7 (Government's Exhibit 2427 received in evidence.) 7 A The final size of the EMATUM bond had not been decided at
8 Q If we can look to the e-mail between you and Jean 8 this time. The hope was that it would be $850 million, but
9 Boustani and Ms. Subeva. What is the date of this e-mail? 9 the bank, Credit Suisse had not confirmed it could place $850
10 A 30th of August, 2013. 10 million with investors. So they were proposing to launch --
11 Q What's the subject? 11 announce to the investor community a bond of a size between
12 A Bond update. 12 $500 and $750 million with a price indicated at 8.25 percent.
13 Q Can you read -- it is lengthy. I'm going to stop you a 13 That is the interest rate that would be paid to investors who
14 few times, but if you could read it to the jury? 14 bought the bond.
15 A Hayati. 15 Q What did you write next?
16 Q What does hayati mean? 16 A "It is possible to up size to $850 million, if the demand
17 A My love, I believe. 17 is there, but unlikely. If it launches on the 3rd, it will
18 Q In what language, if you know? 18 close on Thursday, 5th of September."
19 A Arabic. 19 Q What does that mean?
20 Q After "hayati," what did you write? 20 A The launch is the date that -- the fact the bond is going
21 A "The plan of CS is to launch the bond on Tuesday, 3rd of 21 to be issued becomes public, becomes a matter of public
22 September. Launch means it will be public and in the 22 record. There is a gap between that date and when the bank
23 newspaper. Launch will not happen if there is a big move in 23 finalizes its order book from investors and closes the bond
24 financial markets on Monday." 24 transaction and the date at which the bank says I know got
25 Q I'm going to stop you there for a moment. What launch 25 sufficient investors for in this case $500 million.
Page 538 to 541 of 681
1 Q Can you read the sentence settlement and funding? 1 Q Was that a nickname that you sometimes heard the
2 A Settlement and funding of our loan takes place five 2 defendant used to refer to him?
3 business days after close of the bond i.e., 12 September. 3 A Frequently, yes.
4 Q What does that mean? 4 Q Do you know, or did you have any discussions with the
5 A After the bond closes, investors have committed to buy 5 defendant whether he went to Paris with Manuel Chang?
6 the bond from, in this case, Credit Suisse, there is a period 6 A I do not know whther he went to Paris, but I was aware
7 of time for payment by the investors of the monies for buying 7 that Manuel Chang was in the South of France at the estates of
8 the bond to the bank and, consequently, there is a time period 8 Iskandar Safa the weekend that followed this Friday.
9 after the bond closes before the bank was to make payments to 9 Q What, if anything, did the defendant tell you about that?
10 Privinvest under the procurement contract. 10 A I had sent the defendant a presentation relating to a
11 Q So which comes first, the bond or the payment to 11 fund we were developing, an investment fund idea that we were
12 Privinvest? 12 developing, and he told me he was meeting with Manuel Chang,
13 A The bank was needed to have investors for at least 500 13 wanted to show him the proposal.
14 million from the bond market before it would make the loan to 14
15 pay Privinvest. 15 (Continued on next page.)
16 Q Now, if we can go to the next e-mail on page 1. The 16
17 e-mail from Mr. Pearse at 11:51 p.m. on August 30. 17
18 MR. BINI: If you could expand that for us, Ms. 18
19 DiNardo. 19
20 Q Did you write something else to the defendant? 20
21 A Yes, I did. 21
22 Q What did you write? 22
23 A "Oh, one more thing. It's my birthday on 6th, so I'm 23
24 having a party in London on 5th night if you would like to 24
25 come. Hopefully a double celebration." 25
Pearse - direct - Bini 543 PEARSE/DIRECT/BINI 545

1 Q What were you hoping to celebrate in addition to your 1 (Continuing.)
2 birthday? 2 MR. BINI: At this time, Your Honor, the Government
3 A The closing of the EMATUM bond. 3 would seek to admit Government's Exhibit 2428.
4 Q Why would that be a cause for celebration? 4 THE COURT: Any objection?
5 A Because that would personally have meant that I received 5 MR. SCHACHTER: (No response.)
6 a fee, a significant amount of fee for that financing closing. 6 THE COURT: And again, if defense counsel is having
7 Secondly, it was -- would have resulted in 7 trouble finding it, you can publish it just to defense counsel
8 Privinvest receiving money under the procurement contract in 8 for his review electronically, then he can advise the Court if
9 relation to the tuna fishing fee that was being purchased from 9 he has an objection. That will help move things along.
10 them. 10 MR. SCHACHTER: No objection, Your Honor.
11 Q Would that have been profitable for the defendant? 11 THE COURT: It's admitted. You made publish.
12 A Yes. As it was for me, it was for Mr. Boustani. 12 MR. BINI: Thank you, Your Honor.
13 Q And how did the defendant respond to your request to have 13 (Government's Exhibit 2428 was received in evidence.)
14 this celebration? 14 (Publishes exhibit to the jury.)
15 A "I will do my best. Ouuuuuu hayati habibi oumri." 15 BY MR. BINI:
16 Q What do you understand that to mean, if you know? 16 Q I want to look at the email from Ms. Subeva. Is this an
17 A The first, I don't. 17 email in response to your email regarding the launch of the
18 "Hayati habibi " is my love, my dear. "Oumri," I 18 bond?
19 don't know. I assume it's Arabic. 19 THE COURT: Pull the mic to you if you're going to
20 Q What did the defendant write after that? 20 wander, Counsel, over here.
21 A Happy birthday, my angel. I wish I could, bro, will be 21 MR. BINI: Sorry, Your Honor.
22 in Paris with Chopstick. 22 THE COURT: Flip the T. You can move it that way.
23 Q Who is Chopstick? 23 A Yes, it is.
24 A Manuel Chang, who was the Minister of Finance of 24 BY MR. BINI:
25 Mozambique. 25 Q And if we go up to the email from 2144, from Ms. Subeva
MDL RPR CRR CSR LISA SCHMID, CCR, RMR
Page 542 to 545 of 681
PEARSE/DIRECT/BINI 546 PEARSE/DIRECT/BINI 548
1 to you. Subject: Re: Bond update, what did Ms. Subeva 1 A That is the description of the type of bond, the amount,
2 write? 2 and the type of bond that was being issued, and the date it
3 A "I'm sure. Do we have confirmation that it will 3 would mature, i.e, be repaid.
4 definitely -- definitely be part of the JPM Index?" 4 Q When you look down to the bottom of the first page, does
5 Q How did you respond? 5 it indicate the joint lead managers?
6 A Apparently, yes. 6 A Yes.
7 Q What is the JPM Index? 7 Q Who are they?
8 A JPM stands for JP Morgan. It's a U. S. Investment bank 8 THE COURT: It's a little tough to read. Could you
9 that publishes an index of emerging market bonds. 9 enhance it for the jury, please?
10 Q Is it important to -- if you have a bond, to get into the 10 MR. BINI: No, the joint lead managers, just at the
11 JP Morgan Index? 11 very bottom Ms. DiNardo.
12 A It is beneficial to get into the JP Morgan Index. 12 (Exhibit published.)
13 Q Why? 13 THE COURT: BNP Paribas, Credit Suisse, the usual
14 A Because bonds that are listed in the JP Morgan Index are 14 suspects, right?
15 required to be bought by investors that use that index as a 15 THE WITNESS: Yes, Your Honor.
16 means to sell all their bond products to other investors, 16 BY MR. BINI:
17 consumers. 17 Q And what is the date of this loan participation note
18 So a bond that was listed in the JP Morgan Index 18 offering circular?
19 would have more buyers, potentially, more buyers than a bond 19 A Ten September, 2013.
20 that was outside the JP Morgan Index. 20 Q Were you still an employee of Credit Suisse when this
21 Q Why is that? 21 launched?
22 A Because more investors were required to buy the bonds 22 A Yes.
23 that were in the index because of the underlying products they 23 Q Had you worked on this project?
24 sold their customers. 24 A I worked on the project behind the scenes, but not while
25 Q Is the United States market important in the bond market? 25 at Credit Suisse.
LISA SCHMID, CCR, RMR LISA SCHMID, CCR, RMR
1 A Yes. It's the largest bond market. 1 Q Did anyone at Credit Suisse know that you had been
2 MR. BINI: Your Honor, at this time the Government 2 working behind the scene in the emails that we have been
3 would seek to admit Government's Exhibit 251. 3 looking at this morning?
4 THE COURT: Any objection to 251? 4 A Yes.
5 MR. SCHACHTER: No objection, Your Honor. 5 Q Who?
6 THE COURT: It's admitted. You may publish. 6 A Surjan Singh.
7 (Government Exhibit 251 was received in evidence.) 7 Q Did Detelina Subeva also know your role in the EMATUM
8 (Publishes exhibit to the jury.) 8 loan?
9 MR. BINI: Thank you, Your Honor. 9 A Excuse me. Yes, she did, as well.
10 BY MR. BINI: 10 Q Did anyone else know at Credit Suisse that you were
11 Q Mr. Pearse, looking to the top of Government's Exhibit -- 11 secretly working on this project?
12 MR. BINI: I wandered. I apologize, Your Honor. 12 A Not that I'm aware of.
13 BY MR. BINI: 13 Q Do you know how this offering circular was used?
14 Q Looking to the top of Government's Exhibit 251, what is 14 A Generically, yes.
15 that exhibit? 15 Q How?
16 A That is the front page of the offering circular for the 16 A It was sent by Credit Suisse and BNP Paribas to their
17 first $500 million of the Mozambique or EMATUM bond. 17 clients who invest in bonds of this type.
18 Q What is an offering circular? 18 Q Who would be responsible for that role at Credit Suisse,
19 A This is the document that is sent to investors to enable 19 if you know?
20 them to decide whether to invest in the bond. 20 A The team was called a debt capital markets team, and at
21 Q And does it say at the top, "USD five hundred thousand -- 21 the time, it was headed by a gentleman called Chris Toughy.
22 excuse me, $500 million loan participation note due 22 Q Who's Chris Toughy?
23 September 2020"? 23 A He was a managing director at Credit Suisse, in charge of
24 A Yes. 24 the bond capital markets desk in Europe.
25 Q What does that mean? 25 Q Was his role similar that that gentleman, Dominic
Page 546 to 549 of 681
1 Schultens you mentioned earlier? 1 A This was the loan agreement that had been agreed between
2 A No, he was much more senior. 2 Credit Suisse and EMATUM, that -- and guaranteed by the
3 Q Did he also market loan instruments? 3 Ministry of Finance, which Credit Suisse then repackaged into
4 A In that respect, yes. Mr. Toughy was responsible for a 4 the bonds that were issued to investors.
5 team that sold bonds in the same way that Dominic Schultens 5 Q Was this loan agreement sent with the offering circular
6 was responsible in my group for selling loans. 6 to potential investors?
7 Q Okay. And if we go to page 15 of this document. The 7 A It's part of the offering circulars, included within it.
8 offering circular. It's 20 in the document. 8 Q And does this loan agreement -- if we go to the next page
9 MR. BINI: Ms. DiNardo, I'm going to ask about the 9 and look at the table of contents.
10 borrower on page 15 of the offering circular, Ms. DiNardo. I 10 THE COURT: Cough drops, nothing more. Let the
11 think it's up on 16. Right after lender. Do you see that? 11 record reflect nothing more.
12 If you could blow that up? 12 Go ahead.
13 BY MR. BINI: 13 If you need anymore, we've got more?
14 Q Is there a portion that summarizes the loan agreement? 14 JUROR: Thank you.
15 A Yes. 15 THE COURT: Okay.
16 Q Why is that summarized in this offering circular? 16 MR. BINI: Thank you.
17 A Because the type of bonds that were issued were known 17 Able to get 251 up?
18 technically as loan participation notes, which means that the 18 If it's not working, I can, with the Court's
19 bond holders would receive all the money that was paid by 19 permission, do this old school with the projector.
20 EMATUM on the loan, would be passed through to them as bond 20 THE COURT: Yes, you can use the projector. It's
21 holders. 21 called the Elmo, which I used to think meant Electronic Light
22 Q And is there a section just below that -- 22 Modification Ordinance. It is the name of the company that
23 MR. BINI: If we could expand that for the jury, Ms. 23 makes the machines that everyone's talking about. We use the
24 DiNardo? It says "Use of Proceeds of the Loan." 24 Elmo.
25 BY MR. BINI: 25 MR. BINI: Thank you, Your Honor.

1 Q What does it indicate, Mr. Pearse? 1 THE COURT: You may have to adjust it or dim the
2 A It indicates that EMATUM will apply the money borrowed to 2 lights a little bit, Mr. Jackson, so the jurors can see it
3 buy 27 vessels, an operation center and related training. 3 more clearly.
4 Q Is that the material that we saw set out in the 4 Can you see, ladies and gentlemen of the jury?
5 procurement contract between EMATUM and Privinvest? 5 That's okay?
6 A Yes. 6 MR. BINI: So this is a loan agreement --
7 Q I would like to now ask you to go to page 44 of the 7 THE COURT: Again, microphone. Twist it to you.
8 offering circular. 8 They're the finders of fact. They've got to see it. They've
9 MR. BINI: You can go one page up. Ms. DiNardo. 9 got to hear it.
10 I'm sorry. Page 44 at the bottom. If you'd expand the top 10 Go ahead.
11 portion where it says "The Loan Documents." 11 MR. BINI: Yes, Your Honor. Thank you.
12 BY MR. BINI: 12 BY MR. BINI:
13 Q Mr. Pearse, what appears at page 44 of the offering 13 Q Is this the loan agreement that we have been looking at,
14 circular? 14 Mr. Pearse?
15 A It's a summary page which relates to the fact that the 15 A Yes.
16 loan documents are appended and attached to the offering 16 Q And is the next page table of contents with clauses?
17 circular. 17 A Yes.
18 Q Okay. And if we go to the next page, what is this? 18 Q Are these clauses many of the same clauses that we saw in
19 A That is a copy of the front page of the loan agreement 19 the Proindicus loan agreement?
20 between Credit Suisse and EMATUM. 20 A Yes. It's based on the same underlying standard form
21 Q Yesterday, we spent some time going through the 21 document.
22 Proindicus loan agreement. Is this loan agreement similar to 22 Q What was that called again?
23 that one? 23 A It's document which is published by the Loan Markets
24 A Yes. 24 Association, in London.
25 Q Why is that? 25 Q I don't want to spend a lot of time on this, because we
Page 550 to 553 of 681
1 did this yesterday. 1 THE COURT: Also, what language is it in?
2 THE COURT: I'm glad to hear that. So is the jury. 2 BY MR. BINI:
3 Go ahead. 3 Q Is the beginning part of this in Portuguese?
4 BY MR. BINI: 4 A Yes, it is.
5 Q On page 13, does it set out the purpose of the loan? 5 Q And if we turn to the third page, what's after those two
6 A Yes. 6 pages in Portuguese?
7 Q And is that the -- is that to finance the project? 7 A That is a copy of the first page of the loan facility
8 A Yes. 8 between Credit Suisse and EMATUM.
9 Q Okay. And is the project defined earlier as what we have 9 Q I just want to go back to the signature pages. Was an
10 been talking about, the EMATUM fishing vessels? 10 unsigned copy of this loan agreement attached to the offering
11 A To the best of my recollection, yes. 11 circular sent to investors and potential investors in the
12 Q Okay. And does this have -- this is the loan agreement 12 EMATUM loan participation note?
13 that we had yesterday -- a definition of the word "clause" 13 A Yes.
14 regarding compliance of laws? 14 Q Who signed the actual facility agreement?
15 A Yes, it does. 15 A Antonio Do Rosario.
16 Q And if you can just summarize what does this compliance 16 Q On behalf of whom?
17 with laws clause state in your own words? 17 A On behalf of EMATUM.
18 A It relation to the clause 19-2A, it's referring to 18 Q Who signed on behalf of Credit Suisse?
19 compliance with anti-corruption laws i.e., what that means is, 19 A Surjan Singh and Malaf Paki.
20 borrowers, promising not to pay bribes or kickbacks. 20 Q Did Surjan Singh have a financial incentive in signing
21 Q Is this part of what went to investors? 21 this?
22 A Yes. 22 A Yes, he did.
23 Q Okay. Now, I'm going to ask you -- 23 Q Why?
24 MR. BINI: Your Honor, I would ask to admit 24 A Prior to this date, he had negotiated through me to
25 Government's Exhibit 2783 and 2783A. 25 receive just over $4 million from Privinvest for his
1 THE COURT: Any objection to 2783 and 2783A? 1 assistance in getting Credit Suisse to make this loan.
2 MR. SCHACHTER: May I just have a moment, Your 2 Q Who if anyone did you negotiate with Privinvest regarding
3 Honor? 3 the fee or kickback to Surjan Singh?
4 THE COURT: You may. 4 A The defendant, Jean Boustani.
5 MR. SCHACHTER: No objection. 5 Q Does the loan agreement in any place describe the
6 THE COURT: You may publish. They're admitted. 6 payments to you or Surjan Singh?
7 (Publishes exhibit to the jury.) 7 A No.
8 (Government Exhibits 2783 and 2783A were received in 8 Q In your experience, is that something that would have
9 evidence.) 9 been important to investors?
10 BY MR. BINI: 10 MR. SCHACHTER: Objection.
11 Q What is 2783? 11 THE COURT: Overruled.
12 A That is an email from myself to Surjan Singh on the 25th 12 In your view, would it have been important to
13 of July, 2014. 13 investors to know you were getting bribes and kickbacks?
14 Q And if we look to -- what did you ask? 14 THE WITNESS: Yes.
15 A I asked him if he could send me a copy of the loan 15 MR. BINI: May I have one moment to confer with my
16 agreements and guarantee for EMATUM. 16 colleagues, Your Honor?
17 Q And what did Mr. Singh respond? 17 THE COURT: Yes. Of course.
18 A He said, "Please see attached," and he attached those 18 MR. BINI: (Confers with co-counsel.)
19 documents. 19 (Pause in proceedings.)
20 Q Okay. This is all the way in 2014, is that right? 20 BY MR. BINI:
21 A Yes. 21 Q Okay. At this time -- before do I that, let me ask you
22 Q Okay. What is 2783A? 22 one other question. Mr. Pearse, would Credit Suisse have
23 A I'm sorry. I can't see what that is. 23 funded this loan if they had known that Surjan Singh was
24 THE COURT: You have to center it, counsel. 24 getting kickbacks?
25 MR. BINI: (Complies.) 25 A No.
Page 554 to 557 of 681
1 MR. BINI: At this time, Your Honor, I would seek to 1 Overruled.
2 admit Government's Exhibit 2452. 2 THE WITNESS: She was expressing concern that it
3 THE COURT: Any objection to 2452? 3 appeared that the Government of Mozambique had issued a
4 MR. SCHACHTER: May I have a moment, Your Honor? 4 sovereign bond.
5 THE COURT: Sorry? 5 She is asking Surjan Singh and Nicholas Samara to
6 MR. SCHACHTER: May I have moment. 6 clarify under what terms of the loan agreement, financial
7 THE COURT: Yes, you may. 7 agreement referred to earlier, that there is an article or
8 MR. SCHACHTER: No objection. 8 provision that allows for the issue of a sovereign bond on
9 THE COURT: You may publish. It is admitted. 9 behalf of the Government of Mozambique. She is also
10 MR. BINI: Thank you, Your Honor. 10 referencing article 35 of that agreement.
11 (Government Exhibit 2452 was received in evidence.) 11 Q What was Ms. DeLucas' position in Mozambique?
12 (Publishes exhibit to the jury.) 12 A She was at this time national director of treasury.
13 BY MR. BINI: 13 Q She's indicating that she didn't know about this?
14 Q I'm going to ask you to look to an email from 14 A That is correct. Yes.
15 September 10th, 2013, from Isaltina Lucas to Surjan Singh. 15 Q Okay.
16 Nicolas Samara at Citi.com, Jean Boustani, Galina Barakova, Ed 16 A Sorry could I --
17 Kelly, Antonio Do Rosario, Jessica Foong at Simmons-.com, 17 Q Could you explain --
18 regarding final version of facility agreement? 18 A -- that answer a little bit more fully.
19 THE COURT: See what happens when you don't pull the 19 Does this refer to the letter that -- she is
20 mic towards you? The reporter can't hear you. 20 explaining through this letter that she was surprised or did
21 MR. BINI: Final version of the facility agreement. 21 not know about the issue of the EMATUM bond.
22 BY MR. BINI: 22 Q And now, I'm going to ask you to look at who responded to
23 Q Did this email later get forwarded to you, Mr. Pearse? 23 that email. Who's that from?
24 A Yes, it did. 24 A It was from Jean Boustani.
25 Q Can you read Ms. DeLucas's email? 25 Q And what did Mr. Boustani write back after Ms. DeLucas

1 A "Dear Singh and Nicholas. It was with some concern that 1 note?
2 we, the Government of Mozambique, took note that there is an 2 A "Dear Surjan, after discussing this matter with" --
3 emission of sovereign bond of the Mozambican Government to 3 THE COURT: Slow it down. It's Vader, not Rock.
4 finance EMATUM Enterprise. This information being divulgate 4 Take your time. Court reporter's got to hear it. Loud and
5 in the economic international media, including Bloomberg. 5 slow.
6 Many financial institutions in and outside the country 6 Go ahead.
7 informed us that they have received from JP Morgan an 7 THE WITNESS: I apologize.
8 invitation to participate on that operation. To have a better 8 A "After discussing this matter with Madam Lucas, we
9 clarification on the matter, we hereby kindly request your 9 realized that there was a misunderstanding. Since the bond is
10 help in order to find in the financial agreement or in the 10 not issued directly from the Ministry of Finance of
11 guarantee an article where it allows the issues of sovereign 11 Mozambique, but from the private company, EMATUM, supported
12 on behalf of the Government of Mozambique. We would also like 12 and guaranteed by the MoF, so all clear, and no issues at all.
13 to attract your attention to article 35 of the finance 13 Thank you."
14 Agreement. In order to avoid much more constraints as this 14 Q What did you understand the defendant to mean?
15 matter is turning, we kindly request your response as soon as 15 A He was responding -- he was responding in relation Ms.
16 it is possible." 16 Isaltina Lucas' letter which had been specifically referencing
17 Q What did you understand Ms. DeLucas to be complaining 17 the issue of a sovereign bond, and he's distinguishing between
18 about? 18 a sovereign bond and the EMATUM bond that was issued, which
19 A The issue of the EMATUM bond. 19 was a loan participation note guaranteed by the Ministry of
20 Q What was she saying -- 20 Finance of Mozambique.
21 MR. SCHACHTER: Objection. 21 Q Did Ms. DeLucas respond?
22 Q -- of her understanding? 22 A Subsequently, yes.
23 A She was expressing surprise that -- 23 Q What did she write?
24 MR. SCHACHTER: Your Honor, objection. 24 A "Clear."
25 THE COURT: In your view, what was she saying? 25 Q Did this email then get forwarded to you?
Page 558 to 561 of 681

1 A Yes, it did. 1 Q Why were you doing that?
2 Q By whom? 2 A In order for him to open an account to receive the
3 A By Mr. Boustani. 3 payment from Privinvest.
4 Q And how did you respond to Mr. Boustani on September 10, 4 MR. BINI: At this time, Your Honor, the Government
5 2013? 5 would admit or seek to admit Government's Exhibit 2456.
6 A "Bro, this is okay, but not really good enough. Can you 6 THE COURT: Any objection to 2456?
7 get the full email out of him?" 7 MR. SCHACHTER: May I have just a moment?
8 Q What did you mean when you said, this is okay, but really 8 No objection.
9 not good enough? 9 THE COURT: You may publish. It is admitted.
10 A The letter that Ms. DeLucas had sent to Credit Suisse was 10 MR. BINI: Thank you, Your Honor.
11 complaint letter. It indicated that Credit Suisse had issued 11 (Government Exhibit 2456 was received in evidence.)
12 a bond on behalf of Government of Mozambique without having 12 (Publishes exhibit to the jury.)
13 the approval of the Government of Mozambique. 13 BY MR. BINI:
14 This was a serious matter within Credit Suisse. It 14 Q Do you recognize this email chain, Mr. Pearse?
15 was a breach of contract and protocol. So, the most 15 A Yes.
16 appropriate response was from the Ministery of Finance, not 16 Q What's the top email, who's it from, who's it to?
17 from the contractor, Mr. Boustani. 17 A It's from myself to Pauline Kamel.
18 So, I felt that Ms. DeLucas should send a more full 18 Q And what were you sending Pauline Kamel?
19 explanation as to why the complaint would be withdrawn, not 19 A A copy of Mr. Singh's passport, including the residency
20 simply reference the explanation given by Mr. Boustani. 20 stamp.
21 MR. BINI: Your Honor, I understand that the laptop 21 MR. BINI: Your Honor, at this time, the Government
22 is working again. Can I switch back to that and turn this 22 would seek to admit Government's Exhibit 2457 and 2458.
23 off? 23 THE COURT: Any objection?
24 THE COURT: Yes, you can. 24 MR. SCHACHTER: No, Your Honor.
25 Can we do that, Mr. Jackson? 25 THE COURT: They are admitted. You may publish.

1 THE CLERK: Yes, Judge. 1 (Government's Exhibits 2457 and 2458 were received in
2 THE COURT: Thank you. 2 evidence.)
3 MR. BINI: At this time, the Government would seek 3 (Exhibit published to the jury.)
4 to admit Government's Exhibit 5083. 4 BY MR. BINI:
5 THE COURT: Any objection to 5083. 5 Q Before we go there, I'll just ask you, Mr. Pearse, who
6 MR. SCHACHTER: No objection, Your Honor. 6 sent you the -- Surjan Singh's passport?
7 THE COURT: It's admitted. You may publish. 7 A He did.
8 (Government Exhibit 5083 was received in evidence.) 8 THE COURT: He being?
9 (Publishes exhibit to the jury.) 9 THE WITNESS: Excuse me, Your Honor. Surjan Singh
10 BY MR. BINI: 10 did.
11 Q And what's the date of this email chain? 11 THE COURT: Okay. Go ahead.
12 THE COURT: It's just a little blurry. Can you make 12 BY MR. BINI:
13 it a bit more accessible, please? Thank you. 13 Q Okay. Now we can go to 2457.
14 A September 11, 2013. 14 MR. BINI: And you could flip that upside. Thank
15 BY MR. BINI: 15 you, Ms. DiNardo. You can blow up the page that has a picture
16 Q Who is it from, who is it to? 16 of an individual.
17 A It's from myself to Dilawar Property, Limited. 17 BY MR. BINI:
18 MR. BINI: If you can, Ms. DiNardo, get the top two 18 Q What's 2457?
19 emails, so we can see the email that was responding to. 19 A That is a copy of the photo page from the passport of Mr.
20 BY MR. BINI: 20 Singh.
21 Q Why were you emailing Surjan Singh, "Please send a 21 Q And if we go to 2458, what is 2458?
22 passport copy, including residency page"? 22 A This is a copy of the residency stamp in Mr. Singh's
23 A In order that I could send that to Pauline Kamel at Abu 23 passport.
24 Dhabi Commercial Bank, so that she would open an account, a 24 Q Did you have any conversations with the defendant or
25 bank account for Mr. Singh. 25 Surjan Singh regarding how his -- Surjan Singh had a residency
Page 562 to 565 of 681
1 permit for the United Arab Emirates? 1 (In open court - jury present.)
2 A Yes. 2 THE COURT: The objection is withdrawn. The
3 Q Who you did speak to and what did they the tell you? 3 document is admitted. You may publish it to the jury, it
4 A I spoke to the defendant, Surjan Singh and Najib Allam. 4 being Government Exhibit 3125 in evidence.
5 Q And what did they tell you? 5 (Government's Exhibit 3125 was received in evidence.)
6 A They agreed to assist in the opening of the bank account, 6 (Exhibit published the jury.)
7 and obtaining the residency permit. 7 MR. BINI: Thank you, Your Honor.
8 Q What was indicated as the employer or the sponsor for 8 THE COURT: You may proceed.
9 Surjan Singh? 9 BY MR. BINI:
10 A Privinvest Holding, Abu Dhabi. 10 Q If we can go to the email from you to David Langford, at
11 Q What position was he indicated as having? 11 2:44 p.m., the bottom email? Who is this email from and who
12 A Archives clerk. 12 is it to?
13 Q What was Surjan's Singh's position at this time, in 13 A It's from myself to David Langford and Chris Langford,
14 reality? 14 and the defendant.
15 A He was managing director, head of the global finance 15 Q What is the subject?
16 group in Europe for Credit Suisse. 16 A Palomar Holding.
17 MR. BINI: At this time, Your Honor, the Government 17 Q And if you could review it and then explain to the jury
18 would seek to admit Government's Exhibit 3125? 18 what were you emailing about.
19 THE COURT: Any objection to 3125? 19 A I was emailing about how the fee that Palomar was to
20 MR. SCHACHTER: Yes, Your Honor. 20 receive from Privinvest for advising on the EMATUM bond would
21 THE COURT: All right. Sidebar. 21 be paid to the shareholders of Palomar.
22 22 Q Why were you emailing David Langford, Chris Langford and
23 23 Jean Boustani, the defendant?
24 24 A David Langford, as well as Mr. Safa, and was a person I
25 25 would email in relation to matters that affected Mr. Safa. I
SIDEBAR 567 PEARSE/DIRECT/BINI 569

1 (Sidebar.) 1 did not have Mr. Safa's email address.
2 THE COURT: May I see the document, please, counsel? 2 Chris Langford is the father of the David Langford,
3 Counsel who is offering it should hand it up. 3 who established the companies in the British Virgin Islands,
4 MR. BINI: I'm grabbing a copy. I think I grabbed 4 that was Palomar Holdings, and Jean Boustani was a partner in
5 the wrong binder. I apologize. 5 Palomar Holdings.
6 THE COURT: That's all right. 6 Q How did the defendant respond?
7 MR. SCHACHTER: Your Honor, I withdraw the objection 7 A "ADM will transfer $49,200,000 to Palomar. I think we
8 again. 8 need to conduct the shareholders' loan of PH first, as agreed,
9 THE COURT: Okay. 9 and the rest goes to the others. Do you want to leave some
10 (Sidebar concluded.) 10 OPEX, up to you my friend."
11 11 Q What did you understand the defendant to mean?
12 12 A Firstly, that Abu Dhabi Mar would pay Palomar $49,00,000
13 13 as a fee for advising on the EMATUM loan.
14 14 Secondly, that from that $49,200,000, a shareholder
15 15 loan which had previously been made would be repaid. And
16 16 after deducting that amount, the rest of the $49,200,000
17 17 would be paid to the owners.
18 18 He then asked me if I would like Palomar to retain
19 19 some of those monies in Palomar's account for operating
20 20 expenses.
21 21 MR. BINI: Okay. At this time, the Government would
22 22 seek to admit Government's Exhibit 2493.
23 23 THE COURT: Any objection?
24 24 MR. SCHACHTER: No objection.
25 25 THE COURT: It's admitted. You may publish to the
Page 566 to 569 of 681
1 jury. 1 relation to these projects.
2 MR. BINI: Thank you, Your Honor. 2
3 (Government Exhibit 2493 was received in evidence.) 3 (Continued on the next page.)
4 (Publishes exhibit to the jury.) 4
5 BY MR. BINI: 5
6 Q If we can look at the top email. Mr. Pearse, what's the 6
7 date of this email? 7
8 A First October, 2013. 8
9 Q What did the defendant write to you? 9
10 A "Sure. What I'm trying to say, Bro, is that we have a 10
11 green light to package as much as we want, but the IMF celing 11
12 will remain a problem. Anything we secure as extra seating 12
13 will be for us though." 13
14 Q What did you understand the defendant to mean? 14
15 A I understood that to mean that he had the political 15
16 support to raise as much financing as possible in Mozambique, 16
17 subject to not exceeding the IMF ceiling, the IMF's ceiling 17
18 was the maximum amount of borrowing that had been agreed 18
19 between Mozambique and the IMF for commercial borrowing. 19
20 Q Why was that important? 20
21 A It was important because that was -- the IMF ceiling was 21
22 a number that was published by the IMF from time to time. It 22
23 changed from time to time. 23
24 But it was publicly available, as was the total 24
25 amount of borrowing that Mozambique had been made. So any 25
PEARSE/DIRECT/BINI 571 Pearse - direct - Bini 573

1 bank who was to lend would know the size of the difference 1 EXAMINATION CONTINUING
2 between the ceiling and the amount that had been borrowed at 2 BY MR. BINI:
3 any given point in time. So that was the maximum any bank 3 Q What had happened around this time, October 2013?
4 would ever lend. 4 A VTB had underwritten a further 350 million of EMATUM
5 MR. BINI: At the time, this Government would seek 5 bonds.
6 to admit Government's Exhibit 2509. 6 Q So we had the 500 million from Credit Suisse, and now 350
7 THE COURT: Any objection to 2509? 7 additional sold by VTB?
8 MR. SCHACHTER: No objection. 8 A Yes.
9 THE COURT: It's admitted. You you may publish it 9 Q What's the next sentence from Mr. Berliner?
10 to the jury. 10 A Citi should now confirm receipt (we haven't received
11 (Government Exhibit 2509 was received in evidence.) 11 confirmation yet) and then Citi shall transfer the money to
12 (Publishes exhibit to the jury.) 12 Credit Suisse as facility agent.
13 BY MR. BINI: 13 Q Can you explain what that meant?
14 Q I want to ask you to look at the email from Felipe 14 A The paying agent is the person in a bond transaction, it
15 Berliner October 11, 2013, at 10:47. What did Mr. Berliner 15 was the entity in the bond transaction that receives all
16 write here? 16 payments on behalf of bondholders and pays all banks'
17 A "The settlement of the note has cleared, and we sent the 17 bondholders. In the same way that I described yesterday, a
18 money to Citi's account as paying agent." 18 facility agent in a syndicated loan is the entity that
19 Q I'll stop you there, and I'll ask you, who was Felipe 19 receives monies from borrower and pays it to the banks in the
20 Berliner? 20 syndicate. The paying agent has the same -- the same function
21 A He was an employee of VTB Bank. 21 in respect of multiple bondholders.
22 Q And who is Makram Abboud? 22 When a bond is first sold, the money flows from the
23 A He's also an employee of VTB Bank. 23 investors through the paying agent, through the facility agent
24 Q Is that the banker you told us about two days ago? 24 back to the borrower. So Mr. Berliner is describing the chain
25 A Yes, he was the most senior banker that I met from VTB in 25 of events that occur when the investors pay their money to the
LISA SCHMID, CCR, RMR SAM OCR RMR CRR RPR
Page 570 to 573 of 681
1 paying agency to buy the bond. That was Citibank. And then 1 Palomar, plus he was the person that had the most visibility
2 the paying agent then transfers -- transfers it to Credit 2 on the numbers that were used to calculate the final
3 Suisse, who was the facility agent under the loan. And then 3 distribution, the final amount that was paid to the fund.
4 Credit Suisse would then pay those monies as directed by the 4 Q How much did you ultimately receive for the EMATUM
5 borrower to Privinvest. 5 500-million-dollar original bond and the 350-million-dollar
6 Q Okay, if we can go to the top e-mail, what did Felipe 6 upset?
7 Berliner send then? 7 A $23.4 million.
8 A He sends a copy of the payment instruction from Citibank 8 Q Do you have any understanding if the defendant was
9 to Credit Suisse. 9 compensated for these loans?
10 Q And if we look to the line that starts with 32A. 10 A Yes, it's my belief he was compensated for the loans.
11 MR. BINI: If you can blow that up or make it 11 Q Why?
12 yellow, Ms. DiNardo. 32A. 12 A He was a partner in Palomar. It was my expectation he
13 Can you blow it up? It's very hard to read. 13 would receive the same amount of money as I did.
14 BY MR. BINI: 14 Q Did he also have a benefit from Privinvest for ceding
15 Q How much was being sent and to whom? 15 business?
16 A $312 million -- sorry, $312,900,000 was being sent. 16 A Yes, he was also an employee of Privinvest and
17 Q Where was that to go eventually? 17 responsible for having developed this project and obtained it
18 A In -- in this instruction it's being sent from Citibank 18 on behalf of Privinvest.
19 to Credit Suisse. 19 MR. BINI: Your Honor, at this time the Government
20 Q And do you know where it was supposed to go from there? 20 would seek to admit Government's Exhibit 2528.
21 A From there, Credit Suisse was to send it, as directed by 21 THE COURT: Any objection?
22 the borrower, to Privinvest. 22 MR. SCHACHTER: No objection, Your Honor.
23 Q Okay. 23 THE COURT: It's admitted, you may publish.
24 A Excuse me, Abu Dhabi MAR. 24 (Government's Exhibit 2528 was received in
25 Q Thank you. 25 evidence.)
1 MR. BINI: At this time the Government would seek to 1 (Exhibit published.)
2 admit Government's Exhibit 3132. 2 BY MR. BINI:
3 THE COURT: Any objection? 3 Q If we can look to the bottom e-mail. What's the date of
4 MR. SCHACHTER: No, Your Honor. 4 this e-mail?
5 THE COURT: It's admitted. You may publish. 5 A 20th of October, 2013.
6 MR. BINI: Thank you. 6 Q Who is it from, who is it to?
7 (Government's Exhibit 3132 was received in 7 A It's from myself to Mr. Boustani.
8 evidence.) 8 Q And what did you write?
9 MR. BINI: And I would ask Ms. DiNardo if you can 9 A Bro, Uncle's details are as follows:
10 show the top e-mail. 10 I then provided account details at Abu Dhabi
11 (Exhibit published.) 11 commercial bank.
12 BY MR. BINI: 12 Hope that is enough... If we can do something this
13 Q Who is this e-mail from and who is it to? 13 week he would appreciate it.
14 A It's from Mr. Boustani to myself, Naji Allam and David 14 Q Who is Uncle?
15 Langford. 15 A Uncle is Surjan Singh.
16 Q What's the date? 16 Q Is that a nickname that you used to refer to him?
17 A 16th of October 2013. 17 A Yes.
18 Q What is the defendant writing about here? 18 THE COURT: Why was he called Uncle?
19 A He's setting out how the fee to Palomar will be 19 THE WITNESS: He was a close friend of mine who's
20 calculated now that the final piece of the loan was -- piece 20 known to my children, and I described him as Uncle Surjan.
21 of the bond has been -- been finalized and the total of 21 THE COURT: Okay, go ahead.
22 $850 million has been lent. 22 BY MR. BINI:
23 Q Why is the defendant e-mailing, if you know? 23 Q And then after you provided Surjan Singh's account
24 A The end result of this calculation is to determine how 24 details, you had written: If we could do something this week
25 much is paid to the partners in Palomar. He was a partner in 25 he would appreciate it.
Page 574 to 577 of 681
1 What did you mean? 1 Q What did you understand Felipe Berliner to be asking?
2 A I was asking Mr. Boustani to arrange for the payment of 2 A He was asking for the list of the syndicate of lenders
3 the kickback that had been agreed with Surjan for the EMATUM 3 and investors that had currently bought parts of the
4 loan. 4 Proindicus loan.
5 Q And how did the defendant respond? 5 Q Why is that important to VTB Bank?
6 A Done. 6 A At this time VTB were considering whether they could
7 Q How did you respond? 7 purchase a further $118 million of the Proindicus loan and
8 A Love you. 8 they wanted to know who Credit Suisse had previously sold the
9 MR. BINI: Your Honor, at this time the Government 9 loan to in order to establish whether they had other investors
10 would seek to admit Government's Exhibit 5092. 10 they could sell that were not the same as the ones that Credit
11 THE COURT: Any objection to 5092? 11 Suisse had used.
12 MR. SCHACHTER: No objection. 12 Q What's the time of this e-mail?
13 THE COURT: It's admitted. You may publish. 13 A 12:36 p.m.
14 (Government's Exhibit 5092 was received in 14 MR. BINI: Your Honor, at this time the Government
15 evidence.) 15 would seek to admit Government's Exhibit 2568?
16 (Exhibit published.) 16 THE COURT: Any objection?
17 MR. BINI: If we can look to the top e-mail. 17 MR. SCHACHTER: None.
18 BY MR. BINI: 18 THE COURT: It's admitted. You may publish.
19 Q What's the date of this e-mail, Mr. Pearse? 19 (Government's Exhibit 2568 was received in
20 A 21st of October, 2013. 20 evidence.)
21 Q And who is it from, who is it to? 21 (Exhibit published.)
22 A From myself to Mr. Boustani and Ms. Subeva. 22 BY MR. BINI:
23 Q What did you write to the defendant? 23 Q And looking to the top e-mail, what did the defendant
24 A I am speaking to Surjan and Makram so we can get max out 24 write to you?
25 of them. Please tell Said that until we have updated project 25 A Is what Berliner from VTB is asking for? There is a list

1 plan he should wait. 1 of banks at the bottom of the Increase Notice.
2 Q What did you mean when you wrote: I am speaking to 2 Q Did the defendant know the members of the Proindicus
3 Surjan and Makram so we can get the max out of them? 3 syndicate of outside loan investors?
4 A I was discussing with Surjan and Makram who -- the 4 MR. SCHACHTER: Objection.
5 prospect of increasing the size of the Proindicus loan. 5 THE COURT: If you know.
6 MR. BINI: At this time, Your Honor, the Government 6 A Yes, he did.
7 would seek to admit 2567. 7 Q And what time is this e-mail at?
8 THE COURT: Any objection to 2567? 8 A 12:43 p.m.
9 MR. SCHACHTER: No objection. 9 MR. BINI: If we can put side-by-side so the jury
10 THE COURT: It's admitted. You may publish. 10 can see, Ms. DiNardo, 2567 and 2568.
11 (Government's Exhibit 2567 was received in 11 (Exhibit published.)
12 evidence.) 12 BY MR. BINI:
13 (Exhibit published.) 13 Q How much after 2567 is 2568?
14 BY MR. BINI: 14 A Seven minutes.
15 Q And I'll ask you to look at the top e-mail again. 15 Q Is it the same e-mail chain?
16 Is this around the time, Mr. Pearse, that you were 16 A Yes, it is -- no, it isn't. Sorry.
17 seeking to upsize the Proindicus loan as you discussed in the 17 Q What is the defendant doing seven minutes later in the
18 earlier e-mail? 18 second e-mail, 2568?
19 A Yes, this is the 1st of November, it's the same period. 19 A He is asking me whether the document he's attaching to
20 Q And who is this e-mail from and who is it to? 20 this e-mail has the information that Berliner from VTB is
21 A It is from Felipe Berliner to Detelina Subeva, Makram 21 requesting.
22 Abboud, Jean Boustani, Hamet Aguemon, and myself. 22 Q Okay.
23 Q And what did Felipe Berliner ask you? 23 MR. BINI: Your Honor, I would seek to admit 2568-A
24 A Hi Andy, any news on the breakdown of lenders/amounts 24 and 2568-B.
25 under the loan? We look forward to it. Thanks. 25 MR. SCHACHTER: No objection. Sorry.
Page 578 to 581 of 681
1 THE COURT: A and B, any objection? 1 A This is wording that Ms. Subeva is proposing be sent to
2 MR. SCHACHTER: No. 2 Credit Suisse.
3 THE COURT: They are admitted. You may publish. 3 Q Why?
4 (Government's Exhibits 2568-A and 2568-B were 4 A In response to a request from Credit Suisse who had been
5 received in evidence.) 5 contacted by a financial reporter asking questions about
6 (Exhibit published.) 6 Credit Suisse's involvements -- involvement in the loans to
7 BY MR. BINI: 7 Mozambique.
8 Q Okay, if we can go to 2568-A, what is that? 8 Q Was an article regarding this issue of concern to you and
9 A This is a copy of the Increase Notice that was sent from 9 the Mozambique officials who were part of this criminal
10 Proindicus to Credit Suisse in order to increase the 10 scheme?
11 Proindicus loan in August by $32 million. 11 A No, the proposed response from Credit Suisse to the
12 Q And if we look to the back, is this attached to the 12 financial reporter was of concern.
13 e-mail that the defendant sent you at 12:43? 13 Q Why?
14 A Yes. 14 A Because Credit Suisse had proposed in that response to
15 Q Why did he attach it? I am going to ask you to look to 15 refer to the Proindicus loan.
16 Schedule 1. 16 Q Why was that a concern to the Mozambican officials, you
17 (Exhibit published.) 17 and the other members of this criminal scheme?
18 THE COURT: Make it more legible, please. 18 A At that time the only Mozambican loan that was known to
19 MR. BINI: If we can go to Schedule 1 and blow that 19 the public was EMATUM. Proindicus -- the loan to Proindicus,
20 up. 20 rather, was a secret and had not been communicated to the
21 BY MR. BINI: 21 outside world.
22 Q What is Schedule 1? 22 Q And did you later learn that Mozambican, certain
23 A That was the list of lenders, members of the syndicate, 23 Mozambican officials were deliberately not telling the IMF
24 for Proindicus as of that date. 24 about the Proindicus loan?
25 Q Were two ICE-Canyon-owned funds members of the syndicate 25 MR. SCHACHTER: Objection.

1 at that point? 1 THE COURT: Did you learn that?
2 A Two funds managed by ICE Canyon were members of the 2 THE WITNESS: I subsequently learned that the IMF
3 syndicate, yes. 3 had not been informed of the details of the Proindicus loan.
4 Q What are those funds? 4 THE COURT: The objection is overruled. That is the
5 A ICE 3: Global Credit CLO Limited and ICE Global Credit 5 answer.
6 CLO Limited. 6 Go ahead.
7 Q How much had they invested? 7 MR. BINI: Your Honor, at this time the Government
8 A In total, $15 million. 8 would seek to admit Government's Exhibit 2573.
9 Q Where is ICE Canyon located? 9 THE COURT: Any objection?
10 A Los Angeles. 10 MR. SCHACHTER: No objection.
11 MR. BINI: Your Honor, at this time the Government 11 THE COURT: It's admitted. You may publish.
12 would seek to admit Government's Exhibit 2570. 12 (Government's Exhibit 2573 was received in
13 THE COURT: Any objection? 13 evidence.)
14 MR. SCHACHTER: No objection. 14 (Exhibit published.)
15 THE COURT: You may publish, it's admitted. 15 BY MR. BINI:
16 (Government's Exhibit 2570 was received in 16 Q I am going to ask you to look at the top e-mail. Who is
17 evidence.) 17 that from and who is that to?
18 (Exhibit published.) 18 A This is from myself to Felipe Berliner, Ms. Subeva,
19 BY MR. BINI: 19 Makram Abboud, Mr. Boustani and Hamet Aguemon.
20 Q At the top e-mail, what's the date of that e-mail? 20 Q What were you e-mailing about?
21 A November 1st, 2013. 21 A I was setting out for VTB the list of syndicate members,
22 Q And who is it from, who is it to? 22 banks and investors who had invested in the Proindicus loan as
23 A It's from Ms. Subeva to myself. 23 at that date.
24 Q What is this? If you can take a look at it and then tell 24 Q Okay. How much did ICE Canyon have invested?
25 the jury what it discusses. 25 A $15 million.
Page 582 to 585 of 681
1 MR. BINI: Your Honor, at this time I would ask to 1 defendant, did you ever hear him use nicknames to refer to
2 admit 2594. 2 certain people?
3 THE COURT: Any objection? 3 A Yes.
4 MR. SCHACHTER: No objection. 4 Q I just wanted to ask you about a few of them.
5 THE COURT: It's admitted. You may publish. 5 You already spoke about Uncle. Who is that?
6 (Government's Exhibit 2594 was received in 6 A Surjan Singh.
7 evidence.) 7 Q Croco, who is that?
8 (Exhibit published.) 8 A Armando Guebuza.
9 BY MR. BINI: 9 Q Junior, who is that?
10 Q And if you can take a look at it, Mr. Pearse, I just want 10 A Also Armando Guebuza.
11 to ask you to start on -- does this relate to -- let me ask 11 Q We saw earlier today Chopstick. Who did the defendant
12 you this: 12 use that to refer to?
13 Does this e-mail relate to a different deal that is 13 A Manuel Chang.
14 not the deals in this case? 14 Q Did you ever see the name Pantero?
15 A It relates to a potential deal that didn't happen. 15 A Yes.
16 Q Okay. 16 Q Who, if anyone, did the defendant use to refer to using
17 Going to the second page of 2594, do you see the 17 the name Pantero?
18 sentence at the top: Do you know what Junior's angle is on 18 A Manuel Chang.
19 this? 19 Q What about the name Marshal?
20 THE COURT: Can you make it more legible, please? 20 A Antonio do Rosario.
21 BY MR. BINI: 21 Q What about the name 3 Beijos?
22 Q Is that part of an e-mail, you responding to the 22 A Isaltina Lucas.
23 defendant? 23 Q Who is Isaltina Lucas again?
24 A Yes. 24 A The national director of -- now? I'm sorry.
25 Q Who were you referring to when you said: Do you know 25 Q Then.
1 what Junior's angle is on this? 1 THE COURT: Who is that person?
2 A I was referring to Armando Guebuza, the son of the then 2 Why don't you spell it, if you can.
3 president of Mozambique. 3 And then is this an appropriate time to take a
4 Q Okay. And if you go up to the first page of the e-mail 4 luncheon recess after you do this question?
5 chain, is there an e-mail of you with an expletive talking 5 MR. BINI: Yes, Your Honor.
6 about that you shouldn't do the deal? 6 THE COURT: Go ahead, spell the name of the person
7 THE COURT: Highlight it, please, so the jury can 7 you are asking about.
8 see it. 8 MR. BINI: Oh.
9 MR. BINI: The top two e-mails, Ms. DiNardo. 9 BY MR. BINI:
10 (Exhibit published.) 10 Q If you could, Mr. Pearse, Isaltina Lucas.
11 A Yes, there is. 11 A I-S-A-L-T-I-N-A, Lucas is L-U-C-A-S.
12 Q Okay. 12 Q HE?
13 And what did you mean when you said: Need guidance 13 A His Excellency, the president of Mozambique.
14 from Croc as to why he is supportive on this one? 14 Q DG?
15 A I needed to understand from Armando Guebuza why he wanted 15 A The Director General of SISE.
16 to do this particular transaction. 16 Q What's SISE again?
17 Q But were you not in favor of it? 17 A SISE is the Secret Service of Mozambique.
18 A Not at all. 18 MR. BINI: Your Honor, this would be a good time to
19 Q Okay. 19 stop, if it's okay with Your Honor.
20 How did the defendant respond? 20 THE COURT: All right, ladies and gentlemen, it is a
21 A That I will tell him, drop it Croco? 21 little past 1 o'clock, why don't we resume at 2:15?
22 Q Who is Croco again? 22 Do not talk about the case. Enjoy your lunch.
23 A Croco is Crocodilio, who is Armando Guebuza, the son of 23 Thank you.
24 then president of Mozambique. 24 (Jury exits.)
25 Q Over the course of your criminal conduct with the 25 THE COURT: You may step down, Mr. Pearse.
Page 586 to 589 of 681

1 (Witness steps down.) 1 I have told defense counsel throughout, I will give the law to
2 THE COURT: The jury has left the courtroom. You 2 the jury at the appropriate time and they will apply the law
3 may be seated, ladies and gentlemen. 3 as I give it to them to the facts as they find them.
4 Do we have any issues to discuss outside of the 4 So I think your concerns are, at best, premature.
5 presence of the jury? 5 MR. JACKSON: May I respond, Your Honor?
6 MR. JACKSON: Yes; briefly, Your Honor. 6 THE COURT: That's why I am here.
7 THE COURT: I will hear first from the Government, 7 MR. JACKSON: Your Honor, we, of course, understand
8 then from defendant. 8 appreciate that the Court will give all the instruction on the
9 Any issues from the Government? 9 law.
10 MR. BINI: Not from the Government. 10 I think that the Government is coming very close, if
11 THE COURT: Okay, from defense counsel; yes. 11 not already surpassing what the Second Circuit has warned
12 MR. JACKSON: Thank you, Your Honor. 12 repeatedly the Government isn't allowed to do with regard to
13 Your Honor, at a pretrial conference in this case 13 the proof.
14 one of the -- one of the representations that was made by the 14 Putting aside the law, in the United States versus
15 Government to the Court was that this is not an omissions 15 D'Amelio, the Second Circuit made clear that where the proof,
16 case. That was at the August 21st, 2019 pretrial conference 16 itself, regardless of the instruction of the law, but where
17 when Ms. Moeser was addressing the Court and she said: This 17 the proof, itself, alters the core of criminality that is
18 is not an omissions case, Your Honor. This is a 18 presented in the case, that can constitute a constructive
19 misrepresentation case. 19 amendment of the Indictment.
20 And we understood that that made sense, Your Honor, 20 And so, Your Honor, we are only -- we defer to
21 because pursuant to clear Black Letter Law, the Chiarella 21 the -- to the wisdom of the Court in terms of the
22 decision, among others, this isn't a case that could be 22 administration course, but we wanted to make a record to
23 charged as an omissions case. 23 explain our objection and to warn the Government that we
24 We would like to voice , Your Honor, a continuing 24 believe they are proceeding past the point that the Second
25 objection to the Government's repeated injection into the 25 Circuit has said is appropriate, in terms of the proof
1 record of questions that are pure omissions questions. 1 regardless of what law the Court will, ultimately, wisely
2 For example, Mr. Bini asked the witness the 2 determine is appropriate to instruct the Court on.
3 question: 3 THE COURT: I am sure that the Government is duly
4 Did the loan agreement in any place describe payment 4 warned by the defendant, and the Government will be so advised
5 to you and Singh? 5 and so warned by the defendant.
6 Now, we think, Your Honor, that that is a clear 6 Now, anything else?
7 violation of what the Government represented to the Court it 7 MR. JACKSON: Yes, Your Honor, just one more thing.
8 would do in this case and what the law allows the Government 8
9 to do. 9 (Continued on the following page.)
10 THE COURT: Well, let me put it to you this way, 10
11 Mr. Jackson, I have not charged the jury yet with respect to 11
12 what the law is that they have to apply to the facts of this 12
13 case as they find them. We have not even had our charge 13
14 conference yet. So I think you ought, to use an expression 14
15 that someone who is, essentially, a non-skier should really 15
16 use. You are getting out over your skis when you start down 16
17 this road. 17
18 I do not think this is the time to talk about what 18
19 the law is or is not in the case. Right now the jury is 19
20 hearing facts and hearing testimony from this witness, and you 20
21 will be allowed to cross-examine quite extensively, to the 21
22 extent you wish to do so , about what the witness has 22
23 testified to on direct. 23
24 But if you are now getting into the question of what 24
25 the law is in this case, as I have told the Government and as 25
Page 590 to 593 of 681
Proceedings 594 Proceedings 596
1 (Continuing) 1 AFTERNOON SESSION
2 MR. SCHACHTER: Your Honor, we have one additional 2 (In open court - jury not present.)
3 issue. It relates to a number of exhibits that we believe the 3 THE COURTROOM DEPUTY: All rise. Judge Kuntz
4 Government may seek to offer this afternoon. 4 presiding.
5 THE COURT: Let me stop you right there. That's why 5 THE COURT: Good afternoon. We have the
6 God invented lunch. Lunch is not for wimps. Lunch is a time 6 appearances. I see counsel are present. Can we have the
7 when counsel discuss the question of documents that might or 7 defendant produced? And then we will address any procedural
8 might not come in. After you have your non-wimpy lunch of 8 issues we need to address.
9 discussing that, let me know if after you have had that 9 Please be seated, ladies and gentlemen of the
10 discussion there are documents that you would like to discuss 10 public. Thank you.
11 at the sidebar. That way we will have a more productive 11 MR. BINI: Your Honor.
12 discussion. While some of us will be actually eating, some of 12 THE COURT: Good afternoon. Wait for the defendant
13 you will be working through lunch at this lovely space that is 13 to be seated.
14 available. 14 MR. BINI: Yes, Your Honor. Thank you.
15 MR. SCHACHTER: I apologize if I wasn't clear. I 15 THE COURT: Thank you.
16 have already conferred with the Government and they do intend 16 (Defendant present.)
17 to introduce these documents. The only thing that I was 17 THE COURT: Yes. Do we have any issues to address?
18 uncertain about is whether that's going to be this afternoon 18 MR. BINI: Yes, Your Honor. I think there are still
19 or tomorrow. 19 certain e-mails. We did reach agreement on one e-mail. There
20 THE COURT: It won't be tomorrow. 20 are still certain e-mails that we don't have agreement on.
21 MR. SCHACHTER: I'm sorry, Monday. Although 21 THE COURT: All right. Do we need to talk about
22 tomorrow, I am free. 22 those at sidebar or should we talk about them in open court?
23 THE COURT: Well, I'm not because I'm going on a 23 I don't know what the nature of the e-mails is.
24 walk, believe it or not. It's not going to be a run, I assure 24 Sidebar, on the record or open court?
25 you. It is a walk that has to do with to help prevent 25 MR. BINI: Whichever.
1 suicide. So I am going for that walk tomorrow. I just want 1 THE COURT: You guys know what they are.
2 the record to reflect that yes, occasionally, I do walk, 2 MR. JACKSON: They are not sensitive, Your Honor.
3 contrary to appearance. 3 THE COURT: They are not sensitive. Okay. So let's
4 Yes, I hear you. To the extent that when we come 4 have them described by the Government. I take it you are
5 back, before we bring the jury in, we need to have a 5 offering and there is an objection?
6 discussion about particular documents, you will present them 6 MR. BINI: Yes, Your Honor.
7 to me and I will make rulings to help move this along well in 7 THE COURT: Why don't you publish them so I can see
8 advance of the time of the jury, which, as you know, is quite 8 what they are, or hand them up. Whatever is easier for you
9 precious. 9 folks.
10 Anything else? 10 MR. BINI: I can hand you up a copy.
11 MR. JACKSON: No, Your Honor. 11 THE COURT: Just hand them to Mr. Jackson, he'll
12 THE COURT: Have a nice working lunch. 12 hand it up to me. Thank you.
13 MR. BINI: Thank you, Your Honor. 13 So you've got the same package and defense counsel
14 (Lunch recess.) 14 is starting, I take it, with GX 3127; is that right?
15 15 MR. SCHACHTER: Okay.
16 16 THE COURT: I'm asking.
17 17 MR. JACKSON: Yes, Your Honor.
18 18 THE COURT: Or whatever you want. You tell me.
19 19 MR. BINI: Oh, I'm sorry. Did I miss 5112?
20 20 MR. SCHACHTER: I think 5112 is where we are going
21 21 to start.
22 22 THE COURT: If you want to publish them
23 23 electronically so we are literally on the same page? That
24 24 might be easier. The first one I've got in this package is
25 25 3127.
Page 594 to 597 of 681
1 Do you want to do it electronically? 1 is relevant because the defendant and Mr. Pearse put their
2 MS. MOESER: We are starting it up right now, Your 2 money into that, which includes that -- that eventually
3 Honor. 3 Palomar Natural Resources includes --
4 THE COURT: Okay, use the microphone. You, too. 4 THE COURT: Slow it down. Vader, not Robin or Woody
5 MR. SCHACHTER: Yes, Your Honor. 5 Allen. Go ahead.
6 THE COURT: Go ahead. The first one is? 6 MR. BINI: Which includes that United States
7 MR. BINI: Government's Exhibit 5112. 7 concession, so they invest money in that.
8 THE COURT: Wait until it pops up on the screen. I 8 THE COURT: I'm going to overrule the objection and
9 can't see it yet. 9 you could, again, point out how it's related or not related on
10 MR. BINI: The top e-mail. 10 cross or you can make it clear when you examine Mr. Pearse
11 THE COURT: Okay. 11 about what it addresses and what it doesn't.
12 MR. BINI: This is an e-mail from Mr. Pearse to 12 So the objection is overruled.
13 Gwendolyn Arnold and Markus Kroll. 13 MR. SCHACHTER: Your Honor, in addition to the point
14 THE COURT: Okay, it is offered by the witness. 14 Mr. Bini made, not addressing the objection to the exhibit,
15 Let me just turn to defense counsel, what is the 15 but a separate matter. It is unclear to me, until Mr. Bini
16 problem with this document that you can cross-examine the 16 said this, as to whether he intends to go into something
17 witness about and that he authored? I'm assuming there is no 17 called Palomar Natural Resources which is not discussed in the
18 question that he authored it. 18 indictment. It is no part of this case, and I don't know if
19 MR. SCHACHTER: Yes, Your Honor. But, Your Honor, 19 that's a subject that he intends to explore with Mr. Pearse,
20 it's not relevant to Mr. Boustani's state of mind and, 20 but it has nothing to do with the charges. We have gotten no
21 therefore, we don't think it's relevant to any issue of 21 404(b) notice with respect to issues relating to some
22 consequence in this case. 22 different entity called Palomar Natural Resources or --
23 THE COURT: Well, on the issue of relevance I am 23 THE COURT: Well, let me ask the Government.
24 going to overrule it. You can cross-examine him but that's 24 Is this an entity that the defendant has an interest
25 not enough to keep it out. 25 in?
1 What else do you have, other than relevance? On 1 MR. BINI: Yes, Your Honor.
2 that document, anything else? 2 THE COURT: Is that why it's relevant to the issues
3 MR. SCHACHTER: No, Your Honor. 3 in this case from the Government's point of view?
4 THE COURT: Okay, so you are overruled on that. 4 MR. BINI: Yes, and --
5 Your record is preserved for sure for sure. 5 THE COURT: Okay. That's enough. It's in.
6 Okay, next. 6 Overruled.
7 MR. BINI: Government's Exhibit 3127. 7 Next.
8 THE COURT: 3127, okay. 8 MR. BINI: 2843.
9 MR. BINI: The top e-mail. 9 THE COURT: Okay, what's the objection? Can I see
10 THE COURT: Offered by the defendant. 10 the document, please?
11 All right. What's the issue with that? It's 11 Okay, authored by Dominic Shultens, addressed to Mr.
12 seemingly something along the lines of an admission -- unless 12 Pearse. I take it you are going to ask Mr. Pearse about his
13 you are contesting that the defendant actually authored it, 13 understanding about the contents of the document?
14 what's the objection? 14 MR. BINI: Yes, Your Honor.
15 MR. SCHACHTER: Your Honor, it is also irrelevant. 15 THE COURT: This is a document that presumably he
16 If the Court turns to the second page of the exhibit, this 16 will testify he received.
17 relates to an entirely different transaction, one relating to 17 MR. BINI: Yes, Your Honor.
18 Mr. Pearse's desired acquisition of something called San Leon 18 THE COURT: In or about March 2nd of 2015.
19 Energy and, therefore, is not relevant to any issue in this 19 What's the objection?
20 case. 20 MR. SCHACHTER: Your Honor it is hearsay and Mr.
21 THE COURT: Well, what is your response to the 21 Shultens was not described by --
22 relevance issue? Should I keep it out under 403 for 22 THE COURT: Is it being offered for the truth of the
23 confusion, waste of time? Why do you want it in? 23 matter asserted?
24 MR. BINI: Because, first of all, San Leon Energy is 24 MR. BINI: Your Honor --
25 something that is acquired by Palomar Natural Resources so it 25 THE COURT: Is it being offered for the truth of the
Page 598 to 601 of 681
1 matter asserted? 1 Shultens, but I'm admitting it for the purposes of --
2 MR. BINI: Yes. 2 THE COURT: No, you are not admitting it; you are
3 THE COURT: In which case, it would be hearsay and I 3 asking me to admit it. But go ahead.
4 keep it out. 4 MR. BINI: Okay, I am asking you to admit this one,
5 MR. BINI: Your Honor, I would note that we believe 5 Your Honor, because below that is an e-mail from Najib Allam,
6 the co-conspirator exception applies, because the Government 6 to Andrew Pearse, copying David Langford and Jean Boustani,
7 intends to ask the defendant regarding, at this point, whether 7 where there is a letter from Privinvest that --
8 Mr. Shultens is joined with the defendant and others in 8 THE COURT: Well, let's back up. Let's go to the
9 actively lying about the existence of the Proindicus and MAM 9 top one. You are not calling Mr. Shultens and you are
10 loan. 10 offering it for the truth of the matter asserted; correct?
11 THE COURT: Do you need the document to ask him that 11 MR. BINI: Well, in this one, Mr. Shultens is not
12 question? I don't think you do. Your right, it's about the 12 speaking.
13 admissibility of the document. You can ask him, Do you know 13 THE COURT: So it is from Mr. Pearse, right? It
14 who Mr. Dominic Shultens is? Yes. Who was he? He can say 14 says from Pearse to Shultens, it's the top item.
15 who he was, and then he can testify about his relationship 15 MR. BINI: Oh, you are right. I'm sorry.
16 with Mr. Shultens. The question is a document that was not 16 THE COURT: You guys are living it, but I'm looking
17 authored by Mr. Pearse, but was sent to him and to Ms. Lina. 17 at it, so I don't have a problem with the statement -- the
18 Are you going to have Mr. Shultens here as a 18 document from Pearse to Shultens, because you've got Pearse on
19 witness? 19 the stand. So the top one, I don't see as a problem.
20 MR. BINI: We are not going to call Mr. Shultens. 20 The second one was sent to Pearse from Allam, is
21 THE COURT: Okay, well, I'm going to keep this one 21 there an objection to that coming in?
22 out. Next. 22 MR. JACKSON: Yes, Your Honor. It's a 403 issue and
23 MR. BINI: Okay. Government's Exhibit 2851. 23 a 404(b) notice issue. This relates to interactions with
24 THE COURT: Okay. Let's see it. 24 EMATUM's auditor, as I understand it. This is not part of the
25 Mr. Shultens again? 25 indictment. There was no 404(b) notice provided of any
1 MR. BINI: Yes, Your Honor. 1 allegations of some kind of separate misstatements to an
2 THE COURT: Again being offered for the truth of the 2 auditor, which I believe is what Mr. Bini is getting at.
3 matter as heard? 3 THE COURT: Well, let's ask Mr. Bini.
4 MR. BINI: Yes, Your Honor. 4 Mr. Bini, what are you getting at with this
5 THE COURT: No. Out. Next. 5 document -- or this part of the e-mail chain?
6 MR. BINI: May I ask the witness about the 6 MR. BINI: This goes to the value of the goods
7 information? 7 provided by the defendant and his company. There is, in this
8 THE COURT: You can ask about the information 8 e-mail chain --
9 without -- no, this is about the admissibility of documents, 9 THE COURT: Why don't you scroll further down
10 not whether or not Mr. Shultens was a co-conspirator. Don't 10 because this is just, "hi, attached." It doesn't tell me very
11 become a prisoner of the documents in conducting your 11 much. What is the gravamen, if you will, of the document?
12 examination. 12 MR. BINI: At the bottom, where Andrew Pearse writes
13 MR. BINI: Okay. 13 to David Langford and Najib Allam --
14 THE COURT: Okay. So, next. 14 THE COURT: I don't have a problem with Pearse's
15 MR. BINI: Government's Exhibit 3097. 15 letters to his alleged co-conspirators and to the defendant,
16 THE COURT: All right, put it up. 16 as well, so that part of it I don't have a problem with. But
17 MR. BINI: This is another e-mail from Dominic 17 if you are offering documents authored by people who are not
18 Shultens. 18 in the courtroom and who are not going to be called as
19 THE COURT: Same ruling, if you are offering it for 19 witnesses for the truth of the matter asserted, that's the
20 the truth. Not coming in. 20 problem. So if you need to present this in a redacted fashion
21 MR. BINI: Okay. 21 to address my concerns with respect to the documents, the
22 THE COURT: Next. 22 objections are still on the record and it preserves the
23 MR. BINI: Government's Exhibit 3098. 23 record, but you have the benefit of my ruling. So that's how
24 THE COURT: Can I see it, please? 24 we can handle that. You may need to get some scissors and
25 MR. BINI: Yes. This is an e-mail from Mr. 25 paste or take some other old school remedies to offer portions
Page 602 to 605 of 681
1 of the document. 1 MR. SCHACHTER: Your Honor, may we ask to just
2 MR. BINI: Okay. 2 redact the language about paying taxes and Mr. Boustani's
3 THE COURT: All right. 3 desire not to pay taxes. It's prejudicial.
4 MR. BINI: The next objection, I think, is to 2876. 4 THE COURT: He writes: It pisses me off to pay
5 THE COURT: Okay. Put that up, please. 5 taxes. Spoiler alert; it probably pisses everybody off to pay
6 Okay, this is from Pearse. 6 taxes. People don't like paying taxes. I believe there was
7 MR. SCHACHTER: We withdraw our objection to this, 7 something along the lines of when Oliver Weldon Holmes
8 Your Honor. 8 aggrandized, or one of the old guard, who said: Taxes are
9 THE COURT: Okay. That's in. You won that one. 9 what is extracted by the Government. Nobody likes to pay
10 Go ahead, next. 10 taxes. Now, whether you are willing to comply with the law or
11 (Government's Exhibit 2876 received in evidence.) 11 not, that's a different question, but nobody likes to pay
12 MR. BINI: 2890. 12 taxes.
13 THE COURT: From Pearse? 13 No, I am going to overrule that objection.
14 MR. BINI: Yes. 14 MR. SCHACHTER: Yes, Your Honor.
15 THE COURT: That is going to come in from Mr. 15 THE COURT: Go ahead.
16 Boustani. That's an admission. The next one? 16 MR. BINI: 3106.
17 MR. SCHACHTER: Your Honor? 17 THE COURT: From the defendant to Pearse. What's
18 THE COURT: I'm sorry, go ahead. 18 the objection to an admission by the defendant, Government?
19 MR. SCHACHTER: I just want to raise the effect of 19 MR. SCHACHTER: Your Honor, this is now at a point
20 the subject matter, it relates to JAFZA Offshore Company, 20 where we are after all of the relevant events in the
21 something related to Angola. It's completely unrelated to any 21 indictment. This has to do with compensating employees of
22 issue in this case. There has been no 404(b) notice. 22 Palomar and is unrelated to any issue in the case.
23 THE COURT: I take it you have produced this 23 THE COURT: Really? I don't think that's a very
24 document to the other side. 24 strong argument. If that's your argument, I am going to
25 MR. BINI: Yes, Your Honor. 25 overrule it. Boustani to Pearse about payments, no.
1 THE COURT: Okay, so why are you offering it in 1 MR. SCHACHTER: Yes, Your Honor.
2 connection with this case? 2 THE COURT: Overruled. What else?
3 MR. BINI: Mr. Pearse indicates JB, referring to the 3 MR. BINI: 3111.
4 defendant, just turned into a structure, because the defendant 4 THE COURT: From Pearse to Lina Subeva, one
5 appears to understand complex financial transactions, and -- 5 defendant was convicted to another. What's the objection?
6 THE COURT: So it goes to the question of knowledge? 6 MR. SCHACHTER: It's a subject matter issue, Your
7 MR. BINI: Yes, Your Honor. 7 Honor. I mean, this relates to responding to some Wall Street
8 THE COURT: Yeah. I will allow it in on that basis. 8 Journal article which is going to potentially inject some
9 Go ahead. 9 issue about a hearsay issue --
10 MR. BINI: The next one is 28 -- 3175. 10 THE COURT: Am I misreading this? Doesn't this
11 THE COURT: Okay. That's from Shultens, that's not 11 refer to Proindicus and to MAM?
12 coming in for the truth. So that one is out. You can 12 MR. SCHACHTER: It does, Your Honor.
13 question about the subject matter, but not the document. 13 THE COURT: Well, if that's the basis for keeping it
14 MR. BINI: Okay. 14 out, I think that's a pretty week basis, as a non-existent.
15 THE COURT: Next. 15 Overruled. What else?
16 MR. BINI: 3103. 16 MR. BINI: That's it, Your Honor. I think.
17 THE COURT: That's from Pearse? Any objection to 17 MR. SCHACHTER: That's it. Thank you, Your Honor.
18 that, to Boustani? 18 THE COURT: Okay. Anything else we need to address?
19 MR. SCHACHTER: Yes, Your Honor. It is just a 19 MR. BINI: No, Your Honor.
20 matter unrelated to anything alleged in the indictment. 20 THE COURT: Anything else?
21 THE COURT: What's the purpose of offering this one? 21 MR. SCHACHTER: No, Your Honor.
22 MR. BINI: Because it shows the control of Palomar 22 THE COURT: Okay. Why don't we have the witness
23 between Pearse and Boustani. 23 come back and I will have the jury brought out.
24 THE COURT: Okay, I will overrule the objection. 24 (Witness resumes stand.)
25 It's allowed. Next. 25 THE COURT: Please have a seat, Mr. Pearse.
Page 606 to 609 of 681
1 THE WITNESS: Thank you, Your Honor. 1 MR. BINI: Your Honor, at this time the Government
2 THE COURT: We are getting the jury back. 2 would seek to admit Government's Exhibit 7.
3 (Jury enters the courtroom.) 3 THE COURT: Any objection?
4 THE COURT: Good afternoon, ladies and gentlemen of 4 MR. SCHACHTER: Can I have a moment, Your Honor?
5 the jury. Again, thank you very much, I appreciate your 5 THE COURT: Why don't you publish it just to your
6 promptness. Once again, please be seated, with the thanks of 6 adversary so they can see it and tell us if they have an
7 the Court. 7 objection to move things along.
8 Ladies and gentlemen of the public, you may be 8 MR. SCHACHTER: No objection.
9 seated as well. Mr. Pearse, you may be seated. 9 THE COURT: It's admitted. You may publish to the
10 We will continue with the examination. And I assure 10 jury.
11 you, even though it's Friday afternoon, we are going to have 11 MR. BINI: Thank you, Your Honor.
12 our hard stop at five o'clock. That clock is there and I 12 (Government Exhibit 7 admitted in evidence.)
13 don't play any tricks with slowing it down and making it 13 (Exhibit published.)
14 break. So, five o'clock, even though it's Friday, we are done 14 Q Mr. Pearse, what is Government's Exhibit 7?
15 for the day. 15 A This is a copy of the arrangement fee letter between
16 So, with that, continue. 16 Credit Suisse and Proindicus from March of 2013.
17 MR. BINI: Thank you, Your Honor. 17 Q Is this what we saw referred to in the loan agreement?
18 MR. BINI: 18 A Yes. The clause in the loan agreement refers to a fee
19 Q Mr. Pearse, I want to ask you a couple of questions to go 19 letter and this was the fee letter it's referring to.
20 back on something on the Proindicus loan agreement I didn't 20 Q And does this indicate that there is an arrangement fee
21 ask you before. 21 for Credit Suisse?
22 MR. BINI: If we can show GX-4, in evidence, to Mr. 22 A Yes, it does.
23 Pearse and the jury. 23 MR. BINI: If we can go to paragraph 4.
24 Q Is this the Proindicus loan agreement, Mr. Pearse? 24 Q Does it speak on the arrangement fee for Credit Suisse?
25 A Yes, it is. 25 A Yes. It states that the arrangement fee will be $6

1 MR. BINI: If you can go to the second page, the 1 million.
2 table of contents, Ms. DiNardo. 2 Q What was the kickback that you received for Proindicus?
3 Q We looked at some of the other clauses, but I want to ask 3 A Five-and-a-half million dollars.
4 you about clause 11, Fees, on page 24. 4 Q Were you working at Credit Suisse at the time that the
5 Do you see that, Mr. Pearse? 5 Proindicus loan was signed?
6 A Yes, I do. 6 A Yes, I was.
7 Q Is that standard in loan agreements like this one? 7 Q Does it mention the kickback to you in this section?
8 A For a close on fees to the loan agreement? 8 A Sorry, in those words that are on the screen?
9 Q Yes. 9 Q Yes.
10 A It depends on the loan agreement and the bank whose 10 A No, it doesn't.
11 making the loan. 11 Q Who's the person who ultimately signed the loan agreement
12 Q There is one in this loan agreement; is that right? 12 for Proindicus?
13 A Yes, sir, there is. 13 A I don't recall, sir.
14 MR. BINI: If we can go to page 24 and look to Fees. 14 Q Let's go back to GX-4, and go to the signature page.
15 Q What is clause 11 and clause 11.1? 15 A That was Surjan Singh and Tim Malton.
16 A This is the clause that refers to fees that will be paid 16 Q Who, if anyone, told Surjan Singh to sign this loan
17 to the arranger bank. 17 agreement?
18 Q And did the loan agreement that went to investors and 18 A Technically, it was the credit department of Credit
19 potential investors speak on the issue of fees to the arranger 19 Suisse but he was under my prior authorization.
20 bank? 20 Q Thank you.
21 A The investors will have received a copy of this loan 21 MR. BINI: You can take that down, Ms. DiNardo.
22 agreement with these words relating to the fee arrangements. 22 At this time, the Government would offer
23 Q What does it say? 23 Government's Exhibit 2596.
24 A The borrower shall pay to the arranger the fees in the 24 THE COURT: Any objection?
25 amounts and at the times agreed in the arrangement fee letter. 25 MR. BINI: Oh, I'm sorry. We covered that already,
Page 610 to 613 of 681
1 Your Honor. I would offer Government's Exhibit 5101. 1 finally with the bank.
2 THE COURT: Any objection? 2 Q I will stop you there, and I'll just ask you, what did
3 MR. SCHACHTER: May I have a moment, Your Honor? 3 you understand Najib Allam to be referring to?
4 THE COURT: Sir, why don't you publish it to him. 4 A He was asking me about a meeting that I had had with my
5 MR. SCHACHTER: No objection, Your Honor. 5 bank in the United Arab Emirates.
6 THE COURT: All right, that's fine. 6 Q If we can go to the first page of the e-mail, your
7 (Government's Exhibit 5101 received in evidence.) 7 response.
8 (Exhibit published.) 8 How did you respond, Mr. Pearse?
9 Q What is the date of this e-mail? 9 A Would you like me to read it, sir?
10 A Sixteenth of January, 2014. 10 Q If you could?
11 Q And I want to go down to the e-mail from the defendant to 11 A Hi, Najib. The bank was a little painful. The biggest
12 you, the bottom e-mail. 12 issue is that they want the residency job description changed
13 What's the time of that e-mail? 13 to something more consistent with earnings. Can we do this?
14 A Ten past 9:00 in the morning. 14 Also they want --
15 Q What did the defendant write? 15 Q I will stop you there.
16 A F, all set to get MOF new guarantee for $500 million. 16 Can you explain to the jury what was the bank
17 Will do it in Palomar's name. The borrowers will be 17 concerned with regarding your residency job description?
18 Proindicus and EMATUM and to build a maintenance 18 A The bank was concerned with the fact that my application
19 infrastructure in Moz to maintain their fleets. I think 19 form for a bank account had described my job title as a tube
20 Proindicus will borrow, as we don't want public noise. Can I 20 welder with an expected annual salary of approximately
21 have the MOF guarantee to make him sign it next week before 21 $250,000. By this point in time, I had received approximately
22 procurement contract, et cetera. 22 $35 million into that bank account.
23 Q I want to ask you about the part: I think Proindicus 23 Q Where were you getting all that money from?
24 will borrower, as we don't want public noise. 24 A From Privinvest.
25 What was going on at this time and what does that 25 Q And by the way, did you have substantially any other
1 refer to? 1 funds in that UAE bank account other Privinvest funds?
2 A He is referring to the fact that Proindicus is still -- 2 A No. Every penny that was in that account came from my
3 not being disclosed to the public. 3 activities with Privinvest, from proceeds of crime.
4 Q Why does he want to borrow without public knowledge? 4 THE COURT: I'm sorry, excuse me. This says the
5 MR. SCHACHTER: Objection. 5 bank wanted the residency job description changed? The bank
6 THE COURT: If you know, in your view. 6 suggested to you that you change the job description?
7 A In this context, sir, it would require me to speculate to 7 THE WITNESS: Yes, Your Honor.
8 answer this question. 8 THE COURT: Okay. Go ahead.
9 Q Well, don't do that. 9 Q And what did Mr. Allam attach to the mail, if anything?
10 What did you understand the defendant to mean? 10 A He attached the constitutional docs for Palomar
11 A That any new borrowing should be done without being made 11 consulting, the articles for Palomar holding and a letter, I
12 public. 12 believe.
13 Q Thank you. 13 Q Why did he attach those documents?
14 MR. BINI: At this time, the Government would seek 14 A Those were documents that had been requested -- well,
15 to admit Government Exhibit 2746. 15 some of the documents had been requested by my bank, Abu Dhabi
16 THE COURT: Any objection? 16 Commercial Bank.
17 MR. SCHACHTER: No objection, Your Honor. 17 MR. BINI: Your Honor, at this time the Government
18 THE COURT: You may publish. It's admitted. 18 would seek to admit 2746A, 2746B and 2746C.
19 (Government Exhibit 2746 admitted into evidence.) 19 THE COURT: Any objection?
20 (Exhibit published.) 20 MR. SCHACHTER: No, Your Honor.
21 Q Looking to the first e-mail on page 2, what did Najib 21 THE COURT: Admitted. You may publish.
22 Allam write to you. 22 (Government's Exhibits 2746A, 2746B and 2746C
23 A Hi, Andrew. I hope all went well with bank and if you 23 received in evidence.)
24 still need any document from my side, please let me know. FGB 24 (Exhibits published.)
25 credit cards should be received soon. All has been settled 25 (Continued on next page.)
Page 614 to 617 of 681

1 (Continuing.) 1 A 23rd of March, 2013.
2 BY MR. BINI: 2 Q Is this a real agreement?
3 Q Can you tell us what 2746A is, Mr. Pearse? 3 A No, it's not a real agreement.
4 A It is a notarial certificate from a notary public in 4 Q How it not a real agreement?
5 London. 5 A It is untrue in that I did not provide consultancy
6 Q What is 2746B? 6 services to Privinvest Shipbuilding in relation to WP18 and
7 A It is a copy of a commercial license for Palomar 7 BR71 products in Russia and Azerbaijan.
8 Consulting LLC, in Abu Dhabi. 8 MR. BINI: If we can go to the terms and conditions,
9 Q What is 2746C? 9 Ms. DiNardo, if you can blow up "Terms and Conditions,"
10 A This is the first page of the memorandum of Association 10 paragraph one.
11 of Palomar Consulting. 11 BY MR. BINI:
12 MR. BINI: At this time the Government would seek to 12 Q Is that what you were referring to, Mr. Pearse, as being
13 admit 2747 and 2747A. 13 untrue?
14 THE COURT: Any objection? 14 A Yes.
15 MR. SCHACHTER: No, Your Honor. 15 Q What is set out in paragraph two of the terms and
16 THE COURT: Admitted. 16 conditions?
17 You may publish. 17 Before do I that, let me ask you this or ask you
18 (Government Exhibit 2747 was received in evidence.) 18 that. What is a WP18, if you know?
19 (Government Exhibit 2747A was received in evidence.) 19 A That is one of the vessel types that is produced by
20 (Publishes exhibit to the jury.) 20 Privinvest was sold to Proindicus.
21 BY MR. BINI: 21 Q What is the BR71, if you know?
22 Q If we can go down the bottom, is this a follow-up email 22 A I don't know.
23 chain related to the email chain we were just looking at? 23 Q Did you do any consulting in Russia for Privinvest.
24 A Yes, sir, it is. 24 A No, I did not.
25 Q And after you reported that the bank was a little 25 Q What about consulting in Azerbaijan?

1 painful, did Najib Allam write to you on March 21, 2014, at 1 A Not there either.
2 15:22? 2 Q Okay. Now if we can look at two, do you recognize those
3 A Yes, he did. 3 payments?
4 Q What did he write? 4 A Yes, I do.
5 A Hi, Andrew. I'm not copying anyone here. I had a draft 5 Q What are they?
6 of after agreement between PISB and you which I updated. Have 6 A These are the payments I received from Privinvest in
7 a look and sign it; and we can use at the bank, if needed. 7 respect of the kickbacks and unlawful payments for the
8 Q What did you do with this agreement? 8 Proindicus loans.
9 A I'm sorry. Which agreement? 9 Q Did you have discussions with the defendant, Najib Allam,
10 Q Oh, I'm sorry. What did you do with this email in the 10 or anyone else about why you have this fake contract, setting
11 document attached to it? 11 out all your Proindicus payments?
12 A The documents they said were relevant to the bank I sent 12 A Yes, I did.
13 to Abu Dhabi Commercial Bank. 13 Q Who did you discuss it with?
14 Q Okay. Did you forward it to yourself? 14 A I discussed it with the defendant and Iskandar Safa the
15 A I'm looking at the top email. 15 year preceding the date of that email that sent me this --
16 My apologies. Yes, I forwarded it to myself and my 16 this contract. I described the events yesterday, sir.
17 Hotmail account. 17 Q Can you please describe what to the jury what you're
18 Q And if we can now look at 2747A, what is this agreement 18 referring to?
19 Mr. Pearse? 19 A In March of 2013, after the first Proindicus loan was
20 A This is the agreement that was referred to in the email 20 closed, I met with Iskandar Safa and Jean Boustani the estate
21 from Najib Allam, and this is the consulting agreement between 21 of Iskandar Safa in the South of France and discussed how,
22 Privinvest Shipbuilding, SAO and myself, relating to 22 among other things, how to characterize the kickback that I
23 consultancy services that I provided to Privinvest 23 wad receiving in relation to the first Proindicus loan in the
24 Shipbuilding in Russia and Azerbaijan. 24 event that I was ever asked by a third party where the money
25 Q What's the date of this agreement? 25 came from.
Page 618 to 621 of 681

1 Q Is this consistent with the conversation that you had 1 MR. SCHACHTER: No objection, Your Honor.
2 with Iskandar Safa and the defendant in March of 2013? 2 THE COURT: Admitted.
3 A Yes, during that conversation, Iskandar Safa told me 3 (Government Exhibit 5111 was received in evidence.)
4 that, if I was ever asked, I should describe the payments as 4 (Publishes exhibit to the jury.)
5 being paid to me under the terms of a consultancy agreement 5 BY MR. BINI:
6 with Privinvest where I was consulting on the sale of two 6 Q Did there come a time that you began working on the loan
7 vessel types, the WP18 and a DV15. 7 for MAM?
8 Q Are those the two boats that are set out here, if we go 8 A Yes.
9 back to "1"? 9 Q What bank was involved that that loan?
10 A The WP18 is one of those boats described by Mr. Safa. 10 A The VTB Bank.
11 The BR71 was not. The product he told me about in March of 11 Q Was that a syndicated loan?
12 2013 was a DV15 which had been the other vessel type that we 12 A Not to best of my knowledge, no.
13 provided to Proindicus at that stage contracted to be 13 Q What type of loan was it?
14 provided. Excuse me. 14 A It was a loan between VTB and what was to become MAM.
15 Q Is this the first time you'd ever seen this fake 15 Q What was the project supposed to be?
16 contract? 16 A I'm sorry.
17 A The date I received it from Najib Allam was the first 17 THE WITNESS: I'm sorry, Your Honor.
18 time I'd seen it. 18 May I correct my previous statement?
19 Q If we could go back to 2747, what's the date, if we go to 19 BY MR. BINI:
20 the top? 20 Q Yes.
21 A 21st of March, 2014. 21 MR. BINI: I should I ask Your Honor.
22 Q Did the contract appear to be backdated? 22 THE COURT: Yes, of course.
23 A It is backdated, sir. It's from a year earlier. 23 THE WITNESS: The MAM loan was drafted as a
24 Q By the way, if we look to the top, if we go back to 24 syndicated loan. It was capable of being syndicated. I don't
25 2747A, do you see how it said it's entered into March 23rd, 25 know if it was syndicated because I did not work at VTB.

1 2013? 1 BY MR. BINI:
2 A Yes. 2 Q Okay. What was the MAM project supposed to be?
3 Q If you look down to the paragraph two, one of these 3 A It had two primary purposes. One was to build shipyards
4 payments -- 4 to be able to allow the Mozambicans to build vessels of the
5 A They're all subsequent to that date. 5 types that had been supplied under the Proindicus and EMATUM
6 Q Does that make sense? 6 loans, and the second element was to provide maintenance
7 A No. It would seem quite difficult to have been able to 7 facilities for the boats that had already been spotted or were
8 foresee the payments on the 23rd of March, 2013. 8 being in the process of being delivered for Proindicus and
9 MR. BINI: Okay. At this time I would ask to admit 9 EMATUM and third parties.
10 Government's Exhibit 3112. 10 Q Did you think that business plan could work?
11 THE COURT: Any objection? 11 A I did not, no.
12 MR. SCHACHTER: May I have just a moment, Your 12 Q Why not?
13 Honor? 13 A Because it relied on Proindicus and EMATUM being able to
14 THE COURT: If you would publish it just to your 14 petty MAM for the maintenance of their vessels. At this stage
15 adversary to move it along, counsel. 15 it wasn't clear that either of those entities were -- had not
16 MR. SCHACHTER: No objection. 16 generated any revenue. It wasn't clear that they would
17 THE COURT: Admitted. You may publish. 17 generate sufficient revenue to support the business plan.
18 (Government Exhibit 3112 was received in evidence.) 18 Secondly, the shipyard's shipbuilding proposal was
19 MR. BINI: Your Honor, I'm actually going to go to 19 for the Mozambique to build vessels of the type that had being
20 next exhibit in the interest of time. 20 supplied by Privinvest, which I knew to be highly technical;
21 THE COURT: Which is. 21 and without any expertise in the matter, it seemed unlikely
22 MR. BINI: Government's Exhibit 5111. 22 that nations would want to buy vessels built in Mozambique
23 I'll ask to offer it now. 23 when they could buy them built in Germany or France.
24 THE COURT: Any objection? Show it to your 24 Q What was the loan size for the MAM loan?
25 adversary. 25 A $535 million.
Page 622 to 625 of 681
1 Q Did you think that was an appropriate loan size for the 1 Q Okay. Was the discomfort that Ms. Subeva expressed
2 project? 2 something that you discussed with the defendant?
3 A No, because I thought the business plan was unlikely to 3 A Yes. The need for consistency between the transactions
4 succeed. 4 was very important.
5 Q Were you paid in relation to that loan? 5 Q Why was it important?
6 A Yes, I was. 6 A Because VTB had been a -- was a lender at this stage to
7 Q How much did you receive? 7 Proindicus and had been one of the arrangers of the EMATUM
8 A Just over $10 million. 8 bonds. So they were in possession of the business plans for
9 Q How did you receive that $10 million? 9 both of those projects and were able to cross-reference.
10 A I received it as a dividend from Palomar Holdings after 10 MR. BINI: If we can, Your Honor, at this time the
11 Palomar Holdings received a fee from Privinvest. 11 Government seeks to admit Government Exhibit 2761.
12 Q What happened to the MAM project? 12 THE COURT: Any objection?
13 A I do not know sir. 13 MR. SCHACHTER: No objection.
14 Q Was it successful? 14 THE COURT: Admitted. You may publish.
15 A Not that I'm aware of. 15 (Government Exhibit 2761 was received in evidence.)
16 Q Are you aware of if it made any revenues? 16 (Publishes exhibit to the jury.)
17 A I'm not, no. 17 BY MR. BINI:
18 Q Now looking to 5111, is this an email regarding the MAM 18 Q What's the date of this email, looking to the email from
19 project? 19 the defendant?
20 A Yes. 20 A 9th of April, 2014.
21 Q And looking to the email, the top email from Ms. Subeva 21 Q Is it a response to Ms. Subeva's email?
22 to you, and another email and address for Ms. Subeva, what was 22 A Yes.
23 Ms. Subeva setting out in her email? 23 MR. BINI: You can go to the top of the email,
24 A She at the time was trying to build a financial model 24 Ms. DiNardo.
25 which was to be provided for MAM to the bank. In that model 25 BY MR. BINI:
1 she had assumed that MAM would make revenue from selling 1 Q Did the defendant disagree with Ms. Subeva?
2 certain boats it built as part of the project. 2 A Yes.
3 The sale prices that the defendant had provided to 3 Q Was he pretty vehement about his disagreement?
4 her for the vessels were that were being built in Mozambique 4 MR. SCHACHTER: Objection.
5 were inconsistent with the values that were being paid for the 5 THE COURT: Yeah, I'll sustain it. The jury has got
6 paid for by EMATUM and Proindicus under the terms of their 6 the document. Why don't you just call attention to what was
7 contracts. Her, without reading the email -- 7 said by Mr. Boustani in the document --
8 Q Let me direct you to the second paragraph, if you could 8 MR. BINI: Sure.
9 just read that paragraph, the second practice of Ms. Subeva's 9 THE COURT: -- other than characterizes it?
10 email, starting for EMATUM or EMATUM. 10 BY MR. BINI:
11 A "For EMATUM, we have three trimarans and 24 long liners 11 Q What was the first sentence the defendant wrote?
12 straight trawlers. If we now say that we sell the trimarans 12 A "You got it wrong."
13 for $20 million and the trawlers for $10 million, if someone 13 Q And if you would, does he -- if you could, read the rest
14 does the math, they get to cost of amount of vessels of just 14 of it.
15 $300 million. Of course, that are other equipment, center 15 A Out loud.
16 components, and TOT fees. So no one expects to get to 16 Q Yes.
17 $850 million, but I want to be higher than $300 million to 17 A Privinvest, being the manager for MAM, will insure that
18 avoid issue." 18 MAM's parts of the jobs are estimated at these values,
19 Q I'm going to stop you there. 19 trimaran trawler, et cetera. So it is not the sales price.
20 Did you understand Ms. Subeva to be saying the 20 All components, engines, et cetera, will be paid by Privinvest
21 prices for MAM made EMATUM look like way too much of a loan? 21 because it has a mega-discount package with all suppliers.
22 A No. I understood her to be saying that if she used the 22 That is why MAM will work as part of the Privinvest network.
23 prices that would be provided to her in MAM, it would appear 23 So the parts of the trimaran will be valued at $20 million and
24 that the prices paid under the procurement contract were 24 will generate an NOP of $4 1/2 million. This does not
25 higher than they were here. 25 included major parts. Is it clear?
Page 626 to 629 of 681
1 Q Did you have conversations with the defendant regarding 1 A So as not freak out the banks, my suggestion will be to
2 prices or the various component parts of the MAM, Proindicus, 2 start with 500 and look to upsize after three months based on
3 and EMATUM? 3 the 36 DB 15s. Docks for up to 750 but an initial business
4 A At different times. 4 plan would be 500 this current procurement contract. Okay
5 THE COURT: What is an NOP? I'm sorry. 5 with everyone?
6 THE WITNESS: Net operating profit, I believe, sir. 6 Q Why do you write "so as not to freak out the banks"?
7 THE COURT: Net operating. 7 A Seven hundred fifty million was just too big and
8 THE WITNESS: Profit. 8 impossible to place in my view at that time.
9 THE COURT: Okay. I'm sorry. Go ahead. 9 Q How did the defendant respond?
10 BY MR. BINI: 10 A Okay, Bro. Go ahead.
11 Q And would the defendant give you specific prices for 11 MR. BINI: Your Honor, at this time I would seek to
12 those? 12 admit Government's Exhibit 3123.
13 A No. The defendant was always very hesitant to provide a 13 THE COURT: Any objection?
14 breakdown of the prices of the individual components of any 14 MR. SCHACHTER: No objection.
15 project. 15 THE COURT: You may publish.
16 MR. BINI: At this time the Government would seek to 16 (Government Exhibit 3123 was received in evidence.)
17 admit Government's Exhibit 2763. 17 (Publishes exhibit to the jury.)
18 THE COURT: Any objection? 18 MR. BINI: If we can go to the bottom email on the
19 MR. SCHACHTER: No objection. 19 second page, Ms. DiNardo.
20 THE COURT: It's admitted. 20 BY MR. BINI:
21 You may publish. 21 Q What is the date of your email, Mr. Pearse?
22 (Government Exhibit 2763 was received in evidence.) 22 A 19th of April, 2014.
23 (Publishes exhibit to the jury.) 23 Q What's the subject?
24 BY MR. BINI: 24 A Final Contract Comments.
25 Q Okay. If we can go to the bottom email from the 25 Q Who did you write it to?

1 defendant to Mr. Pearse and Ms. Subeva, what's the date of 1 A David Langford, Jean Boustani and Ms. Subeva.
2 that bottom email? 2 Q What did you write to them?
3 A 9th of April, 2014. 3 A Attached, Lena's work with a little massaging from me.
4 Q What did the defendant write? 4 Nothing too dramatic. The following are worth highlighting.
5 A Morning, Love. Please increase MAM to $600 million. 5 Q I'm going to stop you there. What were you sending?
6 Q What did you understand him to mean? 6 A Comments on the procurement contract for MAM.
7 A The defendant wanted the financing size for MAM to be 7 Q Okay. Did the defendant respond?
8 increased to $600 million. 8 A Yes, he did.
9 Q And how did you respond? 9 Q What did he write?
10 A EMATUM may need the economist again. 10 A David, Love, let's remove all precise things like number
11 Q Did you respond on April 10th of 2014? 11 of employees, dock size, et cetera, so all is consistent.
12 A Yes, sir. 12 Q Who does "David" refer to?
13 Q How did the defendant respond? 13 A David Langford.
14 A "Negative or positive article? Lena, my love, now we're 14 Q Who typically wrote the procurement contracts for
15 at $750 million. That will be at 36 DB 15 stock built in MAM 15 Privinvest and subsidiaries?
16 to start with. Happy with me?" 16 A In relation to transactions I was involved in? David
17 Q What did you understand her to mean there with the 17 Langford.
18 750 million? 18 Q What did you understand the defendant to mean when he
19 A I understood that the transaction size for MAM was being 19 said, "let's move remove all precise things like number of
20 increased to $750 million by the defendant. 20 employees dock size, et cetera"?
21 Q Was it just 600 million in the email the day before? 21 A He was frustrated at the time by the questions from Ms.
22 A If I could look at that previous email, the dates, 22 Subeva that showed the inconsistencies between what was being
23 please. Yes, it was the day before. 23 provided and what was required for the project and for the
24 Q Okay. Now, if we can go to your response, how did you 24 business plan. So his solution was to remove all references
25 respond to the defendant increasing the loan to 750 million? 25 to anything that was precise in order to avoid any potential
Page 630 to 633 of 681

1 conflict and cross-referencing errors. 1 Q What did you understand was occurring in -- at this
2 MR. SCHACHTER: Objection. Move to strike, Your 2 point?
3 Honor. 3 A He was asking for help in order to be able to answer the
4 THE COURT: Overruled. 4 question. He was worried about why creditors were phoning
5 BY MR. BINI: 5 him, and he wanted us to help with that business.
6 Q How did David Langford respond? 6 Q How did you respond?
7 A I'm doing this now. Then nothing 'til Monday. I can't 7 A "I am trying to get ahold of uncle. Don't have a call,
8 just randomly take thing out, J.B., to be less precise. A 8 please, until I have spoken with him and conformed what the
9 contract illegally enforceable needs to be certain. 9 fuck this is about."
10 Q I'll stop you there. What did you understand 10 Q Who were you referring to as "uncle"?
11 Mr. Langford to be responding to the defendant? 11 A Surjan Singh.
12 A He was responding to say that he could not do what the 12 Q Why were you going to call Surjan Singh?
13 defendant had asked him to do, namely, take out the elements 13 A Because I didn't know why they were calling. I wanted to
14 that were being supplied under the contract. 14 find out from him, that he would give me that information.
15 MR. BINI: Your Honor, at this time the Government 15 MR. BINI: Okay. At this time, the Government would
16 would seek to admit 3069. 16 seek to admit Government's Exhibit 2771.
17 THE COURT: Any objection? 17 THE COURT: Any objection?
18 MR. SCHACHTER: No objection. 18 MR. SCHACHTER: No, Your Honor.
19 THE COURT: Admitted. 19 THE COURT: It's admitted. You may publish.
20 You may publish. 20 MR. BINI: Thank you, Your Honor.
21 (Government Exhibit 3069 was received in evidence.) 21 (Government Exhibit 2771 was received in evidence.)
22 (Publishes exhibit to the jury.) 22 (Publishes exhibit to the jury.)
24 Q I'm going to ask you to look at the bottom email. What's 24 Q Did there come that time that you updated do Rosario and
25 the date of that email? 25 the defendant regarding what Credit Suisse was interested in?

1 A 15th of May, 2014. 1 Can you go to the middle of the page, on May 15th, at 19:13?
2 Q Who's it from? 2 A Yes.
3 A Galina Barakova Perez. 3 MR. BINI: The part that says, "Uncle is sorting it
4 Q And who was she? 4 out," if could you expand that for the jury, Ms. DiNardo.
5 A She was a member of the Global Finance Group at Credit 5 BY MR. BINI:
6 Suisse in London. 6 Q What did you write?
7 Q Was she making an inquiry into Antonio do Rosario? 7 A "Uncle is sorting it out. There is some stupid UK
8 A Yes, she was. 8 regulatory requirement that Credit Suisse accounts be
9 Q What was she asking for? 9 following, to speak to someone at the Martin, to confirm the
10 A A callback with the operational team at Credit Suisse. 10 payment details, but I will get full details shortly. In any
11 Q What how did Mr. Do Rosario respond? 11 event, I told him to tell Barakova she's fired if she doesn't
12 A Do Rosario, my secretary said that you called three times 12 behave in the future."
13 this afternoon and wanted to talk -- 13 Q Why did you write "uncle is sorting it out"?
14 THE COURT: Slow it down. 14 A I had spoken to Surjan Singh. He explained what the
15 THE WITNESS: I apologize. 15 issue was, and he was sorting it out within Credit Suisse.
16 A "My secretary said that you called three times this 16 Q Why did you write, "I told him to tell Barakova she's
17 afternoon and wanted to talk to me or someone else. Had I 17 fired if she doesn't behave in the future?
18 known it, I would have directed her to pass the phone to 18 A I was pretending I had some control over that issue.
19 Mr. Enrigue Gamato, administrator, member of the board in 19 Throw away line.
20 charge of admin and finance. 20 Q Did you actually at that point?
21 Q I'm going to stop you there, and ask you to then go to 21 A No.
22 the first page and look to the email at May 15th, 2014, at 22 (Continued on the next page.)
23 18:55. What happened at that point in the email chain? 23
24 A The email messages were forwarded by Antonio do Rosario 24
25 to Mr. Boustani and myself. 25
Page 634 to 637 of 681
1 EXAMINATION CONTINUING 1 A The 9th of May, 2014.
2 BY MR. BINI: 2 Q And who is it from and to?
3 MR. BINI: At this time, the Government would seek 3 A From Mr. Boustani to Naji Allam.
4 to admit Government's Exhibit 5112. 4 Q What's the "Subject"?
5 THE COURT: Any objection? 5 A "MAM Contract and Signed Annexes."
6 MR. SCHACHTER: Your Honor, this has been ruled on 6 MR. BINI: And if we can go to -- if we can go up.
7 before. 7 BY MR. BINI:
8 THE COURT: Any objection? 8 Q Was this e-mail forwarded to you, Mr. Pearse?
9 MR. SCHACHTER: No further objection. 9 A Yes, it was.
10 THE COURT: You may publish. It's admitted. 10 MR. BINI: If you can go up, Ms. DiNardo, the
11 MR. BINI: Thank you, Your Honor. 11 May 22nd e-mail.
12 (Government's Exhibit 5112 was received in 12 Q Who forwarded it to you on May 22nd?
13 evidence.) 13 A Mr. Boustani.
14 (Exhibit published.) 14 Q And looking to the first page of 2774, the very top
15 BY MR. BINI: 15 e-mail, who did you forward the document to, if anyone?
16 Q If you can look at the e-mail to you from Gwendoline 16 A Antonio do Rosario.
17 Arnal, copying Makram Abboud, Ms. Subeva, and Markus Kroll 17 MR. BINI: Your Honor, I would also ask to admit at
18 Palomar. 18 this time 2774-B.
19 Who's Markus Kroll Palomar? 19 THE COURT: Any objection?
20 A Markus Kroll was the COO of Palomar Capital Advisors. 20 MR. SCHACHTER: No objection.
21 Q What did Gwendoline Arnal write? 21 THE COURT: Admitted. You may publish.
22 A I'm sorry, could you repeat the question, please? 22 MR. BINI: Okay.
23 Q What did Gwendoline Arnal write? 23 (Government's Exhibit 2774-B was received in
24 A "Dear Andrew, Markus, Could you please provide 24 evidence.)
25 confirmation that Palomar Capital Advisors, AG complied with 25 (Exhibit published.)
1 all laws applicable to anti-bribery and corruption? Reference 1 BY MR. BINI:
2 to any local laws or regulations would be most helpful. This 2 Q Starting with 2774-A, what were you sending to
3 information is required to enable VTB Capital to satisfy our 3 Antonio do Rosario?
4 regulatory responsibilities." 4 A This is the procurement contract between Privinvest
5 Q What did you understand Ms. Arnal to be asking you to 5 Shipbuilding Investments, LLC, and MAM.
6 confirm? 6 Q And what's on the first page?
7 A That Palomar Capital Advisors had not been involved in 7 A It's a certification by Antonio do Rosario that the
8 any bribery or corruption. 8 document is correct, complete, in full force as of -- as
9 Q How did you respond? 9 effective -- and effective as of May 2014.
10 A "Confirmed. Markus will revert with full details of 10 Q Who are the parties to this procurement contract?
11 prevailing law. Thanks." 11 A Privinvest Shipbuilding Investments and MAM.
12 MR. BINI: At this time, the Government would seek 12 Q Looking to the second page --
13 to admit 2774 and 2774-A. 13 (Exhibit published.)
14 THE COURT: Just state the numbers again, please. 14 BY MR. BINI:
15 MR. BINI: 2774 and 2774-A. 15 Q -- is there a "Preamble" section?
16 THE COURT: Any objection? 16 MR. BINI: Can you expand that, Ms. DiNardo?
17 MR. SCHACHTER: No objection, Your Honor. 17 A (No response.)
18 THE COURT: Admitted. You may publish. 18 Q And if you can take a look at that for a moment, and then
19 (Government's Exhibits 2774 and 2774-A were received 19 explain to the jury, in your own words, what was the MAM
20 in evidence.) 20 procurement contract to cover?
21 (Exhibit published.) 21 (Pause.)
22 MR. BINI: If we could go to the earliest e-mail on 22 A The contract was to provide for the construction of a
23 page 3. 23 shipyard in Mozambique.
24 BY MR. BINI: 24 Q And if we look to page 7, Roman numeral VII, what was the
25 Q What is the date of this e-mail? 25 price in this procurement contract?
Page 638 to 641 of 681
1 A $500 million. 1 permission, issued by the customer or relevant Mozambique
2 Q And if we go to the signature page, on pages 16 and 17, 2 authorities, including access rights to relevant facilities."
3 who signed on behalf of MAM? 3 Q I'll stop you there.
4 A Antonio Rosario. 4 What did you understand this provision to require?
5 Q And who signed on behalf of Privinvest? 5 A The first paragraph refers to the contractor and the
6 A Mr. Boustani. 6 customer, being MAM, stating that they won't pay bribes or
7 MR. BINI: If we can look at Government's 7 kickbacks.
8 Exhibit 2774-B. 8 Q Okay.
9 (Exhibit published.) 9 MR. BINI: Now, if we can take that down and go to
10 MR. BINI: If you would scroll through to the second 10 Government's Exhibit 301.
11 page. 11 (Exhibit published.)
13 Q What is 2774-B? 13 Q Did there come a time that the MAM loan agreement was
14 A It's a short description of one of the vessels we 14 entered into with VTB?
15 provided under the MAM contract. 15 A Yes.
16 Q Okay. 16 Q What was the date of that agreement?
17 MR. BINI: You can take that down, Ms. DiNardo. 17 A 20th of May, 2014.
18 At this time, the Government would seek to admit 18 Q Is Government's Exhibit 301 that agreement?
19 Government's Exhibits 301 and 302. 19 A Yes, as far as I know.
20 THE COURT: Any objection? 20 Q Okay.
21 MR. SCHACHTER: No, no objection. 21 And if we go to the Table of Contents, does this
22 THE COURT: Publish it to your adversary so they can 22 have many of the same clauses that we've seen before?
23 see it, please, electronically. 23 A Would it be possible to go down, scroll down?
24 MR. BINI: I'm sorry. Before I go to 301 and 302, 24 Q Does it have a clause with "Purpose"?
25 one matter -- 25 A Yes.

1 THE COURT: Use the mic, pull it to you. 1 Q Which one is that?
2 MR. BINI: Yes, Your Honor. 2 A 3.
3 If we can go back to 2774-A for a moment. 3 Q Is that similar in nature to the "Purpose" clauses we've
4 THE COURT: That's in evidence, right? 4 seen in the other loan agreements?
5 MR. BINI: Yes, Your Honor. 5 A Yes, but the clause is contained in this "Contents," sir.
6 THE COURT: Okay, please go back to that. 6 Largely the same as the ones contained in the other documents,
7 MR. BINI: And if we can go to page 14. 7 the other agreements we looked at.
8 (Exhibit published.) 8 THE COURT: Try to keep your voice up. Again, move
9 BY MR. BINI: 9 the microphone closer to you. Speak directly into it like
10 Q Did the MAM procurement contract have a section L on 10 this, and then you will be heard. Maybe not like this, but go
11 "Remuneration," if I pronounced that correctly? 11 ahead.
12 A Yes. 12 BY MR. BINI:
13 Q What did it say regarding payments to third-parties? 13 Q And is there a Clause 19 with "Representations" that has
14 A "The contractor, as well as customer, represents and 14 similar language on compliance with laws?
15 warrants that it and no person interested or connected with it 15 A Yes, there is.
16 has not and shall not offer pay or propose to pay money or to 16 Q And is there a Clause 28 on "Payment Mechanics"?
17 give anything of value, directly or indirectly, to any civil 17 A Yes.
18 servant or any other person holding a governmental position or 18 Q And does that require payment to a New York City
19 who is otherwise prohibited from receiving any such money or 19 corresponding bank account?
20 thing of value. 20 A I don't know, sir. You'd have to refresh my memory. If
21 "For the execution of the project, the contractor 21 I could look at that page?
22 might require governmental or regulatory approvals/permissions 22 Q Okay.
23 both within Mozambique and outside of Mozambique. For 23 MR. BINI: Let's go to page 73, Clause 28.1.
24 obtaining such permissions, it may be necessary to receive an 24 (Exhibit published.)
25 adequate end-user certificate or other legal authority or 25 BY MR. BINI:
Page 642 to 645 of 681

1 Q Where are payments to be made, according to this loan 1 Q Why was Palomar an arranger for this loan?
2 agreement, in 28.1(b)? 2 A We had asked to be an arranger alongside VTB in order to
3 A It indicates that payments will be made to Deutsche Bank 3 publicize our activities, help us in marketing for further
4 Trust Company Americas, 60 Wall Street, New York, New York, 4 business.
5 United States of America. 5 THE COURT: When you say "we," you mean?
6 Q You had discussed syndication being different on this 6 THE WITNESS: Palomar Capital Advisors.
7 loan than on other loans. 7 THE COURT: Thank you.
8 Can you describe that to the jury? 8 Go ahead.
9 A No, sir, I didn't say that. I corrected whether the loan 9 BY MR. BINI:
10 was drafted to enable it to be syndicated. 10 Q And if we go to the next page, 107, who signed on behalf
11 Q Did it have a provision, a clause that enabled 11 of VTB?
12 syndication at some later point? 12 A Makram Abboud and Cicely Leemhuis.
13 A Would it be possible to have a look at the "Contents" 13 Q Is Makram Abboud the person who you said the defendant
14 page, please? 14 told you he paid millions of dollars to?
15 MR. BINI: If we can go to the Table of Contents, 15 A Yes, sir, he is.
16 Ms. DiNardo. 16 MR. BINI: At this time, the Government would seek
17 (Exhibit published.) 17 to admit Government's Exhibit 3129 and 3129-A.
18 MR. BINI: If you can keep going down. 18 THE COURT: Any objection?
19 THE WITNESS: Yes, it did. 19 MR. SCHACHTER: No objection, Your Honor.
20 BY MR. BINI: 20 THE COURT: You may publish. They're admitted.
21 Q Which clause is that? 21 (Government's Exhibits 3129 and 3129-A were received
22 A "Changes to Lenders," 23. 22 in evidence.)
23 Q Okay. 23 BY MR. BINI:
24 MR. BINI: If we can go to page 58. 24 Q Who is this e-mail from?
25 BY MR. BINI: 25 A This is from Felipe Berliner.
1 Q If you could take a look at that, can you explain how 1 Q And who is it to?
2 this clause is similar or different to the other loan 2 A Myself, Ms. Subeva, and Natalia Kouznitsyna. Sorry, a
3 agreements we've looked at? 3 terrible pronunciation.
4 A It is different from the loans for Proindicus and EMATUM 4 Q And what did Felipe Berliner write to you on May 23rd,
5 in one key respect, there's a restriction on syndication or 5 2014?
6 transfer of the loan from the original lender for one year. 6 A "Hi. As requested, please find attached the Payment
7 Q Okay. 7 Instruction for the net amount of U.S. dollars,
8 And if we look to the back, to the signatures, to 8 406,542,056.07."
9 the last two pages, 107 and 108. 9 Q What was that for?
10 Who signed on behalf of MAM? 10 A That was the amount of the first tranche of the MAM loan
11 A I'm not sure. I can't see, sir. 11 that was sent after deducting the fees that VTB wrote.
12 MR. BINI: Can we blow up the page that has the MAM 12 Q Okay.
13 signature. 13 And I just need to ask you now to look at
14 THE WITNESS: It was signed by Antonio do Rosario 14 Government's Exhibit 3129-A.
15 and another name which I cannot read, I'm afraid. 15 (Exhibit published.)
16 BY MR. BINI: 16 Q Who is the sender of this -- what is this, first of all?
17 Q Okay. 17 A This is a SWIFT confirmation, a payment confirmation
18 And if we go to the next page, 107, there is a 18 between banks.
19 Palomar Capital Advisors, Limited, signature. 19 Q Who is the sender on the SWIFT at the very top of the
20 MR. BINI: You can blow up the arrangers. 20 page?
21 BY MR. BINI: 21 THE COURT: What is a SWIFT?
22 Q Was VTB one of the arrangers? 22 THE WITNESS: This --
23 A Yes. 23 THE COURT: Do you know? Yes.
24 Q Who was the other arranger for this loan? 24 THE WITNESS: Excuse me, Your Honor.
25 A Palomar Capital Advisors. 25 A SWIFT is a document which sets out the terms of a
Page 646 to 649 of 681
1 bank transfer between banks. It's akin to a receipt to show 1 Q And who is that e-mail from and to?
2 that one bank has sent money to another. 2 A That's from myself to Naji Allam, copying Mr. Boustani.
3 THE COURT: Why is it called a SWIFT, do you know? 3 Q Why -- I'm sorry.
4 THE WITNESS: Yeah, SWIFT refers to the settlement 4 What happened around June 11th, 2014?
5 system that is used. I do not know anything other than... 5 A If I recall correctly, a hundred million -- an additional
6 THE COURT: The acronym. All right. Thank you. 6 hundred million of the MAM loan was funded.
7 Go ahead. 7 MR. BINI: If we can look to 3126-A.
8 MR. BINI: Thank you, Your Honor. 8 (Exhibit published.)
10 Q Who is the receiver for the SWIFT? 10 Q Is that the attachment?
11 A Deutsche Bank Trust Company Americas. 11 A I believe so, yes.
12 Q And if we look to 32A, how much money is being sent to 12 Q And how much is being sent here?
13 Deutsche Bank Trust Company Americas in New York, New York? 13 Who is the sender?
14 A $406,542,056.07. 14 A VTB Capital, PLC.
15 Q What is this for? 15 Q Who is the receiver?
16 A This is the first installment under the MAM loan that was 16 A Deutsche Bank Trust Company Americas, New York.
17 borrowed by MAM. 17 Q And looking to line 32A, how much is being sent?
18 Q Who is the ordering customer? 18 A $93,457,943.93.
19 A VTB Capital, PLC. 19 Q And is this for a beneficiary customer, Privinvest
20 Q And is there an intermediary institution? 20 Shipbuilding?
21 MR. BINI: If we keep going down, Ms. DiNardo. 21 A Yes, it is.
22 THE WITNESS: Yes. 22 MR. BINI: Your Honor, at this time, the Government
23 BY MR. BINI: 23 would seek to publish to the jury Government's Exhibit 302,
24 Q What institution? 24 already admitted in evidence.
25 A The Bank of New York Mellon, New York. 25 THE COURT: You may publish.
1 Q And where does it get remitted? 1 (Exhibit published.)
2 A I'm sorry, can you explain your question, please? 2 BY MR. BINI:
3 Q Does it indicate a remittance -- excuse me, a beneficiary 3 Q Is this the guaranty for the MAM loan that we looked at a
4 customer? 4 minute ago?
5 A Yes. The beneficiary customer is Privinvest Shipbuilding 5 A Yes, it appears to be.
6 Investments, LLC. 6 Q Looking to the third to last page, I want to ask you who
7 MR. BINI: At this time, the Government would seek 7 signed the guaranty on behalf of the Republic of Mozambique?
8 to admit 3126 and 3126-A. 8 A Manuel Chang.
9 THE COURT: Any objection? 9 MR. BINI: At this time, the Government would seek
10 MR. SCHACHTER: No objection. 10 to admit Government's Exhibit 3070, 3070-A, 3070-B, and C.
11 THE COURT: Admitted. You may publish. 11 THE COURT: Any objection?
12 (Government's Exhibits 3126 and 3126-A were received 12 MR. SCHACHTER: No objection.
13 in evidence.) 13 THE COURT: Admitted. You may publish.
14 (Exhibit published.) 14 And after you finish with these documents, we will
15 BY MR. BINI: 15 take our 12-minute break.
16 Q What is 3126? What's going on in this e-mail chain? 16 MR. BINI: Thank you, Your Honor.
17 A Could I have the opportunity to read the whole e-mail 17 (Government's Exhibits 3070, 3070-A, 3070-B, and
18 chain, please? 18 3070-C were received in evidence.)
19 Q Sure. 19 (Exhibit published.)
20 (Pause.) 20 BY MR. BINI:
21 A This chain is an e-mail from myself to Felipe Berliner at 21 Q What is the date of this e-mail, Mr. Pearse?
22 VTB Bank thanking him for his efforts, and asking for a copy 22 A June 26th, 2014.
23 of the SWIFT, which is the payment instruction. 23 Q And looking to the top e-mail, who is it from and to?
24 Q What's the date of the top e-mail? 24 A It is from Naji Allam to myself, copying David Langford
25 A 11th of June, 2014. 25 and Markus Kroll.
Page 650 to 653 of 681
1 Q What was Naji Allam writing about, Mr. Pearse? 1 DIRECT EXAMINATION
2 A In order to refresh my recollection, would it be possible 2 BY MR. BINI: (Continuing)
3 to see the preceding e-mails? 3 Q And who did that go to, if you know?
4 MR. BINI: Let's look to the bottom e-mail. 4 A It went to -- a third of it went to the Boustani, Mr.
5 (Exhibit published.) 5 Boustani as far as I'm aware and the other third went to Mr.
6 BY MR. BINI: 6 Safa.
7 Q What did you write? 7 MR. BINI: Your Honor, this would be a good time for
8 A "Hi, Najib. Did the 1.2 million from ADCB arrive in the 8 a break.
9 end? Now that the SLE deal is finished, could you please send 9 THE COURT: All right. Let's take our 12-minute
10 a reconciliation of amounts in Palomar Holdings. Thank you." 10 break and we will have a hard stop at 5:00. Ladies and
11 Q Okay. 11 gentlemen, don't talk about the case during the break.
12 MR. BINI: And if we can look to 3070-A. 12 (Jury exits the courtroom.)
13 (Exhibit published.) 13 THE COURT: You may step down, sir. Thank you.
14 BY MR. BINI: 14 (Witness steps down.)
15 Q Was Naji Allam settling up certain things in this e-mail? 15 THE COURT: The jury has left. You may be seated,
16 A No, this is a copy of a -- what appears to be a bank 16 ladies and gentlemen. The jury has left the courtroom.
17 statement. 17 Do we have any procedural issues to discuss in the
18 MR. BINI: Well, go back to 3070. 18 absence of the jury, not from the Government, Your Honor.
19 (Exhibit published.) 19 THE COURT: The defense?
20 Q Was Naji Allam attaching certain documents? 20 MR. JACKSON: No, Your Honor.
21 A Yes, he was attaching -- excuse me -- copies of Palomar 21 THE COURT: See you in 12 minutes.
22 Holdings' bank accounts at First Gulf Bank. 22 (Recess taken.)
23 Q I'd like to ask you to look at the Attachment 3070-A. 23 THE COURTROOM DEPUTY: All rise. Judge Kuntz
24 (Exhibit published.) 24 presiding.
25 What is 3070-A, Mr. Pearse, if you recognize it? 25 THE COURT: We are waiting for the defendant to be

1 A It's one page of an account statement for Palomar 1 produced. We have the appearances. Then can we have the
2 Holdings, Limited. 2 witness resume the witness stand and then we will finish up
3 Q And looking to the entry on the posting date, 03/06/2014. 3 the day with a hard stop at 5:00.
4 MR. BINI: It's on that page. No. 4 Thank you, Mr. Pearse.
5 Ms. DiNardo, if you can go up a little bit. It's a 5 THE WITNESS: Thank you, Your Honor.
6 debit amount that says 20,100,000. Yes. 6 THE COURT: Did you speak with anyone about your
7 BY MR. BINI: 7 testimony while you were out?
8 Q Mr. Pearse, what was this debit amount of $20,100,000 8 THE WITNESS: No, we were too busy discussing the
9 for, if you know? 9 Yankees, Your Honor.
10 A If I may? Below that, there is an amount of $10,050,000, 10 THE COURT: There you go. I know, very painful.
11 which was the amount I referred to earlier as the payment that 11 You can get the jury in now.
12 I received in relation to the MAM transaction. The fee or 12 I promise not to bring up Brexit or anything like
13 the -- my share of the dividend that was paid by Palomar as a 13 that.
14 result of receiving fees from Privinvest. 14 THE WITNESS: Appreciate that.
15 The entry above that for 20,100,000 was the other 15 (Jury enters the courtroom.)
16 two-thirds share. My 10 million was one-third share of the 16 THE COURT: Thank you. Ladies and gentlemen of the
17 total that was paid to Palomar Partners. 17 jury, as promised, there are cough drops as you come in, if
18 18 you want. Not a requirement, but at the end of the day.
19 (Continued on the following page.) 19 Thank you, sir. Ladies and gentlemen of the jury, you may be
20 20 seated. Thank you for your patience. We will have our hard
21 21 stop at 5:00.
22 22 Sir, I take it you did not discuss your testimony
23 23 with anyone during the break.
24 24 THE WITNESS: I did not.
25 25 THE COURT: Thank you. Please be seated. We will
Page 654 to 657 of 681
1 now continue with the direct examination of the witness. 1 was from the transactions you had engaged in with him?
2 MR. BINI: Thank you, Your Honor. 2 MR. SCHACHTER: Objection.
3 BY MR. BINI: 3 THE COURT: If you have a belief.
4 Q Mr. Pearse, did you take any of the money that you made 4 A I had that belief.
5 from the MAM transaction and move it somewhere else? 5 Q Why?
6 A Yes, I did. 6 A Because I knew that I had made approximately $35 million
7 Q What did you do with the funds that you earned from the 7 from EMATUM and MAM from Palomar Holdings, for monies I had
8 MAM transaction, Mr. Pearse? 8 received from Palomar Holdings, and I was aware that the
9 A In part, I invested them into a company called Palomar 9 defendant was a one-third partner in Palomar, same as myself
10 Natural Resources. 10 and would receive the same amount of money.
11 Q What is Palomar Natural Resources? 11 Q Was he an official partner of Palomar?
12 A It is a company that I acquired together with the 12 A No. The legal ownership structure involved another
13 defendant and Iskandar Safa, which is an oil and gas 13 company, another Privinvest company as being the two-thirds
14 exploration company, originally with assets in New Mexico, the 14 owner of Palomar. I owned my one-third share in EMATUM and
15 USA, and then literally in Poland in Eastern Europe. 15 the two-thirds were held by another company.
16 Q Did you invest assets before and after the MAM 16 Q What, if anything, did the defendant say that led you to
17 transaction into those concessions? 17 believe that he was an owner of Palomar?
18 A Yes. I invested a large part, almost $30 million of the 18 A Many things. When Palomar was established way back in
19 monies I received for these transactions in that company. 19 2013, it was established as a partnership. All discussions I
20 Q When you say these transactions, are you referring to the 20 had with the defendant in relation to the payment of monies
21 criminal scheme that we have been discussing? 21 made by Palomar were with the defendant. To the extent there
22 A I'm referring to -- yes, I am -- to Proindicus, and 22 were arguments about money in relation to expenditure or
23 ultimately MAM, monies I received from those projects. 23 investments, they were with the defendant, we co-invested, as
24 Q During the course of your criminal conduct with the 24 I said, into Palomar Natural Resources in which we all put a
25 defendant, did you observe or see anything -- before I ask you 25 lot of money. I put $20 million. The defendant put $20

1 that, let me ask you, I asked you about a concession, what's a 1 million. When we were unable to sell that company, he was
2 concession? 2 very unhappy about not having his money repaid to him. There
3 A That is a right that is given by a Government to explore 3 were many instances I could recite.
4 for hydrocarbons in a certain area, a geographical area, so a 4 Q What, if anything, did he say to you about that dispute
5 concession provides the holder of the concession with the 5 regarding money you just referred to?
6 right to explore and drill for oil and gas in this context. 6 A So, the largest investment we made collectively was --
7 Q During your time in this criminal scheme, did you observe 7 we, being the defendant, myself, and Iskandar Safa, was into
8 anything that led you to believe the defendant had become 8 Palomar Natural Resources, the oil and gas company. We
9 wealthier? 9 collectively put $70 million into that company.
10 A Yes, I did. 10 THE COURT: How much?
11 Q What did you observe? 11 THE WITNESS: 70.
12 A I observed him buying property in London and South of 12 THE COURT: Seven zero?
13 France. 13 THE WITNESS: Seven zero.
14 Q Do you have an idea of the approximate amounts of the 14 THE COURT: Go ahead.
15 properties based upon your conversations with the defendant? 15 A We -- I had been trying -- I tried to sell that company
16 A Yes. He told me that he had acquired two properties in 16 in 2016 and subsequently, unfortunately, due to adverse
17 central London for approximately 10 to 11 million pounds, 17 publicity, because of the Mozambican loans and my association,
18 which at that time was approximately $15 million, and a 18 Mr. Safa's association with those loans, it became
19 property South of France, which is next to the golf course 19 increasingly difficult to sell the company and ultimately we
20 which is owned by Iskandar Safa. He told me that was 20 needed to invest more money into the company. And in 2018,
21 approximately 2 million Euros. 21 end of 2018 I did not have the money to invest it, and the
22 Q What was the timeframe of these purchases? 22 conditions to which Iskandar Safa was prepared to put more
23 A The timeframe was in the period after the MAM transaction 23 money into it involved me losing considerable amounts of my
24 closed, so approximately 2015. 24 share in the company. And I had a discussion with the
25 Q Did you have reason to believe that the additional wealth 25 defendant at length about this in Abu Dhabi and he said to me
Page 658 to 661 of 681

1 unless you agree with Safa, he's going to burn the company 1 THE COURT: Would you spell that for the reporter,
2 down, which neither of us can afford to do. He got lots of 2 at least phonetic.
3 money, but we can't afford to lose 20 million each. That was 3 THE WITNESS: John, J-O-H-N. Buggenhagen,
4 the conversation I had with him at the end of 2018. 4 B-U-G-G-E-N-H-A-G-E-N.
5 MR. BINI: I'd like to at this point, Your Honor, if 5 THE COURT: Thank you, sir.
6 I could admit Government Exhibit 3127. 6 Continue.
7 THE COURT: Any objection? 7 Q And if we look to your e-mail on the bottom of the first
8 MR. SCHACHTER: Can I have just a moment, Your 8 page into the top of the second page on November 12, 2014 at
9 Honor. 9 1:55 p.m., I want to ask you about the part where you said,
10 THE COURT: Show it to him electronically, if you 10 "Does Sandy want to be involved and we lend out of PH or we do
11 can. 11 this you and me?" What were you asking the defendant?
12 MR. SCHACHTER: No further objection. 12 A I was asking the defendant whether Iskandar Safa wanted
13 THE COURT: All right. It's admitted. 13 to be involved in this loan. It was a profitable venture in
14 (Government's Exhibit 3127 received in evidence.) 14 my opinion and asking whether the loan that we were to make to
15 THE COURT: You may publish. 15 Sandy would be from Palomar Holdings or separately, just
16 MR. BINI: Thank you, Your Honor. 16 involving a vehicle involving the defendant and myself.
17 (Exhibit published.) 17 Q And if we go to the next e-mail from the defendant at
18 Q If we can go to the e-mail from November 12, 2014 at 18 15:29. What did the defendant indicate?
19 15:29. What did the defendant Jean Boustani write to you 19 A He suggests that Palomar Capital Advisors be the lender
20 regarding this e-mail subject loan? 20 for the transaction.
21 A He writes Palomar Capital Advisors, please. 21 Q Okay. And if we go up to your e-mail at 6:44 p.m., what
22 Q What was Palomar Capital Advisors, Mr. Pearse? 22 did you set out to the defendant?
23 A Palomar Capital Advisors was the financial advisor based 23 A I asked are we doing two-thirds, one-third or 50/50?
24 in Zurich, Switzerland we originally acquired in 2013 together 24 Better out of PH as it's in BV and technically PCAAD is 50
25 from Markus Kroll. 25 percent owned by the lawyers.

1 Q Was the defendant officially in charge of Palomar Capital 1 Q What did you mean by PCAAD is 50 percent owned by the
2 Advisors? 2 lawyers?
3 A No, he wasn't. 3 A I was referring to Palomar Consulting -- I used the wrong
4 Q What was he requesting in this e-mail? 4 acronym in this e-mail -- which was a company which was
5 A I'm sorry, would it be possible to see the preceding 5 incorporated in Abu Dhabi, which was part of the Palomar
6 e-mail? 6 group.
7 MR. BINI: If we can go to the bottom e-mail, Ms. 7 Q Why did you indicate it's 50 percent owned by the
8 DiNardo, so Mr. Pearse can see that. 8 lawyers?
9 Q I am going to ask you to take a look at it. Does that 9 A Because foreigners are not allowed to own 100 percent of
10 relate to a different transaction? 10 a company based in Abu Dhabi. They could only own 49 percent.
11 A Yes, it does. 11 So the way to get around that is for law firms to own 51
12 Q And are you talking about a loan? 12 percent and hold those shares on behalf of the foreign entity.
13 A Yes. This was a loan that was being proposed that 13 Q If you go up to the e-mail in response from the
14 Palomar made to -- Palomar made to a company called San Leon 14 defendant, at 15:46, what did the defendant write to you about
15 Energy. 15 that structure?
16 Q What's San Leon Energy? 16 A "Bro, I don't understand. I don't do anything without
17 A It's an oil and gas company based in London. 17 Iskandar. Palomar Abu Dhabi is controlled by us. Lawyers are
18 Q Is it related to Palomar Natural Resources? 18 nominees, no worries. "
19 A It is because Palomar Natural Resources bought the Polish 19 Q What did you understand the defendant to mean lawyers are
20 gas concessions from San Leon Energy and the chief -- the CEO 20 nominees, no worries?
21 of Palomar Natural Resources, a gentleman called John 21 A He means that the lawyers are just holding the shares;
22 Buggenhagen, who had previously been an employee of San Leon 22 they don't make the decisions in relation to the company.
23 Energy. 23 Q Who made the decisions with respect to Palomar Holdings?
24 THE COURT: What was his name? 24 A The partners: Myself, the defendant, and Iskandar Safa.
25 THE WITNESS: John Buggenhagen. 25 Q You spoke about the defendant appearing to become
Page 662 to 665 of 681

1 wealthier during the criminal scheme. What about Iskandar 1 MR. BINI: If we can look to 3145A.
2 Safa, did he appear to become wealthier? 2 Q Is this a copy of your ticket?
3 A When I first met him, he appeared to be a wealthy man 3 A Yes, it is.
4 already. He did appear to become wealthier as time -- during 4 Q Did you continue to work on the Mozambican projects while
5 the period that I knew him from 2013 onwards. 5 you were in New York?
6 Q What did you see, hear, or observe that led you to 6 A I would work on Mozambican projects wherever I was in the
7 believe that he had become wealthy? 7 world at the time, including New York.
8 A I saw his estate in the South of France being 8 Q Did you exchange e-mails while in New York with others
9 significantly renovated. I saw him acquire a private jet and 9 involved in the fraud scheme?
10 I was told by a member of his staff that he had acquired a 10 A I don't recall, sir.
11 large yacht. 11 Q Well, let me ask you --
12 Q Did you have any understanding as to what the source of 12 MR. BINI: At this time, Your Honor, I would like to
13 his additional wealth had been? 13 move into evidence Government Exhibit 3154.
14 A I did not. 14 THE COURT: Any objection?
15 Q During the course of your involvement in this scheme, did 15 MR. SCHACHTER: No objection.
16 you travel to the United States on several occasions? 16 THE COURT: It's admitted.
17 A Yes. There was a period of time that I was in the U.S. 17 (Government's Exhibit 3154 received in evidence.)
18 on a number of occasions. 18 THE COURT: You may publish.
19 MR. BINI: At this time the Government would seek to 19 (Exhibit published.)
20 admit Government Exhibit 3145 and 3145A. 20 Q What is the top e-mail, who is that from and to?
21 MR. SCHACHTER: No objection. 21 A That's from myself to Mr. Boustani, Dominic Shultens, and
22 THE COURT: No objection? Did you say no objection? 22 Ms. Subeva.
23 MR. SCHACHTER: No objection. 23 Q What is the date of the e-mail?
24 THE COURT: Admitted. 24 A September 17, 2014.
25 (Government's Exhibits 3145 and 3145A received in 25 Q Where were you on September 17, 2014?

1 evidence.) 1 A In New York.
2 THE COURT: You may publish. 2 Q What did you write?
3 MR. BINI: Okay if we can is show 3145. 3 A "Spoke to uncle.
4 Q What is Government Exhibit 3145? 4 "They have not been discussing anything. They have
5 MR. BINI: You can stop there. 5 not discussed upsize with anyone. The only thing they did was
6 Q Is this a travel reservation, Mr. Pearse? 6 speak to Moza and BCP about potential extension. So, in
7 A Yes, it is. 7 short, no idea where this came from."
8 Q For whom? 8 Q What upsize were you discussing?
9 A For myself and Ms. Subeva. 9 Let me stop there. Whose uncle?
10 Q When were you leaving? 10 A Uncle is Surjan Singh.
11 A 15th of September. 11 Q If we can go to the earliest e-mail. On September 17,
12 Q And where were you going from and to? 12 2014 at 21:42, what did the defendant write to you?
13 A From London, Heathrow to JFK, New York. 13 A He writes "Isaltina just called employee freaking out.
14 THE COURT: I'm sorry, what year is this? 14 She got a call from Rand Bank saying that JP Morgan is
15 MR. BINI: If we can go to the top of the e-mail. 15 arranging $540 million dollars for Moz with MoF guarantee.
16 Let's see what the date is. 16 She is worried that this is VTB flipping the MAM deal. And
17 THE COURT: 2014, is that the date, sir? 17 she is really panicking. I told her I very much doubt there
18 MR. BINI: Yes, Your Honor. 18 is strict confidentiality and non-trading restriction for one
19 THE COURT: Go ahead, counsel. 19 year."
20 Q Now, if we can go further down, does it indicate a return 20 Q Let me stop you there. What did you understand the
21 flight on Friday, September 19th? 21 defendant to mean when he said that Isaltina was freaking out?
22 A Yes, it does. 22 A That Isaltina was very worried.
23 Q If we go further down, where were you going to fly from 23 Q About what?
24 and to on September 19th? 24 A About the possibility that the MAM loan would become
25 A From JFK, New York to London, Heathrow. 25 public.
Page 666 to 669 of 681

1 Q Why was that a source of concern, if you are aware? 1 in evidence.)
2 A Because the Ministry of Finance and, indeed, the other 2 THE COURT: You may publish.
3 participants in the scheme did not want the MAM loan to become 3 (Exhibit published.)
4 public. 4 Q We can go to 3160. Look at this top e-mail. What's the
5 Q Do you see where the defendant wrote there is strict 5 date of this e-mail?
6 confidentiality and non-trading restriction for one year? 6 A October 14, 2014.
7 What did you understand the defendant to mean? 7 Q Whose it from and whose it to?
8 A He's referring to two of the clauses in the MAM loan 8 A It's from myself Dominic Shultens.
9 agreement. 9 Q What's the subject of the e-mail?
10 Q Is that that complicated clause you explained to us on 10 A Proindicus update.
11 changing lenders? 11 Q What was going on in October of 2014 with respect to the
12 A He's referring to what was -- yes. In the MAM loan there 12 Proindicus loan, Mr. Pearse?
13 was a very unusual provision restricting VTB from transferring 13 A At this point in time, myself and other members of
14 the loan for one year and there are other provisions related 14 Palomar were working with Credit Suisse and VTB to extend the
15 to confidentiality that are in the back end of that loan. 15 terms of the Proindicus loan.
16 MR. BINI: And if you go up to the next page. 16 Q What do you mean by extend the terms of the Proindicus
17 Q Is there an e-mail from Dominic Shultens? 17 loan?
18 A Yes, there is. 18 A If I may explain. Proindicus, the original Proindicus
19 Q If you go to the e-mail after that, did the defendant 19 loan was now $622 million in size and there was an obligation
20 e-mail again? 20 in March of 2015 to repay part of the loan, as well as the
21 A Yes, he did. 21 interest that was due on that date. It was clear that
22 Q What did he indicate? 22 Proindicus did not have the money to make those payments, so,
23 A "Please, I promised Isaltina an answer tomorrow." 23 Palomar, the Palomar team, myself, Mr. Laverne, Mr. Shultens
24 Q What did you understand the defendant to be asking for an 24 were working with Credit Suisse and VTB to change the original
25 answer about? 25 terms of the Proindicus loan to make it longer to reduce the
1 A An answer as to who was marketing another Mozambican loan 1 payment that was due the following March of 2015.
2 and -- we were trying to establish what Isaltina was referring 2 Q What did you indicate in your e-mail?
3 to when she was freaking out to Mr. Boustani at the beginning 3 A "Thanks. I'm off to New York to finalize with Surj.
4 of the e-mail chain. 4 Happy house hunting."
5 Q Okay. And is that what you were responding to when you 5 Q What did surrender refer to?
6 said "spoke to uncle"? 6 A Surjan Singh.
7 A Yes. One of the potential parties who may have been 7 MR. BINI: We can go to 3159A.
8 marketing Mozambican loans, trying to sell Mozambican loans 8 Q What is 3159A, Mr. Pearse?
9 was Credit Suisse. 9 A That is a copy of my flight ticket to -- from Heathrow to
10 Q Was this -- all these e-mails that we've gone through, 10 Newark, New Jersey.
11 were you in New York City when you sent and received these, 11 Q What is the date of your flight to Newark, New Jersey?
12 the New York City area? 12 A 14 October, 14th.
13 A Could I look at the first e-mail, the date of the first 13 Q And when were you returning from the United States back
14 e-mail, please? 14 to London?
15 Q Yes. 15 A On the 16th of October 2014.
16 A Yes. 16 MR. BINI: If we go to Government Exhibit 3161.
17 Q Did you ever go back to New York City after this, while 17 Q What is 3161, Mr. Pearse?
18 the fraud scheme was continuing? 18 A It's an e-mail from myself to the front desk of The Mark
19 A Yes, I did. 19 Hotel.
20 MR. BINI: At this time the Government would seek to 20 Q What's the address of The Mark Hotel?
21 admit 3160, 3159A and 3161. 21 A It's 25 East 77th Street, upper east side, New York.
22 THE COURT: Any objection? 22 Q Is that in Manhattan?
23 MR. SCHACHTER: No objection. 23 A I don't know, sir.
24 THE COURT: They're admitted. 24 THE COURT: It's Manhattan.
25 (Government's Exhibits 3160, 3159A and 3161 received 25 Q Mr. Pearse, while you were in the New York City area, did
Page 670 to 673 of 681

Pearse - direct - Bini 674 676
1 you, in fact, meet with Surjan Singh? 1 INDEX
2 A Yes, I did, on that occasion. 2
3 Q And what did you and Surjan Singh discuss while you were 3 WITNESS PAGE
4 in New York? 4
5 A Amongst other things, we discussed the extension of the 5 ANDREW PEARSE
6 Proindicus loan and the potential fee that Palomar could earn 6 DIRECT EXAMINATION BY MR. BINI (Cont'd) 500
7 as part of the process to extend the loan. 7
8 MR. BINI: Your Honor, I see I'm hard on five 8
9 o'clock. Is this a good time to stop? 9
10 THE COURT: It is the absolute best time to stop as 10
11 promised to my jury. We are stopping at five o'clock. 11
12 Ladies and gentlemen, do not talk about the case 12
13 with anyone. Go home. And if you are a Yankees fan, you know 13
14 what to do. If you are a Mets fan, I'm sure you know to do 14
15 the opposite. Thank you. We will see you Monday, 9:30 a.m. 15
16 when we resume the trial. Have a good weekend everyone. 16
17 Thank you. 17
18 (Jury exits the courtroom.) 18
19 THE COURT: You may step down, Mr. Pearse. Thank 19
20 you. 20
21 21
22 (Continued on next page.) 22
23 23
24 24
25 25
MDL RPR CRR CSR SAM OCR RMR CRR RPR
PROCEEDINGS 675 677
1 THE COURT: (Continuing.) Thank you, ladies and 1 EXHIBITS
2 gentlemen. 2
3 The defendants are still here? We have any 3
4 procedural matters to address before we adjourn? 4 Government's Exhibit 2373 501
5 You may be seated. 5
6 MR. BINI: Yes, Your Honor. 6 Government's Exhibit 2375 502
7 THE COURT: Any other procedural matters to adjourn 7
8 other than the matter we're going to take up? 8 Government's Exhibit 2377 506
9 MR. BINI: Not from the Government. 9
10 THE COURT: Anything else? 10 Government's Exhibits 2384 and 2384-A 511
11 MR. BINI: No, Your Honor. 11
12 MR. JACKSON: No, Your Honor. 12 Government's Exhibit 2384-B 514
13 THE COURT: Okay. 13
14 Ladies and gentlemen of the public, have a nice 14 Government's Exhibit 2391 514
15 weekend. See you later. 15
16 16 Government's Exhibits 2393 and 2393-A
17 (Trial adjourned to Monday, October 21, 2019, at 9:30 a.m.) 17 through C 520
18 18
19 19 Government's Exhibit 2396 524
20 20
21 ooo0ooo 21 Government's Exhibit 2397 527
22 22
24 24
LISA SCHMID, CCR, RMR SAM OCR RMR CRR RPR
Page 674 to 677 of 681
678 680
1 E X H I B I T S (Cont'd) 1 E X H I B I T S (Cont'd)
2 2
3 Government's Exhibit 2427 539 3 Government's Exhibits 2746A, 2746B and 2746C 617
4 4
5 Government's Exhibit 2428 545 5 Government Exhibit 2747 618
6 6
7 Government Exhibit 251 547 7 Government Exhibit 2747A 618
8 8
9 Government Exhibits 2783 and 2783A 555 9 Government Exhibit 3112 623
10 10
11 Government Exhibit 2452 558 11 Government Exhibit 5111 624
12 12
14 14
16 16
17 Government's Exhibits 2457 and 2458 565 17 Government Exhibit 3123 632
18 18
19 Government's Exhibit 3125 568 19 Government Exhibit 3069 634
20 20
22 22
23 Government Exhibit 2509 571 23 Government's Exhibit 5112 638
24 24
25 Government's Exhibit 3132 575 25 Government's Exhibits 2774 and 2774-A 639
679 681
1 E X H I B I T S (Cont'd) 1 E X H I B I T S (Cont'd)
2 2
3 Government's Exhibit 2528 576 3 Government's Exhibit 2774-B 640
4 4
6 6
8 8
9 Government's Exhibit 2568 580 9 Government's Exhibits 3070, 3070-A, 3070-B,
10 10 and 3070-C 653
11 Government's Exhibits 2568-A and 2568-B 582 11

13 Government's Exhibit 2570 583 13

14 14 Government's Exhibits 3145 and 3145A 666


18 18 Government's Exhibits 3160, 3159A and 3161 671

20 20
21 Government Exhibit 7 612 21
22 22
24 24
25 Government Exhibit 2746 615 25
Page 678 to 681 of 681

All Word // USA v Jean Boustani
1
10th [2] - 558:15, 631:11 644:17, 649:5, 651:25, 652:4, 653:22,

$
11 [5] - 563:14, 571:15, 611:4, 611:15, 662:18, 664:8, 667:17, 668:24,
$10 [3] - 626:8, 626:9, 627:13 659:17 668:25, 669:12, 672:6, 672:11, 673:15
$10,050,000 [1] - 655:10 11.1 [1] - 611:15 2015 [4] - 601:18, 659:24, 672:20, 673:1
$100 [2] - 504:3, 523:6 11.8 [2] - 508:1, 508:7 2016 [1] - 661:16
$118 [1] - 580:7 11201 [1] - 494:18 2018 [3] - 661:20, 661:21, 662:4
$15 [4] - 508:12, 583:8, 585:25, 659:18 11:51 [1] - 542:17 2019 [3] - 494:7, 590:16, 675:17
$180,000 [1] - 509:2 11th [2] - 651:25, 652:4 2020 [1] - 547:23
$20 [4] - 627:13, 629:23, 660:25 12 [4] - 542:3, 656:21, 662:18, 664:8 20th [2] - 577:5, 644:17
$20,100,000 [1] - 655:8 12-minute [2] - 653:15, 656:9 21 [2] - 619:1, 675:17
$250 [1] - 501:10 12:36 [1] - 580:13 2144 [1] - 545:25
$250,000 [1] - 616:21 12:43 [2] - 581:8, 582:13 21:42 [1] - 669:12
$27 [1] - 508:13 13 [1] - 554:5 21st [3] - 578:20, 590:16, 622:21
$30 [1] - 658:18 136 [1] - 510:15 22nd [2] - 640:11, 640:12
$300 [2] - 627:15, 627:17 13th [1] - 516:5 23 [1] - 646:22
$312 [1] - 574:16 14 [3] - 643:7, 672:6, 673:12 23.4 [1] - 576:7
$312,900,000 [1] - 574:16 14-1/2 [1] - 508:12 23.8 [2] - 508:3, 508:8
$32 [2] - 524:6, 582:11 1400 [1] - 494:22 2373 [3] - 501:21, 501:25, 677:4
$34 [1] - 500:23 14th [1] - 673:12 2375 [5] - 502:16, 502:21, 531:22,
$35 [3] - 500:19, 616:22, 660:6 15 [5] - 525:17, 526:3, 550:7, 550:10, 531:23, 677:6
$360,000 [1] - 509:2 631:15 2377 [4] - 506:16, 506:20, 522:20, 677:8
$372 [2] - 503:24, 504:2 15-minute [2] - 525:15, 526:2 2384 [5] - 511:18, 511:24, 512:3, 514:4,
$406,542,056.07 [1] - 650:14 150,000 [2] - 508:16, 508:24 677:10
$472 [1] - 524:4 15:22 [1] - 619:2 2384-A [5] - 511:18, 511:24, 513:8,
$480 [1] - 509:11 15:29 [2] - 662:19, 664:18 514:4, 677:10
$49,00,000 [1] - 569:12 15:46 [1] - 665:14 2384-B [5] - 513:15, 514:3, 514:5, 514:9,
$49,200,000 [3] - 569:7, 569:14, 569:16 15s [1] - 632:3 677:12
$500 [6] - 541:12, 541:25, 547:17, 15th [4] - 635:1, 635:22, 637:1, 667:11 2391 [6] - 514:12, 514:16, 514:21,
547:22, 614:16, 642:1 16 [2] - 550:11, 642:2 523:10, 677:14
$535 [1] - 625:25 16th [2] - 575:17, 673:15 2393 [4] - 519:22, 520:15, 521:3, 677:16
$540 [1] - 669:15 17 [4] - 642:2, 668:24, 668:25, 669:11 2393-A [3] - 519:22, 520:15, 677:16
$600 [2] - 631:5, 631:8 17th [1] - 533:11 2393A [2] - 521:8, 523:10
$622 [1] - 672:19 18 [1] - 494:7 2396 [3] - 524:11, 524:18, 677:19
$640 [2] - 510:19, 510:20 18-CR-00681(WFK)(WFK [1] - 494:3 2397 [3] - 527:3, 527:7, 677:21
$70 [1] - 661:9 18-CR-681 [1] - 496:5 2398 [4] - 529:19, 529:24, 532:3, 677:23
$750 [3] - 541:12, 631:15, 631:20 18:55 [1] - 635:23 23rd [4] - 620:1, 622:25, 623:8, 649:4
$754 [1] - 510:11 19 [1] - 645:13 24 [4] - 509:15, 611:4, 611:14, 627:11
$850 [7] - 501:12, 517:23, 541:8, 541:9, 19-2A [1] - 554:18 2406 [3] - 532:24, 533:4, 677:25
541:16, 575:22, 627:17 19:13 [1] - 637:1 2427 [9] - 535:9, 535:17, 537:4, 537:7,
$93,457,943.93 [1] - 652:18 19th [3] - 632:22, 667:21, 667:24 537:9, 537:14, 539:5, 539:7, 678:3
1:55 [1] - 664:9 2428 [3] - 545:3, 545:13, 678:5
0 1st [2] - 579:19, 583:21 2452 [4] - 558:2, 558:3, 558:11, 678:11
2456 [4] - 564:5, 564:6, 564:11, 678:15
00:11 [1] - 507:1 2 2457 [5] - 564:22, 565:1, 565:13,
03/06/2014 [1] - 655:3 565:18, 678:17
2 [3] - 533:6, 615:21, 659:21 2458 [5] - 564:22, 565:1, 565:21, 678:17
1 20 [2] - 550:8, 662:3 2493 [3] - 569:22, 570:3, 678:21
20,100,000 [2] - 655:6, 655:15 25 [2] - 502:11, 673:21
1 [8] - 522:7, 533:5, 542:16, 582:16, 20001 [1] - 494:22 2509 [4] - 571:6, 571:7, 571:11, 678:23
582:19, 582:22, 589:21, 622:9 2013 [32] - 502:6, 503:3, 503:22, 507:1, 251 [6] - 547:3, 547:4, 547:7, 547:14,
1.2 [1] - 654:8 512:6, 515:7, 516:5, 527:14, 530:2, 552:17, 678:7
1/2 [1] - 629:24 533:11, 539:10, 548:19, 558:15, 2528 [3] - 576:20, 576:24, 679:3
10 [3] - 562:4, 655:16, 659:17 562:5, 563:14, 570:8, 571:15, 573:3, 2567 [6] - 579:7, 579:8, 579:11, 581:10,
100 [2] - 504:1, 665:9 575:17, 577:5, 578:20, 583:21, 581:13, 679:7
10019-6099 [1] - 495:4 612:16, 620:1, 621:19, 622:2, 622:12, 2568 [6] - 580:15, 580:19, 581:10,
107 [3] - 647:9, 647:18, 648:10 623:1, 623:8, 660:19, 662:24, 666:5 581:13, 581:18, 679:9
108 [1] - 647:9 2014 [27] - 555:13, 555:20, 614:10, 2568-A [4] - 581:23, 582:4, 582:8,
10:42 [1] - 503:3 619:1, 622:21, 628:20, 631:3, 631:11, 679:11
10:47 [1] - 571:15 632:22, 635:1, 635:22, 640:1, 641:9, 2568-B [3] - 581:24, 582:4, 679:11
SAM OCR RMR

Page 1 to 1 of 28 CRR RPR
2
2570 [3] - 583:12, 583:16, 679:13 3112 [3] - 623:10, 623:18, 680:9 506 [1] - 677:8
2573 [3] - 585:8, 585:12, 679:15 3123 [3] - 632:12, 632:16, 680:17 5083 [4] - 563:4, 563:5, 563:8, 678:13
2594 [4] - 586:2, 586:6, 586:17, 679:17 3125 [5] - 566:18, 566:19, 568:4, 568:5, 5092 [4] - 578:10, 578:11, 578:14, 679:5
2596 [1] - 613:23 678:19 51 [1] - 665:11
25th [1] - 555:12 3126 [4] - 651:8, 651:12, 651:16, 681:7 5101 [3] - 614:1, 614:7, 679:23
26 [1] - 508:13 3126-A [4] - 651:8, 651:12, 652:7, 681:7 511 [1] - 677:10
26th [1] - 653:22 3127 [7] - 597:14, 597:25, 599:7, 599:8, 5111 [4] - 623:22, 624:3, 626:18, 680:11
27 [1] - 551:3 662:6, 662:14, 681:12 5112 [6] - 597:19, 597:20, 598:7, 638:4,
271 [1] - 494:17 3129 [3] - 648:17, 648:21, 681:5 638:12, 680:23
2746 [3] - 615:15, 615:19, 679:25 3129-A [4] - 648:17, 648:21, 649:14, 514 [2] - 677:12, 677:14
2746A [4] - 617:18, 617:22, 618:3, 680:3 681:5 520 [1] - 677:17
2746B [4] - 617:18, 617:22, 618:6, 680:3 3132 [3] - 575:2, 575:7, 678:25 524 [1] - 677:19
2746C [4] - 617:18, 617:22, 618:9, 680:3 3145 [5] - 666:20, 666:25, 667:3, 667:4, 527 [1] - 677:21
2747 [4] - 618:13, 618:18, 622:19, 680:5 681:14 529 [1] - 677:23
2747A [5] - 618:13, 618:19, 619:18, 3145A [4] - 666:20, 666:25, 668:1, 533 [1] - 677:25
622:25, 680:7 681:14 539 [1] - 678:3
2761 [3] - 628:11, 628:15, 680:13 3154 [3] - 668:13, 668:17, 681:16 545 [1] - 678:5
2763 [3] - 630:17, 630:22, 680:15 3159A [5] - 671:21, 671:25, 673:7, 547 [1] - 678:7
2771 [3] - 636:16, 636:21, 680:21 673:8, 681:18 555 [1] - 678:9
2774 [5] - 639:13, 639:15, 639:19, 3160 [4] - 671:21, 671:25, 672:4, 681:18 558 [1] - 678:11
640:14, 680:25 3161 [5] - 671:21, 671:25, 673:16, 563 [1] - 678:13
2774-A [6] - 639:13, 639:15, 639:19, 673:17, 681:18 564 [1] - 678:15
641:2, 643:3, 680:25 3175 [1] - 607:10 565 [1] - 678:17
2774-B [5] - 640:18, 640:23, 642:8, 31st [3] - 502:6, 503:2, 507:1 568 [1] - 678:19
642:13, 681:3 32A [4] - 574:10, 574:12, 650:12, 652:17 570 [1] - 678:21
2783 [5] - 554:25, 555:1, 555:8, 555:11, 33 [1] - 537:24 571 [1] - 678:23
678:9 34 [1] - 500:25 575 [1] - 678:25
2783A [5] - 554:25, 555:1, 555:8, 35 [2] - 559:13, 560:10 576 [1] - 679:3
555:22, 678:9 350 [2] - 573:4, 573:6 578 [1] - 679:5
28 [2] - 607:10, 645:16 350-million-dollar [1] - 576:5 579 [1] - 679:7
28.1 [1] - 645:23 36 [3] - 510:10, 631:15, 632:3 58 [1] - 646:24
28.1(b [1] - 646:2 36.5 [1] - 510:5 580 [1] - 679:9
2843 [1] - 601:8 3rd [3] - 539:21, 541:1, 541:17 582 [1] - 679:11
2851 [1] - 602:23 583 [1] - 679:13
2876 [3] - 606:4, 606:11, 679:19 4 585 [1] - 679:15
2890 [1] - 606:12 586 [1] - 679:17
2:15 [1] - 589:21 4 [7] - 507:24, 508:5, 509:22, 556:25, 5:00 [3] - 656:10, 657:3, 657:21
2:44 [1] - 568:11 612:23, 629:24 5th [2] - 541:18, 542:24
2nd [3] - 512:6, 515:7, 601:18 403 [2] - 599:22, 604:22
404(b [4] - 600:21, 604:23, 604:25,
606:22
6
3
406,542,056.07 [1] - 649:8 6 [2] - 509:4, 612:25
3 [4] - 583:5, 588:21, 639:23, 645:2 44 [3] - 551:7, 551:10, 551:13 60 [1] - 646:4
30 [3] - 517:12, 517:16, 542:17 472 [1] - 504:1 600 [1] - 631:21
300,000 [2] - 508:16, 508:24 480 [1] - 510:9 606 [1] - 679:19
301 [4] - 642:19, 642:24, 644:10, 644:18 480M [1] - 509:5 612 [1] - 679:21
302 [3] - 642:19, 642:24, 652:23 485 [1] - 510:15 614 [1] - 679:23
3069 [3] - 634:16, 634:21, 680:19 49 [1] - 665:10 615 [1] - 679:25
3070 [4] - 653:10, 653:17, 654:18, 681:9 4th [2] - 527:14, 530:2 617 [1] - 680:3
3070-A [6] - 653:10, 653:17, 654:12, 618 [2] - 680:5, 680:7
654:23, 654:25, 681:9 5 623 [1] - 680:9
3070-B [3] - 653:10, 653:17, 681:9 624 [1] - 680:11
3070-C [2] - 653:18, 681:10 5 [2] - 508:14, 509:22
628 [1] - 680:13
3097 [1] - 603:15 50 [4] - 502:11, 664:24, 665:1, 665:7
630 [1] - 680:15
3098 [1] - 603:23 50/50 [1] - 664:23
632 [1] - 680:17
30th [1] - 539:10 500 [6] - 541:4, 542:13, 573:6, 632:2,
634 [1] - 680:19
3103 [1] - 607:16 632:4, 676:6
636 [1] - 680:21
3106 [1] - 608:16 500-million-dollar [1] - 576:5
638 [1] - 680:23
3111 [1] - 609:3 501 [1] - 677:4
639 [1] - 680:25
502 [1] - 677:6
SAM OCR RMR

3
640 [2] - 510:18, 681:3 619:17, 645:19, 655:1 628:14, 634:19, 653:13
648 [1] - 681:5 accounts [2] - 637:8, 654:22 admitting [2] - 604:1, 604:2
651 [1] - 681:7 acquire [1] - 666:9 advance [2] - 511:11, 595:8
653 [1] - 681:10 acquired [5] - 599:25, 658:12, 659:16, adversary [5] - 520:8, 612:6, 623:15,
662 [1] - 681:12 662:24, 666:10 623:25, 642:22
666 [1] - 681:14 acquisition [1] - 599:18 adverse [1] - 661:16
668 [1] - 681:16 acronym [3] - 521:20, 650:6, 665:4 advise [2] - 520:8, 545:8
671 [1] - 681:18 action [1] - 540:20 advised [1] - 593:4
6:44 [1] - 664:21 actively [1] - 602:9 advising [2] - 568:20, 569:13
6th [1] - 542:23 activities [2] - 617:3, 648:3 advisor [1] - 662:23
actual [2] - 513:20, 556:14 Advisors [11] - 638:20, 638:25, 639:7,
7 ADCB [1] - 654:8 647:19, 647:25, 648:6, 662:21,
add [1] - 510:10 662:22, 662:23, 663:2, 664:19
7 [6] - 509:19, 612:2, 612:12, 612:14, adding [2] - 509:5, 509:24 affected [1] - 568:25
641:24, 679:21 addition [2] - 543:1, 600:13 afford [2] - 662:2, 662:3
70 [1] - 661:11 additional [7] - 510:1, 510:3, 573:7, afraid [1] - 647:15
73 [1] - 645:23 594:2, 652:5, 659:25, 666:13 African [3] - 505:4, 505:7, 505:10
750 [4] - 541:4, 631:18, 631:25, 632:3 address [17] - 497:14, 510:23, 510:24, afternoon [8] - 594:4, 594:18, 596:5,
754 [2] - 510:16, 523:4 510:25, 511:1, 511:3, 525:22, 526:9, 596:12, 610:4, 610:11, 635:13, 635:17
77th [1] - 673:21 569:1, 596:7, 596:8, 596:17, 605:21, AFTERNOON [1] - 596:1
785,400,000 [2] - 522:19, 522:24 609:18, 626:22, 673:20, 675:4 AG [1] - 638:25
787 [1] - 495:3 addressed [1] - 601:11 agency [1] - 574:1
addresses [2] - 513:19, 600:11 agent [9] - 571:18, 573:12, 573:14,
8 addressing [2] - 590:17, 600:14 573:18, 573:20, 573:23, 574:2, 574:3
adequate [1] - 643:25 Agent [1] - 496:11
8 [2] - 510:6, 522:25 adjourn [2] - 675:4, 675:7 aggrandized [1] - 608:8
8.25 [2] - 541:5, 541:12 adjourned [1] - 675:17 ago [2] - 571:24, 653:4
800 [1] - 517:23 adjust [1] - 553:1 agree [1] - 662:1
825 [1] - 502:10 ADM [8] - 507:8, 507:9, 531:15, 531:24, agreed [6] - 552:1, 566:6, 569:8,
532:1, 532:7, 532:10, 569:7 570:18, 578:3, 611:25
9 admin [1] - 635:20 Agreement [1] - 559:14
administration [1] - 592:22 agreement [51] - 534:1, 550:14, 551:19,
9:00 [1] - 614:14 administrator [1] - 635:19 551:22, 552:1, 552:5, 552:8, 553:6,
9:30 [3] - 494:8, 674:15, 675:17 admissibility [2] - 602:13, 603:9 553:13, 553:19, 554:12, 556:10,
9th [3] - 628:20, 631:3, 640:1 admission [8] - 499:2, 511:18, 511:19, 556:14, 557:5, 558:18, 558:21,
514:4, 537:6, 599:12, 606:16, 608:18 559:10, 560:6, 560:7, 560:10, 591:4,
A admit [47] - 514:2, 514:12, 524:10, 596:19, 596:20, 610:20, 610:24,
529:19, 535:8, 545:3, 547:3, 554:24, 611:8, 611:10, 611:12, 611:18,
A-T-U-M [1] - 521:18 611:22, 612:17, 612:18, 613:11,
558:2, 563:4, 564:5, 564:22, 566:18,
a.m [4] - 494:8, 503:3, 674:15, 675:17 613:17, 619:6, 619:8, 619:9, 619:18,
569:22, 571:6, 575:2, 576:20, 578:10,
Abboud [6] - 571:22, 579:22, 585:19, 619:20, 619:21, 619:25, 620:2, 620:3,
579:7, 580:15, 581:23, 583:12, 585:8,
638:17, 648:12, 648:13 620:4, 622:5, 644:13, 644:16, 644:18,
586:2, 604:3, 604:4, 612:2, 615:15,
ability [1] - 501:11 646:2, 670:9
617:18, 618:13, 623:9, 628:11,
Able [1] - 552:17 630:17, 632:12, 634:16, 636:16, agreements [5] - 555:16, 611:7, 645:4,
able [11] - 508:22, 511:4, 511:6, 511:13, 638:4, 639:13, 640:17, 642:18, 645:7, 647:3
513:4, 527:21, 623:7, 625:4, 625:13, 648:17, 651:8, 653:10, 662:6, 666:20, Aguemon [2] - 579:22, 585:19
628:9, 636:3 671:21 ahead [27] - 497:3, 527:21, 529:1,
absence [1] - 656:18 admitted [49] - 501:24, 502:19, 506:19, 539:6, 552:12, 553:10, 554:3, 561:6,
absolute [1] - 674:10 511:22, 514:5, 514:7, 514:19, 520:13, 565:11, 577:21, 585:6, 589:6, 598:6,
Abu [20] - 507:10, 507:14, 517:21, 524:17, 527:6, 529:22, 533:2, 535:14, 600:5, 604:3, 606:10, 606:18, 607:9,
521:13, 522:3, 522:18, 531:20, 545:11, 547:6, 555:6, 558:9, 563:7, 608:15, 617:8, 630:9, 632:10, 645:11,
531:21, 563:23, 566:10, 569:12, 564:9, 564:25, 568:3, 569:25, 571:9, 648:8, 650:7, 661:14, 667:19
574:24, 577:10, 617:15, 618:8, 575:5, 576:23, 578:13, 579:10, ahold [1] - 636:7
619:13, 661:25, 665:5, 665:10, 665:17 580:18, 582:3, 583:15, 585:11, 586:5, aided [1] - 495:17
access [2] - 534:24, 644:2 612:9, 612:12, 615:18, 615:19, akin [1] - 650:1
accessible [1] - 563:13 617:21, 630:20, 636:19, 638:10, alert [1] - 608:5
according [1] - 646:1 639:18, 640:21, 648:20, 651:11, Allam [18] - 566:4, 575:14, 604:5,
account [15] - 563:24, 563:25, 564:2, 652:24, 662:13, 666:24, 668:16, 604:20, 605:13, 615:22, 616:3, 617:9,
566:6, 569:19, 571:18, 577:10, 671:24 619:1, 619:21, 621:9, 622:17, 640:3,
577:23, 616:19, 616:22, 617:1, 617:2, Admitted [6] - 618:16, 623:17, 624:2, 652:2, 653:24, 654:1, 654:15, 654:20
SAM OCR RMR

4
allegations [1] - 605:1 applicable [1] - 639:1 Attached [1] - 633:3

alleged [2] - 605:15, 607:20 application [1] - 616:18 attaches [1] - 521:5
Allen [1] - 600:5 applies [1] - 602:6 attaching [3] - 581:19, 654:20, 654:21
allow [3] - 508:21, 607:8, 625:4 apply [3] - 551:2, 591:12, 592:2 attachment [1] - 652:10
allowed [5] - 528:24, 591:21, 592:12, appoint [1] - 531:21 Attachment [1] - 654:23
607:25, 665:9 appointed [3] - 507:8, 531:19, 532:10 attention [3] - 527:11, 559:13, 629:6
allows [3] - 559:11, 560:8, 591:8 appreciate [6] - 498:7, 577:13, 577:25, Attorney [1] - 494:16
almost [1] - 658:18 592:8, 610:5, 657:14 Attorneys [1] - 494:19
alongside [1] - 648:2 appropriate [7] - 525:12, 562:16, 589:3, attract [1] - 559:13
alters [1] - 592:17 592:2, 592:25, 593:2, 626:1 Atum [1] - 521:13
amendment [1] - 592:19 approval [2] - 516:22, 562:13 auditor [2] - 604:24, 605:2
AMERICA [1] - 494:3 approvals /permissions [1] - 643:22 August [10] - 512:6, 515:7, 524:5,
America [1] - 646:5 approved [2] - 522:1, 529:4 527:14, 530:2, 533:11, 539:10,
Americas [4] - 646:4, 650:11, 650:13, approximate [2] - 516:8, 659:14 542:17, 582:11, 590:16
652:16 April [4] - 628:20, 631:3, 631:11, 632:22 authored [6] - 598:17, 598:18, 599:13,
amount [18] - 500:22, 500:25, 543:6, Arab [2] - 566:1, 616:5 601:11, 602:17, 605:17
548:1, 569:16, 570:18, 570:25, 571:2, Arabic [2] - 539:19, 543:19 authorities [1] - 644:2
576:3, 576:13, 627:14, 649:7, 649:10, Archives [1] - 566:12 authority [1] - 643:25
655:6, 655:8, 655:10, 655:11, 660:10 area [4] - 659:4, 671:12, 673:25 authorization [1] - 613:19
amounts [6] - 501:14, 537:22, 611:25, areas [1] - 512:22 available [2] - 570:24, 594:14
654:10, 659:14, 661:23 argument [2] - 608:24 Avenue [2] - 494:22, 495:3
ANDREW [1] - 676:5 arguments [1] - 660:22 avoid [3] - 559:14, 627:18, 633:25
Andrew [6] - 532:14, 604:6, 605:12, Armando [8] - 518:6, 518:9, 531:12, awarded [2] - 501:8, 503:10
615:23, 619:5, 638:24 587:2, 587:15, 587:23, 588:8, 588:10 awarding [1] - 505:11
Andy [1] - 579:24 Arnal [4] - 638:17, 638:21, 638:23, aware [21] - 500:23, 503:9, 511:12,
angel [1] - 543:21 639:5 513:3, 518:18, 519:11, 523:19,
Angeles [1] - 583:10 Arnold [1] - 598:13 523:22, 523:24, 529:2, 529:9, 529:11,
angle [2] - 586:18, 587:1 arrange [1] - 578:2 530:25, 544:6, 549:12, 626:15,
Angola [1] - 606:21 arrangement [5] - 611:25, 612:15, 626:16, 656:5, 660:8, 670:1
Annexes [1] - 640:5 612:20, 612:24, 612:25 aww [1] - 532:14
announce [1] - 541:11 arrangements [1] - 611:22 Azerbaijan [3] - 619:24, 620:7, 620:25
annual [1] - 616:20 arranger [6] - 611:17, 611:19, 611:24,
answer [13] - 518:1, 529:1, 531:1, 647:24, 648:1, 648:2 B
531:2, 532:9, 534:22, 560:18, 585:5, arrangers [3] - 628:7, 647:20, 647:22
615:8, 636:3, 670:23, 670:25, 671:1 arranging [1] - 669:15 B-U-G-G-E-N-H-A-G-E-N [1] - 664:4
answering [1] - 519:7 arrive [6] - 510:1, 510:11, 510:16, backdated [2] - 622:22, 622:23
answers [3] - 513:5, 525:5, 531:15 510:17, 515:17, 654:8 background [2] - 503:8, 515:15
ant [1] - 531:14 arrived [1] - 509:10 bank [46] - 519:14, 533:21, 533:22,
anti [2] - 554:19, 639:1 article [7] - 559:11, 559:13, 560:7, 533:25, 534:7, 534:9, 534:16, 534:18,
anti-bribery [1] - 639:1 560:10, 584:8, 609:8, 631:14 534:24, 541:9, 541:22, 541:24, 542:8,
anti-corruption [1] - 554:19 articles [1] - 617:11 542:9, 542:13, 546:8, 563:25, 566:6,
Antonio [30] - 517:14, 517:18, 518:13, aside [1] - 592:14 571:1, 571:3, 577:11, 611:10, 611:17,
518:25, 519:3, 519:5, 519:7, 519:17, asserted [4] - 601:23, 602:1, 604:10, 611:20, 615:23, 616:1, 616:5, 616:11,
524:23, 525:2, 525:8, 528:15, 530:6, 605:19 616:16, 616:18, 616:19, 616:22,
530:11, 530:13, 530:24, 530:25, assets [4] - 522:1, 522:6, 658:14, 617:1, 617:5, 617:15, 618:25, 619:7,
531:15, 532:14, 532:19, 556:15, 658:16 619:12, 624:9, 626:25, 645:19, 650:1,
558:17, 588:20, 635:7, 635:24, assist [2] - 513:4, 566:6 650:2, 654:16, 654:22
640:16, 641:3, 641:7, 642:4, 647:14 assistance [1] - 557:1 Bank [15] - 563:24, 571:21, 571:23,
apologies [1] - 619:16 Assistant [1] - 494:19 580:5, 617:16, 619:13, 624:10, 646:3,
apologize [7] - 537:10, 537:16, 547:12, 650:11, 650:13, 650:25, 651:22,
Association [2] - 553:24, 618:10
561:7, 567:5, 594:15, 635:15 652:16, 654:22, 669:14
association [2] - 661:17, 661:18
appear [5] - 510:13, 622:22, 627:23, banker [4] - 504:6, 504:7, 571:24,
assume [3] - 537:21, 537:22, 543:19
666:2, 666:4 571:25
assumed [1] - 627:1
appearance [1] - 595:3 banks [12] - 501:14, 533:22, 534:5,
assuming [1] - 598:17
appearances [3] - 496:7, 596:6, 657:1 534:8, 573:19, 581:1, 585:22, 632:1,
assure [2] - 594:24, 610:10
appeared [2] - 560:3, 666:3 632:6, 649:18, 650:1
attach [3] - 582:15, 617:9, 617:13
appearing [1] - 665:25 banks' [1] - 573:16
attached [10] - 521:8, 551:16, 555:18,
appended [1] - 551:16 Barakova [6] - 512:19, 521:5, 558:16,
556:10, 582:12, 605:10, 617:10,
appetite [2] - 540:11, 540:13 635:3, 637:11, 637:16
619:11, 649:6
based [7] - 523:3, 553:20, 632:2,
SAM OCR RMR

5
659:15, 662:23, 663:17, 665:10 537:18, 537:20, 539:4, 542:18, 545:2, 671:20, 673:7, 673:16, 674:8, 675:6,
basis [3] - 607:8, 609:13, 609:14 545:12, 545:15, 545:21, 545:24, 675:9, 675:11, 676:6
BCP [1] - 669:6 547:2, 547:9, 547:10, 547:12, 547:13, birthday [3] - 542:23, 543:2, 543:21
became [1] - 661:18 548:10, 548:16, 550:9, 550:13, bit [4] - 553:2, 560:18, 563:13, 655:5
become [9] - 603:11, 624:14, 659:8, 550:23, 550:25, 551:9, 551:12, Black [1] - 590:21
665:25, 666:2, 666:4, 666:7, 669:24, 552:16, 552:25, 553:6, 553:11, Bloomberg [1] - 559:5
670:3 553:12, 554:4, 554:24, 555:10, blow [11] - 515:3, 524:21, 531:23,
becomes [2] - 541:21 555:25, 556:2, 557:15, 557:18, 550:12, 565:15, 574:11, 574:13,
BEFORE [1] - 494:12 557:20, 558:1, 558:10, 558:13, 582:19, 620:9, 647:12, 647:20
began [1] - 624:6 558:21, 558:22, 562:21, 563:3, blurry [1] - 563:12
beginning [2] - 556:3, 671:3 563:10, 563:15, 563:18, 563:20, BNP [2] - 548:13, 549:16
behalf [19] - 496:18, 496:23, 497:5, 564:4, 564:10, 564:13, 564:21, 565:4, board [1] - 635:19
497:8, 497:11, 556:16, 556:17, 565:12, 565:14, 565:17, 566:17, boat [2] - 505:1, 505:23
556:18, 559:12, 560:9, 562:12, 567:4, 568:7, 568:9, 569:21, 570:2, boats [8] - 501:6, 503:11, 509:15, 522:2,
573:16, 576:18, 642:3, 642:5, 647:10, 570:5, 571:5, 571:13, 573:2, 574:11, 622:8, 622:10, 625:7, 627:2
648:10, 653:7, 665:12 574:14, 575:1, 575:6, 575:9, 575:12, bond [55] - 503:21, 506:5, 534:2, 534:3,
behave [2] - 637:12, 637:17 576:19, 577:2, 577:22, 578:9, 578:17, 534:5, 535:6, 539:21, 540:2, 540:22,
behind [5] - 528:21, 529:3, 532:21, 578:18, 579:6, 579:14, 580:14, 540:23, 540:24, 541:7, 541:11,
548:24, 549:2 580:22, 581:9, 581:12, 581:23, 582:7, 541:14, 541:20, 541:23, 542:3, 542:5,
Beijos [1] - 588:21 582:19, 582:21, 583:11, 583:19, 542:6, 542:8, 542:9, 542:11, 542:14,
belief [3] - 576:10, 660:3, 660:4 585:7, 585:15, 586:1, 586:9, 586:21, 543:3, 545:18, 546:10, 546:16,
587:9, 589:5, 589:8, 589:9, 589:18, 546:18, 546:19, 546:25, 547:1,
below [4] - 512:16, 550:22, 604:5,
590:10, 595:13, 596:11, 596:14, 547:17, 547:20, 548:1, 548:2, 549:24,
655:10
596:18, 596:25, 597:6, 597:10, 550:19, 550:20, 559:3, 559:19, 560:4,
benchmark [1] - 504:16
597:19, 598:7, 598:10, 598:12, 599:7, 560:8, 560:21, 561:9, 561:17, 561:18,
beneficial [1] - 546:12
599:9, 599:24, 600:6, 601:1, 601:4, 562:12, 568:20, 573:14, 573:15,
beneficiary [3] - 651:3, 651:5, 652:19
601:8, 601:14, 601:17, 601:24, 602:2, 573:22, 574:1, 575:21, 576:5
benefit [2] - 576:14, 605:23
602:5, 602:20, 602:23, 603:1, 603:4, Bond [2] - 539:12, 546:1
benefited [1] - 501:3
603:6, 603:13, 603:15, 603:17, bondholders [3] - 573:16, 573:17,
benefiting [1] - 500:15
603:21, 603:23, 603:25, 604:4, 573:21
Berliner [15] - 571:15, 571:20, 573:9,
604:11, 604:15, 605:6, 605:12, 606:2,
573:24, 574:7, 579:21, 579:23, 580:1, bonds [16] - 533:16, 533:17, 533:19,
606:4, 606:12, 606:14, 606:25, 607:3,
580:25, 581:20, 585:18, 648:25, 533:21, 533:23, 540:9, 546:9, 546:14,
607:7, 607:10, 607:14, 607:16,
649:4, 651:21 546:22, 549:17, 550:5, 550:17, 552:4,
607:22, 608:16, 609:3, 609:16,
best [6] - 516:9, 543:15, 554:11, 592:4, 573:5, 628:8
609:19, 610:17, 610:18, 610:22,
624:12, 674:10 book [1] - 541:23
611:1, 611:14, 612:1, 612:11, 612:23,
better [3] - 534:24, 559:8, 664:24 borrow [2] - 614:20, 615:4
613:21, 613:25, 615:14, 617:17,
between [20] - 539:8, 541:11, 541:22, borrowed [3] - 551:2, 571:2, 650:17
618:2, 618:12, 618:21, 620:8, 620:11,
551:5, 551:20, 552:1, 556:8, 561:17, borrower [9] - 502:11, 503:5, 550:10,
623:9, 623:19, 623:22, 624:5, 624:19,
570:19, 571:2, 607:23, 612:15, 619:6, 573:19, 573:24, 574:5, 574:22,
624:21, 625:1, 628:10, 628:17,
619:21, 624:14, 628:3, 633:22, 641:4, 611:24, 614:24
628:23, 628:25, 629:8, 629:10,
649:18, 650:1 borrowers [2] - 554:20, 614:17
630:10, 630:16, 630:24, 632:11,
big [4] - 539:23, 540:3, 540:5, 632:7 borrowing [4] - 570:18, 570:19, 570:25,
632:18, 632:20, 634:5, 634:15,
bigger [4] - 500:15, 500:16, 501:15, 615:11
634:23, 636:15, 636:20, 636:23,
523:2 bottom [24] - 502:4, 515:1, 522:7,
637:3, 637:5, 638:2, 638:3, 638:11,
biggest [1] - 616:11 523:13, 529:25, 533:5, 535:19, 538:2,
638:15, 639:12, 639:15, 639:22,
binder [1] - 567:5 548:4, 548:11, 551:10, 568:11, 577:3,
639:24, 640:6, 640:7, 640:10, 640:17,
Bini [8] - 496:9, 535:21, 591:2, 600:14, 581:1, 605:12, 614:12, 618:22,
640:22, 641:1, 641:14, 641:16, 642:7,
600:15, 605:2, 605:3, 605:4 630:25, 631:2, 632:18, 634:24, 654:4,
642:10, 642:12, 642:17, 642:24,
BINI [336] - 494:18, 496:9, 497:16, 663:7, 664:7
643:2, 643:5, 643:7, 643:9, 644:9,
497:24, 498:25, 500:6, 501:20, 502:3, bought [4] - 541:14, 546:15, 580:3,
644:12, 645:12, 645:23, 645:25,
502:14, 502:20, 502:24, 504:10, 663:19
646:15, 646:18, 646:20, 646:24,
504:11, 506:13, 506:23, 511:15, 646:25, 647:12, 647:16, 647:20, BOUSTANI [1] - 494:8
511:23, 512:2, 513:8, 513:10, 513:15, 647:21, 648:9, 648:16, 648:23, 650:8, Boustani [61] - 496:6, 496:19, 496:23,
513:17, 514:1, 514:8, 514:11, 514:20, 650:9, 650:21, 650:23, 651:7, 651:15, 496:25, 497:5, 497:8, 497:11, 500:21,
514:24, 515:3, 515:5, 519:19, 520:3, 652:7, 652:9, 652:22, 653:2, 653:9, 501:2, 502:8, 502:13, 503:3, 507:5,
520:10, 521:2, 522:20, 523:2, 524:9, 653:16, 653:20, 654:4, 654:6, 654:12, 512:8, 515:9, 515:24, 516:11, 519:5,
524:19, 524:21, 525:12, 525:24, 654:14, 654:18, 655:4, 655:7, 656:2, 521:4, 524:24, 529:16, 530:4, 532:5,
526:11, 526:15, 527:2, 527:9, 529:18, 656:7, 658:2, 658:3, 662:5, 662:16, 533:8, 538:5, 539:9, 543:12, 557:4,
529:23, 531:22, 532:12, 532:22, 663:7, 666:19, 667:3, 667:5, 667:15, 558:16, 560:24, 560:25, 562:3, 562:4,
533:3, 535:8, 535:16, 537:3, 537:5, 667:18, 668:1, 668:12, 670:16, 562:17, 562:20, 568:23, 569:4,
SAM OCR RMR

6
575:14, 577:7, 578:2, 578:22, 579:22, 634:5, 634:23, 636:23, 637:5, 638:2, 517:19, 519:17, 525:3
585:19, 604:6, 606:16, 607:18, 638:15, 639:24, 640:7, 641:1, 641:14, chance [1] - 531:14
607:23, 608:25, 621:20, 629:7, 633:1, 642:12, 643:9, 644:12, 645:12, Chang [8] - 531:11, 543:24, 544:5,
635:25, 640:3, 640:13, 642:6, 652:2, 645:25, 646:20, 646:25, 647:16, 544:7, 544:12, 588:13, 588:18, 653:8
656:4, 656:5, 662:19, 668:21, 671:3 647:21, 648:9, 648:23, 650:9, 650:23, change [2] - 617:6, 672:24
Boustani's [3] - 538:2, 598:20, 608:2 651:15, 652:9, 653:2, 653:20, 654:6, changed [3] - 570:23, 616:12, 617:5
BR71 [3] - 620:7, 620:21, 622:11 654:14, 655:7, 656:2, 658:3, 676:6 changes [1] - 646:22
breach [1] - 562:15 changing [1] - 670:11
break [10] - 525:13, 525:15, 526:3, C characterize [1] - 621:22
610:14, 653:15, 656:8, 656:10, characterizes [1] - 629:9
656:11, 657:23 Cadman [1] - 494:17 charge [4] - 549:23, 591:13, 635:20,
breakdown [2] - 579:24, 630:14 calculate [1] - 576:2 663:1
Brexit [1] - 657:12 calculated [1] - 575:20 charged [2] - 590:23, 591:11
bribery [2] - 639:1, 639:8 calculation [5] - 510:8, 523:3, 523:5, charges [1] - 600:20
bribes [3] - 554:20, 557:13, 644:6 523:7, 575:24 cheapest [1] - 503:18
briefed [1] - 525:8 callback [1] - 635:10 Chiarella [1] - 590:21
briefing [1] - 525:1 cannot [2] - 532:15, 647:15 chief [1] - 663:20
briefly [1] - 590:6 Canyon [4] - 582:25, 583:2, 583:9, children [1] - 577:20
bring [4] - 497:20, 526:10, 595:5, 585:24 choice [1] - 503:16
657:12 capable [1] - 624:24 choose [2] - 503:16, 504:8
British [1] - 569:3 capacity [1] - 525:2 Chopstick [3] - 543:22, 543:23, 588:11
bro [2] - 543:21, 665:16 Capital [14] - 638:20, 638:25, 639:3, chosen [2] - 506:9, 507:14
Bro [5] - 505:16, 562:6, 570:10, 577:9, 639:7, 647:19, 647:25, 648:6, 650:19, Chris [5] - 549:21, 549:22, 568:13,
632:10 652:14, 662:21, 662:22, 662:23,
568:22, 569:2
broad [1] - 507:15 663:1, 664:19
Cicely [1] - 648:12
Brooklyn [2] - 494:6, 494:18 capital [2] - 549:20, 549:24
Circuit [3] - 592:11, 592:15, 592:25
brought [1] - 609:23 cards [1] - 615:25
circular [12] - 547:16, 547:18, 548:18,
Buggenhagen [3] - 663:22, 663:25, case [29] - 503:15, 525:16, 534:11,
549:13, 550:8, 550:10, 550:16, 551:8,
664:3 537:21, 541:25, 542:6, 586:14,
551:14, 551:17, 552:5, 556:11
build [9] - 508:9, 508:22, 510:2, 525:10, 589:22, 590:13, 590:16, 590:18,
circulars [1] - 552:7
614:18, 625:3, 625:4, 625:19, 626:24 590:19, 590:22, 590:23, 591:8,
Citi [2] - 573:10, 573:11
building [4] - 501:5, 508:6, 509:14, 591:13, 591:19, 591:25, 592:18,
Citi's [1] - 571:18
509:23 598:22, 599:20, 600:18, 601:3, 602:3,
Citi.com [1] - 558:16
built [6] - 509:20, 625:22, 625:23, 627:2, 606:22, 607:2, 608:22, 656:11, 674:12
Citibank [3] - 574:1, 574:8, 574:18
627:4, 631:15 cases [1] - 498:9
City [5] - 645:18, 671:11, 671:12,
burn [1] - 662:1 CASEY [1] - 495:5
671:17, 673:25
business [12] - 510:1, 525:11, 542:3, Casey [1] - 497:5
civil [1] - 643:17
576:15, 625:10, 625:17, 626:3, 628:8, CAUSE [1] - 494:11
clarification [1] - 559:9
632:3, 633:24, 636:5, 648:4 CCR [1] - 495:15
clarify [1] - 560:6
busy [1] - 657:8 ceding [1] - 576:14
clause [14] - 554:13, 554:17, 554:18,
buy [6] - 542:5, 546:22, 551:3, 574:1, ceiling [4] - 570:17, 570:21, 571:2
611:4, 611:15, 611:16, 612:18,
625:22, 625:23 celebrate [1] - 543:1
644:24, 645:5, 646:11, 646:21, 647:2,
buyers [2] - 546:19 celebration [3] - 542:25, 543:4, 543:14
670:10
buying [3] - 535:4, 542:7, 659:12 celing [1] - 570:11
Clause [3] - 645:13, 645:16, 645:23
BV [1] - 664:24 center [3] - 551:3, 555:24, 627:15
clauses [7] - 553:16, 553:18, 611:3,
BY [102] - 494:18, 494:23, 495:4, 500:6, central [1] - 659:17
644:22, 645:3, 670:8
502:3, 502:24, 504:11, 506:23, 512:2, CEO [1] - 663:20 clear [12] - 514:2, 519:14, 561:12,
513:10, 513:17, 514:24, 515:5, 521:2, certain [10] - 534:10, 584:22, 588:2, 590:21, 591:6, 592:15, 594:15,
527:9, 532:3, 545:15, 545:24, 547:10, 596:19, 596:20, 627:2, 634:9, 654:15, 600:10, 625:15, 625:16, 629:25,
547:13, 548:16, 550:13, 550:25, 654:20, 659:4 672:21
551:12, 553:12, 554:4, 555:10, 556:2, certificate [2] - 618:4, 643:25 Clear [1] - 561:24
557:20, 558:13, 558:22, 563:10, certification [1] - 641:7 cleared [1] - 571:17
563:15, 563:20, 564:13, 565:4, cetera [5] - 614:22, 629:19, 629:20, clearly [1] - 553:3
565:12, 565:17, 568:9, 570:5, 571:13, 633:11, 633:20 CLERK [1] - 563:1
573:2, 574:14, 575:12, 577:2, 577:22, chain [15] - 515:19, 563:11, 564:14, clerk [1] - 566:12
578:18, 579:14, 580:22, 581:12, 573:24, 581:15, 587:5, 605:5, 605:8,
click [1] - 498:3
582:7, 582:21, 583:19, 585:15, 586:9, 618:23, 635:23, 651:16, 651:18,
clients [1] - 549:17
586:21, 589:9, 618:2, 618:21, 620:11, 651:21, 671:4
CLO [2] - 583:5, 583:6
624:5, 624:19, 625:1, 628:17, 628:25, chair [1] - 498:21
clock [1] - 610:12
629:10, 630:10, 630:24, 632:20, chairman [6] - 517:11, 517:15, 517:16,
SAM OCR RMR

7
close [5] - 541:18, 542:3, 577:19, Computer-aided [1] - 495:17 611:2

592:10, 611:8 computerized [1] - 495:17 Contents [4] - 644:21, 645:5, 646:13,
closed [3] - 540:19, 621:20, 659:24 concept [1] - 501:10 646:15
closer [3] - 526:20, 527:19, 645:9 concern [7] - 506:9, 559:1, 560:2, contesting [1] - 599:13
closes [3] - 541:23, 542:5, 542:9 584:8, 584:12, 584:16, 670:1 context [4] - 516:23, 534:6, 615:7,
closing [2] - 543:3, 543:6 concerned [6] - 528:19, 528:20, 532:18, 659:6
co [5] - 557:18, 602:6, 603:10, 605:15, 532:19, 616:17, 616:18 continue [8] - 498:24, 526:25, 529:1,
660:23 concerns [2] - 592:4, 605:21 610:10, 610:16, 658:1, 664:6, 668:4
co-conspirator [2] - 602:6, 603:10 concession [5] - 600:7, 659:1, 659:2, Continued [11] - 495:1, 499:5, 520:19,
co-conspirators [1] - 605:15 659:5 538:10, 544:15, 572:3, 593:9, 617:25,
co-counsel [1] - 557:18 concessions [2] - 658:17, 663:20 637:22, 655:19, 674:22
co-invested [1] - 660:23 concluded [2] - 538:9, 567:10 continued [1] - 526:24
colleagues [1] - 557:16 condition [1] - 534:6 CONTINUING [3] - 500:5, 573:1, 638:1
collectively [2] - 661:6, 661:9 conditions [3] - 620:8, 620:16, 661:22 continuing [4] - 521:2, 590:24, 656:2,
comfortable [1] - 504:15 Conditions [1] - 620:9 671:18
coming [4] - 592:10, 603:20, 604:21, conduct [3] - 569:8, 587:25, 658:24 Continuing [4] - 545:1, 594:1, 618:1,
607:12 conducting [1] - 603:11 675:1
commented [1] - 507:20 confer [1] - 557:15 Contract [2] - 632:24, 640:5
Comments [2] - 632:24, 633:6 conference [3] - 590:13, 590:16, 591:14 contract [41] - 500:16, 501:7, 503:11,
comments [2] - 507:4, 507:23 conferred [1] - 594:16 505:11, 508:20, 517:11, 517:16,
commercial [3] - 570:19, 577:11, 618:7 confers [1] - 557:18 517:20, 517:25, 521:6, 521:10,
Commercial [3] - 563:24, 617:16, confidentiality [3] - 669:18, 670:6, 521:12, 521:21, 522:5, 522:12,
619:13 670:15 522:21, 522:23, 523:8, 523:20,
committed [1] - 542:5 confirm [4] - 531:14, 573:10, 637:9, 523:23, 542:10, 543:8, 551:5, 562:15,
common [1] - 533:22 639:6 614:22, 621:10, 621:16, 622:16,
communicated [1] - 584:20 confirmation [5] - 546:3, 573:11, 622:22, 627:24, 632:4, 633:6, 634:9,
community [1] - 541:11 638:25, 649:17 634:14, 641:4, 641:10, 641:20,
companies [3] - 503:14, 534:10, 569:3 confirmed [3] - 530:7, 541:9, 639:10 641:22, 641:25, 642:15, 643:10
company [28] - 500:14, 500:20, 501:5, conflict [1] - 634:1 contracted [1] - 622:13
521:7, 534:1, 552:22, 561:11, 605:7, conformed [1] - 636:8 contractor [16] - 501:3, 501:4, 501:8,
658:9, 658:12, 658:14, 658:19, confusion [1] - 599:23 501:16, 503:25, 504:3, 504:5, 506:11,
660:13, 660:15, 661:1, 661:8, 661:9, connected [1] - 643:15 507:8, 507:10, 507:11, 509:21,
661:15, 661:19, 661:20, 661:24, 562:17, 643:14, 643:21, 644:5
connection [1] - 607:2
662:1, 663:14, 663:17, 665:4, 665:10, contracts [3] - 528:25, 627:7, 633:14
consequence [1] - 598:22
665:22 contrary [1] - 595:3
consequently [2] - 501:2, 542:8
Company [5] - 606:20, 646:4, 650:11, control [3] - 529:17, 607:22, 637:18
consider [1] - 504:4
650:13, 652:16 controlled [1] - 665:17
considerable [1] - 661:23
comparisons [1] - 503:6 conversation [4] - 530:13, 622:1, 622:3,
considered [1] - 534:4
compensated [2] - 576:9, 576:10 662:4
considering [3] - 503:21, 506:5, 580:6
compensating [1] - 608:21 conversations [3] - 565:24, 630:1,
consistency [1] - 628:3
competitive [3] - 503:11, 503:13, 659:15
consistent [3] - 616:13, 622:1, 633:11
531:21 convey [2] - 511:4, 519:10
conspirator [2] - 602:6, 603:10
competitor [1] - 505:21 conveying [1] - 524:2
conspirators [1] - 605:15
complaining [1] - 559:17 convicted [1] - 609:5
constitute [1] - 592:18
complaint [2] - 562:11, 562:19 COO [1] - 638:20
constitutional [1] - 617:10
complete [1] - 641:8 copied [1] - 537:24
constraints [1] - 559:14
completed [1] - 517:10 copies [1] - 654:21
construction [2] - 510:10, 641:22
completely [1] - 606:21 copy [22] - 520:3, 520:5, 520:7, 551:19,
constructive [1] - 592:18
complex [1] - 607:5 555:15, 556:7, 556:10, 563:22,
consultancy [3] - 619:23, 620:5, 622:5
compliance [4] - 554:14, 554:16, 564:19, 565:19, 565:22, 567:4, 574:8,
consulting [5] - 617:11, 619:21, 620:23,
554:19, 645:14 582:9, 597:10, 611:21, 612:15, 618:7,
620:25, 622:6
complicated [1] - 670:10 651:22, 654:16, 668:2, 673:9
Consulting [3] - 618:8, 618:11, 665:3
complied [1] - 638:25 copying [7] - 524:24, 533:8, 604:6,
consumers [1] - 546:17
619:5, 638:17, 652:2, 653:24
Complies [1] - 555:25 Cont'd [5] - 676:6, 678:1, 679:1, 680:1,
core [1] - 592:17
comply [1] - 608:10 681:1
corporate [1] - 521:6
component [1] - 630:2 contacted [5] - 503:6, 505:4, 505:7,
correct [8] - 510:13, 510:16, 519:6,
components [3] - 627:16, 629:20, 505:10, 584:5
540:15, 560:14, 604:10, 624:18, 641:8
630:14 contained [2] - 645:5, 645:6
corrected [1] - 646:9
Computer [1] - 495:17 contents [4] - 552:9, 553:16, 601:13,
correctly [2] - 643:11, 652:5
SAM OCR RMR

8
corresponding [1] - 645:19 597:22, 598:4, 598:6, 598:8, 598:11, 519:10, 523:22, 523:24, 524:5, 525:3,
corruption [3] - 554:19, 639:1, 639:8 598:14, 598:23, 599:4, 599:8, 599:10, 528:6, 528:10, 528:16, 528:20,
cost [19] - 508:1, 508:3, 508:6, 508:8, 599:21, 600:4, 600:8, 600:23, 601:2, 528:25, 529:2, 529:7, 529:9, 531:3,
508:16, 508:18, 509:5, 509:7, 509:8, 601:5, 601:9, 601:15, 601:18, 601:22, 532:11, 532:15, 532:20, 533:15,
509:11, 509:13, 509:22, 510:1, 510:2, 601:25, 602:3, 602:11, 602:21, 534:11, 534:24, 534:25, 535:1, 540:6,
510:9, 510:11, 522:17, 627:14 602:24, 603:2, 603:5, 603:8, 603:14, 541:9, 542:6, 548:13, 548:20, 548:25,
costs [2] - 509:7, 509:24 603:16, 603:19, 603:22, 603:24, 549:1, 549:10, 549:16, 549:18,
Cough [1] - 552:10 604:2, 604:8, 604:13, 604:16, 605:3, 549:23, 551:20, 552:2, 552:3, 556:8,
cough [1] - 657:17 605:9, 605:14, 606:3, 606:5, 606:9, 556:18, 557:1, 557:22, 562:10,
counsel [16] - 496:7, 498:24, 520:5, 606:13, 606:15, 606:18, 606:23, 562:11, 562:14, 566:16, 573:6,
545:6, 545:7, 555:24, 557:18, 567:2, 607:1, 607:6, 607:8, 607:11, 607:15, 573:12, 574:2, 574:4, 574:9, 574:19,
590:11, 592:1, 594:7, 596:6, 597:13, 607:17, 607:21, 607:24, 608:4, 574:21, 580:8, 580:10, 582:10, 583:5,
598:15, 623:15, 667:19 608:15, 608:17, 608:23, 609:2, 609:4, 584:2, 584:4, 584:6, 584:11, 584:14,
Counsel [2] - 545:20, 567:3 609:10, 609:13, 609:18, 609:20, 612:16, 612:21, 612:24, 613:4,
country [1] - 559:6 609:22, 609:25, 610:2, 610:4, 612:3, 613:18, 635:5, 635:10, 636:25, 637:8,
couple [2] - 503:5, 610:19 612:5, 612:9, 613:24, 614:2, 614:4, 637:15, 671:9, 672:14, 672:24
course [10] - 521:16, 557:17, 587:25, 614:6, 615:6, 615:16, 615:18, 617:4, creditors [1] - 636:4
592:7, 592:22, 624:22, 627:15, 617:8, 617:19, 617:21, 618:14, crime [1] - 617:3
658:24, 659:19, 666:15 618:16, 623:11, 623:14, 623:17, criminal [7] - 584:9, 584:17, 587:25,
Court [16] - 495:15, 495:16, 502:15, 623:21, 623:24, 624:2, 624:22, 658:21, 658:24, 659:7, 666:1
520:9, 531:18, 545:8, 561:4, 590:15, 628:12, 628:14, 629:5, 629:9, 630:5, Criminal [1] - 496:5
590:17, 591:7, 592:8, 592:21, 593:1, 630:7, 630:9, 630:18, 630:20, 632:13, CRIMINAL [2] - 494:11, 494:21
593:2, 599:16, 610:7 632:15, 634:4, 634:17, 634:19, criminality [1] - 592:17
COURT [349] - 494:1, 496:14, 496:21, 635:14, 636:17, 636:19, 638:5, 638:8, Croc [1] - 587:14
496:24, 497:3, 497:6, 497:9, 497:12, 638:10, 639:14, 639:16, 639:18, croco [1] - 518:10
497:17, 497:20, 497:25, 498:2, 498:6, 640:19, 640:21, 642:20, 642:22, Croco [4] - 587:21, 587:22, 587:23,
498:17, 498:23, 501:22, 501:24, 643:1, 643:4, 643:6, 645:8, 648:5, 588:7
502:17, 502:19, 506:17, 506:19, 648:7, 648:18, 648:20, 649:21, crocodile [1] - 518:10
511:19, 511:22, 514:5, 514:7, 514:13, 649:23, 650:3, 650:6, 651:9, 651:11, crocodiling [3] - 517:12, 518:4, 518:8
514:16, 514:19, 519:23, 519:25, 652:25, 653:11, 653:13, 656:9, Crocodilio [1] - 587:23
520:4, 520:7, 520:13, 521:14, 524:12, 656:13, 656:15, 656:19, 656:21, crocodilo [1] - 518:10
524:15, 524:17, 525:14, 525:19, 656:25, 657:6, 657:10, 657:16,
cross [6] - 591:21, 598:16, 598:24,
525:25, 526:2, 526:7, 526:13, 526:16, 657:25, 660:3, 661:10, 661:12,
600:10, 628:9, 634:1
526:19, 526:23, 527:4, 527:6, 527:19, 661:14, 662:7, 662:10, 662:13,
cross-examine [3] - 591:21, 598:16,
529:1, 529:20, 529:22, 532:25, 533:2, 662:15, 663:24, 664:1, 664:5, 666:22,
598:24
534:20, 534:22, 535:10, 535:14, 666:24, 667:2, 667:14, 667:17,
cross-reference [1] - 628:9
667:19, 668:14, 668:16, 668:18,
535:22, 536:3, 537:2, 537:4, 537:6, cross-referencing [1] - 634:1
537:12, 537:14, 537:19, 537:21, 671:22, 671:24, 672:2, 673:24,
CRR [1] - 495:15
538:4, 538:8, 539:2, 539:5, 545:4, 674:10, 674:19, 675:1, 675:7, 675:10,
CS [5] - 504:14, 523:11, 523:16, 533:18,
545:6, 545:11, 545:19, 545:22, 547:4, 675:13
539:21
547:6, 548:8, 548:13, 552:10, 552:15, court [7] - 496:1, 526:5, 539:1, 568:1,
CSO [1] - 526:13
552:20, 553:1, 553:7, 554:2, 555:1, 596:2, 596:22, 596:24
CSOs [1] - 497:20
555:4, 555:6, 555:24, 556:1, 557:11, Court 's [1] - 552:18
current [2] - 504:7, 632:4
557:17, 558:3, 558:5, 558:7, 558:9, Courthouse [1] - 494:5
customer [7] - 643:14, 644:1, 644:6,
558:19, 559:25, 561:3, 562:24, 563:2, courtroom [12] - 496:13, 498:15,
650:18, 651:4, 651:5, 652:19
563:5, 563:7, 563:12, 564:6, 564:9, 525:18, 525:20, 526:22, 590:2,
customers [1] - 546:24
564:23, 564:25, 565:8, 565:11, 605:18, 610:3, 656:12, 656:16,
566:19, 566:21, 567:2, 567:6, 567:9, 657:15, 674:18
568:2, 568:8, 569:23, 569:25, 571:7, COURTROOM [4] - 496:2, 526:6, 596:3, D
571:9, 575:3, 575:5, 576:21, 576:23, 656:23
D'Amelio [1] - 592:15
577:18, 577:21, 578:11, 578:13, cover [1] - 641:20
D.C [1] - 494:22
579:8, 579:10, 580:16, 580:18, 581:5, covered [1] - 613:25
Damen [1] - 505:16
582:1, 582:3, 582:18, 583:13, 583:15, created [1] - 521:25
date [45] - 502:5, 512:5, 515:6, 516:7,
585:1, 585:4, 585:9, 585:11, 586:3, credit [5] - 540:6, 540:11, 540:13,
524:4, 527:12, 530:1, 533:10, 539:9,
586:5, 586:20, 587:7, 589:1, 589:6, 613:18, 615:25
541:20, 541:22, 541:24, 548:2,
589:20, 589:25, 590:2, 590:7, 590:11, Credit [96] - 503:9, 503:20, 503:23,
548:17, 556:24, 563:11, 570:7,
591:10, 592:6, 593:3, 594:5, 594:20, 504:4, 505:9, 505:22, 506:4, 507:6,
575:16, 577:3, 578:19, 582:24,
594:23, 595:12, 596:5, 596:12, 507:7, 507:23, 511:5, 511:7, 511:12,
583:20, 585:23, 614:9, 619:25,
596:15, 596:17, 596:21, 597:1, 597:3, 511:14, 512:15, 512:22, 515:15,
621:15, 622:17, 622:19, 623:5,
597:7, 597:11, 597:16, 597:18, 515:25, 516:3, 516:6, 517:1, 518:21,
628:18, 631:1, 632:21, 634:25,
SAM OCR RMR

9
639:25, 644:16, 651:24, 653:21, defendants [1] - 675:3 difficult [3] - 531:2, 623:7, 661:19
655:3, 667:16, 667:17, 668:23, defense [9] - 497:18, 525:25, 545:6, Dilawar [2] - 510:24, 563:17
671:13, 672:5, 672:21, 673:11 545:7, 590:11, 592:1, 597:13, 598:15, diligence [16] - 503:9, 507:6, 511:9,
dates [1] - 631:22 656:19 512:21, 512:22, 512:24, 513:2,
David [15] - 568:10, 568:13, 568:22, defer [1] - 592:20 513:12, 515:13, 515:16, 516:24,
568:24, 569:2, 575:14, 604:6, 605:13, defined [2] - 522:6, 554:9 517:9, 519:7, 519:16, 528:22, 532:1
633:1, 633:10, 633:12, 633:13, definitely [2] - 546:4 dim [1] - 553:1
633:16, 634:6, 653:24 definition [1] - 554:13 DiNardo [34] - 496:10, 504:10, 506:14,
days [3] - 498:9, 542:3, 571:24 definitions [1] - 522:7 511:16, 515:3, 519:20, 522:21, 523:2,
DB [2] - 631:15, 632:3 delay [2] - 531:1, 540:6 523:9, 542:19, 548:11, 550:9, 550:10,
DD [2] - 515:11, 515:12 deliberately [1] - 584:23 550:24, 551:9, 563:18, 565:15,
de [1] - 521:13 delivered [1] - 625:8 574:12, 575:9, 581:10, 587:9, 611:2,
DE [1] - 521:17 DeLucas [5] - 559:17, 560:25, 561:21, 613:21, 620:9, 628:24, 632:19, 637:4,
deal [8] - 509:16, 532:17, 537:24, 562:10, 562:18 640:10, 641:16, 642:17, 646:16,
586:13, 586:15, 587:6, 654:9, 669:16 DeLucas ' [1] - 560:11 650:21, 655:5, 663:8
deals [1] - 586:14 DeLucas 's [1] - 558:25 DIRECT [4] - 500:5, 521:1, 656:1, 676:6
Dear [2] - 559:1, 561:2 demand [1] - 541:16 direct [4] - 527:11, 591:23, 627:8, 658:1
dear [2] - 543:18, 638:24 denominated [1] - 540:23 directed [3] - 574:4, 574:21, 635:18
debit [2] - 655:6, 655:8 department [1] - 613:18 directly [3] - 561:10, 643:17, 645:9
debt [1] - 549:20 DEPARTMENT [1] - 494:21 director [4] - 549:23, 560:12, 566:15,
decide [1] - 547:20 dependent [1] - 540:10 588:24
decided [1] - 541:7 Deputy [2] - 516:16, 518:19 Director [3] - 516:20, 531:10, 589:15
decision [1] - 590:22 DEPUTY [4] - 496:2, 526:6, 596:3, disagree [1] - 629:1
decisions [2] - 665:22, 665:23 656:23 disagreement [1] - 629:3
deducting [2] - 569:16, 649:11 describe [6] - 511:6, 557:5, 591:4, DISANTO [1] - 495:6
DEFENDANT [1] - 497:2 621:17, 622:4, 646:8 diSANTO [1] - 497:7
Defendant [2] - 495:3, 496:13 described [8] - 522:19, 573:17, 577:20, DiSanto [1] - 497:8
defendant [151] - 494:9, 500:10, 501:18, 597:4, 601:21, 616:19, 621:16, 622:10 disclose [1] - 532:19
501:19, 502:9, 505:6, 505:15, 505:19, describing [1] - 573:24 disclosed [1] - 615:3
506:3, 506:25, 507:3, 507:17, 507:25, description [7] - 522:15, 548:1, 616:12, discomfort [1] - 628:1
508:5, 509:4, 509:6, 509:19, 510:7, 616:17, 617:5, 617:6, 642:14 discount [1] - 629:21
512:13, 513:1, 513:6, 515:20, 516:11, designed [2] - 504:20, 507:13 discover [1] - 528:20
517:7, 517:15, 518:3, 518:9, 518:24, designs [1] - 504:16 discuss [11] - 530:7, 530:11, 530:14,
523:3, 523:12, 523:15, 523:19, desire [2] - 540:13, 608:3 531:15, 590:4, 594:7, 594:10, 621:13,
523:22, 523:24, 524:2, 526:8, 531:25, desired [1] - 599:18 656:17, 657:22, 674:3
532:5, 532:8, 533:14, 535:20, 542:20, desk [2] - 549:24, 673:18 discussed [11] - 500:7, 506:3, 522:3,
543:11, 543:13, 543:20, 544:2, 544:5, detailed [1] - 530:24 579:17, 600:17, 621:14, 621:21,
544:9, 544:10, 557:4, 561:14, 565:24, details [11] - 505:21, 507:15, 525:9, 628:2, 646:6, 669:5, 674:5
566:4, 568:14, 568:23, 569:6, 569:11, 530:25, 577:9, 577:10, 577:24, 585:3, discusses [1] - 583:25
570:9, 570:14, 575:18, 575:23, 576:8, 637:10, 639:10 discussing [9] - 518:5, 561:2, 561:8,
578:5, 578:23, 580:23, 581:2, 581:17, Detelina [8] - 512:10, 515:21, 524:23, 579:4, 594:9, 657:8, 658:21, 669:4,
582:13, 586:23, 587:20, 588:1, 527:16, 533:8, 535:20, 549:7, 579:21 669:8
588:11, 588:16, 590:8, 593:4, 593:5, determine [2] - 575:24, 593:2 discussion [5] - 531:18, 594:10,
596:7, 596:12, 596:16, 599:10, determined [1] - 523:18 594:12, 595:6, 661:24
599:13, 600:1, 600:24, 602:7, 602:8, discussions [3] - 544:4, 621:9, 660:19
Deutsche [4] - 646:3, 650:11, 650:13,
605:7, 605:15, 607:4, 608:17, 608:18, dispute [1] - 661:4
652:16
609:5, 614:11, 614:15, 615:10, 621:9, distinguishing [1] - 561:17
developed [2] - 513:25, 576:17
621:14, 622:2, 627:3, 628:2, 628:19, distribution [2] - 500:20, 576:3
developing [2] - 544:11, 544:12
629:1, 629:11, 630:1, 630:11, 630:13, DISTRICT [3] - 494:1, 494:1, 494:12
DG [1] - 589:14
631:1, 631:4, 631:7, 631:13, 631:20, District [1] - 494:17
Dhabi [20] - 507:10, 507:14, 517:21,
631:25, 632:9, 633:7, 633:18, 634:11, dividend [2] - 626:10, 655:13
521:13, 522:3, 522:18, 531:20,
634:13, 636:25, 648:13, 656:25, DIVISION [1] - 494:21
531:21, 563:24, 566:10, 569:12,
658:13, 658:25, 659:8, 659:15, 660:9,
574:24, 577:10, 617:15, 618:8, divulgate [1] - 559:4
660:16, 660:20, 660:21, 660:23,
619:13, 661:25, 665:5, 665:10, 665:17 doc [1] - 507:18
660:25, 661:7, 661:25, 662:19, 663:1,
dictated [1] - 501:14 dock [2] - 633:11, 633:20
664:11, 664:12, 664:16, 664:17,
difference [1] - 571:1 Docket [1] - 496:5
664:18, 664:22, 665:14, 665:19,
different [10] - 503:17, 586:13, 599:17, Docks [1] - 632:3
665:24, 665:25, 669:12, 669:21,
600:22, 608:11, 630:4, 646:6, 647:2, docs [1] - 617:10
670:5, 670:7, 670:19, 670:24
647:4, 663:10 document [36] - 507:21, 513:19, 513:22,
defendant's [3] - 504:12, 505:2, 518:11
SAM OCR RMR

10
524:20, 525:1, 537:2, 537:7, 547:19, 524:1, 524:21, 524:25, 525:1, 525:7, 569:1, 570:6, 570:7, 571:14, 618:22,
550:7, 550:8, 553:21, 553:23, 567:2, 527:10, 527:11, 527:12, 528:14, 618:23, 619:10, 619:15, 619:20,
568:3, 581:19, 598:16, 599:2, 601:10, 529:15, 529:25, 530:1, 531:23, 532:4, 621:15, 626:18, 626:21, 626:22,
601:13, 601:15, 602:11, 602:13, 532:5, 532:12, 532:18, 533:5, 535:19, 626:23, 627:7, 627:10, 628:18,
602:16, 604:18, 605:5, 605:11, 606:1, 538:2, 538:6, 539:8, 539:9, 542:16, 628:21, 628:23, 630:25, 631:2,
606:24, 607:13, 615:24, 619:11, 542:17, 574:6, 575:10, 575:13, 577:3, 631:21, 631:22, 632:18, 632:21,
629:6, 629:7, 640:15, 641:8, 649:25 577:4, 578:17, 578:19, 579:15, 634:24, 634:25, 635:22, 635:23,
documents [22] - 512:14, 512:21, 579:18, 579:20, 580:12, 580:23, 635:24
515:18, 519:23, 521:7, 551:16, 581:7, 581:15, 581:18, 581:20, emailing [4] - 563:21, 568:18, 568:19,
555:19, 594:7, 594:10, 594:17, 595:6, 582:13, 583:20, 585:16, 586:13, 568:22
603:9, 603:11, 605:17, 605:21, 586:22, 587:4, 587:5, 596:19, 598:10, emails [2] - 549:2, 563:19
617:13, 617:14, 617:15, 619:12, 598:12, 599:9, 603:17, 603:25, 604:5, EMATUM [80] - 500:18, 503:21, 505:9,
645:6, 653:14, 654:20 605:5, 605:8, 614:9, 614:11, 614:12, 505:23, 507:8, 507:11, 508:21,
Documents [1] - 551:11 614:13, 615:21, 616:6, 638:16, 508:22, 509:16, 511:9, 513:2, 515:16,
dollar [1] - 540:23 639:22, 639:25, 640:8, 640:11, 516:22, 516:24, 517:10, 517:19,
dollar-denominated [1] - 540:23 640:15, 648:24, 651:16, 651:17, 521:6, 521:7, 521:19, 521:20, 522:1,
dollars [9] - 508:10, 509:1, 522:19, 651:21, 651:24, 652:1, 653:21, 522:2, 522:18, 523:20, 523:23, 525:3,
522:24, 523:4, 613:3, 648:14, 649:7, 653:23, 654:4, 654:15, 662:18, 525:11, 528:2, 528:7, 528:11, 528:21,
669:15 662:20, 663:4, 663:6, 663:7, 664:7, 529:10, 530:15, 531:9, 531:19,
Dominic [8] - 549:25, 550:5, 601:11, 664:17, 664:21, 665:4, 665:13, 531:20, 532:10, 532:20, 533:16,
602:14, 603:17, 668:21, 670:17, 672:8 667:15, 668:20, 668:23, 669:11, 540:2, 541:7, 543:3, 547:17, 549:7,
done [4] - 504:14, 578:6, 610:14, 615:11 670:17, 670:19, 670:20, 671:4, 550:20, 551:2, 551:5, 551:20, 552:2,
Donnelly [1] - 497:5 671:13, 671:14, 672:4, 672:5, 672:9, 554:10, 555:16, 556:8, 556:12,
DONNELLY [2] - 495:5, 497:4 673:2, 673:18 556:17, 559:4, 559:19, 560:21,
DONOGHUE [1] - 494:16 E-mail [1] - 495:16 561:11, 561:18, 568:20, 569:13,
double [1] - 542:25 e-mailing [2] - 575:23, 585:20 573:4, 576:4, 578:3, 584:19, 614:18,
doubt [1] - 669:17 e-mails [11] - 512:4, 512:5, 512:11, 625:5, 625:9, 625:13, 627:6, 627:10,
down [33] - 506:13, 511:15, 519:19, 537:8, 587:9, 596:19, 596:20, 596:23, 627:11, 627:21, 628:7, 630:3, 631:10,
522:6, 524:9, 525:19, 532:22, 535:23, 654:3, 668:8, 671:10 647:4, 660:7, 660:14
548:4, 561:3, 589:25, 590:1, 591:16, earliest [2] - 639:22, 669:11 EMATUM 's [1] - 604:24
600:4, 605:9, 610:13, 613:21, 614:11, early [1] - 523:16 emerging [1] - 546:9
618:22, 623:3, 635:14, 642:17, 644:9, earn [1] - 674:6 Emirates [2] - 566:1, 616:5
644:23, 646:18, 650:21, 656:13, earned [1] - 658:7 emission [1] - 559:3
656:14, 662:2, 667:20, 667:23, 674:19 earnings [1] - 616:13 employee [7] - 500:14, 548:20, 571:21,
draft [1] - 619:5 easier [2] - 597:8, 597:24 571:23, 576:16, 663:22, 669:13
drafted [2] - 624:23, 646:10 East [2] - 494:17, 673:21 employees [6] - 512:15, 512:18, 515:25,
dramatic [1] - 633:4 east [1] - 673:21 608:21, 633:11, 633:20
drill [1] - 659:6 EASTERN [1] - 494:1 employer [2] - 500:16, 566:8
drop [1] - 587:21 Eastern [2] - 494:17, 658:15 Empresa [1] - 521:13
drops [2] - 552:10, 657:17 eating [1] - 594:12 enable [3] - 547:19, 639:3, 646:10
due [18] - 507:6, 511:9, 512:21, 512:22, economic [2] - 513:23, 559:5 enabled [1] - 646:11
512:23, 513:2, 513:12, 515:13, economist [1] - 631:10 end [10] - 498:8, 503:22, 523:17,
515:15, 516:24, 517:9, 519:7, 519:16, Ed [1] - 558:16 575:24, 643:25, 654:9, 657:18,
532:1, 547:22, 661:16, 672:21, 673:1 Edward [2] - 512:19, 521:5 661:21, 662:4, 670:15
duly [2] - 500:3, 593:3 effect [1] - 606:19 end-user [1] - 643:25
during [9] - 528:25, 622:3, 656:11, effective [2] - 641:9 Energy [6] - 599:19, 599:24, 663:15,
657:23, 658:24, 659:7, 666:1, 666:4, efficient [1] - 503:18 663:16, 663:20, 663:23
666:15 efforts [1] - 651:22 enforceable [1] - 634:9
DV15 [2] - 622:7, 622:12 either [3] - 524:14, 621:1, 625:15 engaged [1] - 660:1
Electronic [1] - 552:21 engines [1] - 629:20
E electronically [6] - 535:12, 545:8, enhance [1] - 548:9
597:23, 598:1, 642:23, 662:10 enjoy [1] - 589:22
E-M-P-R-E-S-A [1] - 521:16 element [1] - 625:6 enough.. [1] - 577:12
e-mail [138] - 502:4, 502:5, 502:12, elements [3] - 509:20, 525:9, 634:13 Enrigue [1] - 635:19
502:25, 503:2, 503:4, 504:13, 506:25, Elmo [2] - 552:21, 552:24 ensure [3] - 511:9, 518:20, 525:8
507:4, 507:13, 509:22, 510:21, email [53] - 531:13, 533:12, 545:16, entered [4] - 496:13, 498:15, 622:25,
510:23, 511:3, 511:7, 512:7, 512:16, 545:17, 545:25, 555:12, 558:14, 644:14
513:2, 513:13, 514:25, 515:6, 515:19, 558:23, 558:25, 560:23, 561:25, Enterprise [1] - 559:4
515:24, 518:2, 518:11, 521:4, 521:8, 562:7, 563:11, 563:19, 564:14, enters [4] - 498:1, 526:22, 610:3, 657:15
521:11, 522:25, 523:11, 523:13, 564:16, 568:10, 568:11, 568:25, entertain [1] - 538:5
SAM OCR RMR

11
entirely [1] - 599:17 exhibit [22] - 532:22, 545:14, 547:8, exits [4] - 525:18, 589:24, 656:12,
entities [1] - 625:15 547:15, 555:7, 558:12, 563:9, 564:12, 674:18
entity [5] - 573:15, 573:18, 600:22, 570:4, 571:12, 599:16, 600:14, 614:8, expand [5] - 542:18, 550:23, 551:10,
600:24, 665:12 615:20, 618:20, 623:20, 624:4, 637:4, 641:16
entry [2] - 655:3, 655:15 628:16, 630:23, 632:17, 634:22, expect [1] - 523:16
equipment [1] - 627:15 636:22 expectation [1] - 576:12
errors [1] - 634:1 Exhibit [196] - 499:2, 501:21, 501:25, expected [5] - 519:18, 528:2, 528:7,
ESQ [10] - 494:16, 494:18, 494:19, 502:2, 502:15, 502:16, 502:21, 533:16, 616:20
494:23, 494:23, 495:4, 495:5, 495:5, 502:23, 506:16, 506:20, 506:22, expects [1] - 627:16
495:6, 495:6 511:18, 512:1, 513:9, 513:16, 514:9, expenditure [1] - 660:22
essentially [1] - 591:15 514:21, 514:23, 519:22, 520:17, expenses [2] - 510:1, 569:20
establish [2] - 580:9, 671:2 521:3, 524:11, 524:18, 527:3, 527:7, experience [2] - 529:6, 557:8
established [3] - 569:3, 660:18, 660:19 527:8, 529:19, 529:24, 532:24, 533:4, expertise [3] - 534:10, 534:25, 625:21
estate [2] - 621:20, 666:8 535:9, 535:17, 535:18, 537:7, 539:7, explain [12] - 521:23, 533:13, 541:6,
estates [1] - 544:7 545:3, 545:13, 547:3, 547:7, 547:11, 560:17, 568:17, 573:13, 592:23,
estimate [1] - 533:17 547:14, 548:12, 554:25, 558:2, 616:16, 641:19, 647:1, 651:2, 672:18
estimated [1] - 629:18 558:11, 563:4, 563:8, 564:5, 564:11, explained [3] - 523:5, 637:14, 670:10
et [5] - 614:22, 629:19, 629:20, 633:11, 564:22, 565:3, 566:18, 568:4, 568:5, explaining [1] - 560:20
633:20 568:6, 569:22, 570:3, 571:6, 571:11, explanation [2] - 562:19, 562:20
575:2, 575:7, 575:11, 576:20, 576:24, expletive [1] - 587:5
euro [7] - 508:1, 508:2, 508:3, 508:4,
577:1, 578:10, 578:14, 578:16,
508:7, 508:16, 508:17 exploration [1] - 658:14
579:11, 579:13, 580:15, 580:19,
Europe [4] - 534:25, 549:24, 566:16, explore [3] - 600:19, 659:3, 659:6
580:21, 581:11, 582:6, 582:17,
658:15 expressed [1] - 628:1
583:12, 583:16, 583:18, 585:8,
Euros [1] - 659:21 expressing [2] - 559:23, 560:2
585:12, 585:14, 586:6, 586:8, 587:10,
euros [3] - 508:8, 508:24 expression [1] - 591:14
598:7, 599:7, 602:23, 603:15, 603:23,
event [2] - 621:24, 637:11 extend [3] - 672:14, 672:16, 674:7
606:11, 612:2, 612:12, 612:13,
events [3] - 573:25, 608:20, 621:16 extension [2] - 669:6, 674:5
612:14, 613:23, 614:1, 614:7, 615:15,
eventually [2] - 574:17, 600:2 extensively [1] - 591:21
615:19, 618:18, 618:19, 623:10,
evidence [63] - 502:1, 502:15, 502:22, extent [3] - 591:22, 595:4, 660:21
623:18, 623:22, 624:3, 628:11,
506:21, 511:25, 514:10, 514:22, extra [1] - 570:12
628:15, 630:17, 630:22, 632:12,
520:16, 524:18, 527:7, 529:24, 533:4, extracted [1] - 608:9
632:16, 634:21, 636:16, 636:21,
535:17, 539:5, 539:7, 545:13, 547:7,
638:4, 638:12, 638:14, 639:21,
555:9, 558:11, 563:8, 564:11, 565:2, F
640:23, 640:25, 641:13, 642:8, 642:9,
568:4, 568:5, 570:3, 571:11, 575:8,
643:8, 644:10, 644:11, 644:18,
576:25, 578:15, 579:12, 580:20, facilities [2] - 625:7, 644:2
645:24, 646:17, 648:17, 649:14,
582:5, 583:17, 585:13, 586:7, 606:11, facility [8] - 556:7, 556:14, 558:18,
649:15, 651:14, 652:8, 652:23, 653:1,
610:22, 612:12, 614:7, 615:19, 558:21, 573:12, 573:18, 573:23, 574:3
653:10, 653:19, 654:5, 654:13,
617:23, 618:18, 618:19, 623:18, fact [12] - 517:18, 518:22, 522:3, 524:7,
654:19, 654:24, 662:6, 662:14,
624:3, 628:15, 630:22, 632:16, 528:9, 529:7, 541:20, 551:15, 553:8,
662:17, 666:20, 667:4, 668:13,
634:21, 636:21, 638:13, 639:20, 615:2, 616:18, 674:1
668:17, 668:19, 672:3, 673:16, 677:4,
640:24, 643:4, 648:22, 651:13, facts [3] - 591:12, 591:20, 592:3
677:6, 677:8, 677:12, 677:14, 677:19,
652:24, 653:18, 662:14, 667:1, faith [1] - 537:23
677:21, 677:23, 677:25, 678:3, 678:5,
668:13, 668:17, 672:1 fake [2] - 621:10, 622:15
678:7, 678:11, 678:13, 678:15,
EXAMINATION [6] - 500:5, 521:1, fan [2] - 674:13, 674:14
678:19, 678:21, 678:23, 678:25,
573:1, 638:1, 656:1, 676:6 far [4] - 529:9, 529:11, 644:19, 656:5
679:3, 679:5, 679:7, 679:9, 679:13,
examination [4] - 526:25, 603:12, 679:15, 679:17, 679:19, 679:21, FARR [1] - 495:3
610:10, 658:1 679:23, 679:25, 680:5, 680:7, 680:9, fashion [1] - 605:20
examine [4] - 591:21, 598:16, 598:24, 680:11, 680:13, 680:15, 680:17, father [1] - 569:2
600:10 680:19, 680:21, 680:23, 681:3, favor [1] - 587:17
examined [1] - 500:3 681:12, 681:16 favorably [1] - 511:13
example [1] - 591:2 exhibits [3] - 511:20, 594:3, 617:24 feasibility [2] - 531:6, 531:8
exceeding [1] - 570:17 Exhibits [25] - 511:24, 520:15, 555:8, fee [18] - 543:6, 543:9, 557:3, 568:19,
Excellency [2] - 531:11, 589:13 565:1, 582:4, 617:22, 639:19, 642:19, 569:13, 575:19, 611:22, 611:25,
exception [1] - 602:6 648:21, 651:12, 653:17, 666:25, 612:15, 612:18, 612:19, 612:20,
exchange [2] - 508:11, 668:8 671:25, 677:10, 677:16, 678:9, 612:24, 612:25, 626:11, 655:12, 674:6
excuse [10] - 509:17, 510:22, 513:22, 678:17, 679:11, 680:3, 680:25, 681:5, Fees [2] - 611:4, 611:14
540:15, 547:22, 574:24, 617:4, 681:7, 681:9, 681:14, 681:18 fees [7] - 611:8, 611:16, 611:19, 611:24,
649:24, 651:3, 654:21 existence [1] - 602:9 627:16, 649:11, 655:14
Excuse [3] - 549:9, 565:9, 622:14 existent [1] - 609:14 Felipe [10] - 571:14, 571:19, 574:6,
execution [1] - 643:21
SAM OCR RMR

12
579:21, 579:23, 580:1, 585:18, flipping [1] - 669:16 G

648:25, 649:4, 651:21 flows [1] - 573:22
felt [1] - 562:18 fly [1] - 667:23 Galina [4] - 512:19, 521:5, 558:16,
few [2] - 539:14, 588:4 focus [2] - 512:23, 518:12 635:3
FGB [1] - 615:24 focused [1] - 513:23 GALLAGHER [1] - 495:3
fifty [1] - 632:7 folks [1] - 597:9 Gamato [1] - 635:19
Final [2] - 558:21, 632:24 follow [1] - 618:22 gap [1] - 541:22
final [6] - 521:18, 541:7, 558:18, 575:20, follow-up [1] - 618:22 garden [1] - 528:25
576:2, 576:3 followed [1] - 544:8 gas [5] - 658:13, 659:6, 661:8, 663:17,
finalize [1] - 673:3 following [10] - 499:5, 520:19, 537:1, 663:20
finalized [2] - 501:11, 575:21 538:10, 541:2, 593:9, 633:4, 637:9, General [1] - 589:15
finalizes [1] - 541:23 655:19, 673:1 generate [4] - 528:7, 528:11, 625:17,
finally [1] - 616:1 follows [2] - 500:4, 577:9 629:24
Finance [11] - 513:14, 516:20, 531:5, Foong [1] - 558:17 generated [1] - 625:16
531:10, 543:24, 552:3, 561:10, FOR [1] - 494:11 generic [1] - 518:13
561:20, 562:16, 635:5, 670:2 force [1] - 641:8 Generically [1] - 549:14
finance [6] - 523:20, 554:7, 559:4, foreign [1] - 665:12 gentleman [3] - 549:21, 549:25, 663:21
559:13, 566:15, 635:20 foreigners [1] - 665:9 gentlemen [19] - 496:16, 498:6, 498:11,
financial [22] - 500:7, 500:11, 513:21, foresee [1] - 623:8 525:21, 526:23, 536:4, 553:4, 589:20,
525:10, 527:18, 527:22, 528:2, forgets [1] - 537:23 590:3, 596:9, 610:4, 610:8, 656:11,
529:10, 530:14, 530:24, 539:24, form [2] - 553:20, 616:19 656:16, 657:16, 657:19, 674:12,
540:4, 540:17, 556:20, 559:6, 559:10, former [1] - 504:6 675:2, 675:14
560:6, 584:5, 584:12, 607:5, 626:24, forward [5] - 512:13, 529:8, 579:25, geographical [1] - 659:4
662:23 619:14, 640:15 Germany [1] - 625:23
financing [4] - 500:8, 543:6, 570:16, forwarded [9] - 502:13, 510:23, 515:21, given [5] - 537:22, 540:18, 562:20,
631:7 558:23, 561:25, 619:16, 635:24, 571:3, 659:3
Fincantieri [1] - 505:17 640:8, 640:12 glad [1] - 554:2
finders [1] - 553:8 forwarding [1] - 512:14 global [1] - 566:15
fine [4] - 520:13, 523:18, 537:12, 614:6 four [1] - 509:17 Global [3] - 583:5, 635:5
finish [2] - 653:14, 657:2 fourth [1] - 530:17 Gmail [3] - 510:24, 510:25, 511:1
finished [1] - 654:9 France [6] - 544:7, 621:21, 625:23, God [1] - 594:6
fired [2] - 637:11, 637:17 659:13, 659:19, 666:8 golf [1] - 659:19
firms [1] - 665:11 FRANCIS [1] - 494:12 goods [2] - 509:21, 605:6
first [39] - 504:9, 504:10, 505:18, fraud [2] - 668:9, 671:18 government [4] - 503:16, 519:11,
506:25, 508:15, 512:4, 513:12, 515:1, freak [2] - 632:1, 632:6 628:15, 680:13
542:11, 543:17, 547:17, 548:4, 556:7, freaking [3] - 669:13, 669:21, 671:3 Government [129] - 494:16, 497:15,
569:8, 573:22, 587:4, 590:7, 597:24, free [3] - 505:14, 526:19, 594:22 499:1, 500:2, 506:15, 511:17, 513:21,
598:6, 599:24, 615:21, 616:6, 618:10, frequently [1] - 544:3 516:16, 517:5, 519:21, 521:3, 524:10,
621:19, 621:23, 622:15, 622:17, Friday [6] - 494:7, 523:18, 544:8, 524:11, 525:23, 525:24, 527:2, 527:3,
629:11, 635:22, 640:14, 641:6, 644:5, 610:11, 610:14, 667:21 529:18, 529:19, 532:23, 534:1, 535:8,
649:10, 649:16, 650:16, 664:7, 666:3, friend [2] - 569:10, 577:19 537:7, 537:17, 540:12, 545:2, 547:2,
671:13 front [5] - 521:10, 537:9, 547:16, 547:7, 555:8, 558:11, 559:2, 559:3,
First [2] - 570:8, 654:22 551:19, 673:18 559:12, 560:3, 560:9, 562:12, 562:13,
Firstly [1] - 569:12 frustrated [1] - 633:21 563:3, 563:8, 564:4, 564:11, 564:21,
fisheries [1] - 528:17 fuck [1] - 636:9 566:17, 568:4, 569:21, 570:3, 571:5,
Fisheries [7] - 516:16, 517:2, 517:6, full [6] - 519:4, 562:7, 562:18, 637:10, 571:11, 575:1, 576:19, 578:9, 579:6,
517:8, 517:25, 518:19 639:10, 641:8 580:14, 583:11, 585:7, 590:7, 590:9,
fishing [17] - 501:6, 503:11, 504:21, fully [1] - 560:18 590:10, 590:15, 591:7, 591:8, 591:25,
505:23, 509:15, 509:17, 515:16, function [2] - 540:10, 573:20 592:10, 592:12, 592:23, 593:3, 593:4,
516:12, 516:15, 517:3, 517:4, 517:20, 594:4, 594:16, 597:4, 600:23, 602:6,
fund [3] - 544:11, 576:3
518:14, 519:12, 543:9, 554:10 608:9, 608:18, 612:1, 612:12, 613:22,
funded [2] - 557:23, 652:6
five [7] - 542:2, 547:21, 610:12, 610:14, 615:14, 615:15, 615:19, 617:17,
funding [2] - 542:1, 542:2
613:3, 674:8, 674:11 618:12, 618:18, 618:19, 623:18,
funds [6] - 582:25, 583:2, 583:4, 617:1,
five-and-a-half [1] - 613:3 624:3, 628:11, 630:16, 630:22,
658:7
flag [1] - 529:8 632:16, 634:15, 634:21, 636:15,
future [2] - 637:12, 637:17
fleet [1] - 501:9 636:21, 638:3, 639:12, 642:18,
FYI [1] - 505:16
fleets [1] - 614:19 648:16, 651:7, 652:22, 653:9, 656:18,
flight [3] - 667:21, 673:9, 673:11 659:3, 662:6, 666:19, 666:20, 667:4,
flip [1] - 565:14 668:13, 671:20, 673:16, 675:9, 678:7,
Flip [1] - 545:22 678:9, 678:11, 678:13, 678:15,
SAM OCR RMR

13
678:21, 678:23, 679:21, 679:25, 543:18 525:12, 526:1, 526:12, 526:15,

680:5, 680:7, 680:9, 680:11, 680:15, half [1] - 613:3 526:18, 527:2, 527:5, 529:18, 529:21,
680:17, 680:19, 680:21 Hamet [2] - 579:22, 585:19 529:23, 532:23, 533:3, 535:16, 536:2,
Government 's [124] - 499:2, 501:21, hand [5] - 567:3, 597:8, 597:10, 597:11, 537:3, 537:5, 537:10, 537:13, 537:16,
501:25, 502:14, 502:16, 502:21, 597:12 538:1, 538:7, 539:4, 545:2, 545:10,
506:20, 511:24, 514:9, 514:21, handle [2] - 531:25, 605:24 545:12, 545:21, 547:2, 547:5, 547:9,
519:22, 520:15, 524:18, 527:7, Happy [1] - 631:16 547:12, 548:15, 552:25, 553:11,
529:24, 532:24, 533:4, 535:17, 539:7, happy [2] - 543:21, 673:4 554:24, 555:3, 557:16, 558:1, 558:4,
545:3, 545:13, 547:3, 547:11, 547:14, hard [6] - 574:13, 610:12, 656:10, 558:10, 559:24, 562:21, 563:6, 564:4,
554:25, 558:2, 563:4, 564:5, 564:22, 657:3, 657:20, 674:8 564:10, 564:21, 564:24, 565:9,
565:1, 566:18, 568:5, 569:22, 571:6, hayati [5] - 539:15, 539:16, 539:20, 566:17, 566:20, 567:7, 568:7, 570:2,
575:2, 575:7, 576:20, 576:24, 578:10, 543:15, 543:18 575:4, 576:19, 576:22, 578:9, 579:6,
578:14, 579:11, 580:15, 580:19, hayeti [1] - 532:7 580:14, 581:23, 583:11, 585:7, 586:1,
582:4, 583:12, 583:16, 585:8, 585:12, HE [2] - 531:5, 589:12 589:5, 589:18, 589:19, 590:6, 590:12,
586:6, 590:25, 598:7, 599:7, 601:3, head [2] - 517:8, 566:15 590:13, 590:18, 590:20, 590:24,
602:23, 603:15, 603:23, 606:11, headed [1] - 549:21 591:6, 592:5, 592:7, 592:20, 593:7,
612:2, 612:14, 613:23, 614:1, 614:7, hear [11] - 498:3, 526:20, 527:21, 553:9, 594:2, 595:11, 595:13, 596:11,
617:22, 623:10, 623:22, 630:17, 554:2, 558:20, 561:4, 588:1, 590:7, 596:14, 596:18, 597:2, 597:6, 597:17,
632:12, 636:16, 638:4, 638:12, 595:4, 666:6 598:3, 598:5, 598:19, 599:3, 599:15,
639:19, 640:23, 642:7, 642:19, 600:13, 601:1, 601:14, 601:17,
heard [4] - 498:4, 544:1, 603:3, 645:10
644:10, 644:18, 648:17, 648:21, 601:20, 601:24, 602:5, 603:1, 603:4,
hearing [3] - 536:5, 591:20
649:14, 651:12, 652:23, 653:10, 604:5, 604:22, 606:8, 606:17, 606:25,
hearsay [3] - 601:20, 602:3, 609:9
653:17, 662:14, 666:25, 668:17, 607:7, 607:19, 608:1, 608:14, 608:19,
Heathrow [3] - 667:13, 667:25, 673:9
671:25, 677:4, 677:6, 677:8, 677:10, 609:1, 609:7, 609:12, 609:16, 609:17,
held [2] - 536:5, 660:15
677:12, 677:14, 677:16, 677:19, 609:19, 609:21, 610:1, 610:17, 612:1,
help [10] - 507:14, 518:25, 534:8, 545:9,
677:21, 677:23, 677:25, 678:3, 678:5, 612:4, 612:11, 614:1, 614:3, 614:5,
559:10, 594:25, 595:7, 636:3, 636:5,
678:17, 678:19, 678:25, 679:3, 679:5, 615:17, 617:7, 617:17, 617:20,
648:3
679:7, 679:9, 679:11, 679:13, 679:15, 618:15, 623:13, 623:19, 624:1,
helpful [1] - 639:2
679:17, 679:19, 679:23, 680:3, 624:17, 624:21, 628:10, 632:11,
hereby [1] - 559:9
680:23, 680:25, 681:3, 681:5, 681:7, 634:3, 634:15, 636:18, 636:20, 638:6,
hesitant [1] - 630:13
681:9, 681:12, 681:14, 681:16, 681:18 638:11, 639:17, 640:17, 643:2, 643:5,
Hi [2] - 502:10, 619:5 648:19, 649:24, 650:8, 652:22,
governmental [2] - 643:18, 643:22
hi [8] - 528:15, 530:6, 579:24, 605:10, 653:16, 656:7, 656:18, 656:20, 657:5,
Governments [1] - 534:11
615:23, 616:11, 649:6, 654:8 657:9, 658:2, 662:5, 662:9, 662:16,
grabbed [1] - 567:4
high [1] - 523:6 667:18, 668:12, 674:8, 675:6, 675:11,
grabbing [1] - 567:4
higher [2] - 627:17, 627:25 675:12
gravamen [1] - 605:11
highlight [1] - 587:7 HONORABLE [1] - 494:12
green [1] - 570:11
highlighting [1] - 633:4 Honorable [1] - 496:3
Group [1] - 635:5
highly [1] - 625:20 hope [3] - 541:8, 577:12, 615:23
group [4] - 534:4, 550:6, 566:16, 665:6
Hiral [1] - 496:9 hopefully [1] - 542:25
guarantee [5] - 555:16, 559:11, 614:16,
HIRAL [1] - 494:19 hoping [1] - 543:1
614:21, 669:15
hold [1] - 665:12 Hotel [2] - 673:19, 673:20
guaranteed [3] - 552:2, 561:12, 561:19
holder [1] - 659:5 Hotmail [1] - 619:17
guarantor [1] - 513:24
holders [2] - 550:19, 550:21 house [1] - 673:4
guaranty [2] - 653:3, 653:7
Holding [2] - 566:10, 568:16 hulls [3] - 504:24, 504:25, 505:1
guard [1] - 608:8
holding [3] - 617:11, 643:18, 665:21 hundred [4] - 547:21, 632:7, 652:5,
Guebuza [8] - 518:6, 518:9, 531:12,
Holdings [10] - 569:4, 569:5, 626:10, 652:6
587:2, 587:15, 587:23, 588:8, 588:10
626:11, 654:10, 655:2, 660:7, 660:8, hunting [1] - 673:4
guests [1] - 538:5
664:15, 665:23 hydrocarbons [1] - 659:4
guidance [1] - 587:13
Holdings' [1] - 654:22
Gulf [1] - 654:22
Holland [1] - 505:16
guys [2] - 597:1, 604:16 I
Holmes [1] - 608:7
Gwendoline [3] - 638:16, 638:21,
home [1] - 674:13 i.e [3] - 542:3, 548:3, 554:19
638:23
Honor [195] - 496:12, 496:20, 496:22, ICE [6] - 582:25, 583:2, 583:5, 583:9,
Gwendolyn [1] - 598:13
497:19, 497:24, 498:22, 498:25, 585:24
GX [1] - 597:14
499:1, 501:23, 502:18, 502:20, ICE-Canyon-owned [1] - 582:25
GX-4 [2] - 610:22, 613:14
506:15, 506:18, 511:21, 511:23, idea [3] - 544:11, 659:14, 669:7
514:1, 514:2, 514:6, 514:11, 514:15, II [3] - 494:12, 496:3, 522:12
H 514:20, 519:21, 519:24, 520:1, illegally [1] - 634:9
520:12, 521:16, 524:13, 524:16, IMF [7] - 570:11, 570:17, 570:19,
habibi [4] - 532:7, 532:17, 543:15,
SAM OCR RMR

14
570:21, 570:22, 584:23, 585:2 instruction [5] - 574:8, 574:18, 592:8, issued [9] - 541:21, 548:2, 550:17,
IMF's [1] - 570:17 592:16, 651:23 552:4, 560:3, 561:10, 561:18, 562:11,
important [18] - 503:20, 506:4, 506:6, Instruction [1] - 649:7 644:1
506:7, 519:5, 519:9, 519:10, 540:8, instruments [1] - 550:3 issues [12] - 497:13, 525:22, 526:9,
540:21, 546:10, 546:25, 557:9, insurance [1] - 509:25 559:11, 561:12, 590:4, 590:9, 596:8,
557:12, 570:20, 570:21, 580:5, 628:4, insure [1] - 629:17 596:17, 600:21, 601:2, 656:17
628:5 intend [1] - 594:16 issuing [1] - 540:9
impossible [1] - 632:8 intends [3] - 600:16, 600:19, 602:7 Italy [1] - 505:17
incentive [3] - 500:8, 500:11, 556:20 interactions [1] - 604:23 item [2] - 533:18, 604:14
include [1] - 504:20 interest [7] - 540:5, 540:10, 540:23, Items [1] - 509:22
included [5] - 507:22, 528:1, 535:5, 541:13, 600:24, 623:20, 672:21 items [1] - 507:13
552:7, 629:25 interested [3] - 535:4, 636:25, 643:15 itself [4] - 508:22, 532:3, 592:16, 592:17
includes [3] - 600:2, 600:3, 600:6 intermediary [1] - 650:20
including [5] - 559:5, 563:22, 564:19, international [1] - 559:5 J
644:2, 668:7 introduce [1] - 594:17
inconsistencies [1] - 633:22 invented [1] - 594:6 J-O-H-N [1] - 664:3
inconsistent [1] - 627:5 invest [6] - 547:20, 549:17, 600:7, J.B [1] - 634:8
incorporated [1] - 665:5 658:16, 661:20, 661:21 JACKSON [16] - 495:5, 496:18, 497:19,
incorrect [1] - 523:7 invested [6] - 583:7, 585:22, 585:24, 526:1, 526:12, 590:6, 590:12, 592:5,
Increase [2] - 581:1, 582:9 658:9, 658:18, 660:23 592:7, 593:7, 595:11, 597:2, 597:17,
increase [2] - 582:10, 631:5 investment [7] - 533:21, 534:16, 604:22, 656:20, 675:12
increased [6] - 503:25, 504:2, 524:5, 534:18, 534:23, 544:11, 546:8, 661:6 Jackson [6] - 496:18, 526:13, 553:2,
524:8, 631:8, 631:20 Investments [3] - 641:5, 641:11, 651:6 562:25, 591:11, 597:11
increasing [2] - 579:5, 631:25 investments [1] - 660:23 JAFZA [1] - 606:20
increasingly [1] - 661:19 investor [1] - 541:11 January [1] - 614:10
indeed [1] - 670:2 investors [41] - 523:11, 523:16, 523:20, JB [1] - 607:3
Index [7] - 546:4, 546:7, 546:11, 546:12, 523:21, 523:23, 523:25, 534:3, 534:9, Jean [22] - 502:8, 512:8, 515:9, 516:11,
546:14, 546:18, 546:20 534:10, 534:24, 534:25, 535:3, 535:5, 519:5, 524:24, 528:17, 530:4, 531:14,
index [3] - 546:9, 546:15, 546:23 540:14, 541:10, 541:13, 541:23, 532:5, 533:8, 539:8, 557:4, 558:16,
indicate [11] - 502:9, 523:12, 548:5, 541:25, 542:5, 542:7, 542:13, 546:15, 560:24, 568:23, 569:4, 579:22, 604:6,
551:1, 612:20, 651:3, 664:18, 665:7, 546:16, 546:22, 547:19, 552:4, 552:6, 621:20, 633:1, 662:19
667:20, 670:22, 673:2 554:21, 556:11, 557:9, 557:13, JEAN [1] - 494:8
indicated [7] - 508:8, 510:3, 534:12, 573:23, 573:25, 580:3, 580:9, 581:3, Jersey [2] - 673:10, 673:11
541:12, 562:11, 566:8, 566:11 585:22, 611:18, 611:19, 611:21 Jessica [1] - 558:17
indicates [3] - 551:2, 607:3, 646:3 invitation [1] - 559:8 jet [1] - 666:9
indicating [4] - 517:24, 524:1, 531:25, involve [5] - 533:19, 533:22, 534:7, JFK [2] - 667:13, 667:25
560:13 534:12, 535:2 job [5] - 616:12, 616:17, 616:19, 617:5,
Indictment [1] - 592:19 involved [13] - 505:23, 516:21, 516:24, 617:6
indictment [4] - 600:18, 604:25, 607:20, 532:16, 534:8, 624:9, 633:16, 639:7, jobs [1] - 629:18
608:21 660:12, 661:23, 664:10, 664:13, 668:9 john [1] - 664:3
indirectly [1] - 643:17 involvement [2] - 584:6, 666:15 John [3] - 516:12, 663:21, 663:25
individual [2] - 565:16, 630:14 involvements [1] - 584:6 joined [1] - 602:8
info [1] - 507:18 involving [4] - 503:24, 534:17, 664:16 joining [1] - 534:4
information [16] - 506:4, 506:6, 506:7, irrelevant [1] - 599:15 joint [2] - 548:5, 548:10
511:2, 511:4, 511:11, 515:23, 519:4, Isaltina [15] - 516:12, 516:18, 516:19, Journal [1] - 609:8
524:2, 530:23, 559:4, 581:20, 603:7, 531:5, 531:9, 558:15, 561:16, 588:22, JP [8] - 546:8, 546:11, 546:12, 546:14,
603:8, 636:14, 639:3 588:23, 589:10, 669:13, 669:21, 546:18, 546:20, 559:7, 669:14
informed [2] - 559:7, 585:3 669:22, 670:23, 671:2 JPM [3] - 546:4, 546:7, 546:8
infrastructure [2] - 501:6, 614:19 ISALTINA [1] - 589:11 Judge [4] - 526:6, 563:1, 596:3, 656:23
initial [1] - 632:3 Iskandar [14] - 544:8, 621:14, 621:20, JUDGE [1] - 494:12
inject [1] - 609:8 621:21, 622:2, 622:3, 658:13, 659:20, July [5] - 502:6, 503:2, 503:22, 507:1,
injection [1] - 590:25 661:7, 661:22, 664:12, 665:17, 555:13
inquire [1] - 503:10 665:24, 666:1 June [4] - 504:3, 651:25, 652:4, 653:22
inquiry [2] - 498:24, 635:7 Islands [1] - 569:3 junior [1] - 588:9
installment [1] - 650:16 issue [25] - 534:2, 537:25, 559:19, Junior's [2] - 586:18, 587:1
instances [1] - 661:3 560:8, 560:21, 561:17, 584:8, 594:3, JUROR [1] - 552:14
institution [2] - 650:20, 650:24 598:21, 598:23, 599:11, 599:19, jurors [1] - 553:2
institutions [1] - 559:6 599:22, 604:22, 604:23, 606:22, jury [78] - 496:1, 497:14, 497:21, 498:7,
instruct [1] - 593:2 608:22, 609:6, 609:9, 611:19, 616:12, 503:4, 507:3, 508:15, 521:23, 525:19,
627:18, 637:15, 637:18 525:23, 526:5, 526:10, 526:22,
SAM OCR RMR

15
526:24, 533:13, 535:15, 536:5, 539:1, 568:24, 569:2, 575:15, 604:6, 605:13, life [1] - 528:12
539:14, 541:6, 545:14, 547:8, 548:9, 633:1, 633:13, 633:17, 634:6, 634:11, lifetime [1] - 528:8
550:23, 553:4, 554:2, 555:7, 558:12, 653:24 light [2] - 498:2, 570:11
563:9, 564:12, 565:3, 568:1, 568:3, language [4] - 539:18, 556:1, 608:2, Light [1] - 552:21
568:6, 568:17, 570:1, 570:4, 571:10, 645:14 lights [1] - 553:2
571:12, 581:9, 583:25, 587:7, 590:2, laptop [1] - 562:21 likely [1] - 525:4
590:5, 591:11, 591:19, 592:2, 595:5, large [2] - 658:18, 666:11 Lillian [1] - 496:10
595:8, 596:2, 609:23, 610:2, 610:3, largely [1] - 645:6 Limited [6] - 510:24, 563:17, 583:5,
610:5, 610:23, 612:10, 616:16, larger [3] - 500:11, 501:7 583:6, 647:19, 655:2
618:20, 621:17, 624:4, 628:16, 629:5, largest [2] - 547:1, 661:6 lina [1] - 602:17
630:23, 632:17, 634:22, 636:22, last [5] - 523:14, 524:3, 531:13, 647:9, Lina [1] - 609:4
637:4, 641:19, 646:8, 652:23, 656:15, 653:6 line [4] - 538:2, 574:10, 637:19, 652:17
656:16, 656:18, 657:11, 657:15, launch [12] - 539:21, 539:22, 539:23, liners [1] - 627:11
657:17, 657:19, 674:11 539:25, 540:2, 540:7, 540:24, 541:1, lines [2] - 599:12, 608:7
JURY [1] - 494:11 541:4, 541:10, 541:20, 545:17 list [4] - 580:2, 580:25, 582:23, 585:21
Jury [5] - 498:1, 525:18, 589:24, 656:12, launched [1] - 548:21 listed [3] - 507:13, 546:14, 546:18
674:18 launches [1] - 541:17 literally [2] - 597:23, 658:15
JUSTICE [1] - 494:21 launching [1] - 540:21 living [1] - 604:16
justification [1] - 531:19 Laverne [1] - 672:23 LLC [3] - 618:8, 641:5, 651:6
justify [2] - 506:8, 507:14 Law [1] - 590:21 LLP [1] - 495:3
law [13] - 591:8, 591:12, 591:19, 591:25, Loan [3] - 550:24, 551:11, 553:23
K 592:1, 592:2, 592:9, 592:14, 592:16, loan [129] - 500:8, 500:16, 501:7,
593:1, 608:10, 639:11, 665:11 502:10, 503:21, 503:24, 503:25,
Kamel [3] - 563:23, 564:17, 564:18 laws [6] - 554:14, 554:17, 554:19, 504:2, 506:5, 517:9, 517:22, 523:23,
KATHERINE [1] - 494:23 639:1, 639:2, 645:14 524:4, 529:4, 542:2, 542:14, 547:22,
Katherine [1] - 496:10 lawyers [6] - 664:25, 665:2, 665:8, 548:17, 549:8, 550:3, 550:14, 550:18,
keep [8] - 527:20, 598:25, 599:22, 665:17, 665:19, 665:21 550:20, 551:16, 551:19, 551:22,
602:4, 602:21, 645:8, 646:18, 650:21 lead [3] - 534:7, 548:5, 548:10 552:1, 552:5, 552:8, 553:6, 553:13,
keeping [1] - 609:13 learn [2] - 584:22, 585:1 553:19, 554:5, 554:12, 555:15, 556:7,
Kelly [3] - 512:19, 521:5, 558:17 learned [1] - 585:2 556:10, 556:12, 557:1, 557:5, 557:23,
key [2] - 519:14, 647:5 least [2] - 542:13, 664:2 560:6, 561:19, 569:8, 569:13, 569:15,
kickback [5] - 557:3, 578:3, 613:2, leave [2] - 528:25, 569:9 573:18, 574:3, 575:20, 578:4, 579:5,
613:7, 621:22 leaving [2] - 498:20, 667:10 579:17, 579:25, 580:4, 580:7, 580:9,
kickbacks [5] - 554:20, 557:13, 557:24, led [3] - 659:8, 660:16, 666:6 581:3, 582:11, 584:15, 584:18,
621:7, 644:7 Leemhuis [1] - 648:12 584:19, 584:24, 585:3, 585:22, 591:4,
kind [1] - 605:1 602:10, 610:20, 610:24, 611:7, 611:8,
left [7] - 516:3, 516:6, 522:21, 525:20,
kindly [2] - 559:9, 559:15 590:2, 656:15, 656:16 611:10, 611:11, 611:12, 611:18,
knowledge [4] - 516:9, 607:6, 615:4, legal [2] - 643:25, 660:12 611:21, 612:17, 612:18, 613:5,
624:12 legible [2] - 582:18, 586:20 613:11, 613:16, 621:19, 621:23,
known [5] - 550:17, 557:23, 577:20, 624:6, 624:9, 624:11, 624:13, 624:14,
Lena [1] - 631:14
584:18, 635:18 624:23, 624:24, 625:24, 626:1, 626:5,
Lena's [1] - 633:3
knows [1] - 532:16 627:21, 631:25, 644:13, 645:4, 646:1,
lend [4] - 501:15, 571:1, 571:4, 664:10
Kouznitsyna [1] - 649:2 646:7, 646:9, 647:2, 647:6, 647:24,
lender [4] - 550:11, 628:6, 647:6,
Kroll [6] - 598:13, 638:17, 638:19, 648:1, 649:10, 650:16, 652:6, 653:3,
664:19
638:20, 653:25, 662:25 662:20, 663:12, 663:13, 664:13,
Lenders [1] - 646:22
KUNTZ [1] - 494:12 664:14, 669:24, 670:3, 670:8, 670:12,
lenders [3] - 580:2, 582:23, 670:11
Kuntz [4] - 496:3, 526:6, 596:3, 656:23 670:14, 670:15, 671:1, 672:12,
lenders /amounts [1] - 579:24
672:15, 672:17, 672:19, 672:20,
length [1] - 661:25
L lengthy [1] - 539:13
672:25, 674:6, 674:7
loans [16] - 500:11, 500:24, 501:1,
lent [1] - 575:22
L-U-C-A-S [1] - 589:11 524:8, 550:6, 576:9, 576:10, 584:6,
Leon [6] - 599:18, 599:24, 663:14,
Labor [1] - 540:18 621:8, 625:6, 646:7, 647:4, 661:17,
663:16, 663:20, 663:22
Ladies [1] - 675:14 661:18, 671:8
less [2] - 501:1, 634:8
ladies [18] - 496:16, 498:6, 498:11, local [1] - 639:2
Letter [1] - 590:21
525:20, 526:23, 536:4, 553:4, 589:20, located [2] - 534:14, 583:9
letter [11] - 560:19, 560:20, 561:16,
590:3, 596:9, 610:4, 610:8, 656:10, logical [1] - 517:5
562:10, 562:11, 604:7, 611:25,
656:16, 657:16, 657:19, 674:12, 675:1 London [11] - 534:16, 542:24, 553:24,
612:15, 612:19, 617:11
lady [4] - 516:12, 516:15, 518:14, 618:5, 635:6, 659:12, 659:17, 663:17,
letters [1] - 605:15
528:17 667:13, 667:25, 673:14
license [1] - 618:7
Langford [17] - 568:10, 568:13, 568:22, look [63] - 502:4, 503:19, 506:24, 512:3,
SAM OCR RMR

16
513:8, 514:25, 520:8, 521:22, 532:4, 579:15, 579:18, 579:20, 580:12, MARGARET [1] - 494:23
533:6, 533:12, 533:18, 539:8, 545:16, 580:23, 581:7, 581:15, 581:18, margin [2] - 510:11, 511:6
548:4, 552:9, 555:14, 558:14, 560:22, 581:20, 582:13, 583:20, 585:16, Mark [3] - 496:9, 673:18, 673:20
570:6, 571:14, 574:10, 577:3, 578:17, 586:13, 586:22, 587:4, 587:5, 596:19, MARK [1] - 494:18
579:15, 579:25, 582:12, 582:15, 598:10, 598:12, 599:9, 603:17, market [10] - 523:23, 523:25, 534:6,
583:24, 585:16, 586:10, 611:14, 603:25, 604:5, 605:5, 605:8, 614:9, 540:6, 542:14, 546:9, 546:25, 547:1,
619:7, 619:18, 621:2, 622:24, 623:3, 614:11, 614:12, 614:13, 615:21, 550:3
627:21, 631:22, 632:2, 634:24, 616:6, 617:9, 638:16, 639:22, 639:25, marketing [3] - 648:3, 671:1, 671:8
635:22, 638:16, 641:18, 641:24, 640:8, 640:11, 640:15, 648:24, Markets [1] - 553:23
642:7, 645:21, 646:13, 647:1, 647:8, 651:16, 651:17, 651:21, 651:24, markets [8] - 539:24, 540:4, 540:17,
649:13, 650:12, 652:7, 654:4, 654:12, 652:1, 653:21, 653:23, 654:4, 654:15, 540:19, 540:21, 540:24, 549:20,
654:23, 663:9, 664:7, 668:1, 671:13, 662:18, 662:20, 663:4, 663:6, 663:7, 549:24
672:4 664:7, 664:17, 664:21, 665:4, 665:13, Markus [8] - 598:13, 638:17, 638:19,
looked [6] - 515:18, 522:25, 611:3, 667:15, 668:20, 668:23, 669:11, 638:20, 638:24, 639:10, 653:25,
645:7, 647:3, 653:3 670:17, 670:19, 670:20, 671:4, 662:25
Looking [1] - 547:14 671:13, 671:14, 672:4, 672:5, 672:9, Marshal [1] - 588:19
looking [21] - 510:6, 512:7, 515:19, 673:2, 673:18 Martin [1] - 637:9
529:25, 547:11, 549:3, 553:13, mailing [2] - 575:23, 585:20 massaging [1] - 633:3
580:23, 604:16, 615:21, 618:23, mails [11] - 512:4, 512:5, 512:11, 537:8, material [1] - 551:4
619:15, 626:18, 626:21, 628:18, 587:9, 596:19, 596:20, 596:23, 654:3, materially [1] - 519:16
640:14, 641:12, 652:17, 653:6, 668:8, 671:10 materials [1] - 512:20
653:23, 655:3 maintain [1] - 614:19 math [3] - 510:12, 510:16, 627:14
Los [1] - 583:10 maintenance [3] - 614:18, 625:6, matter [19] - 541:21, 559:9, 559:15,
lose [1] - 662:3 625:14 561:2, 561:8, 562:14, 600:15, 601:23,
losing [1] - 661:23 major [1] - 629:25 602:1, 603:3, 604:10, 605:19, 606:20,
Loud [1] - 561:4 Makram [9] - 571:22, 578:24, 579:3, 607:13, 607:20, 609:6, 625:21,
loud [1] - 629:15 579:4, 579:21, 585:19, 638:17, 642:25, 675:8
love [4] - 539:17, 543:18, 578:8, 631:14 648:12, 648:13 matters [3] - 568:25, 675:4, 675:7
Love [2] - 631:5, 633:10 Malaf [1] - 556:19 mature [1] - 548:3
lovely [1] - 594:13 Malton [1] - 613:15 max [3] - 500:15, 578:24, 579:3
Lucas [9] - 516:19, 517:7, 531:9, MAM [51] - 500:18, 602:9, 609:11, maximize [1] - 535:3
558:15, 561:8, 588:22, 588:23, 624:7, 624:14, 624:23, 625:2, 625:14, maximized [1] - 500:24
589:10, 589:11 625:24, 626:12, 626:18, 626:25,
maximizing [2] - 500:8, 500:24
Lucas' [1] - 561:16 627:1, 627:21, 627:23, 629:17,
maximum [2] - 570:18, 571:3
Lunch [1] - 595:14 629:22, 630:2, 631:5, 631:7, 631:15,
MCLEOD [1] - 495:6
lunch [7] - 589:22, 594:6, 594:8, 594:13, 631:19, 633:6, 640:5, 641:5, 641:11,
McLeod [2] - 497:10, 497:11
595:12 641:19, 642:3, 642:15, 643:10, 644:6,
mean [48] - 501:3, 505:6, 507:17,
luncheon [1] - 589:4 644:13, 647:10, 647:12, 649:10,
508:14, 508:18, 509:6, 516:14,
lying [1] - 602:9 650:16, 650:17, 652:6, 653:3, 655:12,
516:18, 517:17, 518:3, 518:5, 518:8,
658:5, 658:8, 658:16, 658:23, 659:23,
519:2, 529:14, 530:9, 530:10, 531:7,
660:7, 669:16, 669:24, 670:3, 670:8,
M 531:8, 532:8, 532:9, 533:24, 539:16,
670:12
540:3, 540:13, 541:19, 542:4, 543:16,
M-O-C-A-M-B-I-C-A-N-A [1] - 521:17 MAM's [1] - 629:18
547:25, 561:14, 562:8, 569:11,
Mace [1] - 495:15 man [1] - 666:3
570:14, 570:15, 578:1, 579:2, 587:13,
machines [1] - 552:23 managed [1] - 583:2
609:7, 615:10, 631:6, 631:17, 633:18,
Madam [3] - 526:20, 527:20, 561:8 management [1] - 509:25
648:5, 665:1, 665:19, 669:21, 670:7,
mail [140] - 495:16, 502:4, 502:5, manager [1] - 629:17
672:16
502:12, 502:25, 503:2, 503:4, 504:13, managers [2] - 548:5, 548:10 means [6] - 518:10, 539:22, 546:16,
506:25, 507:4, 507:13, 509:22, managing [2] - 549:23, 566:15 550:18, 554:19, 665:21
510:21, 510:23, 511:3, 511:7, 512:7, Manhattan [2] - 673:22, 673:24 meant [6] - 508:5, 519:3, 540:5, 543:5,
512:16, 513:2, 513:13, 514:25, 515:6, Manuel [8] - 531:11, 543:24, 544:5, 552:21, 573:13
515:19, 515:24, 518:2, 518:11, 521:4, 544:7, 544:12, 588:13, 588:18, 653:8 Mechanics [1] - 645:16
521:8, 521:11, 522:25, 523:11, MAR [9] - 507:10, 507:14, 517:21, media [1] - 559:5
523:13, 524:1, 524:21, 524:25, 525:1, 521:13, 522:3, 522:18, 531:20, meet [1] - 674:1
525:7, 527:10, 527:11, 527:12, 531:21, 574:24
meeting [5] - 519:6, 525:4, 528:22,
528:14, 529:15, 529:25, 530:1, Mar [1] - 569:12
544:12, 616:4
531:23, 532:4, 532:5, 532:12, 532:18, March [12] - 601:18, 612:16, 619:1, meetings [1] - 530:7
533:5, 535:19, 538:2, 538:6, 539:8, 620:1, 621:19, 622:2, 622:11, 622:21,
mega [1] - 629:21
539:9, 542:16, 542:17, 574:6, 575:10, 622:25, 623:8, 672:20, 673:1
mega-discount [1] - 629:21
575:13, 577:3, 577:4, 578:17, 578:19, Margaret [1] - 496:9
MEHTA [1] - 494:19
SAM OCR RMR

17
Mehta [1] - 496:9 mistakes [1] - 519:6 521:25, 522:1, 531:11, 540:12,
Mellon [1] - 650:25 misunderstanding [1] - 561:9 543:25, 547:17, 559:2, 559:12, 560:3,
member [3] - 635:5, 635:19, 666:10 model [11] - 525:10, 527:18, 527:22, 560:9, 560:11, 561:11, 561:20,
members [7] - 581:2, 582:23, 582:25, 528:10, 529:10, 530:7, 530:12, 562:12, 562:13, 570:16, 570:19,
583:2, 584:17, 585:21, 672:13 530:14, 530:24, 626:24, 626:25 570:25, 584:7, 584:9, 587:3, 587:24,
memorandum [1] - 618:10 Modification [1] - 552:22 589:13, 589:17, 625:19, 625:22,
memory [1] - 645:20 MOESER [2] - 494:23, 598:2 627:4, 641:23, 643:23, 644:1, 653:7
mention [3] - 528:15, 532:14, 613:7 Moeser [2] - 496:9, 590:17 MR [465] - 496:9, 496:18, 496:22, 497:7,
mentioned [3] - 501:9, 514:3, 550:1 MOF [2] - 614:16, 614:21 497:10, 497:16, 497:19, 497:24,
messages [1] - 635:24 MoF [2] - 561:12, 669:15 498:25, 500:6, 501:20, 501:23, 502:3,
met [3] - 571:25, 621:20, 666:3 moment [18] - 496:11, 507:2, 514:14, 502:14, 502:18, 502:20, 502:24,
Mets [1] - 674:14 519:24, 521:22, 535:21, 539:25, 504:10, 504:11, 506:13, 506:18,
Mexico [1] - 658:14 555:2, 557:15, 558:4, 558:6, 564:7, 506:23, 511:15, 511:21, 511:23,
mic [3] - 545:19, 558:20, 643:1 612:4, 614:3, 623:12, 641:18, 643:3, 512:2, 513:8, 513:10, 513:15, 513:17,
Michael [1] - 496:23 662:8 514:1, 514:6, 514:8, 514:11, 514:14,
Monday [7] - 539:24, 540:4, 540:6, 514:18, 514:20, 514:24, 515:3, 515:5,
MICHAEL [1] - 495:4
594:21, 634:7, 674:15, 675:17 519:19, 519:24, 520:1, 520:3, 520:6,
microphone [6] - 526:19, 527:19,
money [35] - 500:22, 500:25, 501:1, 520:10, 520:12, 521:2, 522:20, 523:2,
535:23, 553:7, 598:4, 645:9
501:11, 501:14, 501:15, 501:16, 524:9, 524:13, 524:16, 524:19,
mid [1] - 525:15
523:25, 543:8, 550:19, 551:2, 571:18, 524:21, 525:12, 525:24, 526:1,
mid-morning [1] - 525:15
573:11, 573:22, 573:25, 576:13, 526:11, 526:12, 526:15, 527:2, 527:5,
middle [2] - 532:5, 637:1
600:2, 600:7, 616:23, 621:24, 643:16, 527:9, 529:18, 529:21, 529:23,
might [5] - 519:7, 594:7, 594:8, 597:24,
643:19, 650:2, 650:12, 658:4, 660:10, 531:22, 532:12, 532:22, 533:1, 533:3,
643:22
660:22, 660:25, 661:2, 661:5, 661:20, 534:15, 534:19, 535:8, 535:13,
military [1] - 540:20
661:21, 661:23, 662:3, 672:22 535:16, 535:21, 536:2, 537:3, 537:5,
million [84] - 500:19, 500:23, 500:25,
monies [9] - 500:18, 542:7, 569:19, 537:10, 537:13, 537:16, 537:18,
501:10, 501:12, 503:24, 504:1, 504:2,
573:19, 574:4, 658:19, 658:23, 660:7, 537:20, 538:1, 538:7, 539:4, 542:18,
504:3, 508:1, 508:3, 508:7, 508:8,
660:20 545:2, 545:5, 545:10, 545:12, 545:15,
508:12, 508:13, 509:11, 510:9,
months [2] - 503:23, 632:2 545:21, 545:24, 547:2, 547:5, 547:9,
510:11, 510:19, 510:20, 517:23,
Morgan [15] - 533:19, 534:4, 534:12, 547:10, 547:12, 547:13, 548:10,
523:4, 523:6, 524:5, 524:6, 541:4,
534:14, 534:23, 535:2, 535:6, 546:8, 548:16, 550:9, 550:13, 550:23,
541:8, 541:10, 541:12, 541:16,
546:11, 546:12, 546:14, 546:18, 550:25, 551:9, 551:12, 552:16,
541:25, 542:14, 547:17, 547:22,
546:20, 559:7, 669:14 552:25, 553:6, 553:11, 553:12, 554:4,
556:25, 573:4, 573:6, 574:16, 575:22,
554:24, 555:2, 555:5, 555:10, 555:25,
576:7, 580:7, 582:11, 583:8, 585:25, morning [19] - 496:12, 496:14, 496:20,
556:2, 557:10, 557:15, 557:18,
613:1, 613:3, 614:16, 616:22, 625:25, 496:21, 496:22, 496:24, 496:25,
557:20, 558:1, 558:4, 558:6, 558:8,
626:8, 626:9, 627:13, 627:15, 627:17, 497:2, 497:4, 497:6, 497:7, 497:9,
558:10, 558:13, 558:21, 558:22,
629:23, 629:24, 631:5, 631:8, 631:15, 497:10, 497:12, 498:6, 498:17,
559:21, 559:24, 562:21, 563:3, 563:6,
631:18, 631:20, 631:21, 631:25, 525:15, 549:3, 614:14
563:10, 563:15, 563:18, 563:20,
632:7, 642:1, 652:5, 652:6, 654:8, Morning [1] - 631:5
564:4, 564:7, 564:10, 564:13, 564:21,
655:16, 658:18, 659:17, 659:18, most [7] - 503:18, 517:5, 533:6, 562:15,
564:24, 565:4, 565:12, 565:14,
659:21, 660:6, 660:25, 661:1, 661:9, 571:25, 576:1, 639:2
565:17, 566:17, 566:20, 567:4, 567:7,
662:3, 669:15, 672:19 motivate [1] - 506:10
568:7, 568:9, 569:21, 569:24, 570:2,
millions [1] - 648:14 Move [1] - 634:2
570:5, 571:5, 571:8, 571:13, 573:2,
min [1] - 517:12 move [15] - 501:20, 502:15, 526:19,
574:11, 574:14, 575:1, 575:4, 575:6,
mind [2] - 506:10, 598:20 539:23, 540:3, 540:5, 545:9, 545:22,
575:9, 575:12, 576:19, 576:22, 577:2,
mine [2] - 516:10, 577:19 595:7, 612:7, 623:15, 633:19, 645:8,
577:22, 578:9, 578:12, 578:17,
Minister [5] - 516:16, 518:19, 531:5, 658:5, 668:13
578:18, 579:6, 579:9, 579:14, 580:14,
531:10, 543:24 moving [1] - 529:8
580:17, 580:22, 581:4, 581:9, 581:12,
Ministery [1] - 562:16 Moz [2] - 614:19, 669:15
581:23, 581:25, 582:2, 582:7, 582:19,
Ministry [11] - 513:14, 516:20, 517:2, Moza [1] - 669:6
582:21, 583:11, 583:14, 583:19,
517:6, 517:8, 517:25, 518:19, 552:3, Mozambican [15] - 516:22, 519:11, 584:25, 585:7, 585:10, 585:15, 586:1,
561:10, 561:19, 670:2 528:22, 529:16, 559:3, 584:16, 586:4, 586:9, 586:21, 587:9, 589:5,
ministry [1] - 517:5 584:18, 584:22, 584:23, 661:17, 589:8, 589:9, 589:18, 590:6, 590:10,
minute [1] - 653:4 668:4, 668:6, 671:1, 671:8 590:12, 592:5, 592:7, 593:7, 594:2,
minutes [6] - 517:16, 525:17, 526:3, Mozambicana [1] - 521:13 594:15, 594:21, 595:11, 595:13,
581:14, 581:17, 656:21 Mozambicans [1] - 625:4 596:11, 596:14, 596:18, 596:25,
misreading [1] - 609:10 Mozambique [48] - 501:6, 503:16, 597:2, 597:6, 597:10, 597:15, 597:17,
misrepresentation [1] - 590:19 504:5, 504:8, 506:8, 506:10, 512:23, 597:19, 597:20, 598:5, 598:7, 598:10,
miss [1] - 597:19 513:14, 513:21, 513:23, 515:17, 598:12, 598:19, 599:3, 599:7, 599:9,
misstatements [1] - 605:1 516:17, 516:20, 517:3, 517:5, 518:7, 599:15, 599:24, 600:6, 600:13, 601:1,
SAM OCR RMR

18
601:4, 601:8, 601:14, 601:17, 601:20, 588:14, 588:17, 588:19, 588:21, noise [2] - 614:20, 614:24
601:24, 602:2, 602:5, 602:20, 602:23, 589:6, 614:17, 647:15, 663:24 nominees [2] - 665:18, 665:20
603:1, 603:4, 603:6, 603:13, 603:15, namely [2] - 522:2, 634:13 non [5] - 591:15, 594:8, 609:14, 669:18,
603:17, 603:21, 603:23, 603:25, names [3] - 505:16, 505:20, 505:22 670:6
604:4, 604:11, 604:15, 604:22, 605:6, naming [1] - 505:5 non-existent [1] - 609:14
605:12, 606:2, 606:4, 606:7, 606:12, Natalia [1] - 649:2 non-skier [1] - 591:15
606:14, 606:17, 606:19, 606:25, national [2] - 560:12, 588:24 non-trading [2] - 669:18, 670:6
607:3, 607:7, 607:10, 607:14, 607:16, National [2] - 516:19, 531:10 non-wimpy [1] - 594:8
607:19, 607:22, 608:1, 608:14, nations [1] - 625:22 none [1] - 580:17
608:16, 608:19, 609:1, 609:3, 609:6, Natural [11] - 599:25, 600:3, 600:17, NOP [2] - 629:24, 630:5
609:12, 609:16, 609:17, 609:19, 600:22, 658:10, 658:11, 660:24, normal [1] - 534:6
609:21, 610:17, 610:18, 610:22, 661:8, 663:18, 663:19, 663:21 normally [1] - 534:7
611:1, 611:14, 612:1, 612:4, 612:8, nature [2] - 596:23, 645:3 notarial [1] - 618:4
612:11, 612:23, 613:21, 613:25, naval [1] - 501:5 notary [1] - 618:4
614:3, 614:5, 615:5, 615:14, 615:17, Navantia [1] - 505:17 note [9] - 496:25, 547:22, 548:17,
617:17, 617:20, 618:2, 618:12, necessary [1] - 643:24 556:12, 559:2, 561:1, 561:19, 571:17,
618:15, 618:21, 620:8, 620:11, 623:9, need [19] - 502:10, 519:12, 519:25, 602:5
623:12, 623:16, 623:19, 623:22, 520:4, 525:22, 552:13, 569:8, 587:13, notes [1] - 550:18
624:1, 624:5, 624:19, 624:21, 625:1, 595:5, 596:8, 596:21, 602:11, 605:20, Nothing [1] - 633:4
628:10, 628:13, 628:17, 628:23,
605:24, 609:18, 615:24, 628:3, nothing [4] - 552:10, 552:11, 600:20,
628:25, 629:4, 629:8, 629:10, 630:10, 631:10, 649:13 634:7
630:16, 630:19, 630:24, 632:11,
needed [5] - 519:3, 542:13, 587:15, notice [4] - 600:21, 604:23, 604:25,
632:14, 632:18, 632:20, 634:2, 634:5,
619:7, 661:20 606:22
634:15, 634:18, 634:23, 636:15,
needs [3] - 518:25, 533:18, 634:9 Notice [2] - 581:1, 582:9
636:18, 636:20, 636:23, 637:3, 637:5,
Negative [1] - 631:14 November [4] - 579:19, 583:21, 662:18,
638:2, 638:3, 638:6, 638:9, 638:11,
negotiate [1] - 557:2 664:8
638:15, 639:12, 639:15, 639:17,
negotiated [1] - 556:24 Number [1] - 496:5
639:22, 639:24, 640:6, 640:7, 640:10,
net [1] - 649:7 number [8] - 503:16, 509:9, 535:3,
640:17, 640:20, 640:22, 641:1,
Net [2] - 630:6, 630:7 570:22, 594:3, 633:10, 633:19, 666:18
641:14, 641:16, 642:7, 642:10,
network [1] - 629:22 numbers [3] - 509:9, 576:2, 639:14
642:12, 642:17, 642:21, 642:24,
never [1] - 529:13 numeral [4] - 522:12, 522:16, 522:22,
643:2, 643:5, 643:7, 643:9, 644:9,
644:12, 645:12, 645:23, 645:25, NEW [1] - 494:1 641:24
646:15, 646:18, 646:20, 646:24, new [2] - 614:16, 615:11
646:25, 647:12, 647:16, 647:20, New [30] - 494:6, 494:17, 494:18, O
647:21, 648:9, 648:16, 648:19, 494:22, 495:4, 645:18, 646:4, 650:13,
650:25, 652:16, 658:14, 667:13, o'clock [5] - 589:21, 610:12, 610:14,
648:23, 650:8, 650:9, 650:21, 650:23,
667:25, 668:5, 668:7, 668:8, 669:1, 674:9, 674:11
651:7, 651:10, 651:15, 652:7, 652:9,
652:22, 653:2, 653:9, 653:12, 653:16, 671:11, 671:12, 671:17, 673:3, Objection [4] - 557:10, 559:21, 629:4,
653:20, 654:4, 654:6, 654:12, 654:14, 673:10, 673:11, 673:21, 673:25, 674:4 634:2
654:18, 655:4, 655:7, 656:2, 656:7, Newark [2] - 673:10, 673:11 objection [140] - 501:22, 501:23,
656:20, 658:2, 658:3, 660:2, 662:5, news [1] - 579:24 502:17, 506:17, 511:19, 514:5,
662:8, 662:12, 662:16, 663:7, 666:19, newspaper [1] - 539:23 514:13, 514:18, 519:23, 520:9,
666:21, 666:23, 667:3, 667:5, 667:15, next [38] - 515:19, 518:24, 521:17, 520:12, 524:12, 524:16, 527:4, 527:5,
667:18, 668:1, 668:12, 668:15, 522:11, 523:16, 531:4, 541:3, 541:15, 529:20, 529:21, 532:25, 533:1,
670:16, 671:20, 671:23, 673:7, 542:16, 544:15, 551:18, 552:8, 534:15, 534:19, 535:10, 535:13,
673:16, 674:8, 675:6, 675:9, 675:11, 553:16, 572:3, 573:9, 599:6, 601:7, 535:23, 535:24, 535:25, 536:1, 537:6,
675:12, 676:6 602:22, 603:5, 603:14, 603:22, 606:4, 537:8, 537:11, 537:15, 539:2, 545:4,
MS [2] - 497:4, 598:2 606:10, 606:16, 607:10, 607:15, 545:9, 545:10, 547:4, 547:5, 555:1,
607:25, 614:21, 617:25, 623:20, 555:5, 558:3, 558:8, 559:24, 563:5,
multiple [2] - 503:14, 573:21
637:22, 647:18, 648:10, 659:19, 563:6, 564:6, 564:8, 564:23, 566:19,
multiplied [2] - 509:9, 510:15
664:17, 670:16, 674:22 567:7, 568:2, 569:23, 569:24, 571:7,
multiply [1] - 510:9
nice [2] - 595:12, 675:14 571:8, 575:3, 576:21, 576:22, 578:11,
Nicholas [2] - 559:1, 560:5 578:12, 579:8, 579:9, 580:16, 581:4,
N 581:25, 582:1, 583:13, 583:14,
nickname [3] - 518:9, 544:1, 577:16
Naji [7] - 575:14, 640:3, 652:2, 653:24, nicknames [1] - 588:1 584:25, 585:4, 585:9, 585:10, 586:3,
Nicolas [1] - 558:16 586:4, 590:25, 592:23, 597:5, 599:14,
654:1, 654:15, 654:20
Nielsen [1] - 496:10 600:8, 600:12, 600:14, 601:9, 601:19,
Najib [11] - 566:4, 604:5, 605:13,
NIELSEN [1] - 494:23 604:21, 606:4, 606:7, 607:17, 607:24,
615:21, 616:3, 616:11, 619:1, 619:21,
night [1] - 542:24 608:13, 608:18, 609:5, 612:3, 612:7,
621:9, 622:17, 654:8
612:8, 613:24, 614:2, 614:5, 615:5,
name [11] - 503:5, 521:19, 552:22, nobody [2] - 608:9, 608:11
SAM OCR RMR

19
615:16, 615:17, 617:19, 618:14, 604:11, 604:19, 604:20, 606:9,

P
623:11, 623:16, 623:24, 624:1, 606:16, 607:10, 607:12, 607:21,
628:12, 628:13, 630:18, 630:19, 608:8, 609:4, 611:7, 611:12, 620:10, p.m [6] - 542:17, 568:11, 580:13, 581:8,
632:13, 632:14, 634:17, 634:18, 620:19, 622:10, 623:3, 627:16, 628:7, 664:9, 664:21
636:17, 638:5, 638:8, 638:9, 639:16, 642:14, 642:25, 645:1, 647:5, 647:6, package [4] - 570:11, 597:13, 597:24,
639:17, 640:19, 640:20, 642:20, 647:22, 650:2, 655:1, 655:16, 660:9, 629:21
642:21, 648:18, 648:19, 651:9, 660:14, 664:23, 669:18, 670:6, Page [1] - 551:10
651:10, 653:11, 653:12, 660:2, 662:7, 670:14, 671:7 page [81] - 499:5, 503:2, 504:10,
662:12, 666:21, 666:22, 666:23, one-third [6] - 500:19, 500:21, 655:16, 506:25, 512:4, 513:12, 515:1, 515:2,
668:14, 668:15, 671:22, 671:23 660:9, 660:14, 664:23 520:19, 521:10, 521:21, 522:7,
objections [1] - 605:22 ones [2] - 580:10, 645:6 522:11, 522:16, 533:5, 533:6, 537:7,
obligation [1] - 672:19 online [1] - 538:4 538:10, 541:3, 542:16, 544:15,
observe [4] - 658:25, 659:7, 659:11, onwards [1] - 666:5 547:16, 548:4, 550:7, 550:10, 551:7,
666:6 ooo0ooo [2] - 495:10, 675:21 551:9, 551:13, 551:15, 551:18,
observed [1] - 659:12 open [9] - 496:1, 526:5, 539:1, 563:24, 551:19, 552:8, 553:16, 554:5, 556:5,
obtained [1] - 576:17 564:2, 568:1, 596:2, 596:22, 596:24 556:7, 563:22, 565:15, 565:19, 572:3,
obtaining [2] - 566:7, 643:24 opening [1] - 566:6 586:17, 587:4, 593:9, 597:23, 599:16,
obviously [1] - 528:16 operating [3] - 569:19, 630:6, 630:7 611:1, 611:4, 611:14, 613:14, 615:21,
occasion [1] - 674:2 operation [2] - 551:3, 559:8 616:6, 617:25, 618:10, 632:19,
occasionally [2] - 537:23, 595:2 operational [1] - 635:10 635:22, 637:1, 637:22, 639:23,
occasions [2] - 666:16, 666:18 OPEX [1] - 569:10 640:14, 641:6, 641:12, 641:24, 642:2,
occur [2] - 528:9, 573:25 opinion [3] - 523:7, 534:23, 664:14 642:11, 643:7, 645:21, 645:23,
occurred [1] - 537:1 opportunity [1] - 651:17 646:14, 646:24, 647:12, 647:18,
occurring [1] - 636:1 opposite [1] - 674:15 648:10, 649:20, 653:6, 655:1, 655:4,
October [12] - 494:7, 570:8, 571:15, option [1] - 503:19 655:19, 664:8, 670:16, 674:22
573:3, 575:17, 577:5, 578:20, 672:6, options [1] - 503:17 PAGE [1] - 676:3
672:11, 673:12, 673:15, 675:17 order [19] - 513:4, 515:23, 523:20, pages [4] - 556:6, 556:9, 642:2, 647:9
OF [4] - 494:1, 494:3, 494:11, 494:21 523:23, 523:25, 531:1, 531:20, 534:8, paid [20] - 500:23, 501:16, 522:18,
offer [12] - 503:15, 506:15, 519:21, 541:23, 559:10, 559:14, 563:23, 541:13, 550:19, 568:21, 569:17,
527:3, 532:23, 534:5, 594:4, 605:25, 564:2, 580:9, 582:10, 633:25, 636:3, 575:25, 576:3, 611:16, 622:5, 626:5,
613:22, 614:1, 623:23, 643:16 648:2, 654:2 627:5, 627:6, 627:24, 629:20, 648:14,
offered [5] - 598:14, 599:10, 601:22, ordering [1] - 650:18 655:13, 655:17
601:25, 603:2 Ordinance [1] - 552:22 painful [3] - 616:11, 619:1, 657:10
offering [20] - 547:16, 547:18, 548:18, original [6] - 501:9, 503:24, 576:5, Paki [1] - 556:19
549:13, 550:8, 550:10, 550:16, 551:8, 647:6, 672:18, 672:24 Palomar [70] - 500:17, 568:16, 568:19,
551:13, 551:16, 552:5, 552:7, 556:10, originally [2] - 658:14, 662:24 568:21, 569:4, 569:5, 569:7, 569:12,
567:3, 597:5, 603:19, 604:10, 605:17, otherwise [1] - 643:19 569:18, 575:19, 575:25, 576:1,
607:1, 607:21 ought [1] - 591:14 576:12, 599:25, 600:3, 600:17,
office [1] - 534:16 oumri [2] - 543:15, 543:18 600:22, 607:22, 608:22, 617:10,
Official [1] - 495:16 outside [12] - 523:19, 523:21, 523:23, 617:11, 618:7, 618:11, 626:10,
official [1] - 660:11 525:23, 536:5, 540:13, 546:20, 559:6, 626:11, 638:18, 638:19, 638:20,
officially [1] - 663:1 581:3, 584:21, 590:4, 643:23 638:25, 639:7, 647:19, 647:25, 648:1,
officials [4] - 528:22, 584:9, 584:16, ouuuuuu [1] - 543:15 648:6, 654:10, 654:21, 655:1, 655:13,
584:23 655:17, 658:9, 658:11, 660:7, 660:8,
oval [1] - 498:3
Offshore [1] - 606:20 660:9, 660:11, 660:14, 660:17,
overhead [1] - 509:25
offshore [3] - 504:21, 504:22, 509:18 660:18, 660:21, 660:24, 661:8,
overrule [5] - 598:24, 600:8, 607:24,
oil [4] - 658:13, 659:6, 661:8, 663:17 662:21, 662:22, 662:23, 663:1,
608:13, 608:25
663:14, 663:18, 663:19, 663:21,
old [4] - 498:9, 552:19, 605:25, 608:8 Overruled [5] - 538:8, 557:11, 560:1,
664:15, 664:19, 665:3, 665:5, 665:17,
Oliver [1] - 608:7 609:2, 634:4
665:23, 672:14, 672:23, 674:6
omissions [4] - 590:15, 590:18, 590:23, overruled [6] - 539:2, 585:4, 599:4,
Palomar 's [2] - 569:19, 614:17
591:1 600:12, 601:6, 609:15
panicking [1] - 669:17
once [1] - 610:6 oversight [1] - 517:6
Pantero [2] - 588:14, 588:17
One [2] - 537:13, 625:3 own [7] - 521:24, 534:25, 554:17,
paper [2] - 525:1, 537:22
one [65] - 500:19, 500:21, 503:19, 641:19, 665:9, 665:10, 665:11
papers [1] - 517:11
504:7, 504:9, 506:6, 506:12, 507:18, owned [6] - 582:25, 659:20, 660:14,
paragraph [7] - 612:23, 620:10, 620:15,
512:16, 519:14, 519:24, 524:14, 664:25, 665:1, 665:7
623:3, 627:8, 627:9, 644:5
533:18, 537:23, 542:23, 551:9, owner [3] - 500:21, 660:14, 660:17
551:23, 557:15, 557:22, 587:14, Paribas [2] - 548:13, 549:16
owners [1] - 569:17
590:14, 593:7, 594:2, 596:19, 597:24, Paris [3] - 543:22, 544:5, 544:6
ownership [1] - 660:12
598:6, 599:17, 602:21, 604:4, 604:9, Parliament [1] - 540:19
SAM OCR RMR

20
part [23] - 503:9, 503:11, 508:20, 546:4, 604:18, 604:20, 605:12, 606:6, 646:12, 662:5, 672:13
552:7, 554:21, 556:3, 584:9, 586:22, 606:13, 607:3, 607:17, 607:23, points [1] - 507:21
600:18, 604:24, 605:5, 605:16, 608:17, 608:25, 609:4, 609:25, 610:9, Poland [1] - 658:15
614:23, 627:2, 629:22, 637:3, 658:9, 610:19, 610:23, 610:24, 611:5, Polish [1] - 663:19
658:18, 664:9, 665:5, 672:20, 674:7 612:14, 616:8, 618:3, 619:19, 620:12, political [1] - 570:15
participants [1] - 670:3 631:1, 632:21, 640:8, 653:21, 654:1, pops [1] - 598:8
participate [1] - 559:8 654:25, 655:8, 657:4, 658:4, 658:8, portion [6] - 512:3, 532:1, 532:4,
participation [5] - 547:22, 548:17, 662:22, 663:8, 667:6, 672:12, 673:8, 550:14, 551:11
550:18, 556:12, 561:19 673:17, 673:25, 674:19 portions [1] - 605:25
particular [2] - 587:16, 595:6 Pearse's [2] - 599:18, 605:14 Portuguese [5] - 505:5, 505:8, 505:11,
particularly [2] - 525:9, 534:9 penny [1] - 617:2 556:3, 556:6
parties [6] - 521:12, 529:16, 625:9, people [4] - 516:21, 588:2, 605:17, position [7] - 511:13, 513:21, 529:17,
641:10, 643:13, 671:7 608:6 560:11, 566:11, 566:13, 643:18
partner [6] - 500:17, 569:4, 575:25, per [4] - 508:24, 509:7, 509:8 positive [1] - 631:14
576:12, 660:9, 660:11 percent [11] - 510:5, 510:10, 510:15, possession [1] - 628:8
Partners [1] - 655:17 541:5, 541:12, 664:25, 665:1, 665:7, possibility [1] - 669:24
partners [2] - 575:25, 665:24 665:9, 665:10, 665:12 possible [10] - 502:11, 511:10, 511:13,
partnership [1] - 660:19 percentage [1] - 510:3 541:16, 559:16, 570:16, 644:23,
parts [7] - 519:11, 535:1, 580:3, 629:18, Perez [1] - 635:3 646:13, 654:2, 663:5
629:23, 629:25, 630:2 performance [1] - 528:2 posting [1] - 655:3
party [2] - 542:24, 621:24 perhaps [1] - 537:23 potential [8] - 552:6, 556:11, 586:15,
pass [1] - 635:18 period [9] - 503:22, 515:14, 516:8, 611:19, 633:25, 669:6, 671:7, 674:6
passed [1] - 550:20 542:6, 542:8, 579:19, 659:23, 666:5, potentially [7] - 503:17, 518:20, 534:17,
passport [5] - 563:22, 564:19, 565:6, 666:17 535:4, 540:11, 546:19, 609:8
565:19, 565:23 permission [3] - 514:12, 552:19, 644:1 pound [1] - 508:1
past [3] - 589:21, 592:24, 614:14 permissions [1] - 643:24 pounds [1] - 659:17
paste [1] - 605:25 permit [2] - 566:1, 566:7 practice [1] - 627:9
patience [1] - 657:20 person [9] - 568:24, 573:14, 576:1, Preamble [1] - 641:15
patrol [2] - 504:21, 504:22 589:1, 589:6, 613:11, 643:15, 643:18, preamble [2] - 521:22, 522:9
Pauline [3] - 563:23, 564:17, 564:18 648:13 preceding [3] - 621:15, 654:3, 663:5
pause [5] - 498:5, 514:17, 520:11, personal [3] - 511:1, 511:3, 513:1 precious [1] - 595:9
641:21, 651:20 personally [1] - 543:5 precise [4] - 633:10, 633:19, 633:25,
Pause [1] - 557:19 personnel [1] - 519:14 634:8
pay [14] - 542:15, 554:20, 569:12, petty [1] - 625:14 prefer [1] - 504:14
573:25, 574:4, 608:3, 608:4, 608:5, PH [3] - 569:8, 664:10, 664:24 prejudicial [1] - 608:3
608:9, 608:11, 611:24, 643:16, 644:6 PHILIP [1] - 495:6 premature [1] - 592:4
paying [8] - 571:18, 573:14, 573:20, Philip [1] - 497:8 prepare [1] - 530:23
573:23, 574:1, 574:2, 608:2, 608:6 phone [1] - 635:18 prepared [7] - 501:15, 518:25, 528:3,
Payment [2] - 645:16, 649:6 phonetic [1] - 664:2 528:5, 528:6, 529:10, 661:22
payment [13] - 542:7, 542:11, 564:3, phoning [1] - 636:4 preparing [1] - 513:5
574:8, 578:2, 591:4, 637:10, 645:18, photo [1] - 565:19 presence [3] - 496:25, 525:23, 590:5
649:17, 651:23, 655:11, 660:20, 673:1 picture [1] - 565:15 present [9] - 496:1, 526:5, 539:1, 568:1,
payments [15] - 542:9, 557:6, 573:16, piece [2] - 575:20 595:6, 596:2, 596:6, 596:16, 605:20
608:25, 621:3, 621:6, 621:7, 621:11, pieces [1] - 506:6 presentation [1] - 544:10
622:4, 623:4, 623:8, 643:13, 646:1, PISB [1] - 619:6 presented [1] - 592:18
646:3, 672:22 pisses [2] - 608:4, 608:5 preserved [1] - 599:5
pays [2] - 573:16, 573:19 place [5] - 541:9, 542:2, 557:5, 591:4, preserves [1] - 605:22
PCAAD [2] - 664:24, 665:1 632:8 President [3] - 518:6, 518:7, 531:11
PEARSE [1] - 676:5 plan [8] - 525:11, 539:21, 579:1, 625:10, president [3] - 587:3, 587:24, 589:13
Pearse [90] - 498:17, 500:7, 502:4, 625:17, 626:3, 632:4, 633:24 presiding [4] - 496:4, 526:6, 596:4,
502:12, 502:25, 503:4, 503:7, 504:12, plans [1] - 628:8 656:24
506:24, 509:1, 510:6, 512:5, 513:11, play [1] - 610:13 presumably [1] - 601:15
513:18, 515:4, 515:6, 523:12, 524:20, Plaza [1] - 494:17 pretending [1] - 637:18
525:19, 527:10, 527:13, 527:23, PLC [2] - 650:19, 652:14 pretrial [2] - 590:13, 590:16
530:1, 533:20, 542:17, 547:11, 551:1, plus [3] - 509:8, 529:2, 576:1 pretty [3] - 504:15, 609:14, 629:3
551:13, 553:14, 557:22, 558:23, point [25] - 507:24, 508:5, 508:14, prevailing [1] - 639:11
564:14, 565:5, 570:6, 578:19, 579:16, 509:4, 509:19, 510:6, 511:8, 517:22, prevent [1] - 594:25
586:10, 589:10, 589:25, 598:12, 534:11, 535:2, 571:3, 583:1, 592:24, prevented [1] - 529:8
600:1, 600:10, 600:19, 601:12, 600:9, 600:13, 601:3, 602:7, 608:19, previous [10] - 506:12, 509:21, 513:13,
602:17, 604:6, 604:13, 604:14, 616:21, 635:23, 636:2, 637:20,
SAM OCR RMR

21
513:22, 515:18, 521:11, 532:17, 523:17, 524:4, 524:7, 524:8, 551:22, 541:21, 584:19, 596:10, 610:8,
624:18, 631:22 553:19, 579:5, 579:17, 580:4, 580:7, 614:20, 614:24, 615:3, 615:4, 615:12,
previously [4] - 500:3, 569:15, 580:8, 581:2, 582:10, 582:11, 582:24, 618:4, 669:25, 670:4, 675:14
663:22 584:15, 584:19, 584:24, 585:3, publicity [1] - 661:17
price [15] - 503:6, 504:14, 508:6, 508:9, 585:22, 602:9, 609:11, 610:20, publicize [1] - 648:3
522:18, 522:22, 522:23, 523:1, 523:3, 610:24, 612:16, 613:2, 613:5, 613:12, publicly [1] - 570:24
533:17, 540:10, 541:5, 541:12, 614:18, 614:20, 614:23, 615:2, publish [62] - 501:24, 502:19, 506:19,
629:19, 641:25 620:20, 621:8, 621:11, 621:19, 511:22, 514:7, 514:19, 520:14,
prices [7] - 627:3, 627:21, 627:23, 621:23, 622:13, 625:5, 625:8, 625:13, 524:17, 527:6, 529:22, 533:2, 535:11,
627:24, 630:2, 630:11, 630:14 627:6, 628:7, 630:2, 647:4, 658:22, 535:14, 539:3, 545:7, 545:11, 547:6,
pricing [2] - 509:20, 511:5 672:10, 672:12, 672:15, 672:16, 555:6, 558:9, 563:7, 564:9, 564:25,
primarily [1] - 534:2 672:18, 672:22, 672:25, 674:6 568:3, 569:25, 571:9, 575:5, 576:23,
primary [2] - 511:8, 625:3 project [52] - 501:10, 501:11, 501:14, 578:13, 579:10, 580:18, 582:3,
prisoner [1] - 603:11 501:15, 504:5, 504:9, 504:20, 505:24, 583:15, 585:11, 586:5, 597:7, 597:22,
private [3] - 512:11, 561:11, 666:9 506:11, 507:12, 507:15, 511:6, 612:5, 612:9, 614:4, 615:18, 617:21,
Privinvest [54] - 503:10, 503:24, 504:3, 513:20, 513:25, 515:16, 516:13, 618:17, 623:14, 623:17, 628:14,
504:8, 505:12, 506:9, 507:11, 507:16, 516:24, 517:3, 517:4, 518:6, 518:13, 630:21, 632:15, 634:20, 636:19,
508:20, 508:23, 509:13, 509:23, 518:20, 518:23, 519:4, 519:12, 638:10, 639:18, 640:21, 642:22,
510:10, 511:5, 542:10, 542:12, 519:15, 519:18, 525:9, 528:2, 528:7, 648:20, 651:11, 652:23, 652:25,
542:15, 543:8, 551:5, 556:25, 557:2, 528:8, 528:12, 528:21, 531:9, 532:16, 653:13, 662:15, 667:2, 668:18, 672:2
564:3, 566:10, 568:20, 574:5, 574:22, 532:20, 548:23, 548:24, 549:11, published [52] - 502:2, 502:23, 506:22,
576:14, 576:16, 576:18, 604:7, 554:7, 554:9, 576:17, 578:25, 624:15, 512:1, 513:9, 513:16, 514:23, 520:17,
616:24, 617:1, 617:3, 619:22, 619:23, 625:2, 626:2, 626:12, 626:19, 627:2, 527:8, 535:18, 548:12, 553:23, 565:3,
620:6, 620:20, 620:23, 621:6, 622:6, 630:15, 633:23, 643:21 568:6, 570:22, 575:11, 577:1, 578:16,
625:20, 626:11, 629:17, 629:20, projection [1] - 528:1 579:13, 580:21, 581:11, 582:6,
629:22, 633:15, 641:4, 641:11, 642:5, projector [2] - 552:19, 552:20 582:17, 583:18, 585:14, 586:8,
651:5, 652:19, 655:14, 660:13 projects [7] - 500:23, 501:4, 572:1, 587:10, 612:13, 614:8, 615:20,
problem [8] - 528:23, 570:12, 598:16, 628:9, 658:23, 668:4, 668:6 617:24, 638:14, 639:21, 640:25,
604:17, 604:19, 605:14, 605:16, promise [1] - 657:12 641:13, 642:9, 643:8, 644:11, 645:24,
605:20 promised [3] - 657:17, 670:23, 674:11 646:17, 649:15, 651:14, 652:8, 653:1,
procedural [6] - 497:13, 526:9, 596:7, promising [1] - 554:20 653:19, 654:5, 654:13, 654:19,
656:17, 675:4, 675:7 promptness [3] - 498:7, 526:24, 610:6 654:24, 662:17, 668:19, 672:3
proceed [1] - 568:8 pronounced [1] - 643:11 Publishes [15] - 545:14, 547:8, 555:7,
proceeding [1] - 592:24 pronunciation [1] - 649:3 558:12, 563:9, 564:12, 570:4, 571:12,
Proceedings [1] - 495:17 proof [4] - 592:13, 592:15, 592:17, 618:20, 624:4, 628:16, 630:23,
proceedings [1] - 557:19 592:25 632:17, 634:22, 636:22
Proceeds [1] - 550:24 properties [2] - 659:15, 659:16 publishes [1] - 546:9
proceeds [1] - 617:3 Property [2] - 510:24, 563:17 pull [3] - 527:19, 558:19, 643:1
process [14] - 503:9, 503:12, 503:13, property [2] - 659:12, 659:19 Pull [1] - 545:19
507:6, 511:9, 516:22, 516:24, 517:19, proposal [2] - 544:13, 625:18 purchase [2] - 540:14, 580:7
519:13, 519:16, 531:20, 531:21, propose [1] - 643:16 purchased [2] - 522:2, 543:9
625:8, 674:7 proposed [3] - 584:11, 584:14, 663:13 purchases [1] - 659:22
procurement [14] - 521:6, 542:10, proposing [2] - 541:10, 584:1 pure [2] - 510:2, 591:1
543:8, 551:5, 614:22, 627:24, 632:4, prospect [1] - 579:5 purpose [2] - 554:5, 607:21
633:6, 633:14, 641:4, 641:10, 641:20, protocol [1] - 562:15 Purpose [2] - 644:24, 645:3
641:25, 643:10 provide [10] - 503:14, 520:3, 520:5, purposes [2] - 604:1, 625:3
produced [6] - 495:17, 537:22, 596:7, 520:7, 522:4, 620:5, 625:6, 630:13, pursuant [1] - 590:21
606:23, 620:19, 657:1 638:24, 641:22 put [11] - 507:18, 581:9, 591:10, 600:1,
producing [1] - 526:7 provided [18] - 505:22, 515:23, 519:3, 603:16, 606:5, 660:24, 660:25, 661:9,
product [1] - 622:11 528:6, 531:9, 537:18, 577:10, 577:23, 661:22
productive [1] - 594:11 604:25, 605:7, 619:23, 622:13, putting [2] - 505:19, 592:14
products [4] - 504:16, 546:16, 546:23, 622:14, 626:25, 627:3, 627:23,
620:7 633:23, 642:15 Q
profit [3] - 510:11, 511:6, 630:6 provides [1] - 659:5
Profit [1] - 630:8 providing [5] - 505:21, 508:20, 511:11, questions [26] - 504:7, 512:22, 513:2,
profitability [1] - 507:15 530:25, 533:15 513:3, 513:4, 513:5, 513:12, 513:19,
profitable [2] - 543:11, 664:13 provision [5] - 510:11, 560:8, 644:4, 513:24, 515:17, 516:25, 517:9, 518:1,
profits [1] - 500:21 646:11, 670:13 518:12, 518:22, 519:8, 519:13, 525:3,
prohibited [1] - 643:19 provisions [1] - 670:14 525:5, 530:18, 532:10, 584:5, 591:1,
public [17] - 496:16, 498:12, 539:22, 610:19, 633:21
Proindicus [58] - 503:24, 503:25, 504:2,
SAM OCR RMR

22
quit [1] - 537:21 recess [2] - 589:4, 595:14 619:12, 644:1, 644:2
quite [3] - 591:21, 595:8, 623:7 recite [1] - 661:3 relied [1] - 625:13
quotes [1] - 503:14 recognize [4] - 524:20, 564:14, 621:2, remain [1] - 570:12
654:25 remedies [1] - 605:25
R recollection [2] - 554:11, 654:2 remember [1] - 498:2
reconciliation [1] - 654:10 remind [1] - 532:14
raise [3] - 501:11, 570:16, 606:19 Record [1] - 534:21 remittance [1] - 651:3
Rand [1] - 669:14 record [10] - 496:8, 541:22, 552:11, remitted [1] - 651:1
RANDALL [1] - 495:5 591:1, 592:22, 595:2, 596:24, 599:5, remove [3] - 633:10, 633:19, 633:24
Randall [1] - 496:18 605:22, 605:23 Remuneration [1] - 643:11
randomly [1] - 634:8 recorded [1] - 495:17 renovated [1] - 666:9
rate [2] - 540:11, 541:13 red [1] - 529:7 repackaged [1] - 552:3
rates [3] - 508:11, 540:5, 540:24 redact [1] - 608:2 repaid [3] - 548:3, 569:15, 661:2
rather [2] - 513:20, 584:20 redacted [2] - 538:3, 605:20 repay [1] - 672:20
Ray [1] - 497:11 reduce [1] - 672:25 repeat [1] - 638:22
RAYMOND [1] - 495:6 refer [17] - 504:19, 515:12, 516:14, repeated [1] - 590:25
Re [1] - 546:1 516:15, 516:18, 517:13, 544:2, repeatedly [1] - 592:12
reach [1] - 596:19 560:19, 577:16, 584:15, 588:1, reported [1] - 618:25
read [21] - 503:4, 504:12, 505:2, 507:2, 588:12, 588:16, 609:11, 615:1, reporter [5] - 521:14, 558:20, 584:5,
508:15, 518:2, 523:13, 523:14, 633:12, 673:5 584:12, 664:1
534:20, 534:21, 539:13, 539:14, reference [9] - 503:17, 516:19, 518:16, Reporter [4] - 495:15, 495:16, 526:20,
542:1, 548:8, 558:25, 574:13, 616:9, 524:6, 524:7, 562:20, 628:9, 639:1 527:20
627:9, 629:13, 647:15, 651:17 references [1] - 633:24 reporter's [1] - 561:4
reading [1] - 627:7 referencing [3] - 560:10, 561:16, 634:1 reporting [1] - 530:13
ready [2] - 517:8, 517:25 referred [9] - 513:13, 515:18, 521:11, represent [1] - 509:12
real [3] - 620:2, 620:3, 620:4 527:22, 560:7, 612:17, 619:20, representations [1] - 590:14
reality [1] - 566:14 655:11, 661:5 Representations [1] - 645:13
realized [1] - 561:9 referring [21] - 517:18, 518:15, 531:16, representative [1] - 518:21
really [6] - 504:14, 562:6, 562:8, 591:15, 531:18, 540:1, 554:18, 586:25, 587:2, represented [1] - 591:7
608:23, 669:17 607:3, 612:19, 615:2, 616:3, 620:12, representing [1] - 509:13
reason [2] - 525:6, 659:25 621:18, 636:10, 658:20, 658:22, represents [1] - 643:14
reasons [2] - 500:14, 521:25 665:3, 670:8, 670:12, 671:2 Republic [1] - 653:7
receipt [2] - 573:10, 650:1 refers [4] - 611:16, 612:18, 644:5, 650:4 request [5] - 514:11, 543:13, 559:9,
receive [11] - 502:12, 550:19, 556:25, reflect [2] - 552:11, 595:2 559:15, 584:4
564:2, 568:20, 576:4, 576:13, 626:7, reflected [1] - 518:22 requested [3] - 617:14, 617:15, 649:6
626:9, 643:24, 660:10 refresh [2] - 645:20, 654:2 requesting [2] - 581:21, 663:4
received [77] - 500:18, 500:21, 500:25, regard [1] - 592:12 require [4] - 615:7, 643:22, 644:4,
501:1, 501:25, 502:21, 506:20, regarding [16] - 517:7, 517:9, 545:17, 645:18
510:21, 511:24, 512:14, 514:9, 554:14, 557:2, 558:18, 565:25, 584:8, required [6] - 510:4, 530:23, 546:15,
514:21, 520:16, 524:18, 527:7, 602:7, 616:17, 626:18, 630:1, 636:25, 546:22, 633:23, 639:3
529:24, 533:4, 535:17, 539:7, 543:5, 643:13, 661:5, 662:20 requirement [2] - 637:8, 657:18
545:13, 547:7, 555:8, 558:11, 559:7, regardless [2] - 592:16, 593:1 reservation [1] - 667:6
563:8, 564:11, 565:1, 568:5, 570:3, regulations [1] - 639:2 residency [8] - 563:22, 564:19, 565:22,
571:11, 573:10, 575:7, 576:24, regulatory [3] - 637:8, 639:4, 643:22 565:25, 566:7, 616:12, 616:17, 617:5
578:14, 579:11, 580:19, 582:5, relate [5] - 513:24, 521:7, 586:11, Resources [11] - 599:25, 600:3, 600:17,
583:16, 585:12, 586:6, 601:16, 586:13, 663:10 600:22, 658:10, 658:11, 660:24,
606:11, 611:21, 613:2, 614:7, 615:25, related [8] - 512:20, 551:3, 600:9, 661:8, 663:18, 663:19, 663:21
616:21, 617:23, 618:18, 618:19, 606:21, 618:23, 663:18, 670:14 respect [10] - 522:21, 550:4, 573:21,
621:6, 622:17, 623:18, 624:3, 626:10, relates [7] - 551:15, 586:15, 594:3, 591:11, 600:21, 605:21, 621:7, 647:5,
626:11, 628:15, 630:22, 632:16, 599:17, 604:23, 606:20, 609:7 665:23, 672:11
634:21, 636:21, 638:12, 639:19, relating [7] - 518:12, 519:4, 544:10, respond [29] - 505:13, 505:15, 516:11,
640:23, 648:21, 651:12, 653:18, 599:17, 600:21, 611:22, 619:22 517:7, 518:11, 529:12, 532:6, 532:13,
655:12, 658:19, 658:23, 660:8, relation [16] - 500:17, 500:22, 519:5, 543:13, 546:5, 555:17, 561:21, 562:4,
662:14, 666:25, 668:17, 671:11, 543:9, 554:18, 561:15, 568:25, 572:1, 569:6, 578:5, 578:7, 587:20, 592:5,
671:25 620:6, 621:23, 626:5, 633:16, 655:12, 616:8, 631:9, 631:11, 631:13, 631:25,
receiver [2] - 650:10, 652:15 660:20, 660:22, 665:22 632:9, 633:7, 634:6, 635:11, 636:6,
receives [2] - 573:15, 573:19 relationship [1] - 602:15 639:9
receiving [4] - 543:8, 621:23, 643:19, relevance [3] - 598:23, 599:1, 599:22 responded [2] - 510:22, 560:22
655:14 relevant [11] - 529:16, 540:24, 598:20, responding [9] - 529:15, 561:15,
Recess [2] - 526:4, 656:22 598:21, 599:19, 600:1, 601:2, 608:20,
SAM OCR RMR

23
563:19, 586:22, 609:7, 634:11, Safa's [2] - 569:1, 661:18 second [17] - 503:2, 513:19, 515:2,
634:12, 671:5 salary [1] - 616:20 521:21, 527:11, 581:18, 586:17,
response [18] - 503:1, 504:13, 505:3, sale [2] - 622:6, 627:3 599:16, 604:20, 611:1, 625:6, 627:8,
507:7, 531:1, 545:5, 545:17, 559:15, sales [1] - 629:19 627:9, 632:19, 641:12, 642:10, 664:8
562:16, 584:4, 584:11, 584:14, Samara [2] - 558:16, 560:5 Second [3] - 592:11, 592:15, 592:24
599:21, 616:7, 628:21, 631:24, San [6] - 599:18, 599:24, 663:14, secondly [1] - 543:7
641:17, 665:13 663:16, 663:20, 663:22 Secondly [2] - 569:14, 625:18
responsibilities [1] - 639:4 Sandy [2] - 664:10, 664:15 secret [1] - 584:20
responsible [6] - 533:25, 534:2, 549:18, SAO [1] - 619:22 Secret [1] - 589:17
550:4, 550:6, 576:17 satisfy [1] - 639:3 secretary [2] - 635:12, 635:16
rest [4] - 505:2, 569:9, 569:16, 629:13 Saturdays [1] - 498:8 secretly [1] - 549:11
restricting [1] - 670:13 saw [6] - 551:4, 553:18, 588:11, 612:17, section [4] - 550:22, 613:7, 641:15,
restriction [3] - 647:5, 669:18, 670:6 666:8, 666:9 643:10
result [2] - 575:24, 655:14 scene [1] - 549:2 secure [1] - 570:12
resulted [1] - 543:7 scenes [4] - 528:22, 529:3, 532:21, see [37] - 507:25, 525:17, 526:3, 550:11,
resume [5] - 497:22, 498:14, 589:21, 548:24 553:2, 553:4, 553:8, 555:18, 555:23,
657:2, 674:16 Schachter [1] - 496:23 563:19, 567:2, 581:10, 586:17, 587:8,
resumed [1] - 498:15 SCHACHTER [114] - 495:4, 496:22, 588:14, 596:6, 597:7, 598:9, 601:9,
resumes [1] - 609:24 501:23, 502:18, 506:18, 511:21, 602:24, 603:24, 604:19, 611:5, 612:6,
retain [1] - 569:18 514:6, 514:14, 514:18, 519:24, 520:1, 622:25, 642:23, 647:11, 654:3,
return [1] - 667:20 520:6, 520:12, 524:13, 524:16, 527:5, 656:21, 658:25, 663:5, 663:8, 666:6,
returning [1] - 673:13 529:21, 533:1, 534:15, 534:19, 667:16, 670:5, 674:8, 674:15
revenue [5] - 528:8, 528:11, 625:16, 535:13, 535:21, 536:2, 537:10, See [2] - 558:19, 675:15
625:17, 627:1 537:13, 537:16, 538:1, 538:7, 545:5, seek [39] - 499:1, 501:20, 511:17,
revenues [1] - 626:16 545:10, 547:5, 555:2, 555:5, 557:10, 529:19, 545:3, 547:3, 558:1, 563:3,
revert [2] - 530:19, 639:10 558:4, 558:6, 558:8, 559:21, 559:24, 564:5, 564:22, 566:18, 569:22, 571:5,
review [3] - 521:23, 545:8, 568:17 563:6, 564:7, 564:24, 566:20, 567:7, 575:1, 576:20, 578:10, 579:7, 580:15,
RICHARD [1] - 494:16 569:24, 571:8, 575:4, 576:22, 578:12, 581:23, 583:12, 585:8, 594:4, 612:2,
rights [1] - 644:2 579:9, 580:17, 581:4, 581:25, 582:2, 615:14, 617:18, 618:12, 630:16,
rise [4] - 496:2, 596:3, 656:23 583:14, 584:25, 585:10, 586:4, 594:2, 632:11, 634:16, 636:16, 638:3,
risk [1] - 540:12 594:15, 594:21, 597:15, 597:20, 639:12, 642:18, 648:16, 651:7,
RMR [1] - 495:15 598:5, 598:19, 599:3, 599:15, 600:13, 652:23, 653:9, 666:19, 671:20
road [1] - 591:17 601:20, 606:7, 606:17, 606:19, seeking [1] - 579:17
Robin [1] - 600:4 607:19, 608:1, 608:14, 608:19, 609:1, seeks [1] - 628:11
Rock [1] - 561:3 609:6, 609:12, 609:17, 609:21, 612:4, seem [1] - 623:7
role [4] - 511:8, 549:7, 549:18, 549:25 612:8, 614:3, 614:5, 615:5, 615:17, seemingly [1] - 599:12
Roman [4] - 522:11, 522:16, 522:22, 617:20, 618:15, 623:12, 623:16, sell [8] - 533:19, 546:16, 580:10,
641:24 624:1, 628:13, 629:4, 630:19, 632:14, 627:12, 661:1, 661:15, 661:19, 671:8
634:2, 634:18, 636:18, 638:6, 638:9, selling [2] - 550:6, 627:1
Rosario [27] - 517:14, 517:18, 517:24,
639:17, 640:20, 642:21, 648:19, send [11] - 507:19, 507:23, 511:7,
519:3, 519:7, 519:17, 524:23, 525:2,
651:10, 653:12, 660:2, 662:8, 662:12, 531:14, 555:15, 562:18, 563:21,
525:4, 525:8, 530:14, 530:24, 531:1,
666:21, 666:23, 668:15, 671:23 563:23, 574:7, 574:21, 654:9
532:19, 556:15, 558:17, 588:20,
Schedule [3] - 582:16, 582:19, 582:22 sender [3] - 649:16, 649:19, 652:13
635:7, 635:11, 635:12, 635:24,
636:24, 640:16, 641:3, 641:7, 642:4, scheduled [1] - 512:24 sending [6] - 511:2, 513:1, 525:6,
647:14 scheme [10] - 511:9, 584:10, 584:17, 564:18, 633:5, 641:2
RPR [1] - 495:15 658:21, 659:7, 666:1, 666:15, 668:9, sends [1] - 574:8
ruled [1] - 638:6 670:3, 671:18 senior [2] - 550:2, 571:25
ruling [2] - 603:19, 605:23 school [2] - 552:19, 605:25 sense [2] - 590:20, 623:6
rulings [1] - 595:7 Schultens [2] - 550:1, 550:5 sensitive [2] - 597:2, 597:3
run [1] - 594:24 scissors [1] - 605:24 sent [29] - 507:5, 511:12, 513:7, 525:2,
running [2] - 507:6, 510:1 screen [3] - 524:19, 598:8, 613:8 528:10, 544:10, 547:19, 549:16,
Russia [3] - 619:24, 620:7, 620:23 scroll [3] - 605:9, 642:10, 644:23 552:5, 556:11, 562:10, 565:6, 571:17,
seamlessly [1] - 511:10 574:15, 574:16, 574:18, 582:9,
seat [2] - 526:17, 609:25 582:13, 584:1, 602:17, 604:20,
S seated [19] - 496:15, 496:16, 497:12, 619:12, 621:15, 649:11, 650:2,
safa [1] - 568:24 498:11, 498:12, 498:23, 525:20, 650:12, 652:12, 652:17, 671:11
Safa [17] - 544:8, 568:25, 621:14, 526:7, 526:25, 590:3, 596:9, 596:13, sentence [7] - 524:3, 530:16, 531:13,
621:20, 621:21, 622:2, 622:3, 622:10, 610:6, 610:9, 656:15, 657:20, 657:25, 542:1, 573:9, 586:18, 629:11
656:6, 658:13, 659:20, 661:7, 661:22, 675:5 sentences [1] - 523:14
662:1, 664:12, 665:24, 666:2 seating [1] - 570:12 separate [4] - 507:21, 528:18, 600:15,
SAM OCR RMR

24
605:1 side-by-side [1] - 581:9 sorry [32] - 510:22, 530:17, 535:22,

separately [1] - 664:15 sidebar [6] - 536:1, 536:3, 537:1, 536:4, 537:13, 537:20, 551:10,
September [15] - 516:5, 539:22, 541:18, 594:11, 596:22, 596:24 555:23, 574:16, 581:16, 581:25,
542:3, 547:23, 548:19, 558:15, 562:4, Sidebar [5] - 536:5, 538:9, 566:21, 588:24, 594:21, 597:19, 604:15,
563:14, 667:11, 667:21, 667:24, 567:1, 567:10 606:18, 613:8, 613:25, 617:4, 619:9,
668:24, 668:25, 669:11 sign [3] - 613:16, 614:21, 619:7 619:10, 624:16, 624:17, 630:5, 630:9,
seriatim [1] - 519:25 signature [5] - 556:9, 613:14, 642:2, 638:22, 642:24, 649:2, 651:2, 652:3,
series [1] - 533:22 647:13, 647:19 663:5, 667:14
serious [1] - 562:14 signatures [1] - 647:8 Sorry [3] - 545:21, 558:5, 560:16
servant [1] - 643:18 signed [14] - 517:11, 517:15, 517:24, sorting [4] - 637:3, 637:7, 637:13,
Service [1] - 589:17 521:5, 556:14, 556:18, 613:5, 613:11, 637:15
services [2] - 619:23, 620:6 642:3, 642:5, 647:10, 647:14, 648:10, source [2] - 666:12, 670:1
SESSION [1] - 596:1 653:7 South [8] - 505:4, 505:7, 505:10, 544:7,
set [15] - 509:19, 510:7, 512:21, 522:14, Signed [1] - 640:5 621:21, 659:12, 659:19, 666:8
530:6, 530:8, 530:11, 530:14, 531:22, signed-off [1] - 517:24 sovereign [6] - 559:3, 559:11, 560:4,
551:4, 554:5, 614:16, 620:15, 622:8, significance [1] - 534:17 560:8, 561:17, 561:18
664:22 significant [3] - 528:7, 528:11, 543:6 space [2] - 498:3, 594:13
sets [6] - 509:20, 510:8, 521:25, 522:3, significantly [1] - 666:9 Spain [1] - 505:17
525:3, 649:25 signing [2] - 517:19, 556:20 Spanish [3] - 505:4, 505:8, 505:10
setting [7] - 507:3, 524:25, 533:20, similar [6] - 522:9, 549:25, 551:22, speaking [6] - 523:11, 523:16, 535:24,
575:19, 585:21, 621:10, 626:23 645:3, 645:14, 647:2 578:24, 579:2, 604:12
settled [1] - 615:25 Simmons-.com [1] - 558:17 Special [1] - 496:10
settlement [4] - 542:1, 542:2, 571:17, simply [1] - 562:20 specific [4] - 513:20, 518:13, 530:19,
650:4 Singh [43] - 502:8, 502:9, 507:5, 507:23, 630:11
settling [1] - 654:15 511:1, 512:19, 515:1, 515:9, 518:16, specifically [1] - 561:16
Seven [2] - 581:14, 632:7 518:17, 518:18, 521:4, 549:6, 555:12, specification [1] - 508:21
seven [3] - 581:17, 661:12, 661:13 555:17, 556:19, 556:20, 557:3, 557:6, speculate [1] - 615:7
Seventh [1] - 495:3 557:23, 558:15, 559:1, 560:5, 563:21, speed [1] - 516:13
several [1] - 666:16 563:25, 565:9, 565:20, 565:25, 566:4, spell [4] - 521:14, 589:2, 589:6, 664:1
shall [3] - 573:11, 611:24, 643:16 566:9, 577:15, 588:6, 591:5, 613:15, spellings [1] - 496:15
share [5] - 655:13, 655:16, 660:14, 613:16, 636:11, 636:12, 637:14, spend [1] - 553:25
661:24 669:10, 673:6, 674:1, 674:3 spent [1] - 551:21
shareholder [1] - 569:14 Singh's [7] - 511:2, 511:8, 564:19, spoiler [1] - 608:5
shareholders [1] - 568:21 565:6, 565:22, 566:13, 577:23 spoken [6] - 498:20, 518:17, 518:18,
shareholders ' [1] - 569:8 SISE [3] - 589:15, 589:16, 589:17 528:17, 636:8, 637:14
shares [2] - 665:12, 665:21 sit [2] - 498:8, 535:23 sponsor [1] - 566:8
shipbuilding [1] - 625:18 situation [1] - 513:23 sponsored [1] - 517:4
Shipbuilding [7] - 619:22, 619:24, sixteenth [1] - 614:10 spotted [1] - 625:7
620:6, 641:5, 641:11, 651:5, 652:20 size [17] - 500:15, 500:24, 501:13, spreadsheet [2] - 528:1, 528:3
ships [1] - 503:15 523:18, 541:4, 541:7, 541:11, 541:16, Stacy [1] - 495:15
shipyard [1] - 641:23 571:1, 579:5, 625:24, 626:1, 631:7, staff [1] - 666:10
shipyard's [1] - 625:18 631:19, 633:11, 633:20, 672:19 stage [5] - 504:1, 504:20, 622:13,
shipyards [10] - 501:6, 503:5, 505:10, skier [1] - 591:15 625:14, 628:6
505:11, 505:16, 505:20, 505:21, skis [1] - 591:16 stamp [2] - 564:20, 565:22
505:22, 625:3 SLE [1] - 654:9 stand [7] - 497:23, 498:14, 498:16,
short [4] - 525:13, 525:14, 642:14, slipup [1] - 532:16 526:14, 604:19, 609:24, 657:2
669:7 Slow [2] - 561:3, 635:14 standard [2] - 553:20, 611:7
shortly [1] - 637:10 slow [2] - 561:5, 600:4 stands [2] - 508:19, 546:8
Show [1] - 623:24 slowing [1] - 610:13 Stanley [7] - 533:19, 534:4, 534:13,
show [9] - 503:6, 528:6, 535:3, 544:13, SMaceRPR @gmail.com [1] - 495:16 534:14, 534:23, 535:2, 535:6
575:10, 610:22, 650:1, 662:10, 667:3 smaller [1] - 501:1 start [8] - 517:12, 518:4, 518:5, 586:11,
showed [2] - 531:18, 633:22 sold [6] - 546:24, 550:5, 573:7, 573:22, 591:16, 597:21, 631:16, 632:2
shows [1] - 607:22 580:8, 620:20 starting [5] - 533:6, 597:14, 598:2,
Shultens [20] - 601:11, 601:21, 602:8, solution [1] - 633:24 627:10, 641:2
602:14, 602:16, 602:18, 602:20, someone [4] - 591:15, 627:13, 635:17, starts [1] - 574:10
602:25, 603:10, 603:18, 604:1, 604:9, 637:9 state [4] - 496:7, 554:17, 598:20, 639:14
604:11, 604:14, 604:18, 607:11, sometimes [1] - 544:1 statement [4] - 604:17, 624:18, 654:17,
668:21, 670:17, 672:8, 672:23 somewhere [1] - 658:5 655:1
side [12] - 516:22, 522:20, 523:10, son [4] - 518:6, 518:10, 587:2, 587:23 STATES [3] - 494:1, 494:3, 494:12
531:22, 581:9, 606:24, 615:24, 673:21 soon [4] - 504:9, 506:11, 559:15, 615:25
SAM OCR RMR

25
states [1] - 612:25 suggestion [1] - 632:1 switch [1] - 562:22

States [13] - 494:5, 494:16, 494:19, suggests [2] - 525:5, 664:19 Switzerland [1] - 662:24
496:11, 497:16, 508:25, 526:11, suicide [1] - 595:1 sworn/affirmed [1] - 500:3
546:25, 592:14, 600:6, 646:5, 666:16, Suisse [93] - 503:9, 503:20, 503:23, syndicate [7] - 573:20, 580:2, 581:3,
673:13 504:4, 505:9, 505:22, 506:4, 507:6, 582:23, 582:25, 583:3, 585:21
stating [1] - 644:6 507:7, 507:23, 511:5, 511:7, 511:12, syndicated [6] - 573:18, 624:11, 624:24,
stenography [1] - 495:17 511:14, 512:15, 512:22, 515:15, 624:25, 646:10
step [4] - 525:19, 589:25, 656:13, 515:25, 516:4, 516:6, 517:1, 518:21, syndication [3] - 646:6, 646:12, 647:5
674:19 519:10, 523:22, 523:24, 524:5, 525:4, Syria [1] - 540:20
steps [2] - 590:1, 656:14 528:6, 528:10, 528:17, 528:20, system [1] - 650:5
still [9] - 504:6, 515:25, 548:20, 596:18, 528:25, 529:2, 529:7, 529:9, 531:3,
596:20, 605:22, 615:2, 615:24, 675:3 532:11, 532:15, 532:20, 533:15, T
stock [1] - 631:15 534:12, 534:24, 534:25, 535:2, 540:6,
stop [24] - 504:17, 530:9, 539:13, 541:9, 542:6, 548:13, 548:20, 548:25, table [3] - 552:9, 553:16, 611:2
539:25, 541:6, 571:19, 589:19, 594:5, 549:1, 549:10, 549:16, 549:18, Table [2] - 644:21, 646:15
610:12, 616:2, 616:15, 627:19, 633:5, 549:23, 551:20, 552:2, 552:3, 556:8, taxes [8] - 608:2, 608:3, 608:5, 608:6,
634:10, 635:21, 644:3, 656:10, 657:3, 556:18, 557:1, 557:22, 562:10, 608:8, 608:10, 608:12
657:21, 667:5, 669:9, 669:20, 674:9, 562:11, 562:14, 566:16, 573:6, team [7] - 528:18, 532:15, 549:20,
674:10 573:12, 574:3, 574:4, 574:9, 574:19, 550:5, 635:10, 672:23
stopping [1] - 674:11 574:21, 580:8, 580:11, 582:10, 584:2, technical [2] - 508:21, 625:20
straight [1] - 627:12 584:4, 584:11, 584:14, 612:16, technically [3] - 550:18, 613:18, 664:24
Street [3] - 609:7, 646:4, 673:21 612:21, 612:24, 613:4, 613:19, 635:6, technology [3] - 508:19, 508:23, 509:9
strict [2] - 669:18, 670:5 635:10, 636:25, 637:8, 637:15, 671:9, ten [1] - 614:14
strike [1] - 634:2 672:14, 672:24 Ten [1] - 548:19
strip [1] - 538:4 Suisse 's [1] - 584:6 tend [1] - 534:7
strong [2] - 523:17, 608:24 summarize [2] - 533:13, 554:16 tender [2] - 503:11, 503:13
structure [3] - 607:4, 660:12, 665:15 summarized [1] - 550:16 tendering [1] - 505:23
study [2] - 531:6, 531:8 summarizes [1] - 550:14 termination [1] - 516:7
stuff [1] - 518:13 summary [1] - 551:15 terms [13] - 522:4, 528:24, 560:6,
stupid [1] - 637:7 Sunday [2] - 517:12, 518:4 592:21, 592:25, 620:8, 620:15, 622:5,
Subeva [51] - 512:10, 515:21, 515:25, Sundays [1] - 498:8 627:6, 649:25, 672:15, 672:16, 672:25
516:6, 524:23, 524:25, 525:10, supplied [4] - 509:10, 625:5, 625:20, Terms [1] - 620:9
527:12, 527:16, 528:4, 528:14, 634:14 terrible [1] - 649:3
528:19, 529:10, 529:12, 529:25, suppliers [1] - 629:21 Tessone [1] - 496:11
530:10, 530:16, 531:4, 531:13, supply [2] - 503:15, 517:20 testified [2] - 500:4, 591:23
531:16, 531:25, 532:6, 532:13, support [3] - 519:15, 570:16, 625:17 testify [2] - 601:16, 602:15
532:18, 533:9, 533:14, 535:20, 539:9, supported [2] - 519:11, 561:11 testimony [4] - 498:20, 591:20, 657:7,
545:16, 545:25, 546:1, 549:7, 578:22, supportive [1] - 587:14 657:22
579:21, 583:23, 584:1, 585:18, 609:4, supposed [3] - 574:20, 624:15, 625:2 than.. [1] - 650:5
626:21, 626:22, 626:23, 627:20, Surj [3] - 507:19, 515:23, 673:3 thanking [1] - 651:22
628:1, 629:1, 631:1, 633:1, 633:22, Surjan [48] - 502:8, 502:9, 507:5, THE [388] - 494:12, 496:2, 496:14,
638:17, 649:2, 667:9, 668:22 507:23, 511:1, 511:2, 511:8, 512:19, 496:21, 496:24, 497:2, 497:3, 497:6,
Subeva's [2] - 627:9, 628:21 514:25, 515:9, 518:16, 518:17, 497:9, 497:12, 497:17, 497:20,
subject [13] - 515:10, 522:12, 527:17, 518:18, 521:4, 549:6, 555:12, 556:19, 497:25, 498:2, 498:6, 498:17, 498:22,
539:11, 568:15, 570:17, 600:19, 556:20, 557:3, 557:6, 557:23, 558:15, 498:23, 501:22, 501:24, 502:17,
606:20, 607:13, 609:6, 632:23, 560:5, 561:2, 563:21, 565:6, 565:9, 502:19, 506:17, 506:19, 511:19,
662:20, 672:9 565:25, 566:4, 566:9, 577:15, 577:20, 511:22, 514:5, 514:7, 514:13, 514:16,
Subject [2] - 546:1, 640:4 577:23, 578:3, 578:24, 579:3, 579:4, 514:19, 519:23, 519:25, 520:4, 520:7,
subsequent [1] - 623:5 588:6, 613:15, 613:16, 636:11, 520:13, 521:14, 521:16, 524:12,
subsequently [2] - 585:2, 661:16 636:12, 637:14, 669:10, 673:6, 674:1, 524:15, 524:17, 525:14, 525:19,
Subsequently [1] - 561:22 674:3 525:25, 526:2, 526:6, 526:7, 526:13,
subsidiaries [1] - 633:15 Surjan's [1] - 566:13 526:16, 526:18, 526:19, 526:21,
subsidiary [2] - 507:10, 507:11 surpassing [1] - 592:11 526:23, 527:4, 527:6, 527:19, 529:1,
substantially [1] - 616:25 surprise [1] - 559:23 529:20, 529:22, 532:25, 533:2,
succeed [1] - 626:4 surprised [1] - 560:20 534:20, 534:22, 535:10, 535:14,
success [1] - 540:9 surrender [1] - 673:5 535:22, 536:3, 537:2, 537:4, 537:6,
successful [1] - 626:14 suspects [1] - 548:14 537:12, 537:14, 537:19, 537:21,
sufficient [2] - 541:25, 625:17 sustain [1] - 629:5 538:4, 538:8, 539:2, 539:5, 545:4,
suggested [1] - 617:6 SWIFT [8] - 649:17, 649:19, 649:21, 545:6, 545:11, 545:19, 545:22, 547:4,
suggesting [1] - 505:9 649:25, 650:3, 650:4, 650:10, 651:23 547:6, 548:8, 548:13, 548:15, 552:10,
SAM OCR RMR

26
552:15, 552:20, 553:1, 553:7, 554:2, 668:14, 668:16, 668:18, 671:22, transactions [8] - 500:9, 500:18, 607:5,
555:1, 555:4, 555:6, 555:24, 556:1, 671:24, 672:2, 673:24, 674:10, 628:3, 633:16, 658:19, 658:20, 660:1
557:11, 557:14, 557:17, 558:3, 558:5, 674:19, 675:1, 675:7, 675:10, 675:13 Transcript [1] - 495:17
558:7, 558:9, 558:19, 559:25, 560:2, theory [1] - 508:22 TRANSCRIPT [1] - 494:11
561:3, 561:7, 562:24, 563:1, 563:2, therefore [2] - 598:21, 599:19 Transcription [1] - 495:17
563:5, 563:7, 563:12, 564:6, 564:9, They've [2] - 553:8 transfer [7] - 508:19, 508:23, 509:8,
564:23, 564:25, 565:8, 565:9, 565:11, third [14] - 500:19, 500:21, 530:16, 569:7, 573:11, 647:6, 650:1
566:19, 566:21, 567:2, 567:6, 567:9, 556:5, 621:24, 625:9, 643:13, 653:6, transferring [1] - 670:13
568:2, 568:8, 569:23, 569:25, 571:7, 655:16, 656:4, 656:5, 660:9, 660:14, transfers [2] - 574:2
571:9, 575:3, 575:5, 576:21, 576:23, 664:23 travel [2] - 666:16, 667:6
577:18, 577:19, 577:21, 578:11, third-parties [1] - 643:13 trawler [8] - 504:15, 504:18, 507:25,
578:13, 579:8, 579:10, 580:16, thirds [4] - 655:16, 660:13, 660:15, 508:13, 508:16, 508:24, 509:7, 629:19
580:18, 581:5, 582:1, 582:3, 582:18, 664:23 trawlers [7] - 504:21, 508:7, 509:2,
583:13, 583:15, 585:1, 585:2, 585:4, thousand [1] - 547:21 509:10, 509:18, 627:12, 627:13
585:9, 585:11, 586:3, 586:5, 586:20, three [16] - 501:4, 503:23, 504:21, Treasuries [1] - 531:10
587:7, 589:1, 589:6, 589:20, 589:25, 504:24, 504:25, 505:1, 505:16, treasury [1] - 560:12
590:2, 590:7, 590:11, 591:10, 592:6, 505:19, 509:15, 509:18, 627:11, Treasury [1] - 516:20
593:3, 594:5, 594:20, 594:23, 595:12, 632:2, 635:12, 635:16 treat [1] - 528:18
596:3, 596:5, 596:12, 596:15, 596:17, throughout [1] - 592:1 Trial [1] - 675:17
596:21, 597:1, 597:3, 597:7, 597:11, Throw [1] - 637:19 TRIAL [1] - 494:11
597:16, 597:18, 597:22, 598:4, 598:6, Thursday [1] - 541:18 trial [2] - 496:5, 674:16
598:8, 598:11, 598:14, 598:23, 599:4, ticket [2] - 668:2, 673:9 tricks [1] - 610:13
599:8, 599:10, 599:21, 600:4, 600:8, tilt [1] - 526:20 tried [1] - 661:15
600:23, 601:2, 601:5, 601:9, 601:15,
Tim [1] - 613:15 trimaran [9] - 504:15, 504:18, 508:3,
601:18, 601:22, 601:25, 602:3,
timeframe [3] - 530:11, 659:22, 659:23 508:8, 508:17, 508:24, 509:8, 629:19,
602:11, 602:21, 602:24, 603:2, 603:5,
timetable [1] - 533:17 629:23
603:8, 603:14, 603:16, 603:19,
title [1] - 616:19 trimarans [8] - 504:22, 508:13, 509:3,
603:22, 603:24, 604:2, 604:8, 604:13,
today [5] - 517:10, 522:25, 530:7, 509:10, 509:15, 509:18, 627:11,
604:16, 605:3, 605:9, 605:14, 606:3,
530:11, 588:11 627:12
606:5, 606:9, 606:13, 606:15, 606:18,
together [3] - 533:16, 658:12, 662:24 Trip [2] - 515:11, 515:12
606:23, 607:1, 607:6, 607:8, 607:11,
tomorrow [5] - 594:19, 594:20, 594:22, trip [2] - 512:24, 515:13
607:15, 607:17, 607:21, 607:24,
595:1, 670:23 trouble [1] - 545:7
608:4, 608:15, 608:17, 608:23, 609:2,
Tony [4] - 517:11, 517:13, 517:15, 532:7 true [2] - 505:25, 506:1
609:4, 609:10, 609:13, 609:18,
took [1] - 559:2 Trust [4] - 646:4, 650:11, 650:13,
609:20, 609:22, 609:25, 610:1, 610:2,
610:4, 612:3, 612:5, 612:9, 613:24, top [47] - 502:11, 509:24, 512:3, 512:7, 652:16
614:2, 614:4, 614:6, 615:6, 615:16, 515:1, 523:10, 523:11, 524:21, truth [7] - 601:22, 601:25, 603:2,
615:18, 617:4, 617:7, 617:8, 617:19, 527:11, 531:23, 532:4, 532:12, 538:2, 603:20, 604:10, 605:19, 607:12
617:21, 618:14, 618:16, 623:11, 547:11, 547:14, 547:21, 551:10, try [2] - 498:9, 645:8
623:14, 623:17, 623:21, 623:24, 563:18, 564:16, 570:6, 574:6, 575:10, trying [9] - 501:13, 510:8, 537:21,
624:2, 624:17, 624:22, 624:23, 578:17, 579:15, 580:23, 583:20, 570:10, 626:24, 636:7, 661:15, 671:2,
628:12, 628:14, 629:5, 629:9, 630:5, 585:16, 586:18, 587:9, 598:10, 599:9, 671:8
630:6, 630:7, 630:8, 630:9, 630:18, 604:9, 604:14, 604:19, 619:15, tube [1] - 616:19
630:20, 632:13, 632:15, 634:4, 622:20, 622:24, 626:21, 628:23, Tuesday [3] - 523:18, 539:21, 541:1
634:17, 634:19, 635:14, 635:15, 640:14, 649:19, 651:24, 653:23, tuna [3] - 501:9, 517:3, 543:9
636:17, 636:19, 638:5, 638:8, 638:10, 664:8, 667:15, 668:20, 672:4 turn [3] - 556:5, 562:22, 598:15
639:14, 639:16, 639:18, 640:19, TOT [1] - 627:16 turned [1] - 607:4
640:21, 642:20, 642:22, 643:1, 643:4, ToT [3] - 508:16, 508:18, 508:19 turning [1] - 559:15
643:6, 645:8, 646:19, 647:14, 648:5, total [5] - 509:10, 570:24, 575:21, 583:8, turns [1] - 599:16
648:6, 648:7, 648:18, 648:20, 649:21, 655:17 Twenty [1] - 509:17
649:22, 649:23, 649:24, 650:3, 650:4, totaled [1] - 500:19 Twenty-four [1] - 509:17
650:6, 650:22, 651:9, 651:11, 652:25, tough [1] - 548:8 Twist [1] - 553:7
653:11, 653:13, 656:9, 656:13, Toughy [3] - 549:21, 549:22, 550:4 two [23] - 500:14, 500:22, 523:14, 537:7,
656:15, 656:19, 656:21, 656:23, towards [1] - 558:20 556:5, 563:18, 571:24, 582:25, 583:2,
656:25, 657:5, 657:6, 657:8, 657:10, trading [2] - 669:18, 670:6 587:9, 620:15, 621:2, 622:6, 622:8,
657:14, 657:16, 657:24, 657:25, training [1] - 551:3 623:3, 625:3, 647:9, 655:16, 659:16,
660:3, 661:10, 661:11, 661:12, tranche [1] - 649:10 660:13, 660:15, 664:23, 670:8
661:13, 661:14, 662:7, 662:10, transaction [15] - 511:13, 535:4, two-page [1] - 537:7
662:13, 662:15, 663:24, 663:25, 541:24, 573:14, 573:15, 587:16, two-thirds [4] - 655:16, 660:13, 660:15,
664:1, 664:3, 664:5, 666:22, 666:24, 599:17, 631:19, 655:12, 658:5, 658:8, 664:23
667:2, 667:14, 667:17, 667:19, 658:17, 659:23, 663:10, 664:20
SAM OCR RMR

27
type [7] - 548:1, 548:2, 549:17, 550:17, 597:10, 597:12, 598:2, 598:8, 603:16, walk [6] - 520:3, 524:15, 594:24,
622:12, 624:13, 625:19 604:8, 606:5, 618:22, 620:9, 632:3, 594:25, 595:1, 595:2
types [4] - 534:10, 620:19, 622:7, 625:5 640:6, 640:10, 645:8, 647:12, 647:20, Wall [2] - 609:7, 646:4
typically [1] - 633:14 654:15, 655:5, 657:2, 657:12, 664:21, wander [1] - 545:20
665:13, 670:16, 675:8 wandered [1] - 547:12
U update [4] - 533:15, 539:12, 546:1, warn [1] - 592:23
672:10 warned [3] - 592:11, 593:4, 593:5
U.K [1] - 540:19 updated [3] - 578:25, 619:6, 636:24 warrants [1] - 643:15
U.S [15] - 522:19, 522:24, 523:4, 534:16, upper [1] - 673:21 Washington [1] - 494:22
534:17, 534:23, 534:24, 535:5, upset [1] - 576:6 waste [1] - 599:23
540:19, 540:21, 540:23, 649:7, 666:17 upside [1] - 565:14 wealth [2] - 659:25, 666:13
UAE [1] - 617:1 upsize [6] - 523:18, 524:7, 579:17, wealthier [4] - 659:9, 666:1, 666:2,
UK [1] - 637:7 632:2, 669:5, 669:8 666:4
ultimately [8] - 501:10, 507:5, 535:6, USA [2] - 496:6, 658:15 wealthy [2] - 666:3, 666:7
576:4, 593:1, 613:11, 658:23, 661:19 USD [1] - 547:21 week [8] - 498:8, 523:16, 523:17, 541:2,
unable [1] - 661:1 user [1] - 643:25 577:13, 577:24, 609:14, 614:21
unaware [1] - 518:20 usual [1] - 548:13 weekend [3] - 544:8, 674:16, 675:15
uncertain [1] - 594:18 welcome [2] - 498:17, 526:23
Uncle [7] - 577:14, 577:15, 577:18, V welder [1] - 616:20
577:20, 588:5, 637:3, 637:7 Weldon [1] - 608:7
uncle [7] - 636:7, 636:10, 637:13, 669:3, Vader [2] - 561:3, 600:4 whereby [1] - 510:8
669:9, 669:10, 671:6 value [3] - 605:6, 643:17, 643:20 whichever [1] - 596:25
Uncle 's [1] - 577:9 valued [2] - 508:23, 629:23 whole [1] - 651:17
unclear [1] - 600:15 values [3] - 509:21, 627:5, 629:18 whther [1] - 544:6
under [17] - 500:19, 522:4, 528:24, various [3] - 509:25, 521:6, 630:2 WILLIAM [1] - 494:12
542:10, 543:8, 560:6, 574:3, 579:25, vehement [1] - 629:3 William [1] - 496:3
599:22, 613:19, 622:5, 625:5, 627:6, vehicle [1] - 664:16 willing [1] - 608:10
627:24, 634:14, 642:15, 650:16 venture [1] - 664:13 WILLKIE [1] - 495:3
underlying [3] - 513:24, 546:23, 553:20 version [2] - 558:18, 558:21 wimps [1] - 594:6
undermined [1] - 519:16 versus [2] - 496:6, 592:14 wimpy [1] - 594:8
understood [9] - 518:5, 519:12, 529:6, vessel [4] - 509:23, 620:19, 622:7, wisdom [1] - 592:21
531:8, 532:9, 570:15, 590:20, 627:22, 622:12 wisely [1] - 593:1
631:19 vessels [24] - 501:5, 504:6, 504:21, wish [2] - 543:21, 591:22
underwrite [3] - 533:16, 534:5, 535:6 504:22, 508:7, 508:21, 508:22, withdraw [3] - 537:10, 567:7, 606:7
underwriter [2] - 533:21, 533:23 509:14, 509:18, 510:2, 517:20, 522:2, withdrawn [2] - 562:19, 568:2
underwriting [1] - 534:7 522:4, 522:10, 522:15, 551:3, 554:10,
witness [23] - 497:22, 498:13, 498:15,
underwritten [1] - 573:4 625:4, 625:14, 625:19, 625:22, 627:4,
500:2, 526:14, 527:1, 590:1, 591:2,
unfamiliar [1] - 519:14 627:14, 642:14
591:20, 591:22, 598:14, 598:17,
unfortunately [1] - 661:16 via [1] - 509:21
602:19, 603:6, 609:22, 609:24,
unhappy [1] - 661:2 view [6] - 523:17, 557:12, 559:25, 656:14, 657:2, 658:1
unique [1] - 504:16 601:3, 615:6, 632:8 WITNESS [34] - 498:22, 521:16, 526:18,
UNITED [3] - 494:1, 494:3, 494:12 VII [3] - 522:16, 522:22, 641:24 526:21, 548:15, 557:14, 560:2, 561:7,
United [15] - 494:5, 494:16, 494:19, violation [1] - 591:7 565:9, 577:19, 585:2, 610:1, 617:7,
496:11, 497:16, 508:25, 526:11, Virgin [1] - 569:3 624:17, 624:23, 630:6, 630:8, 635:15,
546:25, 566:1, 592:14, 600:6, 616:5, visibility [1] - 576:1 646:19, 647:14, 648:6, 649:22,
646:5, 666:16, 673:13 voice [3] - 527:20, 590:24, 645:8 649:24, 650:4, 650:22, 657:5, 657:8,
unlawful [1] - 621:7 voted [1] - 540:19 657:14, 657:24, 661:11, 661:13,
unless [2] - 599:12, 662:1 VTB [27] - 571:21, 571:23, 571:25, 663:25, 664:3, 676:3
unlike [1] - 498:9 573:4, 573:7, 580:5, 580:6, 580:25, witnesses [1] - 605:19
unlikely [5] - 529:3, 540:18, 541:17, 581:20, 585:21, 624:10, 624:14, won [1] - 606:9
625:21, 626:3 624:25, 628:6, 639:3, 644:14, 647:22, Woody [1] - 600:4
unrelated [3] - 606:21, 607:20, 608:22 648:2, 648:11, 649:11, 650:19, word [4] - 521:17, 521:18, 554:13
unsigned [1] - 556:10 651:22, 652:14, 669:16, 670:13, wording [1] - 584:1
untrue [2] - 620:5, 620:13 672:14, 672:24 words [5] - 521:24, 554:17, 611:22,
unusual [1] - 670:13 613:8, 641:19
up [45] - 515:3, 515:19, 516:13, 524:21, W world [3] - 535:1, 584:21, 668:7
527:10, 527:20, 530:14, 531:23, worried [3] - 636:4, 669:16, 669:22
541:16, 545:25, 550:11, 550:12, wad [1] - 621:23
worries [4] - 519:1, 532:7, 665:18,
551:9, 552:17, 565:15, 567:3, 569:10, wait [3] - 579:1, 596:12, 598:8
665:20
574:11, 574:13, 582:20, 587:4, 597:8, waiting [1] - 656:25
SAM OCR RMR

28
worth [1] - 633:4

WP18 [4] - 620:6, 620:18, 622:7, 622:10
write [42] - 507:21, 518:24, 528:14,
530:3, 530:5, 530:16, 539:20, 540:16,
540:25, 541:3, 541:15, 542:20,
542:22, 543:20, 546:2, 560:25,
561:23, 570:9, 571:16, 577:8, 578:23,
580:24, 614:15, 615:22, 619:1, 619:4,
631:4, 632:6, 632:25, 633:2, 633:9,
637:6, 637:13, 637:16, 638:21,
638:23, 649:4, 654:7, 662:19, 665:14,
669:2, 669:12
writes [6] - 507:25, 517:15, 605:12,
608:4, 662:21, 669:13
writing [5] - 503:7, 530:19, 533:14,
575:18, 654:1
written [1] - 577:24
wrote [13] - 505:7, 507:18, 518:4,
523:15, 530:10, 530:20, 531:4,
540:16, 579:2, 629:11, 633:14,
649:11, 670:5
Y
yacht [1] - 666:11
Yankees [2] - 657:9, 674:13
yards [2] - 505:4, 505:7
year [7] - 621:15, 622:23, 647:6, 667:14,
669:19, 670:6, 670:14
years [1] - 537:24
yellow [1] - 574:12
yesterday [8] - 500:7, 501:9, 516:3,
540:20, 554:1, 554:13, 573:17, 621:16
Yesterday [1] - 551:21
YORK [1] - 494:1
York [27] - 494:6, 494:17, 494:18,
494:22, 495:4, 645:18, 646:4, 650:13,
650:25, 652:16, 667:13, 667:25,
668:5, 668:7, 668:8, 669:1, 671:11,
671:12, 671:17, 673:3, 673:21,
673:25, 674:4
yourself [1] - 619:14
yourselves [1] - 525:16
Z
zero [2] - 661:12, 661:13
Zurich [1] - 662:24
SAM OCR RMR


10-18-19 - USA V Jean Boustani - 18CR681 (SFK) - Criminal Jury Trial - MI PDF

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10-18-19 - USA V Jean Boustani - 18CR681 (SFK) - Criminal Jury Trial - MI PDF

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Proceedings 496

1 (In open court - jury not present.)

14 14 THE COURT: Good morning.

21 DEPARTMENT OF JUSTICE 20 Good morning, Your Honor.

25 Mr. Boustani, I note your presence. Good morning,

9 10 MR. McLEOD: Good morning.

11 Ray McLeod on behalf of Mr. Boustani.

13 15 Anything from the Government?

16 MR. BINI: Not for the United States.

Page 494 to 497 of 681

Proceedings 499 Pearse - direct - Bini 501

Page 498 to 501 of 681

24 BY MR. BINI: 24 A They had three hulls.

25 Q What's this e-mail, Mr. Pearse? 25 Q Three hulls?

Pearse - direct - Bini 503 Pearse - direct - Bini 505

Page 502 to 505 of 681

Pearse - direct - Bini 507 Pearse - direct - Bini 509

Page 506 to 509 of 681

Pearse - direct - Bini 511 Pearse - direct - Bini 513

Page 510 to 513 of 681

Pearse - direct - Bini 515 Pearse - direct - Bini 517

Pearse - direct - Bini 519 Pearse - direct - Bini 521

5 contract. 5 million was increased again in August by Credit Suisse by a

8 A Yes. 8 that the Proindicus loans to be increased again.

12 numeral II subject to the contract? 12 THE COURT: Any objection?

14 Q And what is set out there? 14 that one either.

24 A 785,400,000 U.S. dollars. 24 copying Jean Boustani and myself.

MDL RPR CRR CSR MDL RPR CRR CSR

Pearse - direct - Bini 523 Pearse - direct - Bini 525

1 was the price? 1 A This e-mail is a briefing paper, a document which is

7 A It's in my opinion that calculation is incorrect. 7 e-mail?

13 bottom of that e-mail that we read? 13 time for a short break?

21 A I was not going to outside investors. 21 gentlemen.

MDL RPR CRR CSR MDL RPR CRR CSR

Page 522 to 525 of 681

2 A 4th of August, 2013. 2 A Yes.

8 set." 8 Q What did you understand the defendant to mean?

12 model? 12 MR. BINI: If we can go to the very top e-mail.

21 A Yes. 21 behind the scenes.

MDL RPR CRR CSR MDL RPR CRR CSR

Pearse - direct - Bini 531 Pearse - direct - Bini 533

7 Q What did you understand that to mean? 7 is from and to.

17 there? 17 estimate of the timetable and the price of the bonds.

24 ADM? 24 does that mean?

MDL RPR CRR CSR MDL RPR CRR CSR

Page 530 to 533 of 681

Pearse - direct - Bini 539 Pearse - direct - Bini 541

Pearse - direct - Bini 543 PEARSE/DIRECT/BINI 545

PEARSE/DIRECT/BINI 551 PEARSE/DIRECT/BINI 553

PEARSE/DIRECT/BINI 559 PEARSE/DIRECT/BINI 561

Page 558 to 561 of 681

PEARSE/DIRECT/BINI 563 PEARSE/DIRECT/BINI 565

SIDEBAR 567 PEARSE/DIRECT/BINI 569

PEARSE/DIRECT/BINI 571 Pearse - direct - Bini 573

Pearse - direct - Bini 579 Pearse - direct - Bini 581

Pearse - direct - Bini 583 Pearse - direct - Bini 585

2 admit 2594. 2 certain people?

3 THE COURT: Any objection? 3 A Yes.

6 (Government's Exhibit 2594 was received in 6 A Surjan Singh.

7 evidence.) 7 Q Croco, who is that?

8 (Exhibit published.) 8 A Armando Guebuza.

9 BY MR. BINI: 9 Q Junior, who is that?

12 you this: 12 use that to refer to?