allen stanford criminal trial transcript volume 7 jan. 31, 2012
DESCRIPTION
Transcript of R. Allen Stanford criminal trial in Houston, Texas.TRANSCRIPT
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Johnny C. Sanchez, RMR, CRR - [email protected]
1971
UNITED STATES DISTRICT COURTSOUTHERN DISTRICT OF TEXAS
HOUSTON DIVISION
UNITED STATES OF AMERICA * 09-CR-342* Houston, Texas
VS. ** January 31, 2012
ROBERT ALLEN STANFORD * 10:19 a.m.
JURY TRIAL
VOLUME 7
BEFORE THE HONORABLE DAVID HITTNERUNITED STATES DISTRICT JUDGE
APPEARANCES:
FOR THE GOVERNMENT:Gregg J. CostaAssistant US AttorneyPO Box 61129Houston, Texas 77208-1129
William StellmachAndrew Howard WarrenU.S. Department of Justice1400 New York Avenue NWWashington, DC 20005
FOR THE DEFENDANT:Ali R. FazelRobert ScardinoScardino & Fazel1004 Congress Street3rd FloorHouston, Texas 77002
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Johnny C. Sanchez, RMR, CRR - [email protected]
1972
A P P E A R A N C E S: (Continued)
FOR THE DEFENDANT: (Continued)John M. ParrasAttorney at Law1018 PrestonFloor 2Houston, Texas 77002
Kenneth W. McGuireMcGuire Law FirmPO Box 79535Houston, Texas 77279
Court Reporter:Johnny C. Sanchez, RPR, RMR, CRR515 Rusk, #8016Houston, Texas 77002713.250.5581
Proceedings recorded by mechanical stenography. Transcriptproduced by computer-assisted transcription.
Court Reporter:Johnny C. Sanchez, RPR, RMR, CRR515 Rusk, #8016Houston, Texas 77002713.250.5581
Proceedings recorded by mechanical stenography. Transcriptproduced by computer-assisted transcription.
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1973
I N D E X
WITNESS PAGE
MARIAN ALTHEA CRICK
CROSS-EXAMINATION BY MR. PARRAS................ 1983
REDIRECT EXAMINATION BY MR. WARREN............. 2062
RECROSS EXAMINATION BY MR. PARRAS.............. 2084
REDIRECT EXAMINATION BY MR. WARREN............. 2098
ARNOLD KNOCHE
DIRECT EXAMINATION BY MR. COSTA................ 2099
CROSS-EXAMINATION BY MR. SCARDINO.............. 2169
REDIRECT EXAMINATION BY MR. COSTA.............. 2233
RECROSS EXAMINATION BY MR. SCARDINO............ 2244
REDIRECT EXAMINATION BY MR. COSTA.............. 2251
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1974
RECROSS EXAMINATION BY MR. SCARDINO............ 2255
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Direct-Crick/By Mr. Warren
Johnny C. Sanchez, RMR, CRR - [email protected]
1975
(The following was held before the jury)
THE COURT: Thank you. Be seated. Good
morning. I can't say I've had a full day already, but I've
had full of something this morning already.
So we're ready to proceed. Counsel, go
right ahead.
MR. WARREN: Thank you, Your Honor.
DIRECT EXAMINATION
BY MR. WARREN:
Q. Good morning, Ms. Crick?
A. Good morning.
Q. Are you familiar with Antiguan bank secrecy laws?
A. Yes, I am.
Q. Can you generally describe what those laws are?
A. Those laws are contained in the International
Business Corporations Act, and it describes the conditions
under which information can be released to an individual
making a request.
Q. And what types of information can be released and
what types of information can't be released, generally
speaking?
A. Well, generally speaking, all information can be
released. It's a question of the conditions under which
they're released. For example, there are pieces of
information that are available to the public in general.
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Direct-Crick/By Mr. Warren
Johnny C. Sanchez, RMR, CRR - [email protected]
1976
For a fee, the public can see certain documents. There is
information that is shared with regulatory authorities
around the world under circumstances in which there is a
memorandum of understanding between the countries or
mutual legal assistance treaty with those countries. And
there are instances where if the information relates to
customer information, a bank -- court order is required.
Q. What do you mean by "customer information"?
A. Specifically in banking, information that would
outline a customer's business transactions with the bank.
Q. By "customer," do you mean -- who's a customer in the
case of Stanford International Bank?
A. In the case of Stanford International Bank, a
customer is one who either by way of deposit or loan
accesses the services of the bank.
Q. Is there any prohibition against a bank like Stanford
International Bank disclosing its assets?
MR. PARRAS: Judge, object to the form of the
question.
THE COURT: Why?
MR. PARRAS: Best evidence would be the
statute? If it's to her knowledge, I -- to her
understanding, then I understand it. The question is?
THE COURT: State it again -- no, I want it
read back. Johnny, read it back, please.
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Direct-Crick/By Mr. Warren
Johnny C. Sanchez, RMR, CRR - [email protected]
1977
(Requested portion was read.)
THE COURT: Now, what's your problem?
MR. PARRAS: It's not qualified to indicate
that it's her understanding, and it seems --
THE COURT: Hold it.
Ma'am, how long have you been in the
banking business?
THE WITNESS: For over 25 years.
THE COURT: On your country, you're familiar
with the laws?
THE WITNESS: Yes, I am.
THE COURT: Overrule the objection.
BY MR. WARREN:
Q. Ms. Crick, do you recall the question?
A. There is nothing that prevents a bank from revealing
its assets, no.
Q. If Stanford International Bank wanted to tell its
customers or even the entire world about every single
asset in its investment portfolio, was it allowed to do
that?
A. Yes, there's nothing in law that prevents the bank
from doing that.
Q. Whose decision would that have been to disclose those
assets?
A. The bank's decision.
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Direct-Crick/By Mr. Warren
Johnny C. Sanchez, RMR, CRR - [email protected]
1978
Q. Can the FSRC tell the bank you're not allowed to do
that?
A. No.
Q. Are you familiar with a form called an IB5?
A. Yes.
Q. What's an IB5?
A. An IB5 is a form which was designed by our
commission. It's information that the regulated entity is
required to submit to us on its investment portfolio on a
quarterly basis.
Q. What kind of information is included in the IB5?
A. The IB5 includes information -- the IB5 details a
bank's investment portfolio. It outlines the various
investment companies and the amounts invested, the
balances with those various investment houses.
Q. Was Stanford International Bank an entity that
produced IB5s to the FSRC?
A. Yes.
Q. And please describe the information that would be
contained in those IB5s.
A. The IB5 would contain --
Q. I'm sorry. Particularly Stanford International
Bank's IB5s.
A. It would contain a listing of all the investment
houses, the balances, the date at which those balances
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Direct-Crick/By Mr. Warren
Johnny C. Sanchez, RMR, CRR - [email protected]
1979
relate to. I can't remember all the details because it's
quite a compact schedule that is required, but those two
pieces of information would be essential.
Q. The investment houses and?
A. The balances with each of these investment houses.
Q. What do you mean by "the investment houses"?
A. The bank would at intervals within its own
decision-making process determine where it wants to invest
its resources with which investment company. So what that
schedule contain is a listing of all these institutions
with which the bank had, in fact, placed these
investments.
Q. These would be other banks where Stanford
International Bank has its assets like a Credit Suisse or
a bank --
A. It could range anything from other banks to
institutions that specialize in investing portfolios. It
would be a wide range. It's a matter of their decision
with which organization to invest.
Q. Is there any prohibition against Stanford
International Bank taking that IB5 that contains all its
investment houses and all the balances that it submits to
the commission and releasing that to its customers?
A. There is nothing that prohibits that.
Q. I'm showing you Government's Exhibit 218, which is
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Direct-Crick/By Mr. Warren
Johnny C. Sanchez, RMR, CRR - [email protected]
1980
already in evidence.
I'll represent to you that this is a
manual from Stanford International Bank?
THE COURT: When you say it's already in
evidence, it's all in evidence if it's been previously
referenced.
MR. WARREN: Yes, Your Honor, it's been
previously shown.
THE COURT: Here it is. I got it at the bottom
of that page. You can just say that, it's been previously
referencing, because it's all in evidence pursuant to my
initial ruling subject to defense objections.
BY MR. WARREN:
Q. Ms. Crick, I'll represent to you that this is a
manual from Stanford International Bank that contains
questions and answers about the bank's operations and
portfolio.
MR. WARREN: If we could turn to Page 21.
BY MR. WARREN:
Q. Ms. Crick, let me know if you're able to read that on
the screen in front of you; otherwise, I can give you a
hard copy.
A. It's going to be a little difficult.
Q. Sure. Ms. Crick, is that better?
A. That's a lot better.
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Direct-Crick/By Mr. Warren
Johnny C. Sanchez, RMR, CRR - [email protected]
1981
Q. You see the question: "Can a client see the
investments in the portfolio?"
A. Yes, I do.
Q. Can you please read the answer?
A. "Bank regulators do not allow SIBL to discuss
specifics about the portfolio."
Q. Let me stop you there.
Is that an accurate statement of what
Antiguan regulators allow or don't allow?
A. That is not accurate.
Q. Could you continue reading, please?
A. "SIBL is also allowed" -- sorry -- "is only allowed
to discuss the portfolio from an investment philosophy
exercising the overall diversification parameters."
Q. Let me stop you there, Ms. Crick.
Is that an accurate statement?
A. No, it's not.
Q. Could you continue reading, please?
A. "If a bank were to drill down into the portfolio,
regulators would view this as the bank is representing
itself as a security or fund (sic) and would put the
banking license in jeopardy."
Q. Ms. Crick, your reaction in answer to the question,
but is that a correct statement?
A. That is not correct.
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Direct-Crick/By Mr. Warren
Johnny C. Sanchez, RMR, CRR - [email protected]
1982
Q. And the last line, please.
A. "Because SIBL is a bank and sells only bank products,
it must adhere to these guidelines."
Q. Is that an accurate statement?
A. That is not accurate.
Q. What about the next paragraph? The question is:
"What are the top positions in the portfolio?" Could you
please read what the manual says in response?
A. "Unfortunately, SIBL is not allowed to disclose
individual positions because of banking regulations."
Q. Let me stop you there.
Is that an accurate statement?
A. No, it's not.
Q. Can you continue reading, please?
A. "If it were to do so, it could be construed as
presenting itself as a security and/or fund which would
put the banking license in jeopardy."
Q. Is that an accurate statement?
A. No, it's not.
Q. Would any type of disclosure of the bank's assets or
where its accounts were held, where its money was held be
a violation of Antiguan law that would put its license in
jeopardy?
A. No.
MR. WARREN: Court's indulgence.
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Cross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
1983
THE COURT: All right.
MR. WARREN: Pass the witness, Your Honor.
THE COURT: All right.
MR. PARRAS: Can I ask before counsel sits down
what exhibit number this was?
THE COURT: 218.
MR. PARRAS: And the page?
MR. WARREN: 21.
MR. PARRAS: If I could have a few seconds.
THE COURT: You've got a few seconds. The
clock is running. So take as much time as you want. You
Ou might put those chess clocks up here and hit it when
counsel come up.
MR. PARRAS: If you could go back to the whole
page. Thank you.
CROSS-EXAMINATION
BY MR. PARRAS:
Q. Good morning, Ms. Crick.
A. Good morning.
Q. My name is John Parras. We've never met before;
right?
A. That's correct.
Q. Actually, the first time that we talked --
THE COURT: Counsel, at least in front of the
microphone. If you want the lapel, that's fine.
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Cross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
1984
MR. PARRAS: I'll try this for a while, Judge.
THE COURT: Okay.
BY MR. PARRAS:
Q. The first time that you and I met, we were -- I was
coming in from a break and you were sitting outside on the
bench; correct?
A. That is correct.
Q. I said, "Hello, are you Ms. Crick?" introduced
myself?
A. That is correct.
Q. And at the time you were standing with Mr. Gerber or
sitting with Mr. Gerber, correct, the agent that's right
here? He was right there with you?
A. He was standing off to the side.
Q. Right. And an FBI agent, Walter, was there with you,
too, right? The lady, the FBI agent, the lady, she was
there with you, too?
A. She was standing to the side, yes.
Q. We didn't talk about the case; right?
A. No, we did not discuss the case.
Q. Okay. And you and I -- you've never called my office
or any of the lawyers for Stanford to tell them that you
were going to come testify so that we could have a chance
to visit with you about what you might say here; right?
A. No, I did not.
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Cross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
1985
Q. You had another gentleman there with you that was
seated right next to you to your left, who was that
gentleman?
A. That's Mr. Tom Baker.
Q. Is he your lawyer?
A. Yes, he is.
Q. Are you afraid that you may be charged civilly or
criminally as a result of the FSRC's regulation of SIBL?
A. No, I'm not.
Q. What's the reason for having a lawyer here with you?
A. It was simply a matter of giving me someone with whom
I could connect once I got here.
Q. Is it a lawyer that you paid for?
A. It's a lawyer that the commission paid for.
Q. It's a U.S. lawyer?
A. It's a U.S. lawyer, yes.
MR. PARRAS: I want to look up at Government's
Exhibit 218. We're looking at Page 21. And if you could
please for me, zoom in on the bottom left.
THE WITNESS: Could we have this enlarged as
well, please?
THE COURT: That's what he's going to do.
MR. PARRAS: Very, very bottom left under the
line.
THE COURT: Are you going to enlarge it?
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Cross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
1986
MR. PARRAS: Yes.
THE COURT: There we go.
How about that?
THE WITNESS: That's very good, yes.
BY MR. PARRAS:
Q. Have you seen that before, ma'am? This is a document
that's not for distribution.
A. I have not seen that, no.
Q. Do you know whether this is a draft document or a
finalized version?
A. I do not.
Q. Do you know who created this document?
A. I do not.
Q. When is the first time you were shown this document?
A. This morning.
Q. Where were you shown this document?
A. Here in court.
Q. And do you know whether this document is drafted for
customers in the U.S. or outside the U.S.?
A. I do not know.
Q. If it were -- if it were created for customers of the
United States, there may be different laws that apply;
correct?
A. I suppose that's possible.
Q. For example, it may well be that if it were
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Cross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
1987
distributed to customers in the U.S., the information that
we talked about, where the investments are, that it could
be considered a security; correct?
A. Given that I'm not familiar with U.S. laws, I really
can't answer that.
Q. Well, you answered a number of questions for the
prosecutor --
THE COURT: Hold it. I can't -- do you want
the lapel mike?
MR. PARRAS: I think so, Judge.
THE COURT: All right. Let's get the lapel
mike. Right here. I think you hold the budget until it
goes. I'll stop the clock. And you need to put it high on
the tie, please.
MR. PARRAS: If you could go back to the whole
page. Thank you.
BY MR. PARRAS:
Q. So the first time you saw this document was this
morning in court, and yet you were shown pieces and
blown-up sections of it for this jury to convey what idea,
Ms. Crick?
A. It was not to convey an idea, it was in response to
questions that was asked.
MR. PARRAS: I don't need that document
anymore. Thank you.
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Cross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
1988
May I have the ELMO, Judge?
Thank you.
BY MR. PARRAS:
Q. I'm going to show you Government's Exhibit 511.
Do you remember being shown this document?
A. Yes.
Q. And being asked about whether or not it would be
important for you to know that the government of
Montserrat proposed to revoke the license of GIBL --
A. Yes.
Q. -- back in 1990; do you remember that?
A. Yes, I do.
Q. You told this jury that the first time you saw that
document was the night before you testified; correct?
A. That is correct.
Q. You answered a number of questions about why it might
be important to know that information; correct?
A. That is correct.
Q. Were you also shown an opinion by Judge Redhead that
held that the license was not revoked and that, in fact,
help from Mr. Stanford and his directors that knew that it
had been revoked was improper?
A. I have not seen such a document.
Q. I'm going to show you what's been marked and admitted
into evidence as Defendant's Exhibit 2-14. And this is my
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Cross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
1989
copy.
Do you see that?
A. Yes.
MR. PARRAS: I want to verify with the Court
that this is in evidence. I believe it is.
MR. WARREN: No objection.
THE COURT: Has it been referenced yet?
MR. WARREN: It has, Your Honor.
THE COURT: All right. 511 -- correct, 511?
What number is that?
MR. PARRAS: This is Defendant's Exhibit 2-14.
THE COURT: Okay. I'm sorry. Defendant's.
No. I don't have that. 2-14? I have the latest one, 7-4.
MR. PARRAS: It would have been marked with the
second witness. That's the significant of the two. That's
correct, Your Honor, it was introduced.
THE COURT: Ellen may have it. All right.
2-14.
MR. PARRAS: Yes, Your Honor.
THE COURT: Double-check during the break. I'm
pretty sure it's in now that I remember.
MR. PARRAS: Yes, sir.
THE COURT: All right. Go right ahead. What
is this or what is it.
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Cross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
1990
BY MR. PARRAS:
Q. Let's look at the first page so that we can determine
what this is. Okay. You see at the top there, In the
High Court of Justice, Colony of Montserrat, 1994. Can
you read that, ma'am?
A. Yes, I do.
BY MR. PARRAS:
Q. Do you see the case is between James Stanford,
R. Allen Stanford, Don Caldwell, O.Y. Goswick, and the
attorney general of Montserrat. Do you see that?
A. Yes, sir.
Q. And you see that the case is before the Honorable
Justice Albert Redhead?
A. Yes.
Q. And then there's the names of the lawyers that
appeared for the parties. This was a case that was heard
on the 25th, 26th, 27th and 31st of August 1994, and this
is the judgment of the Court.
I'm going to turn to Page 20 and -- do you
know what this lawsuit was about, by the way?
A. No, I've never seen the document, so I have no idea.
Q. The government didn't show you this document when
they showed you the letter about the propose to revoke
GIBL language?
A. I have not seen this document.
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Cross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
1991
Q. All right. As a regulator who licenses corporations,
would it be important for you to know whether or not, in
fact, the license was revoked or not?
A. Yes, it would be.
Q. I'm going to go page by page, and eventually we will
skip a few.
You're a judge with the labor court;
court?
A. I am a member of the court, yes.
Q. You're not a judge?
A. There's a reference to a judge. I sit on a panel,
yes, of three judges.
Q. Are you trained in law?
A. I'm not.
THE COURT: She's a CPA or the equivalent of
our CPA.
BY MR. PARRAS:
Q. But you're not trained in law --
THE COURT: You never said you were an
attorney?
THE WITNESS: That's correct, sir.
THE COURT: Do you want to be an attorney?
THE WITNESS: Yes, sir.
THE COURT: You do?
THE WITNESS: Yes.
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Cross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
1992
THE COURT: Okay. Usually I get an absolutely
"no."
Okay. Go on.
BY MR. PARRAS:
Q. Ma'am, this letter, this opinion is in evidence, and
if the jury so chooses, they can read it in its entirety.
I'm going to represent to you that this is a lawsuit
regarding the idea that Guardian's bank's license was
revoked. And in this lawsuit, which the exhibit will
speak for itself, the directors of Guardian are suing the
attorney general of Montserrat so that the directors of
Guardian could affirmatively say their license had not
been revoked, okay? Do you understand?
A. I understand what you're saying, yes.
Q. I want to go -- it's Bates marked A Stanford 0010763.
And I'm going to read and you follow, and if I mess up,
you tell me, okay?
A. Uh-huh.
Q. "Allen Stanford" --
MR. WARREN: I'm sorry, Counsel. Can you
repeat that page, please?
BY MR. PARRAS:
Q. This is an opinion about the trial. "Allen Stanford
testified that at the very end of October 30th, 1990, the
government of Montserrat was informed of the bank's
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Cross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
1993
intention to leave and go to Antigua. This was before he
received the letter of 28th November 1990."
That's the Government's Exhibit 511, 28
November 1990.
The Judge goes on to say -- and these are
my markings. "Allen Stanford said on oath that on 30th
October 1990, he, James Stanford; Goswick; Judge Don
Caldwell, Jr., came to Montserrat, especially to inform
the government of Montserrat of the bank's intention. He
said they went to the governor's place of business and the
office of C.P. John and informed them.
"Allen Stanford said the chairman informed
Charles G. John of the bank's intention to move to Antigua.
Allen Stanford said that the chairman, James Stanford,
asked Charles John in his and in the presence of others if
there were any items that the bank needed to address prior
to its departure."
I want to stop right there. Does it sound
to you like the directors of Guardian International who are
about to leave Montserrat are going to the highest official
they can to make sure that things are okay?
A. On that reading, it would appear that way.
Q. It's the Judge's opinion? That's what he's saying;
right, that reading?
A. I'm not sure what I have before me is the Judge's
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Cross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
1994
opinion.
Q. Let's go to the front, then. Defendant's
Exhibit 214. Judgment in court. And if we go on the
back, who is it signed by?
A. Judge Albert Redhead.
Q. Do you have any doubt that this is an opinion by
Judge Redhead?
A. The sections you quote to me were not the opinions of
the Judge.
Q. Well, let's read further to be fair. "Stanford said
that he made a note of that conversation in that meeting.
Charles T. John denied that he ever told Allen Stanford
that Guardian International Bank had no problems in
Montserrat. He, however, testified that Allen Stanford
and the other members of the Guardian International Bank
visited his office on the 30th of October 1990."
So there's a dispute about what was said,
correct, from that reading?
A. It would appear that way.
Q. But there's no dispute that there was a meeting on
October 30th, correct, from this reading?
A. From the reading, yes.
Q. We'll read on to what the gentleman said. "The
purpose of the meeting according to my understanding was
that they were seeking a letter of good standing to
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Cross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
1995
certify that Guardian International Bank was in good
standing with us. I did not issue such a letter. At that
meeting, I cannot recall any of the directors informing me
that Guardian International Bank had taken the decision to
leave Montserrat. I did not issue a letter of good
standing, because in my view, there were some difficulties
which militate against me issuing such a letter:
"I told Mr. Stanford that there were
difficulties and I could not do it. I did not tell him
what the difficulties were, but I told him where he could
get the information. I did not at any time tell
Mr. Stanford that Guardian International Bank had no
problems in Montserrat."
That's the dispute, right, who said what;
correct?
A. It would appear that way from the document.
Q. Okay. "Charles T. Jordan, Charles T. John, said that
the Antiguan government did not ask for a letter of good
standing." That's another witness making another
statement. "I entertain no doubt" -- now we have the
Judge talking -- "whatever that the directors of Guardian
International Bank who were operating a bank in Montserrat
by the name of Guardian International Bank are the same
persons who are the directors of a bank in Antigua,
Guardian International Bank." Let's stop right there for
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Cross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
1996
a second.
It's clear to you from this judicial opinion
that the Judge is speaking about the same directors that
ended up moving to Antigua and later becoming regulated by
you; correct?
A. It would appear from that, yes.
Q. Okay. This is the Judge's finding here. "I
entertain no doubt either that prior to 30 October 1990,
the bank had consummated its plan to move to Antigua. If
the Antiguan government needed a letter of good standing
from the Montserrat government or if a letter of good
standing was a prerequisite, then in my view" -- Judge
speaking; correct -- "it would have been a simple and an
easy matter to obtain such a letter from a governmental
level. By this I mean it would have been an easy thing
for the government of Antigua to request such a letter
from the government of Montserrat."
As a regulator, ma'am, you could have
requested from Montserrat at any time that you were
director the files of Montserrat regarding Guardian
International Bank; correct?
A. There is something I need to make clear in terms
of --
THE COURT: In other words, you can't -- can
you answer the question yes or no. If you can't --
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Cross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
1997
THE WITNESS: I can't answer it yes or no.
THE COURT: Okay.
BY MR. PARRAS:
Q. You're the regulator now, right, of the FSRC in
Antigua?
A. I am the Chairman of the Board, yes.
Q. If you wanted to get information today about a bank
in Montserrat today, you could ask the government of
Montserrat for that information; correct?
A. We could make the request, yes.
Q. Let's keep reading, and I'll be done on the next
page. Down at the bottom. "Charles T. John having said
that he did not issue such a letter to Allen Stanford,
neither was one requested of him by the government of
Antigua. I must, therefore, conclude that such a letter
was not necessary so far as the government of Antigua was
concerned. If it was not necessary, then why would Allen
Stanford request one? I, therefore, accept Allen
Stanford's evidence in preference to Charles T. John's
evidence."
That's a finding; right?
THE COURT: That's a what, Counsel?
MR. PARRAS: A judicial finding, a fact
finding.
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Cross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
1998
BY MR. PARRAS:
Q. This is the Judge saying that he gives more credit to
Allen Stanford's account than Charles John's account;
right?
A. It would appear that way, yes.
Q. "This is, he, Allen Stanford, did not request any
letter of good standing and that the purpose of the
meeting of 30 October 1990 was to inform Charles T. John
of the bank's intention to move to Antigua.
"Mr. Kenneth Allen and Allen Stanford
testified that they went to the chief minister's office on
21 December 1990."
We're talking about a different meeting
now; correct?
A. It would appear that way, yes.
Q. "Mr. Allen said that at the chief minister's office,
he explained to the then chief minister, Mr. Osborne, that
the purpose of their meeting with him was to surrender the
A and B licenses of the time bank since we were about to
move to another jurisdiction and had seized business in
Montserrat and to thank him for the time we had operated
here.
"Mr. Allen said that he handed the chief
minister a large envelope which contained two original
licenses and later addressed to him -- and a letter
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Cross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
1999
addressed to him. He read the letter carefully, looked at
the two licenses, and then, according to Mr. Allen, said to
Allen Stanford, 'I'm sorry you're leaving because I've
always heard good news about your company.'"
That's what the opinion says; correct?
THE COURT: Counsel, that is a judicial
opinion?
MR. PARRAS: Yes, it is Judge.
THE COURT: Is that they write -- I guess they
write it in different jurisdictions different ways?
MR. PARRAS: Yes.
THE COURT: I mean, that --
MR. PARRAS: He probably was wearing a wig at
the time he wrote this.
THE COURT: Maybe they have it right. I don't
know.
MR. PARRAS: I always wanted to wear one of
those little legal wigs, especially now with this hair
going away, Judge.
THE COURT: They're hot. I've tried them on.
There is a wig store named -- what is it -- something in
Ravenscroft -- Ede & Ravenscroft in London, and I actually
went there to see what it was like and tried them on. I
don't need to wear it. It's hot. They're horse hair. And
the long -- the short ones are by the barristers and for
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Cross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
2000
judges when they try civil matters. When they try criminal
matters, they wear a red robe with a big long wig. I
learned all about that. I did not buy one.
MR. PARRAS: Going on to Page 25. And, again,
this is in evidence, the jury can ask for it. The jury can
read the entire thing. I'm going to go to Page 25, first
full paragraph.
BY MR. PARRAS:
Q. "Neither Mr. Kenneth Allen nor Mr. Allen Stanford who
were present at the meeting can recall John Osborne
handing the license to the financial secretary."
It sounds like we're talking about the
same meeting where licenses were handed over.
"In my view" -- Judge speaking -- "it is
not of critical importance whether John Osborne handed the
license to Charles John or not. What is of importance is
whether Allen Stanford handed over the license to John
Osborne." Now the Judge speaking. "I have absolute no
doubt that on 21 December 1990 Allen Stanford handed over
the original A and B licenses to John Osborne at his
office.
And this opinion also alludes to some
differences of opinion that Mr. Stanford had with a
regulator named Roe. And I want to show you what the
Judge's findings are in that regard. Here's the Judge
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Cross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
2001
speaking. "From the evidence, I have no doubt that there
was bad blood again Allen Stanford and Roe."
Do you know Mr. Roe?
A. No, I do not.
MR. PARRAS: Let me go to Page 38.
BY MR. PARRAS:
Q. "The evidence is that Roe was a banking advisor. He
was not a lawyer."
Do you see that? Right there where the
pen is pointed.
A. Okay. Yes, uh-huh.
Q. It's true, ma'am, that there are times when in your
business, in your job as a regulator, you either don't
have the legal answers or you need to seek legal advice or
you need a legal opinion or you're frustrated that the law
doesn't allow you to do something you want to do; correct?
A. I'll accept the last one.
Q. Well, there are times --
A. It's not been my experience.
Q. So it's your experience that the IBC act of 1982 has
everything needed and you've never been frustrated by the
law in your pursuit of information or regulatory?
A. I wouldn't use the word "frustrated," no.
Q. Okay. Have you had occasion to think it should be
better, the law the should be better?
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Cross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
2002
A. Laws can always be improved, and that's the case with
us as well.
Q. And then just to close this out again, last page,
signed Judge Redhead. There are some -- I believe these
were admitted as well, these articles, and at the end a
judgment of the Court 20 December 1994. And I'm going to
read the judgment. It's only a page.
"This action having been tried before the
Honorable Mr. Justice Redhead, without a jury, and the
said Mr. Justice Redhead having on the 31st day of
August 1994 ordered that judgment as hereinafter provided
be entered for the plaintiff."
Let's go back to the front. We have here
the plaintiffs, James Stanford, Allen Stanford, Don
Caldwell, O.Y. Goswick.
"It is adjudged and declared as follows:
That Guardian International Bank, Limited, ceased to do
business on the 19th of December 1990."
I'm going to skip ahead.
"That the licenses granted to Guardian
International Bank on 9 January '86 and the 14th day of
November '88 could not be revoked."
I'm going to skip ahead.
"That the revocation referred to in a
letter dated -- I think that's 19th June, '91 --
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Cross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
2003
"purported to have been made on the 31st day of May 1991
is null and void and of no effect."
Do you see that, ma'am?
A. Yes.
Q. Okay. And this, you'll agree with me, was 1994;
correct?
A. Yes.
Q. Long before you had any occasion to regulate SIBL on
the island of Antigua; correct?
A. Yes.
Q. So if it was necessary for your duties to learn about
the history, in addition to this letter that the
government showed you, it would have been important for
you to have this exhibit that the defense has shown you,
wouldn't it?
A. Yes.
Q. And that would have cleared up the matter; right?
A. Not necessarily.
Q. Do you want to take that up with Judge Redhead?
A. I don't have the benefit of having read the entire
document. I've been given sections of it. I don't know
how it all fits together cohesively.
Q. Thank you.
We're talking about regulations. And it's
true that in 1998 and in 1999 when you -- so difficult to
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Cross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
2004
see with that screen, ma'am, sorry.
In 1998 and in 1999, there was an effort
in Montserrat to make the laws, the offshore banking laws,
the international business regulation laws better;
correct?
A. In Montserrat?
Q. I mean, in Antigua. I'm sorry. Thank you.
A. Yes, uh-huh.
Q. And it's true that in 1996 there was a law passed in
Antigua regarding money laundering; correct?
A. That's correct.
Q. At that time in the world, the drug war was raging
all over the Caribbean, South America, Central America and
North America; correct?
A. I don't know that I have the expertise to answer
that.
Q. Well, the money laundering laws were an effort to
impose tighter controls on banks and on financial
services --
A. Uh-huh.
Q. -- in the Caribbean area and otherwise so that money
laundering could be shut down; correct?
A. Money laundering, yes.
Q. And that was 1996; right?
A. Yes.
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Cross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
2005
Q. And as time progressed into 1998 and 1999, what the
governments realized is that they had to also regulate the
financial services industry better; correct?
A. There was that realization that the sector had to be
regulated better, yes.
Q. And you were asked to join the Antiguan government in
an effort to make the bank, offshore bank, regulations
better; right?
A. Yes, uh-huh.
Q. You were asked to also join then Antiguan government
so that you could make offshore banking a business on the
Island of Antigua; correct?
A. That's not correct.
Q. You were asked to compare the Antiguan laws to other
Caribbean islands so that you could compete with places
like the Bahamas and the Cayman Islands for offshore
banking business; correct?
A. That's not true.
Q. Do you remember writing an International Financial
Sector operational plan --
A. Yes.
Q. -- in November of 1998?
A. Yes.
Q. You authored it; correct?
A. Yes.
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Cross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
2006
Q. You authored it under the -- as the executive
director of the International Financial Sector Authority
correct?
A. Yes.
Q. And it was commissioned and intended to give the
commission a quick plan for hypergrowth; correct?
A. Yes, uh-huh.
Q. Of the offshore sector?
A. Yes.
Q. So the Government of Antigua was looking to expand
the offshore banking business; right?
A. The international business. You see, you keep
focussing on banking sector. It's the international
business sector.
Q. That's a great point because international business
and the AIBCI doesn't apply just to offshore bank;
correct?
A. Exactly.
Q. It applies to --
A. A range of types of entities and services.
Q. Internet gambling services?
A. Internet gambling is not considered international
financial banking. International financial service, no.
Q. So then, what are -- just give me an idea of what the
range is.
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Cross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
2007
A. The range would include international insurance,
international trusts. We now regulate nonfinancial
business cooperatives. It's a wide range of regulatory
functions that we carry out.
Q. And -- and you wrote a report and presented it to the
board. And that was late of 1998; correct?
A. That sounds about right, yes, uh-huh.
Q. And it's true that at that time there was a group
called the "Offshore Financial Sector Planning Committee";
right?
A. Yes.
Q. Okay. I'm going to call it the OFS for short. Is
that okay?
A. The acronym doesn't quite fit, but yes.
Q. The -- that committee was not a government entity;
correct?
A. That is correct.
Q. That committee was made up to help the government to
strengthen their financial laws and regulations, the same
kind of work that you were doing; correct?
A. Yes.
Q. And it's that committee that Mr. Stanford was a
chairman of; correct?
A. Yes.
Q. And you objected to that; right? You didn't think it
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Cross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
2008
was proper?
A. No, I didn't object to that.
Q. Okay. You didn't object? You never lodged a
complaint? You didn't file a report with anybody in the
government saying that you thought it was improper for
Mr. Stanford to be chairman of the OFSPC, did you?
A. This was not a government body.
Q. I understand.
A. It's a civil body. Why would I object to a group of
business persons, in effect, to getting together to assist
the government.
Q. It was a good thing?
A. There's no need to object to that.
Q. It was a good thing, wasn't it?
A. I don't know that it was a good thing, but I know
there would be no need to object to it.
Q. You found no -- let's just move on.
Let's -- you will agree that, on that
committee, was a former FBI agent named Lloyd Harold;
correct?
A. I think -- I can't be sure that Harold was on that
committee. It's quite possible that he was.
Q. A former DEA agent named Tom Cash?
A. Yes. But --
Q. A U.S. customs agent named Pat' O'Brien, former U.S.
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Cross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
2009
Customs agent. Same division that Mr. Gerber works with;
right?
A. Uh-huh.
Q. And a -- there were accountants from the big -- the
big accounting firm, BDO Seidman; correct?
A. I don't recall that no.
Q. There were lawyers from Greenberg, Traurig; correct?
A. I know of a lawyer.
Q. Was that Carlos Lumiere?
A. The name that comes to mind is Patrick O'Brien.
Q. And Patrick --
A. That's not to say there wasn't. I just don't recall.
Q. And that's a good point.
In addition to being a former customs
agent he was a lawyer too; right? Pat O'Brien?
A. He was a lawyer, uh-huh.
Q. There was a gentleman who had been the head of the
Puerto Rican financial regulatory agency named Mr. Diaz.
Was he on that committee?
A. Mr. Ivan Diaz, yes.
Q. And then there was a former East Caribbean Supreme
Court Judge named Kenneth Allen who was on that committee;
correct? If you remember.
A. I can't recall that gentleman being on the committee.
Q. It's true that that committee was helping you to
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Cross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
2010
establish a regulatory framework for international
corporations?
A. This -- I cannot recall that committee doing that.
Q. What do you recall that committee doing?
A. In fact, the names that you mentioned, I know of them
as a team working on Operation Clean Slate.
Q. Okay.
A. The committee I was referring to when you asked me
early on was a committee I knew of as the Sectoral
Committee. This is why I said your acronym was not
correct, because you inserted the word "planning
committee," and I'm not familiar with the planning
committee. That's why I'm looking very confused because
the two things that I'm not -- that are not marrying at
all. They are two different things?
Q. Maybe you can help me then.
A. I would love to.
Q. There was a committee of private individuals that
were helping the government regarding the regulations that
you were working on as the executive director of the IFSA;
correct?
A. Among other things, yes. That was the Sectoral
Committee when I came on board.
Q. Okay. And then you came on board and you and your
team developed a plan that we talked about started in
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Cross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
2011
November of '98 and resulted in a second report in
February of '99; correct?
A. Yes. It's possible, yes.
Q. And could you describe basically what your report was
about?
A. This is so long ago. The report outlined what I saw
as the needs of the body to develop the sector to
strengthen the regulatory regime of the sector. That was
the broad theme of the report, if I recall correctly.
Q. Is it true that at that time the United States and
places like UK had concerns about the banking industry
down in Antigua?
A. It had concerns about operators in the sector, yes.
Q. And you and this private group were trying to address
those concerns.
That's fair, isn't it?
A. Not that group. I did not work with that group.
That's the point I want to make.
Q. Okay. Let's just stick to you then, what you know.
You were working to address concerns of
the international community regarding the regulations of
international companies on Antigua?
A. I was working as the person who was brought on board
to develop a regime that would make the jurisdiction
effective in respect to regulating the various
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Cross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
2012
international entities.
Q. Okay.
A. That was my task. It involved a number of things
that had to be done, from administrative to legislative.
It was a range of things that had to be put in place.
The team that you are describing is the
team I knew of Operating Clean Slate.
Q. Okay. Then I will get there then; okay? Let's just
stick to what you did.
You turned in your reports to the board
and they replied back basically saying, you know, that's
good work, but we need you to do more quicker, and they
gave you a memo outlining the various things that they
wanted you to do, 29, 30 items, with a definitive time by
which you should get them done; correct?
A. I remember that memo, yes.
Q. Did that memo upset you?
A. I was somewhat disturbed by the memo, yes. Some of
the timelines were unreasonable.
Q. You thought they were asking you to do too much too
quickly; right?
A. No.
Q. What did you think then? Why were you disturbed by
the timeline?
A. Because some of the things that were contained that I
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Cross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
2013
was being -- in that letter, that was being asked to do,
were things that could not reasonably be done in the
timeframe set.
Q. Okay. Is it -- do you remember that memo coming out
approximately two months after your second report in April
of '99?
A. That, I couldn't say for sure. It probably did.
Q. Do you remember in April of '99 that the United
States and the United Kingdom sent a message out to the
world about doing business on the Island of Antigua?
A. Yes.
Q. What was the message that the United States and the
United Kingdom sent out to the world in April of '99?
A. I don't recall exactly, but the gist of it was
essentially to -- alerting their constituents that there
were certain weaknesses within the regulatory regime in
Antigua and Barbuda. That's the general terms. I can't
remember the specifics.
Q. And here's where we get to Operation Clean Slate.
Either in conjunction with or as a result
of that message, a group of individuals who you called
Operation Clean Slate undertook the job to scrub the
island of all its banks; correct? Basically?
A. I never knew what was really the task of Operation
Clean Slate.
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Cross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
2014
Q. Okay. Is this the group that was asking for your
files, or is that a different incident?
A. It's the team, the Operation Clean Slate team, but
some of the names that you called are not familiar to me
as being part of the team. That's not to say they were
not.
Q. Okay. Which ones do you remember being part of
Operation Clean Slate?
A. I remember Lloyd Harold. I remember Pat O'Brien. I
remember Sandra Jeffrey. I remember Ivan Diaz and Cynthia
Roche.
Q. And what you're telling us here today is that, as the
executive director of the regulatory agency on the Island
of Antigua, you don't know exactly what Operation Clean
Slate was doing?
A. Sounds strange, doesn't it? But that was the case,
believe me.
Q. Do you know that eventually Operation Clean Slate was
able to scrub the banks, get rid of some Russian banks and
drop a number of international offshore banks from 50 down
to 25 or less?
A. Operation Clean Slate, its actions, what it did, what
the results were, were never revealed to me.
Q. Okay.
A. I don't have information leading to that. Anything
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Cross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
2015
that I had, any knowledge that I had, might have come
after; but certainly I don't know what they accomplished.
Q. Okay. Let's talk about after this.
It's clear to you that, after Operation
Clean Slate, GIBL was still operating on the Island of
Antigua; right?
A. I think so. If it was still Guardian. I'm not sure
when it changed to Stanford.
Q. It's either Guardian or Stanford?
A. Yes.
Q. But bottom line is, Operation Clean Slate ended.
Guardian or SIBL is still in operation; correct?
A. That is correct.
Q. And you were successful in getting your regulatory
framework up and running, weren't you?
A. As a result of Operation Clean Slate?
Q. No. Just --
A. Generally?
Q. You eventually started examining banks; correct?
A. In that regard, yes, uh-huh.
Q. You started sending examiners to the different
international banks, having them go through the
accounting, go through the procedures, go through the
banks's processes, and reporting back to you; correct?
A. I began that exercise, yes.
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Cross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
2016
Q. As a side note, were you aware that Guardian
International Bank or SIBL in the spring of 1999 wrote
a 3 million-dollar check to the United States Marshals
Service pursuant to an investigation regarding money
laundering, an allegation that one of its customers had
improperly used the bank?
A. I'm aware of that, yes.
Q. And that's true. That happened; right?
A. Yes. I'm aware of it, yes.
Q. Guardian International Bank and Mr. Allen Stanford
cooperated with authorities in the investigation of money
laundering, didn't they?
A. I don't know of that.
Q. We talked briefly about the bank secrecy that was
raised this morning.
Is it good business or bad business to
give your customer information out to anybody that asks?
A. Customer information?
Q. Yes.
A. No.
Q. All right. Is it good business or bad business to
give your competitors information about how you're
investing money?
A. That depends on the information and the nature of the
investment.
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Cross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
2017
Q. It's true, isn't it, that depending on the
jurisdiction and the country that you're in, different
rules may apply?
A. That is correct, yes.
Q. I want to talk a little bit about your island; okay?
A. Sure.
Q. Let me show you what I think has been admitted as
Government's Exhibit 516.
MR. PARRAS: And if I can get verification on
that.
THE COURT: It's in. The question is: Has it
been identified?
It hasn't been identified since I've been
keeping the list. Has it been identified before?
MR. WARREN: Yes, Your Honor.
THE COURT: Okay.
BY MR. PARRAS:
Q. I'm putting Government's Exhibit 5 -- 1516 --
THE COURT: Well, hold it. 1516?
MR. PARRAS: I thought it was five, Judge. I
misspoke. And I'm going to move this. Excuse me.
BY MR. PARRAS:
Q. I'm going to point to the far right where it says
Barbuda and Antigua.
Do you see that?
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Cross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
2018
A. Yes.
Q. Is that where were born?
A. I was born in Antigua, yes.
Q. You lived there until you left for college in
Florida?
A. Yes.
Q. Was Florida the first place you visited outside of
Antigua?
A. No.
Q. What other places had you been to before you went to
Florida?
A. Before I went to Florida, I had been to a number of
the other Caribbean islands, and basically that's the
extent of my travel, within the islands.
Q. I haven't been out there. Whether we say the West
Indies, what are we talking about on this map?
A. You're talking islands ranging anywhere from Trinidad
all the way up the chain to Anguilla.
Q. Okay. And it's true that -- and this is way off
subject, but not way off subject. But it -- the one thing
that you nights all of those islands is cricket; right?
A. You could say that, yes.
Q. There's a saying that cricket is the glue that binds
the West Indies; correct?
A. Not so much now, but there was a time, yes.
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Cross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
2019
Q. And that's -- you're going exactly where I was
thinking.
There was a time -- there was a time when
the cricket players -- and cricket's a lot like baseball;
right? It's not a lot. It's kind of like baseball.
A. It's not quite like baseball, no, but -- I wouldn't
say it's a lot like baseball, no.
Q. There was a time in the '70s, I believe, and into the
'80s when the West Indies cricket team were the premier
team of the world for 15 years running; right?
A. Yes.
Q. They became known as the legend; right?
A. Yes.
Q. And it's true that the islands rise and fall with the
success of the cricket team --
A. Rise and fall.
Q. -- of the West Indies?
A. Rise and fall in what respect?
Q. Well, heart and soul of the islands as a whole, as a
group, really come together behind the Westies; right?
A. Yes. Uh-huh.
Q. And during that time, the '70s and into the '80s, the
Westies, as they're called, traveled to?
A. Indies.
Q. The Indies -- West -- the Windies?
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Cross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
2020
A. Indies.
Q. Indies.
They traveled to places that had been
other colonial -- other colonies like Australia; right?
A. (Answered affirmatively).
Q. New Zealand, South Africa?
A. (Answered affirmatively).
Q. And they absolutely whipped all of the countries in
cricket where they went to for 15 years; right?
A. That's correct.
Q. They went to London and did that in London, didn't
they, against the English team?
A. All over.
THE COURT: All right, Counsel. Make the
point, please.
BY MR. PARRAS:
Q. Cricket was something that Mr. Stanford attempted to
revive in the Indies in the five, ten years before SIBL
was taken over; correct?
A. I don't know that that's the case, no.
Q. I'm going to show you what's been marked as
Defendant's Exhibit 1530, it's a series of photos. I want
you to look through them see if you recognize them.
And when you're done, let me know; okay?
Do you recognize those places?
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Cross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
2021
A. Not all of them.
Q. Okay. If you -- let me walk up there, if you don't
mind, and I'll put a little note on the ones you
recognize.
Can you tell me which ones you recognize?
This first one?
A. I don't recognize that.
Q. Okay. Second one?
A. Yes.
Q. Third one?
A. Yes.
Q. Fourth one?
A. Yes.
Q. Fifth one?
A. No.
Q. Sixth one?
A. Yes.
Q. This one?
A. Yes.
Q. There may be a few of them. How about that one?
A. Yes, sir.
Q. Is that one?
A. No.
Q. That one?
A. No.
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Cross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
2022
Q. That one?
A. Yes.
Q. Is this one?
A. No, that's not familiar.
Q. This one?
A. That looks like familiar. Yes, uh-huh.
Q. Yes?
A. I'm not familiar with that one. And, yes.
(Attorneys conferring)
MR. PARRAS: I should ask her.
MR. WARREN: That's fine.
MR. PARRAS: Judge, I move to admit
Government's Exhibit 1530.
THE COURT: Has it -- it's already is, isn't
it?
MR. WARREN: I'm not making an objection.
THE COURT: Has it been identified?
MR. PARRAS: I can --
THE COURT: Hold it. Counsel, has it been
identified?
MR. WARREN: I don't believe so yet, Your
Honor. We have no objection.
THE COURT: All right. So it's already in, but
it's now identified.
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Cross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
2023
BY MR. PARRAS:
Q. Just generally speaking, Ms. Crick, could you tell
the jury here what it is that you recognize in those
pictures?
A. I recognized pictures of buildings that house
Mr. Stanford's -- some of Mr. Stanford's businesses.
Q. Okay. Let me show you what is Bates Number 006.
Do you recognize that building?
A. Yes.
Q. Tell the jury what that building is?
A. It's Stanford International Bank Services.
Q. It's not a apartment in a strip club -- I mean a
strip mall, is it?
A. No, it is not.
Q. It's a big building for the Island of Antigua, isn't
it?
A. You said for the Island of Antigua?
Q. On the Island of Antigua, it's actually a nice
building?
A. It's a building on the Island of Antigua.
Q. Is it a nice one?
A. You could say that, yes.
Q. You indicated that you recognize this building.
Could you tell the jury what this building
is?
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Cross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
2024
A. This is a hangar, aircraft hangar.
Q. Who owns the hangar?
A. As far as I'm aware, it's owned by Stanford, one of
Stanford's companies.
Q. Is it still on the Island of Antigua?
A. I think it is. I'm not absolutely sure.
Q. When you fly in and out of Antigua, do you fly in and
out of the airport attached to this hangar?
A. The airport attached to that hangar?
Q. The airport where this hangar is located?
A. In the general region, yes.
Q. Do you have more than one airport on the Island of
Antigua?
A. We have one airport, yes.
Q. Okay. When you fly out, do you fly out of this
airport?
A. Yes.
Q. Okay. And this is in evidence, but you didn't
recognize this building; correct?
A. No. I don't know. I'm not familiar with that
building.
Q. You did say that you recognize this building. And
it's at Bates 000015.
What is this building?
A. That's the building that houses Bank of Antigua.
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Cross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
2025
Q. Now, Bank of Antigua is the bank that serves
Antiguans that Mr. Stanford or SIBL or -- and I don't know
exactly who right now, but that is part of the Stanford
entities; correct?
A. Yes.
Q. Okay. You told me you recognize this as an aerial
view of the cricket field?
A. That's true yes.
Q. And it's true that this cricket field is one of the
best cricket fields in the world; right? Do you know
that?
A. I don't know that.
Q. It's -- okay.
A. I'm not a cricket field expert.
Q. Have you been to a cricket match on this field?
A. No.
Q. All of the buildings that we just looked at to your
knowledge continue to exist on Antigua; correct?
A. The buildings are there, yes.
Q. Do you know whether there's an Antiguan receiver who
is in control or who has ownership of those buildings
right now?
A. I know there is a liquidator. Whether the person has
control, to what extent, that, I'm not familiar with.
Q. Have you seen any of the liquidators or attorneys for
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Cross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
2026
the liquidators in court here this week?
A. No.
Q. Okay. And you do know that there's another receiver,
a second receiver, in the United States who is in a legal
dispute with the Antiguan receiver about ownership of SIB
assets; correct?
A. I know there's a dispute. I don't know the exact
details of the dispute.
Q. On direct examination, you talked about a Mr. Hewlett
offering you a job to go and audit the Bank of Antigua;
correct?
A. To partner with him in conducting the audit.
Q. At the time -- do you remember what year he asked you
to do that?
A. No, I don't recall. But I know it was in the --
maybe the late '80s, I think it might have been, or early
90s, somewhere around there.
Q. Did Mr. Hewlett have a good reputation or a bad
reputation on the island?
A. I don't know that he had a good -- in respect of
what?
Q. Well, in respect to your decision to possibly partner
with him, did it concern you to concern to partner with
Mr. Hewlett?
A. No, it did not cause me concern.
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Cross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
2027
Q. In fact, as late of 2007, you and Mr. Hewlett were on
the same auditing organizations, island organizations;
correct?
A. Yes. He's a certified accountant on the island.
Q. And on direct, I believe you were asked about the
annual reports.
You know that Mr. Hewlett signed every
single one of these audits, these annual reports, that you
were asked about? Do you know that?
A. The annual reports?
Q. The SIBL or GIBL annual reports.
A. The auditor's report?
Q. Yes.
A. He signed. He was the auditor, yes. He would have
signed them.
Q. Let me show you what's been introduced as
Government's Exhibit 111.
MR. PARRAS: And I could -- I could use some
help here, PDF Page 27, please. Government's Exhibit 111.
MR. SCARDINO: Need to switch, Judge.
THE COURT: Okay.
MR. PARRAS: And if we could zoom in on the
signature and address at the bottom.
BY MR. PARRAS:
Q. Is that the company and the address where from
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Cross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
2028
Mr. Hewlett worked?
A. Yes.
MR. PARRAS: Okay. If we could go back out to
the full page. And if we can focus on the opinion at the
very end there.
BY MR. PARRAS:
Q. And I'm going to read this out loud. If I mess it
up, please tell me.
"In our opinion, the financial statements
give a true and fair view of the state of affairs of the
bank as at 31 December 1998, and of the result of its
operation for the year then ended. The statements have
been prepared to comply with international accounting and
financial reporting standards and the companies law of
Antigua and Barbuda."
MR. PARRAS: This -- if we could can to the
first page of this exhibit to see what year it is. And if
we could zoom in there on annual report 1998.
BY MR. PARRAS:
Q. Is this an annual report that at this time would have
been subject to a regulatory -- an Antiguan regulatory
body or agency for review?
A. It would have been submitted, because it's a
requirement, yes.
Q. Okay. And to your knowledge as the executive
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Cross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
2029
director of the regulatory body just a year later, was
there ever any complaint, professional complaint, about
Mr. Hewlett?
A. Professional complaint, not that I can recall.
MR. PARRAS: Okay. Let's go to Government's
Exhibit 112, PDF 30 and let's start with the first page,
PDF 1, please. If we can go to the first page. I'm sorry.
BY MR. PARRAS:
Q. What year is this, ma'am?
A. 1999.
Q. Okay. At that time, you were head of the -- the
executive director of the regulatory agency on Antigua;
correct?
A. Yes.
Q. If you wanted to, you could have looked through a
comb of this report and asked the bank to go in and
examine their paperwork; correct?
A. We could have, yes. I'm just trying to -- I'm
hesitating for a reason.
MR. PARRAS: Well, let's go to PDF Page 30.
And zoom in on the signature and address block at the
bottom.
BY MR. PARRAS:
Q. That's Mr. Hewlett's signature and his working
address there on the island?
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Cross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
2030
A. The address, yes. The signature appears to be his.
MR. PARRAS: Okay. Let's zoom back out.
BY MR. PARRAS:
Q. And this one is harder to read, but let's try reading
the opinion again.
MR. PARRAS: That one -- yeah, we'll go to the
next year. Please pull up Government's Exhibit 113. Go to
the first page and show us what year this is in the bottom
left-hand section of the report.
BY MR. PARRAS:
Q. You see that that's the 2000 annual report; right?
A. Yes.
Q. You were the executive director of the Antiguan
regulatory agency at that time; right?
A. Yes.
MR. PARRAS: Let's go to PDF Page 37. And if
we could -- I'm going to read the whole thing this time.
If you could zoom in, please, on the first two paragraphs.
The whole thing, please, right above that.
BY MR. PARRAS:
Q. Okay. The title says "Auditors' Report to the
Members," and then Mr. Hewlett's signature is under the
statement.
"We have audited the financial statements
on Pages 18 to 31."
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Cross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
2031
And then there's the heading, "Respective
Responsibilities of Directors and Auditors."
"As described on Page 34, the company's
management is responsible for the preparation of the
financial statements. It is our responsibility to form an
independent opinion based on our audit of those statements
and to report our opinion to you."
MR. PARRAS: Let's go to the next.
BY MR. PARRAS:
Q. "Basis of opinion."
"We conducted our audit in accordance with
international auditing standards, which include
examination on a test basis of evidence relevant to the
amounts and disclosures in the financial statements. It
also includes an assessment of the significant estimates
and judgments made by the directors in the preparation of
the financial statements, and of whether the accounting
policies are appropriate to the bank's circumstances" --
MR. PARRAS: Let's move that up, please.
BY MR. PARRAS:
Q. -- "consistently applied and adequately disclosed.
We planned and performed our audit so as to obtain all the
information and explanations which we considered necessary
in order to provide us with sufficient evidence to give
reasonable assurance that the financial statements are
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Cross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
2032
free from material misstatement, whether caused by fraud
or other irregularity or error."
MR. PARRAS: If you can move that up, please.
BY MR. PARRAS:
Q. "In forming our opinions, we also evaluated the
overall adequacy of the presentation of information in the
financial statements."
MR. PARRAS: Next paragraph please.
BY MR. PARRAS:
Q. And before I go on, the auditor, Mr. Hewlett, his
signature, is telling people that he has reviewed
financial statements, that he has made an independent
judgment about the adequacy of the financial statements,
and is representing that they are free from material
misrepresentations, fraud or other irregularities;
correct?
A. Uh-huh.
Q. Okay. Let's go to his opinion.
"In our opinion, the financial statements
give a true and fair view of the state of the company's
affairs as at 31 December 2000, and of the results of its
operation for the year then ended. They have been
prepared to comply with international accounting and
financial reporting standards and the company's law of
Antigua and Barbuda."
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Cross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
2033
And then it's signed underneath by
Mr. Hewlett.
Have you had an occasion to go through all
of the annual reports available to you for the SIBL and
GIBL entities while they existed on Antigua?
A. That would have been done, and I cannot recall if I'd
gone through all of the reports, which is your question.
Q. Yes.
A. But I know reviews were made of audited financial
statements prior to the examination which was first
conducted -- the first on-site examination which was
conducted in 2001, I think.
Q. Okay. I think I'm going to break that down because I
think I know what you're saying and I want to be sure;
okay?
A. Uh-huh.
Q. That once your regulatory regime was set up, you
asked the -- whoever you asked, the SIBL or GIBL, whatever
it was at the time, you asked them to give you their
annual reports in preparation for your examination, for
your agency's examination?
A. I think we would have been in possession of them. I
can't be sure. But I think we might have been in
possession. If not of all, of some of them.
Q. Did you ask for other information as well?
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Cross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
2034
A. There were other documents, pieces of information,
that we would have requested, yes.
Q. And were you provided that information?
A. I don't know. I can't be sure.
Q. If you were not provided that information, would you
have correspondence about it?
A. There ought to have been, yes.
Q. Did you bring any correspondence with that regard
with you to the U.S. from Antigua?
A. No.
Q. Did you bring any records from the Island of Antigua
to the U.S. for your preparation and testimony here today?
A. Any documents, no.
Q. Did you bring any reports, notes, memos, exams,
anything in writing, that would help you to prepare for
your testimony here today?
A. I do have a document that I made some notes on, yes.
Q. Where is that document now?
A. That's in my possession.
THE COURT: All right. Counsel, this may be a
time to take a break. We began about 10, 12 minutes,
15 minutes behind schedule, so some folks have been out
they're here for our hour and three-quarters.
MR. WARREN: Before we could take a break, I'm
not sure if counsel is coming back to those documents, but
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Cross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
2035
we would just ask for an instruction reminding the jury
that those annual reports have not been admitted for the
truth, but only as to what the investors were told.
THE COURT: That's so noted. That's so noted.
Let me get the screen up.
Okay. We'll see you back ready to resume
in 15 minutes. See you at that time.
(Recessed at 11:41 a.m.)
THE COURT: Tell the jury we'll be with them in
about a minute.
Have a seat. What have you got to bring
up?
MR. WARREN: Your Honor, Mr. Parras handed me
two documents, one he handed me at 10:00 o'clock this
morning, the other one he handed me after the court broke,
that he intends to use on cross-examination.
Just note for the Court these weren't
produced in a timely matter as with the Court's order from
last week. They've had more than a week's notice with
Ms. Crick. These are not surprise documents. This goes --
one of them is part of her testimony. The other is
actually beyond the scope of direct in the first place.
But we would just note our objection to counsel using these
documents.
THE COURT: Wait a second. Not note your
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Cross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
2036
objection, do you object?
MR. WARREN: Yeah, we do object.
THE COURT: Okay. What's the first one, the
left hand, what's that?
MR. WARREN: This document is a letter from
November 29, 2000, regarding a certificate of good standing
that Ms. Crick issued regarding some of the directors of
the bank.
THE COURT: Okay. Have you ever seen those
before -- that before?
MR. WARREN: I've seen this document before,
Your Honor.
THE COURT: But you didn't know it was coming
here?
MR. WARREN: Did not.
THE COURT: What's the other one?
MR. WARREN: The other one I don't believe I've
ever seen before. It's from 1999. This was a document
just handed to me maybe ten minutes ago that has to do with
the growth of the international business corporations.
Mr. Parras went into that on cross-examination. It's
beyond the scope.
THE COURT: Aside from that, had you ever seen
it before?
MR. WARREN: No, Your Honor.
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Cross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
2037
THE COURT: What's your response?
MR. PARRAS: As to the first document, Judge,
it is a document that was produced to us by the government.
The reason that it is --
THE COURT: First document objection is
overruled.
MR. PARRAS: The second one, Judge, we did talk
about it --
THE COURT: Now, hold it. Let me make a note
on that.
And you've got a list, Ellen, and so do I.
That was -- that's defense document;
correct? Mr. Parras?
MR. PARRAS: Yes, Judge.
THE COURT: What number is it?
MR. PARRAS: I haven't given it a number. I
think we're on 10-1.
THE COURT: I don't know what you're on. You
got 17,000 documents. I don't know what number this is.
MR. PARRAS: Well, we're working to narrow it
down, so we've had to change our numbering system.
THE COURT: Well, you change it down to 100s?
MR. PARRAS: We started to do witnesses --
THE COURT: How many thousands do you have now?
Don't answer that question. I'm looking for hundreds, low
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Cross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
2038
hundreds. Hold it. Give it a number. Anybody.
MR. WARREN: 15,742, Your Honor.
THE COURT: That's a good number. Give me a
number eventually.
But, Ellen, I'm going to put a blank
there. That is admitted.
The other one?
MR. PARRAS: The second one, Judge, they're
correct, we have -- this is not from their production. It
is a letter that we talked about on cross-examination, and
it basically outlines the 30 points that the board,
regulatory board, was asking Ms. Crick to complete that she
talked as being lengthy and probably some of these not
being possible within the time given. I just want to get
it in to support the testimony.
THE COURT: Objection sustained as to that
second document.
All right. Are we ready to call the jury
in?
MR. WARREN: Nothing further from the
government, Your Honor.
THE COURT: All right. Let's go.
(The following was held before the jury)
THE COURT: Before we get going, I've stopped
the clock. A 30-second story, a 30-second short note, the
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Cross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
2039
comment was about wearing wigs. There's a book that was
just recently published by former Supreme Court Justice
John Paul Stevens. He was on the court for 30 years. I
had met him on a number of occasions. Wonderful man.
It's entitled five chiefs, about the five
chief justices either he worked for or knew. And there was
a story that he told when Associate Justice William
Rehnquist became the chief justice. A couple of months
after he was chief, he showed up one time with a robe that
had four gold stripes sewn into the sleeves. And
apparently they were talking about it behind the scenes of
the Court. Of course, no one ever complained to the chief.
But it was a from a Gilbert -- the chief had seen it years
ago in a Gilbert & Sullivan production, and in that
production by that cast, there was a judge and he was
wearing a robe with four stripes. So for his tenure on the
Court, that's what he did.
And we've asked -- what is it -- Chief
Justice Roberts -- or at least Chief Justice Roberts does
not wear one. He became chief. He's now in plain black
robe.
So it's just a little story about what
goes on at the high 9. Fascinating book. It's a short
book, but it was most enjoyable.
With that, now that that is over and done
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Cross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
2040
with, defense time begins. Go on.
MR. PARRAS: Thank you, Judge.
BY MR. PARRAS:
Q. Last year, Ms. Crick, okay? It's about your work as
a regulator on the island of Antigua, and I want to go a
little bit backwards to the spring of 1999.
If we remember correctly, in November you
wrote your first report, in February you wrote your second
report, and then sometime later, about April, there was a
response from the board with the 30 points, that you took
issue with some of them, but there's no doubt there were
approximately 30 points. And these were tasks that the
board felt you should complete so that the regulatory
agency could be set up and start working for the island;
correct?
A. Basically, yes, uh-huh.
Q. Each one of those tasks required money so that the
infrastructure and implementation could be put into place;
right.
A. That's not true.
Q. Well, let's talk about some of the tasks. You
certainly wanted to get an Internet system up for your
regulatory agency so that people could become licensed
over the Internet, that would be easier for people
offshore to become incorporated on the island; correct?
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Cross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
2041
A. As a general requirement, yes, it's part of the task.
I don't recall that being in terms of a priority. Might
have been, but I don't recall it being a priority.
Q. Would it help you or help you to remember if you were
to look at the memo itself?
A. Yes, it would.
Q. Okay. I'm going to hand you this, and I'm just going
to ask you to look at it, read it to yourself, and when
you're done, let me know, okay?
A. (Reading document.)
Q. Have you finished, ma'am?
A. Yes, appears to.
Q. Did it help you to remember some of the things that
the board --
A. Yes, it did. It did.
Q. Go ahead and tell the jury the kinds of things that
the board wanted you to complete so that your agency could
start doing its work.
A. Prepare, recruit staff, train staff, improve the --
as you mentioned before, the services that would be
provided by an Internet platform. Prepare budget to
support the overall development and, in fact, a budget for
each of the various items.
Q. And --
A. The other information on some various offshore
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Cross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
2042
sectors on the development of the sector, the industry in
the region. I did a quick read, so I'm really just trying
to --
Q. It's fair to say that there were a number of other
requests, but the bottom line was they wanted you to get a
regulatory agency in place and to hit the ground running;
correct?
A. You could say that.
Q. And you ended up doing that, didn't you?
A. Putting -- to some extent, yes.
Q. You hired staff?
A. Yes, I did.
Q. Staff that you felt were adequate to the task;
correct?
A. Recommended, yes, uh-huh, but a staff -- interview
staff that I thought would have been -- had the skill
sets, yes.
Q. And when do you think it was that you and your
regulatory agency started to examine the businesses under
your jurisdiction?
A. It would have been sometime 2000, 2001.
Q. Okay. I want to talk specifically now about SIBL.
You testified yesterday about the first examination, a
gentleman named Mr. Quelley and others were sent out
Mr. Quelley -- you got a call about Mr. Quelley, and the
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Cross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
2043
next thing you know -- the next thing you told us was that
you were on a tour of the Caribbean with Mr. Quelley,
yourself and a gentleman named Mr. Ferrance?
A. Yes, uh-huh.
Q. That was the first examination of Stanford
International Bank?
A. That I can recall.
Q. Do you remember approximately what time of the year
that was?
A. It was sometime in August or September of 2001.
Q. And did you do a subsequent examination -- August or
September, would that have been with Francis De Abreu?
A. Yeah, De Abreu, yes.
Q. And Peter Quelley was the junior examiner on that?
A. Yes, uh-huh.
Q. And Trevor Bailey was the senior examiner on that
team; correct?
A. Not initially, no.
Q. After Mr. Quelley taken off, then Mr. Trevor
Bailey became --
A. That's correct.
Q. Before we get there, did you have occasion to examine
Stanford International Bank and its directors once you had
your regulatory agency up and running because they
requested a certificate of good standing?
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Cross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
2044
A. To examine them, I don't recall that.
Q. Do you think it would refresh your recollection to
see some correspondence?
A. Sure.
Q. Maybe we can do it this way. You can keep reading.
Do you recognize this document?
A. Yes. I'm the author of the document.
Q. It's something you -- it's your signature?
A. Yes, uh-huh.
Q. Do you remember writing it?
A. Yes.
MR. PARRAS: Move to admit Defendant's
Exhibit --
THE COURT: Is that the one we don't have a
number for yet?
MR. PARRAS: We're going to give this one -- it
is Judge. That's exactly the one. We're going to give it
10-1.
THE COURT: 10-1?
MR. PARRAS: Yes.
THE COURT: 10-1, we've already discussed it.
It's admitted.
MR. PARRAS: Let me put this on the board,
please, the ELMO.
MR. WARREN: Your Honor, we have an objection
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Cross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
2045
just to the copy we have as handwritten comments on it, I'm
not sure if those handwritten comments have been
authenticated. I don't know whose they are.
MR. PARRAS: I'll try to clear it up, Judge,
before I show it to the jury.
THE COURT: Okay.
BY MR. PARRAS:
Q. Ms. Crick, do you recognize the handwriting there on
the left margin as yours?
A. No.
Q. Do you recognize it as someone in your agency?
A. No, not that I can recall right off, no.
MR. PARRAS: Judge, I'll redact that portion
out.
THE COURT: Do you want to put a sticker over
it or something?
MR. PARRAS: I'm going to grab something from
my bag.
Okay. If I can have the ELMO, Judge.
THE COURT: All right.
BY MR. PARRAS:
Q. Do you recognize that, Ms. Crick, as the letterhead
for the agency that you were the executive director of?
A. Yes.
Q. And I'm going to start reading -- this is addressed
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Cross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
2046
to Stanford International Bank; correct?
A. Yes.
Q. And I'm going to start reading there. "We knowledge
receipt of your request for a certificate of good standing
made on November 23, 2000. We wish to inform you,
however, that a letter requesting approval of Sir Courtney
Blackman and Mr. Robert Winter as directors should be
submitted to the authority. In accordance with Section 10
of the statutory instruments number 41 of 1998 of the
International Business Corporations Act Number 28 of" --
THE COURT: Slow down a little bit.
BY MR. PARRAS:
Q. -- "1982 as amended, which states: No licensed
institution shall make a change to its directors or the
director or indirect legal or beneficial owner of
5 percent or more of a class of shares in the institution
without the prior approval from the authority."
I'm going to stop right there, stop
reading.
What you were telling Stanford
International Bank is before you should issue a letter of
good standing, it had to comply with some statutory
requirements that you were now in charge of enforcing;
correct?
A. That's correct, uh-huh.
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Cross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
2047
Q. And specifically in this paragraph, they needed to
give you more information about Sir Courtney Blackman and
Mr. Robert Winter; correct?
A. Not more information. They needed to obtain -- they
needed to request approval because they were coming on.
There was a change in directors, and they had not made
that request.
Q. Okay. Next paragraph. "Additionally, the following
information is outstanding for Courtney Blackman: One
professional reference, and this is in addition to the one
on file, a statement whether Sir Blackman has ever been
formally charged or indicted with the commission of a
crime, criminal offense in any jurisdiction, and if so a
description of the offense charged and a statement of the
outcome of the charge. Three, a letter from Sir Blackman
accepting the position as the director of the bank."
These requirements -- I'm going to stop
there. Turn to Page 2 and ask you some questions.
These requirements were requests by you as
the regulator for more information; correct?
A. Yes.
Q. The application that a International Corporation has
to fill out only requires that you list the names and
addresses of the boards of directors; correct?
A. The application for?
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Cross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
2048
Q. Application for incorporation under the IBC Act. If
you know. If you don't know --
A. It only requires the name of the -- an address of the
directors.
Q. Well, it actually has four or five statutory
requirements, but when it comes to the names of the
directors or the identity of the directors, the only thing
that's asked about the directors are their names and
addresses; correct?
A. On the form itself, that's possible.
Q. However --
A. I can't recall the contents of the form immediately,
but --
Q. Okay.
A. -- that's possible.
Q. Okay. If you wanted to ask for more information, you
have the power to do so; right?
A. That is correct.
Q. And what you're doing here in this letter is
exercising that power to a degree; correct?
A. Yes.
Q. It's not required anywhere on the application that
you say whether you've been in a discharged bankruptcy,
whether you have never been in bankruptcy, whether --
that's something that's not asked on the form; correct?
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Cross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
2049
A. It depends on which form you're referring to, because
there is the form you just described, but there is also,
if I remember correctly, a form that lists additional
details about the applicant.
Q. Okay. What about the statute? The statute doesn't
require that you turn in that information when you file
your application; correct?
A. It does not, but it does say that upon applying, the
supervisor can -- it makes provision, let me say, for the
supervisor to request any information.
Q. And that's the point I'm trying to make. It makes
provision for the supervisor to request information. It
does not put the duty on the applicant to report the
information; correct?
A. No, that's not correct.
Q. Would it help you to look at the act itself?
A. If I may be allowed to explain.
Q. Would it help you to look at the act --
A. I'm trying to assist you. If I could explain.
THE COURT: But that's up to the attorney.
Do you want to allow her to explain or are
you going to go on to the next question? Either way it's
okay. It's cross-examination. Go on.
BY MR. PARRAS:
Q. If I could show you something, it may refresh your
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Cross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
2050
recollection, perhaps you could point me to what you're
talking about.
A. Sure. Uh-huh.
Yes, I've read it.
Q. Okay. It's true that within the application itself,
the statutory application, that information is not
required; correct?
A. That is not correct.
Q. What subsection do you think applies --
A. 232.
Q. And I'm getting there.
MR. PARRAS: Judge --
BY MR. PARRAS:
Q. Do you recognize what's in front of you, ma'am, what
you're reading?
A. It's a section from the International Business
Corporations Act.
Q. Do you have any reason to believe that it's
inaccurate or not the actual language of the act itself?
A. I'm not in a position to say that just looking at
this document, no.
Q. Okay. What -- from your memory, okay, from your
memory, what is Section 231 titled?
A. Section 231 is -- it's not even titled.
Q. Is it titled Formalities?
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Cross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
2051
A. I don't have this before me.
Q. Let's go this way: Does Section 231 list five
requirements for the application?
A. Along -- yes, along with Section 232.
Q. And I'll get to 232. Let's just talk about 231.
A. Okay. Fair enough. 231.
Q. Among the five subsections, is there any requirement
that you indicate whether you've ever been in a
bankruptcy?
A. No, it does not make an indication there.
Q. And Section 232 is a section that applies to the
regulator on receipt of the application; correct?
A. That is not correct.
MR. PARRAS: Judge, I move to admit this as
Defendant's 10-2. I provided to the government early this
morning. It's something that I had not --
THE COURT: Wait a second. Did I rule on that
already?
MR. WARREN: It's a different document, Your
Honor.
THE COURT: It's a different document. Okay.
Go on.
You move to admit 10-2. No.
What's the position of the government?
MR. WARREN: Objection, Your Honor.
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Cross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
2052
THE COURT: Why?
MR. WARREN: Well, for one, it was given to us
just earlier this morning in violation of the Court's prior
order.
Also, it hasn't been authenticated. It's
hearsay. The witness said she doesn't know whether it's
authentic.
THE COURT: Sustained.
BY MR. PARRAS:
Q. Ma'am, you're the regulator for the Antiguan
government regarding the IBC Act; correct? As it applies
to international corporations?
A. Yes.
Q. Is it your testimony that Section 232 of the statutes
that you regulate does not apply upon receipt of an
application?
A. Yes.
Q. It's clear to you that, once an application is filed,
you have the power to ask for more information if you want
to; correct?
A. That is correct.
Q. Okay. Let's go back to this letter that is in
evidence.
Defendant's Exhibit 10-1, third paragraph,
second page.
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Cross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
2053
"The following information is needed for
Mr. Winter:
"A complete and up-to-date curriculum
vitae.
"Two references from well-established
banks stating the nature and extent of their knowledge of
and experience with him.
"A legible copy of Mr. Winter's passport
containing his photograph, as well as the passport numbers
and date and place of issue.
"One professional reference should be
submitted. Please note that this is in addition to the one
previously submitted.
"A letter from Mr. Winter accepting the
position as director of the bank.
"You are hereby requested to submit the
outstanding information as soon as possible so as to
complete the processing of the certificate of good
standing. Please be guided accordingly.
"Respectfully, M. Althea Crick, Executive
Director."
Did I read that correctly?
A. That's correct.
Q. You were asking for more information; correct?
A. Yes.
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Cross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
2054
Q. You didn't ask for information about Mr. Allen
Stanford, did you?
A. No. This letter does not.
Q. You could have asked for information about Mr. Allen
Stanford; right?
A. I could have asked for information for him, yes, if
it was necessary.
Q. If it was necessary.
So you didn't think it was necessary to
later on certify this --
THE COURT: Look at the witness. Don't argue
it to the jury. They're listening.
BY MR. PARRAS:
Q. You didn't think that it was necessary to ask for
more information beyond this letter so that you could
eventually issue a certificate of good standing; correct?
A. Correct.
Q. And eventually, you did issue a certificate of good
standing; correct?
A. That is correct, in keeping with what it is that the
certificate of good standing actually states.
Q. Okay. We talked about the first examination. And
it's true that, in addition to regulating the banks and
offshore companies on Antigua, you started to seek out
agreements with other jurisdictions on
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Cross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
2055
information-sharing; correct?
A. That's one of the things we did, yes.
Q. And what you did in July of 2001 is, you reached out
to the State of Texas and you entered into the first
agreement between Texas and a foreign entity to share
information; correct?
A. That is correct.
Q. You were proud of that? That was had a good thing,
wasn't it?
A. Yes, it was a good thing.
Q. I'm going to show you what's been marked as
Government's Exhibit 666.
And if you could look at it and let me
know if you recognize it, please.
A. Yes, I'm familiar with the document.
Q. Okay. While we're at it, let me show you what's been
marked as Government's Exhibit 615.
Also look through that and see if you
recognize it.
A. Yes.
Q. Speaking about Government's 666, is that something
that your agency produced?
A. Yes.
Q. Okay. And then and speaking about Government's
Exhibit 615, is that something that you received in your
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Cross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
2056
capacity as the executive director?
A. Yes.
MR. PARRAS: Move to admit Government's
Exhibit --
THE COURT: It's already in. All of the
Government's exhibits are in subject to the defense
specifically objecting to when it's referenced. So go
right ahead.
MR. PARRAS: Thank you, Judge.
BY MR. PARRAS:
Q. Let me show you the dates on both of these quickly so
that we could start with the first one.
Looking at Government's Exhibit 666. This
is --
MR. PARRAS: Let's go to the top here.
BY MR. PARRAS:
Q. -- a confidential report, violations and
recommendations for examination of Stanford International
Bank; correct?
A. Yes.
Q. And down here, it says "Examined by," and then it
lists the names and has dates; correct?
A. That is correct.
Q. And the dates are August through September 2001;
right?
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Cross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
2057
A. Yes.
Q. Do you recognize this as the first report of the
first exam of Stanford International Bank?
A. I believe it is, yes.
Q. Okay. And if we were to flip through Government's
Exhibit 666, what we would see -- let me back this up --
is that you have, you and your agency have written a
number of points that you would like the bank, Stanford
International, to address; correct?
A. That is correct.
Q. Now, going to Government's Exhibit 615, dated
November 9, 2001, addressed to Ms. Althea Crick, and
signed by Frans Vingerhoedt.
Do you see that?
A. Yes.
Q. It's true that this letter is a response, a
point-by-point response, to your first exam inquiry;
correct?
A. That is correct.
MR. PARRAS: And at this point, Judge, if I
could have the computer turned on back there. So I need
the help of the ladies. Thank you.
BY MR. PARRAS:
Q. I want to go back through these two documents,
Government's Exhibit 666 on your left and Government's
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Cross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
2058
Exhibit 615 on your right. And I think that when they
come up, they're either going to be either side-by-side or
top and bottom, and we'll be able to -- I hope we'll be
able to tell which one is your report and which one is the
response.
MR. PARRAS: Next slide, please.
BY MR. PARRAS:
Q. All right. Looking at Section 1.1. Do you recognize
the top portion as the -- coming from your report,
Government's Exhibit 666?
Do you recognize the top portion as coming
from your report, Ms. Crick?
A. Yes.
Q. And the bottom is coming from the response; correct?
A. Yes.
Q. And these are in evidence, so the jury will have them
to read.
But the complaint that you're telling SIB
about is that some of the loans did not have a purpose
identified on the paperwork; correct?
A. It speaks to loan application forms having not been
seen in all the files examined.
Q. And the second sentence says, "The examiners were
unable to establish the purpose of the loan in order to
verify compliance with the IBC Act; correct?
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Cross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
2059
A. Yes.
Q. And the response of the bank was -- is there at the
bottom, and I'll read it: "Loan portfolio
administration."
"Current loan request/application forms,
implemented in 1998 are mandatory for all new loans,
include a section for specification of the purpose of the
loan. Your recommendation is fully implemented."
Are they telling you that before 1998,
you're right, we have some problems and we're fixing them?
Is that basically what they're saying?
A. It says that they have -- they have now complied with
our recommendation, yes.
Q. And if we were to go through the letters together and
I'll just go through these slides --
MR. PARRAS: Next slide, please. 2.1, 2.1,
next slide, please. 2.2, 2.2, next slide, please. And try
to line up the paragraphs here, same 2.2, next slide,
please, 2.3. Next slide. And if you could scroll through
the rest of the slide, please.
THE COURT: We don't have to. What's your
question? Let's assume she's scrolling through them. If
anybody wants to watch, you can scroll through them.
Just ask her the question.
BY MR. PARRAS:
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Cross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
2060
Q. The process that you set up, everything that you were
trying to do, was finally working, wasn't it?
A. I wouldn't say that.
Q. Well, you were making queries of banks and they were
responding and you were going back and forth implementing
the regulations that finally came into existence; correct?
A. We were conducting examinations, yes. We had started
the process.
Q. Okay. And then you told this jury that, in 2002, you
left the -- you decided not to reapply under circumstances
that you've already described; correct?
A. Not to apply, yes.
Q. Your decision; right?
A. That was my decision.
Q. No one forced you to not apply; correct?
A. No one forced me.
Q. And you don't go back to the FSRC until April
of 2009; correct?
A. That is correct.
Q. And that's your current position: Executive director
of the FSRC; right?
A. Current position is chairman of the board of
directors.
Q. Do you have business outside of that position?
A. Yes, I do.
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Cross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
2061
Q. Do you have banks as clients?
A. No, I don't, not currently. I have had banks as
clients, yes.
Q. While you were the chairman of the board of the FSRC?
A. No.
Q. Okay. While you were chairman of the board of the
FSRC, do you do any work with people who are regulated by
your body?
A. No.
Q. If you could give me a minute, please, ma'am.
MR. PARRAS: Thank you, Ms. Crick.
I have no further questions.
THE COURT: Government is next, they keep going
back and forth until they have no more questions. You
can't get up and leave.
MR. PARRAS: He might ask you questions.
THE COURT: That's what I mean. The government
is next.
THE WITNESS: Oh, sorry.
THE COURT: We go back and forth or until they
have no more questions, or until I say that's all.
THE WITNESS: Okay.
THE COURT: Michelle can get it for you. Is it
the top button or the front button? Okay. Thank you.
All right, Counsel. Go on.
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Redirect-Crick/By Mr.Warren
Johnny C. Sanchez, RMR, CRR - [email protected]
2062
MR. WARREN: Thank you, Your Honor.
REDIRECT EXAMINATION
BY MR. WARREN:
Q. Ms. Crick, do you still have Government's Exhibit 615
in front of you?
MR. WARREN: If you would pull it up.
Your Honor, can you switch the --
THE COURT: Okay. To yours.
MR. WARREN: To the computer, please?
THE WITNESS: Yes, I do.
BY MR. WARREN:
Q. Ms. Crick, what's the date of this letter?
A. November 9, 2001.
Q. And who sent it to you?
A. Mr. Frans Fingervoedt.
Q. And he was the president and CEO of the bank at the
time?
A. Yes, he was.
Q. And in Section 1, as Mr. Parras just asked you,
they're telling you that all the information about the
loans has been fully implemented, right, and now it's been
provided for the FSRC to roll up to speed about everything
on their loan portfolio?
A. All they're saying is that we have now put this in
place. Thereby the applications are on file. That's the
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Redirect-Crick/By Mr.Warren
Johnny C. Sanchez, RMR, CRR - [email protected]
2063
extent of what that is saying.
Q. Ms. Crick, I'm handing you what's been marked as
Government's Exhibit 334.
MR. WARREN: If there are no objections, Your
Honor, I'd ask that it be published.
THE COURT: Just keep going. On any of these,
just keep going unless we hear an objection.
That's 334; correct?
MR. WARREN: That top paragraph is fine. Thank
you.
BY MR. WARREN:
Q. Ms. Crick, do you see the date of this document?
A. Yes, I do.
Q. What's the date of it?
A. December 31, 2000.
Q. And if you could please read that first paragraph
starting with the words "promissory note."
A. "Promissory note. For value received, R. Allen
Stanford [hereinafter called 'Maker'] promises to pay to
the order of Stanford International Bank, Limited, at its
office located at 2000 Airport Boulevard, St. John's,
Antigua, West Indies [hereinafter called 'Payee'] the
principal sum of 59,500,000 no cents, U.S. dollars,"
59,500,000 in numbers, "[the 'Loan'] together with any
unpaid interest at the rate and on the terms set forth
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Redirect-Crick/By Mr.Warren
Johnny C. Sanchez, RMR, CRR - [email protected]
2064
herein, as follows."
Q. Ms. Crick, would you agree with me that this is a
promissory note from Mr. Stanford in the amount of
$59.5 million?
A. It is.
Q. Was this ever disclosed to the FSRC?
A. Not to my knowledge.
Q. Ms. Crick you were asked a series of questions about
the examination of the bank in 2001 and the report which
is Government's Exhibit 666 that resulted from that
examination.
Do you recall those questions?
A. Yes.
Q. Were you there throughout the end of the examination?
A. No, I was not.
Q. Can you remind the jury why you weren't there?
A. Along with Mr. Queeley and Mr. Ferrance, I had been
asked to travel outside the island to visit several of the
islands in the region.
Q. That was that hastily arranged trip?
A. The hastily arranged trip. I was not present
throughout the course of that examination.
Q. And you testified yesterday that Mr. Bailey replaced
you on the examination; correct?
A. He replaced Mr. Queeley, yes.
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Redirect-Crick/By Mr.Warren
Johnny C. Sanchez, RMR, CRR - [email protected]
2065
Q. Do you know that Mr. Bailey went to work for
Mr. Stanford after he left the FSRC?
A. I, in recent times, subsequently learned that, yes.
Q. And he became the examiner after you and Mr. Queeley
were sent off island; correct?
A. That is correct.
Q. Do you recall Mr. Parras asking you about the IBC and
the statutes and what it requires the disclosure of?
A. Yes.
Q. Does the IBC -- is that the exhaustive statute
regulating the banking sector?
A. The banking sector as a whole, no.
Q. There are regulations that regulatory body can pass
in furtherance of its regulations, in furtherance of its
duties?
A. There is.
Q. And do you recall Section 231 that Mr. Parras showed
you?
A. Yes.
Q. Can you quote verbatim what Section 231 says? Off
your memory. I'm not asking you to read off the document.
MR. PARRAS: Judge, I have no objection to
admitting this into evidence.
MR. WARREN: I'm not offering it into evidence,
Your Honor.
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Redirect-Crick/By Mr.Warren
Johnny C. Sanchez, RMR, CRR - [email protected]
2066
THE COURT: Okay.
BY MR. WARREN:
Q. Ms. Crick, I'm handing you what you had seen before.
I direct your attention to Subparagraph (e) at
Section 231.
A. Yes.
Q. And look at that for a minute and I'll take it back
from you.
A. Uh-huh.
Q. Are you aware of any regulation that would require
the directors or owners of a bank to disclose other
relevant financial information for their application?
A. Yes.
Q. Would a prior bankruptcy be included in that
information that's required to be disclosed to the
regulatory body?
A. If I recall correctly, yes.
Q. Do you recall being asked some questions, a lot of
questions, about the judicial opinion from Montserrat?
A. Yes.
MR. WARREN: If we could show Government's
Exhibit 511, please.
BY MR. WARREN:
Q. Ms. Crick, what is the date of this document? This
is the one we looked at before about the notice of
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Redirect-Crick/By Mr.Warren
Johnny C. Sanchez, RMR, CRR - [email protected]
2067
revocation.
A. 28 November 1990.
Q. If we could please turn to Defense Exhibit -- and I
don't have the number offhand. It's the?
MR. COSTA: 2-14.
THE COURT: Thank you.
MR. WARREN: Could you use the overhead for
that, please.
Your Honor, if we could switch to the
easel -- I'm sorry. To the -- let's go to the last page.
BY MR. WARREN:
Q. Ms. Crick, are you able to read -- this is the
government findings that Mr. Parras showed you.
Can you read that second paragraph to the
jury, please?
A. That's Item 2?
Q. Yes?
A. "That the licenses granted to Guardian International
Bank Limited, on 9 January 1986, and the 14th day of
November 1988, could not be revoked by the government in
council since they did not exist."
Q. And based on that document, on what date did Guardian
International Bank surrender its license, if you look at
the paragraph just above?
A. It says it ceased to do business on the 19th of
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Redirect-Crick/By Mr.Warren
Johnny C. Sanchez, RMR, CRR - [email protected]
2068
December 1990.
Q. Ms. Crick, would you agree with me that they
surrendered their license after they had been notified of
the potential revocation?
A. It would appear that way, yes.
Q. Have you ever heard the phrase, "You can't fire me, I
quit"?
A. Yes. I'm familiar with the phrase.
Q. There was some questioning on cross-examination about
the sector committee.
Do you recall that? That was the
nongovernment committee of people that -- private bankers,
et cetera?
A. Yes.
Q. And Mr. Parras asked you questions about you having a
problem with that committee or Mr. Stanford's involvement
in that committee.
That wasn't the committee you had a
problem with his involvement in; right?
A. No, it was not.
Q. You testified yesterday on direct that Mr. Stanford
was a part of what regulatory body when you joined in
1998?
A. When I joined in '98, he was part of the -- the
Financial Services Sectoral Committee.
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Redirect-Crick/By Mr.Warren
Johnny C. Sanchez, RMR, CRR - [email protected]
2069
Q. And you had a problem with that; right?
A. The sectoral committee?
Q. No, not with the sectoral committee, with the -- I'm
sorry.
Was Mr. Stanford a part of the FSRC, a
member of the board of the FSRC when you joined?
A. When I joined in '98, there was not yet a board.
Q. And what was it that you had -- what position did
Mr. Stanford have that you testified about to yesterday
that you raised concerns about when you joined in 1998?
A. There were -- there were two areas of concern. Prior
to 19 -- November 1998, my interaction was with the
sectoral committee.
Q. Ms. Crick, I'm sorry. If I could just focus you.
A. Okay.
Q. What -- did Mr. Stanford have any position with any
government agency or regulatory body when you joined in
1998 that caused you concern?
A. No.
Q. We were discussing -- counsel asked you on
cross-examination about Operation Clean Slate.
Who bank-rolled Operation Clean Slate?
A. Allen Stanford.
Q. Did -- as part of Operation Clean Slate, was there
legislation passed regarding the banking sector and
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Redirect-Crick/By Mr.Warren
Johnny C. Sanchez, RMR, CRR - [email protected]
2070
anti-money laundering in general in Antigua?
A. As part of Operation Clean Slate, yes. There were
amendments to the --
THE COURT: Excuse me. Yes, sir.
MR. PARRAS: Judge, I object. Lack of personal
knowledge.
On my examination, she said she didn't
know what Operation Clean Slate meant.
THE COURT: Do you want to respond to that?
MR. WARREN: I'm sorry, Your Honor. What was
the basis for the objection?
THE COURT: He said that on his examination,
she said she didn't know about Clean Slate.
MR. PARRAS: About what it did.
THE COURT: What it did.
BY MR. WARREN:
Q. I'm asking whether during that time period,
Ms. Crick, there was legislation passed regarding the
industry we've been discussing?
A. That is correct.
MR. PARRAS: Object to the form of the
question. I believe he's tying Operation Clean Slate with
a --
THE COURT: Again, I didn't hear an answer to
that question, but I'll sustain the objection as to the
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Redirect-Crick/By Mr.Warren
Johnny C. Sanchez, RMR, CRR - [email protected]
2071
first question. He restated it. If you need to get back
into it, I'll consider it.
BY MR. WARREN:
Q. Is that legislation still in effect?
A. No, it's not.
Q. What happened to it?
A. It was repealed in its entirety.
Q. Why?
THE COURT: The question is: Why was it
repealed; correct?
THE WITNESS: Yes. The legislation was
repealed for several reasons. Reason number one was
concerned about the author of the amendments.
THE COURT: Who was the author?
THE WITNESS: Mr. Patrick O'Brien.
BY MR. WARREN:
Q. Who did Mr. O'Brien work for at the time, as you
understood?
A. Allen Stanford.
Q. What was reason number two?
A. Reason number two was the thinking at the time that
the legislation might have in some respect weakened the
regulatory regime.
Q. And what was reason number three?
A. Reason number three was a general concern about the
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Redirect-Crick/By Mr.Warren
Johnny C. Sanchez, RMR, CRR - [email protected]
2072
amendments that had been coming to the government from the
international community.
Q. Ms. Crick, with regard to Operation Clean Slate, that
was when your files were taken from you; right?
A. Yes.
Q. Did it help or hinder your function as an Antiguan
regulator when Mr. Scardino took those files?
MR. PARRAS: Objection. Form of the question.
THE COURT: Sustained. Just rephrase it.
BY MR. WARREN:
Q. Did it help or render your work whether those files
were taken?
A. Hindered.
Q. A moment ago we were talking about Mr. Stanford's
position when you came on to the commission, the
commission's predecessor in 1998, and I was asking you if
Mr. Stanford had any positions at that time.
Did Mr. Stanford have any positions with a
regulatory body on the board of a government department
before you came on?
A. No.
Q. You were asked questions about bank secrecy on
cross-examination. Do you recall that?
A. Yes.
Q. When Mr. Parras asked you whether it would be good or
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Redirect-Crick/By Mr.Warren
Johnny C. Sanchez, RMR, CRR - [email protected]
2073
bad business, if you knew, to give the bank's competitors
information about where its assets were located, do you
recall that?
A. Yes.
MR. WARREN: If we could look at Exhibit 218,
please.
Your Honor, if you could switch to the
computer, please.
THE COURT: Yes.
MR. WARREN: Page 21.
Can we focus again on the two paragraphs
we looked at before on the right-hand side of the page --
I'm sorry -- the left-hand side of the page.
Thank you.
BY MR. WARREN:
Q. Ms. Crick, I won't ask you to read these again out
loud, but do you see anything in there about the bank
saying it can't turn over its assets or its positions
because it would be bad to give that information to
competitors?
A. No, I don't see that.
Q. Instead, you see information that it says the bank
can't disclose that information because of Antiguan
regulations; isn't that correct?
A. That is correct.
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Redirect-Crick/By Mr.Warren
Johnny C. Sanchez, RMR, CRR - [email protected]
2074
Q. And is that statement accurate?
A. It is not.
Q. Mr. Parras also suggested during cross-examination
that there were other jurisdictions that may have these
limitations. Where was the Stanford International Bank
located during this time?
A. In Antigua.
Q. Ms. Crick, you were asked some questions about
Mr. Hewlett on cross-examination. Do you recall that?
A. Yes, I do.
Q. And you were shown annual reports from the years
where you were at the commission where Mr. Hewlett had
certified to the statements. Do you recall that?
A. Yes.
Q. And Mr. Hewlett in his certification, as Mr. Parras
read, said that he formed an independent opinion as to the
accuracy of the financial statements?
A. That is correct.
Q. And Mr. Parras asked you about whether the FSRC could
have gone into the bank and asked for documents; right?
A. Yes.
Q. Did the FSRC have access to Mr. Hewlett's private
bank records?
A. No.
Q. To his personal bank account information?
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Redirect-Crick/By Mr.Warren
Johnny C. Sanchez, RMR, CRR - [email protected]
2075
A. No.
Q. Did the FSRC have access to Mr. Stanford's Swiss bank
account?
MR. PARRAS: At this point object to
argumentative.
THE COURT: Overruled.
THE WITNESS: No, it did not.
BY MR. WARREN:
Q. Did the commission know that Mr. Stanford had been
paying millions of dollars to Mr. Hewlett from its -- a
Swiss bank account to Mr. Hewlett's personal bank account?
MR. PARRAS: Objection, Judge --
THE WITNESS: No.
MR. PARRAS: -- argumentive and leading facts
that are not in evidence.
THE COURT: Sustained.
BY MR. WARREN:
Q. Would information about payments from Mr. Stanford to
Mr. Hewlett have mattered to the commission?
A. Certainly would have.
Q. You were also asked a series of questions on
cross-examination about cricket. Do you remember that?
A. Yes.
Q. Most of which probably have nothing to do with what
we're here for, but --
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Redirect-Crick/By Mr.Warren
Johnny C. Sanchez, RMR, CRR - [email protected]
2076
MR. PARRAS: Objection, Judge, to sidebar.
This jury is the one that's going to decide what it has to
do with why we're here.
THE COURT: Jury will decide.
BY MR. WARREN:
Q. You were asked questions about Mr. Stanford trying to
revise the cricket industry. Do you recall that?
A. Yes.
THE COURT: That it was the finest cricket
field in the world and you weren't sure; right? I
remember, too. Okay. Just like the jury does.
BY MR. WARREN:
Q. Ms. Crick, was it ever disclosed to the FSRC or any
of its predecessors that Mr. Stanford was using investor
funds from the purchase of CDs to fund his promotion of
cricket?
MR. PARRAS: Objection, Judge, assumes facts
that are not in evidence and argumentative.
THE COURT: Hang on one second.
Let me hear the -- I listened, but I want
to hear it one more time.
Johnny, read that back, please.
(Requested portion was read.)
THE COURT: All right. For the purpose of this
witness, sustain the objection.
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Redirect-Crick/By Mr.Warren
Johnny C. Sanchez, RMR, CRR - [email protected]
2077
BY MR. WARREN:
Q. Were there any disclosure to the FSRC about how
Mr. Stanford was paying for his promotion of cricket?
A. No, there was no disclosure.
MR. WARREN: If we turn to Government's
Exhibit 1530, please.
THE COURT: All right. After you get through
with this exhibit, we'll take a break.
MR. WARREN: Yes, Your Honor.
THE COURT: Going up there. We'll talk about
this exhibit, if that's a good time.
MR. WARREN: That will be a good stopping
point, Your Honor.
THE COURT: Okay.
MR. WARREN: Turn to the next -- start with
that page.
BY MR. WARREN:
Q. This is a picture of the Antigua Athletic Club;
right?
A. Yes.
Q. Was the FSRC ever told how this was paid for?
A. No, it was not.
Q. Was it ever told that -- I'm sorry.
Was the FSRC ever told that this building
was paid for through CD investor funds?
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Redirect-Crick/By Mr.Warren
Johnny C. Sanchez, RMR, CRR - [email protected]
2078
A. No, it was --
MR. PARRAS: Objection, assumes facts not in
evidence, argumentative.
THE COURT: Counsel, how do you get around the
objection? You're making -- you're going into this area,
perhaps I'll allow it. You hear the objection, why don't
you tell me or you want to do it after lunch break?
MR. WARREN: No, Your Honor.
THE COURT: Why don't you do it right now.
Let's talk about it right now.
MR. WARREN: Of course. There's been testimony
about what the FSRC was told and wasn't told in regard to
its examination of the bank. I'm not assuming any facts.
I'm simply asking Ms. Crick if the FSRC was aware of this.
The requirement to ask that sort of a question is a good
faith basis.
Now, if Mr. Parras wants me to, I am happy
to put before the Court my good faith basis for asking
these questions.
THE COURT: Got it.
Your response? Isn't that basically the
rule?
MR. PARRAS: Judge, it is. My response is this
is purely argumentative. This witness is being used as a
ping-pong ball to make the arguments of prosecutors -- of
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Redirect-Crick/By Mr.Warren
Johnny C. Sanchez, RMR, CRR - [email protected]
2079
the prosecution side.
THE COURT: All right. Let me ask you this:
Would this have been in this witness's ambit of
responsibility if that was known?
MR. WARREN: Yes. The answer is yes to that,
Your Honor.
And also in response to Mr. Parras's
point --
MR. PARRAS: And I have not objected when the
question is asked in that manner.
THE COURT: All right. Let's see if you can
avoid objection. If you can't, then I'll rule, okay? I
may agree with you.
MR. WARREN: Yes, Your Honor.
THE COURT: But, however, I agree on one thing
right now. It's almost five after 1:00, and that's our
outer limit. You remember there used to be a TV program,
The Outer Limits. So the first thing we do is raise the
screen, and the second thing we'll do is I'll see you back
at 2:15.
(Recessed at 1:05 p.m.)
(The following was held before the jury)
THE COURT: All right, Counsel. Go right
ahead.
MR. WARREN: Thank you, Your Honor.
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Redirect-Crick/By Mr.Warren
Johnny C. Sanchez, RMR, CRR - [email protected]
2080
BY MR. WARREN:
Q. Ms. Crick, let's go back to Government's
Exhibit 1530, and we're looking at Page 11.
This was a photo that --
MR. WARREN: Your Honor, could you turn on the
overhead for the --
THE COURT: Yes.
MR. WARREN: -- I'm sorry, the computer table.
Thank you.
THE COURT: Which one? The computer table?
MR. WARREN: Yes, sir.
BY MR. WARREN:
Q. Ms. Crick, this was a photo that Mr. Parras showed
you on cross-examination.
Do you recall that?
A. Yes.
Q. Was it ever disclosed to the FSRC that this hangar
was paid for with CD money?
MR. PARRAS: Objection, Judge. Form of the
question. Assumes facts not in evidence. It's
argumentative.
THE COURT: I have concern it -- read it back
one time, Johnny.
(The requested portion was read.)
THE COURT: I'm going to take it question and
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Redirect-Crick/By Mr.Warren
Johnny C. Sanchez, RMR, CRR - [email protected]
2081
answer. Sustained as to that question. I'm not saying you
can't go into this generally based upon what we talked
about after the jury left. I'll go question and answer on
it.
BY MR. WARREN:
Q. Ms. Crick, was it ever disclosed to the FSRC how this
hangar was paid for?
MR. PARRAS: Judge, objection. If we could get
a timeframe, when she -- personal knowledge. And same
objections, also.
THE COURT: Overruled.
THE WITNESS: No, it was not.
BY MR. WARREN:
Q. If we could turn to Page 9.
Do you recognize this?
A. No, I do not.
Q. Will you turn to Page 3.
Do you recognize the Sticky Wicket?
A. Yes, I do.
Q. What's the Sticky Wicket?
A. The Sticky Wicket is a restaurant located at the
airport owned by Mr. Allen Stanford.
THE COURT: When they say "Sticky Wicket,"
that's kind of an idiomatic expression in the United
States. A wicket is those -- in effect, for want of a
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Redirect-Crick/By Mr.Warren
Johnny C. Sanchez, RMR, CRR - [email protected]
2082
better, that sticks behind, what we call the catcher, isn't
it, or be in front of a catcher in a game of cricket;
right? Aren't the wickets the sticks in the ground?
THE WITNESS: A Sticky Wicket.
THE COURT: No. No. Not a stick wicket.
THE WITNESS: Uh-huh.
THE COURT: Okay. Now that's what a wicket is.
What is a sticky wicket.
THE WITNESS: Okay. The entire area between
the two sets of wickets is the area that's being referred
to, and if it is that area, the pitch as we speak, the
pitch between the two sets of three stumps that we call a
wicket, the two sets, the pitch between those two sets of
wickets --
THE COURT: You mean the dirt?
THE WITNESS: The dirt; right.
-- can prevent a problem if it is -- if
it's been raining, it's awkward to run on, and for the
bowlers to bowl. So if you're on a sticky wicket, you're
on a wicket -- in a situation that's very awkward, very --
THE COURT: And a bowler is the pitcher; right?
THE WITNESS: The equivalent of, yes. Uh-huh.
THE COURT: All right. I never knew where it
came from. Thank you.
THE WITNESS: You're welcome.
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Redirect-Crick/By Mr.Warren
Johnny C. Sanchez, RMR, CRR - [email protected]
2083
THE COURT: Go on. Stole a minute of the
government's time. It's a minute, but.
Thank you, Counsel.
MR. WARREN: Of course, Your Honor.
THE COURT: Go on.
BY MR. WARREN:
Q. A sticky wicket refers to an awkward situation on the
pitch?
A. Basically, yes.
Q. How interesting.
Ms. Crick, was it ever disclosed to the
FSRC that the Sticky Wicket was paid for through CD
investor funds?
MR. PARRAS: Same objection, Judge.
THE WITNESS: No.
THE COURT: Hold it. I think the bottom
line -- I understand -- I think the jury will pick it up
either way. So I'm going to say overruled. The jury will
pick it up either way, even if you rephrase it.
But, Counsel, you're entitled to a ruling.
It's overruled.
MR. PARRAS: May I have a running objection to
that line of questioning?
THE COURT: No. By that, I mean a running
objection meaning every time the same subject came up, I
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Recross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
2084
know he's got an objection. I'd rather do it question and
answer. Because if there's any slight deviation, I may
agree or disagree.
MR. WARREN: Can we have the question read back
from the record, please.
THE COURT: I think she answered it.
Go on, Johnny.
(The requested testimony was read)
BY MR. WARREN:
Q. I'm sorry. That the Sticky Wicket --
A. Sticky Wicket.
Q. -- was paid for through CD investor funds?
A. No, not to my knowledge, no.
MR. WARREN: Pass the witness, Your Honor.
MR. PARRAS: Hopefully briefly, Judge.
THE COURT: Sure.
RECROSS EXAMINATION
BY MR. PARRAS:
Q. Let's start with that last few questions.
Between the years 2002, and the years
2009, you were not a part of the FSRC; correct?
A. That is correct.
Q. And as to those lines of questions about whether it
was ever disclosed, for that time period, if those
buildings, the hangar, the Sticky Wicket, if that was
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Recross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
2085
built after you left or towards the time -- beginning of
when you left, you wouldn't know whether or not it was
disclosed to the FSRC; correct?
A. I would know, yes.
THE COURT: You would know?
THE WITNESS: I would know even though it's not
that time period.
BY MR. PARRAS:
Q. Okay. And what you -- you would have to be the
accountant for SIBL to know how they disclosed their
investments, let's say, to the FSRC; for example, if they
were on this IB 5 to have put the Sticky Wicket or money
put into the Sticky Wicket into a broad category, you
wouldn't know that from the IB 5; correct?
A. If it's part of an overall investment, I would not
know.
Q. Okay. I want to go to the red head opinion, once
again. And again, this is in evidence so the jury will be
able to look at the entire thing if they'd like to.
I'd like to point out three places; okay?
MR. PARRAS: If I could have the overhead
projector, Judge.
BY MR. PARRAS:
Q. First of all, the reason we're even talking about
this is because of Government's Exhibit 511.
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Recross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
2086
THE COURT: Just aim the mike at you. Just
turn it around. Okay. Thank you.
MR. PARRAS: Thank you, Judge.
BY MR. PARRAS:
Q. The reason we even discuss the Redhead opinion is
because of Government's Exhibit 511, the five reasons that
Montserrat at this time proposed to make an order under
the banking ordinance.
Now, going to Defendant's Exhibit 2-14,
the -- in the High Court of Justice, Colony of Montserrat,
if someone wanted to, they could go to A. Stanford,
0010774, and review the Judge's five grounds on which the
bank's license were purportedly revoked. Those would be
the Grounds 1 through 5, listed in Government's
Exhibit 511.
And I want to go to what the prosecutor
showed you. We are -- A. Stanford 001792.
Do you remember him asking you on redirect
to read this section ending in the fact that the licenses
granted to Guardian International Bank Limited on 9
January 1986, and the 14th day of November 1988, could not
be revoked by the government in council since they did not
exist.
Do you remember that?
A. Yes, I do.
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Recross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
2087
Q. They did not exist will at the time that the
government attempted to revoke them; correct?
A. I need a refresh on the time the government intended
to revoke them.
Q. Well, this isn't a statement that they never existed,
is it?
A. That's what this statement indicates, yes.
Q. Okay. Well, let's go to the Judge's opinion. This
is the last part. I told you I'd show you three places.
Judge's holding, A. Stanford 0010790.
Judge's holding, "I do hold, therefore, as from the 19th
of December 1990, when the bank surrendered its licenses
to the Ministry of Finance and accepted by the Minister of
Finance, the bank ceased to exist from that date."
You can't cease to exist without existing;
correct?
A. I would think that, yes.
Q. And then just -- I wasn't correct when I said three
places. One last page, front page, first sentence,
"Guardian International Bank Limited was granted a B
banking license on the 9th of January 1986, and an A
banking license on the 14th of November 1988, by the
government of Montserrat."
That's a pretty clear sentence, isn't it?
A. Yes, it is.
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Recross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
2088
Q. You weren't tempting to mislead this jury and making
them think that the licenses never exist, were you?
Existed, were you?
A. Yes, the license existed.
Q. Okay. As an accountant, do you know what tax
minimization is?
A. Tax minimization?
Q. Uh-huh.
A. I'm familiar with the term, yes.
Q. It's a concept, isn't it, by which companies or
people attempt to reduce their tax liability?
MR. WARREN: Your Honor, I'd object. It's
beyond the scope of the redirect.
THE COURT: Sustained.
BY MR. PARRAS:
Q. Do you remember being shown Government's Exhibit 334
on redirect? This is the promissory note of December 31,
2000.
A. Yes, I do.
Q. Do you know whether this was an attempt by lawyers
and accountants for Mr. Stanford to set up a regulatory or
a reporting regime whereby tax minimization could take
place?
A. I have no knowledge of that.
Q. Okay. It's possible, isn't it?
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Recross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
2089
A. I suppose anything is possible.
Q. In response to the some of the question about the IBC
Act Section 231(e), your answer was, "If I recall
correctly"; right?
About subsection whether you could ask for
more information, you prefaced your answer with, "If I
could recall correctly."
Do you remember that?
A. I might have, yes. I don't recall, but I might have,
yes.
Q. The best thing to do would be to go to the act
itself, wouldn't it, to see what it says?
A. Yes, uh-huh.
MR. PARRAS: Judge I move to introduce that
page --
THE COURT: From what?
MR. PARRAS: -- of the exhibit.
BY MR. PARRAS:
Q. That was Section 231; is that correct? And 232,
Ms. Crick?
A. Yes, uh-huh.
Q. Do you have that section up there with you?
A. Yes, I do.
Q. Does it look like a correct statement of the law?
A. It appears to be.
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Recross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
2090
MR. PARRAS: Move to offer as Defendant's
Exhibit 10-2.
THE COURT: What?
MR. PARRAS: The Sections 231 and 232 of the
IBC Act.
THE COURT: Which act was it?
MR. PARRAS: International Business Act from
Antigua.
THE COURT: In other words, what year? Oh, is
it still in effect? Is that -- ma'am, is it still in
effect?
THE WITNESS: Yes, it's in effect.
THE COURT: Okay. Any objection?
MR. WARREN: We have no objection to those two
sections, Your Honor, if the witness can authenticate that
they're still in effect.
THE COURT: Okay. So it's -- again, that's
10-2; correct? And that's two sections of the law; is that
correct, Counsel?
MR. PARRAS: Yes, Judge.
MR. FAZEL: IBC Act.
THE COURT: Two sections. Okay. Got it.
MR. PARRAS: And Judge, I have a highlighted
copy. I'll mark one for the Court that's not highlighted
and use this one for now.
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Recross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
2091
THE COURT: Okay.
BY MR. PARRAS:
Q. Let's look at Section 231, Ms. Crick. This is the
one you and I talked about.
And your answer under Subsection (e) is
that "Perhaps the issue of bankruptcy could be construed
to be called for by Subsection (e); "correct?
A. That's not the statement I need made, no.
Q. Tell me what you believe you were asked about
Subsection (e). What was the statement you made about
Subsection (e)?
A. Subsection (e) clearly defines that any other
information can be requested.
Q. And that's the part I want to focus on, the last part
of your sentence. "Can be requested"; correct?
A. Yes.
Q. If we go to subsections (a), (b), (c), (d),
there's -- those are things that the applicant must
provide; correct?
A. Must provide once the request is made.
Q. Okay. So the request has to be made before something
like some more information is required to be produced;
correct?
A. That is correct.
Q. And if we go to Subsection or Section 232, do you
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Recross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
2092
remember talking about on receipt of an application?
A. Yes, uh-huh.
Q. There is no -- you have the power to request more
information after you receive the initial application;
correct?
A. That is not correct.
Q. Well, let's read 232.
"On receipt of an application for a
license under this part...."
What does that mean?
THE COURT: Okay, it's under that section. We
all understand. Keep going.
BY MR. PARRAS:
Q. "...the appropriate official may cause such
investigations and inquiries to be made of the applicant
corporation, its directors and officers or proposed
directors and officers," et cetera, et cetera.
Maybe I'm wrong, tell me if I'm wrong,
that tells me that once an application is submitted, you
have the authority to then, if you want to, request more
information.
A. That is not what that statement is indicating.
Q. Okay.
A. I disagree.
Q. Okay. Do you remember talking to the -- talking
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Recross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
2093
about the files that were in your office, and you told
this jury that Mr. Stanford removed those files; correct?
A. That is correct.
Q. You also told this jury that you left work on Friday
and you returned Monday and they weren't there; correct?
A. That is correct.
Q. The reality, the truth, is you don't know who removed
your files; correct?
A. Yes, I do.
Q. Is it your belief that Mr. Stanford himself went to
your office and physically removed those files?
A. That is my belief, yes.
Q. That's not any personal knowledge that you have;
correct?
A. It's -- well, I'm not sure how you define "personal
knowledge." I'm aware that that was what happened.
Q. Well, did you see Mr. Stanford go into your office
and pull boxes of files out of your office?
A. I did not see that. And it was not boxes of files.
The filing cabinets that were moved containing files.
Q. Is there a video somewhere of Mr. Stanford removing
file cabinets of materials and files?
A. No, there is not.
Q. Are there pictures of Mr. Stanford going into your
office removing files and boxes of files?
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Recross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
2094
A. No, there is not.
Q. At that time, Lloyd Harold the former FBI agent, had
been made president, supervisor of banks; correct?
A. Yes.
Q. He was the person that took the files; correct?
A. That is not correct. To my knowledge, that is not
correct.
Q. Okay. Let's put aside -- what about Mr. Pat O'Brien
do you believe he took the files?
A. I'm not sure if he was involved in the removement of
the files -- removal of the files.
Q. Just to be clear, it's your belief that Mr. Stanford
himself physically picked up those files out of your
office?
A. Mr. Stanford was present and conducted, or should I
say, supervised the removal of the filing cabinets from
the premises.
Q. To your knowledge, who --
A. To my knowledge.
Q. To your knowledge, who did he supervise?
A. A number of persons who were lifting and helping to
move the cabinets.
Q. What are their names?
A. I don't know their names.
Q. Did you make a police report about that?
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Recross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
2095
A. I believe I did, yes. I reported that the files are
missing.
Q. What you did do was you asked for a legal opinion
from the solicitor general about whether it was
appropriate for the files to be removed, didn't you?
A. That is incorrect.
Q. You told this jury on direct examination that you
were being ordered to turn over the files and you sought a
legal opinion; correct?
A. That was prior to the removal of the files.
Q. Okay. And the result of that legal opinion was that
you should turn over the files; correct?
A. That I should turn over the files to the supervisor
of international banks.
Q. Okay. It was clear that they were going to leave
your office; correct?
A. I don't understand the question.
Q. I'll move on.
You told this jury that Pat O'Brien was an
employee of Mr. Stanford.
That's not true, is it?
A. It is true.
Q. Pat O'Brien was paid by the IFSA; correct?
A. That is not correct.
Q. It would help, wouldn't it, for you to review
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Recross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
2096
correspondence regarding the payment of Pat O'Brien,
wouldn't it?
A. Yes, it would.
Q. Take your time to read this to yourself, and when
you're finished --
THE COURT: How many pages?
BY MR. PARRAS:
Q. -- let me know?
MR. PARRAS: Two pages and a paragraph on the
third, Judge. I apologize.
THE COURT: Counsel.
MR. PARRAS: It's on my time, Judge.
THE COURT: I know. I'm looking at the time.
It's clicking away.
While we're waiting, I will tell you what,
but we have a really nicer mindset like we did here. It's
not swearing in a new lawyer on -- what is it -- Friday?
It's one of the pleasures you get doing some things like
that. So I try to bring the jury into it. In fact, when I
have civil cases going on, like contract cases or civil
rights cases or whatever, I always bring those juries in to
see the criminal aspect of the case, of what we do here.
It's not just criminal work, all sorts of civil work. But
I may do the same thing. If I see I have a civil motion
some morning that may be of interest for you, we'll call
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Recross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
2097
you in to see what the civil aspects of this job is because
I've got civil cases stacked up both before and behind this
case. As soon as it's over, we'll be doing some one -- big
civil rights case, for instance, concerning matters that
allegedly occurred overseas that are suing a major U.S.
company about.
All right. Are we ready?
MR. PARRAS: I think so, Judge.
THE WITNESS: Yes, sir. Go right ahead,
Counsel.
BY MR. PARRAS:
Q. Does that help to remind you that Mr. O'Brien was
being paid by the IFSA?
A. It helps to confirm that that was not the case.
Q. Is it because you believe that the Antiguan
government ended up meeting to get a loan from the Bank of
Antigua which is owned by Mr. Stanford? Is that why
you're saying --
A. That is not why I am saying that.
Q. Okay.
MR. PARRAS: No further questions.
THE COURT: Anything further?
MR. PARRAS: No, Judge. And I'll grab this
back.
THE COURT: Anything further, Counsel?
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Recross-Crick/By Mr. Parras
Johnny C. Sanchez, RMR, CRR - [email protected]
2098
MR. WARREN: Yes, Your Honor, very briefly.
REDIRECT EXAMINATION
BY MR. WARREN:
Q. Ms. Crick, on the recross, Mr. Parras asked you again
about the Montserrat decision.
What was the date on which Guardian
International Bank surrendered its license?
A. December 1999.
Q. Is that before or after the notice of revocation came
in November of 1999?
A. That is after the notice of revocation.
MR. WARREN: Pass the witness, Your Honor.
THE COURT: Anything further, Counsel.
MR. PARRAS: No, Judge.
THE COURT: All right. Thank you, ma'am.
Now you may step down. You're excused and
free to leave. I tell all witnesses this: If you'd like
to stick around and watch, you can. You're released from
that prior ruling as far as not being in the courtroom, but
you're certainly free to leave. Thank you.
THE WITNESS: Thank you, Your Honor.
THE COURT: Yes, ma'am.
All right. Call your next witness.
MR. COSTA: United States calls Arnold Knoche.
THE COURT: Sir, do you want to come around to
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Direct-Knoche/By Mr. Costa
Johnny C. Sanchez, RMR, CRR - [email protected]
2099
your right.
Raise your right hand to be sworn.
Have a seat, please.
ARNOLD KNOCHE,
after having been first cautioned and duly sworn, testified
as follows:
DIRECT EXAMINATION
BY MR. COSTA:
Q. Good afternoon.
A. Good afternoon.
Q. Would you please introduce yourself to the jury and
spell your last name for the court reporter?
A. My name is Arnold Knoche, A-R-N-O-L-D, K-N-O-C-H-E.
Q. And where do you live Mr. Knoche?
A. I live in Ft. Bend County.
Q. How long have you lived in the Houston area?
A. Ever since I was six months old.
Q. Got here as soon as you could?
A. As soon as I could, yeah.
Q. What do you do for a living these days?
A. I'm semiretired. I'm still working a little bit,
just doing some bookkeeping work.
Q. What is your profession?
A. A CPA.
Q. Tell the jury briefly about your educational
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Direct-Knoche/By Mr. Costa
Johnny C. Sanchez, RMR, CRR - [email protected]
2100
background.
A. Okay. I went to public schools in the Houston
Independent School District, and then to the University of
Houston. Got a bachelor's of administration with a major
in accounting.
Q. And you said you're a CPA or a certified public
accountant?
A. Yes.
Q. How long have you held that title?
A. For -- since I was 23 years old, so 45 years.
Q. What's your current status as a CPA?
A. In retired status for the last three years.
Q. What did you do after graduating from the University
of Houston?
A. I started out in public accounting, a national firm
called Peat, Marwick, Mitchell and then a local firm
called Milton & Milton.
Q. Peat Marwick, was that one of the big international
accounting firms?
A. Yes. It's called -- back then, it was called Big 8
accounting firms. They were the largest eight accounting
firms in the U.S.
THE COURT: What are they now down to? How
many big --
THE WITNESS: I believe it's four now.
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Direct-Knoche/By Mr. Costa
Johnny C. Sanchez, RMR, CRR - [email protected]
2101
BY MR. COSTA:
Q. There have been some mergers?
A. Yes, mergers.
Q. Is Peat Marwick still around in any merged entity?
A. Yes. I think its merged name is KPMG.
Q. So you said you worked for Peat Marwick and then a
local accounting firm.
Did you at some point to into the real
estate industry?
A. Well, I went first to the construction industry. I
worked for two subsidiaries of Austin Industries. They
were construction companies.
Q. And then did you go to a homebuilder?
A. Yes. A homebuilder named Monarch Homes. I was there
for 11 years, started as controller and then was executive
vice-president of finance.
Q. What is a controller?
A. That's responsible for the overall accounting
function and be sure the bills are paid, the payroll is
done, and then prepare the financial statements to be
presented to the president or the board of directors.
Q. What year did you leave Monarch Homes?
A. 1987.
Q. Why were you looking to leave Monarch Homes in 1987?
A. The homebuilding business was very bad in Texas.
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Direct-Knoche/By Mr. Costa
Johnny C. Sanchez, RMR, CRR - [email protected]
2102
That was back in the savings and loan crisis. And I was
going to have -- we were going to shut down in Texas, and
I was going to have to move to San Diego, California.
Q. You didn't think the weather in San Diego would
measure up to Houston?
A. No. It would have been beautiful, but our daughter
was in high school and we just didn't want to -- didn't
want to pull her out of high school if we could possibly
avoid it.
Q. Did you start looking for jobs that would allow you
to stay here in the Houston area?
A. That's correct.
Q. And where did you end up going to work?
A. A company -- it was Guardian International Investment
Services at that time.
THE COURT: What year was that? 1980 --
THE WITNESS: 1987.
BY MR. COSTA:
Q. And who owned that company?
A. Allen Stanford.
Q. How did you first find out about that position with
Guardian International?
A. I answered a newspaper ad.
Q. Do you remember where the ad was placed?
A. Probably The Houston Chronicle. It could have been
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Direct-Knoche/By Mr. Costa
Johnny C. Sanchez, RMR, CRR - [email protected]
2103
the Wall Street Journal, but I believe it was The Houston
Chronicle.
Q. And what do you recall the want ad requesting in
terms of background for the position?
A. It advertised for a certified public accounting with
real estate experience.
Q. Did you submit a resumé?
A. Yes. I sent a cover letter and a resumé.
Q. Were you invited for an interview?
A. Yes.
Q. With whom did you interview?
A. I met with Allen Stanford.
Q. Where was that meeting?
A. It was on a Saturday morning at the 1100 Milam
Building. It's just a few blocks from here.
Q. What did Mr. Stanford tell you about this position he
was interviewing for?
A. Well, it was going to be a newly created part of the
organization that was going to seek out distressed real
estate and purchase it, operate it and sell it.
Q. Do you see Mr. Stanford in the courtroom today?
A. Yes. He's right there.
Q. Can you point out what he's wearing?
A. That's him.
THE COURT: He's standing up; correct?
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Direct-Knoche/By Mr. Costa
Johnny C. Sanchez, RMR, CRR - [email protected]
2104
THE WITNESS: Correct. That's correct.
MR. COSTA: Ask that the record --
THE COURT: The record will reflect that he
identified Mr. Stanford.
BY MR. COSTA:
Q. So Mr. Stanford told you this was a new entity he was
looking to hire someone for?
A. That's correct.
Q. Focused on distressed real estate?
A. Yes.
Q. Did he tell you at that initial interview about any
other businesses he had?
A. Yes. He said he had a bank in Montserrat.
Q. And what was the name of that bank?
A. It was Guardian International Bank.
Q. And this position you were interviewing for, was that
going to be with the bank?
A. No, no.
Q. It was going to be separate?
A. Separate.
Q. And focused on --
A. Focused on real estate.
Q. After that first interview with Mr. Stanford, what
happened?
A. He called me back in a couple of days or somebody
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Direct-Knoche/By Mr. Costa
Johnny C. Sanchez, RMR, CRR - [email protected]
2105
called me back and said they'd like me to go to Mexia,
Texas, to meet with the board of directors.
Q. And did you go up to Mexia?
A. Yes, I did.
Q. Where is Mexia from Houston?
A. It's up towards Dallas. Not quite all the way to
Dallas.
Q. With whom did you meet in Mexia?
A. That would have been James Stanford and Bill Goswick
and Don Caldwell.
Q. Did you learn anything about Mr. Stanford's history
from that interview with those board members in Mexia?
A. About his history?
Q. Did anyone make a comment about what Mr. Allen
Stanford had done in the past?
A. Oh, Bill Goswick, I think --
MR. SCARDINO: We object to clarify who he's
referring to, who made the statement.
THE COURT: Okay.
BY MR. COSTA:
Q. Who made a statement about what Mr. Allen Stanford
had done in the past?
A. Oh, Bill Goswick made a comment about that Allen had
been in the --
MR. SCARDINO: Object to the hearsay.
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Direct-Knoche/By Mr. Costa
Johnny C. Sanchez, RMR, CRR - [email protected]
2106
THE COURT: How do you get around hearsay?
MR. COSTA: It's for the truth, it's just to
show what he understood about Mr. Stanford's business, but
I can move on. It's not --
THE COURT: Sustain the objection.
BY MR. COSTA:
Q. What did you learn from the board about this real
estate, distressed real estate project Mr. Stanford wanted
to hire you for?
A. They basically said the same thing Mr. Stanford did;
that they thought this was a good opportunity to have
purchase of distressed real estate. There was a lot of it
around, and they thought we could do well.
Q. Did you eventually get hired for the position?
A. Yes.
Q. And the entity that hired you was this Guardian
International Investment Services?
A. That's correct.
Q. Did anyone else work with you initially on the real
estate investments?
A. Yes. When Mr. Stanford made me the offer, he said
that they had decided to hire two people, or they were
just going to hire one, but there was another applicant
that he hired at the same time. We were both -- both
executive vice-presidents reporting to him.
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Direct-Knoche/By Mr. Costa
Johnny C. Sanchez, RMR, CRR - [email protected]
2107
Q. Who was the other individual?
A. Larry Slater.
Q. And you both reported to Mr. Allen Stanford?
A. That's correct.
Q. We mentioned Mr. Stanford's father, but from now on
when I say "Mr. Stanford," do you understand I'm talking
about Mr. Allen Stanford?
A. Yes.
Q. Unless I specify?
A. Yes.
Q. You said Mr. Stanford already had a bank at this
time?
A. That's correct.
Q. So when was it that you started working at Guardian
International Investment Services?
A. That would have been in the early part of 1987.
Q. And did you learn about the bank after you went to
work even though you were working for this separate real
estate investment?
A. Yes. It was a very small office in Houston, so that
I think there were three bank officers -- or they
weren't -- they weren't employees of the bank. They were
employees of Guardian International Investment Services,
another part of it. So it was a small office, and we had
meetings that would discuss some part -- early on, some
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Direct-Knoche/By Mr. Costa
Johnny C. Sanchez, RMR, CRR - [email protected]
2108
parts about the bank.
Q. And these were salespeople for the bank?
A. These were salespeople for the bank.
Q. What product were they selling for the bank
primarily?
A. Primarily certificates of deposit.
Q. Do you remember the names of some of those folks?
A. I recall three of them. Sydney Adler. Michelle
Chambliess and Maria -- no. There's four. Maria
Promindon and Elsie Ethridge. And, actually, Michelle
came a little bit later, it was Sydney, Maria, and Elsie
first, and then Michelle came shortly thereafter.
Q. You were there before Michelle?
A. Yes.
Q. In terms of Mr. Stanford's attention, from what you
saw, which part of his businesses did he devote most of
his time to in those first few years?
A. The bank.
Q. If you could put a percentage of his time that he was
focused on the bank, from what you saw, what would you
estimate?
A. Oh, probably 90 percent.
Q. And you said partly you learned about the bank just
because you were in the office with these other bankers,
the bankers who were actually selling the CD product?
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Direct-Knoche/By Mr. Costa
Johnny C. Sanchez, RMR, CRR - [email protected]
2109
A. That's correct.
Q. Did you ever read promotional materials put out by
Guardian Bank?
A. Yes.
Q. Why?
A. Oh, we were so small we were asked to. We would have
meetings to review the promotional material, in the early
days.
Q. Who asked you to read the promotional materials?
A. Mr. Stanford.
Q. Who would be at these meetings where the promotional
materials were reviewed?
A. That was the same people that I mentioned. And Larry
Slater and myself.
Q. Would Mr. Stanford attend those meetings?
A. Yes.
Q. Did you also read the bank's annual reports?
A. In the early years, yes.
Q. Was that something Mr. Stanford required that you
read?
A. Yes. He asked each of us to be totally familiar with
the bank's annual report.
Q. And from the materials you read and from these
meetings you attended with Mr. Stanford, what did you
understand that the bank told the depositors it was doing
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Direct-Knoche/By Mr. Costa
Johnny C. Sanchez, RMR, CRR - [email protected]
2110
with the CD money?
MR. SCARDINO: Objection to foundation and
hearsay.
THE COURT: Okay. Your response?
MR. COSTA: The foundation has been laid. He
said he read all the promotional materials. He was at
meetings with Mr. Stanford.
And for hearsay, it's not offered for the
truth. It's for what he understood what Mr. Stanford and
the materials told him the bank did with their money.
MR. SCARDINO: That's a different question than
asking him what materials they were asked to read.
THE COURT: Right. Okay. Ask the question.
Sir, don't answer it. See if there's an
objection, if we can around the objection; okay?
BY MR. COSTA:
Q. Based on the materials you read, based on what
Mr. Stanford told you and others discussed in these
meetings, what did you understand that the bank was
telling its depositors it did with the money that was
deposited?
MR. SCARDINO: Again, I object to foundation,
the materials that he said he reviewed.
THE COURT: Overruled.
THE WITNESS: Would you repeat it then, please.
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Direct-Knoche/By Mr. Costa
Johnny C. Sanchez, RMR, CRR - [email protected]
2111
BY MR. COSTA:
Q. Sure. What did you understand, from what you read
and what you were told by Mr. Stanford, about what
Guardian Bank did with the money once it was deposited in
the bank?
A. It was invested in conservative equities and bonds,
stocks and bonds.
MR. COSTA: And given Mr. Scardino's objection,
we'll show one of those. 103, please, which has already
been offered.
MR. SCARDINO: 103?
MR. COSTA: Yes.
BY MR. COSTA:
Q. Do you recognize this as a Guardian Bank annual
report from 1990, Mr. Knoche?
A. Yes.
MR. COSTA: If we could turn to Page 13,
please.
Thank you, Judge.
And there is a paragraph there, investment
portfolio, towards the beginning of the bottom half, if you
could highlight that.
BY MR. COSTA:
Q. It says, "The investment portfolio is made up of
86.9 percent bonds, 9.4 percent equities, 2.6 percent
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Direct-Knoche/By Mr. Costa
Johnny C. Sanchez, RMR, CRR - [email protected]
2112
commercial paper and 1.1 percent notes."
Is that consistent with what your memory
is of the type of investments the bank was saying it made?
A. Yes.
MR. SCARDINO: Excuse me. I'll object. This
witness is not -- there's no foundation to establish this
witness had this knowledge personally. He's not being
asked to form an opinion as an expert, so I would object to
this line of questioning unless he plans to prove him up as
an expert.
THE COURT: Go on.
MR. COSTA: I asked him what he understood.
He's already said if there's no foundation, I -- he's been
at numerous meetings. He was required by Mr. Stanford to
read the bank's promotional materials. I'm happy to lay
more foundation, but I think it was -- it's clear he read
all the materials at the time he was required to, and
Mr. Stanford was in meetings telling him all that.
THE COURT: Now you're reading from something
already in evidence; correct?
MR. COSTA: Right.
MR. SCARDINO: Your Honor, I would respectfully
object, because the prosecutor -- Mr. Costa is actually
trying to have it both ways. He's trying to not make the
man an expert witness but still elicit an opinion from hi,
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Direct-Knoche/By Mr. Costa
Johnny C. Sanchez, RMR, CRR - [email protected]
2113
and I would object.
THE COURT: Overruled.
MR. SCARDINO: I --
MR. COSTA: No, no, overruled. I'll keep an
eye out, though, Mr. Scardino. If you think you're getting
into pure expert witness testimony as a CPA, I'll jump in
or you jump in.
BY MR. COSTA:
Q. Is that highlighted portion, Mr. Knoche, consistent
with what you heard from Mr. Stanford and from reading
materials that that's the nature of the bank's investment
portfolio?
A. Yes, I agree.
Q. You said you were told it was conservative, low-risk
investments. Do you think if it was in bonds and
9 percent equities, would that be conservative, in your
view?
MR. SCARDINO: Again, he's asking for an
opinion.
THE COURT: Overruled. Overruled.
THE WITNESS: Yes, certainly there is some
equities that are more risk than others, but basically
bonds, especially, that's conservative investment, yes.
BY MR. COSTA:
Q. What did the bank say about whether it made loans
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Direct-Knoche/By Mr. Costa
Johnny C. Sanchez, RMR, CRR - [email protected]
2114
like a commercial bank?
A. It was my understanding there was no loans.
MR. COSTA: If we can go to 519, which has also
already been offered. If we can go to Page 5. On the
left-hand side, the second question and answer.
BY MR. COSTA:
Q. It says, "Does the bank make loans?"
"Guardian International Bank limited has
never made and will never make loans or offer credit
instruments."
Is that consistent with the understanding
you had from working at Guardian Investment Services?
MR. SCARDINO: Again, object to foundation.
There's no basis to show that this man had knowledge of
loans or not.
THE COURT: Overruled.
MR. COSTA: I'm not asking whether he knew the
bank --
THE COURT: I understand. I've overruled it.
Go on.
BY MR. COSTA:
Q. Is that consistent with what you were told about the
bank?
A. Yes.
Q. Where did Mr. Stanford -- or did Mr. Stanford tell
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Direct-Knoche/By Mr. Costa
Johnny C. Sanchez, RMR, CRR - [email protected]
2115
you who was making the investment decisions for the bank's
portfolio?
A. Well, in the very early years, it would be himself,
and he --
THE COURT: Hold it. The question is: Did he
tell you. Right? That was the question.
BY MR. COSTA:
Q. Did Mr. Stanford tell you which individuals were
overseeing the bank's investment portfolio?
A. I don't recall that he was -- specifically had
said that he would have answered that question. No, I
don't specifically remember that, but...
Q. Did Mr. Stanford ever discuss money managers with
you?
A. Yes, he said there were some money managers in
Switzerland.
Q. And what were those Swiss money managers doing
according to Mr. Stanford?
A. It would have been my understanding managing the
funds of the bank.
Q. In these meetings you had with the bankers who were
selling the CDs that Mr. Stanford attended, did the topic
of insurance ever come up?
A. Yes. They said that some of their clients had asked
if he had --
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Direct-Knoche/By Mr. Costa
Johnny C. Sanchez, RMR, CRR - [email protected]
2116
MR. SCARDINO: Object to nonresponsive.
THE COURT: Sustained. The answer is -- it
will go a lot quicker if he asks for a narrative, then
visit with him. Otherwise, yes or no. If you can't answer
a question yes or no, let me know and I'll have him
rephrase it.
THE WITNESS: Yes, Your Honor.
BY MR. COSTA:
Q. Did the topic of insurance come up?
A. Yes.
Q. Did the bankers, the people selling the CDs, ask
Mr. Stanford about the insurance issue?
A. Yes.
MR. SCARDINO: Object to foundation.
THE COURT: Sustained.
BY MR. COSTA:
Q. Were you in these meetings where the insurance issue
came up?
A. Yes.
Q. What did the banker say to Mr. Stanford about
insurance?
A. That some of the clients had asked if there was -- if
their deposits were covered by FDIC insurance.
Q. And what was the response?
A. Response was no.
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Direct-Knoche/By Mr. Costa
Johnny C. Sanchez, RMR, CRR - [email protected]
2117
Q. So was there another insurance that Mr. Stanford said
applied to his bank?
A. I think initially no, but then later yes.
Q. Do you recall the name of that insurance that he said
applied to his bank?
A. I remember two companies were mentioned. I don't
know what order. Lloyd's of London was mentioned, and a
British Insurance Fund was mentioned.
MR. COSTA: If we can go to 502, which has
already been offered and referenced, Your Honor.
BY MR. COSTA:
Q. Do you see the name at the top there, Mr. Knoche,
British Insurance Fund, Limited?
A. Yes.
Q. Is that the insurance company you were just
referencing that Mr. Stanford talked about in these
meetings with the bankers?
A. Yes.
Q. In any of those meetings you attended where this
company was discussed, did Mr. Stanford ever say that it
was a captive insurance company that he owned?
MR. SCARDINO: Object to the form of the
question what did he ever say.
THE COURT: Overruled.
BY MR. COSTA:
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Direct-Knoche/By Mr. Costa
Johnny C. Sanchez, RMR, CRR - [email protected]
2118
Q. Did Mr. Stanford ever say that the British Insurance
Fund, Limited, was a captive insurance company that he
owned?
A. No.
Q. Was there ever in any of these brochures you were
required to review for the bank mentioned of an office in
Switzerland?
A. Yes.
MR. COSTA: If we can go to 522, please. This
has already been offered and admitted. Page 19, please.
If you can highlight the bottom list of cities.
BY MR. COSTA:
Q. List the number of offices and then it says,
"Affiliate offices."
What's listed there?
A. It says Geneva, Switzerland.
MR. COSTA: If we can go to Page 3 of the same
Guardian brochure.
BY MR. COSTA:
Q. If we go to the bottom, is that a list of offices as
well, Mr. Knoche?
A. Yes.
Q. And at the bottom, it says, "Affiliate office
Geneva"?
A. Yes.
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Direct-Knoche/By Mr. Costa
Johnny C. Sanchez, RMR, CRR - [email protected]
2119
Q. Did you ever ask Mr. Stanford about whether there
was, in fact, an office of the bank in Geneva?
A. In conjunction with reviewing one of the promotional
things, it had pictures of the other offices, Miami and
Aruba, but in Geneva, it just had a picture of a river.
And I said, "Wouldn't it be better if we had a picture of
the office?"
Q. And what did Mr. Stanford say?
A. He said, "Well, it's more like this, the
representative -- representation. There's not a formal
office as such."
Q. I want to go on and talk about the real estate
investment group that you worked for.
Was -- were you told that that was the
bank -- the CD depositors' money that was going into those
real estate investments?
A. No.
Q. What did Mr. Stanford say about that?
A. Well, the first ones we did were limited
partnerships. We raised money by -- can I elaborate?
Q. I'll ask --
THE COURT: Okay. Go on.
BY MR. COSTA:
Q. Did you understand that the bank was separate from
these real estate partnerships?
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Direct-Knoche/By Mr. Costa
Johnny C. Sanchez, RMR, CRR - [email protected]
2120
A. Yes.
Q. Now, was Mr. Stanford at first trying to target bank
customers to see if they would also be willing to invest
in the real estate partnerships?
A. Yes.
Q. And these real estate partnerships were focused on
what type of investments?
A. Residential rental property.
Q. In what area?
A. In primarily Houston, Texas.
Q. And what was going on in the economy here in Houston
when you were hired in 1987?
A. It was -- in home building business and the real
estate business, it was very bad.
Q. So what was the idea -- I think you used the term
"distressed real estate." What was the idea with
targeting distressed real estate?
A. To purchase these properties that the current owners
were not able to spend money to keep them up on and
rehabilitate them and run them properly and then sell
them.
Q. And was each project set up as a separate
partnership?
A. Yes.
Q. Where was the first partnership? What did that
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Direct-Knoche/By Mr. Costa
Johnny C. Sanchez, RMR, CRR - [email protected]
2121
involve?
A. It was a small apartment project in southwest Houston
called Takara So Apartments.
MR. SCARDINO: Spell that.
THE WITNESS: Yes, it was T-a-k-a-r-a S-o
Apartments.
BY MR. COSTA:
Q. And did that partnership -- in that first
partnership, was Mr. Stanford's successful in getting some
of the bank's clients to also invest separately in the
real estate partnership?
A. Yes.
Q. What about -- was there a second real estate
partnership set up?
A. Yes.
Q. What did that partnership purchase?
A. It was called the Jonathan Square One Apartments.
Q. Where was that located?
A. In southwest Houston.
Q. For that second partnership that was set up, was
Mr. Stanford successful in getting the bank's clients to
invest separately in the real estate partnership?
A. Not to the full extent.
Q. It didn't fund the whole partnership?
A. That's correct.
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Direct-Knoche/By Mr. Costa
Johnny C. Sanchez, RMR, CRR - [email protected]
2122
Q. Where -- were you told by Mr. Stanford where the rest
of the money came from to fund that second partnership?
A. He said he had personal resources to take care of it.
Q. Was there a third real estate partnership?
A. Yes.
Q. What did that purchase?
A. It was called the Rock Springs Apartments.
Q. In Houston?
A. Southwest Houston.
Q. Was Mr. Stanford successful in getting the bank
customers to invest separately in this third real estate
partnership?
A. Yes, but not to the full extent, not to the full
need.
Q. Who did Mr. Stanford say made up the difference?
A. He said he had personal resources that would take
care of it.
Q. Was there a fourth partnership set up?
A. No, there was only three.
Q. Was there -- were there also Austin investments?
A. Yes, more properties were purchased, but they were
not limited partnerships.
Q. How were those set up?
A. They were -- these purchases -- by that time, the
name of the company had the changed to Guardian
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Direct-Knoche/By Mr. Costa
Johnny C. Sanchez, RMR, CRR - [email protected]
2123
Development Corporation, and they were purchased by
Guardian Development Corporation.
Q. How long did it take for Guardian Investment Services
that you started with in 1987 to become Guardian
Development Company?
A. It was in the first two to three years.
Q. And by this time when Guardian Development was
created, did you have a new title?
A. Yes. I became president.
Q. When Guardian Development was created, was
Mr. Stanford still trying to get bank customers to invest
separately in the real estate investments?
A. No.
Q. Did you learn why there were difficulties with
getting bank clients to invest in the real estate
partnerships?
A. I heard from the bank officers some of the reasons.
MR. SCARDINO: Excuse me. Assuming facts that
are not in evidence, and he's leading the witness.
THE COURT: All right. Rephrase it.
BY MR. COSTA:
Q. You mentioned that after the first real estate
partnership, the second and third were not fully funded by
the bank customers; correct?
A. Yes.
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Johnny C. Sanchez, RMR, CRR - [email protected]
2124
Q. And then once Guardian Development started, the bank
clients weren't helping to fund that is your
understandings; right?
MR. SCARDINO: Object to leading.
THE COURT: Overruled.
THE WITNESS: Could you repeat it, please?
BY MR. COSTA:
Q. Once Guardian Development started, was Mr. Stanford
still trying to get the bank clients to fund Guardian
Development?
A. No.
Q. Did you learn why he wasn't able to get enough bank
clients to fund, say, the second and third real estate
partnerships fully?
THE WITNESS: I would have to answer with some
narrative, Judge.
Q. It's a narrative. It calls for a narrative.
THE COURT: Answer it yes or no.
BY MR. COSTA:
Q. Did you learn why?
A. Yes.
THE COURT: All right.
BY MR. COSTA:
Q. What was different about investing in the bank CDs
as -- according to what the bank said it did with the
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Johnny C. Sanchez, RMR, CRR - [email protected]
2125
money versus investing in these real estate partnerships?
A. The real estate partnerships were not liquid.
Q. What do you mean by that?
A. Liquid means you can get your money if you decide --
MR. SCARDINO: Excuse me, Mr. Knoche.
He asking him to give an opinion about a
matter -- a financial transaction, and he's not qualified
to give an opinion about a financial transaction.
MR. COSTA: They've been asking all these
questions about international accounting standards, about
all types of stuff. I'm just asking what he understands --
he was involved in the real estate companies.
THE COURT: Overruled.
BY MR. COSTA:
Q. What do you mean when you say the real estate
partnerships were not liquid?
A. If you want to get your money out, a real estate
partnership would not -- you would have to wait until the
property is sold.
Q. What about -- we saw earlier the banks's annual
report talking about bonds and equities. How long does it
take to sell bonds and equities if they're traded on a
public market?
A. Usually one to two days, I think.
Q. These apartment complexes that you were working on on
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Johnny C. Sanchez, RMR, CRR - [email protected]
2126
the real estate side of things, how long would it take to
sell those?
A. It would take months.
Q. What about the risk level? You mentioned the
liquidity difference. Is there also a difference in risk
level between what the bank was saying it did with its
investment portfolio versus these investments in
distressed real estate?
A. Yes.
Q. And what's the risk level of investments in
distressed real estate?
A. Real estate would be considered to have some degree
of risk in it. The price of -- the value of the property
can go up or down.
Q. Everything can go up or down; right?
A. Yes.
Q. What about the level of risk in a distressed real
estate investment versus the risk in a diversified
portfolio stocks and bonds?
A. I would say it is more in the real estate.
Q. You mentioned that Mr. Stanford was saying he
personally -- when the bank clients weren't interested in
funding these real estate partnerships, you said that he
told you it was his funds that were making up the
difference?
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Direct-Knoche/By Mr. Costa
Johnny C. Sanchez, RMR, CRR - [email protected]
2127
A. He had personal resources.
Q. And what about when Guardian Development Company
started, where did Mr. Stanford tell you he was getting
the money for those acquisitions?
A. Personal resources.
Q. Were you actually able to see the bank records
showing the actual sources of those money?
A. No.
Q. At times did you ask Mr. Stanford where the money was
coming from?
A. Maybe once or twice and then --
Q. Why did you stop asking him?
A. If he didn't want to answer a question, he wouldn't
answer it -- he wouldn't answer it.
Q. So when you'd asked him those first couple of times,
did he give you a lot of information?
A. No.
THE COURT: Move that mike away just a little
bit.
THE WITNESS: Okay. I'm sorry. Tell me if
this is going to be better.
THE COURT: Depends upon how close you get
again.
THE WITNESS: I'm sorry.
THE COURT: Right now it's fine.
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THE WITNESS: My fault.
BY MR. COSTA:
Q. I'm sorry. You're saying if he didn't like to give
you more information?
A. No.
Q. Okay. In terms of working for Mr. Stanford, what was
the general atmosphere, in your view, about whether he
liked being questioned?
A. He did not like to be questioned.
MR. SCARDINO: I object to the relevance of
whether he liked to be questioned.
THE COURT: Overruled.
By the way, you can sit back and pull that
microphone in if you want.
THE WITNESS: Okay.
BY MR. COSTA:
Q. I'm sorry. There was an interruption. So could you
answer again what -- whether -- your understanding of
whether Mr. Stanford liked being questioned.
A. My impression was he did not like to be questioned.
Q. What do you base that impression on?
A. Just the way he would respond if somebody asked him
about where monies came from.
Q. How would he respond?
A. If it was an employee, he would probably just not
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2129
answer it, period. If it was somebody else, he might say,
"We'll talk about that later" or something like that.
Q. Did Mr. Stanford ever tell you that he was taking
money from the bank, from its investment portfolio, to
invest in any of these real estate projects?
A. No.
Q. Would that have concerned you if he had told you
that?
A. Yes.
Q. Why?
A. Well, because the bank's promotional material says
it's invested in other things.
Q. You said you started with Mr. Stanford in 1987. And
I'm jumping ahead just a little bit. How long did you
work for Mr. Stanford?
A. I worked there until 2003.
Q. So that's about 16 years?
A. Yes, 16 years.
Q. Did there come a time when you learned that the bank
moved from Montserrat?
A. Yes.
Q. What -- did Mr. Stanford say about why the bank moved
from Montserrat?
A. He said the bank had outgrown Montserrat, that he
needed to go to a larger venue such as Antigua.
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Direct-Knoche/By Mr. Costa
Johnny C. Sanchez, RMR, CRR - [email protected]
2130
Q. Did he ever tell you that Montserrat had sent a
letter notifying him they were planning to revoke his
banking license?
A. No.
Q. When you started working for Mr. Stanford in 1987,
was Jim Davis already working there?
A. No.
Q. Do you recall about how long after you got there that
Jim Davis came on board?
A. Within the first year.
Q. And what was Mr. Davis's position when he came on
board?
A. Chief financial officer.
Q. You already said you were a CPA; correct?
A. Yes.
Q. And you'd been a controller at one of those home
building companies?
A. Yes.
Q. Did Mr. Stanford ever ask you if you were interested
in that position of CFO that he gave to Jim Davis?
A. No.
Q. Had you heard that they were looking for that --
someone to fill that position?
A. No.
Q. Had there been an advertisement, a want ad, like the
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Johnny C. Sanchez, RMR, CRR - [email protected]
2131
one for your position looking for a CFO?
A. Not to my knowledge.
Q. You said you were a CPA; correct?
A. Yes.
Q. Was Mr. Davis a CPA, to your knowledge?
A. Not to my knowledge.
Q. What was Mr. Stanford's relationship with Mr. Davis?
A. He said they went way back. They were college
roommates.
Q. And was there -- where was Mr. Davis's office in
relation to Mr. Stanford's once Mr. Davis came on board?
A. In the same building, 1100 Milam Building.
Q. Was Mr. Stanford's relationship with Mr. Davis
different than with his relationship with other employees
from what you saw?
A. From what I saw, yes.
Q. How was it different?
A. They were friends. I mean, the rest of us were
employees, they were friends.
Q. After Mr. Davis arrived, did it seem to you like
Mr. Davis was now in charge?
A. No.
Q. And you said you worked there through 2003?
A. That's correct.
Q. Through 2003, did it ever seem to you like Mr. Davis
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Direct-Knoche/By Mr. Costa
Johnny C. Sanchez, RMR, CRR - [email protected]
2132
was in charge?
A. No.
Q. Did that thought ever even cross your mind?
A. No.
Q. Why not?
A. It was Mr. Stanford's companies. There was no doubt.
Q. Including the bank?
A. Yes.
Q. How would you describe Mr. Stanford's management
style in terms of his level of involvement?
A. He was very involved. He knew what was going on.
Q. Did there come a point when Mr. Davis actually helped
provide accounting services for your -- the company you
were president of, Stanford Development?
A. Yes.
Q. So Mr. Davis didn't just work for the bank; is that
right?
A. That's correct.
Q. Did Stanford Financial Group provide accounting and
other support services for a number of the companies?
A. Yes.
Q. So if it was said that Mr. Davis only had involvement
with the bank, you wouldn't agree with that?
A. No.
Q. Do you recall when it was that Mr. Davis started to
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Direct-Knoche/By Mr. Costa
Johnny C. Sanchez, RMR, CRR - [email protected]
2133
help with the accounting for Stanford Development Company?
A. Probably the early 1990s, early-to-mid-1990s.
Q. And I should clarify one thing. You said -- you
started off you were hired for Guardian Investment
Services; right?
A. Yes. Guardian International Investment Services.
Q. And then you said it became Guardian Development?
A. Yes.
Q. And then did it change to something else?
A. Yes.
Q. What did it change to?
A. Stanford Development Company -- Corporation.
Q. And when Mr. Davis in the early '90s started to help
with the financial statements for Guardian Development
Company, did you just withdraw completely from having any
involvement in the financial aspects of your business?
A. No.
Q. Why not if he was CFO?
A. Well, the president's responsible.
Q. So you mentioned in the late '80s when you started,
the focus of these real estate investments was distressed
apartment complexes?
A. Yes.
Q. And the idea was to -- with these partnerships was to
sell those as an investment and eventually make a profit;
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Direct-Knoche/By Mr. Costa
Johnny C. Sanchez, RMR, CRR - [email protected]
2134
right?
A. Yes.
Q. During the '90s, did the focus of the development
company begin to change?
A. Yes.
Q. Did the focus -- let's say in the mid-'90s, was the
focus still on buying distressed properties and then
trying to sell them a few years later?
A. No.
Q. What became the focus in the mid-'90s?
A. Two things: We built some houses for sale, but
mainly we, I think, became like a construction department
for the other entities. We built things for the other
members of the group.
Q. Let's take those one at a time. You mentioned some
houses that were built?
A. Yes.
Q. Tell the jury about those.
A. We built one in Houston called Stanford Oaks. It was
16 townhomes, just off Kirby and San Felipe. And we built
one called Le Voisinage. It was about the same number of
units over off West Alabama.
MR. SCARDINO: Could you spell that?
THE WITNESS: Yes. It's a French word.
L-e V-o-i-s-a-n-g-e (sic), I believe.
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Direct-Knoche/By Mr. Costa
Johnny C. Sanchez, RMR, CRR - [email protected]
2135
And then later, very late, we started the
loft project downtown, The Stanford over by Minute Maid
Park. It was about a four-story loft project.
BY MR. COSTA:
Q. So, say, your last ten years with the company, say,
from '93 to '03, were those three projects you just
mentioned, were those the only investment-type projects --
A. Yes.
Q. -- that you recall?
A. Oh. In Antigua, we built some houses, also. We
built a small subdivision in Antigua called Cedar Valley
Springs. Those were for sale.
Q. And with any of those four projects that occurred
over your last decade or so, did Mr. Stanford ever tell
you that CD depositors' money was being used to fund
those?
A. No.
Q. Where did you understand the funding to come from for
those projects?
A. They were coming from Stanford Financial Group or
Allen Stanford as an individual.
Q. Now, you said most of the work during your last
decade became construction projects for other Stanford
businesses?
A. Yes.
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Direct-Knoche/By Mr. Costa
Johnny C. Sanchez, RMR, CRR - [email protected]
2136
Q. And where were most of those construction projects
located?
A. Well, some -- the offices for Stanford Group Company
were in the United States, and the others were in Antigua.
Q. Did you end up spending a lot of time in Antigua?
A. Yes. A great deal.
Q. How often -- in your latter few years with the
company, how much time did you have to spend in Antigua?
A. About half the time.
MR. COSTA: If we could go to 1530, please.
This we've already offered early this morning.
BY MR. COSTA:
Q. Do you recognize that photo, Mr. Knoche?
A. That was not completed when I left in 2003, but that
is the Antigua Athletic Club.
Q. Who owned the Antigua Athletic Club?
A. Stanford Development Company.
Q. Like a health club?
A. Yes.
Q. With a swimming pool?
A. Yes.
MR. COSTA: Let's go to Page 3, please. The
jury's already seen this.
BY MR. COSTA:
Q. What's this photo?
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Direct-Knoche/By Mr. Costa
Johnny C. Sanchez, RMR, CRR - [email protected]
2137
A. That's the Sticky Wicket Restaurant and Bar.
Q. And what entity built that?
A. Stanford Development Company.
MR. COSTA: If we can go to Page 11.
BY MR. COSTA:
Q. Do you recognize that?
A. That's the airplane hangar in Antigua.
Q. When you say airplane hangar, what airplanes were
allowed to use that hangar?
A. The Stanford fleet or Stanford planes.
Q. And who built -- which entity built that?
A. Stanford Development Company did the construction.
There might have been a separate entity like Stanford
Aviation or something that might have been the ownership,
but Stanford Development Company built it.
Q. You mentioned Stanford Aviation. That was another
company?
A. That's my recollection -- that might not be exactly
the right terminology, but there was a separate entity
that had to do with aviation.
Q. Now, when you say the aviation, what types of planes
are you talking about?
A. That's strictly the private planes, Stanford planes.
Q. Did there come a time when Mr. Stanford owned
commercial airline companies?
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Direct-Knoche/By Mr. Costa
Johnny C. Sanchez, RMR, CRR - [email protected]
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A. Yes. He started two commercial airline companies.
Q. What were those called?
A. Caribbean Star and Caribbean Sun.
Q. But this hangar and the Stanford Aviation Company
related to the private jets?
A. Yes.
MR. COSTA: Let's go to Page 13, please.
BY MR. COSTA:
Q. Do you recognize that?
A. That was not built when I was there. I believe
that's out on a place called Barnacle Point, but that was
not even under construction when I left.
THE COURT: What is it? What is Barnacle
Point.
THE WITNESS: I believe it was going to be a
dock facility for the boat, his boat, or perhaps other
visitors' boats.
BY MR. COSTA:
Q. So you weren't there to actually construct this, but
you were aware for the planning for a boat dock?
A. Yes.
Q. And whose boat was going to dock there?
A. Mr. Stanford's and I guess anybody else he invited.
MR. COSTA: Let's go to Page 19, please.
BY MR. COSTA:
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Direct-Knoche/By Mr. Costa
Johnny C. Sanchez, RMR, CRR - [email protected]
2139
Q. Do you recognize that?
A. Yes. That's the cricket grounds.
Q. Did Stanford Development build that when you were
president?
A. Yes.
MR. COSTA: And finally number 23, please,
Page 23.
BY MR. COSTA:
Q. It's an overview shot. Do you recognize that?
A. Yes.
Q. What is that showing?
A. That's the overall -- some of the things we've
already seen. It shows the Sticky Wicket and the Athletic
Club. It also shows Stanford International Bank building.
Q. Are these properties all in a certain area in
Antigua?
A. Yes, they're all in approximately 20 acres adjacent
to the airport.
Q. What were the years when this whole development
started construction?
A. From the late 1990s through the early 2000s.
Q. Was it expensive to build all these different
buildings?
A. Yes, I mean, expensive relative, but, yes.
Q. Was Mr. Stanford involved -- was he involved with you
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Johnny C. Sanchez, RMR, CRR - [email protected]
2140
in the plans and the budgets?
A. In the plans, very much so.
Q. What about the budgets. Did Mr. Stanford -- did he
express a lot of concerns about cost?
A. No.
Q. Did you ever raise with him concerns about costs?
A. Yes. And we tried to do budgets, but a lot of times
it was fast tracked and we weren't able to do a budget
because we already started construction before all the
bids were in and the construction documents were
completed.
Q. And who wanted it fast tracked?
A. Mr. Stanford.
Q. What did he tell you about the time in which he
wanted these things built?
A. They always needed to be built very quickly to show
that things could be done rapidly in the Caribbean.
Q. What did Mr. Stanford say about the quality of this
construction?
A. The quality had to be the best in the world.
Q. Did he actually use the term about the standard of
quality he wanted to set?
A. Yes, create a new standard of quality for the
Caribbean.
Q. Is it difficult to get some of these materials used
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Johnny C. Sanchez, RMR, CRR - [email protected]
2141
in these buildings down to Antigua?
A. Yes. It's a small island, so there's very few
materials on the island. Almost everything has to be
brought in.
Q. Can that be expensive to import all the materials?
A. Yes. It adds to the cost, yes.
Q. What types of materials did Mr. Stanford want
included that you had to import?
A. The millwork, which is the wood paneling, granite and
marble finances.
Q. Once the construction started, did Mr. Stanford stay
involved in monitoring the progress?
A. Yes.
Q. Was there ever an issue with some hardwood floors?
A. Yes. We had hardwood floors in Stanford
International Bank. He thought we had a too light a shade
on them, and he wanted them change out.
Q. Why did he want a different shade for the hardwoods?
A. He wanted them to be the same as the other offices.
They end up being put in, in a lighter shade than the
other offices around the world. He wanted them all to be
the same.
Q. And he noticed just that that shading was off in the
hardwood floors?
A. Yes.
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Direct-Knoche/By Mr. Costa
Johnny C. Sanchez, RMR, CRR - [email protected]
2142
Q. What was his reaction when he saw that?
A. He was very upset.
Q. Did he talk to you about it?
A. Yes.
Q. What did he say?
A. He said, "This shouldn't have happened."
Q. What were you told from Mr. Stanford about the source
of funding for this Stanford world down in Antigua?
A. Just he had his resources. He was doing it.
Q. A few days ago, did I show you a video clip of
Mr. Stanford talking about these construction projects?
A. Yes.
Q. Did you recognize him as Mr. Stanford in that video?
A. Yes.
Q. Now, were you actually present at that particular
speech?
A. No.
Q. But was what Mr. Stanford said in that video, was it
consistent with what he was telling you over the years
about this Antiguan development?
A. Yes.
MR. COSTA: Your Honor, at this time I'd offer
1535A.
(Attorneys conferring)
MR. SCARDINO: We have no objection.
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Johnny C. Sanchez, RMR, CRR - [email protected]
2143
THE COURT: No objection, 1350 --
MR. COSTA: 1535A, Your Honor.
THE COURT: 1535A is now identified, and it's
in evidence.
Now, what is A? A is --
MR. COSTA: Let's go back.
THE COURT: What is --
MR. COSTA: A, Your Honor, is a clip. It's not
the entire -- the entire speech goes on. This is a clip of
a few minutes.
THE COURT: Video clip?
MR. COSTA: Video clip.
THE COURT: Thank you.
MR. COSTA: Can we get the lights maybe, Your
Honor?
THE COURT: Well, more lights.
MR. COSTA: Less.
(Whereupon, the tape was played)
MR. COSTA: Stop it right there.
BY MR. COSTA:
Q. Who did he just say there? What pronoun did he use
when he was talking about who built it and who paid for
it?
A. "I."
Q. Is that consistent with your discussions with
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Direct-Knoche/By Mr. Costa
Johnny C. Sanchez, RMR, CRR - [email protected]
2144
Mr. Stanford over the years?
A. Yes.
MR. COSTA: Continue now.
THE COURT: A little louder.
(Whereupon, the tape was played)
BY MR. COSTA:
Q. Did Mr. Stanford, again, say who was paying for the
development?
A. He said "I."
Q. What else did he say about the economics of the
development?
A. On parts, that would make no economic sense.
MR. COSTA: Maybe we can just finish it up.
(Whereupon, the tape was played)
BY MR. COSTA:
Q. Mr. Knoche, towards the end there, did Mr. Stanford
say where he was giving the speech?
A. In the airport in Antigua. In the aircraft hangar in
Antigua.
Q. That's the private hangar we just saw the picture of?
A. Yes.
Q. That wasn't part of the airport that any American
Airlines or any other plane could use; right?
A. No. That's correct.
Q. And when Mr. Stanford said in the video a couple of
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Direct-Knoche/By Mr. Costa
Johnny C. Sanchez, RMR, CRR - [email protected]
2145
times, "I'm building this," that's consistent with what he
told you?
A. Yes.
Q. Did you ever inquire where he was getting all the
money?
A. No. No.
Q. Did he ever tell you -- mention his family money?
A. On the early -- in the early, early days.
MR. SCARDINO: Excuse me. He asked him if he
ever inquired where he got the money, and he said no.
THE COURT: Okay.
MR. SCARDINO: Object to the form of the
question.
THE COURT: All right. Next question.
BY MR. COSTA:
Q. Did he ever mention family money?
A. Only in the early days.
Q. What did he say in the early days?
A. When -- where is the money coming from, he said, I
have fam -- personal resources, family resources.
Q. And in later years, it was -- he just said it was
him?
A. Yes.
Q. Now despite Mr. Stanford telling you that, like he
said on the video, towards the end of your time with
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Direct-Knoche/By Mr. Costa
Johnny C. Sanchez, RMR, CRR - [email protected]
2146
Mr. Stanford, did you start having concerns about whether,
in fact, all the money was coming from him?
A. I just wondered where all the money was coming from
because it was a huge amount of money with the airlines
and all.
Q. What do you mean when you say, "with the airlines and
all"?
A. That was the biggest endeavor. To start two airlines
in the Caribbean was a huge endeavor.
Q. That's the Caribbean Sun and Star you mentioned?
A. Yes.
Q. Was it also costing a lot for all these construction
projects --
A. Yes.
Q. -- in Antigua?
And if the money wasn't coming from
Mr. Stanford's personal wealth, did you have a suspicion
where it possibly could be coming from?
MR. SCARDINO: Assuming facts not in evidence.
THE COURT: Sustained.
BY MR. COSTA:
Q. Did you know which other business of Mr. Stanford had
funds to support this type of construction and these two
airlines?
A. I was not aware -- I was not aware of where it came
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Direct-Knoche/By Mr. Costa
Johnny C. Sanchez, RMR, CRR - [email protected]
2147
from. I don't know.
Q. You didn't know -- you didn't know where the money
came from?
A. No.
Q. You didn't see any financial records?
A. No.
Q. But did you have a concern -- if it wasn't coming
from Mr. Stanford, were you concerned about where it might
be coming from?
A. Yes.
MR. SCARDINO: Too late.
BY MR. COSTA:
Q. What was your concern about where it might be coming
from?
MR. SCARDINO: Objection to relevance as to
what his concern might have been.
THE COURT: Sustained.
MR. COSTA: Your Honor --
THE COURT: What?
MR. COSTA: It's -- I'm going to go ahead, but
it's part of the reason he --
THE COURT: Well, thank you for going ahead,
but I appreciate that.
What else, though, Counsel? What else do
you want to say to get me to reverse that ruling? That's
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Johnny C. Sanchez, RMR, CRR - [email protected]
2148
what I want to know.
MR. COSTA: Well, I just want to --
THE COURT: Put it that way.
MR. COSTA: I want to put it in context to make
it relevant as for his concerns when he left the company.
THE COURT: All right. He had concerns. See
if it's relevant.
BY MR. COSTA:
Q. Let's go to Government 115, please, which is already
in evidence.
Do you recognize this as a Stanford
International Bank annual report?
A. Yes. 2 -- I'm sorry. 2002.
Q. That's towards the end of your time with
Mr. Stanford?
A. Yes.
Q. And in the 16 years you were with Mr. Stanford, did
he ever say that bank money was going to the development
corporation?
A. No.
Q. Did you ever see any bank documents that said that?
A. No.
MR. COSTA: If we can turn to Page 50 of this
annual report. If we can highlight the top portion, that
first note.
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Johnny C. Sanchez, RMR, CRR - [email protected]
2149
BY MR. COSTA:
Q. This shows the bank's supposed investments for 2002.
Do you see it lists total assets in the
investment portfolio of 1.5 billion, Mr. Knoche?
A. 1.573 billion, yes.
Q. And what does it say it has in equities?
A. $720,900,000 -- $720,951.040.
Q. And what about treasury bonds?
A. $832,336,398.
Q. It's actually 852. 852 million on treasury bonds?
A. 852 million on treasury bonds, yes.
Q. Anywhere on there that you see it showing real estate
investments?
A. No.
Q. You were the president of the development company?
A. Yes.
Q. Did Mr. Stanford ever tell you he had received loans
from this Stanford International Bank to help fund the
development company?
A. No.
Q. I want to show you Government 336.
Do you recognize the signature on the
second page of this, Mr. Knoche?
A. Yes, I do.
Q. Whose signature is it?
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Direct-Knoche/By Mr. Costa
Johnny C. Sanchez, RMR, CRR - [email protected]
2150
A. R. Allen Stanford.
Q. And what type of document is this?
A. It is a promissory note.
MR. COSTA: Government offers 336.
MR. SCARDINO: Can I have just a second?
THE COURT: Sure.
MR. SCARDINO: No objection.
THE COURT: Okay. Keep in mind 336 --
MR. SCARDINO: Is it offered for the truth of
the matter?
MR. COSTA: It's just a contract, and it's
signed by the defendant as a party opponent.
THE COURT: All right. Keep in mind if you're
going to enter it -- if you're going offer it for other
than the standard reason, I think you just mentioned that
you would.
MR. COSTA: We're offering this for all
purposes. It's a document signed by Mr. Stanford. It's a
statement by party opponent.
THE COURT: Correct. What I'm about to say,
everything is already in evidence; okay. For -- what is
it -- just for the docket itself. I'm not going into the
exact determination.
So if you would, just say you're about to
discuss a certain exhibit and just put them on notice.
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Direct-Knoche/By Mr. Costa
Johnny C. Sanchez, RMR, CRR - [email protected]
2151
And so it may go ahead with no objection.
But anyhow, 336 is in for all purposes.
MR. COSTA: Thank you, Your Honor.
If we can highlight the top portion,
including the first full paragraph. Perfect. Thank you.
THE COURT: Ladies and gentlemen, we'll take a
break in about five minutes.
BY MR. COSTA:
Q. What's the date on this, Mr. Knoche?
A. December 31, 2002.
Q. I think you've said you left in 2003; is that
correct?
A. That's correct.
Q. So you were working for Mr. Stanford on that day?
A. Yes.
Q. And it's a promissory. It says Promissory Note.
What's a promissory note?
A. That's a debt that -- it says -- it's a debt.
Q. And do you see that it says, "For value received,
R. Allen Stanford promises to pay to the order of Stanford
International Bank," lists the address, "the principal sum
of $168 million, together with any unpaid interest at the
rate" -- "and on the terms set forth below."
Do you see that?
A. Yes.
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Direct-Knoche/By Mr. Costa
Johnny C. Sanchez, RMR, CRR - [email protected]
2152
Q. At the top, it lists that amount again, $168 million?
A. Yes.
Q. Were you ever told about this when you worked for
Mr. Stanford?
A. No.
Q. Were you ever told that this loan was helping to fund
some of the development corporation projects that you were
in charge of?
MR. SCARDINO: Assuming facts that are not in
evidence. Object.
MR. COSTA: Just asking if Mr. Stanford told
him that.
THE COURT: Well, again, are you going for link
it up later?
MR. COSTA: The next witness is going to show
hundreds of millions of dollars going to that development
corporation.
MR. SCARDINO: Well, okay. If the next witness
does it that's fine, but this witness doesn't have
knowledge of it.
MR. COSTA: But all I need is a good faith
basis to ask the question.
THE COURT: I overrule the objection with that
caveat, with that proviso.
BY MR. COSTA:
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Direct-Knoche/By Mr. Costa
Johnny C. Sanchez, RMR, CRR - [email protected]
2153
Q. Did Mr. Stanford ever tell you that this $168 million
he was taking out of the bank, that some of that was being
used to fund the development corporation which you were
president of?
A. No.
Q. Would it have concerned you if you had seen this
promissory note and heard that some of this money was
going to the development corporation?
A. Yes.
Q. Why?
A. That the depositors and the bank would not have --
were told that there were not loans being made.
Q. I want to show 337.
MR. COSTA: Is it in, Your Honor?
THE COURT: Pardon me. They're still talking.
MR. COSTA: Give you a second.
THE COURT: But the clock is on them.
MR. SCARDINO: We don't have any objections to
this, Judge.
THE COURT: Okay. What exhibit then?
MR. COSTA: 337, Your Honor.
THE COURT: It's already been identified?
MR. COSTA: No. This is the first time it's
been discussed at trial.
THE COURT: Hang on a second. 337 is admitted.
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Direct-Knoche/By Mr. Costa
Johnny C. Sanchez, RMR, CRR - [email protected]
2154
BY MR. COSTA:
Q. When did you leave in 2003?
A. At the end of June 2003.
Q. About halfway through the year?
A. Yes.
Q. And this is dated the end of 2003; correct?
A. Yes.
Q. And does it look pretty much --
MR. COSTA: If you can go back to the full
document for a second, please. Please blow up --
BY MR. COSTA:
Q. Does that look similar to the prior promissory note
from 2002 I showed you?
And I can hand that to you, if you want.
Just generally, is it the same --
A. Yes.
Q. -- type of document?
But it's just one year later,
December 2003?
A. One year later, yes.
MR. COSTA: If we can go to the top portion
again, please.
BY MR. COSTA:
Q. And what is the amount in December 31, 2003, that
Mr. Stanford now owes Stanford International Bank?
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Direct-Knoche/By Mr. Costa
Johnny C. Sanchez, RMR, CRR - [email protected]
2155
A. 330 million.
Q. And in 2003, there was still a lot of construction
being done on all these -- the Antiguan development we
looked at?
A. Yes.
MR. COSTA: This is a good stopping point if
you want a break, Your Honor?
THE COURT: Ladies and gentlemen, it's now
3:55. We'll take our 20-minute break for the afternoon.
See you back ready to resume at 4:15.
(Recessed at 3:56 p.m.)
(The following was held before the jury.)
THE COURT: Thank you. Be seated.
MR. COSTA: May I proceed, Your Honor?
THE COURT: Yes.
MR. COSTA: Thank you.
BY MR. COSTA:
Q. Mr. Knoche, before the break, we were talking about
Government 337, which is this promissory note from the end
of December 2003 for $330 million.
And you said you were never told either in
2002 or 2003 that money from the bank was going to the
development corporation you were president of?
A. That's correct.
MR. COSTA: If we can go to Page 2 and look at
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Johnny C. Sanchez, RMR, CRR - [email protected]
2156
the signature. Blow up the signature portion.
BY MR. COSTA:
Q. Do you recognize the signature on that promissory
note?
A. Yes.
Q. Whose signature is that?
A. R. Allen Stanford.
Q. During the break, did I hand you Government 115,
which is the 2002 annual report?
A. Yes.
Q. And to save time, did I ask you to look through it
during the break?
A. Yes.
Q. In 2002 --
MR. COSTA: If we can go back to 336 real
quick.
BY MR. COSTA:
Q. 2002, was that the year when there was the
168 million-dollar promissory note we saw?
A. Yes.
Q. Do you recall that? It's on the screen.
A. Yes.
Q. Anywhere in that 2002 annual report for the Stanford
International Bank did you see disclosure of this
168 million-dollar loan?
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Direct-Knoche/By Mr. Costa
Johnny C. Sanchez, RMR, CRR - [email protected]
2157
A. No.
MR. COSTA: If we can go to Government 111,
which has already been referenced Your Honor. Go to
Page 21. I'm sorry.
BY MR. COSTA:
Q. Do you see that that's the Stanford International
Bank annual report? It's for 1998? It's hard to read,
but --
A. Yes.
MR. COSTA: And if we can go to Page 21.
BY MR. COSTA:
Q. In this annual report, do you see disclosure of a
loan the bank extended to Robert Allen Stanford in the
blown-up portion?
A. Yes.
Q. It says on December 31st of '96, the bank extended to
Robert Allen Stanford, a director, a loan in the amount of
13 million and change for two years?
A. Yes.
Q. And it gives the balance of still 11.6 million --
A. Yes.
Q. -- at the end of '97?
And it gives more information about that
particular loan?
A. Yes.
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Direct-Knoche/By Mr. Costa
Johnny C. Sanchez, RMR, CRR - [email protected]
2158
Q. So in 1998, there's discussion in the annual report
of a 13 million-dollar loan, but in the 2002 annual
report, you saw no discussion of 168 million-dollar loan?
A. That's correct.
Q. Is there a term you would use to describe the type of
loan being disclosed in this 1998 annual report?
A. That would be a related party transaction.
Q. Were you ever told when you worked for Mr. Stanford
that the bank or your company, Stanford -- the company you
were president of, Stanford Development, was using
international financial reporting standards?
A. No.
Q. Were you ever told that because of those
international financial reporting standards, that related
party transactions were not required to be disclosed?
A. No.
Q. And here in the '98 report, there is such a
disclosure; correct?
A. That's correct.
MR. COSTA: If we can go back to the 2002
annual report, which is Government 115.
BY MR. COSTA:
Q. Is that the one you looked through? It that
Government 115? There might be a sticker on it. Is that
the 2002 annual report --
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Johnny C. Sanchez, RMR, CRR - [email protected]
2159
A. Yes.
Q. -- that you looked at during the break?
MR. COSTA: And if you can turn to the page --
BY MR. COSTA:
Q. That's the one you said did not have the disclosure
of the 168 million-dollar loan?
A. That's correct.
MR. COSTA: If we can go to Page 59 on the PDF.
BY MR. COSTA:
Q. It might be different than the hard copy, Mr. Knoche.
If you can look on the screen.
MR. COSTA: If we can highlight the top couple
paragraphs.
BY MR. COSTA:
Q. It says, "Independent auditors' report to the
members."
Are you familiar that the annual reports
for the bank typically had this independent auditor
report?
A. Yes.
Q. Who was the bank's independent auditor throughout the
whole time you worked for Mr. Stanford?
A. It was Cas Hewlett.
MR. COSTA: And if we go to the bottom.
BY MR. COSTA:
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Direct-Knoche/By Mr. Costa
Johnny C. Sanchez, RMR, CRR - [email protected]
2160
Q. Is Mr. Hewlett signing off in this independent
auditor's report?
A. Yes.
Q. And generally what is an independent or outside
auditor? What's their job?
A. Their job is to examine the books and records of the
client and give the necessary tests that they feel
necessary and then state an opinion as to the accuracy of
the financial statements.
Q. Were you ever in meetings with the private banker and
Mr. Stanford where the banker raised issues about
Mr. Hewlett?
A. Yes.
Q. What did the banker tell Mr. Stanford about
Mr. Hewlett?
A. That it was a very small firm.
Q. And why was that a problem the bankers were bringing
to Mr. Stanford's Attention?
A. They said that some of their clients did not
understand why the bank would not use a larger
international firm.
Q. And you said you spent -- by the end of your time
with Mr. Stanford, you spent about half of your time down
on the island of Antigua?
A. Yes.
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Direct-Knoche/By Mr. Costa
Johnny C. Sanchez, RMR, CRR - [email protected]
2161
Q. Was there a big international accounting firm with an
office in Antigua?
A. Yes. Price Waterhouse had an office.
Q. Did you understand what Mr. Stanford said about why
he wanted to hire Price Waterhouse like the clients were
requesting?
A. I recall that he had met the general partner of that
firm and they didn't hit it off. He just didn't --
MR. SCARDINO: Objection. If he has personal
knowledge of this --
THE COURT: Overruled.
Mr. Stanford told you?
THE WITNESS: Yes.
THE COURT: Okay. Overruled.
BY MR. COSTA:
Q. What was Mr. Stanford's explanation as to why he did
not want to use Price Waterhouse which had an office in
Antigua?
A. He did not go into any detail. He just said he did
not care for that partner, and they didn't hit it off, and
he just did not want to use them.
Q. In your last couple of years working for
Mr. Stanford, did he have a new business idea that he
asked you to get involved in?
A. Yes. The Stanford Caribbean Investment Fund.
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Direct-Knoche/By Mr. Costa
Johnny C. Sanchez, RMR, CRR - [email protected]
2162
Q. So that was going to be separate from the development
corporation you worked for?
A. Yes.
Q. Was it also supposed to be separate from Stanford
International Bank?
A. Yes.
Q. A whole new business?
A. Whole new business.
Q. What was the idea behind the Stanford Caribbean
Investment Fund?
A. He wanted to spread to many of the islands, probably
about a dozen of the other islands, and seek out
investment opportunities in those islands.
Q. And what types of investment opportunities did he say
he wanted to seek out with this fund?
A. He said anything was opened, but primarily he was
interested in resorts, and then he was interested in
improving the infrastructure of those islands that would
support the resorts.
Q. Did this fund get off the ground by the time you left
in June 2003?
A. It was in its very initial stage. We had hired
managers on each of, I think, eight islands, and he had
selected a board of directors from -- with directors from
the different islands.
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Direct-Knoche/By Mr. Costa
Johnny C. Sanchez, RMR, CRR - [email protected]
2163
Q. Do you know by that point in June 2003 if he had
actually got an outside investment money for the fund?
A. I do not know.
Q. You said it involved resorts and building
infrastructure on these islands?
A. Yes.
Q. What was your reaction to this business idea?
A. Well, I thought it was very speculative.
Q. Does that include the resorts?
A. Yes.
Q. Why did you think the idea of investing in resorts in
the Caribbean was speculative?
A. I just always have thought it is. It's a very
fragile market. It's subject to hurricanes, subject to
public perception of that individual island, and it's the
difficulty of building things in the islands, difficulty
of staffing things in the islands.
Q. The first thing you mentioned was hurricanes were a
risk with resorts in the Caribbean?
A. That is a risk, yes.
Q. That speaks for itself.
The second thing you mentioned was public
perception of the island. Could you explain why you say
that's a risk?
A. Well, in any one given island, if there's a
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Direct-Knoche/By Mr. Costa
Johnny C. Sanchez, RMR, CRR - [email protected]
2164
well-publicized crime of any sort against tourists and
that spreads all over the world -- it's not something that
happens every year, but if it does happen -- it's very
detrimental to the marketing.
Q. Sort of like the Natalee Holloway that was in Aruba?
A. That would be an example.
Q. And, third, you mentioned the difficulty with
construction?
A. Yes. All of the islands are small, and you have to
import everything. If something breaks, you have to
import the repair parts. There are some good people --
workers, but there's not very many. So frequently you
have to import or relocate employees there.
Q. What about infrastructure like plumbing and
electricity, is that ever a problem --
A. Oh, yes. Your --
Q. -- in surrounding resorts?
A. The resort is dependent to some extent on the
infrastructure of the island. You have to have the proper
roads to get to the resort.
Unless you produce your own electricity
and your own water, you're relying on the government
electricity and the government water, which in almost all
the islands is very undependable. It goes out frequently.
Q. Did Mr. Stanford ever tell you as part of this
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Direct-Knoche/By Mr. Costa
Johnny C. Sanchez, RMR, CRR - [email protected]
2165
discussion of resorts in the Caribbean about an idea he
had for a resort in Antigua?
A. Yes.
Q. What did he say? What was his idea for that Antiguan
resort?
A. He wanted it to be a super high-end resort. It would
be the best of the best.
Q. Catering to which type of folks?
A. Extremely wealthy.
Q. And when he's telling you that, it was part of this
idea for the Stanford Caribbean Investment Fund?
A. No. Those were separate discussions.
Q. Did he ever tell you the bank was going to put its
money into this super high-end resort he was thinking
about in Antigua?
A. No.
Q. In your view, would that type of investment had been
consistent with what you were told about the bank's
investment strategy?
A. No.
Q. Why wouldn't it be consistent with the bank's -- what
the bank said its investment strategy was?
A. In my opinion, by any definition, that would be a
speculative investment, and the bank said it's in
conservative investments.
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Direct-Knoche/By Mr. Costa
Johnny C. Sanchez, RMR, CRR - [email protected]
2166
Q. Would an investment in a super fancy resort in
Antigua be a liquid investment?
A. No.
Q. Why not?
A. There would be -- if you wanted to sell it, there
would be very, very, very few potential purchasers.
Q. You've already told us you left Mr. Stanford's
company in 2003; is that right?
A. That's correct.
Q. By 2003, how were you -- what were your feelings
about the job with Mr. Stanford?
A. Well, I was very concerned about the amount of travel
I was doing. I was away from home about half the time.
And the Stanford Caribbean Investment Fund, that was just
going to add to that.
Q. And did you decide to resign?
A. Yes.
Q. Did you sit down with Mr. Stanford and tell him about
your decision?
A. Well, I talked to my wife first. It was a hard
decision. And we sent an e-mail and a letter giving two
months' notice, and then he and I discussed it after that,
but I gave two months' notice.
THE COURT: Again, your specific reason for
resigning was?
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Direct-Knoche/By Mr. Costa
Johnny C. Sanchez, RMR, CRR - [email protected]
2167
THE WITNESS: Travel.
BY MR. COSTA:
Q. What did you tell Mr. Stanford when you sat down with
him after sending -- after sending the two months' notice?
A. Just that, I was just away from home too much.
Q. And was that the main reason you wanted to leave?
A. Yes.
Q. Was there also a concern you had, though, by that
time working for the development corporation in 2003?
A. I was concerned about how much money was being spent,
invested.
Q. In this -- all these construction projects in
Antigua?
A. Yes.
Q. If it's all Mr. Stanford's personal money, why be
concerned?
A. Only that -- it seemed like there would be some limit
to how much money he had.
Q. Did you have a job lined up when you sent that
two-month notice to Mr. Stanford?
A. No.
Q. How much were you making as president of the
development corporation?
A. Approximately $300,000 a year including bonuses.
Q. And how old were you when you decided to resign?
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Direct-Knoche/By Mr. Costa
Johnny C. Sanchez, RMR, CRR - [email protected]
2168
A. I would have been 60 years old.
Q. Did you try looking for another job?
A. Yes.
Q. Did you find a job that paid about the same,
$300,000?
A. No.
Q. What did you end up doing?
A. Went to work for the Society of St. Vincent de Paul.
It's a Catholic nonprofit organization that assists the
poor. And I made a salary of $60,000.
Q. And what was your position?
A. Director of finance.
Q. So you took a 240,000-dollar pay cut after leaving
Mr. Stanford?
A. Yes.
Q. Did you regret that decision?
A. No, no regrets.
Q. You said at the beginning of your testimony that when
you -- the first couple of years you worked for
Mr. Stanford, he spent about 90 percent of his time
focused on the bank?
A. Yes.
Q. By the end of your time with Mr. Stanford in 2003,
from what you observed and what you understood, was the
bank still the primary business that he focused on?
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Cross-Knoche/By Mr. Scardino
Johnny C. Sanchez, RMR, CRR - [email protected]
2169
A. Yes.
Q. Did he ever tell you about the importance of the bank
relative to all these other companies?
A. Yes. He said it's what drives it all.
Q. And that's Stanford International Bank?
A. Stanford International Bank drives it all.
MR. COSTA: Pass the witness, Your Honor.
CROSS-EXAMINATION
BY MR. SCARDINO:
Q. Good afternoon, Mr. Knoche. How are you?
A. Very well. Thank you.
Q. My name is Robert Scardino.
We have not met before, have we?
A. No, sir.
Q. How long did you work for Mr. Stanford?
A. Sixteen years.
Q. And what did you do before you came to work for
Mr. Stanford?
A. I worked for Monarch Homes as the chief financial
officer.
Q. Okay. And what was your approximate salary at that
time?
A. Approximately $100,000.
Q. So when you went to work for Mr. Stanford, you ended
up tripling your salary?
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Cross-Knoche/By Mr. Scardino
Johnny C. Sanchez, RMR, CRR - [email protected]
2170
A. Well, in 16 years. When I went to work for
Mr. Stanford, I got the same salary. I started at about a
hundred thousand dollars.
Q. And then you quit and took a job for considerably
less money?
A. Yes, sir.
Q. Now, you've talked a lot about what you observed
while you were working for Mr. Stanford about real estate
and how you were concerned about how maybe he got money to
invest in this real estate.
A. Yes.
Q. And you're a CPA?
A. Yes.
Q. When he hired you, it was for a specific purpose, was
it not?
A. Yes.
Q. And it was to develop real estate, find real estate
deals?
A. That's correct.
Q. And that was in the early '80s in Houston, or really
before that even, when he hired you?
A. He hired me in 1987.
Q. Okay. In '87 -- late '80s, I guess.
And that was a good time to invest in real
estate, wasn't it?
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Cross-Knoche/By Mr. Scardino
Johnny C. Sanchez, RMR, CRR - [email protected]
2171
A. It was depressed. There was depressed real estate
out there, yes.
Q. So it was a good time to invest in real estate?
A. Yes.
Q. And how many real estate deals did you invest in for
Mr. Stanford?
A. We did four in Houston and two in Austin.
Q. Is it possible you're wrong about that and that you
made many more investments other than just four?
A. In Houston?
Q. In Houston, right.
A. Those were the four apartment -- there was only four
apartment projects.
Q. Was there Stanford Lofts?
A. That was one later, for-sale units. There was three
for-sale units, three for-sale projects.
Q. Did you count that as one of the real estate deals?
A. No. It was four rental and three for sale, total of
seven in Houston, Texas.
Q. Okay. So there was a total of seven real estate
transactions?
A. That's correct.
Q. And were they all successful?
A. They were all moderately successful.
Q. They were all moderately successful.
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Cross-Knoche/By Mr. Scardino
Johnny C. Sanchez, RMR, CRR - [email protected]
2172
So it was a good idea to hire you to find
these real estate deals and invest in them?
A. Yes.
Q. Okay. And was what you were specifically hired to
do?
A. Yes.
Q. And you said there was another man that Mr. Stanford
interviewed with -- with you for this job?
A. Yes.
Q. Okay. And he hired you both?
A. That's correct.
Q. And didn't he tell you he couldn't decide who to hire
so he just hired you both?
A. Yes.
Q. Was that generous of him?
A. I wouldn't -- I wouldn't call it generous. It was a
business decision. He made a business decision.
Q. But it was the kind of guy he was. When he was
advertising for a job and two people interviewed for the
job, he didn't pick one of them. He picked both of them;
right?
A. In my opinion, I still wouldn't call it generous. He
made a business decision.
Q. Would it describe his personality where he was the
kind of guy that he thought, Well, instead of just picking
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Cross-Knoche/By Mr. Scardino
Johnny C. Sanchez, RMR, CRR - [email protected]
2173
one of you, I'll just bring both of you in and see what
that brings me? Wasn't maybe -- wasn't financially smart
necessarily, but he did it anyway, didn't he?
A. I think he did it because he thought it was
financially smart, too.
Q. Okay. Well, have you ever hired people --
A. Yes.
Q. -- personally?
A. Yes.
Q. Did you advertise for a position?
A. Yes.
Q. Say, I need to hire somebody?
A. Yes.
Q. Did you interview?
A. Yes.
Q. People come in and talk to them -- talk to you about
the position that you advertised?
A. Yes.
Q. And did you ever hire two people for the same
position?
A. No.
Q. Never did?
THE COURT: Slow down a little bit.
MR. SCARDINO: I'm sorry.
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Cross-Knoche/By Mr. Scardino
Johnny C. Sanchez, RMR, CRR - [email protected]
2174
BY MR. SCARDINO:
Q. So that would be unusual?
A. It was unusual, yes.
Q. Okay. And your credentials, your background, was as
a CPA; right?
A. Yes, sir.
Q. But he didn't hire you as a CPA, did he?
A. No.
Q. He didn't hire you to look at his books, did he?
A. No.
Q. He didn't hire you to look at financial statements,
did he?
A. Only in conjunction with the company I was going to
be working for.
Q. Well, Stanford Development Company eventually; right?
A. Yes.
Q. You were the president of the company?
A. That's correct.
Q. And -- but you didn't -- you weren't C -- CFO of
Stanford Development Company, were you?
A. No.
Q. You weren't the controller of Stanford Development
Company, were you?
A. No.
Q. So you didn't create reports or books and records?
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Cross-Knoche/By Mr. Scardino
Johnny C. Sanchez, RMR, CRR - [email protected]
2175
Even though you had the background for it, that's not what
you were hired to do?
A. That's correct.
Q. So when you asked Mr. Stanford for information about
where did the money come from, that wasn't part of what
you were hired to determine, was it?
A. No.
Q. Okay. And he never bothered to tell you, did he?
A. No.
Q. And that was the kind of guy he was, wasn't he? You
asked him a question, and if he didn't want to answer it,
he didn't answer it.
A. Yes, that's correct.
Q. In fact, you weren't even in a position to ask that
question, were you, Mr. Knoche?
A. You could say that.
Q. You could say that. In fact, we will say that. You
were not in a position -- you weren't hired to make those
kind of determinations, were you?
A. That's correct.
Q. In fact, when you tell this jury you --
THE COURT: Slow down, Counsel. Slow down.
MR. SCARDINO: I'm sorry. I'm wound up a
little bit.
THE COURT: That's all right. I know all about
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Cross-Knoche/By Mr. Scardino
Johnny C. Sanchez, RMR, CRR - [email protected]
2176
being wound up. Go on. Go on.
BY MR. SCARDINO:
Q. When you tell this jury that you were concerned about
where the money came from to make these real estate
developments, to make the deals work, that was none of
your concern, was it?
A. That's correct.
Q. Mr. Stanford never once in the 16 years you worked
for him asked you to be responsible for that kind of
information?
A. That's correct.
Q. In fact, knowing where the money came from wouldn't
have helped you perform your job for Mr. Stanford at all,
would it have?
A. No.
Q. And in your 16 years of working there, the concern
didn't rise to the level where you said, I'm going to quit
because I don't know where this money is coming from, did
it?
A. No.
Q. In fact, you quit because you were tired of the
traveling?
A. Yes.
Q. When you were interviewed by the FBI, do you remember
when that was?
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Cross-Knoche/By Mr. Scardino
Johnny C. Sanchez, RMR, CRR - [email protected]
2177
A. It's been over a year ago, I believe.
Q. It's actually been a lot longer than that.
You've been interviewed twice, haven't
you?
A. Yes.
Q. Do you remember the first date being May 18th of
2010?
A. That could be right.
Q. And do you remember who the FBI agents were that
interviewed you?
A. No, I do not.
Q. Have you had an opportunity to look at reports that
the FBI generates when they interview you?
A. No.
Q. Prosecution hadn't given those to you before you came
here to testify?
A. No.
Q. Did anybody -- did the FBI, when they created the
report, provide you a copy to look at to see if it was
accurate?
A. No.
Q. Nobody's gone back over the interviews to say, Did we
get it right or not, Mr. Knoche?
A. No.
Q. Well, I'll tell you that we get a copy of that as
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Cross-Knoche/By Mr. Scardino
Johnny C. Sanchez, RMR, CRR - [email protected]
2178
part of the process here, and I'd like to ask you some
questions about what you may or may not have told the FBI
during those interviews.
A. Okay.
Q. Back -- do you remember the first interview in
May 18, 2008, that took place in Richmond -- the interview
took place in Richmond, Texas?
A. 2008?
Q. No. I'm sorry. 2010.
A. Okay.
Q. May 18, 2010.
A. Okay.
Q. Okay. Before you had that interview, were you
contacted by the FBI?
A. Yes. They called.
Q. And asked you if you would talk to them?
A. Yes.
Q. And did you agree to do that?
A. Yes.
Q. Okay. And did you hire a lawyer?
A. No.
Q. And did they come over to your place of residence or
home to interview you?
A. My home.
Q. And what time of day or night was that?
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Cross-Knoche/By Mr. Scardino
Johnny C. Sanchez, RMR, CRR - [email protected]
2179
A. It was in the afternoon.
Q. And how many FBI agents arrived?
A. There were three.
Q. Did it make you nervous?
A. No.
Q. Not in the least?
A. Oh, I guess, yes, a little bit. It doesn't happen
every day, no.
Q. But you had three FBI agents at your house at
night --
A. That's correct.
Q. -- asking you about something that you know that at
that time Mr. Stanford had been charged with a crime at
that time?
A. Yes.
Q. Had been arrested at that time?
A. Yes.
Q. Okay. And had been charged with all kinds of
evildoing?
A. Right.
Q. You were familiar with that?
A. I was familiar with that.
Q. Watched -- watched it all on the news; right?
A. Yes.
Q. And, in fact, I think you told them you were
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Cross-Knoche/By Mr. Scardino
Johnny C. Sanchez, RMR, CRR - [email protected]
2180
surprised when you first heard about it. The word you
used was "shocked"?
A. Yes.
Q. And you were shocked because the 16 years that you
were there, you never say anything that you thought was
criminal, did you?
A. No.
Q. And did you tell them -- do you remember telling them
that, when they -- when they asked you if Mr. Stanford was
a hands-on or hands-off guy and in his management style?
A. What's the question?
Q. Well, I mean -- well, your report says you told them
he was a hands-off guy?
MR. COSTA: I'll object to reading from the
report. It's not in evidence. It's hearsay.
THE COURT: Sustained.
BY MR. SCARDINO:
Q. Do you remember telling them that he was a hands-off
guy?
A. No.
Q. You don't remember that? No?
MR. SCARDINO: I'll have to ask him.
BY MR. SCARDINO:
Q. Does it refresh your memory -- show you a report you
say you have not seen before, dated May 18, 2010,
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Cross-Knoche/By Mr. Scardino
Johnny C. Sanchez, RMR, CRR - [email protected]
2181
interview with you by these FBI agents.
MR. COSTA: I'd object. First of all, I don't
think it establishes it was the same FBI agents.
THE COURT: Overruled. You can take him later.
BY MR. SCARDINO:
Q. Second page I've highlighted it, so it's easy to see.
And in reference to answering the question about whether
or not Stanford had a hands-on or a hands-off approach to
managing -- management style, do you remember what you
told them?
A. Okay. To managing myself and Larry Slater, when we
first started, he was not in our offices every day or
anything. So yes, in that connotation, he would have been
hands-off. But he knew what was going on.
Q. Of course, he knew what was going on. He owned
everything, didn't he?
A. That's correct.
Q. I mean, he owned a hundred percent of all of the
companies?
A. That's correct.
Q. Do you know how many companies he owned?
A. No.
Q. It was over a hundred, wasn't it?
A. I would not know.
Q. You had no idea? Because you weren't hired to know
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Cross-Knoche/By Mr. Scardino
Johnny C. Sanchez, RMR, CRR - [email protected]
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that sort of thing, were you?
A. No.
Q. And then, Mr. Knoche, in August of 2011, you were
visited by the FBI again, weren't you?
A. That's correct.
Q. Do you recognize the FBI agent that interviewed you
in the courtroom?
A. I don't remember who was there, because I've talked
to them since here.
Q. Male or female agents?
A. Both.
Q. Okay. And do you remember them asking you in that
interview whether or not he had a hands-on or hands-off
approach to handling his companies?
A. I don't recall that question.
Q. Now, this would have been over a year later; right?
A. Yes.
Q. And you got the second visit.
Was it at your home again?
A. Yes.
Q. Page 4, second paragraph. Do you remember what you
told them when they asked you if he was a hands-on guy or
not?
A. It says right there he was hands-on.
Q. Hands-on.
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Cross-Knoche/By Mr. Scardino
Johnny C. Sanchez, RMR, CRR - [email protected]
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So after they spend 13 months between
times when they interviewed you, your position changes
somewhat about his management style, does it not?
A. From what I was quoted there, one time I said
hands-off; one time I said hands-on.
Q. During the interview process, was it a circumstance
where they said, Mr. Knoche, just tell us everything you
know, and they wrote it down, or was it a process where
they asked you specific questions, and you gave them
specific answers?
A. I would say some of each. They said they wanted to
get background information, and they asked some specific
questions.
Q. Okay. So you volunteered some information?
A. Yes.
Q. Did you take notes?
A. No, I did not.
Q. Did you record the conversation?
A. No, I did not.
Q. When they were talking to you about background
information -- we've talked about this a little bit --
Mr. Stanford asked you to find residential properties such
as apartment complexes, and he specifically wanted a
certain amount of return on the investment, didn't he? Do
you remember that?
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Cross-Knoche/By Mr. Scardino
Johnny C. Sanchez, RMR, CRR - [email protected]
2184
A. I don't remember the amount, but yes, he wanted to
have a certain amount of return of investment for the
partners.
Q. I think you even testified on direct examination that
he was looking for a 10 percent return.
Do you remember that?
A. No, I don't remember saying a specific amount.
MR. COSTA: The question was what he testified
to under direct examination.
THE COURT: Pardon me?
MR. COSTA: The question was what he testified
to under direct examination.
MR. SCARDINO: Said he didn't recall.
THE COURT: Said he didn't recall.
MR. COSTA: He didn't say.
THE COURT: Pardon me? Go on.
BY MR. SCARDINO:
Q. Does it refresh your memory to look at the report
that was created by that interview about what Mr. Stanford
had asked you to do and what kind of return he was looking
for? Page 2, first paragraph. I've highlighted it.
A. That was the range, yes, 10 percent.
Q. Okay.
A. I don't recall saying that specific amount, but
that's not wrong.
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Cross-Knoche/By Mr. Scardino
Johnny C. Sanchez, RMR, CRR - [email protected]
2185
Q. Well, I mean, you don't think the FBI wrote down
something other than what you said, do you?
A. No.
Q. So is it safe to assume that's what Stanford asked
you to provide for him?
A. Yes.
Q. Were you able to do that?
A. Yes.
Q. How about the other fellow that interviewed for the
job? Was he also on board doing that?
A. He stayed there about one year.
Q. Was he successful?
A. Yes.
Q. Did he find real estate deals for Mr. Stanford the
way did you?
A. Yes.
Q. Did they provide a 10 percent return the way you did?
A. Yes.
Q. But he moved on?
A. He moved on.
Q. Okay. And then you go on to talk about how he funded
these various projects, do you not, with the -- in the
interview?
Oh, you haven't reviewed your reports yet.
A. (No audible answer).
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Cross-Knoche/By Mr. Scardino
Johnny C. Sanchez, RMR, CRR - [email protected]
2186
Q. Do you remember talking to the FBI about talking to
Mr. Stanford about how he was going to fund these
projects?
A. I'm sure that was part of the conversation, yes.
Q. Okay. And what did you tell them, if you recall?
A. He said he had clients of the bank that were
interested in real estate in Texas.
Q. Did that raise any red flags for you?
A. No.
Q. Create any problems for you?
A. No.
Q. And when you brought him real estate deals, tell us
generally about what kind of -- like the first deal that
you were able to bring him. You referred to it as a small
project.
A. Yes.
Q. Tell us about it. What kind of project?
A. It was approximately 70 units in Southwest Houston in
the Montrose area, near Southwest Houston.
Q. You say 70 units. What does that mean?
A. 70 apartments.
Q. And was it one apartment complex with 70 apartments
in it?
A. That's correct.
Q. Okay. And how did you acquire that? How did you
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Johnny C. Sanchez, RMR, CRR - [email protected]
2187
find that?
A. We looked at all -- every apartment we could find
that was of interest that was for sale. And that had a
good location, had been very stable. They had a manager
that had been there for 22 years. And it was just very
stable clientele, and it looked like a good opportunity.
Q. Okay. Now, as part of what you were doing for
Mr. Stanford, how would you learn about there particular
project being available? What due diligence would you
have to do?
A. We drove the streets and look at reports. There's a
lot of reports issued about what is -- what is for sale.
Q. Okay. And this was the first deal that came up?
A. It probably was not the first one. It was the first
one that looked like a good opportunity.
Q. Okay. And you took it to Mr. Stanford?
A. Yes.
Q. And you explained to him that you thought it was a
good deal?
A. Yes.
Q. And who put together -- who closed the deal? Was it
you or Mr. Stanford? Who did the paperwork?
A. I did.
Q. You did? Okay.
And after it was acquired, what was the
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Cross-Knoche/By Mr. Scardino
Johnny C. Sanchez, RMR, CRR - [email protected]
2188
company that actually acquired this property?
A. Guardian I Limited, Limited Partnership.
Q. And who owned that?
A. It was owned by -- the general partner was Guardian
International Investment Services, and then there were a
number of limited partners.
Q. Okay. And it was funded by these limited partners;
right?
A. That's correct.
Q. And if you put a deal together that they couldn't get
all the money together to close it, Mr. Stanford came up
with the balance of the money?
A. That's correct.
Q. And you never knew where that money came from; right?
A. That's correct.
Q. And that wasn't part of what you were paid to know or
do, was it?
A. That's correct.
Q. Not in the 16 years that you worked there?
A. No.
Q. And you also talk about in your report to the FBI
that Mr. Stanford asked you to head up a construction
effort in Antigua?
A. Yes.
Q. Do you remember that?
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Cross-Knoche/By Mr. Scardino
Johnny C. Sanchez, RMR, CRR - [email protected]
2189
And what was the reason for that,
Mr. Knoche?
A. He had projects he wanted to build there.
Q. Okay. And was this after you had finished working on
developing the projects here, or were you doing it at the
same time?
A. At the same time.
Q. So you were traveling a lot, weren't you?
A. Yes.
Q. Married at the time?
A. Yes.
Q. Children?
A. Yes.
Q. Pretty tough duty, huh?
A. Yeah, yes.
Q. Working hard, but you were making good money; right?
A. Yes.
Q. And did you have a lot of interaction with
Mr. Stanford during all of this?
A. Sure, yes.
Q. I mean, you would come to him, you'd bring him deals,
and he would respond to them, y'all put it together. And
he was happy; you were happy?
A. Yes.
Q. And then he asked you to expand this, basically the
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Cross-Knoche/By Mr. Scardino
Johnny C. Sanchez, RMR, CRR - [email protected]
2190
same operation, into the Island of Antigua; right?
A. That's correct.
Q. And how long were you working for him when he asked
you to actually make that step, to go to this little
island out in the Atlantic?
A. I started traveling to Antigua in the early 1990s, so
I had been there two, three years.
Q. And how many people were working under you at the
time?
A. In Texas, there would have only been, at the
apartments, maybe 15 total.
Q. Okay. And how about when you went to Antigua. And
how many were working under you then?
A. We eventually got up to where there was probably 250
employees of Stanford Development Company there.
Q. And so, did he tell you why he wanted you to go to
Antigua? What was the general plan for you there?
A. Well, he had confidence in me, and he wanted me to
head up the construction there.
Q. And what were you to construct?
So you go from acquiring real estate to
getting into a construction business; right?
A. Yes. Now, in Texas, we had also built things. We
had built the houses.
Q. And you built the place over by the baseball park;
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Cross-Knoche/By Mr. Scardino
Johnny C. Sanchez, RMR, CRR - [email protected]
2191
right?
A. Yes. That was much later, but yes.
Q. Were all the real estate investments successful?
A. Yes, moderately. Only one of them was very, very
successful. The others were moderately successful.
Q. So it was smart of Mr. Stanford to get into real
estate at that time, and he got the right guy with you to
help him find the properties and acquire them?
A. Yes.
Q. Never a loss on any of the properties that you put
together?
A. No.
Q. Never a problem with funding of these properties with
Mr. Stanford?
A. No.
Q. Never a problem with somebody coming back and saying,
This was a bad deal, this was a fraud or this wasn't what
it was supposed to be?
A. Nau-uh.
Q. No misrepresentations that you know of in any of the
real estate transactions in the 16 years you worked for
Mr. Stanford?
A. No.
Q. Okay. Now, you got into some construction business,
and you built some projects while you were here. And he
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Cross-Knoche/By Mr. Scardino
Johnny C. Sanchez, RMR, CRR - [email protected]
2192
asked you to move to Antigua and build some projects there
and get into construction?
A. That's correct.
Q. Okay. Now, what kind of construction? What did he
want you to build there?
A. The first thing we built was a new headquarters
building for the Bank of Antigua.
Q. Okay. Now, the Bank of Antigua, was that a bank that
Mr. Stanford owned?
A. Yes.
Q. Was he the 100 percent shareholder that I would?
A. As far as I know.
Q. And you were asked to build a new facility?
A. That's correct.
Q. And did you have to acquire property to do that?
A. I think he had already purchased the land. There was
about three acres of land at the airport, and he -- he had
purchased that from the government.
Q. Why was he on the Island of Antigua, if you know?
A. He wanted to move from Montserrat because he said it
was too small, and he just said he had looked at numerous,
and Antigua was one that he thought was the best
opportunity for him.
Q. He had a plan, didn't he?
A. Yes.
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Cross-Knoche/By Mr. Scardino
Johnny C. Sanchez, RMR, CRR - [email protected]
2193
Q. I mean, he didn't just float by one day and say, This
looks like a good place to stop?
A. No.
Q. He had done some homework, hadn't he?
A. Yes, he had.
Q. In fact, he was a visionary in that regard, wasn't
he?
A. Yes.
Q. He was an entrepreneur, wasn't he?
A. He was definitely an entrepreneur.
Q. He started businesses, didn't he?
A. Yes.
Q. Okay. And he had guys like you helping him do it,
didn't he?
A. Yes.
Q. And his idea on Antigua was to build what? Not just
to build a bank, was it?
A. No. Best in the world atmosphere.
Q. Best in the world atmosphere.
Did he tell you that?
A. Yes.
Q. And what did that mean to you, "Best in the world"?
A. Just what it -- just what it says. He wanted to she
better -- as good or better than anything anywhere else.
Q. Why? Why not just okay? Why not just adequate?
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Cross-Knoche/By Mr. Scardino
Johnny C. Sanchez, RMR, CRR - [email protected]
2194
A. That was his style.
Q. And did he have a plan that the best in the world --
well, the best in the world would be expensive, wouldn't
it?
A. Yes.
Q. It would cost more money than just moderate, wouldn't
it?
A. That's correct.
Q. Or just average?
A. Yes.
Q. Did you understand there was a reason why
Mr. Stanford wanted the, quote-unquote, best in the world?
A. Yes.
Q. Was there a motive behind it?
A. He wanted to show that that could be done in the
Caribbean.
Q. And was that because it generally wasn't done in the
Caribbean?
A. That would be fair to say, yes.
Q. And why was it important to him, if you know, that it
be done from the Caribbean, the best in the world could be
accomplished there?
A. That was just his vision.
Q. Well, wasn't -- didn't he have an idea that he wanted
to develop that island in such a way to attract people to
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Cross-Knoche/By Mr. Scardino
Johnny C. Sanchez, RMR, CRR - [email protected]
2195
come there?
A. Yes.
Q. So it wasn't just building something for himself that
he could look at or take a picture of himself standing in
front of it.
He had another plan, didn't he?
A. Yes.
Q. Didn't he explain that to you?
A. Yes.
Q. Okay. What was the plan?
A. That was -- that for the arriving clients of Stanford
International Bank, they would see something that they had
never seen something before their life, and they would be
so attracted to Antigua that they would tell all their
well-to-do friends, and everybody would have confidence in
Stanford International Bank on the Island of Antigua.
Q. Well-to-do friends?
A. Yes.
Q. He wasn't catering to guys like you and me, was he?
A. No.
Q. "High net worth" was the terminology?
A. "High net worth" was the terminology.
Q. High net worth. So the high-net-worth people would
have been attracted to places where they could land their
private jet --
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Cross-Knoche/By Mr. Scardino
Johnny C. Sanchez, RMR, CRR - [email protected]
2196
A. That's correct.
Q. -- wouldn't they?
And what you were shown by the government
earlier -- and I don't remember which exhibit it was, but
it was the one where they were showing a hangar, and it
was -- it wasn't for public use; it was for private use?
A. That's correct.
Q. Did you build that?
A. Yes.
Q. Okay. And was that so that the high-net-worth people
would have a place to land their private jets?
A. Land and be able to clear immigration and customs
right there. They didn't have to stand in line.
Q. And did you build it?
A. Yes.
Q. So if someone would say not a brick was laid
regarding Mr. Stanford's grand plan, that's just not true,
is it? Bricks were laid; right?
A. Yes.
Q. Buildings were built, weren't they?
A. Yes.
Q. Built a fabulous marina that was with cost -- there
was no limit to the cost to that --
A. I was gone when the marina was built.
Q. When Barnacle Point was built? You saw a picture of
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2197
it?
A. I saw a picture of it.
Q. I mean, do you have any question in your mind that it
wasn't built with the best of the best products and
finishes?
A. I have -- I'm sure it was.
THE COURT: Pardon me?
THE WITNESS: I am sure it was built with the
best products.
BY MR. SCARDINO:
Q. And you still had no idea where the money came from
to develop these projects, did you?
A. No.
Q. What are -- what other developments did you build?
What others projects did you have in Antigua besides the
airport and the bank? What else?
A. Well, there were several specific ones at the
airport, and there's also a housing development called
Cedar Valley Springs.
Q. Did you build that?
A. Yes.
Q. Describe that for the jury.
A. That was a like a U.S.-style subdivision. It had an
entrance, one entrance, and it had a little water feature,
and it had individual lots, and we built houses on the
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2198
individual lots.
Q. Okay. And did you actually build houses?
A. Built them -- when I left, we had built some of them,
not all of them.
Q. How many did you build?
A. Probably when I was there, 20.
Q. And how many were left to be built in the development
plan?
A. Probably about that same number. It was probably
about half built when I was -- when I left.
Q. So about 40.
Do you know if it was completed or not?
A. I do not know.
Q. You told the jury that sometime during the time that
you were working for Mr. Stanford, he hired a guy named
Jim Davis or James Davis?
A. That's correct.
Q. Okay. And that they were old college chums?
A. That's what I was told.
Q. And they made -- Mr. Davis to be -- you said, the
CFO; right?
A. That's my recollection. He was the chief financial
officer.
Q. Okay. Can you tell the jury just briefly what a
chief financial officer does?
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2199
A. They're responsible for the overall accounting
function. They make -- be sure everything is paid, the
bills are paid, payroll is met. And then they're
responsible for the preparation the of financial
statements that are presented to the owner.
Q. They're in control of the money; right?
A. They, in conjunction with other management. They're
not -- they're not specifically in charge of the money.
Q. Well, I mean, you have a treasurer, right, in most
companies?
A. In most companies. In this one, there was not a
treasurer.
Q. What's a controller?
A. Controller would be usually right below the chief
financial officer, and they do more of the day-to-day
work. The chief financial officer is overseeing. The
controllers are the day-to-day.
Q. And didn't you tell the FBI that when Mr. Stanford
hired Mr. Davis as -- I think you told them a controller
instead of a chief financial officer, but doesn't make
much difference one way or the other whether it was
controller or chief financial officer?
A. Well, he replaced a controller. I think -- I think
when James Davis came in, his initial title was chief
financial officer, but I'm not positive of that.
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Cross-Knoche/By Mr. Scardino
Johnny C. Sanchez, RMR, CRR - [email protected]
2200
Q. But were you put out that you weren't hired to be the
controller or chief financial officer?
A. No.
Q. I mean, you had previously been a controller; right?
A. Yes, but I was not put out.
Q. Okay. Why would that be an issue that the FBI would
ask you about then?
A. They just asked the questions.
MR. COSTA: Object to the speculation, Your
Honor.
THE COURT: Sustained.
BY MR. SCARDINO:
Q. You talked about -- in your interview with the FBI
about how much Mr. Stanford loved real estate development;
right?
A. Yes. When he got involved in a project, he very much
enjoyed it.
Q. Compulsive in what he did?
A. I wouldn't use the word "compulsive. Extremely
interested in -- I'm not sure what word. I wouldn't say
"compulsive."
Q. Well, I mean, he -- he wanted to make sure things
were done correctly; right?
A. Yeah. Absolutely, yes.
Q. Best of the best?
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Johnny C. Sanchez, RMR, CRR - [email protected]
2201
A. Yes.
Q. And if it wasn't done to his specifications, like
with the way the floor was finished that you talked about,
he made sure that it was changed to his specifications?
A. Yes.
Q. Okay. So he was insistent that things be done in the
manner that he wanted it done?
A. Yes.
Q. And he could be difficult in that regard, couldn't
he?
A. That's correct.
Q. He demanded it to be the best of the best?
A. He did.
Q. Okay. And let's talk a little bit how you -- you
told the jury earlier that Mr. Stanford asked you to go to
Mexia, Texas -- and I've always pronounced it Mexia, I've
heard Mexia, but I mean, I'm from here --
A. I understand it's Mexia.
Q. I think it is Mexia. But whatever.
Did you go to Mexia?
A. I did.
Q. And about how long had you been working for him when
you went there?
A. That was before I ever started. That was the
initial -- the second interview.
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Cross-Knoche/By Mr. Scardino
Johnny C. Sanchez, RMR, CRR - [email protected]
2202
Q. Okay. So there was a reason why he asked you to go
there during the interviewing process, wasn't it?
A. Yes.
Q. And what was that reason?
A. Well, these three gentlemen were the board of
directors.
Q. He wanted you to meet the board of directors?
A. Yes.
Q. Before he hired you?
A. Yes.
Q. Okay. And how about the other fellow that was being
interviewed? Did he ask him to go also to Mexia?
A. He must have. I was not there at the same time, but
he -- I'm sure he did.
Q. And did you go meet these guys?
A. Yes.
Q. And tell us who they were again?
A. James Stanford.
Q. Let's stop there. Who was James Stanford?
A. Allen Stanford's father.
Q. And what kind of business was Mr. Stanford in; do you
know?
A. He said he had been mayor of Mexia for many years,
and he was also in the insurance business.
Q. Did he talk about his father at all?
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Cross-Knoche/By Mr. Scardino
Johnny C. Sanchez, RMR, CRR - [email protected]
2203
A. Lotus Stanford.
Q. And what did he tell you about his father?
A. He just said he was --
MR. COSTA: Object to hearsay, Your Honor.
THE COURT: Overruled.
By the way, sometimes things can be
technically hearsay, something said, you know, by a third
party or out of the hearing of anyone here for the truth of
what was said. The judge in federal court has some
flexibility that even though technically it might be to
allow it in. I'm just electing to do so here.
Go on.
BY MR. SCARDINO:
Q. You can answer. What did he tell you about his
father, Lotus?
A. I don't recall him saying anything specific about
what business. He was a successful person, but I don't
know what -- how he --
Q. Don't know what kind of business it was?
A. No, I don't.
Q. Don't know if it had any financial services attached
to it at all?
A. I suspect it did, but, I mean, I don't know
specifically what type of financial services.
Q. Okay. And who else on the board did you meet?
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Cross-Knoche/By Mr. Scardino
Johnny C. Sanchez, RMR, CRR - [email protected]
2204
A. Bill Goswick.
Q. Let's talk about him for a minute. You met him?
A. Re.
Q. Did you learn something about him?
A. He was a car dealer. He owned a car dealership in
Mexia.
Q. Anything else?
A. Not that I recall.
Q. And who else was on the board that you met?
A. Don Caldwell.
Q. Tell me who he was and what he did.
A. They called him -- he was a judge. I do not know a
judge in what court, but he was a judge.
Q. And so he was a lawyer?
A. Must have been lawyer, yes.
Q. And did you talk to him and find out anything about
his background in business or finance?
A. No.
Q. Wasn't there a British barrister also on the board?
A. In later years.
Q. Did you get to meet that person?
A. That was Kenneth Allen. In later years I met him,
yes.
Q. So the board consisted of Mr. Stanford, Allen
Stanford's father, a gentleman who was in business in a
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Cross-Knoche/By Mr. Scardino
Johnny C. Sanchez, RMR, CRR - [email protected]
2205
car dealership, a judge and a lawyer, and a British
barrister or a lawyer consisted of the board of directors?
A. That's correct.
Q. Was there anything, I think the word's been used,
untoward about any of that that you saw?
A. No.
Q. So you didn't just reel away and go, this doesn't
smell right to me. After you went to Mexia, it was
something that you said, okay, let's go with this?
A. That's correct.
Q. And you did?
A. Yes.
Q. Okay. When you were in the island of Antigua
working, did you ever have an opportunity to work with
Mr. Stanford on how he acquired some of the properties?
A. Yes. He acquired almost everything from the
government.
Q. From the government of Antigua?
A. From the government of Antigua.
Q. And that would have required him to do some
negotiating with the government; right?
A. Yes.
Q. And were you with him when he was doing that?
A. Some of the times.
Q. Mr. Knoche, when -- I'll find this in a minute.
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Cross-Knoche/By Mr. Scardino
Johnny C. Sanchez, RMR, CRR - [email protected]
2206
Did you find when you were dealing -- when
you were working with Mr. Stanford and he was dealing with
the government in trying to acquire these properties, was
there anything about that process that concerns you or
made you say, hey, I need to quit this business and leave
the island?
A. No, these dealings with the government were very
normal.
Q. And so, you would say they were arm's length
transactions?
A. They were arm's length transactions.
Q. And during that process, did it require him to
purchase some lands?
A. Yes.
Q. Did it require him to lease some lands?
A. Yes.
Q. Did it require him to get some sort of variances to
do what he wanted to do from the regulations?
A. There were some building permit issues, if that's
what you're speaking of --
Q. Right.
A. -- as far as variances. Yes, there were building
permit issues.
Q. And so, did he negotiate that or did you negotiate
that or how did that process work?
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Cross-Knoche/By Mr. Scardino
Johnny C. Sanchez, RMR, CRR - [email protected]
2207
A. The land sales and the land leases, he would have
been the primary one. He asked me to do certain things in
conjunction with it.
MR. SCARDINO: Your Honor, at this time I'd
offer Defense Exhibit Number 6-1. I provided the
government with a copy.
THE COURT: Any objection?
(Attorneys conferring.)
THE COURT: While they're talking, any problem
going through to 6:00 o'clock today? Anybody need to take
a break? Everybody okay?
All right. Let's go.
MR. COSTA: I don't have an objection, Your
Honor. Some of these were after Mr. Knoche worked for the
company.
THE COURT: 6-1 is admitted.
MR. SCARDINO: There we go. Can you make it
any clearer than that? Go to the next page, please. There
you go. Can you go to the top of the page, please, with
the seal. And highlight that for me.
BY MR. SCARDINO:
Q. Can you see that, Mr. Knoche?
A. Yes, I can.
Q. Now, this was something that happened after you were
there; wasn't it?
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Cross-Knoche/By Mr. Scardino
Johnny C. Sanchez, RMR, CRR - [email protected]
2208
A. Yes. I was gone in 2005.
Q. Okay. Well, let's move on from that.
When was it -- you were there in 2003,
weren't you?
A. I left at the end of June of 2003.
MR. SCARDINO: Okay. Let's go to the next
page, then. And at the very top of the page. If you'd
highlight that.
BY MR. SCARDINO:
Q. Can you see what that is, Mr. Knoche?
A. Yes. Executive cabinet decision in the cabinet of
Antigua and Barbuda.
MR. SCARDINO: And let's go down to the next
underlined portion.
BY MR. SCARDINO:
Q. Purchase of government lands. Do you see that?
A. Yes, I do.
Q. Would you read that for us, please.
A. "Purchases of government lands, conversion of
leaseholds to freeholds, purchase of a damaged warehouse,
the management and operation of the V.C. Bird
International Airport, airport development and
construction of a fixed base operation at the airport by
Stanford Development Company, Limited."
Q. What is a fixed base operation?
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Cross-Knoche/By Mr. Scardino
Johnny C. Sanchez, RMR, CRR - [email protected]
2209
A. That's the terminology for private hangars or private
planes land as opposed to commercial airlines.
Q. And then the next paragraph, please, starting with
"Cabinet discussed." If you would read that for us,
please.
A. "Cabinet discussed the enormous benefits brought to
the country by the airport project being developed by
Stanford Development Company, Limited. In this regard,
there are several matters pending that are essential for
the completion of the airport project. Thus, the cabinet
agrees and orders as follows."
Q. Okay. And have you had an opportunity to look
through any of these types of notes that were generated by
the Antiguan government, Mr. Knoche?
A. Yes, I'm familiar with those.
Q. Okay. So there are numerous transactions between
Allen Stanford and Antiguan government to acquire
property, raw and improved land for Mr. Stanford's
development purposes, was there not?
A. Primarily raw land. I don't recall any improved
land, but there may have been some minor improvements on
some of it.
Q. Was there a hospital that they were building?
A. They wanted to build a hospital.
Q. Yes, sir. That was the intent; right?
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Cross-Knoche/By Mr. Scardino
Johnny C. Sanchez, RMR, CRR - [email protected]
2210
A. That was the intent.
Q. How about a desalination plant. Was that a part of
it, also?
A. I don't recall being involved in a desalination
plant.
Q. Never was part of any project in that regard?
A. At the airport for the Stanford properties, we had a
waste treatment facility, but I don't recall that we had a
desalination plant.
Q. And did these projects actually come to fruition?
Were they built? The Stanford -- how about the Antiguan
Bank, was that built?
A. The Bank of Antiguan building was built.
Q. Okay. What other buildings did you build for
Mr. Stanford on that island?
A. The Stanford International Bank building.
Q. That's separate from the Bank of Antigua?
A. That's correct, it's two separate buildings.
Q. In fact, Mr. Stanford took over the Bank of Antigua,
did he not? Was a bank there?
A. He purchased the Bank of Antigua.
Q. He purchased it.
And was -- do you know if it was failing
at the time he took it over?
A. I think -- I don't know if it was specifically
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Cross-Knoche/By Mr. Scardino
Johnny C. Sanchez, RMR, CRR - [email protected]
2211
failing. It was in bad shape, I believe.
Q. Did he put some capital in it to make it work?
A. Yes, he must have. I wasn't in -- I never saw the
financial statements for Bank of Antigua, but he must
have, yes.
Q. It was still there and up and running when you left,
wasn't it?
A. Yes, it was.
Q. As far as you know, it still is, isn't it?
A. As far as I know, it still is.
Q. What else did he build there?
A. A building for Stanford Trust Company, the Sticky
Wicket Restaurant and Bar --
Q. Okay.
A. -- the cricket field. And when I left, there were
two projects under construction, the Pavilion Restaurant
was under construction and the Antigua Athletic Club was
under construction.
Q. Were these projects inexpensive projects?
A. No.
Q. Were they very expensive projects?
A. They were very expensive projects.
Q. Would you say that hundreds of millions of dollars
were spent on developing projects on the island of Antigua
by Allen Stanford?
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Cross-Knoche/By Mr. Scardino
Johnny C. Sanchez, RMR, CRR - [email protected]
2212
A. When I left, it would not have been in the hundreds
of millions, it would have been in the tens of millions,
but probably after that it became the hundreds of
millions.
Q. And that was -- why would it have become hundreds of
millions?
A. I assume they continued to build things. They
finished off the Pavilion. They built Barnacle Point.
I'm sure they built other things.
Q. Plus you can book one thing as you buy it as book
value and then later as market value as you get licenses
and promote it; right?
A. Say that question again.
Q. Well, I mean, you buy a piece of property and you put
it on your books at book value, what you paid for it, and
then later after you get licenses and promote it and
develop it and get infrastructure there, you can list it
as market price; right?
A. No, not to my knowledge. I don't think that's
correct.
Q. But at any rate, what he built there was a benefit
for the island, wasn't it?
A. Yes.
Q. It provided jobs?
A. Oh, yes.
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Cross-Knoche/By Mr. Scardino
Johnny C. Sanchez, RMR, CRR - [email protected]
2213
Q. A lot of jobs?
A. A lot of jobs.
Q. And improved the island considerably; right?
A. Yes.
Q. You said that you built something called the Sticky
Wicket. And Mr. Costa, the prosecutor, talked to you
about that a little bit.
What was the purpose of the Sticky Wicket;
do you know?
A. It was part of the big picture. It would be a place
where the clients would -- everybody. It was a fun place.
It was a sports bar type of place that featured cricket.
And cricket is the number one sport in Antigua.
Q. Is cricket a sport all around the world, isn't it?
A. Yes.
Q. I mean, in fact, it's big in England and India?
A. It is.
Q. South America?
A. It's extremely popular in some places.
Q. Did you know whether or not they had a ticket --
ticket -- cricket team -- hard to say -- a cricket team on
the island?
A. Well, there was little club teams, and they were part
of the West Indies team. The West Indies played as a
whole in the international competitions. When they played
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Cross-Knoche/By Mr. Scardino
Johnny C. Sanchez, RMR, CRR - [email protected]
2214
England, they would play as the West Indies, not as
Antigua.
Q. And they were good, weren't they?
A. Yes.
Q. In fact, they beat teams around the word, didn't
they?
A. In their early -- past decades, especially, they were
extremely strong.
Q. And do you understand how cricket is played?
A. I've watched the matches, but I can't say I
understand the sport that well, but it's -- I've watched
some.
Q. They don't run around bases like we do, they run up
and down --
A. They run back and forth.
Q. And a sticky wicket is a spot where -- a wicket
that's hard to hit or knock down?
A. Yes.
Q. Understand that?
A. Yes, that's correct.
Q. So Mr. Stanford built this facility, the sports
facility, called the Sticky Wicket, and he built a big
cricket field next to it. Have you seen pictures of it?
A. I was there.
Q. Did you build it?
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Cross-Knoche/By Mr. Scardino
Johnny C. Sanchez, RMR, CRR - [email protected]
2215
A. Yes.
Q. Okay. And next to it, he built a health club
facility; right?
A. Yes. That was under construction when I left.
Q. Was there -- did he change his philosophy when he was
building all this? Did he decide it shouldn't be the best
of the best?
A. No.
Q. Was the best of the best?
A. Best of the best.
Q. So did he tell you what his idea was in investing all
of these tens of millions of dollars in things like the
Sticky Wicket and the cricket field?
A. It was all -- just like he explained in that talk he
gave, that's part of the big picture. It was to make it a
world-class destination.
Q. Anything fraudulent about that, Mr. Knoche?
A. No.
Q. Do you have any problems with that? Did you run away
from the island when he told you what he was going to do
in that regard?
A. No.
Q. Did it seem like a good idea to you that a guy with
Mr. Stanford's vision and money that investing in a sports
franchise like that might pay off big later if it worked?
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Cross-Knoche/By Mr. Scardino
Johnny C. Sanchez, RMR, CRR - [email protected]
2216
A. I'm not sure I ever thought it was going to pay off
big, no.
Q. Did you ever hear of a guy named Tex Schramm?
A. Yes.
Q. He bought a sports franchise?
A. Sports franchise. Yes, it's not possible -- not
impossible. Many sports franchises achieve.
Q. Turned out pretty good, didn't it, for Mr. Schramm?
A. Yes.
Q. Okay. So would it be consistent or inconsistent with
what you knew about Mr. Stanford in the 16 years that you
worked for him that he would be the kind of guy that would
invest tens of millions of dollars in a sports franchise
that had the opportunity maybe to make him a whole a lot
of money later or maybe not make any money at all?
A. Now, the involvement in cricket was after my time. I
mean, we built a cricket field. But I just read in the
newspapers what he did as far as having a cricket team and
all that. That was after my time.
Q. You didn't know about the tournament he put on with
the prize money he put up of $20 million?
A. That was after my time.
Q. That was after.
Did you follow that, though?
A. I read about it some in the newspaper.
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Cross-Knoche/By Mr. Scardino
Johnny C. Sanchez, RMR, CRR - [email protected]
2217
Q. Okay. But you knew what he was up to when you were
reading about all that? He was promoting the sport on the
island, wasn't he?
A. Yes.
Q. And he actually changed it so that the game was
shorter, the whole idea was to -- because cricket matches
can last for days; right?
A. I didn't -- there was two types -- there was always
two types of cricket, the full -- whatever they call it --
match, and then they had some condensed ones that were --
but I think that concept was always there.
Q. So he -- when he had you build all these structures,
the whole idea was to promote cricket. And, actually,
were you there when he was negotiating with the sports
authorities for television rights and marketing rights for
the team?
A. No.
Q. You didn't have anything to do with any of that?
A. Nothing to do with any of that.
Q. You strictly were acquiring land and developing land?
A. That happened -- those things you mentioned happened
after I left, yes.
Q. And were you -- you were there when he was talking
about building the Island Club; right? He talked to you
about that?
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Cross-Knoche/By Mr. Scardino
Johnny C. Sanchez, RMR, CRR - [email protected]
2218
A. What is the Island Club?
Q. The Island Club. The development for the
billionaires to have a place to stay, a place to dock
their yachts and land their jets.
A. I never heard it called that.
Q. What did you hear it called?
A. There was a marina at Barnacle Point that he was
going to build, but I never heard of the terminology
Island Club.
Q. But you heard of the idea from Mr. Stanford that what
his idea was was to build a place for some of the richest
people in the world to come and do whatever they do?
A. A resort, yes.
Q. A resort?
A. Yes, he always had a vision of --
Q. You knew about that?
A. I knew about his vision for a world-class resort.
Q. And he was acquiring property on and near -- on the
islands near the island of Antigua to accomplish that,
wasn't he?
A. When I left, he was negotiating, as I recall, for the
Guana Island area.
Q. And did he ever acquire any of the islands for this
dream as a resort for billionaires? Did he acquire
property while you worked for him?
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Cross-Knoche/By Mr. Scardino
Johnny C. Sanchez, RMR, CRR - [email protected]
2219
A. I don't -- I'm not sure. He was close probably, but
I don't remember if he acquired Guana Island and the land
around it before I left or not.
Q. Mr. Knoche, how long did Allen Stanford talk to you
while you worked for him about this idea of a resort for
billionaires?
A. The last few years.
Q. So it wasn't just an overnight thing?
A. No.
Q. Did you have any idea of how he planned to structure
that, whether or not it was going to be something like a
club as opposed to a high-end place for people to come and
have their own home?
A. I think he was looking at all possibilities where
people would buy into a club and people were -- and
another possibility where people -- it was strictly a
resort. They would come there and pay their money and
then leave.
Q. While you were there, I mean, did he -- did you see
him spend tens of millions of dollars on architecture
plans, hiring architects to come in and help him design?
A. Certainly millions and maybe tens of millions. But I
don't think tens of millions. I would say when I was
there millions of dollars, but then --
Q. On architecture plans?
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Cross-Knoche/By Mr. Scardino
Johnny C. Sanchez, RMR, CRR - [email protected]
2220
A. On architecture plans.
Q. For the wealthy people to come?
A. Yes.
Q. So it wasn't just a dream, was it?
A. No. He was planning.
Q. Spent a lot of money on it, didn't he?
A. Yes.
Q. How about people that come in and build a
infrastructure with information technology and things of
that nature there for this club for the rich people?
A. I'm not familiar with that.
Q. You didn't know anything about that?
A. No.
Q. But because of what you did, you were familiar with
some of the work that he had done regarding engaging the
services of architects?
A. Yes.
Q. Are you familiar with the firm he hired out of
New York for that purpose?
A. Out of New York? No.
Q. What firms are you familiar with that he used in that
regard?
A. He used two from Houston, Watkins, Hamilton & Ross
and Jackson & Ryan, and then there was some firm in
Florida that I don't recall the name.
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Cross-Knoche/By Mr. Scardino
Johnny C. Sanchez, RMR, CRR - [email protected]
2221
Q. And how far did they get when you were there that you
know of in helping him design plans for this club for the
rich people?
A. I don't recall very far along at all when I was still
there.
Q. But you know he had been talking about it and working
on it for years?
A. Yes.
Q. Let me shift gears on you for a minute.
Mr. Costa, the prosecutor, showed you some
information about -- from some of the annual reports that
Mr. Stanford had produced and information of that nature.
Are you familiar with IFRS? Do you know
what that is?
A. It's international financial reporting system or
something like that.
Q. Okay. I think that's close enough.
So you are somewhat familiar with it?
A. Yes.
Q. What is it that you understand?
A. Well, the United States has its own what call GAAP,
accepted accounting principles. Great Britain has also
their GAAP. It's international. I never dealt with it.
But it's a body that oversees some of the other countries
or some of the other locations in the world besides the
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Cross-Knoche/By Mr. Scardino
Johnny C. Sanchez, RMR, CRR - [email protected]
2222
United States and Great Britain.
Q. So you're not familiar with their reporting
requirements?
A. No.
Q. So when Mr. Costa asked you questions about whether
or not Mr. Stanford reported some loans to shareholders on
financial statements, you do know that they were working
under this IFRS rules instead of GAAP rules, right,
because they were on the island of Antigua?
A. They were on the island of Antigua.
Q. So they weren't using GAAP principles, were they?
A. I would have thought they were using the British
GAAP, but it might not have been required.
Q. So you just don't know, do you?
A. I don't know.
Q. And you don't know if these reporting requirements
required Mr. Stanford to list these from loans to
shareholder in the reports or not, do you?
A. No.
Q. You don't know whether it's okay or whether it's real
bad, do you?
A. I don't know according to the standards if it's okay
or if it's real bad.
Q. And the loans to shareholder, Mr. Stanford never
consulted with you about loans -- there's Government's
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Cross-Knoche/By Mr. Scardino
Johnny C. Sanchez, RMR, CRR - [email protected]
2223
Exhibit 337 that showed a 330 million-dollar loan to
shareholder. He showed that. Do you remember that
exhibited?
A. I remember the exhibit, yes.
Q. And, I mean, you're a CPA; right?
A. Yes.
Q. So you're familiar with sometimes a way to capitalize
a company is to take funds from another company if a
person owns both companies? Say, for example, I own
Company A and B, and I've got capital in A, and I want to
transfer it to B, and I want to avoid a taxable event, one
of the ways to do that is to borrow money, for me to
borrow money from A and loan it to B; right?
A. Yes.
Q. Anything wrong with that?
A. No. I think it should be disclosed, but there's
nothing illegal about it.
Q. Under GAAP rules, you think it should be disclosed,
but you don't know anything about the international
regulations disclosing it, do you?
A. I do not.
Q. So you don't know if it's wrong or not?
A. Not according to those regulations.
Q. So if I do that, that would be a way for me to put
capital if Company B needed it, that's a way for me to
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Cross-Knoche/By Mr. Scardino
Johnny C. Sanchez, RMR, CRR - [email protected]
2224
accomplish it?
A. Yes, sir.
Q. Disclosed or not; right?
A. Yes, that's correct.
Q. Perfectly legitimate; right?
A. I don't know if it's perfectly legitimate or not. I
don't know --
Q. Well, you're a CPA?
A. I don't know under those regulations. You're telling
me that under those regulations disclosure is not
required.
Q. Let's talk about one thing at a time. I own Company
A and then B through Z. A's got plenty of capital, B
through Z needs capital. They're start up. They're --
hopefully they'll be successful, but not yet. So they
need capital.
So the way I transfer the money is I
borrow money from A, loan it to myself, and then loan it
to these companies. Now, I owe what I borrowed from A,
but B through Z owns me what I loaned to them; right?
A. Right.
Q. Nothing wrong with that, is there?
A. No.
Q. Now, you're talking about whether it should be
disclosed or how it should be disclosed?
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Cross-Knoche/By Mr. Scardino
Johnny C. Sanchez, RMR, CRR - [email protected]
2225
A. Correct.
Q. Separate issue, isn't it?
A. Yes.
Q. So if it was transferred in a way that -- if I did
something stupid like take money from A and call it a
constructive -- call it a dividend or income, I'm going to
pay taxes on that, aren't I?
A. Yes.
Q. And the way to avoid that is to call it a loan,
wouldn't it?
A. Yes.
Q. Now, are you familiar, Mr. Knoche, with the fact that
the Internal Revenue Service took issue with the way
Mr. Stanford was moving money from A, loaning it to
himself, and transferring it to B through Z, and the
Internal Revenue Service audited him from top to bottom
regarding those transactions. Do you know that?
A. He told me he had been audited many times.
Q. What he had told you, that the IRS kind of parked at
his door because he was -- one of these high net worth
guys; rights?
A. He just -- he didn't tell me the reason. He just
said he had been audited many times and was having lots of
problems with the Internal Revenue Service.
Q. So I guess is your answer you're not familiar with
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Cross-Knoche/By Mr. Scardino
Johnny C. Sanchez, RMR, CRR - [email protected]
2226
the lawsuit he had with the Internal Revenue Service?
A. I don't know details of a specific lawsuit, no.
Q. You don't know that the IRS declared that transfer,
that loan, decided it wasn't a loan but it was a
constructive dividend and wanted him to pay taxes on it?
A. No, I did not know that.
Q. He didn't talk to you about hiring a local law firm,
Chamberlain Hrdlicka, to help him fight the Internal
Revenue Service on that characterization of that transfer
of money?
A. No.
Q. You don't know anything about that?
A. No.
Q. And you're a CPA?
A. No.
Q. He didn't --
A. Yes, I'm a CPA, yes.
Q. Yeah.
He didn't feel like he needed to consult
with you or get your advice about how to deal with that
problem, did he?
A. No.
Q. Even though it created a huge tax liability for him?
A. No.
Q. No. Okay.
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Cross-Knoche/By Mr. Scardino
Johnny C. Sanchez, RMR, CRR - [email protected]
2227
MR. SCARDINO: Can I have just a moment, Your
Honor?
THE COURT: Yes, sir.
BY MR. SCARDINO:
Q. In fact, Mr. Knoche, when Mr. Costa asked you
questions on direct examination, you told him that
Mr. Stanford actually told you that he had loans from the
bank; right?
A. No.
Q. Did not?
A. No.
Q. Did I write that down wrong? Mr. Stanford didn't
tell you he had loans from the bank?
A. No, he did not tell me he had loans from the bank.
MR. FAZEL: One moment, Your Honor. I'm sorry.
THE COURT: Works both ways.
MR. SCARDINO: Can we have Government's
Exhibit 115, please.
THE COURT: What's the number?
MR. SCARDINO: 115, Your Honor?
THE COURT: Has it been identified yet?
MR. SCARDINO: It's in evidence. The
government's identified it.
THE COURT: Has it been identified at any time?
MR. COSTA: Yes.
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Cross-Knoche/By Mr. Scardino
Johnny C. Sanchez, RMR, CRR - [email protected]
2228
THE COURT: It must have been on the clock
before I started making notes. 115.
BY MR. SCARDINO:
Q. Mr. Knoche, I believe you testified on direct
examination that you had actually seen this exhibit, the
annual Stanford annual report?
A. I know what you're speaking of now. He showed me two
financial statements, one back in the '90s that showed
there was like a 13 million-dollar loan to the
shareholder, and then he showed me the 2002 financials
that showed there was no loans.
Q. Okay.
THE COURT: Just for the record, I'm looking
down here, the first notation I have when I started doing
this is 116 through 120. So 115 had been identified prior
to that group coming in?
MR. COSTA: The very first witness.
THE COURT: Okay. That listing I don't have up
here.
BY MR. SCARDINO:
Q. Mr. Knoche, you did testify on direct examination
that you had read the -- this annual report; correct?
A. I was shown the one from the 1990s that showed there
was a debt of about $13 million.
Q. Mr. Costa asked you if you had reviewed -- was it the
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Cross-Knoche/By Mr. Scardino
Johnny C. Sanchez, RMR, CRR - [email protected]
2229
1990 annual report?
A. The early years, 1990, I would -- very early years,
'87, '88, '89, '90, I'm sure I looked at all of those
financial statements. Mr. Stanford asked us all to. The
later years, I would not have read those unless I was
shown it in court today.
Q. Well, I believe Mr. Costa did show you Stanford's
financial -- the annual report for 2002 and asked you if
it showed any loans that were disclosed.
A. And I looked at it right now --
Q. Yes, sir.
A. -- and I did not see any loans disclosed.
Q. And let me bring your attention to a page on that
report that you said you have reviewed.
A. Well, I've reviewed it for about five minutes here in
court.
Q. Review it for another five.
A. Okay. If you can show me where.
MR. COSTA: Object. The question was the $168
loan to Mr. Stanford that was disclosed in that annual
report.
MR. SCARDINO: Actually, I'm going somewhere
completely different with this. If I can just get to the
exhibit. **
THE COURT: All right.
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Cross-Knoche/By Mr. Scardino
Johnny C. Sanchez, RMR, CRR - [email protected]
2230
MR. SCARDINO: Would you bring up, please,
Government's Exhibit 115, Page 59, and down to the Basis of
Opinion paragraph right there.
BY MR. SCARDINO:
Q. Can you see that, Mr. Knoche?
A. Yes.
Q. Can you read that first sentence?
A. "We conducted our audit in accordance with
international auditing standards."
Q. That's not GAAP, is it?
A. That's not GAAP.
Q. So they're saying it right there in that annual
report of how they conduct their audits; right?
A. Yes.
Q. Any question in your mind now about the standards
that are applied?
A. It says they conducted them in accordance with
international auditing standards.
Q. I did leave out some things. I'm sorry, Mr. Knoche.
You talked about -- Mr. Costa asked you about whether or
not Mr. Stanford had any offices or connections in Geneva,
Switzerland?
A. Yes.
Q. And I think you said that he told you he didn't have
anything there except he had contacts there?
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Cross-Knoche/By Mr. Scardino
Johnny C. Sanchez, RMR, CRR - [email protected]
2231
A. He said that there was no office to photograph when
the question came up about why did the other offices have
photographs, and he said there was nothing -- there was
not an appropriate -- or not an office to photograph.
Q. So you don't know whether or not he had somebody
there, a manager there or somebody doing research there
for him or somebody investing money there for him or not?
A. I do not.
MR. COSTA: Clarification on the timeframe.
THE COURT: Okay. Timeframe, please.
BY MR. SCARDINO:
Q. Well, when -- the timeframe would have been when you
were aware of it, when you were there working with
Mr. Stanford?
THE COURT: Is that correct?
THE WITNESS: Yes.
THE COURT: Okay. Thank you.
BY MR. SCARDINO:
Q. So again, you were asked a question about something
you really didn't know anything about; right?
A. About whether there was an office in Geneva,
Switzerland? No.
Q. Well, whether you know anything about Mr. Stanford's
business in Geneva, Switzerland or in South America or
anywhere else?
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Cross-Knoche/By Mr. Scardino
Johnny C. Sanchez, RMR, CRR - [email protected]
2232
A. I know nothing of Geneva, Switzerland. I was at
the -- I helped with the South American offices, several
of those. I know nothing about Geneva, Switzerland.
MR. SCARDINO: If I can have just one minute,
Your Honor, and then I'm finished.
BY MR. SCARDINO:
Q. When Mr. Davis came on board, did you monitor his
activities at all?
A. No.
Q. You didn't have anything to do with what Mr. Davis
did, did you?
A. Nothing.
Q. I mean, you don't know how far his power extended or
his influence extended through Stanford's empire, did you?
A. I do not.
Q. You did know that Mr. Stanford owned 100 percent of
everything, though; right?
A. That's my understanding.
Q. Okay. So you don't -- after you left, you have no
idea what kind of control, if any, Mr. Davis might have
been able to influence over Mr. Stanford's empire, do you?
A. I have no idea.
Q. Did you ever have any interaction with anybody in
Mr. Stanford's organization, particularly Stanford
International Bank? Did you have any interaction with the
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Redirect-Knoche/By Mr. Costa
Johnny C. Sanchez, RMR, CRR - [email protected]
2233
people that worked in the bank or operated the bank?
A. I knew some of the people. As we were building the
bank facility, we talked to them about their space needs
and things like that.
Q. I mean, did you ever have any interaction with people
that sold any of the financial products?
A. Just conversationally. I mean, that's all.
Q. But you never sold any financial products?
A. I never sold any financial -- no, I never sold any
financial products.
Q. And you were never consulted by Mr. Stanford or
anybody else about how to run his business, how to market
his business, how for promote his business, were you?
A. I was not.
MR. SCARDINO: Pass the witness.
REDIRECT EXAMINATION
BY MR. COSTA:
Q. Mr. Knoche, do you remember at the beginning of your
cross-examination Mr. Scardino asked you about your prior
interviews with the FBI?
A. Yes.
Q. And he said the first interview, wasn't it true that
you said that Mr. Stanford wasn't all that hands-on with
you and the other individual who were running Guardian,
the real estate partnerships, at the beginning?
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Redirect-Knoche/By Mr. Costa
Johnny C. Sanchez, RMR, CRR - [email protected]
2234
A. Yes.
Q. Do you remember that?
A. Yes.
Q. And you said that's true with respect to what you
were doing at the earlier years; correct?
A. Yes.
Q. What was Mr. Stanford focused on and hands-on with
respect to in those early years?
A. The bank.
Q. And that continued throughout the time you left in
2003, from what you saw?
A. Yes.
Q. Mr. Scardino asked you a number of questions about
the developments down in Antigua, the airport development?
A. Yes.
Q. Do you recall those?
And he said Mr. Stanford wanted them to be
the best in the world?
A. Yes.
Q. Did Mr. Stanford ever tell you that these
best-in-the-world buildings were being funded by the CD
holders' deposits?
A. No.
Q. What did Mr. Stanford say on that video about the
profitability of these developments in Antigua?
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Redirect-Knoche/By Mr. Costa
Johnny C. Sanchez, RMR, CRR - [email protected]
2235
A. He used the words, "I'm developing, I'm paying for
things that are -- would not otherwise be financially
feasible."
Q. Makes no economic sense?
A. Makes no economic sense.
Q. And from what you've seen in the promotional
materials, what you understood hearing from Mr. Stanford,
were the CD depositors ever told that their money was
going to Antiguan real estate?
A. No.
Q. Mr. Scardino said, Did you ever see anything that you
thought was fraudulent when you worked at the development
company?
Do you remember that?
A. That's correct.
Q. If the CD depositors' money was going to fund the
development corporation and all these Antiguan real estate
deals, would that have been a problem for you?
A. Yes, it would have been a problem.
Q. Why?
A. Because the depositors of the bank were not being
told of that.
Q. Were you a depositor of the bank?
A. No.
Q. You never bought a CD?
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Redirect-Knoche/By Mr. Costa
Johnny C. Sanchez, RMR, CRR - [email protected]
2236
A. No.
Q. Mr. Scardino asked you -- I think when we were
looking at the airport pavilion, he said that was
constructed; right?
A. The --
Q. The airport pavilion?
A. -- airport hangar.
Q. The hangar was built?
A. Yes, it was constructed.
Q. The Pavilion was the restaurant?
A. The Pavilion was the restaurant. That's right.
Q. What did Mr. Stanford say about the Pavilion, the
restaurant? What was its purpose?
A. It was going to be a super high-end restaurant, and
very expensive. I always pictured it was going to be
predominately for the clients of the bank, so they would
have a world class experience there.
Q. Was there a big market in Antigua for a high-end
restaurant like that?
A. No. There would have been a tiny number of people in
Antigua that could afford to eat there.
Q. Was there a big market in Antigua for these types of
high-quality business offices and other buildings?
A. No.
Q. And he asked you if the airport hangar was built, and
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Redirect-Knoche/By Mr. Costa
Johnny C. Sanchez, RMR, CRR - [email protected]
2237
you said it was; right?
A. Yes.
Q. He asked about bricks being laid?
A. (Answered affirmatively).
Q. Was a brick ever laid as far as you know on the super
fancy resort for billionaires?
A. Not while I was there.
Q. And when Mr. Stanford -- he asked you a number of
questions about Mr. Stanford talking for years about this
dream for the super fancy resort.
Did he ever say that was going to be
funded with CD depositors' money?
A. No.
Q. And would that be consistent with what the bank said
it did with the CD depositors' money?
A. Well, if it was used, that would not be consistent.
Q. Would putting the money into a super fancy, high-end
resort be what you consider a conservative, low-risk,
liquid investment?
A. No.
Q. Mr. Scardino talked about the number of jobs in
Antigua and things like that.
A. Yes.
Q. Do you recall that?
A. Yes.
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Redirect-Knoche/By Mr. Costa
Johnny C. Sanchez, RMR, CRR - [email protected]
2238
Q. Did Mr. Stanford, as far as you know, ever tell the
CD depositors that their money was going towards economic
development in Antigua?
A. No.
Q. Mr. Scardino towards the end asked you about
accounting standards.
Do you recall that?
A. Yes.
Q. And he asked you about this IFRS?
A. Yes.
Q. Your entire time working at Stanford, were you ever
told that IFRS, international accounting standards,
financial reporting standards, were these standards that
were being used?
A. I don't recall ever being told that, no.
Q. And Stanford Development Corporation had financial
statements; correct?
A. Yes. And I just do not recall what the audit
report -- how it was worded. I do not recall if it was
under British GAAP or if it was under this intentionally.
I know we got a clean opinion, but I don't know what
standards.
Q. And he asked you about related-party disclosures; do
you recall that?
A. Yes.
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Redirect-Knoche/By Mr. Costa
Johnny C. Sanchez, RMR, CRR - [email protected]
2239
Q. Now, regardless of whether loans should be disclosed,
is putting money into Antiguan real estate consistent with
what the bank said it was doing with its money?
A. No.
Q. And we saw those annual reports with stocks and bonds
and specified dollar amounts for those; correct?
A. Yes.
Q. And none of those that you've seen ever say Antiguan
real estate?
A. I never saw Antiguan real estate listed.
Q. Now, on this issue of related-party disclosures, did
I show you a few days ago an international accounting
standard concerning related-party disclosures?
A. Yes, you did.
Q. I'm going to hand it to you now.
Is that what you saw the other day?
A. Yes.
Q. And it's from this IFRS that Mr. Scardino asked
about?
A. That's correct. International Financial Reporting
Standards.
Q. And the entire subject of that accounting standard is
related-party disclosures?
A. Related-party disclosures, yes.
MR. SCARDINO: Do we have the year?
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Redirect-Knoche/By Mr. Costa
Johnny C. Sanchez, RMR, CRR - [email protected]
2240
THE COURT: While they're looking, Mr. Costa,
the number of that is, Mr. Costa?
MR. COSTA: I'm sorry. I'm not going to offer
it, Your Honor.
THE COURT: Okay.
MR. COSTA: There's no exhibit number. Is that
the question?
THE COURT: No, you didn't hear the question.
MR. COSTA: You asked what number it was.
No? Did I miss it?
THE COURT: No, you didn't.
You may continue.
BY MR. COSTA:
Q. In addition to related-party disclosures, are you
familiar with an accounting concept called "materiality"?
A. Yes.
Q. What does that mean, "materiality"?
A. It means that the transaction --
MR. SCARDINO: Object. That's beyond the scope
of cross.
MR. COSTA: He asked about international
accounting standards repeatedly and related-party
disclosures, but we can't do the same?
THE COURT: Overruled. Give both sides
flexibility on the first go-round, which I've done on the
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Redirect-Knoche/By Mr. Costa
Johnny C. Sanchez, RMR, CRR - [email protected]
2241
first go-round.
This is his rebuttal. And then we have
recross, if we have it. Go on.
BY MR. COSTA:
Q. What does the concept of "materiality" mean?
A. If a transaction is being reviewed, it would depend
on the dollar amount of it. A ten-dollar transaction
would not be material. A million-dollar transaction,
probably in most cases, would be material.
Q. That loan we saw to Mr. Stanford -- one was
$168 million; in 2003, it was $330 million -- are those
material amounts?
A. In my opinion, certainly they're material.
Q. Is it close to the line?
A. I would not think so. I think they're easily
material.
Q. And what does accounting standard of materiality --
is that a more general principle than particular
accounting standards on things like related-party
disclosures?
A. Yes. It would just apply to almost any issue. He'd
just look at whether it was material in amount as to
whether it would be delved into or not.
Q. And material -- someone -- a CD depositor, is that
the individual reading the bank's annual reports who would
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Redirect-Knoche/By Mr. Costa
Johnny C. Sanchez, RMR, CRR - [email protected]
2242
want to know -- would materiality be judged from their
perspective?
A. Yes.
Q. And if you were a CD depositor, would you want to
know if hundreds of millions of dollars had gone to the
sole shareholder, Mr. Allen Stanford?
A. Yes, I would.
Q. Mr. Scardino asked you about the real estate deals.
You said they were all profitable.
Do you remember that?
A. Yes.
Q. And you said most of them were moderately profitable?
A. Yes.
Q. There was one that was a good -- was highly
profitable?
A. That's correct.
Q. What about, though, these developments in Antigua?
Were they sold for a profit?
A. No.
Q. Was that even the goal?
A. Only Cedar Valley Springs had an anticipation of
making some money.
Q. But the airport hangar, was that --
A. No.
Q. -- the idea was to make it profit on that?
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Redirect-Knoche/By Mr. Costa
Johnny C. Sanchez, RMR, CRR - [email protected]
2243
A. No. They were -- they were just built to be used by
the group of companies.
Q. The Sticky Wicket?
A. It had a chance of breaking even maybe.
Q. And Mr. Stanford on the video said this would make no
economic sense; is that right?
A. Yes.
MR. COSTA: Just one minute, Your Honor,
please.
BY MR. COSTA:
Q. Mr. Scardino asked you whether it was your business
where the funding came from --
A. Yes.
Q. -- from these various projects.
Do you recall that?
A. Yes.
Q. Would CD depositors want to know what their money was
being spent on?
A. In my opinion, they would definitely want to know
what CD money was being spent on.
Q. And regardless of whether you were entitled to know,
when Mr. Stanford was asked where the money was coming
from for all these developments down in Antigua, what did
he say?
A. Personal funds. Personal resources.
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Recross-Knoche/By Mr. Scardino
Johnny C. Sanchez, RMR, CRR - [email protected]
2244
MR. COSTA: Pass the witness, Your Honor.
MR. SCARDINO: Just a few questions.
RECROSS EXAMINATION
BY MR. SCARDINO:
Q. Mr. Costa asked you about certificates of deposits?
A. Yes.
Q. You know what those are, don't you?
A. Yes, I do.
Q. And that's when somebody goes to the bank and gives
the bank a sum of money, an agreement that the bank will
pay them back a percentage at a fixed time later; right?
A. They'll pay them back the principal plus interest.
Q. Traditionally, they're sold in 30-, 60-, 90-day,
one-year increments, five-year increments; right?
A. Yes.
Q. And they're not paying much right now, are they?
A. No, paying very low right now.
Q. Very little right now.
And when you -- the CD, when you purchase
it, is that the type of instrument where the person that
actually buys the CD, can they -- can they demand where
the bank invest that money?
A. No.
Q. They can't, can they?
A. No.
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Recross-Knoche/By Mr. Scardino
Johnny C. Sanchez, RMR, CRR - [email protected]
2245
Q. They don't have anything to say about how the bank
invests that money, do they?
A. They cannot make the bank do something, no.
Q. They cannot. And the bank -- the bank does this
because the bank makes money on that money, don't they?
A. Yes.
Q. And they deposit and invest it in various other
things to make money, don't they?
A. That's correct.
Q. And they invest it in stocks; right?
A. Yes.
Q. Bonds, notes, and sometimes real estate to make
money; right?
A. That's correct.
Q. Some make the bank money quicker. Some, it takes the
bank awhile for the bank to make money, doesn't it?
A. Yes.
Q. And sometimes the bank makes stupid decisions and
they go broke, don't they?
A. Yes.
Q. Banks like Bank of America?
MR. COSTA: Your Honor, I object.
MR. SCARDINO: Withdrawn. Withdrawn.
THE COURT: Withdrawn.
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Recross-Knoche/By Mr. Scardino
Johnny C. Sanchez, RMR, CRR - [email protected]
2246
BY MR. SCARDINO:
Q. So a certificate of deposit is an instrument where
the person that owns it holds it, and the bank makes as
promise and the bank makes good on it if the bank is
successful?
A. That's correct.
Q. Okay. As opposed to where if you bought stock in the
bank, now you have something to say how the bank invests
that money; right?
A. Right. If you buy stock, you're a partial owner.
Q. Your own part of the bank.
So that distinguishes between the two;
right?
A. Yes.
Q. Okay. And what Mr. Costa was asking you about was a
CD that Stanford International Bank, Limited was selling.
And in their annual report, they do tell
people how they're investing money in some fashion, don't
they?
I mean, he just asked you about it,
Government's Exhibit 2002; right?
A. Right.
Q. I mean, I'm sorry, Government's Exhibit 115, the 2002
annual report.
Stanford didn't have to do that, did he?
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Recross-Knoche/By Mr. Scardino
Johnny C. Sanchez, RMR, CRR - [email protected]
2247
A. I don't know the specific requirement if he had to or
not.
Q. Well, you just told the jury that, if a person buys a
CD, they got nothing to say about how the bank invests the
money, do they?
A. They have nothing to say about it. They would be
interested in knowing how the money was invested, but they
have no -- they'd have no rights. They can't tell the
bank what to do with it.
Q. Right.
MR. SCARDINO: Would you please bring up
Government's 115 again and go to Page 50.
All right. Would you highlight the
investments and listed securities. Down one more. Right
there.
BY MR. SCARDINO:
Q. Would you look at that, Mr. Knoche. It says
"Investments and listed securities"; right?
A. Yes.
Q. Read the rest of it for us.
A. Equities, $720 million. Treasury bonds, notes,
corporate bonds, $852 million.
Q. Treasury bonds; right? What's that?
A. That's a debt of the government -- of governments,
usually.
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Recross-Knoche/By Mr. Scardino
Johnny C. Sanchez, RMR, CRR - [email protected]
2248
Q. All right. And what's notes?
A. Notes is a debt from somebody. It doesn't define
from whom.
Q. A loan?
A. A loan.
Q. A loan.
So in the 2002 annual report, they do list
that part of what their investment is are in loans; right?
A. The word "notes," yes.
Q. Notes, a loan to somebody; right? They've invested.
Sometimes that's a good investment, isn't it?
A. Could be.
Q. Corporate America does it all the time, don't they?
A. Corporate America borrows money all the time.
Q. All the time. Okay. So they list -- they do list
that in the 2002 annual report, don't they?
A. When there's a caption that says "notes," yes.
Q. It doesn't go into detail of what it is or what it's
to, but --
A. No.
Q. -- it does -- it does list that part of what they're
investing in is -- are in notes; right?
A. That's correct.
Q. Okay. Now, Mr. Costa asked you about that the people
that bought the CDs had a right to know or were somehow
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Recross-Knoche/By Mr. Scardino
Johnny C. Sanchez, RMR, CRR - [email protected]
2249
misled in where their money was being invested, and that
was a problem for you if it had been invested in either
real estate or that wasn't disclosed or loans to
shareholder that wasn't disclosed; right?
A. Correct.
Q. But you still don't know the standards, and you don't
understand the standards under which Mr. Stanford's
enterprise was being run. Mr. Costa showed you an
international financial regulatory commission standard
with no date on it; right? You don't know what year that
would have applied, do you?
A. No.
Q. And you talked about how -- in your opinion, whether
the Sticky Wicket was a profitable enterprise, and you
told Mr. Cost you thought it might break even?
A. We did projections before it was built, and that was
the projections that we thought -- and including a
restaurant consultant. He thought it might break even.
Q. Have you ever started a business?
A. No, I have not.
Q. Never have. I mean, have you ever helped people
start businesses in your capacity as a CPA?
A. No, not as a CPA.
Q. Well, in your business as a -- a business -- in your
CPA work, you know people start businesses, and sometimes
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Recross-Knoche/By Mr. Scardino
Johnny C. Sanchez, RMR, CRR - [email protected]
2250
they have to invest money and it doesn't operate at a
profit at first; right?
A. Sure, yes.
Q. And you know, sometimes when people start businesses
they spend money on things like airplane hangars that you
know is not going to be profitable, but you hope brings in
people that will produce a profit?
A. Yes. That's the concept, yes.
Q. So the hangar never was going to make money?
A. Right.
Q. Right?
But if it brought in all these
billionaires, it could have been very profitable; right?
A. Right.
Q. You didn't do any studies on that, though, did you?
A. No.
Q. Okay. And if the profits from the bank had been
invested in real estate and that had been -- turned out to
be fabulously successful, you wouldn't have had a problem
with that, would you?
A. Well, I don't see it would have made any difference.
I mean --
Q. It wouldn't have been any different if the proceeds
from the bank had been invested in some sports enterprise
and it became fabulously successful, you wouldn't have had
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Redirect-Knoche/By Mr. Costa
Johnny C. Sanchez, RMR, CRR - [email protected]
2251
a problem with that, would you?
A. No. I think it's the same principle. It still
wasn't -- nobody knew about it. Whether it made money or
did not make money, that wouldn't be the...
MR. SCARDINO: Thank you. Pass.
REDIRECT EXAMINATION
BY MR. COSTA:
Q. Mr. Knoche, did -- in your 17 years working for
Mr. Stanford --
A. 16.
Q. 16?
-- did he ever once tell you that since we
sell CDs, the bank can lie to the depositors?
A. No.
Q. What was the purpose of those promotional materials
and those annual reports by giving that information about
the investments being conservative, liquid, low risk?
Do you know why Mr. Stanford -- did he say
why he wanted to put out those promotional materials?
A. Well --
MR. SCARDINO: Objection, asked and answered,
not relevant, and outside the scope of the knowledge of the
witness.
THE COURT: Well, somewhere in there sustained.
He had three different reasons.
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Redirect-Knoche/By Mr. Costa
Johnny C. Sanchez, RMR, CRR - [email protected]
2252
Move on, please.
BY MR. COSTA:
Q. Do you know -- did Mr. Stanford say why he wanted put
all these promotional materials that he required you to
read?
A. Well, to market the products, everybody has to have
marketing materials.
Q. And were depositors relying on those marketing ing
materials?
A. I would think so.
Q. And you understand that when you represent -- make
representations about a product, the law requires you to
be truthful?
A. Yes.
MR. COSTA: If we can go to 115, please.
Page 50, please.
Your Honor, we need to switch back, I
think, to our --
THE COURT: To where?
MR. COSTA: Our computer --
THE COURT: Okay.
MR. COSTA: -- please.
And if we can highlight the same thing
Mr. Scardino was just showing, but also the two lines
beneath the numbers.
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Redirect-Knoche/By Mr. Costa
Johnny C. Sanchez, RMR, CRR - [email protected]
2253
BY MR. COSTA:
Q. And you talked about notes; right?
Corporate bonds and things like that can
also be called notes; correct?
A. Yes.
Q. Debt that Exxon or GM might issue is commonly called
notes as well; correct?
A. Yes, uh-huh.
Q. And beneath there, it says, "All listed securities of
or guaranteed by various governments, mature on fixed
dates up to 30 years. These investments are generally
listed on major international exchanges and are deemed
highly liquid."
Would a 330 million-dollar loan to
Mr. Stanford, do you think that was listed on a major
international exchange?
A. No.
Q. Why is listing on a public exchange relevant to
liquidity?
A. That means you have a ready market for it. You just
call your stockbroker and say, I want to sell my shares on
IBM and you sell your shares in IBM.
Q. And is that true for treasury bonds as well?
A. Yes.
MR. COSTA: Your Honor, it's very hard to
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Redirect-Knoche/By Mr. Costa
Johnny C. Sanchez, RMR, CRR - [email protected]
2254
concentrate with all the --
MR. SCARDINO: I'm sorry.
MR. COSTA: -- talking.
MR. SCARDINO: I didn't mean to talk so loud.
THE COURT: Okay. Go on.
BY MR. COSTA:
Q. Have you heard the term "marketable securities"?
A. Yes.
Q. What does that mean?
A. That's the same thing, that they -- that there's a
market for them. If you want to sell them, there's people
ready to buy them.
Q. And Mr. Scardino was saying, Well, maybe the 168
million to Mr. Stanford in 2002 was included in that one
line entry.
That concept of materiality you talked
about --
A. Yes.
Q. -- would it apply to noting that the sole shareholder
had a loan for $168 million, in your view?
A. In my opinion, yes.
MR. COSTA: Pass the witness, Your Honor.
MR. SCARDINO: Just quickly. In fact, if we
can keep the exhibit. Same exhibit, please.
THE COURT: Okay.
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Recross-Knoche/By Mr. Scardino
Johnny C. Sanchez, RMR, CRR - [email protected]
2255
MR. SCARDINO: If you would highlight that --
that very last two lines, please.
RECROSS EXAMINATION
BY MR. SCARDINO:
Q. Mr. Knoche, Mr. Costa just asked you about all listed
securities are guaranteed various government, mature on
fixed dates up to 30 years, that's referring to a
government bond, isn't it?
A. It says "All listed securities." I don't know what
it refers to.
Q. Well, I mean, that's what's being described there;
right? Government bonds?
A. No. I think there could -- no. There's treasury
notes too. No. That easily be the same thing. Treasury
notes, treasury bonds.
Q. Okay. Are you telling this jury that there's no way
you can invest in any real estate that's not liquid, not
ever, not ever an opportunity to have a real estate
investment that's --
A. No. If you know the facts, you're more than welcome
to invest in any kind of -- anything you want to, if you
know the facts.
Q. In fact, you've been involved in a lot of real estate
transactions where there was closing at the same time
where the guy made money at the closing; right? At the
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Recross-Knoche/By Mr. Scardino
Johnny C. Sanchez, RMR, CRR - [email protected]
2256
closing?
A. I -- I don't follow you.
Q. Well, somebody buys a piece of real estate and then
sells it the -- to a third party right there in the same
transaction?
A. Oh, flips it at the same time? I've not been
involved, but I know property are flipped like that, where
somebody buys and sells it the same day and makes money.
That is -- that's been done before.
Q. Happened in Houston a lot in the '80s?
A. Yes.
Q. Would that be a liquid investment then, or liquid
transaction?
A. Well, in that isolated instance, it happened to be
liquid because they already had it lined up. They would
have never bought the first property if they didn't know
they could sell it.
Q. So you can just make a blanket statement that any
investment in real estate is not liquid, can you?
A. Pretty close to it. I mean, you gave one exception.
MR. SCARDINO: Thank you. Pass.
MR. COSTA: Nothing further, Your Honor.
THE COURT: Thank you, sir. You may -- you're
excused. You may step down. You're free to leave.
THE WITNESS: Thank you, Your Honor.
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06:00:36
Johnny C. Sanchez, RMR, CRR - [email protected]
2257
THE COURT: You're excused.
All right. Let's see. First thing to do,
let's get that screen up.
All right. That ends it for today. We'll
see you tomorrow, ready to resume at 10:00 a.m. Thank you
and good afternoon.
(Recessed at 6:01 p.m.)
COURT REPORTER'S CERTIFICATE
I, Johnny C. Sanchez, certify that the foregoing is a
correct transcript from the record of proceedings in the
above-entitled matter.
/s/_________________________Johnny C. Sanchez, CRR, RMR
#
#8016 [2] - 1972:11, 1972:18
$
$100,000 [1] - 2169:23
$13 [1] - 2228:24
$168 [6] - 2151:22, 2152:1, 2153:1,
2229:19, 2241:11, 2254:20
$20 [1] - 2216:21
$300,000 [2] - 2167:24, 2168:5
$330 [2] - 2155:20, 2241:11
$60,000 [1] - 2168:10
$720 [1] - 2247:21
$720,900,000 [1] - 2149:7
$720,951.040 [1] - 2149:7
$832,336,398 [1] - 2149:9
$852 [1] - 2247:22
'
'03 [1] - 2135:6
'70s [2] - 2019:8, 2019:22
'80s [7] - 2019:9, 2019:22, 2026:16,
2133:20, 2170:20, 2170:23, 2256:10
'86 [1] - 2002:21
'87 [2] - 2170:23, 2229:3
'88 [2] - 2002:22, 2229:3
'89 [1] - 2229:3
'90 [1] - 2229:3
'90s [3] - 2133:13, 2134:3, 2228:8
'91 [1] - 2002:25
'93 [1] - 2135:6
'96 [1] - 2157:16
'97 [1] - 2157:22
'98 [4] - 2011:1, 2068:24, 2069:7,
2158:17
'99 [4] - 2011:2, 2013:6, 2013:8,
2013:13
'Loan' [1] - 2063:24
'Maker' [1] - 2063:19
'Payee' [1] - 2063:22
/
/s [1] - 2257:13
0
000015 [1] - 2024:23
0010763 [1] - 1992:15
0010774 [1] - 2086:12
0010790 [1] - 2087:10
001792 [1] - 2086:17
006 [1] - 2023:7
09-CR-342 [1] - 1971:4
1
1 [3] - 2029:7, 2062:19, 2086:14
1.1 [2] - 2058:8, 2112:1
1.5 [1] - 2149:4
1.573 [1] - 2149:5
10 [5] - 2034:21, 2046:8, 2184:5,
2184:22, 2185:17
10-1 [5] - 2037:17, 2044:18, 2044:19,
2044:21, 2052:24
10-2 [4] - 2051:15, 2051:23, 2090:2,
2090:18
100 [2] - 2192:11, 2232:16
1004 [1] - 1971:22
100s [1] - 2037:22
1018 [1] - 1972:3
103 [2] - 2111:9, 2111:11
10:00 [2] - 2035:14, 2257:5
10:19 [1] - 1971:6
11 [3] - 2080:3, 2101:15, 2137:4
11.6 [1] - 2157:20
1100 [2] - 2103:14, 2131:12
111 [3] - 2027:17, 2027:19, 2157:2
112 [1] - 2029:6
113 [1] - 2030:7
115 [12] - 2148:9, 2156:8, 2158:21,
2158:24, 2227:18, 2227:20, 2228:2,
2228:15, 2230:2, 2246:23, 2247:12,
2252:15
116 [1] - 2228:15
11:41 [1] - 2035:8
12 [1] - 2034:21
120 [1] - 2228:15
13 [6] - 2111:17, 2138:7, 2157:18,
2158:2, 2183:1, 2228:9
1350 [1] - 2143:1
1400 [1] - 1971:17
14th [4] - 2002:21, 2067:19, 2086:21,
2087:22
15 [5] - 2019:10, 2020:9, 2034:22,
2035:7, 2190:11
15,742 [1] - 2038:2
1516 [2] - 2017:18, 2017:19
1530 [5] - 2020:22, 2022:13, 2077:6,
2080:3, 2136:10
1535A [3] - 2142:23, 2143:2, 2143:3
16 [13] - 2129:17, 2129:18, 2134:20,
2148:17, 2170:1, 2176:8, 2176:16,
2180:4, 2188:19, 2191:21, 2216:11,
2251:10, 2251:11
168 [5] - 2156:19, 2156:25, 2158:3,
2159:6, 2254:13
17 [1] - 2251:8
17,000 [1] - 2037:19
18 [4] - 2030:25, 2178:6, 2178:11,
2180:25
18th [1] - 2177:6
19 [3] - 2069:12, 2118:10, 2138:24
1980 [1] - 2102:16
1982 [2] - 2001:20, 2046:13
1983 [1] - 1973:6
Johnny C. Sanchez, RMR, CRR - [email protected]
2258
1986 [3] - 2067:19, 2086:21, 2087:21
1987 [9] - 2101:23, 2101:24, 2102:17,
2107:16, 2120:12, 2123:4, 2129:13,
2130:5, 2170:22
1988 [3] - 2067:20, 2086:21, 2087:22
1990 [17] - 1988:11, 1992:24, 1993:2,
1993:4, 1993:7, 1994:16, 1996:8,
1998:8, 1998:12, 2000:19, 2002:18,
2067:2, 2068:1, 2087:12, 2111:15,
2229:1, 2229:2
1990s [4] - 2133:2, 2139:21, 2190:6,
2228:23
1991 [1] - 2003:1
1994 [5] - 1990:4, 1990:17, 2002:6,
2002:11, 2003:5
1996 [2] - 2004:9, 2004:24
1998 [18] - 2003:25, 2004:2, 2005:1,
2005:22, 2007:6, 2028:11, 2028:18,
2046:9, 2059:6, 2059:9, 2068:23,
2069:10, 2069:12, 2069:18, 2072:16,
2157:7, 2158:1, 2158:6
1999 [9] - 2003:25, 2004:2, 2005:1,
2016:2, 2029:10, 2036:18, 2040:6,
2098:8, 2098:10
19th [4] - 2002:18, 2002:25, 2067:25,
2087:11
1:00 [1] - 2079:16
1:05 [1] - 2079:21
2
2 [6] - 1972:4, 2047:18, 2067:16,
2148:13, 2155:25, 2184:21
2-14 [6] - 1988:25, 1989:11, 1989:13,
1989:18, 2067:5, 2086:9
2.1 [2] - 2059:16
2.2 [3] - 2059:17, 2059:18
2.3 [1] - 2059:19
2.6 [1] - 2111:25
20 [4] - 1990:19, 2002:6, 2139:17,
2198:6
20-minute [1] - 2155:9
2000 [8] - 2030:11, 2032:21, 2036:6,
2042:21, 2046:5, 2063:15, 2063:21,
2088:18
20005 [1] - 1971:18
2000s [1] - 2139:21
2001 [8] - 2033:12, 2042:21, 2043:10,
2055:3, 2056:24, 2057:12, 2062:13,
2064:9
2002 [21] - 2060:9, 2084:20, 2148:13,
2149:2, 2151:10, 2154:13, 2155:22,
2156:9, 2156:14, 2156:18, 2156:23,
2158:2, 2158:20, 2158:25, 2228:10,
2229:8, 2246:21, 2246:23, 2248:7,
2248:16, 2254:14
2003 [23] - 2129:16, 2131:23, 2131:25,
2136:14, 2151:11, 2154:2, 2154:3,
2154:6, 2154:19, 2154:24, 2155:2,
2155:20, 2155:22, 2162:21, 2163:1,
2166:8, 2166:10, 2167:9, 2168:23,
2208:3, 2208:5, 2234:11, 2241:11
2005 [1] - 2208:1
2007 [1] - 2027:1
2008 [2] - 2178:6, 2178:8
2009 [2] - 2060:18, 2084:21
2010 [4] - 2177:7, 2178:9, 2178:11,
2180:25
2011 [1] - 2182:3
2012 [1] - 1971:5
2062 [1] - 1973:8
2084 [1] - 1973:10
2098 [1] - 1973:12
2099 [1] - 1973:17
21 [8] - 1980:18, 1983:8, 1985:18,
1998:12, 2000:19, 2073:10, 2157:4,
2157:10
214 [1] - 1994:3
2169 [1] - 1973:19
218 [4] - 1979:25, 1983:6, 1985:18,
2073:5
22 [1] - 2187:5
2233 [1] - 1973:21
2244 [1] - 1973:23
2251 [1] - 1973:25
2255 [1] - 1974:2
23 [4] - 2046:5, 2100:10, 2139:6,
2139:7
231 [11] - 2050:23, 2050:24, 2051:2,
2051:5, 2051:6, 2065:17, 2065:20,
2066:5, 2089:19, 2090:4, 2091:3
231(e [1] - 2089:3
232 [9] - 2050:10, 2051:4, 2051:5,
2051:11, 2052:14, 2089:19, 2090:4,
2091:25, 2092:7
240,000-dollar [1] - 2168:13
25 [4] - 1977:8, 2000:4, 2000:6,
2014:21
250 [1] - 2190:14
25th [1] - 1990:17
26th [1] - 1990:17
27 [1] - 2027:19
27th [1] - 1990:17
28 [3] - 1993:3, 2046:10, 2067:2
28th [1] - 1993:2
29 [2] - 2012:14, 2036:6
2:15 [1] - 2079:20
3
3 [4] - 2016:3, 2081:17, 2118:17,
2136:22
30 [12] - 1996:8, 1998:8, 2012:14,
2029:6, 2029:20, 2038:11, 2039:3,
2040:10, 2040:12, 2244:13, 2253:11,
2255:7
30-second [2] - 2038:25
30th [4] - 1992:24, 1993:6, 1994:16,
1994:21
31 [8] - 1971:5, 2028:11, 2030:25,
2032:21, 2063:15, 2088:17, 2151:10,
2154:24
31st [4] - 1990:17, 2002:10, 2003:1,
2157:16
330 [3] - 2155:1, 2223:1, 2253:14
334 [3] - 2063:3, 2063:8, 2088:16
336 [5] - 2149:21, 2150:4, 2150:8,
2151:2, 2156:15
337 [5] - 2153:13, 2153:21, 2153:25,
2155:19, 2223:1
34 [1] - 2031:3
37 [1] - 2030:16
38 [1] - 2001:5
3:55 [1] - 2155:9
3:56 [1] - 2155:11
3rd [1] - 1971:22
4
4 [1] - 2182:21
40 [1] - 2198:11
41 [1] - 2046:9
45 [1] - 2100:10
4:15 [1] - 2155:10
5
5 [6] - 2017:18, 2046:16, 2085:12,
2085:14, 2086:14, 2114:4
50 [4] - 2014:20, 2148:23, 2247:12,
2252:16
502 [1] - 2117:9
511 [8] - 1988:4, 1989:9, 1993:3,
2066:22, 2085:25, 2086:6, 2086:15
515 [2] - 1972:11, 1972:18
516 [1] - 2017:8
519 [1] - 2114:3
522 [1] - 2118:9
59 [2] - 2159:8, 2230:2
59,500,000 [2] - 2063:23, 2063:24
59.5 [1] - 2064:4
6
6-1 [2] - 2207:5, 2207:16
60 [2] - 2168:1, 2244:13
61129 [1] - 1971:14
615 [5] - 2055:17, 2055:25, 2057:11,
2058:1, 2062:4
666 [7] - 2055:12, 2055:21, 2056:13,
2057:6, 2057:25, 2058:10, 2064:10
6:00 [1] - 2207:10
6:01 [1] - 2257:7
7
7 [1] - 1971:8
7-4 [1] - 1989:13
70 [4] - 2186:18, 2186:20, 2186:21,
2186:22
713.250.5581 [2] - 1972:12, 1972:19
77002 [4] - 1971:23, 1972:4, 1972:11,
1972:19
77208-1129 [1] - 1971:15Johnny C. Sanchez, RMR, CRR - [email protected]
2259
77279 [1] - 1972:7
79535 [1] - 1972:7
8
8 [1] - 2100:20
852 [3] - 2149:10, 2149:11
86.9 [1] - 2111:25
9
9 [8] - 2002:21, 2039:23, 2057:12,
2062:13, 2067:19, 2081:14, 2086:20,
2113:16
9.4 [1] - 2111:25
90 [2] - 2108:22, 2168:20
90-day [1] - 2244:13
90s [1] - 2026:17
9th [1] - 2087:21
A
A's [1] - 2224:13
a.m [3] - 1971:6, 2035:8, 2257:5
able [14] - 1980:20, 2014:19, 2058:3,
2058:4, 2067:12, 2085:19, 2120:19,
2124:12, 2127:6, 2140:8, 2185:7,
2186:14, 2196:12, 2232:21
above-entitled [1] - 2257:12
Abreu [2] - 2043:12, 2043:13
absolute [1] - 2000:18
absolutely [4] - 1992:1, 2020:8,
2024:6, 2200:24
accept [2] - 1997:18, 2001:17
accepted [2] - 2087:13, 2221:22
accepting [2] - 2047:16, 2053:14
access [2] - 2074:22, 2075:2
accesses [1] - 1976:15
accomplish [2] - 2218:19, 2224:1
accomplished [2] - 2015:2, 2194:22
accordance [4] - 2031:11, 2046:8,
2230:8, 2230:17
according [6] - 1994:24, 1999:2,
2115:18, 2124:25, 2222:22, 2223:23
accordingly [1] - 2053:19
account [6] - 1998:3, 2074:25, 2075:3,
2075:11
accountant [4] - 2027:4, 2085:10,
2088:5, 2100:7
accountants [2] - 2009:4, 2088:21
accounting [28] - 2009:5, 2015:23,
2028:13, 2031:17, 2032:23, 2100:5,
2100:15, 2100:19, 2100:21, 2101:7,
2101:18, 2103:5, 2125:10, 2132:13,
2132:19, 2133:1, 2161:1, 2199:1,
2221:22, 2238:6, 2238:12, 2239:12,
2239:22, 2240:15, 2240:22, 2241:17,
2241:19
accounts [1] - 1982:21
accuracy [2] - 2074:17, 2160:8
accurate [9] - 1981:8, 1981:10,
1981:16, 1982:4, 1982:5, 1982:12,
1982:18, 2074:1, 2177:20
achieve [1] - 2216:7
acquire [7] - 2186:25, 2191:8,
2192:15, 2206:3, 2209:17, 2218:23,
2218:24
acquired [5] - 2187:25, 2188:1,
2205:15, 2205:16, 2219:2
acquiring [3] - 2190:21, 2217:20,
2218:18
acquisitions [1] - 2127:4
acres [2] - 2139:17, 2192:17
acronym [2] - 2007:14, 2010:10
act [6] - 2001:20, 2049:16, 2049:18,
2050:19, 2089:11, 2090:6
Act [10] - 1975:16, 2046:10, 2048:1,
2050:17, 2052:11, 2058:25, 2089:3,
2090:5, 2090:7, 2090:21
action [1] - 2002:8
actions [1] - 2014:22
activities [1] - 2232:8
actual [2] - 2050:19, 2127:7
ad [4] - 2102:23, 2102:24, 2103:3,
2130:25
add [1] - 2166:15
addition [6] - 2003:12, 2009:14,
2047:10, 2053:12, 2054:23, 2240:14
additional [1] - 2049:3
additionally [1] - 2047:8
address [11] - 1993:16, 2011:14,
2011:20, 2027:23, 2027:25, 2029:21,
2029:25, 2030:1, 2048:3, 2057:9,
2151:21
addressed [4] - 1998:25, 1999:1,
2045:25, 2057:12
addresses [2] - 2047:24, 2048:9
adds [1] - 2141:6
adequacy [2] - 2032:6, 2032:13
adequate [2] - 2042:13, 2193:25
adequately [1] - 2031:21
adhere [1] - 1982:3
adjacent [1] - 2139:17
adjudged [1] - 2002:16
Adler [1] - 2108:8
administration [2] - 2059:4, 2100:4
administrative [1] - 2012:4
admit [5] - 2022:12, 2044:12, 2051:14,
2051:23, 2056:3
admitted [9] - 1988:24, 2002:5,
2017:7, 2035:2, 2038:6, 2044:22,
2118:10, 2153:25, 2207:16
admitting [1] - 2065:23
advertise [1] - 2173:10
advertised [2] - 2103:5, 2173:17
advertisement [1] - 2130:25
advertising [1] - 2172:19
advice [2] - 2001:14, 2226:20
advisor [1] - 2001:7
aerial [1] - 2025:6
affairs [2] - 2028:10, 2032:21
Affiliate [2] - 2118:14, 2118:23
affirmatively [1] - 1992:12
affirmatively) [3] - 2020:5, 2020:7,
2237:4
afford [1] - 2236:21
afraid [1] - 1985:7
Africa [1] - 2020:6
afternoon [6] - 2099:9, 2099:10,
2155:9, 2169:10, 2179:1, 2257:6
agency [16] - 2009:18, 2014:13,
2028:22, 2029:12, 2030:14, 2040:14,
2040:23, 2041:17, 2042:6, 2042:19,
2043:24, 2045:11, 2045:23, 2055:22,
2057:7, 2069:17
agency's [1] - 2033:21
agent [10] - 1984:12, 1984:15,
1984:16, 2008:19, 2008:23, 2008:25,
2009:1, 2009:15, 2094:2, 2182:6
agents [6] - 2177:9, 2179:2, 2179:9,
2181:1, 2181:3, 2182:10
ago [7] - 2011:6, 2036:19, 2039:14,
2072:14, 2142:10, 2177:1, 2239:12
agree [10] - 2003:5, 2008:18, 2064:2,
2068:2, 2079:13, 2079:15, 2084:3,
2113:13, 2132:23, 2178:18
agreement [2] - 2055:5, 2244:10
agreements [1] - 2054:25
agrees [1] - 2209:11
ahead [12] - 1975:6, 1989:23, 2002:19,
2002:23, 2041:16, 2056:8, 2079:24,
2097:9, 2129:14, 2147:20, 2147:22,
2151:1
AIBCI [1] - 2006:16
aim [1] - 2086:1
aircraft [2] - 2024:1, 2144:18
airline [2] - 2137:25, 2138:1
Airlines [1] - 2144:23
airlines [5] - 2146:4, 2146:6, 2146:8,
2146:24, 2209:2
airplane [3] - 2137:7, 2137:8, 2250:5
airplanes [1] - 2137:8
Airport [2] - 2063:21, 2208:22
airport [24] - 2024:8, 2024:9, 2024:10,
2024:12, 2024:14, 2024:16, 2081:22,
2139:18, 2144:18, 2144:22, 2192:17,
2197:16, 2197:18, 2208:22, 2208:23,
2209:7, 2209:10, 2210:7, 2234:14,
2236:3, 2236:6, 2236:7, 2236:25,
2242:23
Alabama [1] - 2134:22
Albert [2] - 1990:13, 1994:5
alerting [1] - 2013:15
Ali [1] - 1971:20
allegation [1] - 2016:5
allegedly [1] - 2097:5
ALLEN [1] - 1971:6
Allen [51] - 1990:9, 1992:19, 1992:23,
1993:6, 1993:12, 1993:14, 1994:12,
1994:14, 1997:13, 1997:17, 1997:18,
1998:3, 1998:6, 1998:10, 1998:16,
1998:23, 1999:2, 1999:3, 2000:9,
2000:17, 2000:19, 2001:2, 2002:14,
2009:22, 2016:10, 2054:1, 2054:4,
2063:18, 2069:23, 2071:19, 2081:22,Johnny C. Sanchez, RMR, CRR - [email protected]
2260
2102:20, 2103:12, 2105:14, 2105:21,
2105:23, 2107:3, 2107:7, 2135:21,
2150:1, 2156:7, 2157:13, 2157:17,
2204:22, 2204:24, 2209:17, 2211:25,
2219:4, 2242:6
allen [2] - 2151:20, 2202:20
allow [8] - 1981:5, 1981:9, 2001:16,
2049:21, 2078:6, 2102:10, 2203:11
allowed [7] - 1977:19, 1978:1,
1981:12, 1982:9, 2049:17, 2137:9
alludes [1] - 2000:22
almost [5] - 2079:16, 2141:3, 2164:23,
2205:16, 2241:21
Althea [2] - 2053:20, 2057:12
ALTHEA [1] - 1973:4
ambit [1] - 2079:3
amended [1] - 2046:13
amendments [3] - 2070:3, 2071:13,
2072:1
America [8] - 2004:13, 2004:14,
2213:18, 2231:24, 2245:21, 2248:13,
2248:14
AMERICA [1] - 1971:4
American [2] - 2144:22, 2232:2
amount [13] - 2064:3, 2146:4, 2152:1,
2154:24, 2157:17, 2166:12, 2183:24,
2184:1, 2184:2, 2184:7, 2184:24,
2241:7, 2241:22
amounts [4] - 1978:14, 2031:14,
2239:6, 2241:12
Andrew [1] - 1971:16
Anguilla [1] - 2018:18
annual [42] - 2027:6, 2027:8, 2027:10,
2027:11, 2028:18, 2028:20, 2030:11,
2033:4, 2033:20, 2035:2, 2074:11,
2109:17, 2109:22, 2111:14, 2125:20,
2148:12, 2148:24, 2156:9, 2156:23,
2157:7, 2157:12, 2158:1, 2158:2,
2158:6, 2158:21, 2158:25, 2159:17,
2221:11, 2228:6, 2228:22, 2229:1,
2229:8, 2229:20, 2230:12, 2239:5,
2241:25, 2246:17, 2246:24, 2248:7,
2248:16, 2251:16
answer [30] - 1981:4, 1981:23, 1987:5,
1996:25, 1997:1, 2004:15, 2037:25,
2070:24, 2079:5, 2081:1, 2081:3,
2084:2, 2089:3, 2089:6, 2091:5,
2110:14, 2114:5, 2116:2, 2116:4,
2124:15, 2124:18, 2127:13, 2127:14,
2128:18, 2129:1, 2175:11, 2175:12,
2203:14, 2225:25
answer) [1] - 2185:25
Answered [3] - 2020:5, 2020:7, 2237:4
answered [6] - 1987:6, 1988:16,
2084:6, 2102:23, 2115:11, 2251:21
answering [1] - 2181:7
answers [3] - 1980:16, 2001:14,
2183:10
anti [1] - 2070:1
anti-money [1] - 2070:1
anticipation [1] - 2242:21
Antigua [109] - 1993:1, 1993:13,
1995:24, 1996:4, 1996:9, 1996:16,
1997:5, 1997:15, 1997:16, 1998:9,
2003:9, 2004:7, 2004:10, 2005:12,
2006:10, 2011:12, 2011:22, 2013:10,
2013:17, 2014:14, 2015:6, 2017:24,
2018:3, 2018:8, 2023:15, 2023:17,
2023:18, 2023:20, 2024:5, 2024:7,
2024:13, 2024:25, 2025:1, 2025:18,
2026:10, 2028:15, 2029:12, 2032:25,
2033:5, 2034:9, 2034:11, 2040:5,
2054:24, 2063:22, 2070:1, 2074:7,
2077:18, 2090:8, 2097:17, 2129:25,
2135:10, 2135:11, 2136:4, 2136:5,
2136:8, 2136:15, 2136:16, 2137:7,
2139:16, 2141:1, 2142:8, 2144:18,
2144:19, 2146:15, 2160:24, 2161:2,
2161:18, 2165:2, 2165:15, 2166:2,
2167:13, 2188:23, 2190:1, 2190:6,
2190:12, 2190:17, 2192:1, 2192:7,
2192:8, 2192:19, 2192:22, 2193:16,
2195:14, 2195:16, 2197:15, 2205:13,
2205:18, 2205:19, 2208:12, 2210:17,
2210:19, 2210:21, 2211:4, 2211:17,
2211:24, 2213:13, 2214:2, 2218:19,
2222:9, 2222:10, 2234:14, 2234:25,
2236:18, 2236:21, 2236:22, 2237:22,
2238:3, 2242:17, 2243:23
Antiguan [28] - 1975:12, 1981:9,
1982:22, 1995:18, 1996:10, 2005:6,
2005:10, 2005:14, 2025:20, 2026:5,
2028:21, 2030:13, 2052:10, 2072:6,
2073:23, 2097:15, 2142:20, 2155:3,
2165:4, 2209:14, 2209:17, 2210:11,
2210:13, 2235:9, 2235:17, 2239:2,
2239:8, 2239:10
Antiguans [1] - 2025:2
anyhow [1] - 2151:2
anyway [1] - 2173:3
apartment [9] - 2023:12, 2121:2,
2125:25, 2133:22, 2171:12, 2171:13,
2183:23, 2186:22, 2187:2
Apartments [4] - 2121:3, 2121:6,
2121:17, 2122:7
apartments [3] - 2186:21, 2186:22,
2190:11
apologize [1] - 2096:10
appear [7] - 1993:22, 1994:19,
1995:16, 1996:6, 1998:5, 1998:15,
2068:5
APPEARANCES [1] - 1971:12
appeared [1] - 1990:16
applicant [5] - 2049:4, 2049:13,
2091:18, 2092:15, 2106:23
application [17] - 2047:22, 2047:25,
2048:1, 2048:22, 2049:7, 2050:5,
2050:6, 2051:3, 2051:12, 2052:16,
2052:18, 2058:21, 2066:12, 2092:1,
2092:4, 2092:8, 2092:19
applications [1] - 2062:25
applied [5] - 2031:21, 2117:2, 2117:5,
2230:16, 2249:11
applies [4] - 2006:19, 2050:9, 2051:11,
2052:11
apply [8] - 1986:22, 2006:16, 2017:3,
2052:15, 2060:12, 2060:15, 2241:21,
2254:19
applying [1] - 2049:8
appreciate [1] - 2147:23
approach [2] - 2181:8, 2182:14
appropriate [4] - 2031:18, 2092:14,
2095:5, 2231:4
approval [3] - 2046:6, 2046:17, 2047:5
approximate [1] - 2169:21
April [5] - 2013:5, 2013:8, 2013:13,
2040:9, 2060:17
architects [2] - 2219:21, 2220:16
architecture [3] - 2219:20, 2219:25,
2220:1
area [11] - 2004:21, 2078:5, 2082:9,
2082:10, 2082:11, 2099:16, 2102:11,
2120:9, 2139:15, 2186:19, 2218:22
areas [1] - 2069:11
argue [1] - 2054:11
argumentative [5] - 2075:5, 2076:18,
2078:3, 2078:24, 2080:21
argumentive [1] - 2075:14
arguments [1] - 2078:25
arm's [2] - 2206:9, 2206:11
Arnold [2] - 2098:24, 2099:13
ARNOLD [3] - 1973:15, 2099:4,
2099:13
arranged [2] - 2064:20, 2064:21
arrested [1] - 2179:16
arrived [2] - 2131:20, 2179:2
arriving [1] - 2195:11
articles [1] - 2002:5
Aruba [2] - 2119:5, 2164:5
aside [2] - 2036:23, 2094:8
aspect [1] - 2096:22
aspects [2] - 2097:1, 2133:16
assessment [1] - 2031:15
asset [1] - 1977:19
assets [9] - 1976:17, 1977:16,
1977:24, 1979:14, 1982:20, 2026:6,
2073:2, 2073:18, 2149:3
assist [2] - 2008:10, 2049:19
assistance [1] - 1976:5
Assistant [1] - 1971:14
assisted [2] - 1972:13, 1972:21
assists [1] - 2168:9
Associate [1] - 2039:7
assume [3] - 2059:22, 2185:4, 2212:7
assumes [3] - 2076:17, 2078:2,
2080:20
assuming [4] - 2078:13, 2123:18,
2146:19, 2152:9
assurance [1] - 2031:25
Athletic [5] - 2077:18, 2136:15,
2136:16, 2139:13, 2211:17
Atlantic [1] - 2190:5
atmosphere [3] - 2128:7, 2193:18,
2193:19
attached [3] - 2024:8, 2024:9, 2203:21
attempt [2] - 2088:11, 2088:20
attempted [2] - 2020:17, 2087:2
attend [1] - 2109:15Johnny C. Sanchez, RMR, CRR - [email protected]
2261
attended [3] - 2109:24, 2115:22,
2117:19
attention [4] - 2066:4, 2108:15,
2160:18, 2229:13
attorney [5] - 1990:10, 1991:20,
1991:22, 1992:11, 2049:20
Attorney [2] - 1971:14, 1972:3
attorneys [4] - 2022:9, 2025:25,
2142:24, 2207:8
attract [1] - 2194:25
attracted [2] - 2195:14, 2195:24
audible [1] - 2185:25
audit [7] - 2026:10, 2026:12, 2031:6,
2031:11, 2031:22, 2230:8, 2238:18
audited [5] - 2030:24, 2033:9,
2225:16, 2225:18, 2225:23
auditing [4] - 2027:2, 2031:12, 2230:9,
2230:18
auditor [5] - 2027:14, 2032:10,
2159:18, 2159:21, 2160:5
auditor's [2] - 2027:12, 2160:2
Auditors [1] - 2031:2
auditors' [1] - 2159:15
Auditors' [1] - 2030:21
audits [2] - 2027:8, 2230:13
August [6] - 1990:17, 2002:11,
2043:10, 2043:11, 2056:24, 2182:3
Austin [3] - 2101:11, 2122:20, 2171:7
Australia [1] - 2020:4
authentic [1] - 2052:7
authenticate [1] - 2090:15
authenticated [2] - 2045:3, 2052:5
author [3] - 2044:7, 2071:13, 2071:14
authored [2] - 2005:24, 2006:1
authorities [3] - 1976:2, 2016:11,
2217:15
authority [3] - 2046:8, 2046:17,
2092:20
Authority [1] - 2006:2
available [3] - 1975:25, 2033:4, 2187:9
Avenue [1] - 1971:17
average [1] - 2194:9
Aviation [3] - 2137:14, 2137:16,
2138:4
aviation [2] - 2137:20, 2137:21
avoid [4] - 2079:12, 2102:9, 2223:11,
2225:9
aware [11] - 2016:1, 2016:7, 2016:9,
2024:3, 2066:10, 2078:14, 2093:16,
2138:20, 2146:25, 2231:13
awhile [1] - 2245:16
awkward [3] - 2082:18, 2082:20,
2083:7
B
bachelor's [1] - 2100:4
background [7] - 2100:1, 2103:4,
2174:4, 2175:1, 2183:12, 2183:20,
2204:17
backwards [1] - 2040:6
bad [12] - 2001:2, 2016:16, 2016:21,
2026:18, 2073:1, 2073:19, 2101:25,
2120:14, 2191:17, 2211:1, 2222:21,
2222:23
bag [1] - 2045:18
Bahamas [1] - 2005:16
Bailey [4] - 2043:16, 2043:20, 2064:23,
2065:1
Baker [1] - 1985:4
balance [2] - 2157:20, 2188:12
balances [5] - 1978:15, 1978:25,
1979:5, 1979:22
ball [1] - 2078:25
bank [160] - 1975:12, 1976:7, 1976:10,
1976:15, 1976:16, 1977:15, 1977:21,
1978:1, 1979:7, 1979:11, 1979:15,
1981:5, 1981:19, 1981:20, 1982:2,
1993:16, 1995:22, 1995:24, 1996:9,
1997:7, 1998:19, 2005:7, 2006:16,
2016:6, 2016:14, 2025:1, 2028:11,
2029:16, 2036:8, 2047:16, 2053:15,
2057:8, 2059:2, 2062:16, 2064:9,
2066:11, 2069:22, 2072:22, 2073:17,
2073:22, 2074:20, 2074:23, 2074:25,
2075:2, 2075:11, 2078:13, 2087:12,
2087:14, 2104:13, 2104:14, 2104:17,
2107:11, 2107:17, 2107:21, 2107:22,
2108:1, 2108:2, 2108:3, 2108:4,
2108:18, 2108:20, 2108:23, 2109:25,
2110:10, 2110:19, 2111:5, 2112:3,
2113:25, 2114:1, 2114:7, 2114:18,
2114:23, 2115:20, 2117:2, 2117:5,
2118:6, 2119:2, 2119:15, 2119:24,
2120:2, 2122:10, 2123:11, 2123:15,
2123:17, 2123:24, 2124:1, 2124:9,
2124:12, 2124:24, 2124:25, 2126:6,
2126:22, 2127:6, 2129:4, 2129:19,
2129:22, 2129:24, 2132:7, 2132:16,
2132:23, 2148:18, 2148:21, 2153:2,
2153:11, 2155:22, 2157:13, 2157:16,
2158:9, 2159:18, 2160:20, 2165:13,
2165:22, 2165:24, 2168:21, 2168:25,
2169:2, 2186:6, 2192:8, 2193:17,
2197:16, 2210:20, 2227:8, 2227:13,
2227:14, 2233:1, 2233:3, 2234:9,
2235:21, 2235:23, 2236:16, 2237:14,
2239:3, 2244:9, 2244:10, 2244:22,
2245:1, 2245:3, 2245:4, 2245:5,
2245:15, 2245:16, 2245:18, 2246:3,
2246:4, 2246:8, 2246:11, 2247:4,
2247:9, 2250:17, 2250:24, 2251:13
Bank [70] - 1976:12, 1976:13, 1976:17,
1977:17, 1978:16, 1979:14, 1979:21,
1980:3, 1980:15, 1994:13, 1994:15,
1995:1, 1995:4, 1995:12, 1995:22,
1995:23, 1995:25, 1996:21, 2002:17,
2002:21, 2016:2, 2016:10, 2023:11,
2024:25, 2025:1, 2026:10, 2043:6,
2043:23, 2046:1, 2046:21, 2056:19,
2057:3, 2063:20, 2067:19, 2067:23,
2074:5, 2086:20, 2087:20, 2097:16,
2098:7, 2104:15, 2109:3, 2111:4,
2111:14, 2114:8, 2139:14, 2141:16,
2148:12, 2149:18, 2151:21, 2154:25,
2156:24, 2157:7, 2162:5, 2169:5,
2169:6, 2192:7, 2192:8, 2195:12,
2195:16, 2210:12, 2210:13, 2210:16,
2210:17, 2210:19, 2210:21, 2211:4,
2232:25, 2245:21, 2246:16
Bank's [1] - 1978:23
bank's [26] - 1977:25, 1978:13,
1980:16, 1982:20, 1992:8, 1992:25,
1993:9, 1993:13, 1998:9, 2031:18,
2073:1, 2086:13, 2109:17, 2109:22,
2112:15, 2113:11, 2115:1, 2115:9,
2121:10, 2121:21, 2129:11, 2149:2,
2159:21, 2165:18, 2165:21, 2241:25
bank-rolled [1] - 2069:22
banker [4] - 2116:20, 2160:10,
2160:11, 2160:14
bankers [7] - 2068:12, 2108:24,
2108:25, 2115:21, 2116:11, 2117:17,
2160:17
banking [20] - 1976:9, 1977:7,
1981:22, 1982:10, 1982:17, 2001:7,
2004:3, 2005:11, 2005:17, 2006:11,
2006:13, 2006:23, 2011:11, 2065:11,
2065:12, 2069:25, 2086:8, 2087:21,
2087:22, 2130:3
bankruptcy [5] - 2048:23, 2048:24,
2051:9, 2066:14, 2091:6
banks [17] - 1979:13, 1979:16,
2004:18, 2013:23, 2014:19, 2014:20,
2015:19, 2015:22, 2053:6, 2054:23,
2060:4, 2061:1, 2061:2, 2094:3,
2095:14, 2245:21
banks's [2] - 2015:24, 2125:20
bar [1] - 2213:12
Bar [2] - 2137:1, 2211:13
Barbuda [5] - 2013:17, 2017:24,
2028:15, 2032:25, 2208:12
Barnacle [5] - 2138:11, 2138:13,
2196:25, 2212:8, 2218:7
barrister [2] - 2204:19, 2205:2
barristers [1] - 1999:25
base [3] - 2128:21, 2208:23, 2208:25
baseball [5] - 2019:4, 2019:5, 2019:6,
2019:7, 2190:25
based [5] - 2031:6, 2067:22, 2081:2,
2110:17
bases [1] - 2214:13
Basis [1] - 2230:2
basis [8] - 1978:10, 2031:10, 2031:13,
2070:11, 2078:16, 2078:18, 2114:14,
2152:22
Bates [3] - 1992:15, 2023:7, 2024:23
BDO [1] - 2009:5
beat [1] - 2214:5
beautiful [1] - 2102:6
became [12] - 2019:12, 2039:8,
2039:20, 2043:20, 2065:4, 2123:9,
2133:7, 2134:10, 2134:12, 2135:23,
2212:3, 2250:25
become [4] - 2040:23, 2040:25,
2123:4, 2212:5
becoming [1] - 1996:4
BEFORE [1] - 1971:10Johnny C. Sanchez, RMR, CRR - [email protected]
2262
began [2] - 2015:25, 2034:21
begin [1] - 2134:4
beginning [5] - 2085:1, 2111:21,
2168:18, 2233:18, 2233:25
begins [1] - 2040:1
behind [7] - 2019:20, 2034:22,
2039:11, 2082:1, 2097:2, 2162:9,
2194:14
belief [3] - 2093:10, 2093:12, 2094:12
below [2] - 2151:23, 2199:14
bench [1] - 1984:6
Bend [1] - 2099:15
beneath [2] - 2252:25, 2253:9
beneficial [1] - 2046:15
benefit [2] - 2003:20, 2212:21
benefits [1] - 2209:6
Best [1] - 2193:22
best [28] - 1976:21, 2025:10, 2089:11,
2140:20, 2165:7, 2192:22, 2193:18,
2193:19, 2194:2, 2194:3, 2194:12,
2194:21, 2197:4, 2197:9, 2200:25,
2201:12, 2215:6, 2215:7, 2215:9,
2215:10, 2234:18, 2234:21
best-in-the-world [1] - 2234:21
better [13] - 1980:24, 1980:25,
2001:25, 2004:4, 2005:3, 2005:5,
2005:8, 2082:1, 2119:6, 2127:21,
2193:24
between [11] - 1976:4, 1990:8, 2055:5,
2082:9, 2082:12, 2082:13, 2084:20,
2126:6, 2183:1, 2209:16, 2246:12
beyond [5] - 2035:22, 2036:22,
2054:15, 2088:13, 2240:19
bids [1] - 2140:10
big [16] - 2000:2, 2009:4, 2009:5,
2023:15, 2097:3, 2100:18, 2100:24,
2161:1, 2213:10, 2213:16, 2214:22,
2215:15, 2215:25, 2216:2, 2236:18,
2236:22
Big [1] - 2100:20
biggest [1] - 2146:8
Bill [3] - 2105:9, 2105:16, 2105:23
bill [1] - 2204:1
billion [2] - 2149:4, 2149:5
billionaires [5] - 2218:3, 2218:24,
2219:6, 2237:6, 2250:13
bills [2] - 2101:19, 2199:3
binds [1] - 2018:23
Bird [1] - 2208:21
bit [13] - 2017:5, 2040:6, 2046:11,
2099:21, 2108:11, 2127:19, 2129:14,
2173:23, 2175:24, 2179:7, 2183:21,
2201:14, 2213:7
black [1] - 2039:20
Blackman [5] - 2046:7, 2047:2,
2047:9, 2047:11, 2047:15
blank [1] - 2038:5
blanket [1] - 2256:18
block [1] - 2029:21
blocks [1] - 2103:15
blood [1] - 2001:2
blow [2] - 2154:10, 2156:1
blown [2] - 1987:20, 2157:14
blown-up [2] - 1987:20, 2157:14
board [35] - 2007:6, 2010:23, 2010:24,
2011:23, 2012:10, 2038:11, 2038:12,
2040:10, 2040:13, 2041:14, 2041:17,
2044:23, 2060:22, 2061:4, 2061:6,
2069:6, 2069:7, 2072:19, 2101:21,
2105:2, 2105:12, 2106:7, 2130:9,
2130:12, 2131:11, 2162:24, 2185:10,
2202:5, 2202:7, 2203:25, 2204:9,
2204:19, 2204:24, 2205:2, 2232:7
Board [1] - 1997:6
boards [1] - 2047:24
boat [4] - 2138:16, 2138:20, 2138:22
boats [1] - 2138:17
body [12] - 2008:7, 2008:9, 2011:7,
2028:22, 2029:1, 2061:8, 2065:13,
2066:16, 2068:22, 2069:17, 2072:19,
2221:24
bond [1] - 2255:8
bonds [20] - 2111:6, 2111:7, 2111:25,
2113:15, 2113:23, 2125:21, 2125:22,
2126:19, 2149:8, 2149:10, 2149:11,
2239:5, 2245:12, 2247:21, 2247:22,
2247:23, 2253:3, 2253:23, 2255:12,
2255:15
bonuses [1] - 2167:24
book [6] - 2039:1, 2039:23, 2039:24,
2212:10, 2212:15
bookkeeping [1] - 2099:22
books [4] - 2160:6, 2174:9, 2174:25,
2212:15
born [2] - 2018:2, 2018:3
borrow [3] - 2223:12, 2223:13,
2224:18
borrowed [1] - 2224:19
borrows [1] - 2248:14
bothered [1] - 2175:8
bottom [19] - 1980:9, 1985:19,
1985:23, 1997:12, 2015:11, 2027:23,
2029:22, 2030:8, 2042:5, 2058:3,
2058:14, 2059:3, 2083:16, 2111:21,
2118:11, 2118:20, 2118:23, 2159:24,
2225:16
bought [5] - 2216:5, 2235:25, 2246:7,
2248:25, 2256:16
Boulevard [1] - 2063:21
bowl [1] - 2082:19
bowler [1] - 2082:21
bowlers [1] - 2082:19
Box [2] - 1971:14, 1972:7
boxes [3] - 2093:18, 2093:19, 2093:25
break [17] - 1984:5, 1989:20, 2033:13,
2034:21, 2034:24, 2077:8, 2078:7,
2151:7, 2155:7, 2155:9, 2155:18,
2156:8, 2156:12, 2159:2, 2207:11,
2249:15, 2249:18
breaking [1] - 2243:4
breaks [1] - 2164:10
brick [2] - 2196:16, 2237:5
bricks [2] - 2196:18, 2237:3
briefly [5] - 2016:14, 2084:15, 2098:1,
2099:25, 2198:24
bring [12] - 2034:8, 2034:11, 2034:14,
2035:11, 2096:19, 2096:21, 2173:1,
2186:14, 2189:21, 2229:13, 2230:1,
2247:11
bringing [1] - 2160:17
brings [2] - 2173:2, 2250:6
Britain [2] - 2221:22, 2222:1
British [7] - 2117:8, 2117:13, 2118:1,
2204:19, 2205:1, 2222:12, 2238:20
broad [2] - 2011:9, 2085:13
brochure [1] - 2118:18
brochures [1] - 2118:5
broke [2] - 2035:15, 2245:19
brought [5] - 2011:23, 2141:4,
2186:12, 2209:6, 2250:12
budget [4] - 1987:12, 2041:21,
2041:22, 2140:8
budgets [3] - 2140:1, 2140:3, 2140:7
build [23] - 2139:3, 2139:22, 2189:3,
2192:1, 2192:5, 2192:13, 2193:16,
2193:17, 2196:8, 2196:14, 2197:14,
2197:20, 2198:2, 2198:5, 2209:24,
2210:14, 2211:11, 2212:7, 2214:25,
2217:12, 2218:8, 2218:11, 2220:8
Building [2] - 2103:15, 2131:12
building [31] - 2023:8, 2023:10,
2023:15, 2023:19, 2023:20, 2023:23,
2023:24, 2024:19, 2024:21, 2024:22,
2024:24, 2024:25, 2077:24, 2120:13,
2130:17, 2131:12, 2139:14, 2145:1,
2163:4, 2163:16, 2192:7, 2195:3,
2206:19, 2206:22, 2209:23, 2210:13,
2210:16, 2211:12, 2215:6, 2217:24,
2233:2
buildings [12] - 2023:5, 2025:17,
2025:19, 2025:21, 2084:25, 2139:23,
2141:1, 2196:20, 2210:14, 2210:18,
2234:21, 2236:23
built [47] - 2085:1, 2134:11, 2134:13,
2134:16, 2134:19, 2134:20, 2135:10,
2135:11, 2137:2, 2137:11, 2137:15,
2138:10, 2140:15, 2140:16, 2143:22,
2190:23, 2190:24, 2190:25, 2191:25,
2192:6, 2196:20, 2196:22, 2196:24,
2196:25, 2197:4, 2197:8, 2197:25,
2198:3, 2198:7, 2198:10, 2210:11,
2210:12, 2210:13, 2212:8, 2212:9,
2212:21, 2213:5, 2214:21, 2214:22,
2215:2, 2216:17, 2236:8, 2236:25,
2243:1, 2249:16
Business [4] - 1975:16, 2046:10,
2050:16, 2090:7
business [56] - 1976:10, 1977:7,
1993:10, 1998:20, 2001:13, 2002:18,
2004:4, 2005:11, 2005:17, 2006:11,
2006:12, 2006:14, 2006:15, 2007:3,
2008:10, 2013:10, 2016:16, 2016:21,
2036:20, 2060:24, 2067:25, 2073:1,
2101:25, 2106:3, 2120:13, 2120:14,
2133:16, 2146:22, 2161:23, 2162:7,
2162:8, 2163:7, 2168:25, 2172:17,
2172:23, 2190:22, 2191:24, 2202:21,
2202:24, 2203:17, 2203:19, 2204:17,Johnny C. Sanchez, RMR, CRR - [email protected]
2263
2204:25, 2206:5, 2231:24, 2233:12,
2233:13, 2236:23, 2243:11, 2249:19,
2249:24
businesses [9] - 2023:6, 2042:19,
2104:12, 2108:16, 2135:24, 2193:11,
2249:22, 2249:25, 2250:4
but.. [1] - 2115:12
button [2] - 2061:24
buy [6] - 2000:3, 2212:10, 2212:14,
2219:15, 2246:10, 2254:12
buying [1] - 2134:7
buys [4] - 2244:21, 2247:3, 2256:3,
2256:8
BY [186] - 1973:6, 1973:8, 1973:10,
1973:12, 1973:17, 1973:19, 1973:21,
1973:23, 1973:25, 1974:2, 1975:9,
1977:13, 1980:13, 1980:19, 1983:17,
1984:3, 1986:5, 1987:17, 1988:3,
1990:1, 1990:7, 1991:17, 1992:4,
1992:22, 1997:3, 1998:1, 2000:8,
2001:6, 2017:17, 2017:22, 2020:16,
2023:1, 2027:24, 2028:6, 2028:19,
2029:8, 2029:23, 2030:3, 2030:10,
2030:20, 2031:9, 2031:20, 2032:4,
2032:9, 2040:3, 2045:7, 2045:21,
2046:12, 2049:24, 2050:13, 2052:9,
2054:13, 2056:10, 2056:16, 2057:23,
2058:7, 2059:25, 2062:3, 2062:11,
2063:11, 2066:2, 2066:23, 2067:11,
2070:16, 2071:3, 2071:16, 2072:10,
2073:15, 2075:8, 2075:17, 2076:5,
2076:12, 2077:1, 2077:17, 2080:1,
2080:12, 2081:5, 2081:13, 2083:6,
2084:9, 2084:18, 2085:8, 2085:23,
2086:4, 2088:15, 2089:18, 2091:2,
2092:13, 2096:7, 2097:11, 2098:3,
2099:8, 2101:1, 2102:18, 2104:5,
2105:20, 2106:6, 2110:16, 2111:1,
2111:13, 2111:23, 2113:8, 2113:24,
2114:6, 2114:21, 2115:7, 2116:8,
2116:16, 2117:11, 2117:25, 2118:12,
2118:19, 2119:23, 2121:7, 2123:21,
2124:7, 2124:19, 2124:23, 2125:14,
2128:2, 2128:16, 2135:4, 2136:12,
2136:24, 2137:5, 2138:8, 2138:18,
2138:25, 2139:8, 2143:20, 2144:6,
2144:15, 2145:15, 2146:21, 2147:12,
2148:8, 2149:1, 2151:8, 2152:25,
2154:1, 2154:11, 2154:23, 2155:17,
2156:2, 2156:17, 2157:5, 2157:11,
2158:22, 2159:4, 2159:9, 2159:14,
2159:25, 2161:15, 2167:2, 2169:9,
2174:1, 2176:2, 2180:17, 2180:23,
2181:5, 2184:17, 2197:10, 2200:12,
2203:13, 2207:21, 2208:9, 2208:15,
2227:4, 2228:3, 2228:20, 2230:4,
2231:11, 2231:18, 2232:6, 2233:17,
2240:13, 2241:4, 2243:10, 2244:4,
2246:1, 2247:16, 2251:7, 2252:2,
2253:1, 2254:6, 2255:4
C
C.P [1] - 1993:11
cabinet [4] - 2208:11, 2209:6, 2209:10
Cabinet [1] - 2209:4
cabinets [4] - 2093:20, 2093:22,
2094:16, 2094:22
Caldwell [5] - 1990:9, 1993:8,
2002:15, 2105:10, 2204:10
California [1] - 2102:3
cannot [5] - 1995:3, 2010:3, 2033:6,
2245:3, 2245:4
capacity [2] - 2056:1, 2249:22
capital [6] - 2211:2, 2223:10, 2223:25,
2224:13, 2224:14, 2224:16
capitalize [1] - 2223:7
caption [1] - 2248:17
captive [2] - 2117:21, 2118:2
car [3] - 2204:5, 2205:1
care [3] - 2122:3, 2122:17, 2161:20
carefully [1] - 1999:1
Caribbean [22] - 2004:13, 2004:21,
2005:15, 2009:21, 2018:13, 2043:2,
2138:3, 2140:17, 2140:24, 2146:9,
2146:10, 2161:25, 2162:9, 2163:12,
2163:19, 2165:1, 2165:11, 2166:14,
2194:16, 2194:18, 2194:21
Carlos [1] - 2009:9
carry [1] - 2007:4
Cas [1] - 2159:23
case [14] - 1976:12, 1976:13, 1984:19,
1984:20, 1990:8, 1990:12, 1990:16,
2002:1, 2014:16, 2020:20, 2096:22,
2097:3, 2097:4, 2097:14
cases [5] - 2096:20, 2096:21, 2097:2,
2241:9
Cash [1] - 2008:23
cast [1] - 2039:15
catcher [2] - 2082:1, 2082:2
category [1] - 2085:13
catering [2] - 2165:8, 2195:19
Catholic [1] - 2168:9
caused [2] - 2032:1, 2069:18
cautioned [1] - 2099:5
caveat [1] - 2152:24
Cayman [1] - 2005:16
CD [23] - 2077:25, 2080:18, 2083:12,
2084:12, 2108:25, 2110:1, 2119:15,
2135:15, 2234:21, 2235:8, 2235:16,
2235:25, 2237:12, 2237:15, 2238:2,
2241:24, 2242:4, 2243:17, 2243:20,
2244:19, 2244:21, 2246:16, 2247:4
CDs [6] - 2076:15, 2115:22, 2116:11,
2124:24, 2248:25, 2251:13
cease [1] - 2087:15
ceased [3] - 2002:17, 2067:25,
2087:14
Cedar [3] - 2135:11, 2197:19, 2242:21
Central [1] - 2004:13
cents [1] - 2063:23
CEO [1] - 2062:16
certain [7] - 1976:1, 2013:16, 2139:15,
2150:25, 2183:24, 2184:2, 2207:2
certainly [7] - 2015:2, 2040:22,
2075:20, 2098:20, 2113:21, 2219:22,
2241:13
CERTIFICATE [1] - 2257:8
certificate [8] - 2036:6, 2043:25,
2046:4, 2053:18, 2054:16, 2054:18,
2054:21, 2246:2
certificates [2] - 2108:6, 2244:5
certification [1] - 2074:15
certified [4] - 2027:4, 2074:13, 2100:6,
2103:5
certify [3] - 1995:1, 2054:10, 2257:10
cetera [3] - 2068:13, 2092:17
CFO [5] - 2130:20, 2131:1, 2133:18,
2174:19, 2198:21
chain [1] - 2018:18
Chairman [1] - 1997:6
chairman [7] - 1993:12, 1993:14,
2007:23, 2008:6, 2060:22, 2061:4,
2061:6
Chamberlain [1] - 2226:8
Chambliess [1] - 2108:9
chance [2] - 1984:23, 2243:4
change [10] - 2037:21, 2037:22,
2046:14, 2047:6, 2133:9, 2133:11,
2134:4, 2141:17, 2157:18, 2215:5
changed [4] - 2015:8, 2122:25,
2201:4, 2217:5
changes [1] - 2183:2
characterization [1] - 2226:9
charge [6] - 2046:23, 2047:15,
2131:21, 2132:1, 2152:8, 2199:8
charged [5] - 1985:7, 2047:12,
2047:14, 2179:13, 2179:18
Charles [10] - 1993:13, 1993:15,
1994:12, 1995:17, 1997:12, 1997:19,
1998:3, 1998:8, 2000:16
check [2] - 1989:20, 2016:3
chess [1] - 1983:12
chief [20] - 1998:11, 1998:16, 1998:17,
1998:23, 2039:6, 2039:8, 2039:9,
2039:12, 2039:13, 2039:20, 2130:13,
2169:19, 2198:22, 2198:25, 2199:14,
2199:16, 2199:20, 2199:22, 2199:24,
2200:2
Chief [2] - 2039:18, 2039:19
chiefs [1] - 2039:5
children [1] - 2189:12
chooses [1] - 1992:6
Chronicle [2] - 2102:25, 2103:2
chums [1] - 2198:18
circumstance [1] - 2183:6
circumstances [3] - 1976:3, 2031:18,
2060:10
cities [1] - 2118:11
civil [9] - 2000:1, 2008:9, 2096:20,
2096:23, 2096:24, 2097:1, 2097:2,
2097:4
civilly [1] - 1985:7
clarification [1] - 2231:9
Johnny C. Sanchez, RMR, CRR - [email protected]
2264
clarify [2] - 2105:17, 2133:3
class [4] - 2046:16, 2215:16, 2218:17,
2236:17
Clean [21] - 2010:6, 2012:7, 2013:19,
2013:22, 2013:25, 2014:3, 2014:8,
2014:14, 2014:18, 2014:22, 2015:5,
2015:11, 2015:16, 2069:21, 2069:22,
2069:24, 2070:2, 2070:8, 2070:13,
2070:22, 2072:3
clean [1] - 2238:21
clear [10] - 1996:2, 1996:22, 2015:4,
2045:4, 2052:18, 2087:24, 2094:12,
2095:15, 2112:16, 2196:12
cleared [1] - 2003:17
clearer [1] - 2207:18
clearly [1] - 2091:12
clicking [1] - 2096:14
client [2] - 1981:1, 2160:7
clientele [1] - 2187:6
clients [17] - 2061:1, 2061:3, 2115:24,
2116:22, 2121:10, 2121:21, 2123:15,
2124:2, 2124:9, 2124:13, 2126:22,
2160:19, 2161:5, 2186:6, 2195:11,
2213:11, 2236:16
clip [5] - 2142:10, 2143:8, 2143:9,
2143:11, 2143:12
clock [5] - 1983:11, 1987:13, 2038:25,
2153:17, 2228:1
clocks [1] - 1983:12
close [7] - 2002:3, 2127:22, 2188:11,
2219:1, 2221:17, 2241:14, 2256:20
closed [1] - 2187:21
closing [3] - 2255:24, 2255:25, 2256:1
club [8] - 2023:12, 2136:18, 2213:23,
2215:2, 2219:12, 2219:15, 2220:10,
2221:2
Club [9] - 2077:18, 2136:15, 2136:16,
2139:14, 2211:17, 2217:24, 2218:1,
2218:2, 2218:9
cohesively [1] - 2003:22
college [3] - 2018:4, 2131:8, 2198:18
colonial [1] - 2020:4
colonies [1] - 2020:4
Colony [2] - 1990:4, 2086:10
comb [1] - 2029:16
coming [23] - 1984:5, 2013:4, 2034:25,
2036:13, 2047:5, 2058:9, 2058:11,
2058:14, 2072:1, 2127:10, 2135:20,
2145:19, 2146:2, 2146:3, 2146:16,
2146:18, 2147:7, 2147:9, 2147:13,
2176:18, 2191:16, 2228:16, 2243:22
comment [3] - 2039:1, 2105:14,
2105:23
comments [2] - 2045:1, 2045:2
commercial [5] - 2112:1, 2114:1,
2137:25, 2138:1, 2209:2
commission [10] - 1978:8, 1979:23,
1985:14, 2006:6, 2047:12, 2072:15,
2074:12, 2075:9, 2075:19, 2249:9
commission's [1] - 2072:16
commissioned [1] - 2006:5
Committee [4] - 2007:9, 2010:10,
2010:23, 2068:25
committee [24] - 2007:15, 2007:18,
2007:22, 2008:19, 2008:22, 2009:19,
2009:22, 2009:24, 2009:25, 2010:3,
2010:4, 2010:8, 2010:9, 2010:12,
2010:13, 2010:18, 2068:10, 2068:12,
2068:16, 2068:17, 2068:18, 2069:2,
2069:3, 2069:13
commonly [1] - 2253:6
community [2] - 2011:21, 2072:2
compact [1] - 1979:2
companies [23] - 1978:14, 2011:22,
2024:4, 2028:14, 2054:24, 2088:10,
2101:12, 2117:6, 2125:12, 2130:17,
2132:6, 2132:20, 2137:25, 2138:1,
2169:3, 2181:19, 2181:21, 2182:14,
2199:10, 2199:11, 2223:9, 2224:19,
2243:2
Company [21] - 2123:5, 2127:2,
2133:1, 2133:12, 2133:15, 2136:3,
2136:17, 2137:3, 2137:12, 2137:15,
2138:4, 2174:15, 2174:20, 2174:23,
2190:15, 2208:24, 2209:8, 2211:12,
2223:10, 2223:25, 2224:12
company [29] - 1979:9, 1999:4,
2027:25, 2097:6, 2102:14, 2102:19,
2117:15, 2117:20, 2117:21, 2118:2,
2122:25, 2132:13, 2134:4, 2135:5,
2136:8, 2137:17, 2148:5, 2149:15,
2149:19, 2158:9, 2166:8, 2174:13,
2174:17, 2188:1, 2207:15, 2223:8,
2235:13
company's [3] - 2031:3, 2032:20,
2032:24
compare [1] - 2005:14
compete [1] - 2005:15
competitions [1] - 2213:25
competitors [3] - 2016:22, 2073:1,
2073:20
complained [1] - 2039:12
complaint [5] - 2008:4, 2029:2,
2029:4, 2058:18
complete [5] - 2038:12, 2040:13,
2041:17, 2053:3, 2053:18
completed [3] - 2136:14, 2140:11,
2198:12
completely [2] - 2133:15, 2229:23
completion [1] - 2209:10
complex [1] - 2186:22
complexes [3] - 2125:25, 2133:22,
2183:23
compliance [1] - 2058:25
complied [1] - 2059:12
comply [3] - 2028:13, 2032:23,
2046:22
compulsive [3] - 2200:18, 2200:19,
2200:21
computer [8] - 1972:13, 1972:21,
2057:21, 2062:9, 2073:8, 2080:8,
2080:10, 2252:20
computer-assisted [2] - 1972:13,
1972:21
concentrate [1] - 2254:1
concept [6] - 2088:10, 2217:11,
2240:15, 2241:5, 2250:8, 2254:16
concern [13] - 2026:23, 2026:25,
2069:11, 2069:18, 2071:25, 2080:22,
2147:7, 2147:13, 2147:16, 2167:8,
2176:6, 2176:16
concerned [10] - 1997:17, 2071:13,
2129:7, 2147:8, 2153:6, 2166:12,
2167:10, 2167:16, 2170:9, 2176:3
concerning [2] - 2097:4, 2239:13
concerns [11] - 2011:11, 2011:13,
2011:15, 2011:20, 2069:10, 2140:4,
2140:6, 2146:1, 2148:5, 2148:6, 2206:4
conclude [1] - 1997:15
condensed [1] - 2217:10
conditions [2] - 1975:16, 1975:23
conduct [1] - 2230:13
conducted [6] - 2031:11, 2033:11,
2033:12, 2094:15, 2230:8, 2230:17
conducting [2] - 2026:12, 2060:7
conferring [3] - 2022:9, 2142:24,
2207:8
confidence [2] - 2190:18, 2195:15
confidential [1] - 2056:17
confirm [1] - 2097:14
confused [1] - 2010:13
Congress [1] - 1971:22
conjunction [5] - 2013:20, 2119:3,
2174:13, 2199:7, 2207:3
connect [1] - 1985:12
connections [1] - 2230:21
connotation [1] - 2181:13
conservative [7] - 2111:6, 2113:14,
2113:16, 2113:23, 2165:25, 2237:18,
2251:17
consider [2] - 2071:2, 2237:18
considerably [2] - 2170:4, 2213:3
considered [4] - 1987:3, 2006:22,
2031:23, 2126:12
consisted [2] - 2204:24, 2205:2
consistent [13] - 2112:2, 2113:9,
2114:11, 2114:22, 2142:19, 2143:25,
2145:1, 2165:18, 2165:21, 2216:10,
2237:14, 2237:16, 2239:2
consistently [1] - 2031:21
constituents [1] - 2013:15
construct [2] - 2138:19, 2190:20
constructed [2] - 2236:4, 2236:9
construction [29] - 2101:10, 2101:12,
2134:12, 2135:23, 2136:1, 2137:12,
2138:12, 2139:20, 2140:9, 2140:10,
2140:19, 2141:11, 2142:11, 2146:12,
2146:23, 2155:2, 2164:8, 2167:12,
2188:22, 2190:19, 2190:22, 2191:24,
2192:2, 2192:4, 2208:23, 2211:16,
2211:17, 2211:18, 2215:4
constructive [2] - 2225:6, 2226:5
construed [2] - 1982:15, 2091:6
consult [1] - 2226:19
consultant [1] - 2249:18
consulted [2] - 2222:25, 2233:11
consummated [1] - 1996:9
contacted [1] - 2178:14
Johnny C. Sanchez, RMR, CRR - [email protected]
2265
contacts [1] - 2230:25
contain [3] - 1978:21, 1978:24,
1979:10
contained [4] - 1975:15, 1978:20,
1998:24, 2012:25
containing [2] - 2053:9, 2093:20
contains [2] - 1979:21, 1980:15
contents [1] - 2048:12
context [1] - 2148:4
continue [6] - 1981:11, 1981:18,
1982:14, 2025:18, 2144:3, 2240:12
continued [2] - 2212:7, 2234:10
Continued [2] - 1972:1, 1972:2
contract [2] - 2096:20, 2150:11
control [4] - 2025:21, 2025:24, 2199:6,
2232:20
controller [11] - 2101:15, 2101:17,
2130:16, 2174:22, 2199:13, 2199:14,
2199:19, 2199:22, 2199:23, 2200:2,
2200:4
controllers [1] - 2199:17
controls [1] - 2004:18
conversation [3] - 1994:11, 2183:18,
2186:4
conversationally [1] - 2233:7
conversion [1] - 2208:19
convey [2] - 1987:20, 1987:22
cooperated [1] - 2016:11
cooperatives [1] - 2007:3
copy [9] - 1980:22, 1989:1, 2045:1,
2053:8, 2090:24, 2159:10, 2177:19,
2177:25, 2207:6
corporate [4] - 2247:22, 2248:13,
2248:14, 2253:3
Corporation [5] - 2047:22, 2123:1,
2123:2, 2133:12, 2238:16
corporation [11] - 2092:16, 2148:19,
2152:7, 2152:17, 2153:3, 2153:8,
2155:23, 2162:2, 2167:9, 2167:23,
2235:17
Corporations [3] - 1975:16, 2046:10,
2050:17
corporations [4] - 1991:1, 2010:2,
2036:20, 2052:12
correct [242] - 1981:24, 1981:25,
1983:22, 1984:6, 1984:7, 1984:10,
1984:12, 1986:23, 1987:3, 1988:14,
1988:15, 1988:17, 1988:18, 1989:9,
1989:16, 1991:21, 1994:18, 1994:21,
1995:15, 1996:5, 1996:13, 1996:21,
1997:9, 1998:14, 1999:5, 2001:16,
2003:6, 2003:9, 2004:5, 2004:10,
2004:11, 2004:14, 2004:22, 2005:3,
2005:12, 2005:13, 2005:17, 2005:24,
2006:3, 2006:6, 2006:17, 2007:6,
2007:16, 2007:17, 2007:20, 2007:23,
2008:20, 2009:5, 2009:7, 2009:23,
2010:11, 2010:21, 2011:2, 2012:15,
2013:23, 2015:12, 2015:13, 2015:19,
2015:24, 2017:4, 2018:24, 2020:10,
2020:19, 2024:19, 2025:4, 2025:18,
2026:6, 2026:11, 2027:3, 2029:13,
2029:17, 2032:16, 2037:13, 2038:9,
2040:15, 2040:25, 2042:7, 2042:14,
2043:17, 2043:21, 2046:1, 2046:24,
2046:25, 2047:3, 2047:20, 2047:24,
2048:9, 2048:18, 2048:20, 2048:25,
2049:7, 2049:14, 2049:15, 2050:7,
2050:8, 2051:12, 2051:13, 2052:11,
2052:20, 2052:21, 2053:23, 2053:24,
2054:16, 2054:17, 2054:19, 2054:20,
2055:1, 2055:6, 2055:7, 2056:19,
2056:22, 2056:23, 2057:9, 2057:10,
2057:18, 2057:19, 2058:14, 2058:20,
2058:25, 2060:6, 2060:11, 2060:15,
2060:18, 2060:19, 2063:8, 2064:24,
2065:5, 2065:6, 2070:20, 2071:10,
2073:24, 2073:25, 2074:18, 2084:21,
2084:22, 2085:3, 2085:14, 2087:2,
2087:16, 2087:18, 2089:19, 2089:24,
2090:18, 2090:19, 2091:7, 2091:15,
2091:19, 2091:23, 2091:24, 2092:5,
2092:6, 2093:2, 2093:3, 2093:5,
2093:6, 2093:8, 2093:14, 2094:3,
2094:5, 2094:6, 2094:7, 2095:9,
2095:12, 2095:16, 2095:23, 2095:24,
2102:12, 2103:25, 2104:1, 2104:8,
2106:18, 2107:4, 2107:13, 2109:1,
2112:20, 2121:25, 2123:24, 2130:14,
2131:3, 2131:24, 2132:18, 2144:24,
2150:20, 2151:12, 2151:13, 2154:6,
2155:24, 2158:4, 2158:18, 2158:19,
2159:7, 2166:9, 2170:19, 2171:22,
2172:11, 2174:18, 2175:3, 2175:13,
2175:20, 2176:7, 2176:11, 2179:11,
2181:17, 2181:20, 2182:5, 2186:24,
2188:9, 2188:13, 2188:15, 2188:18,
2190:2, 2192:3, 2192:14, 2194:8,
2196:1, 2196:7, 2198:17, 2201:11,
2205:3, 2205:10, 2210:18, 2212:20,
2214:20, 2224:4, 2225:1, 2228:22,
2231:15, 2234:5, 2235:15, 2238:17,
2239:6, 2239:20, 2242:16, 2245:9,
2245:14, 2246:6, 2248:23, 2249:5,
2253:4, 2253:7, 2257:11
correctly [8] - 2011:9, 2040:7, 2049:3,
2053:22, 2066:17, 2089:4, 2089:7,
2200:23
correspondence [4] - 2034:6, 2034:8,
2044:3, 2096:1
cost [6] - 2140:4, 2141:6, 2194:6,
2196:22, 2196:23, 2249:15
costa [9] - 2213:6, 2221:10, 2240:1,
2240:2, 2244:5, 2246:15, 2248:24,
2249:8, 2255:5
Costa [7] - 1971:13, 2112:23, 2222:5,
2227:5, 2228:25, 2229:7, 2230:20
COSTA [161] - 2067:5, 2098:24,
2099:8, 2101:1, 2102:18, 2104:2,
2104:5, 2105:20, 2106:2, 2106:6,
2110:5, 2110:16, 2111:1, 2111:8,
2111:12, 2111:13, 2111:17, 2111:23,
2112:12, 2112:21, 2113:4, 2113:8,
2113:24, 2114:3, 2114:6, 2114:17,
2114:21, 2115:7, 2116:8, 2116:16,
2117:9, 2117:11, 2117:25, 2118:9,
2118:12, 2118:17, 2118:19, 2119:23,
2121:7, 2123:21, 2124:7, 2124:19,
2124:23, 2125:9, 2125:14, 2128:2,
2128:16, 2135:4, 2136:10, 2136:12,
2136:22, 2136:24, 2137:4, 2137:5,
2138:7, 2138:8, 2138:18, 2138:24,
2138:25, 2139:6, 2139:8, 2142:22,
2143:2, 2143:6, 2143:8, 2143:12,
2143:14, 2143:17, 2143:19, 2143:20,
2144:3, 2144:6, 2144:13, 2144:15,
2145:15, 2146:21, 2147:12, 2147:18,
2147:20, 2148:2, 2148:4, 2148:8,
2148:23, 2149:1, 2150:4, 2150:11,
2150:17, 2151:3, 2151:8, 2152:11,
2152:15, 2152:21, 2152:25, 2153:14,
2153:16, 2153:21, 2153:23, 2154:1,
2154:9, 2154:11, 2154:21, 2154:23,
2155:6, 2155:14, 2155:16, 2155:17,
2155:25, 2156:2, 2156:15, 2156:17,
2157:2, 2157:5, 2157:10, 2157:11,
2158:20, 2158:22, 2159:3, 2159:4,
2159:8, 2159:9, 2159:12, 2159:14,
2159:24, 2159:25, 2161:15, 2167:2,
2169:7, 2180:14, 2181:2, 2184:8,
2184:11, 2184:15, 2200:9, 2203:4,
2207:13, 2227:25, 2228:17, 2229:19,
2231:9, 2233:17, 2240:3, 2240:6,
2240:9, 2240:13, 2240:21, 2241:4,
2243:8, 2243:10, 2244:1, 2245:22,
2251:7, 2252:2, 2252:15, 2252:20,
2252:22, 2253:1, 2253:25, 2254:3,
2254:6, 2254:22, 2256:22
COSTA............. [2] - 1973:21, 1973:25
COSTA............... [1] - 1973:17
costing [1] - 2146:12
costs [1] - 2140:6
council [2] - 2067:21, 2086:22
counsel [11] - 1983:4, 1983:13,
1983:24, 1999:6, 2022:19, 2034:20,
2034:25, 2035:23, 2069:20, 2078:4,
2096:11
Counsel [14] - 1975:5, 1992:20,
1997:22, 2020:14, 2061:25, 2079:23,
2083:3, 2083:20, 2090:19, 2097:10,
2097:25, 2098:13, 2147:24, 2175:22
count [1] - 2171:17
countries [4] - 1976:4, 1976:5, 2020:8,
2221:24
country [3] - 1977:9, 2017:2, 2209:7
County [1] - 2099:15
couple [7] - 2039:8, 2104:25, 2127:15,
2144:25, 2159:12, 2161:22, 2168:19
course [5] - 2039:12, 2064:22,
2078:11, 2083:4, 2181:15
Court [14] - 1972:10, 1972:17, 1989:4,
1990:4, 1990:18, 2002:6, 2009:22,
2035:17, 2039:2, 2039:12, 2039:17,
2078:18, 2086:10, 2090:24
court [15] - 1976:7, 1986:17, 1987:19,
1991:7, 1991:8, 1991:9, 1994:3,
2026:1, 2035:15, 2039:3, 2099:12,
2203:9, 2204:13, 2229:6, 2229:16
COURT [259] - 1971:1, 1975:2,Johnny C. Sanchez, RMR, CRR - [email protected]
2266
1976:20, 1976:24, 1977:2, 1977:5,
1977:9, 1977:12, 1980:4, 1980:9,
1983:1, 1983:3, 1983:6, 1983:10,
1983:24, 1984:2, 1985:22, 1985:25,
1986:2, 1987:8, 1987:11, 1989:7,
1989:9, 1989:12, 1989:17, 1989:20,
1989:23, 1991:15, 1991:19, 1991:22,
1991:24, 1992:1, 1996:24, 1997:2,
1997:22, 1999:6, 1999:9, 1999:12,
1999:15, 1999:20, 2017:11, 2017:16,
2017:19, 2020:14, 2022:14, 2022:17,
2022:19, 2022:23, 2027:21, 2034:20,
2035:4, 2035:9, 2035:25, 2036:3,
2036:9, 2036:13, 2036:16, 2036:23,
2037:1, 2037:5, 2037:9, 2037:15,
2037:18, 2037:22, 2037:24, 2038:3,
2038:16, 2038:22, 2038:24, 2044:14,
2044:19, 2044:21, 2045:6, 2045:15,
2045:20, 2046:11, 2049:20, 2051:17,
2051:21, 2052:1, 2052:8, 2054:11,
2056:5, 2059:21, 2061:13, 2061:17,
2061:20, 2061:23, 2062:8, 2063:6,
2066:1, 2067:6, 2070:4, 2070:9,
2070:12, 2070:15, 2070:24, 2071:9,
2071:14, 2072:9, 2073:9, 2075:6,
2075:16, 2076:4, 2076:9, 2076:19,
2076:24, 2077:7, 2077:10, 2077:14,
2078:4, 2078:9, 2078:20, 2079:2,
2079:11, 2079:15, 2079:23, 2080:7,
2080:10, 2080:22, 2080:25, 2081:11,
2081:23, 2082:5, 2082:7, 2082:15,
2082:21, 2082:23, 2083:1, 2083:5,
2083:16, 2083:24, 2084:6, 2084:16,
2085:5, 2086:1, 2088:14, 2089:16,
2090:3, 2090:6, 2090:9, 2090:13,
2090:17, 2090:22, 2091:1, 2092:11,
2096:6, 2096:11, 2096:13, 2097:22,
2097:25, 2098:13, 2098:15, 2098:22,
2098:25, 2100:23, 2102:16, 2103:25,
2104:3, 2105:19, 2106:1, 2106:5,
2110:4, 2110:13, 2110:24, 2112:11,
2112:19, 2113:2, 2113:20, 2114:16,
2114:19, 2115:5, 2116:2, 2116:15,
2117:24, 2119:22, 2123:20, 2124:5,
2124:18, 2124:22, 2125:13, 2127:18,
2127:22, 2127:25, 2128:12, 2138:13,
2143:1, 2143:3, 2143:7, 2143:11,
2143:13, 2143:16, 2144:4, 2145:11,
2145:14, 2146:20, 2147:17, 2147:19,
2147:22, 2148:3, 2148:6, 2150:6,
2150:8, 2150:13, 2150:20, 2151:6,
2152:13, 2152:23, 2153:15, 2153:17,
2153:20, 2153:22, 2153:25, 2155:8,
2155:13, 2155:15, 2161:11, 2161:14,
2166:24, 2173:23, 2175:22, 2175:25,
2180:16, 2181:4, 2184:10, 2184:14,
2184:16, 2197:7, 2200:11, 2203:5,
2207:7, 2207:9, 2207:16, 2227:3,
2227:16, 2227:19, 2227:21, 2227:24,
2228:1, 2228:13, 2228:18, 2229:25,
2231:10, 2231:15, 2231:17, 2240:1,
2240:5, 2240:8, 2240:11, 2240:24,
2245:24, 2251:24, 2252:19, 2252:21,
2254:5, 2254:25, 2256:23, 2257:1,
2257:8
Court's [3] - 1982:25, 2035:18, 2052:3
Courtney [3] - 2046:6, 2047:2, 2047:9
courtroom [3] - 2098:19, 2103:21,
2182:7
cover [1] - 2103:8
covered [1] - 2116:23
CPA [19] - 1991:15, 1991:16, 2099:24,
2100:6, 2100:11, 2113:6, 2130:14,
2131:3, 2131:5, 2170:12, 2174:5,
2174:7, 2223:5, 2224:8, 2226:14,
2226:17, 2249:22, 2249:23, 2249:25
create [3] - 2140:23, 2174:25, 2186:10
created [8] - 1986:12, 1986:21,
2103:18, 2123:8, 2123:10, 2177:18,
2184:19, 2226:23
credentials [1] - 2174:4
credit [2] - 1998:2, 2114:9
Credit [1] - 1979:14
CRICK [1] - 1973:4
crick [7] - 1975:10, 2045:8, 2045:22,
2073:16, 2074:8, 2076:13, 2078:14
Crick [38] - 1977:14, 1980:14, 1980:20,
1980:24, 1981:15, 1981:23, 1983:18,
1984:8, 1987:21, 2023:2, 2035:20,
2036:7, 2038:12, 2040:4, 2053:20,
2057:12, 2058:12, 2061:11, 2062:4,
2062:12, 2063:2, 2063:12, 2064:2,
2064:8, 2066:3, 2066:24, 2067:12,
2068:2, 2069:14, 2070:18, 2072:3,
2080:2, 2080:13, 2081:6, 2083:11,
2089:20, 2091:3, 2098:4
cricket [33] - 2018:21, 2018:23,
2019:4, 2019:9, 2019:15, 2020:9,
2025:7, 2025:9, 2025:10, 2025:14,
2025:15, 2075:22, 2076:7, 2076:9,
2076:16, 2077:3, 2082:2, 2139:2,
2211:15, 2213:12, 2213:13, 2213:14,
2213:21, 2214:9, 2214:23, 2215:13,
2216:16, 2216:17, 2216:18, 2217:6,
2217:9, 2217:13
Cricket [1] - 2020:17
cricket's [1] - 2019:4
crime [3] - 2047:13, 2164:1, 2179:13
criminal [5] - 2000:1, 2047:13,
2096:22, 2096:23, 2180:6
criminally [1] - 1985:8
crisis [1] - 2102:1
critical [1] - 2000:15
cross [14] - 2035:16, 2036:21,
2038:10, 2049:23, 2068:9, 2069:21,
2072:23, 2074:3, 2074:9, 2075:22,
2080:14, 2132:3, 2233:19, 2240:20
CROSS [4] - 1973:6, 1973:19,
1983:16, 2169:8
cross-examination [12] - 2035:16,
2036:21, 2038:10, 2049:23, 2068:9,
2069:21, 2072:23, 2074:3, 2074:9,
2075:22, 2080:14, 2233:19
CROSS-EXAMINATION [4] - 1973:6,
1973:19, 1983:16, 2169:8
CRR [3] - 1972:10, 1972:18, 2257:14
current [5] - 2059:5, 2060:20, 2060:22,
2100:11, 2120:18
curriculum [1] - 2053:3
customer [7] - 1976:7, 1976:8,
1976:11, 1976:14, 2016:17, 2016:18
customer's [1] - 1976:10
customers [10] - 1977:18, 1979:23,
1986:19, 1986:21, 1987:1, 2016:5,
2120:3, 2122:11, 2123:11, 2123:24
customs [3] - 2008:25, 2009:14,
2196:12
Customs [1] - 2009:1
cut [1] - 2168:13
Cynthia [1] - 2014:10
D
Dallas [2] - 2105:6, 2105:7
damaged [1] - 2208:20
date [13] - 1978:25, 2053:3, 2053:10,
2062:12, 2063:12, 2063:14, 2066:24,
2067:22, 2087:14, 2098:6, 2151:9,
2177:6, 2249:10
dated [4] - 2002:25, 2057:11, 2154:6,
2180:25
dates [5] - 2056:11, 2056:22, 2056:24,
2253:11, 2255:7
daughter [1] - 2102:6
DAVID [1] - 1971:10
Davis [23] - 2130:6, 2130:9, 2130:20,
2131:5, 2131:7, 2131:11, 2131:13,
2131:20, 2131:21, 2131:25, 2132:12,
2132:16, 2132:22, 2132:25, 2133:13,
2198:16, 2198:20, 2199:19, 2199:24,
2232:7, 2232:10, 2232:20
Davis's [2] - 2130:11, 2131:10
day-to-day [2] - 2199:15, 2199:17
days [10] - 2099:20, 2104:25, 2109:8,
2125:24, 2142:10, 2145:8, 2145:17,
2145:18, 2217:7, 2239:12
DC [1] - 1971:18
De [2] - 2043:12, 2043:13
de [1] - 2168:8
DEA [1] - 2008:23
deal [8] - 2136:6, 2186:13, 2187:13,
2187:19, 2187:21, 2188:10, 2191:17,
2226:20
dealer [1] - 2204:5
dealership [2] - 2204:5, 2205:1
dealing [2] - 2206:1, 2206:2
dealings [1] - 2206:7
deals [10] - 2170:18, 2171:5, 2171:17,
2172:2, 2176:5, 2185:14, 2186:12,
2189:21, 2235:18, 2242:8
dealt [1] - 2221:23
debt [6] - 2151:18, 2228:24, 2247:24,
2248:2, 2253:6
decade [2] - 2135:14, 2135:23
decades [1] - 2214:7
December [16] - 1998:12, 2000:19,
2002:6, 2002:18, 2028:11, 2032:21,
2063:15, 2068:1, 2087:12, 2088:17,Johnny C. Sanchez, RMR, CRR - [email protected]
2267
2098:8, 2151:10, 2154:19, 2154:24,
2155:20, 2157:16
decide [6] - 2076:2, 2076:4, 2125:4,
2166:16, 2172:12, 2215:6
decided [4] - 2060:10, 2106:22,
2167:25, 2226:4
decision [16] - 1977:23, 1977:25,
1979:8, 1979:18, 1995:4, 2026:22,
2060:13, 2060:14, 2098:5, 2166:19,
2166:21, 2168:16, 2172:17, 2172:23,
2208:11
decision-making [1] - 1979:8
decisions [2] - 2115:1, 2245:18
declared [2] - 2002:16, 2226:3
deemed [1] - 2253:12
DEFENDANT [2] - 1971:20, 1972:2
defendant [1] - 2150:12
Defendant's [9] - 1988:25, 1989:11,
1994:2, 2020:22, 2044:12, 2051:15,
2052:24, 2086:9, 2090:1
defendant's [1] - 1989:12
Defense [2] - 2067:3, 2207:5
defense [5] - 1980:12, 2003:14,
2037:12, 2040:1, 2056:6
define [2] - 2093:15, 2248:2
defines [1] - 2091:12
definitely [2] - 2193:10, 2243:19
definition [1] - 2165:23
definitive [1] - 2012:14
degree [2] - 2048:20, 2126:12
delved [1] - 2241:23
demand [1] - 2244:21
demanded [1] - 2201:12
denied [1] - 1994:12
department [2] - 2072:19, 2134:12
Department [1] - 1971:17
departure [1] - 1993:17
dependent [1] - 2164:18
deposit [4] - 1976:14, 2108:6, 2245:7,
2246:2
deposited [2] - 2110:21, 2111:4
depositor [3] - 2235:23, 2241:24,
2242:4
depositors [9] - 2109:25, 2110:20,
2153:11, 2235:8, 2235:21, 2238:2,
2243:17, 2251:13, 2252:8
depositors' [5] - 2119:15, 2135:15,
2235:16, 2237:12, 2237:15
deposits [3] - 2116:23, 2234:22,
2244:5
depressed [2] - 2171:1
desalination [3] - 2210:2, 2210:4,
2210:9
describe [7] - 1975:14, 1978:19,
2011:4, 2132:9, 2158:5, 2172:24,
2197:22
described [4] - 2031:3, 2049:2,
2060:11, 2255:11
describes [1] - 1975:16
describing [1] - 2012:6
description [1] - 2047:14
design [2] - 2219:21, 2221:2
designed [1] - 1978:7
despite [1] - 2145:24
destination [1] - 2215:16
detail [2] - 2161:19, 2248:18
details [5] - 1978:12, 1979:1, 2026:8,
2049:4, 2226:2
determination [1] - 2150:23
determinations [1] - 2175:19
determine [3] - 1979:8, 1990:2, 2175:6
detrimental [1] - 2164:4
develop [6] - 2011:7, 2011:24,
2170:17, 2194:25, 2197:12, 2212:17
developed [2] - 2010:25, 2209:7
developing [4] - 2189:5, 2211:24,
2217:20, 2235:1
Development [27] - 2123:1, 2123:2,
2123:5, 2123:7, 2123:10, 2124:1,
2124:8, 2124:10, 2127:2, 2132:14,
2133:1, 2133:7, 2133:12, 2133:14,
2136:17, 2137:3, 2137:12, 2137:15,
2139:3, 2158:10, 2174:15, 2174:20,
2174:22, 2190:15, 2208:24, 2209:8,
2238:16
development [29] - 2041:22, 2042:1,
2134:3, 2139:19, 2142:20, 2144:8,
2144:11, 2148:18, 2149:15, 2149:19,
2152:7, 2152:16, 2153:3, 2153:8,
2155:3, 2155:23, 2162:1, 2167:9,
2167:23, 2197:18, 2198:7, 2200:14,
2208:22, 2209:19, 2218:2, 2234:14,
2235:12, 2235:17, 2238:3
developments [6] - 2176:5, 2197:14,
2234:14, 2234:25, 2242:17, 2243:23
deviation [1] - 2084:2
devote [1] - 2108:16
Diaz [3] - 2009:18, 2009:20, 2014:10
Diego [2] - 2102:3, 2102:4
difference [6] - 2122:15, 2126:5,
2126:25, 2199:21, 2250:21
differences [1] - 2000:23
different [21] - 1986:22, 1998:13,
1999:10, 2010:15, 2014:2, 2015:21,
2017:2, 2051:19, 2051:21, 2110:11,
2124:24, 2131:14, 2131:17, 2139:22,
2141:18, 2159:10, 2162:25, 2229:23,
2250:23, 2251:25
difficult [4] - 1980:23, 2003:25,
2140:25, 2201:9
difficulties [4] - 1995:6, 1995:9,
1995:10, 2123:14
difficulty [3] - 2163:16, 2164:7
diligence [1] - 2187:9
DIRECT [3] - 1973:17, 1975:8, 2099:7
direct [12] - 2026:9, 2027:5, 2035:22,
2066:4, 2068:21, 2095:7, 2184:4,
2184:9, 2184:12, 2227:6, 2228:4,
2228:21
director [15] - 1996:20, 2006:2,
2010:20, 2014:13, 2029:1, 2029:12,
2030:13, 2045:23, 2046:15, 2047:16,
2053:15, 2056:1, 2060:20, 2157:17,
2168:12
Director [1] - 2053:21
directors [30] - 1988:21, 1992:10,
1992:11, 1993:19, 1995:3, 1995:21,
1995:24, 1996:3, 2031:16, 2036:7,
2043:23, 2046:7, 2046:14, 2047:6,
2047:24, 2048:4, 2048:7, 2048:8,
2060:23, 2066:11, 2092:16, 2092:17,
2101:21, 2105:2, 2162:24, 2202:6,
2202:7, 2205:2
Directors [1] - 2031:2
dirt [2] - 2082:15, 2082:16
disagree [2] - 2084:3, 2092:24
discharged [1] - 2048:23
disclose [4] - 1977:23, 1982:9,
2066:11, 2073:23
disclosed [23] - 2031:21, 2064:6,
2066:15, 2076:13, 2080:17, 2081:6,
2083:11, 2084:24, 2085:3, 2085:10,
2158:6, 2158:15, 2223:16, 2223:18,
2224:3, 2224:25, 2229:9, 2229:12,
2229:20, 2239:1, 2249:3, 2249:4
disclosing [2] - 1976:17, 2223:20
disclosure [9] - 1982:20, 2065:8,
2077:2, 2077:4, 2156:24, 2157:12,
2158:18, 2159:5, 2224:10
disclosures [9] - 2031:14, 2238:23,
2239:11, 2239:13, 2239:23, 2239:24,
2240:14, 2240:23, 2241:20
discuss [7] - 1981:5, 1981:13,
1984:20, 2086:5, 2107:25, 2115:13,
2150:25
discussed [7] - 2044:21, 2110:18,
2117:20, 2153:24, 2166:22, 2209:4,
2209:6
discussing [2] - 2069:20, 2070:19
discussion [3] - 2158:1, 2158:3,
2165:1
discussions [2] - 2143:25, 2165:12
dispute [6] - 1994:17, 1994:20,
1995:14, 2026:5, 2026:7, 2026:8
distinguishes [1] - 2246:12
distressed [11] - 2103:19, 2104:9,
2106:8, 2106:12, 2120:16, 2120:17,
2126:8, 2126:11, 2126:17, 2133:21,
2134:7
distributed [1] - 1987:1
distribution [1] - 1986:7
DISTRICT [3] - 1971:1, 1971:1,
1971:10
District [1] - 2100:3
disturbed [2] - 2012:18, 2012:23
diversification [1] - 1981:14
diversified [1] - 2126:18
dividend [2] - 2225:6, 2226:5
division [1] - 2009:1
DIVISION [1] - 1971:2
dock [4] - 2138:16, 2138:20, 2138:22,
2218:3
docket [1] - 2150:22
document [41] - 1986:6, 1986:9,
1986:12, 1986:14, 1986:16, 1986:18,
1987:18, 1987:24, 1988:5, 1988:14,
1988:23, 1990:21, 1990:22, 1990:25,
1995:16, 2003:21, 2034:17, 2034:18,Johnny C. Sanchez, RMR, CRR - [email protected]
2268
2036:5, 2036:11, 2036:18, 2037:2,
2037:3, 2037:5, 2037:12, 2038:17,
2041:10, 2044:6, 2044:7, 2050:21,
2051:19, 2051:21, 2055:15, 2063:12,
2065:21, 2066:24, 2067:22, 2150:2,
2150:18, 2154:10, 2154:17
documents [12] - 1976:1, 2034:1,
2034:13, 2034:25, 2035:14, 2035:20,
2035:24, 2037:19, 2057:24, 2074:20,
2140:10, 2148:21
dollar [13] - 2016:3, 2156:19, 2156:25,
2158:2, 2158:3, 2159:6, 2223:1,
2228:9, 2239:6, 2241:7, 2241:8,
2253:14
dollars [10] - 2063:23, 2075:10,
2152:16, 2170:3, 2211:23, 2215:12,
2216:13, 2219:20, 2219:24, 2242:5
Don [5] - 1990:9, 1993:7, 2002:14,
2105:10, 2204:10
done [24] - 1997:11, 2012:4, 2012:15,
2013:2, 2020:24, 2033:6, 2039:25,
2041:9, 2101:20, 2105:15, 2105:22,
2140:17, 2155:3, 2193:4, 2194:15,
2194:17, 2194:21, 2200:23, 2201:2,
2201:6, 2201:7, 2220:15, 2240:25,
2256:9
door [1] - 2225:20
double [1] - 1989:20
double-check [1] - 1989:20
doubt [7] - 1994:6, 1995:20, 1996:8,
2000:19, 2001:1, 2040:11, 2132:6
down [36] - 1981:19, 1983:4, 1997:12,
2004:22, 2011:12, 2014:20, 2033:13,
2037:21, 2037:22, 2046:11, 2056:21,
2098:16, 2100:23, 2102:2, 2126:14,
2126:15, 2141:1, 2142:8, 2160:23,
2166:18, 2167:3, 2173:23, 2175:22,
2183:8, 2185:1, 2208:13, 2214:14,
2214:17, 2227:12, 2228:14, 2230:2,
2234:14, 2243:23, 2247:14, 2256:24
downtown [1] - 2135:2
dozen [1] - 2162:12
draft [1] - 1986:9
drafted [1] - 1986:18
dream [3] - 2218:24, 2220:4, 2237:10
drill [1] - 1981:19
drives [2] - 2169:4, 2169:6
drop [1] - 2014:20
drove [1] - 2187:11
drug [1] - 2004:12
due [1] - 2187:9
duly [1] - 2099:5
during [16] - 1989:20, 2019:22,
2070:17, 2074:3, 2074:6, 2134:3,
2135:22, 2156:8, 2156:12, 2159:2,
2178:3, 2183:6, 2189:19, 2198:14,
2202:2, 2206:12
duties [2] - 2003:11, 2065:15
duty [2] - 2049:13, 2189:14
E
e) [1] - 2091:10
e-mail [1] - 2166:21
early [23] - 2010:9, 2026:16, 2051:15,
2107:16, 2107:25, 2109:7, 2109:18,
2115:3, 2133:2, 2133:13, 2136:11,
2139:21, 2145:8, 2145:17, 2145:18,
2170:20, 2190:6, 2214:7, 2229:2,
2234:8
early-to-mid-1990s [1] - 2133:2
easel [1] - 2067:10
easier [1] - 2040:24
easily [2] - 2241:15, 2255:14
East [1] - 2009:21
easy [3] - 1996:14, 1996:15, 2181:6
eat [1] - 2236:21
economic [5] - 2144:12, 2235:4,
2235:5, 2238:2, 2243:6
economics [1] - 2144:10
economy [1] - 2120:11
Ede [1] - 1999:22
educational [1] - 2099:25
effect [8] - 2003:2, 2008:10, 2071:4,
2081:25, 2090:10, 2090:11, 2090:12,
2090:16
effective [1] - 2011:25
effort [4] - 2004:2, 2004:17, 2005:7,
2188:23
eight [2] - 2100:21, 2162:23
either [13] - 1976:14, 1996:8, 2001:13,
2013:20, 2015:9, 2039:6, 2049:22,
2058:2, 2083:18, 2083:19, 2155:21,
2249:2
elaborate [1] - 2119:20
electing [1] - 2203:11
electricity [3] - 2164:15, 2164:21,
2164:23
elicit [1] - 2112:25
Ellen [3] - 1989:17, 2037:11, 2038:5
ELMO [3] - 1988:1, 2044:24, 2045:19
Elsie [2] - 2108:10, 2108:11
empire [2] - 2232:14, 2232:21
employee [2] - 2095:20, 2128:25
employees [6] - 2107:22, 2107:23,
2131:14, 2131:19, 2164:13, 2190:15
end [25] - 1992:24, 2002:5, 2028:5,
2064:14, 2102:13, 2136:5, 2141:20,
2144:16, 2145:25, 2148:14, 2154:3,
2154:6, 2155:19, 2157:22, 2160:22,
2165:6, 2165:14, 2168:7, 2168:23,
2208:5, 2219:12, 2236:14, 2236:18,
2237:17, 2238:5
endeavor [2] - 2146:8, 2146:9
ended [7] - 1996:4, 2015:11, 2028:12,
2032:22, 2042:9, 2097:16, 2169:24
ending [1] - 2086:19
ends [1] - 2257:4
enforcing [1] - 2046:23
engaging [1] - 2220:15
England [2] - 2213:16, 2214:1
English [1] - 2020:12
enjoyable [1] - 2039:24
enjoyed [1] - 2200:17
enlarge [1] - 1985:25
enlarged [1] - 1985:20
enormous [1] - 2209:6
enter [1] - 2150:14
entered [2] - 2002:12, 2055:4
enterprise [3] - 2249:8, 2249:14,
2250:24
entertain [2] - 1995:20, 1996:8
entire [9] - 1977:18, 2000:6, 2003:20,
2082:9, 2085:19, 2143:9, 2238:11,
2239:22
entirety [2] - 1992:6, 2071:7
entities [5] - 2006:20, 2012:1, 2025:4,
2033:5, 2134:13
entitled [4] - 2039:5, 2083:20,
2243:21, 2257:12
entity [11] - 1978:8, 1978:16, 2007:15,
2055:5, 2101:4, 2104:6, 2106:16,
2137:2, 2137:11, 2137:13, 2137:19
entrance [2] - 2197:24
entrepreneur [2] - 2193:9, 2193:10
entry [1] - 2254:15
envelope [1] - 1998:24
equities [8] - 2111:6, 2111:25,
2113:16, 2113:22, 2125:21, 2125:22,
2149:6, 2247:21
equivalent [2] - 1991:15, 2082:22
error [1] - 2032:2
especially [4] - 1993:8, 1999:18,
2113:23, 2214:7
essential [2] - 1979:3, 2209:9
essentially [1] - 2013:15
establish [3] - 2010:1, 2058:24,
2112:6
established [1] - 2053:5
establishes [1] - 2181:3
estate [77] - 2101:9, 2103:6, 2103:20,
2104:9, 2104:22, 2106:8, 2106:12,
2106:20, 2107:19, 2119:12, 2119:16,
2119:25, 2120:4, 2120:6, 2120:14,
2120:16, 2120:17, 2121:11, 2121:13,
2121:22, 2122:4, 2122:11, 2123:12,
2123:15, 2123:22, 2124:13, 2125:1,
2125:2, 2125:12, 2125:15, 2125:17,
2126:1, 2126:8, 2126:11, 2126:12,
2126:18, 2126:20, 2126:23, 2129:5,
2133:21, 2149:12, 2170:8, 2170:10,
2170:17, 2170:25, 2171:1, 2171:3,
2171:5, 2171:17, 2171:20, 2172:2,
2176:4, 2185:14, 2186:7, 2186:12,
2190:21, 2191:3, 2191:7, 2191:21,
2200:14, 2233:25, 2235:9, 2235:17,
2239:2, 2239:9, 2239:10, 2242:8,
2245:12, 2249:3, 2250:18, 2255:17,
2255:18, 2255:23, 2256:3, 2256:19
estimate [1] - 2108:21
estimates [1] - 2031:15
et [3] - 2068:13, 2092:17
Ethridge [1] - 2108:10
evaluated [1] - 2032:5
event [1] - 2223:11Johnny C. Sanchez, RMR, CRR - [email protected]
2269
eventually [10] - 1991:5, 2014:18,
2015:19, 2038:4, 2054:16, 2054:18,
2106:14, 2133:25, 2174:15, 2190:14
evidence [34] - 1976:21, 1980:1,
1980:5, 1980:11, 1988:25, 1989:5,
1992:5, 1997:19, 1997:20, 2000:5,
2001:1, 2001:7, 2024:18, 2031:13,
2031:24, 2052:23, 2058:16, 2065:23,
2065:24, 2075:15, 2076:18, 2078:3,
2080:20, 2085:18, 2112:20, 2123:19,
2143:4, 2146:19, 2148:10, 2150:21,
2152:10, 2180:15, 2227:22
evildoing [1] - 2179:19
exact [2] - 2026:7, 2150:23
exactly [7] - 2006:18, 2013:14,
2014:14, 2019:1, 2025:3, 2044:17,
2137:18
exam [2] - 2057:3, 2057:17
EXAMINATION [21] - 1973:6, 1973:8,
1973:10, 1973:12, 1973:17, 1973:19,
1973:21, 1973:23, 1973:25, 1974:2,
1975:8, 1983:16, 2062:2, 2084:17,
2098:2, 2099:7, 2169:8, 2233:16,
2244:3, 2251:6, 2255:3
examination [38] - 2026:9, 2031:13,
2033:10, 2033:11, 2033:20, 2033:21,
2035:16, 2036:21, 2038:10, 2042:23,
2043:5, 2043:11, 2049:23, 2054:22,
2056:18, 2064:9, 2064:11, 2064:14,
2064:22, 2064:24, 2068:9, 2069:21,
2070:7, 2070:12, 2072:23, 2074:3,
2074:9, 2075:22, 2078:13, 2080:14,
2095:7, 2184:4, 2184:9, 2184:12,
2227:6, 2228:5, 2228:21, 2233:19
examinations [1] - 2060:7
examine [5] - 2029:17, 2042:19,
2043:22, 2044:1, 2160:6
Examined [1] - 2056:21
examined [1] - 2058:22
examiner [3] - 2043:14, 2043:16,
2065:4
examiners [2] - 2015:21, 2058:23
examining [1] - 2015:19
example [5] - 1975:24, 1986:25,
2085:11, 2164:6, 2223:9
exams [1] - 2034:14
except [1] - 2230:25
exception [1] - 2256:20
exchange [2] - 2253:16, 2253:18
exchanges [1] - 2253:12
excuse [6] - 2017:21, 2070:4, 2112:5,
2123:18, 2125:5, 2145:9
excused [3] - 2098:16, 2256:24,
2257:1
Executive [1] - 2053:20
executive [12] - 2006:1, 2010:20,
2014:13, 2028:25, 2029:12, 2030:13,
2045:23, 2056:1, 2060:20, 2101:15,
2106:25, 2208:11
exercise [1] - 2015:25
exercising [2] - 1981:14, 2048:20
exhaustive [1] - 2065:10
Exhibit [47] - 1979:25, 1985:18,
1988:4, 1988:25, 1989:11, 1993:3,
1994:3, 2017:8, 2017:18, 2020:22,
2022:13, 2027:17, 2027:19, 2029:6,
2030:7, 2044:13, 2052:24, 2055:12,
2055:17, 2055:25, 2056:4, 2056:13,
2057:6, 2057:11, 2057:25, 2058:1,
2058:10, 2062:4, 2063:3, 2064:10,
2066:22, 2067:3, 2073:5, 2077:6,
2080:3, 2085:25, 2086:6, 2086:9,
2086:15, 2088:16, 2090:2, 2207:5,
2223:1, 2227:18, 2230:2, 2246:21,
2246:23
exhibit [16] - 1983:5, 1992:9, 2003:14,
2028:17, 2077:8, 2077:11, 2089:17,
2150:25, 2153:20, 2196:4, 2223:4,
2228:5, 2229:24, 2240:6, 2254:24
exhibited [1] - 2223:3
exhibits [1] - 2056:6
exist [7] - 2025:18, 2067:21, 2086:23,
2087:1, 2087:14, 2087:15, 2088:2
existed [4] - 2033:5, 2087:5, 2088:3,
2088:4
existence [1] - 2060:6
existing [1] - 2087:15
expand [2] - 2006:10, 2189:25
expensive [7] - 2139:22, 2139:24,
2141:5, 2194:3, 2211:21, 2211:22,
2236:15
experience [5] - 2001:19, 2001:20,
2053:7, 2103:6, 2236:17
expert [5] - 2025:14, 2112:8, 2112:10,
2112:25, 2113:6
expertise [1] - 2004:15
explain [5] - 2049:17, 2049:19,
2049:21, 2163:23, 2195:8
explained [3] - 1998:17, 2187:18,
2215:14
explanation [1] - 2161:16
explanations [1] - 2031:23
express [1] - 2140:4
expression [1] - 2081:24
extended [4] - 2157:13, 2157:16,
2232:13, 2232:14
extent [8] - 2018:14, 2025:24,
2042:10, 2053:6, 2063:1, 2121:23,
2122:13, 2164:18
extremely [4] - 2165:9, 2200:19,
2213:19, 2214:8
Exxon [1] - 2253:6
eye [1] - 2113:5
F
fabulous [1] - 2196:22
fabulously [2] - 2250:19, 2250:25
facility [7] - 2138:16, 2192:13, 2210:8,
2214:21, 2214:22, 2215:3, 2233:3
fact [25] - 1979:11, 1988:20, 1991:3,
1997:23, 2010:5, 2027:1, 2041:22,
2086:19, 2096:19, 2119:2, 2146:2,
2175:14, 2175:17, 2175:21, 2176:12,
2176:21, 2179:25, 2193:6, 2210:19,
2213:16, 2214:5, 2225:12, 2227:5,
2254:23, 2255:23
facts [10] - 2075:14, 2076:17, 2078:2,
2078:13, 2080:20, 2123:18, 2146:19,
2152:9, 2255:20, 2255:22
failing [2] - 2210:23, 2211:1
fair [7] - 1994:10, 2011:16, 2028:10,
2032:20, 2042:4, 2051:6, 2194:19
faith [3] - 2078:16, 2078:18, 2152:21
fall [3] - 2019:14, 2019:16, 2019:18
fam [1] - 2145:20
familiar [30] - 1975:12, 1977:9, 1978:4,
1987:4, 2010:12, 2014:4, 2022:4,
2022:6, 2022:8, 2024:20, 2025:24,
2055:15, 2068:8, 2088:9, 2109:21,
2159:17, 2179:21, 2179:22, 2209:15,
2220:11, 2220:14, 2220:18, 2220:21,
2221:13, 2221:18, 2222:2, 2223:7,
2225:12, 2225:25, 2240:15
family [3] - 2145:7, 2145:16, 2145:20
fancy [4] - 2166:1, 2237:6, 2237:10,
2237:17
far [14] - 1997:16, 2017:23, 2024:3,
2098:19, 2192:12, 2206:22, 2211:9,
2211:10, 2216:18, 2221:1, 2221:4,
2232:13, 2237:5, 2238:1
fascinating [1] - 2039:23
fashion [1] - 2246:18
fast [2] - 2140:8, 2140:12
father [6] - 2107:5, 2202:20, 2202:25,
2203:2, 2203:15, 2204:25
fault [1] - 2128:1
Fazel [2] - 1971:20, 1971:21
FAZEL [2] - 2090:21, 2227:15
FBI [23] - 1984:15, 1984:16, 2008:19,
2094:2, 2176:24, 2177:9, 2177:13,
2177:18, 2178:2, 2178:14, 2179:2,
2179:9, 2181:1, 2181:3, 2182:4,
2182:6, 2185:1, 2186:1, 2188:21,
2199:18, 2200:6, 2200:13, 2233:20
FDIC [1] - 2116:23
feasible [1] - 2235:3
feature [1] - 2197:24
featured [1] - 2213:12
February [2] - 2011:2, 2040:8
federal [1] - 2203:9
fee [1] - 1976:1
feelings [1] - 2166:10
Felipe [1] - 2134:20
fellow [2] - 2185:9, 2202:11
felt [2] - 2040:13, 2042:13
female [1] - 2182:10
Ferrance [2] - 2043:3, 2064:17
few [16] - 1983:9, 1983:10, 1991:6,
2021:20, 2084:19, 2103:15, 2108:17,
2134:8, 2136:7, 2141:2, 2142:10,
2143:10, 2166:6, 2219:7, 2239:12,
2244:2
field [9] - 2025:7, 2025:9, 2025:14,
2025:15, 2076:10, 2211:15, 2214:23,
2215:13, 2216:17
fields [1] - 2025:10
Johnny C. Sanchez, RMR, CRR - [email protected]
2270
fifth [1] - 2021:14
fight [1] - 2226:8
file [5] - 2008:4, 2047:11, 2049:6,
2062:25, 2093:22
filed [1] - 2052:18
files [27] - 1996:20, 2014:2, 2058:22,
2072:4, 2072:7, 2072:11, 2093:1,
2093:2, 2093:8, 2093:11, 2093:18,
2093:19, 2093:20, 2093:22, 2093:25,
2094:5, 2094:9, 2094:11, 2094:13,
2095:1, 2095:5, 2095:8, 2095:10,
2095:12, 2095:13
filing [2] - 2093:20, 2094:16
fill [2] - 2047:23, 2130:23
finalized [1] - 1986:10
finally [3] - 2060:2, 2060:6, 2139:6
finance [3] - 2101:16, 2168:12,
2204:17
Finance [2] - 2087:13, 2087:14
finances [1] - 2141:10
Financial [7] - 2005:19, 2006:2,
2007:9, 2068:25, 2132:19, 2135:20,
2239:20
financial [58] - 2000:11, 2004:18,
2005:3, 2006:23, 2007:19, 2009:18,
2028:9, 2028:14, 2030:24, 2031:5,
2031:14, 2031:17, 2031:25, 2032:7,
2032:12, 2032:13, 2032:19, 2032:24,
2033:9, 2066:12, 2074:17, 2101:20,
2125:7, 2125:8, 2130:13, 2133:14,
2133:16, 2147:5, 2158:11, 2158:14,
2160:9, 2169:19, 2174:11, 2198:22,
2198:25, 2199:4, 2199:15, 2199:16,
2199:20, 2199:22, 2199:25, 2200:2,
2203:21, 2203:24, 2211:4, 2221:15,
2222:7, 2228:8, 2229:4, 2229:8,
2233:6, 2233:8, 2233:9, 2233:10,
2238:13, 2238:16, 2249:9
financially [3] - 2173:2, 2173:5,
2235:2
financials [1] - 2228:10
findings [2] - 2000:25, 2067:13
fine [5] - 1983:25, 2022:11, 2063:9,
2127:25, 2152:19
finest [1] - 2076:9
Fingervoedt [1] - 2062:15
finish [1] - 2144:13
finished [6] - 2041:11, 2096:5, 2189:4,
2201:3, 2212:8, 2232:5
finishes [1] - 2197:5
fire [1] - 2068:6
firm [11] - 2009:5, 2100:15, 2100:16,
2101:7, 2160:16, 2160:21, 2161:1,
2161:8, 2220:18, 2220:24, 2226:7
Firm [1] - 1972:6
firms [4] - 2100:19, 2100:21, 2100:22,
2220:21
first [74] - 1983:23, 1984:4, 1986:14,
1987:18, 1988:13, 1990:2, 2000:6,
2018:7, 2021:6, 2028:17, 2029:6,
2029:7, 2030:8, 2030:18, 2033:10,
2033:11, 2035:22, 2036:3, 2037:2,
2037:5, 2040:8, 2042:23, 2043:5,
2054:22, 2055:4, 2056:12, 2057:2,
2057:3, 2057:17, 2063:16, 2071:1,
2079:18, 2085:24, 2087:19, 2099:5,
2101:10, 2102:21, 2104:23, 2108:12,
2108:17, 2119:19, 2120:2, 2120:25,
2121:8, 2123:6, 2123:22, 2127:15,
2130:10, 2148:25, 2151:5, 2153:23,
2163:18, 2166:20, 2168:19, 2177:6,
2178:5, 2180:1, 2181:2, 2181:12,
2184:21, 2186:13, 2187:13, 2187:14,
2192:6, 2228:14, 2228:17, 2230:7,
2233:22, 2240:25, 2241:1, 2250:2,
2256:16, 2257:2
fit [1] - 2007:14
fits [1] - 2003:22
five [14] - 2017:20, 2020:18, 2039:5,
2048:5, 2051:2, 2051:7, 2079:16,
2086:6, 2086:12, 2151:7, 2229:15,
2229:17, 2244:14
five-year [1] - 2244:14
fixed [5] - 2208:23, 2208:25, 2244:11,
2253:10, 2255:7
fixing [1] - 2059:10
flags [1] - 2186:8
fleet [1] - 2137:10
flexibility [2] - 2203:10, 2240:25
flip [1] - 2057:5
flipped [1] - 2256:7
flips [1] - 2256:6
float [1] - 2193:1
Floor [2] - 1971:22, 1972:4
floor [1] - 2201:3
floors [3] - 2141:14, 2141:15, 2141:24
Florida [5] - 2018:5, 2018:7, 2018:11,
2018:12, 2220:25
fly [4] - 2024:7, 2024:15
focus [9] - 2028:4, 2069:14, 2073:11,
2091:14, 2133:21, 2134:3, 2134:6,
2134:7, 2134:10
focused [8] - 2104:9, 2104:21,
2104:22, 2108:20, 2120:6, 2168:21,
2168:25, 2234:7
focussing [1] - 2006:13
folks [3] - 2034:22, 2108:7, 2165:8
follow [3] - 1992:16, 2216:24, 2256:2
following [6] - 1975:1, 2038:23,
2047:8, 2053:1, 2079:22, 2155:12
follows [4] - 2002:16, 2064:1, 2099:6,
2209:11
FOR [3] - 1971:13, 1971:20, 1972:2
for-sale [3] - 2171:15, 2171:16
forced [2] - 2060:15, 2060:16
foregoing [1] - 2257:10
foreign [1] - 2055:5
Form [1] - 2072:8
form [15] - 1976:18, 1978:4, 1978:7,
2031:5, 2048:10, 2048:12, 2048:25,
2049:1, 2049:2, 2049:3, 2070:21,
2080:19, 2112:8, 2117:22, 2145:12
formal [1] - 2119:10
Formalities [1] - 2050:25
formally [1] - 2047:12
formed [1] - 2074:16
former [7] - 2008:19, 2008:23,
2008:25, 2009:14, 2009:21, 2039:2,
2094:2
forming [1] - 2032:5
forms [2] - 2058:21, 2059:5
forth [6] - 2060:5, 2061:14, 2061:20,
2063:25, 2151:23, 2214:15
foundation [8] - 2110:2, 2110:5,
2110:22, 2112:6, 2112:13, 2112:16,
2114:13, 2116:14
four [12] - 2039:10, 2039:16, 2048:5,
2100:25, 2108:9, 2135:3, 2135:13,
2171:7, 2171:9, 2171:12, 2171:18
four-story [1] - 2135:3
fourth [2] - 2021:12, 2122:18
fragile [1] - 2163:14
framework [2] - 2010:1, 2015:15
franchise [4] - 2215:25, 2216:5,
2216:6, 2216:13
franchises [1] - 2216:7
Francis [1] - 2043:12
Frans [2] - 2057:13, 2062:15
fraud [3] - 2032:1, 2032:15, 2191:17
fraudulent [2] - 2215:17, 2235:12
free [5] - 2032:1, 2032:14, 2098:17,
2098:20, 2256:24
freeholds [1] - 2208:20
French [1] - 2134:24
frequently [2] - 2164:12, 2164:24
Friday [2] - 2093:4, 2096:17
friends [4] - 2131:18, 2131:19,
2195:15, 2195:17
front [10] - 1980:21, 1983:24, 1994:2,
2002:13, 2050:14, 2061:24, 2062:5,
2082:2, 2087:19, 2195:5
fruition [1] - 2210:10
frustrated [3] - 2001:15, 2001:21,
2001:23
FSRC [27] - 1978:1, 1978:17, 1997:4,
2060:17, 2060:21, 2061:4, 2061:7,
2062:22, 2064:6, 2065:2, 2069:5,
2069:6, 2074:19, 2074:22, 2075:2,
2076:13, 2077:2, 2077:21, 2077:24,
2078:12, 2078:14, 2080:17, 2081:6,
2083:12, 2084:21, 2085:3, 2085:11
FSRC's [1] - 1985:8
Ft [1] - 2099:15
full [10] - 1975:3, 1975:4, 2000:7,
2028:4, 2121:23, 2122:13, 2151:5,
2154:9, 2217:9
fully [4] - 2059:8, 2062:21, 2123:23,
2124:14
fun [1] - 2213:11
function [3] - 2072:6, 2101:19, 2199:2
functions [1] - 2007:4
Fund [7] - 2117:8, 2117:13, 2118:2,
2161:25, 2162:10, 2165:11, 2166:14
fund [17] - 1981:21, 1982:16, 2076:15,
2121:24, 2122:2, 2124:2, 2124:9,
2124:13, 2135:15, 2149:18, 2152:6,
2153:3, 2162:15, 2162:20, 2163:2,
Johnny C. Sanchez, RMR, CRR - [email protected]
2271
2186:2, 2235:16
funded [5] - 2123:23, 2185:21, 2188:7,
2234:21, 2237:12
funding [5] - 2126:23, 2135:18,
2142:8, 2191:13, 2243:12
funds [9] - 2076:15, 2077:25, 2083:13,
2084:12, 2115:20, 2126:24, 2146:23,
2223:8, 2243:25
furtherance [2] - 2065:14
G
GAAP [9] - 2221:21, 2221:23, 2222:8,
2222:11, 2222:13, 2223:18, 2230:10,
2230:11, 2238:20
gambling [2] - 2006:21, 2006:22
game [2] - 2082:2, 2217:5
gears [1] - 2221:9
general [14] - 1975:25, 1990:10,
1992:11, 2013:17, 2024:11, 2041:1,
2070:1, 2071:25, 2095:4, 2128:7,
2161:7, 2188:4, 2190:17, 2241:18
generally [11] - 1975:14, 1975:20,
1975:22, 2015:18, 2023:2, 2081:2,
2154:15, 2160:4, 2186:13, 2194:17,
2253:11
generated [1] - 2209:13
generates [1] - 2177:13
generous [3] - 2172:15, 2172:16,
2172:22
Geneva [9] - 2118:16, 2118:24,
2119:2, 2119:5, 2230:21, 2231:21,
2231:24, 2232:1, 2232:3
gentleman [8] - 1985:1, 1985:3,
1994:23, 2009:17, 2009:24, 2042:24,
2043:3, 2204:25
gentlemen [3] - 2151:6, 2155:8,
2202:5
gerber [3] - 1984:11, 1984:12, 2009:1
GIBL [6] - 1988:9, 1990:24, 2015:5,
2027:11, 2033:5, 2033:18
Gilbert [2] - 2039:13, 2039:14
gist [1] - 2013:14
given [8] - 1987:4, 2003:21, 2037:16,
2038:14, 2052:2, 2111:8, 2163:25,
2177:15
glue [1] - 2018:23
GM [1] - 2253:6
go-round [2] - 2240:25, 2241:1
goal [1] - 2242:20
gold [1] - 2039:10
Goswick [7] - 1990:9, 1993:7,
2002:15, 2105:9, 2105:16, 2105:23,
2204:1
Government [8] - 2006:10, 2148:9,
2149:21, 2155:19, 2156:8, 2157:2,
2158:21, 2158:24
GOVERNMENT [1] - 1971:13
government [58] - 1988:8, 1990:22,
1992:25, 1993:9, 1995:18, 1996:10,
1996:11, 1996:16, 1996:17, 1997:8,
1997:14, 1997:16, 2003:13, 2005:6,
2005:10, 2007:15, 2007:18, 2008:5,
2008:7, 2008:11, 2010:19, 2037:3,
2038:21, 2051:15, 2051:24, 2052:11,
2061:13, 2061:17, 2067:13, 2067:20,
2069:17, 2072:1, 2072:19, 2086:22,
2087:2, 2087:3, 2087:23, 2097:16,
2150:4, 2164:22, 2164:23, 2192:18,
2196:3, 2205:17, 2205:18, 2205:19,
2205:21, 2206:3, 2206:7, 2207:6,
2208:16, 2208:19, 2209:14, 2209:17,
2247:24, 2255:6, 2255:8, 2255:12
government's [2] - 2083:2, 2227:23
Government's [39] - 1979:25, 1985:17,
1988:4, 1993:3, 2017:8, 2017:18,
2022:13, 2027:17, 2027:19, 2029:5,
2030:7, 2055:12, 2055:17, 2055:21,
2055:24, 2056:3, 2056:6, 2056:13,
2057:5, 2057:11, 2057:25, 2058:10,
2062:4, 2063:3, 2064:10, 2066:21,
2077:5, 2080:2, 2085:25, 2086:6,
2086:14, 2088:16, 2222:25, 2227:17,
2230:2, 2246:21, 2246:23, 2247:12
governmental [1] - 1996:14
governments [3] - 2005:2, 2247:24,
2253:10
governor's [1] - 1993:10
grab [2] - 2045:17, 2097:23
graduating [1] - 2100:13
grand [1] - 2196:17
granite [1] - 2141:9
granted [4] - 2002:20, 2067:18,
2086:20, 2087:20
great [2] - 2006:15, 2136:6
Great [2] - 2221:22, 2222:1
Greenberg [1] - 2009:7
Gregg [1] - 1971:13
ground [3] - 2042:6, 2082:3, 2162:20
Grounds [1] - 2086:14
grounds [2] - 2086:12, 2139:2
Group [3] - 2132:19, 2135:20, 2136:3
group [12] - 2007:8, 2008:9, 2011:14,
2011:17, 2013:21, 2014:1, 2019:20,
2119:13, 2134:14, 2228:16, 2243:2
growth [1] - 2036:20
Guana [2] - 2218:22, 2219:2
guaranteed [2] - 2253:10, 2255:6
Guardian [53] - 1992:10, 1992:12,
1993:19, 1994:13, 1994:15, 1995:1,
1995:4, 1995:12, 1995:21, 1995:23,
1995:25, 1996:20, 2002:17, 2002:20,
2015:7, 2015:9, 2015:12, 2016:1,
2016:10, 2067:18, 2067:22, 2086:20,
2087:20, 2098:6, 2102:14, 2102:22,
2104:15, 2106:16, 2107:14, 2107:23,
2109:3, 2111:4, 2111:14, 2114:8,
2114:12, 2118:18, 2122:25, 2123:2,
2123:3, 2123:4, 2123:7, 2123:10,
2124:1, 2124:8, 2124:9, 2127:2,
2133:4, 2133:6, 2133:7, 2133:14,
2188:2, 2188:4, 2233:24
Guardian's [1] - 1992:8
guess [5] - 1999:9, 2138:23, 2170:23,
2179:7, 2225:25
guided [1] - 2053:19
guidelines [1] - 1982:3
guy [13] - 2172:18, 2172:25, 2175:10,
2180:10, 2180:13, 2180:19, 2182:22,
2191:7, 2198:15, 2215:23, 2216:3,
2216:12, 2255:25
guys [4] - 2193:13, 2195:19, 2202:15,
2225:21
H
hair [2] - 1999:18, 1999:24
half [5] - 2111:21, 2136:9, 2160:23,
2166:13, 2198:10
halfway [1] - 2154:4
Hamilton [1] - 2220:23
hand [10] - 2030:9, 2036:4, 2041:7,
2073:12, 2073:13, 2099:2, 2114:5,
2154:14, 2156:8, 2239:15
handed [9] - 1998:23, 2000:13,
2000:15, 2000:17, 2000:19, 2035:13,
2035:14, 2035:15, 2036:19
handing [3] - 2000:11, 2063:2, 2066:3
handling [1] - 2182:14
hands [16] - 2180:10, 2180:13,
2180:18, 2181:8, 2181:14, 2182:13,
2182:22, 2182:24, 2182:25, 2183:5,
2233:23, 2234:7
hands-off [7] - 2180:10, 2180:13,
2180:18, 2181:8, 2181:14, 2182:13,
2183:5
hands-on [9] - 2180:10, 2181:8,
2182:13, 2182:22, 2182:24, 2182:25,
2183:5, 2233:23, 2234:7
handwriting [1] - 2045:8
handwritten [2] - 2045:1, 2045:2
hang [2] - 2076:19, 2153:25
hangar [21] - 2024:1, 2024:2, 2024:8,
2024:9, 2024:10, 2080:17, 2081:7,
2084:25, 2137:7, 2137:8, 2137:9,
2138:4, 2144:18, 2144:20, 2196:5,
2236:7, 2236:8, 2236:25, 2242:23,
2250:9
hangars [2] - 2209:1, 2250:5
happy [4] - 2078:17, 2112:15, 2189:23
hard [8] - 1980:22, 2157:7, 2159:10,
2166:20, 2189:16, 2213:21, 2214:17,
2253:25
harder [1] - 2030:4
hardwood [3] - 2141:14, 2141:15,
2141:24
hardwoods [1] - 2141:18
Harold [4] - 2008:19, 2008:21, 2014:9,
2094:2
hastily [2] - 2064:20, 2064:21
head [5] - 2009:17, 2029:11, 2085:17,
2188:22, 2190:19
heading [1] - 2031:1
headquarters [1] - 2192:6
health [2] - 2136:18, 2215:2
hear [8] - 2063:7, 2070:24, 2076:20,
2076:21, 2078:6, 2216:3, 2218:6,Johnny C. Sanchez, RMR, CRR - [email protected]
2272
2240:8
heard [13] - 1990:16, 1999:4, 2068:6,
2113:10, 2123:17, 2130:22, 2153:7,
2180:1, 2201:17, 2218:5, 2218:8,
2218:10, 2254:7
hearing [2] - 2203:8, 2235:7
hearsay [8] - 2052:6, 2105:25, 2106:1,
2110:3, 2110:8, 2180:15, 2203:4,
2203:7
heart [1] - 2019:19
held [8] - 1975:1, 1982:21, 1988:20,
2038:23, 2079:22, 2100:9, 2155:12
Hello [1] - 1984:8
help [21] - 1988:21, 2007:18, 2010:16,
2027:19, 2034:15, 2041:4, 2041:13,
2049:16, 2049:18, 2057:22, 2072:6,
2072:11, 2095:25, 2097:12, 2133:1,
2133:13, 2149:18, 2191:8, 2219:21,
2226:8
helped [4] - 2132:12, 2176:13, 2232:2,
2249:21
helping [7] - 2009:25, 2010:19,
2094:21, 2124:2, 2152:6, 2193:13,
2221:2
helps [1] - 2097:14
hereby [1] - 2053:16
herein [1] - 2064:1
hereinafter [3] - 2002:11, 2063:19,
2063:22
hesitating [1] - 2029:19
Hewlett [18] - 2026:9, 2026:18,
2026:24, 2027:1, 2027:7, 2028:1,
2029:3, 2032:10, 2033:2, 2074:9,
2074:12, 2074:15, 2075:10, 2075:19,
2159:23, 2160:1, 2160:12, 2160:15
Hewlett's [4] - 2029:24, 2030:22,
2074:22, 2075:11
hi [1] - 2112:25
high [17] - 1987:13, 2039:23, 2102:7,
2102:8, 2165:6, 2165:14, 2195:21,
2195:22, 2195:23, 2196:10, 2219:12,
2225:20, 2236:14, 2236:18, 2236:23,
2237:17
High [2] - 1990:4, 2086:10
high-end [6] - 2165:6, 2165:14,
2219:12, 2236:14, 2236:18, 2237:17
high-net-worth [2] - 2195:23, 2196:10
high-quality [1] - 2236:23
highest [1] - 1993:20
highlight [10] - 2111:22, 2118:11,
2148:24, 2151:4, 2159:12, 2207:20,
2208:8, 2247:13, 2252:23, 2255:1
highlighted [5] - 2090:23, 2090:24,
2113:9, 2181:6, 2184:21
highly [2] - 2242:14, 2253:13
himself [6] - 2093:10, 2094:13,
2115:3, 2195:3, 2195:4, 2225:15
hinder [1] - 2072:6
hindered [1] - 2072:13
hire [13] - 2104:7, 2106:9, 2106:22,
2106:23, 2161:5, 2172:1, 2172:12,
2173:12, 2173:19, 2174:7, 2174:9,
2174:11, 2178:20
hired [23] - 2042:11, 2106:14, 2106:16,
2106:24, 2120:12, 2133:4, 2162:22,
2170:14, 2170:21, 2170:22, 2172:4,
2172:10, 2172:13, 2173:6, 2175:2,
2175:6, 2175:18, 2181:25, 2198:15,
2199:19, 2200:1, 2202:9, 2220:18
hiring [2] - 2219:21, 2226:7
history [3] - 2003:12, 2105:11,
2105:13
hit [5] - 1983:12, 2042:6, 2161:8,
2161:20, 2214:17
HITTNER [1] - 1971:10
hold [10] - 1977:5, 1987:8, 1987:12,
2017:19, 2022:19, 2037:9, 2038:1,
2083:16, 2087:11, 2115:5
holders' [1] - 2234:22
holding [2] - 2087:10, 2087:11
holds [1] - 2246:3
Holloway [1] - 2164:5
home [8] - 2120:13, 2130:16, 2166:13,
2167:5, 2178:23, 2178:24, 2182:19,
2219:13
homebuilder [2] - 2101:13, 2101:14
homebuilding [1] - 2101:25
Homes [4] - 2101:14, 2101:22,
2101:24, 2169:19
homework [1] - 2193:4
Honor [69] - 1975:7, 1980:7, 1983:2,
1989:8, 1989:16, 1989:19, 2017:15,
2022:22, 2035:13, 2036:12, 2036:25,
2038:2, 2038:21, 2044:25, 2051:20,
2051:25, 2062:1, 2062:7, 2063:5,
2065:25, 2067:9, 2070:10, 2073:7,
2077:9, 2077:13, 2078:8, 2079:6,
2079:14, 2079:25, 2080:5, 2083:4,
2084:14, 2088:12, 2090:15, 2098:1,
2098:12, 2098:21, 2112:22, 2116:7,
2117:10, 2142:22, 2143:2, 2143:8,
2143:15, 2147:18, 2151:3, 2153:14,
2153:21, 2155:7, 2155:14, 2157:3,
2169:7, 2200:10, 2203:4, 2207:4,
2207:14, 2227:2, 2227:15, 2227:20,
2232:5, 2240:4, 2243:8, 2244:1,
2245:22, 2252:17, 2253:25, 2254:22,
2256:22, 2256:25
Honorable [2] - 1990:12, 2002:9
HONORABLE [1] - 1971:10
hope [2] - 2058:3, 2250:6
hopefully [2] - 2084:15, 2224:15
horse [1] - 1999:24
hospital [2] - 2209:23, 2209:24
hot [2] - 1999:20, 1999:24
hour [1] - 2034:23
house [2] - 2023:5, 2179:9
houses [13] - 1978:15, 1978:25,
1979:4, 1979:5, 1979:6, 1979:22,
2024:25, 2134:11, 2134:16, 2135:10,
2190:24, 2197:25, 2198:2
housing [1] - 2197:18
HOUSTON [1] - 1971:2
Houston [33] - 1971:4, 1971:15,
1971:23, 1972:4, 1972:7, 1972:11,
1972:19, 2099:16, 2100:2, 2100:4,
2100:14, 2102:5, 2102:11, 2102:25,
2103:1, 2105:5, 2107:20, 2120:10,
2120:11, 2121:2, 2121:19, 2122:8,
2122:9, 2134:19, 2170:20, 2171:7,
2171:10, 2171:11, 2171:19, 2186:18,
2186:19, 2220:23, 2256:10
Howard [1] - 1971:16
Hrdlicka [1] - 2226:8
huge [3] - 2146:4, 2146:9, 2226:23
hundred [3] - 2170:3, 2181:18,
2181:23
hundreds [8] - 2037:25, 2038:1,
2152:16, 2211:23, 2212:1, 2212:3,
2212:5, 2242:5
hurricanes [2] - 2163:14, 2163:18
hypergrowth [1] - 2006:6
I
IB [2] - 2085:12, 2085:14
IB5 [8] - 1978:4, 1978:6, 1978:7,
1978:11, 1978:12, 1978:21, 1979:21
IB5s [3] - 1978:17, 1978:20, 1978:23
IBC [9] - 2001:20, 2048:1, 2052:11,
2058:25, 2065:7, 2065:10, 2089:2,
2090:5, 2090:21
IBM [2] - 2253:22
idea [31] - 1987:20, 1987:22, 1990:21,
1992:8, 2006:24, 2120:15, 2120:16,
2133:24, 2161:23, 2162:9, 2163:7,
2163:11, 2165:1, 2165:4, 2165:11,
2172:1, 2181:25, 2193:16, 2194:24,
2197:11, 2215:11, 2215:23, 2217:6,
2217:13, 2218:10, 2218:11, 2219:5,
2219:10, 2232:20, 2232:22, 2242:25
identified [14] - 2017:12, 2017:13,
2017:14, 2022:17, 2022:20, 2022:24,
2058:20, 2104:4, 2143:3, 2153:22,
2227:21, 2227:23, 2227:24, 2228:15
identity [1] - 2048:7
idiomatic [1] - 2081:24
IFRS [5] - 2221:13, 2222:8, 2238:9,
2238:12, 2239:18
IFSA [3] - 2010:20, 2095:23, 2097:13
illegal [1] - 2223:17
immediately [1] - 2048:12
immigration [1] - 2196:12
implementation [1] - 2040:18
implemented [3] - 2059:6, 2059:8,
2062:21
implementing [1] - 2060:5
import [5] - 2141:5, 2141:8, 2164:10,
2164:11, 2164:13
importance [3] - 2000:15, 2000:16,
2169:2
important [5] - 1988:8, 1988:17,
1991:2, 2003:13, 2194:20
impose [1] - 2004:18
impossible [1] - 2216:7
impression [2] - 2128:20, 2128:21
improper [2] - 1988:22, 2008:5
improperly [1] - 2016:6Johnny C. Sanchez, RMR, CRR - [email protected]
2273
improve [1] - 2041:19
improved [4] - 2002:1, 2209:18,
2209:20, 2213:3
improvements [1] - 2209:21
improving [1] - 2162:18
inaccurate [1] - 2050:19
incident [1] - 2014:2
include [4] - 2007:1, 2031:12, 2059:7,
2163:9
included [4] - 1978:11, 2066:14,
2141:8, 2254:14
includes [2] - 1978:12, 2031:15
including [4] - 2132:7, 2151:5,
2167:24, 2249:17
income [1] - 2225:6
inconsistent [1] - 2216:10
incorporated [1] - 2040:25
incorporation [1] - 2048:1
incorrect [1] - 2095:6
increments [2] - 2244:14
Independent [2] - 2100:3, 2159:15
independent [7] - 2031:6, 2032:12,
2074:16, 2159:18, 2159:21, 2160:1,
2160:4
India [1] - 2213:16
indicate [2] - 1977:3, 2051:8
indicated [1] - 2023:23
indicates [1] - 2087:7
indicating [1] - 2092:22
indication [1] - 2051:10
indicted [1] - 2047:12
Indies [12] - 2018:16, 2018:24, 2019:9,
2019:17, 2019:25, 2020:1, 2020:2,
2020:18, 2063:22, 2213:24, 2214:1
indies [1] - 2019:24
indirect [1] - 2046:15
individual [9] - 1975:17, 1982:10,
2107:1, 2135:21, 2163:15, 2197:25,
2198:1, 2233:24, 2241:25
individuals [3] - 2010:18, 2013:21,
2115:8
indulgence [1] - 1982:25
Industries [1] - 2101:11
industry [7] - 2005:3, 2011:11, 2042:1,
2070:19, 2076:7, 2101:9, 2101:10
inexpensive [1] - 2211:19
influence [2] - 2232:14, 2232:21
inform [3] - 1993:8, 1998:8, 2046:5
information [79] - 1975:17, 1975:19,
1975:20, 1975:22, 1975:25, 1976:2,
1976:6, 1976:7, 1976:8, 1976:9,
1978:8, 1978:11, 1978:12, 1978:19,
1979:3, 1987:1, 1988:17, 1995:11,
1997:7, 1997:9, 2001:22, 2014:25,
2016:17, 2016:18, 2016:22, 2016:24,
2031:23, 2032:6, 2033:25, 2034:1,
2034:3, 2034:5, 2041:25, 2047:2,
2047:4, 2047:9, 2047:20, 2048:16,
2049:6, 2049:10, 2049:12, 2049:14,
2050:6, 2052:19, 2053:1, 2053:17,
2053:24, 2054:1, 2054:4, 2054:6,
2054:15, 2055:1, 2055:6, 2062:20,
2066:12, 2066:15, 2073:2, 2073:19,
2073:22, 2073:23, 2074:25, 2075:18,
2089:6, 2091:13, 2091:22, 2092:4,
2092:21, 2127:16, 2128:4, 2157:23,
2175:4, 2176:10, 2183:12, 2183:14,
2183:21, 2220:9, 2221:11, 2221:12,
2251:16
information-sharing [1] - 2055:1
informed [3] - 1992:25, 1993:11,
1993:12
informing [1] - 1995:3
infrastructure [7] - 2040:18, 2162:18,
2163:5, 2164:14, 2164:19, 2212:17,
2220:9
ing [1] - 2252:8
initial [6] - 1980:12, 2092:4, 2104:11,
2162:22, 2199:24, 2201:25
inquire [1] - 2145:4
inquired [1] - 2145:10
inquiries [1] - 2092:15
inquiry [1] - 2057:17
inserted [1] - 2010:11
insistent [1] - 2201:6
instance [2] - 2097:4, 2256:14
instances [1] - 1976:6
instead [4] - 2073:22, 2172:25,
2199:20, 2222:8
institution [2] - 2046:14, 2046:16
institutions [2] - 1979:10, 1979:17
instruction [1] - 2035:1
instrument [2] - 2244:20, 2246:2
instruments [2] - 2046:9, 2114:10
insurance [13] - 2007:1, 2115:23,
2116:9, 2116:12, 2116:17, 2116:21,
2116:23, 2117:1, 2117:4, 2117:15,
2117:21, 2118:2, 2202:24
Insurance [3] - 2117:8, 2117:13,
2118:1
intended [2] - 2006:5, 2087:3
intends [1] - 2035:16
intent [2] - 2209:25, 2210:1
intention [4] - 1993:1, 1993:9,
1993:13, 1998:9
intentionally [1] - 2238:20
interaction [5] - 2069:12, 2189:18,
2232:23, 2232:25, 2233:5
interest [5] - 2063:25, 2096:25,
2151:22, 2187:3, 2244:12
interested [7] - 2126:22, 2130:19,
2162:17, 2186:7, 2200:20, 2247:7
interesting [1] - 2083:10
Internal [5] - 2225:13, 2225:16,
2225:24, 2226:1, 2226:8
international [41] - 2004:4, 2006:12,
2006:13, 2006:15, 2006:22, 2006:23,
2007:1, 2007:2, 2010:1, 2011:21,
2011:22, 2012:1, 2014:20, 2015:22,
2028:13, 2031:12, 2032:23, 2036:20,
2052:12, 2072:2, 2090:7, 2095:14,
2100:18, 2125:10, 2158:11, 2158:14,
2160:21, 2161:1, 2213:25, 2221:15,
2221:23, 2223:19, 2230:9, 2230:18,
2238:12, 2239:12, 2239:20, 2240:21,
2249:9, 2253:12, 2253:16
International [71] - 1975:15, 1976:12,
1976:13, 1976:17, 1977:17, 1978:16,
1978:22, 1979:14, 1979:21, 1980:3,
1980:15, 1993:19, 1994:13, 1994:15,
1995:1, 1995:4, 1995:12, 1995:22,
1995:23, 1995:25, 1996:21, 2002:17,
2002:21, 2005:19, 2006:2, 2016:2,
2016:10, 2023:11, 2043:6, 2043:23,
2046:1, 2046:10, 2046:21, 2047:22,
2050:16, 2056:18, 2057:3, 2057:9,
2063:20, 2067:18, 2067:23, 2074:5,
2086:20, 2087:20, 2098:7, 2102:14,
2102:22, 2104:15, 2106:17, 2107:15,
2107:23, 2114:8, 2133:6, 2139:14,
2141:16, 2148:12, 2149:18, 2151:21,
2154:25, 2156:24, 2157:6, 2162:5,
2169:5, 2169:6, 2188:5, 2195:12,
2195:16, 2208:22, 2210:16, 2232:25,
2246:16
Internet [5] - 2006:21, 2006:22,
2040:22, 2040:24, 2041:21
interruption [1] - 2128:17
intervals [1] - 1979:7
interview [20] - 2042:15, 2103:9,
2103:11, 2104:11, 2104:23, 2105:12,
2173:14, 2177:13, 2178:5, 2178:6,
2178:13, 2178:23, 2181:1, 2182:13,
2183:6, 2184:19, 2185:23, 2200:13,
2201:25, 2233:22
interviewed [9] - 2172:8, 2172:19,
2176:24, 2177:3, 2177:10, 2182:6,
2183:2, 2185:9, 2202:12
interviewing [3] - 2103:17, 2104:16,
2202:2
interviews [3] - 2177:22, 2178:3,
2233:20
introduce [2] - 2089:14, 2099:11
introduced [3] - 1984:8, 1989:16,
2027:16
invest [21] - 1979:8, 1979:19, 2120:3,
2121:10, 2121:22, 2122:11, 2123:11,
2123:15, 2129:5, 2170:10, 2170:24,
2171:3, 2171:5, 2172:2, 2216:13,
2244:22, 2245:7, 2245:10, 2250:1,
2255:17, 2255:21
invested [10] - 1978:14, 2111:6,
2129:12, 2167:11, 2247:7, 2248:10,
2249:1, 2249:2, 2250:18, 2250:24
investigation [2] - 2016:4, 2016:11
investigations [1] - 2092:15
investing [10] - 1979:17, 2016:23,
2124:24, 2125:1, 2163:11, 2215:11,
2215:24, 2231:7, 2246:18, 2248:22
investment [45] - 1977:19, 1978:9,
1978:13, 1978:14, 1978:15, 1978:24,
1979:4, 1979:5, 1979:6, 1979:9,
1979:22, 1981:13, 2016:25, 2085:15,
2107:19, 2111:20, 2111:24, 2113:11,
2113:23, 2115:1, 2115:9, 2119:13,
2126:7, 2126:18, 2129:4, 2133:25,
2135:7, 2149:4, 2162:13, 2162:14,
2163:2, 2165:17, 2165:19, 2165:22,Johnny C. Sanchez, RMR, CRR - [email protected]
2274
2165:24, 2166:1, 2166:2, 2183:24,
2184:2, 2237:19, 2248:8, 2248:11,
2255:19, 2256:12, 2256:19
Investment [13] - 2102:14, 2106:17,
2107:15, 2107:23, 2114:12, 2123:3,
2133:4, 2133:6, 2161:25, 2162:10,
2165:11, 2166:14, 2188:5
investment-type [1] - 2135:7
investments [22] - 1979:12, 1981:2,
1987:2, 2085:11, 2106:20, 2112:3,
2113:15, 2119:16, 2120:7, 2122:20,
2123:12, 2126:7, 2126:10, 2133:21,
2149:2, 2149:13, 2165:25, 2171:9,
2191:3, 2247:14, 2251:17, 2253:11
Investments [1] - 2247:18
investor [4] - 2076:14, 2077:25,
2083:13, 2084:12
investors [1] - 2035:3
invests [3] - 2245:2, 2246:8, 2247:4
invited [2] - 2103:9, 2138:23
involve [1] - 2121:1
involved [13] - 2012:3, 2094:10,
2125:12, 2132:11, 2139:25, 2141:12,
2161:24, 2163:4, 2200:16, 2210:4,
2255:23, 2256:7
involvement [6] - 2068:16, 2068:19,
2132:10, 2132:22, 2133:16, 2216:16
irregularities [1] - 2032:15
irregularity [1] - 2032:2
IRS [2] - 2225:19, 2226:3
island [33] - 2003:9, 2013:23, 2017:5,
2026:19, 2027:2, 2027:4, 2029:25,
2040:5, 2040:14, 2040:25, 2064:18,
2065:5, 2141:2, 2141:3, 2160:24,
2163:15, 2163:23, 2163:25, 2164:19,
2190:5, 2194:25, 2205:13, 2206:6,
2210:15, 2211:24, 2212:22, 2213:3,
2213:22, 2215:20, 2217:3, 2218:19,
2222:9, 2222:10
Island [20] - 2005:12, 2013:10,
2014:13, 2015:5, 2023:15, 2023:17,
2023:18, 2023:20, 2024:5, 2024:12,
2034:11, 2190:1, 2192:19, 2195:16,
2217:24, 2218:1, 2218:2, 2218:9,
2218:22, 2219:2
islands [21] - 2005:15, 2018:13,
2018:14, 2018:17, 2018:21, 2019:14,
2019:19, 2064:19, 2162:11, 2162:12,
2162:13, 2162:18, 2162:23, 2162:25,
2163:5, 2163:16, 2163:17, 2164:9,
2164:24, 2218:19, 2218:23
Islands [1] - 2005:16
isolated [1] - 2256:14
issue [18] - 1995:2, 1995:5, 1997:13,
2040:11, 2046:21, 2053:10, 2054:16,
2054:18, 2091:6, 2116:12, 2116:17,
2141:14, 2200:6, 2225:2, 2225:13,
2239:11, 2241:21, 2253:6
issued [2] - 2036:7, 2187:12
issues [3] - 2160:11, 2206:19, 2206:23
issuing [1] - 1995:7
Item [1] - 2067:16
items [3] - 1993:16, 2012:14, 2041:23
itself [11] - 1981:21, 1982:16, 1992:10,
2041:5, 2048:10, 2049:16, 2050:5,
2050:19, 2089:12, 2150:22, 2163:21
Ivan [2] - 2009:20, 2014:10
J
Jackson [1] - 2220:24
James [9] - 1990:8, 1993:7, 1993:14,
2002:14, 2105:9, 2198:16, 2199:24,
2202:18, 2202:19
January [5] - 1971:5, 2002:21,
2067:19, 2086:21, 2087:21
Jeffrey [1] - 2014:10
jeopardy [3] - 1981:22, 1982:17,
1982:23
jet [1] - 2195:25
jets [3] - 2138:5, 2196:11, 2218:4
Jim [4] - 2130:6, 2130:9, 2130:20,
2198:16
job [16] - 2001:13, 2013:22, 2026:10,
2097:1, 2160:5, 2160:6, 2166:11,
2167:19, 2168:2, 2168:4, 2170:4,
2172:8, 2172:19, 2172:20, 2176:13,
2185:10
jobs [5] - 2102:10, 2212:24, 2213:1,
2213:2, 2237:21
John [15] - 1972:2, 1983:20, 1993:11,
1993:13, 1993:15, 1994:12, 1995:17,
1997:12, 1998:8, 2000:10, 2000:15,
2000:16, 2000:17, 2000:20, 2039:3
John's [3] - 1997:19, 1998:3, 2063:21
johnny [1] - 2076:22
Johnny [7] - 1972:10, 1972:18,
1976:25, 2080:23, 2084:7, 2257:10,
2257:14
join [2] - 2005:6, 2005:10
joined [6] - 2068:22, 2068:24, 2069:6,
2069:7, 2069:10, 2069:17
Jonathan [1] - 2121:17
Jordan [1] - 1995:17
Journal [1] - 2103:1
Jr [1] - 1993:8
judge [9] - 1991:7, 1991:10, 1991:11,
2039:15, 2203:9, 2204:12, 2204:13,
2205:1
JUDGE [1] - 1971:10
Judge [61] - 1976:18, 1984:1, 1987:10,
1988:1, 1988:19, 1993:5, 1993:7,
1994:5, 1994:7, 1994:9, 1995:21,
1996:3, 1996:12, 1998:2, 1999:8,
1999:19, 2000:14, 2000:18, 2000:25,
2002:4, 2003:19, 2009:22, 2017:20,
2022:12, 2027:20, 2037:2, 2037:7,
2037:14, 2038:8, 2040:2, 2044:17,
2045:4, 2045:13, 2045:19, 2050:12,
2051:14, 2056:9, 2057:20, 2065:22,
2070:5, 2075:12, 2076:1, 2076:17,
2078:23, 2080:19, 2081:8, 2083:14,
2084:15, 2085:22, 2086:3, 2089:14,
2090:20, 2090:23, 2096:10, 2096:12,
2097:8, 2097:23, 2098:14, 2111:19,
2124:16, 2153:19
Judge's [8] - 1993:23, 1993:25,
1996:7, 2000:25, 2086:12, 2087:8,
2087:10, 2087:11
judged [1] - 2242:1
judges [2] - 1991:12, 2000:1
judgment [6] - 1990:18, 1994:3,
2002:6, 2002:7, 2002:11, 2032:13
judgments [1] - 2031:16
judicial [4] - 1996:2, 1997:23, 1999:6,
2066:19
July [1] - 2055:3
jump [2] - 2113:6, 2113:7
jumping [1] - 2129:14
June [5] - 2002:25, 2154:3, 2162:21,
2163:1, 2208:5
junior [1] - 2043:14
juries [1] - 2096:21
jurisdiction [5] - 1998:20, 2011:24,
2017:2, 2042:20, 2047:13
jurisdictions [3] - 1999:10, 2054:25,
2074:4
jury [47] - 1975:1, 1987:20, 1988:13,
1992:6, 2000:5, 2002:9, 2023:3,
2023:10, 2023:24, 2035:1, 2035:9,
2038:18, 2038:23, 2041:16, 2045:5,
2054:12, 2058:16, 2060:9, 2064:16,
2067:15, 2076:2, 2076:4, 2076:11,
2079:22, 2081:3, 2083:17, 2083:18,
2085:18, 2088:1, 2093:2, 2093:4,
2095:7, 2095:19, 2096:19, 2099:11,
2099:25, 2134:18, 2155:12, 2175:21,
2176:3, 2197:22, 2198:14, 2198:24,
2201:15, 2247:3, 2255:16
JURY [1] - 1971:7
jury's [1] - 2136:23
Justice [9] - 1971:17, 1990:4, 1990:13,
2002:9, 2039:2, 2039:7, 2039:19,
2086:10
justice [2] - 2002:10, 2039:8
justices [1] - 2039:6
K
K-N-O-C-H-E [1] - 2099:13
keep [12] - 1997:11, 2006:12, 2044:5,
2061:13, 2063:6, 2063:7, 2092:12,
2113:4, 2120:19, 2150:8, 2150:13,
2254:24
keeping [2] - 2017:14, 2054:20
Kenneth [5] - 1972:6, 1998:10, 2000:9,
2009:22, 2204:22
kind [19] - 1978:11, 2007:20, 2019:5,
2081:24, 2172:18, 2172:25, 2175:10,
2175:19, 2176:9, 2184:20, 2186:13,
2186:17, 2192:4, 2202:21, 2203:19,
2216:12, 2225:19, 2232:20, 2255:21
kinds [2] - 2041:16, 2179:18
Kingdom [2] - 2013:9, 2013:13
Kirby [1] - 2134:20
Knoche [38] - 2098:24, 2099:13,
2099:14, 2111:15, 2113:9, 2117:12,Johnny C. Sanchez, RMR, CRR - [email protected]
2275
2118:21, 2125:5, 2136:13, 2144:16,
2149:4, 2149:23, 2151:9, 2155:18,
2159:10, 2169:10, 2175:15, 2177:23,
2182:3, 2183:7, 2189:2, 2205:25,
2207:14, 2207:22, 2208:10, 2209:14,
2215:17, 2219:4, 2225:12, 2227:5,
2228:4, 2228:21, 2230:5, 2230:19,
2233:18, 2247:17, 2251:8, 2255:5
KNOCHE [2] - 1973:15, 2099:4
knock [1] - 2214:17
knowing [2] - 2176:12, 2247:7
knowledge [26] - 1976:22, 2015:1,
2025:18, 2028:25, 2046:3, 2053:6,
2064:7, 2070:6, 2081:9, 2084:13,
2088:24, 2093:13, 2093:16, 2094:6,
2094:18, 2094:19, 2094:20, 2112:7,
2114:14, 2131:2, 2131:5, 2131:6,
2152:20, 2161:10, 2212:19, 2251:22
known [2] - 2019:12, 2079:4
KPMG [1] - 2101:5
L
labor [1] - 1991:7
lack [1] - 2070:5
ladies [3] - 2057:22, 2151:6, 2155:8
lady [2] - 1984:16
laid [5] - 2110:5, 2196:16, 2196:18,
2237:3, 2237:5
land [15] - 2192:16, 2192:17, 2195:24,
2196:11, 2196:12, 2207:1, 2209:2,
2209:18, 2209:20, 2209:21, 2217:20,
2218:4, 2219:2
lands [4] - 2206:13, 2206:15, 2208:16,
2208:19
language [2] - 1990:24, 2050:19
lapel [3] - 1983:25, 1987:9, 1987:11
large [1] - 1998:24
larger [2] - 2129:25, 2160:20
largest [1] - 2100:21
Larry [3] - 2107:2, 2109:13, 2181:11
last [19] - 1982:1, 2001:17, 2002:3,
2035:19, 2040:4, 2067:10, 2084:19,
2087:9, 2087:19, 2091:14, 2099:12,
2100:12, 2135:5, 2135:14, 2135:22,
2161:22, 2217:7, 2219:7, 2255:2
late [8] - 2007:6, 2026:16, 2027:1,
2133:20, 2135:1, 2139:21, 2147:11,
2170:23
latest [1] - 1989:13
latter [1] - 2136:7
laundering [7] - 2004:10, 2004:17,
2004:22, 2004:23, 2016:5, 2016:12,
2070:1
Law [2] - 1972:3, 1972:6
law [14] - 1977:21, 1982:22, 1991:13,
1991:18, 2001:15, 2001:22, 2001:25,
2004:9, 2028:14, 2032:24, 2089:24,
2090:18, 2226:7, 2252:12
laws [13] - 1975:12, 1975:14, 1975:15,
1977:10, 1986:22, 1987:4, 2002:1,
2004:3, 2004:4, 2004:17, 2005:14,
2007:19
lawsuit [5] - 1990:20, 1992:7, 1992:9,
2226:1, 2226:2
lawyer [16] - 1985:5, 1985:10,
1985:13, 1985:14, 1985:15, 1985:16,
2001:8, 2009:8, 2009:15, 2009:16,
2096:17, 2178:20, 2204:14, 2204:15,
2205:1, 2205:2
lawyers [4] - 1984:22, 1990:15,
2009:7, 2088:20
lay [1] - 2112:15
Le [1] - 2134:21
LE [1] - 2134:25
leading [4] - 2014:25, 2075:14,
2123:19, 2124:4
learn [9] - 2003:11, 2105:11, 2106:7,
2107:17, 2123:14, 2124:12, 2124:20,
2187:8, 2204:4
learned [4] - 2000:3, 2065:3, 2108:23,
2129:19
lease [1] - 2206:15
leaseholds [1] - 2208:20
leases [1] - 2207:1
least [3] - 1983:24, 2039:19, 2179:6
leave [15] - 1993:1, 1993:20, 1995:5,
2061:15, 2095:15, 2098:17, 2098:20,
2101:22, 2101:24, 2154:2, 2167:6,
2206:5, 2219:18, 2230:19, 2256:24
leaving [2] - 1999:3, 2168:13
left [35] - 1985:2, 1985:19, 1985:23,
2018:4, 2030:9, 2036:4, 2045:9,
2057:25, 2060:10, 2065:2, 2073:13,
2081:3, 2085:1, 2085:2, 2093:4,
2114:5, 2136:14, 2138:12, 2148:5,
2151:11, 2162:20, 2166:7, 2198:3,
2198:7, 2198:10, 2208:5, 2211:6,
2211:15, 2212:1, 2215:4, 2217:22,
2218:21, 2219:3, 2232:19, 2234:10
left-hand [3] - 2030:9, 2073:13, 2114:5
legal [10] - 1976:5, 1999:18, 2001:14,
2001:15, 2026:4, 2046:15, 2095:3,
2095:9, 2095:11
legend [1] - 2019:12
legible [1] - 2053:8
legislation [5] - 2069:25, 2070:18,
2071:4, 2071:11, 2071:22
legislative [1] - 2012:4
legitimate [2] - 2224:5, 2224:6
length [2] - 2206:9, 2206:11
lengthy [1] - 2038:13
less [3] - 2014:21, 2143:17, 2170:5
letter [35] - 1990:23, 1992:5, 1993:2,
1994:25, 1995:2, 1995:5, 1995:7,
1995:18, 1996:10, 1996:11, 1996:14,
1996:16, 1997:13, 1997:15, 1998:7,
1998:25, 1999:1, 2002:25, 2003:12,
2013:1, 2036:5, 2038:10, 2046:6,
2046:21, 2047:15, 2048:19, 2052:22,
2053:14, 2054:3, 2054:15, 2057:16,
2062:12, 2103:8, 2130:2, 2166:21
letterhead [1] - 2045:22
letters [1] - 2059:14
level [7] - 1996:15, 2126:4, 2126:6,
2126:10, 2126:17, 2132:10, 2176:17
liability [2] - 2088:11, 2226:23
license [20] - 1981:22, 1982:17,
1982:22, 1988:9, 1988:20, 1991:3,
1992:8, 1992:12, 2000:11, 2000:16,
2000:17, 2067:23, 2068:3, 2086:13,
2087:21, 2087:22, 2088:4, 2092:9,
2098:7, 2130:3
licensed [2] - 2040:23, 2046:13
licenses [13] - 1991:1, 1998:19,
1998:25, 1999:2, 2000:13, 2000:20,
2002:20, 2067:18, 2086:19, 2087:12,
2088:2, 2212:11, 2212:16
lie [1] - 2251:13
life [1] - 2195:13
lifting [1] - 2094:21
light [1] - 2141:16
lighter [1] - 2141:20
lights [2] - 2143:14, 2143:16
limit [3] - 2079:17, 2167:17, 2196:23
limitations [1] - 2074:5
Limited [12] - 2002:17, 2063:20,
2067:19, 2086:20, 2087:20, 2117:13,
2118:2, 2188:2, 2208:24, 2209:8,
2246:16
limited [5] - 2114:8, 2119:19, 2122:22,
2188:6, 2188:7
Limits [1] - 2079:18
line [11] - 1982:1, 1985:24, 2015:11,
2042:5, 2059:18, 2083:17, 2083:23,
2112:9, 2196:13, 2241:14, 2254:15
lined [2] - 2167:19, 2256:15
lines [3] - 2084:23, 2252:24, 2255:2
link [1] - 2152:13
liquid [12] - 2125:2, 2125:4, 2125:16,
2166:2, 2237:19, 2251:17, 2253:13,
2255:17, 2256:12, 2256:15, 2256:19
liquidator [1] - 2025:23
liquidators [2] - 2025:25, 2026:1
liquidity [2] - 2126:5, 2253:19
list [13] - 2017:14, 2037:11, 2047:23,
2051:2, 2118:11, 2118:13, 2118:20,
2212:17, 2222:17, 2248:7, 2248:15,
2248:21
listed [10] - 2086:14, 2118:15,
2239:10, 2247:14, 2247:18, 2253:9,
2253:12, 2253:15, 2255:5, 2255:9
listened [1] - 2076:20
listening [1] - 2054:12
listing [4] - 1978:24, 1979:10,
2228:18, 2253:18
lists [5] - 2049:3, 2056:22, 2149:3,
2151:21, 2152:1
live [2] - 2099:14, 2099:15
lived [2] - 2018:4, 2099:16
living [1] - 2099:20
Lloyd [3] - 2008:19, 2014:9, 2094:2
Lloyd's [1] - 2117:7
loan [34] - 1976:14, 2058:21, 2058:24,
2059:3, 2059:5, 2059:8, 2062:23,
2097:16, 2102:1, 2152:6, 2156:25,
2157:13, 2157:17, 2157:24, 2158:2,
Johnny C. Sanchez, RMR, CRR - [email protected]
2276
2158:3, 2158:6, 2159:6, 2223:1,
2223:13, 2224:18, 2225:9, 2226:4,
2228:9, 2229:20, 2241:10, 2248:4,
2248:5, 2248:6, 2248:10, 2253:14,
2254:20
loaned [1] - 2224:20
loaning [1] - 2225:14
loans [23] - 2058:19, 2059:6, 2062:21,
2113:25, 2114:2, 2114:7, 2114:9,
2114:15, 2149:17, 2153:12, 2222:6,
2222:17, 2222:24, 2222:25, 2227:7,
2227:13, 2227:14, 2228:11, 2229:9,
2229:12, 2239:1, 2248:8, 2249:3
local [3] - 2100:16, 2101:7, 2226:7
located [7] - 2024:10, 2063:21,
2073:2, 2074:6, 2081:21, 2121:18,
2136:2
location [1] - 2187:4
locations [1] - 2221:25
lodged [1] - 2008:3
loft [2] - 2135:2, 2135:3
Lofts [1] - 2171:14
London [4] - 1999:22, 2020:11, 2117:7
look [31] - 1985:17, 1990:2, 2020:23,
2041:5, 2041:8, 2049:16, 2049:18,
2054:11, 2055:13, 2055:18, 2066:7,
2067:23, 2073:5, 2085:19, 2089:24,
2091:3, 2154:8, 2154:12, 2155:25,
2156:11, 2159:11, 2174:9, 2174:11,
2177:12, 2177:19, 2184:18, 2187:11,
2195:4, 2209:12, 2241:22, 2247:17
looked [14] - 1999:1, 2025:17,
2029:15, 2066:25, 2073:12, 2155:4,
2158:23, 2159:2, 2187:2, 2187:6,
2187:15, 2192:21, 2229:3, 2229:10
looking [21] - 1985:18, 2006:10,
2010:13, 2037:25, 2050:20, 2056:13,
2058:8, 2080:3, 2096:13, 2101:24,
2102:10, 2104:7, 2130:22, 2131:1,
2168:2, 2184:5, 2184:20, 2219:14,
2228:13, 2236:3, 2240:1
looks [2] - 2022:6, 2193:2
loss [1] - 2191:10
Lotus [2] - 2203:1, 2203:15
loud [3] - 2028:7, 2073:17, 2254:4
louder [1] - 2144:4
love [1] - 2010:17
loved [1] - 2200:14
low [5] - 2037:25, 2113:14, 2237:18,
2244:17, 2251:17
low-risk [2] - 2113:14, 2237:18
Lumiere [1] - 2009:9
lunch [1] - 2078:7
M
ma'am [16] - 1977:6, 1986:6, 1990:5,
1992:5, 1996:18, 2001:12, 2003:3,
2004:1, 2029:9, 2041:11, 2050:14,
2052:10, 2061:10, 2090:10, 2098:15,
2098:22
Maid [1] - 2135:2
mail [1] - 2166:21
main [1] - 2167:6
major [4] - 2097:5, 2100:4, 2253:12,
2253:15
male [1] - 2182:10
mall [1] - 2023:13
man [4] - 2039:4, 2112:25, 2114:14,
2172:7
management [7] - 2031:4, 2132:9,
2180:10, 2181:9, 2183:3, 2199:7,
2208:21
manager [2] - 2187:4, 2231:6
managers [4] - 2115:13, 2115:15,
2115:17, 2162:23
managing [3] - 2115:19, 2181:9,
2181:11
mandatory [1] - 2059:6
manner [2] - 2079:10, 2201:7
manual [3] - 1980:3, 1980:15, 1982:8
map [1] - 2018:16
marble [1] - 2141:10
margin [1] - 2045:9
Maria [3] - 2108:9, 2108:11
MARIAN [1] - 1973:4
marina [3] - 2196:22, 2196:24, 2218:7
mark [1] - 2090:24
marked [7] - 1988:24, 1989:14,
1992:15, 2020:21, 2055:11, 2055:17,
2063:2
market [10] - 2125:23, 2163:14,
2212:11, 2212:18, 2233:12, 2236:18,
2236:22, 2252:6, 2253:20, 2254:11
marketable [1] - 2254:7
marketing [4] - 2164:4, 2217:15,
2252:7, 2252:8
markings [1] - 1993:6
married [1] - 2189:10
marrying [1] - 2010:14
Marshals [1] - 2016:3
Marwick [4] - 2100:16, 2100:18,
2101:4, 2101:6
match [2] - 2025:15, 2217:10
matches [2] - 2214:10, 2217:6
material [11] - 2032:1, 2032:14,
2109:7, 2129:11, 2241:8, 2241:9,
2241:12, 2241:13, 2241:16, 2241:22,
2241:24
materiality [6] - 2240:15, 2240:17,
2241:5, 2241:17, 2242:1, 2254:16
materials [23] - 2093:22, 2109:2,
2109:9, 2109:12, 2109:23, 2110:6,
2110:10, 2110:12, 2110:17, 2110:23,
2112:15, 2112:17, 2113:11, 2140:25,
2141:3, 2141:5, 2141:7, 2235:7,
2251:15, 2251:19, 2252:4, 2252:7,
2252:9
matter [8] - 1979:18, 1985:11,
1996:14, 2003:17, 2035:18, 2125:7,
2150:10, 2257:12
mattered [1] - 2075:19
matters [4] - 2000:1, 2000:2, 2097:4,
2209:9
mature [2] - 2253:10, 2255:6
mayor [1] - 2202:23
McGuire [2] - 1972:6, 1972:6
mean [47] - 1976:8, 1976:11, 1979:6,
1996:15, 1999:12, 2004:7, 2023:12,
2061:17, 2082:15, 2083:24, 2092:10,
2125:3, 2125:15, 2131:18, 2139:24,
2146:6, 2180:12, 2181:18, 2185:1,
2186:20, 2189:21, 2193:1, 2193:22,
2197:3, 2199:9, 2200:4, 2200:22,
2201:17, 2203:23, 2212:14, 2213:16,
2216:17, 2219:19, 2223:5, 2232:13,
2233:5, 2233:7, 2240:17, 2241:5,
2246:20, 2246:23, 2249:21, 2250:22,
2254:4, 2254:9, 2255:11, 2256:20
meaning [1] - 2083:25
means [3] - 2125:4, 2240:18, 2253:20
meant [1] - 2070:8
measure [1] - 2102:5
mechanical [2] - 1972:13, 1972:20
meet [6] - 2105:2, 2105:8, 2202:7,
2202:15, 2203:25, 2204:21
meeting [11] - 1994:11, 1994:20,
1994:24, 1995:3, 1998:8, 1998:13,
1998:18, 2000:10, 2000:13, 2097:16,
2103:13
meetings [14] - 2107:25, 2109:7,
2109:11, 2109:15, 2109:24, 2110:7,
2110:19, 2112:14, 2112:18, 2115:21,
2116:17, 2117:17, 2117:19, 2160:10
member [2] - 1991:9, 2069:6
members [4] - 1994:15, 2105:12,
2134:14, 2159:16
Members [1] - 2030:22
memo [6] - 2012:13, 2012:16,
2012:17, 2012:18, 2013:4, 2041:5
memorandum [1] - 1976:4
memory [6] - 2050:22, 2050:23,
2065:21, 2112:2, 2180:24, 2184:18
memos [1] - 2034:14
mention [2] - 2145:7, 2145:16
mentioned [21] - 2010:5, 2041:20,
2107:5, 2109:13, 2117:6, 2117:7,
2117:8, 2118:6, 2123:22, 2126:4,
2126:21, 2133:20, 2134:15, 2135:7,
2137:16, 2146:10, 2150:15, 2163:18,
2163:22, 2164:7, 2217:21
merged [2] - 2101:4, 2101:5
mergers [2] - 2101:2, 2101:3
mess [2] - 1992:16, 2028:7
message [3] - 2013:9, 2013:12,
2013:21
met [10] - 1983:20, 1984:4, 2039:4,
2103:12, 2161:7, 2169:13, 2199:3,
2204:2, 2204:9, 2204:22
Mexia [15] - 2105:1, 2105:3, 2105:5,
2105:8, 2105:12, 2201:16, 2201:17,
2201:18, 2201:19, 2201:20, 2202:12,
2202:23, 2204:6, 2205:8
Miami [1] - 2119:4
Michelle [5] - 2061:23, 2108:8,
2108:10, 2108:12, 2108:13
microphone [2] - 1983:25, 2128:14Johnny C. Sanchez, RMR, CRR - [email protected]
2277
mid-'90s [2] - 2134:6, 2134:10
might [27] - 1983:12, 1984:24,
1988:16, 2015:1, 2026:16, 2033:23,
2041:2, 2061:16, 2071:22, 2089:9,
2129:1, 2137:13, 2137:14, 2137:18,
2147:8, 2147:13, 2147:16, 2158:24,
2159:10, 2203:10, 2215:25, 2222:13,
2232:20, 2249:15, 2249:18, 2253:6
mike [4] - 1987:9, 1987:12, 2086:1,
2127:18
Milam [2] - 2103:14, 2131:12
militate [1] - 1995:7
million [28] - 2016:3, 2064:4, 2149:10,
2149:11, 2151:22, 2152:1, 2153:1,
2155:1, 2155:20, 2156:19, 2156:25,
2157:18, 2157:20, 2158:2, 2158:3,
2159:6, 2216:21, 2223:1, 2228:9,
2228:24, 2241:8, 2241:11, 2247:21,
2247:22, 2253:14, 2254:14, 2254:20
million-dollar [10] - 2016:3, 2156:19,
2156:25, 2158:2, 2158:3, 2159:6,
2223:1, 2228:9, 2241:8, 2253:14
millions [15] - 2075:10, 2152:16,
2211:23, 2212:2, 2212:4, 2212:6,
2215:12, 2216:13, 2219:20, 2219:22,
2219:23, 2219:24, 2242:5
millwork [1] - 2141:9
Milton [2] - 2100:17
mind [7] - 2009:10, 2021:3, 2132:3,
2150:8, 2150:13, 2197:3, 2230:15
mindset [1] - 2096:16
minimization [3] - 2088:6, 2088:7,
2088:22
minister [2] - 1998:17, 1998:24
Minister [1] - 2087:13
minister's [2] - 1998:11, 1998:16
Ministry [1] - 2087:13
minor [1] - 2209:21
minute [10] - 2035:10, 2061:10,
2066:7, 2083:1, 2083:2, 2204:2,
2205:25, 2221:9, 2232:4, 2243:8
Minute [1] - 2135:2
minutes [7] - 2034:21, 2034:22,
2035:7, 2036:19, 2143:10, 2151:7,
2229:15
mislead [1] - 2088:1
misled [1] - 2249:1
misrepresentations [2] - 2032:15,
2191:20
miss [1] - 2240:10
missing [1] - 2095:2
misspoke [1] - 2017:21
misstatement [1] - 2032:1
Mitchell [1] - 2100:16
moderate [1] - 2194:6
moderately [5] - 2171:24, 2171:25,
2191:4, 2191:5, 2242:12
moment [3] - 2072:14, 2227:1,
2227:15
Monarch [4] - 2101:14, 2101:22,
2101:24, 2169:19
Monday [1] - 2093:5
money [111] - 1982:21, 2004:10,
2004:17, 2004:21, 2004:23, 2016:4,
2016:11, 2016:23, 2040:17, 2070:1,
2080:18, 2085:12, 2110:1, 2110:10,
2110:20, 2111:4, 2115:13, 2115:15,
2115:17, 2119:15, 2119:20, 2120:19,
2122:2, 2125:1, 2125:4, 2125:17,
2127:4, 2127:7, 2127:9, 2129:4,
2135:15, 2145:5, 2145:7, 2145:10,
2145:16, 2145:19, 2146:2, 2146:3,
2146:4, 2146:16, 2147:2, 2148:18,
2153:7, 2155:22, 2163:2, 2165:14,
2167:10, 2167:15, 2167:18, 2170:5,
2170:9, 2175:5, 2176:4, 2176:12,
2176:18, 2188:11, 2188:12, 2188:14,
2189:16, 2194:6, 2197:11, 2199:6,
2199:8, 2215:24, 2216:15, 2216:21,
2219:17, 2220:6, 2223:12, 2223:13,
2224:17, 2224:18, 2225:5, 2225:14,
2226:10, 2231:7, 2235:8, 2235:16,
2237:12, 2237:15, 2237:17, 2238:2,
2239:2, 2239:3, 2242:22, 2243:17,
2243:20, 2243:22, 2244:10, 2244:22,
2245:2, 2245:5, 2245:8, 2245:13,
2245:15, 2245:16, 2246:9, 2246:18,
2247:5, 2247:7, 2248:14, 2249:1,
2250:1, 2250:5, 2250:9, 2251:3,
2251:4, 2255:25, 2256:8
monies [1] - 2128:23
monitor [1] - 2232:7
monitoring [1] - 2141:12
month [1] - 2167:20
months [5] - 2013:5, 2039:8, 2099:17,
2126:3, 2183:1
months' [3] - 2166:22, 2166:23,
2167:4
Montrose [1] - 2186:19
Montserrat [32] - 1988:9, 1990:4,
1990:10, 1992:11, 1992:25, 1993:8,
1993:9, 1993:20, 1994:14, 1995:5,
1995:13, 1995:22, 1996:11, 1996:17,
1996:19, 1996:20, 1997:8, 1997:9,
1998:21, 2004:3, 2004:6, 2066:19,
2086:7, 2086:10, 2087:23, 2098:5,
2104:13, 2129:20, 2129:23, 2129:24,
2130:1, 2192:20
morning [15] - 1975:3, 1975:4,
1975:10, 1975:11, 1983:18, 1983:19,
1986:15, 1987:19, 2016:15, 2035:15,
2051:16, 2052:3, 2096:25, 2103:14,
2136:11
most [9] - 2039:24, 2075:24, 2108:16,
2135:22, 2136:1, 2199:9, 2199:11,
2241:9, 2242:12
motion [1] - 2096:24
motive [1] - 2194:14
move [24] - 1993:13, 1996:9, 1998:9,
1998:20, 2008:17, 2017:21, 2022:12,
2031:19, 2032:3, 2044:12, 2051:14,
2051:23, 2056:3, 2089:14, 2090:1,
2094:22, 2095:18, 2102:3, 2106:4,
2127:18, 2192:1, 2192:20, 2208:2,
2252:1
moved [5] - 2093:20, 2129:20,
2129:22, 2185:19, 2185:20
moving [2] - 1996:4, 2225:14
MR [497] - 1973:6, 1973:8, 1973:10,
1973:12, 1973:17, 1973:19, 1973:21,
1973:23, 1973:25, 1974:2, 1975:7,
1975:9, 1976:18, 1977:3, 1977:13,
1980:7, 1980:13, 1980:18, 1980:19,
1982:25, 1983:2, 1983:4, 1983:7,
1983:8, 1983:9, 1983:14, 1983:17,
1984:1, 1984:3, 1985:17, 1985:23,
1986:1, 1986:5, 1987:10, 1987:17,
1987:24, 1988:3, 1989:4, 1989:6,
1989:8, 1989:11, 1989:14, 1989:19,
1989:22, 1990:1, 1990:7, 1991:17,
1992:4, 1992:20, 1992:22, 1997:3,
1997:23, 1998:1, 1999:8, 1999:11,
1999:13, 1999:17, 2000:4, 2000:8,
2001:5, 2001:6, 2017:9, 2017:15,
2017:17, 2017:20, 2017:22, 2020:16,
2022:10, 2022:11, 2022:12, 2022:16,
2022:18, 2022:21, 2023:1, 2027:18,
2027:20, 2027:22, 2027:24, 2028:3,
2028:6, 2028:16, 2028:19, 2029:5,
2029:8, 2029:20, 2029:23, 2030:2,
2030:3, 2030:6, 2030:10, 2030:16,
2030:20, 2031:8, 2031:9, 2031:19,
2031:20, 2032:3, 2032:4, 2032:8,
2032:9, 2034:24, 2035:13, 2036:2,
2036:5, 2036:11, 2036:15, 2036:17,
2036:25, 2037:2, 2037:7, 2037:14,
2037:16, 2037:20, 2037:23, 2038:2,
2038:8, 2038:20, 2040:2, 2040:3,
2044:12, 2044:16, 2044:20, 2044:23,
2044:25, 2045:4, 2045:7, 2045:13,
2045:17, 2045:21, 2046:12, 2049:24,
2050:12, 2050:13, 2051:14, 2051:19,
2051:25, 2052:2, 2052:9, 2054:13,
2056:3, 2056:9, 2056:10, 2056:15,
2056:16, 2057:20, 2057:23, 2058:6,
2058:7, 2059:16, 2059:25, 2061:11,
2061:16, 2062:1, 2062:3, 2062:6,
2062:9, 2062:11, 2063:4, 2063:9,
2063:11, 2065:22, 2065:24, 2066:2,
2066:21, 2066:23, 2067:5, 2067:7,
2067:11, 2070:5, 2070:10, 2070:14,
2070:16, 2070:21, 2071:3, 2071:16,
2072:8, 2072:10, 2073:5, 2073:10,
2073:15, 2075:4, 2075:8, 2075:12,
2075:14, 2075:17, 2076:1, 2076:5,
2076:12, 2076:17, 2077:1, 2077:5,
2077:9, 2077:12, 2077:15, 2077:17,
2078:2, 2078:8, 2078:11, 2078:23,
2079:5, 2079:9, 2079:14, 2079:25,
2080:1, 2080:5, 2080:8, 2080:11,
2080:12, 2080:19, 2081:5, 2081:8,
2081:13, 2083:4, 2083:6, 2083:14,
2083:22, 2084:4, 2084:9, 2084:14,
2084:15, 2084:18, 2085:8, 2085:21,
2085:23, 2086:3, 2086:4, 2088:12,
2088:15, 2089:14, 2089:17, 2089:18,
2090:1, 2090:4, 2090:7, 2090:14,
2090:20, 2090:21, 2090:23, 2091:2,
Johnny C. Sanchez, RMR, CRR - [email protected]
2278
2092:13, 2096:7, 2096:9, 2096:12,
2097:8, 2097:11, 2097:21, 2097:23,
2098:1, 2098:3, 2098:12, 2098:14,
2098:24, 2099:8, 2101:1, 2102:18,
2104:2, 2104:5, 2105:17, 2105:20,
2105:25, 2106:2, 2106:6, 2110:2,
2110:5, 2110:11, 2110:16, 2110:22,
2111:1, 2111:8, 2111:11, 2111:12,
2111:13, 2111:17, 2111:23, 2112:5,
2112:12, 2112:21, 2112:22, 2113:3,
2113:4, 2113:8, 2113:18, 2113:24,
2114:3, 2114:6, 2114:13, 2114:17,
2114:21, 2115:7, 2116:1, 2116:8,
2116:14, 2116:16, 2117:9, 2117:11,
2117:22, 2117:25, 2118:9, 2118:12,
2118:17, 2118:19, 2119:23, 2121:4,
2121:7, 2123:18, 2123:21, 2124:4,
2124:7, 2124:19, 2124:23, 2125:5,
2125:9, 2125:14, 2128:2, 2128:10,
2128:16, 2134:23, 2135:4, 2136:10,
2136:12, 2136:22, 2136:24, 2137:4,
2137:5, 2138:7, 2138:8, 2138:18,
2138:24, 2138:25, 2139:6, 2139:8,
2142:22, 2142:25, 2143:2, 2143:6,
2143:8, 2143:12, 2143:14, 2143:17,
2143:19, 2143:20, 2144:3, 2144:6,
2144:13, 2144:15, 2145:9, 2145:12,
2145:15, 2146:19, 2146:21, 2147:11,
2147:12, 2147:15, 2147:18, 2147:20,
2148:2, 2148:4, 2148:8, 2148:23,
2149:1, 2150:4, 2150:5, 2150:7,
2150:9, 2150:11, 2150:17, 2151:3,
2151:8, 2152:9, 2152:11, 2152:15,
2152:18, 2152:21, 2152:25, 2153:14,
2153:16, 2153:18, 2153:21, 2153:23,
2154:1, 2154:9, 2154:11, 2154:21,
2154:23, 2155:6, 2155:14, 2155:16,
2155:17, 2155:25, 2156:2, 2156:15,
2156:17, 2157:2, 2157:5, 2157:10,
2157:11, 2158:20, 2158:22, 2159:3,
2159:4, 2159:8, 2159:9, 2159:12,
2159:14, 2159:24, 2159:25, 2161:9,
2161:15, 2167:2, 2169:7, 2169:9,
2173:24, 2174:1, 2175:23, 2176:2,
2180:14, 2180:17, 2180:22, 2180:23,
2181:2, 2181:5, 2184:8, 2184:11,
2184:13, 2184:15, 2184:17, 2197:10,
2200:9, 2200:12, 2203:4, 2203:13,
2207:4, 2207:13, 2207:17, 2207:21,
2208:6, 2208:9, 2208:13, 2208:15,
2227:1, 2227:4, 2227:15, 2227:17,
2227:20, 2227:22, 2227:25, 2228:3,
2228:17, 2228:20, 2229:19, 2229:22,
2230:1, 2230:4, 2231:9, 2231:11,
2231:18, 2232:4, 2232:6, 2233:15,
2233:17, 2239:25, 2240:3, 2240:6,
2240:9, 2240:13, 2240:19, 2240:21,
2241:4, 2243:8, 2243:10, 2244:1,
2244:2, 2244:4, 2245:22, 2245:23,
2246:1, 2247:11, 2247:16, 2251:5,
2251:7, 2251:21, 2252:2, 2252:15,
2252:20, 2252:22, 2253:1, 2253:25,
2254:2, 2254:3, 2254:4, 2254:6,
2254:22, 2254:23, 2255:1, 2255:4,
2256:21, 2256:22
must [9] - 1982:3, 1997:15, 2091:18,
2091:20, 2202:13, 2204:15, 2211:3,
2211:4, 2228:1
mutual [1] - 1976:5
N
name [13] - 1983:20, 1995:23,
2009:10, 2048:3, 2099:12, 2099:13,
2101:5, 2104:14, 2117:4, 2117:12,
2122:25, 2169:12, 2220:25
named [12] - 1999:21, 2000:24,
2008:19, 2008:23, 2008:25, 2009:18,
2009:22, 2042:24, 2043:3, 2101:14,
2198:15, 2216:3
names [10] - 1990:15, 2010:5, 2014:4,
2047:23, 2048:6, 2048:8, 2056:22,
2094:23, 2094:24, 2108:7
narrative [4] - 2116:3, 2124:16,
2124:17
narrow [1] - 2037:20
Natalee [1] - 2164:5
national [1] - 2100:15
nature [5] - 2016:24, 2053:6, 2113:11,
2220:10, 2221:12
nau [1] - 2191:19
nau-uh [1] - 2191:19
near [3] - 2186:19, 2218:18, 2218:19
necessarily [2] - 2003:18, 2173:3
necessary [10] - 1997:16, 1997:17,
2003:11, 2031:23, 2054:7, 2054:8,
2054:9, 2054:14, 2160:7, 2160:8
need [21] - 1987:13, 1987:24, 1996:22,
1999:24, 2001:14, 2001:15, 2008:13,
2008:16, 2012:12, 2027:20, 2057:21,
2071:1, 2087:3, 2091:8, 2122:14,
2152:21, 2173:12, 2206:5, 2207:10,
2224:16, 2252:17
needed [11] - 1993:16, 1996:10,
2001:21, 2047:1, 2047:4, 2047:5,
2053:1, 2129:25, 2140:16, 2223:25,
2226:19
needs [3] - 2011:7, 2224:14, 2233:3
negotiate [2] - 2206:24
negotiating [3] - 2205:21, 2217:14,
2218:21
nervous [1] - 2179:4
net [6] - 2195:21, 2195:22, 2195:23,
2196:10, 2225:20
never [39] - 1983:20, 1984:21,
1990:21, 1991:19, 2001:21, 2008:3,
2013:24, 2014:23, 2048:24, 2082:23,
2087:5, 2088:2, 2114:9, 2155:21,
2173:22, 2175:8, 2176:8, 2180:5,
2188:14, 2191:10, 2191:13, 2191:16,
2195:13, 2210:6, 2211:3, 2218:5,
2218:8, 2221:23, 2222:24, 2233:8,
2233:9, 2233:11, 2235:25, 2239:10,
2249:21, 2250:9, 2256:16
new [10] - 2059:6, 2096:17, 2104:6,
2123:8, 2140:23, 2161:23, 2162:7,
2162:8, 2192:6, 2192:13
New [4] - 1971:17, 2020:6, 2220:19,
2220:20
newly [1] - 2103:18
news [2] - 1999:4, 2179:23
newspaper [2] - 2102:23, 2216:25
newspapers [1] - 2216:18
next [29] - 1982:6, 1985:2, 1997:11,
2030:7, 2031:8, 2032:8, 2043:1,
2047:8, 2049:22, 2058:6, 2059:16,
2059:17, 2059:18, 2059:19, 2061:13,
2061:18, 2077:15, 2098:23, 2145:14,
2152:15, 2152:18, 2207:18, 2208:6,
2208:13, 2209:3, 2214:23, 2215:2
nice [2] - 2023:18, 2023:21
nicer [1] - 2096:16
night [3] - 1988:14, 2178:25, 2179:10
nights [1] - 2018:21
nobody [1] - 2251:3
nobody's [1] - 2177:22
none [2] - 2176:5, 2239:8
nonfinancial [1] - 2007:2
nongovernment [1] - 2068:12
nonprofit [1] - 2168:9
nonresponsive [1] - 2116:1
normal [1] - 2206:8
North [1] - 2004:14
notation [1] - 2228:14
Note [1] - 2151:16
note [21] - 1994:11, 2016:1, 2021:3,
2035:17, 2035:23, 2035:25, 2037:9,
2038:25, 2053:12, 2063:17, 2063:18,
2064:3, 2088:17, 2148:25, 2150:3,
2151:17, 2153:7, 2154:12, 2155:19,
2156:4, 2156:19
noted [2] - 2035:4
notes [19] - 2034:14, 2034:17, 2112:1,
2183:16, 2209:13, 2228:2, 2245:12,
2247:21, 2248:1, 2248:2, 2248:9,
2248:10, 2248:17, 2248:22, 2253:2,
2253:4, 2253:7, 2255:14, 2255:15
nothing [15] - 1977:15, 1977:21,
1979:24, 2038:20, 2075:24, 2217:19,
2223:17, 2224:22, 2231:3, 2232:1,
2232:3, 2232:12, 2247:4, 2247:6,
2256:22
notice [9] - 2035:19, 2066:25, 2098:9,
2098:11, 2150:25, 2166:22, 2166:23,
2167:4, 2167:20
noticed [1] - 2141:23
notified [1] - 2068:3
notifying [1] - 2130:2
noting [1] - 2254:19
November [16] - 1993:2, 1993:4,
2002:22, 2005:22, 2011:1, 2036:6,
2040:7, 2046:5, 2057:12, 2062:13,
2067:2, 2067:20, 2069:12, 2086:21,
2087:22, 2098:10
null [1] - 2003:2
Number [3] - 2023:7, 2046:10, 2207:5
number [40] - 1983:5, 1987:6,
1988:16, 1989:10, 2012:3, 2014:20,Johnny C. Sanchez, RMR, CRR - [email protected]
2279
2018:12, 2037:15, 2037:16, 2037:19,
2038:1, 2038:3, 2038:4, 2039:4,
2042:4, 2044:15, 2046:9, 2057:8,
2067:4, 2071:12, 2071:20, 2071:21,
2071:24, 2071:25, 2094:21, 2118:13,
2132:20, 2134:21, 2139:6, 2188:6,
2198:9, 2213:13, 2227:19, 2234:13,
2236:20, 2237:8, 2237:21, 2240:2,
2240:6, 2240:9
numbering [1] - 2037:21
numbers [3] - 2053:9, 2063:24,
2252:25
numerous [3] - 2112:14, 2192:21,
2209:16
NW [1] - 1971:17
O
O'Brien [11] - 2008:25, 2009:10,
2009:15, 2014:9, 2071:15, 2071:17,
2094:8, 2095:19, 2095:23, 2096:1,
2097:12
o'clock [2] - 2035:14, 2207:10
O.Y [2] - 1990:9, 2002:15
Oaks [1] - 2134:19
oath [1] - 1993:6
object [34] - 1976:18, 2008:2, 2008:3,
2008:9, 2008:13, 2008:16, 2036:1,
2036:2, 2070:5, 2070:21, 2075:4,
2088:12, 2105:17, 2105:25, 2110:22,
2112:5, 2112:8, 2112:23, 2113:1,
2114:13, 2116:1, 2116:14, 2117:22,
2124:4, 2128:10, 2145:12, 2152:10,
2180:14, 2181:2, 2200:9, 2203:4,
2229:19, 2240:19, 2245:22
objected [2] - 2007:25, 2079:9
objecting [1] - 2056:7
objection [45] - 1977:12, 1989:6,
2022:16, 2022:22, 2035:23, 2036:1,
2037:5, 2038:16, 2044:25, 2051:25,
2063:7, 2065:22, 2070:11, 2070:25,
2072:8, 2075:12, 2076:1, 2076:17,
2076:25, 2078:2, 2078:5, 2078:6,
2079:12, 2080:19, 2081:8, 2083:14,
2083:22, 2083:25, 2084:1, 2090:13,
2090:14, 2106:5, 2110:2, 2110:15,
2111:8, 2142:25, 2143:1, 2147:15,
2150:7, 2151:1, 2152:23, 2207:7,
2207:13, 2251:21
Objection [1] - 2161:9
objections [4] - 1980:12, 2063:4,
2081:10, 2153:18
observed [2] - 2168:24, 2170:7
obtain [3] - 1996:14, 2031:22, 2047:4
occasion [4] - 2001:24, 2003:8,
2033:3, 2043:22
occasions [1] - 2039:4
occurred [2] - 2097:5, 2135:13
October [6] - 1992:24, 1993:7,
1994:16, 1994:21, 1996:8, 1998:8
OF [2] - 1971:1, 1971:4
offense [2] - 2047:13, 2047:14
offer [7] - 2090:1, 2106:21, 2114:9,
2142:22, 2150:14, 2207:5, 2240:3
offered [7] - 2110:8, 2111:10, 2114:4,
2117:10, 2118:10, 2136:11, 2150:9
offering [3] - 2026:10, 2065:24,
2150:17
offers [1] - 2150:4
offhand [1] - 2067:4
office [29] - 1984:21, 1993:11,
1994:16, 1998:11, 1998:16, 2000:21,
2063:21, 2093:1, 2093:11, 2093:17,
2093:18, 2093:25, 2094:14, 2095:16,
2107:20, 2107:24, 2108:24, 2118:6,
2118:23, 2119:2, 2119:7, 2119:11,
2131:10, 2161:2, 2161:3, 2161:17,
2231:1, 2231:4, 2231:21
officer [10] - 2130:13, 2169:20,
2198:23, 2198:25, 2199:15, 2199:16,
2199:20, 2199:22, 2199:25, 2200:2
officers [4] - 2092:16, 2092:17,
2107:21, 2123:17
offices [12] - 2118:13, 2118:14,
2118:20, 2119:4, 2136:3, 2141:19,
2141:21, 2181:12, 2230:21, 2231:2,
2232:2, 2236:23
official [2] - 1993:20, 2092:14
Offshore [1] - 2007:9
offshore [11] - 2004:3, 2005:7,
2005:11, 2005:16, 2006:8, 2006:11,
2006:16, 2014:20, 2040:25, 2041:25,
2054:24
OFS [1] - 2007:12
OFSPC [1] - 2008:6
often [1] - 2136:7
old [5] - 2099:17, 2100:10, 2167:25,
2168:1, 2198:18
on-site [1] - 2033:11
once [15] - 1985:12, 2033:17, 2043:23,
2052:18, 2085:17, 2091:20, 2092:19,
2111:4, 2124:1, 2124:8, 2127:11,
2131:11, 2141:11, 2176:8, 2251:12
One [1] - 2121:17
one [122] - 1976:14, 1989:13, 1997:14,
1997:18, 1999:17, 2000:3, 2001:17,
2016:5, 2018:20, 2021:6, 2021:8,
2021:10, 2021:12, 2021:14, 2021:16,
2021:18, 2021:20, 2021:22, 2021:24,
2022:1, 2022:3, 2022:5, 2022:8,
2023:21, 2024:3, 2024:12, 2024:14,
2025:9, 2027:8, 2030:4, 2030:6,
2035:14, 2035:15, 2035:21, 2036:3,
2036:16, 2036:17, 2037:7, 2038:7,
2038:8, 2039:9, 2039:12, 2039:20,
2040:17, 2044:14, 2044:16, 2044:17,
2047:9, 2047:10, 2052:2, 2053:11,
2053:12, 2055:2, 2056:12, 2058:4,
2060:15, 2060:16, 2066:25, 2071:12,
2076:2, 2076:19, 2076:21, 2079:15,
2080:10, 2080:23, 2087:19, 2090:24,
2090:25, 2091:4, 2096:18, 2097:3,
2100:18, 2106:23, 2111:9, 2119:3,
2125:24, 2130:16, 2131:1, 2133:3,
2134:15, 2134:19, 2134:21, 2154:18,
2154:20, 2158:23, 2159:5, 2163:25,
2171:15, 2171:17, 2172:20, 2173:1,
2183:4, 2183:5, 2185:11, 2186:22,
2187:14, 2187:15, 2191:4, 2192:22,
2193:1, 2196:5, 2197:24, 2199:11,
2199:21, 2207:2, 2212:10, 2213:13,
2223:11, 2224:12, 2225:20, 2227:15,
2228:8, 2228:23, 2232:4, 2241:10,
2242:14, 2243:8, 2244:14, 2247:14,
2254:14, 2256:20
one-year [1] - 2244:14
ones [7] - 1999:25, 2014:7, 2021:3,
2021:5, 2119:19, 2197:17, 2217:10
opened [1] - 2162:16
operate [2] - 2103:20, 2250:1
operated [2] - 1998:21, 2233:1
Operating [1] - 2012:7
operating [2] - 1995:22, 2015:5
Operation [18] - 2010:6, 2013:19,
2013:22, 2013:24, 2014:3, 2014:8,
2014:14, 2014:18, 2015:4, 2015:11,
2015:16, 2069:21, 2069:22, 2069:24,
2070:2, 2070:8, 2070:22, 2072:3
operation [8] - 2014:22, 2015:12,
2028:12, 2032:22, 2190:1, 2208:21,
2208:23, 2208:25
operational [1] - 2005:20
operations [1] - 1980:16
operators [1] - 2011:13
Opinion [1] - 2230:3
opinion [41] - 1988:19, 1992:5,
1992:23, 1993:23, 1994:1, 1994:6,
1996:2, 1999:5, 1999:7, 2000:22,
2000:23, 2001:15, 2028:4, 2028:9,
2030:5, 2031:6, 2031:7, 2031:10,
2032:18, 2032:19, 2066:19, 2074:16,
2085:17, 2086:5, 2087:8, 2095:3,
2095:9, 2095:11, 2112:8, 2112:25,
2113:19, 2125:6, 2125:8, 2160:8,
2165:23, 2172:22, 2238:21, 2241:13,
2243:19, 2249:13, 2254:21
opinions [2] - 1994:8, 2032:5
opponent [2] - 2150:12, 2150:19
opportunities [2] - 2162:13, 2162:14
opportunity [9] - 2106:11, 2177:12,
2187:6, 2187:15, 2192:23, 2205:14,
2209:12, 2216:14, 2255:18
opposed [3] - 2209:2, 2219:12, 2246:7
order [9] - 1976:7, 2031:24, 2035:18,
2052:4, 2058:24, 2063:20, 2086:7,
2117:7, 2151:20
ordered [2] - 2002:11, 2095:8
orders [1] - 2209:11
ordinance [1] - 2086:8
organization [4] - 1979:19, 2103:19,
2168:9, 2232:24
organizations [2] - 2027:2
original [2] - 1998:24, 2000:20
Osborne [5] - 1998:17, 2000:10,
2000:15, 2000:18, 2000:20
otherwise [4] - 1980:21, 2004:21,
2116:4, 2235:2
Ou [1] - 1983:12Johnny C. Sanchez, RMR, CRR - [email protected]
2280
ought [1] - 2034:7
outcome [1] - 2047:15
outer [1] - 2079:17
Outer [1] - 2079:18
outgrown [1] - 2129:24
outline [1] - 1976:10
outlined [1] - 2011:6
outlines [2] - 1978:13, 2038:11
outlining [1] - 2012:13
outside [8] - 1984:5, 1986:19, 2018:7,
2060:24, 2064:18, 2160:4, 2163:2,
2251:22
outstanding [2] - 2047:9, 2053:17
overall [7] - 1981:14, 2032:6, 2041:22,
2085:15, 2101:18, 2139:12, 2199:1
overhead [3] - 2067:7, 2080:6,
2085:21
overnight [1] - 2219:8
overrule [2] - 1977:12, 2152:23
overruled [21] - 2037:6, 2075:6,
2081:11, 2083:18, 2083:21, 2110:24,
2113:2, 2113:4, 2113:20, 2114:16,
2114:19, 2117:24, 2124:5, 2125:13,
2128:12, 2161:11, 2161:14, 2181:4,
2203:5, 2240:24
overseas [1] - 2097:5
overseeing [2] - 2115:9, 2199:16
oversees [1] - 2221:24
overview [1] - 2139:9
owe [1] - 2224:19
owes [1] - 2154:25
own [8] - 1979:7, 2164:21, 2164:22,
2219:13, 2221:21, 2223:9, 2224:12,
2246:11
owned [16] - 2024:3, 2081:22,
2097:17, 2102:19, 2117:21, 2118:3,
2136:16, 2137:24, 2181:15, 2181:18,
2181:21, 2188:3, 2188:4, 2192:9,
2204:5, 2232:16
owner [3] - 2046:15, 2199:5, 2246:10
owners [2] - 2066:11, 2120:18
ownership [3] - 2025:21, 2026:5,
2137:14
owns [4] - 2024:2, 2223:9, 2224:20,
2246:3
P
p.m [3] - 2079:21, 2155:11, 2257:7
page [32] - 1980:10, 1983:7, 1983:15,
1987:16, 1990:2, 1991:5, 1992:21,
1997:12, 2002:3, 2002:7, 2028:4,
2028:17, 2029:6, 2029:7, 2030:8,
2052:25, 2067:10, 2073:12, 2073:13,
2077:16, 2087:19, 2089:15, 2149:23,
2159:3, 2181:6, 2207:18, 2207:19,
2208:7, 2229:13
PAGE [1] - 1973:3
Page [34] - 1980:18, 1985:18, 1990:19,
2000:4, 2000:6, 2001:5, 2027:19,
2029:20, 2030:16, 2031:3, 2047:18,
2073:10, 2080:3, 2081:14, 2081:17,
2111:17, 2114:4, 2118:10, 2118:17,
2136:22, 2137:4, 2138:7, 2138:24,
2139:7, 2148:23, 2155:25, 2157:4,
2157:10, 2159:8, 2182:21, 2184:21,
2230:2, 2247:12, 2252:16
Pages [1] - 2030:25
pages [2] - 2096:6, 2096:9
paid [17] - 1985:13, 1985:14, 2077:21,
2077:25, 2080:18, 2081:7, 2083:12,
2084:12, 2095:23, 2097:13, 2101:19,
2143:22, 2168:4, 2188:16, 2199:2,
2199:3, 2212:15
panel [1] - 1991:11
paneling [1] - 2141:9
paper [1] - 2112:1
paperwork [3] - 2029:17, 2058:20,
2187:22
paragraph [17] - 1982:6, 2000:7,
2032:8, 2047:1, 2047:8, 2052:24,
2063:9, 2063:16, 2067:14, 2067:24,
2096:9, 2111:20, 2151:5, 2182:21,
2184:21, 2209:3, 2230:3
paragraphs [4] - 2030:18, 2059:18,
2073:11, 2159:13
parameters [1] - 1981:14
pardon [4] - 2153:15, 2184:10,
2184:16, 2197:7
park [1] - 2190:25
Park [1] - 2135:3
parked [1] - 2225:19
Parras [17] - 1972:2, 1983:20,
2035:13, 2036:21, 2037:13, 2062:19,
2065:7, 2065:17, 2067:13, 2068:15,
2072:25, 2074:3, 2074:15, 2074:19,
2078:17, 2080:13, 2098:4
PARRAS [155] - 1976:18, 1976:21,
1977:3, 1983:4, 1983:7, 1983:9,
1983:14, 1983:17, 1984:1, 1984:3,
1985:17, 1985:23, 1986:1, 1986:5,
1987:10, 1987:15, 1987:17, 1987:24,
1988:3, 1989:4, 1989:11, 1989:14,
1989:19, 1989:22, 1990:1, 1990:7,
1991:17, 1992:4, 1992:22, 1997:3,
1997:23, 1998:1, 1999:8, 1999:11,
1999:13, 1999:17, 2000:4, 2000:8,
2001:5, 2001:6, 2017:9, 2017:17,
2017:20, 2017:22, 2020:16, 2022:10,
2022:12, 2022:18, 2023:1, 2027:18,
2027:22, 2027:24, 2028:3, 2028:6,
2028:16, 2028:19, 2029:5, 2029:8,
2029:20, 2029:23, 2030:2, 2030:3,
2030:6, 2030:10, 2030:16, 2030:20,
2031:8, 2031:9, 2031:19, 2031:20,
2032:3, 2032:4, 2032:8, 2032:9,
2037:2, 2037:7, 2037:14, 2037:16,
2037:20, 2037:23, 2038:8, 2040:2,
2040:3, 2044:12, 2044:16, 2044:20,
2044:23, 2045:4, 2045:7, 2045:13,
2045:17, 2045:21, 2046:12, 2049:24,
2050:12, 2050:13, 2051:14, 2052:9,
2054:13, 2056:3, 2056:9, 2056:10,
2056:15, 2056:16, 2057:20, 2057:23,
2058:6, 2058:7, 2059:16, 2059:25,
2061:11, 2061:16, 2065:22, 2070:5,
2070:14, 2070:21, 2072:8, 2075:4,
2075:12, 2075:14, 2076:1, 2076:17,
2078:2, 2078:23, 2079:9, 2080:19,
2081:8, 2083:14, 2083:22, 2084:15,
2084:18, 2085:8, 2085:21, 2085:23,
2086:3, 2086:4, 2088:15, 2089:14,
2089:17, 2089:18, 2090:1, 2090:4,
2090:7, 2090:20, 2090:23, 2091:2,
2092:13, 2096:7, 2096:9, 2096:12,
2097:8, 2097:11, 2097:21, 2097:23,
2098:14
Parras's [1] - 2079:7
PARRAS............. [1] - 1973:10
PARRAS............... [1] - 1973:6
part [37] - 2014:5, 2014:7, 2025:3,
2035:21, 2041:1, 2068:22, 2068:24,
2069:5, 2069:24, 2070:2, 2084:21,
2085:15, 2087:9, 2091:14, 2103:18,
2107:16, 2107:24, 2107:25, 2108:16,
2144:22, 2147:21, 2164:25, 2165:10,
2175:5, 2178:1, 2186:4, 2187:7,
2188:16, 2210:2, 2210:6, 2213:10,
2213:23, 2215:15, 2246:11, 2248:8,
2248:21
part... [1] - 2092:9
partial [1] - 2246:10
particular [4] - 2142:15, 2157:24,
2187:8, 2241:18
particularly [2] - 1978:22, 2232:24
parties [1] - 1990:16
partly [1] - 2108:23
partner [6] - 2026:12, 2026:22,
2026:23, 2161:7, 2161:20, 2188:4
partners [3] - 2184:3, 2188:6, 2188:7
Partnership [1] - 2188:2
partnership [16] - 2120:23, 2120:25,
2121:8, 2121:9, 2121:11, 2121:14,
2121:16, 2121:20, 2121:22, 2121:24,
2122:2, 2122:4, 2122:12, 2122:18,
2123:23, 2125:18
partnerships [13] - 2119:20, 2119:25,
2120:4, 2120:6, 2122:22, 2123:16,
2124:14, 2125:1, 2125:2, 2125:16,
2126:23, 2133:24, 2233:25
parts [3] - 2108:1, 2144:12, 2164:11
party [14] - 2150:12, 2150:19, 2158:7,
2158:15, 2203:8, 2238:23, 2239:11,
2239:13, 2239:23, 2239:24, 2240:14,
2240:22, 2241:19, 2256:4
pass [10] - 1983:2, 2065:13, 2084:14,
2098:12, 2169:7, 2233:15, 2244:1,
2251:5, 2254:22, 2256:21
passed [3] - 2004:9, 2069:25, 2070:18
passport [2] - 2053:8, 2053:9
past [3] - 2105:15, 2105:22, 2214:7
Pat [6] - 2009:15, 2014:9, 2094:8,
2095:19, 2095:23, 2096:1
Pat' [1] - 2008:25
Patrick [3] - 2009:10, 2009:11,
2071:15
Paul [2] - 2039:3, 2168:8
pavilion [2] - 2236:3, 2236:6Johnny C. Sanchez, RMR, CRR - [email protected]
2281
Pavilion [5] - 2211:16, 2212:8,
2236:10, 2236:11, 2236:12
pay [10] - 2063:19, 2151:20, 2168:13,
2215:25, 2216:1, 2219:17, 2225:7,
2226:5, 2244:11, 2244:12
paying [6] - 2075:10, 2077:3, 2144:7,
2235:1, 2244:16, 2244:17
payment [1] - 2096:1
payments [1] - 2075:18
payroll [2] - 2101:19, 2199:3
PDF [6] - 2027:19, 2029:6, 2029:7,
2029:20, 2030:16, 2159:8
Peat [4] - 2100:16, 2100:18, 2101:4,
2101:6
pen [1] - 2001:10
pending [1] - 2209:9
people [38] - 2032:11, 2040:23,
2040:24, 2061:7, 2068:12, 2088:11,
2106:22, 2109:13, 2116:11, 2164:11,
2172:19, 2173:6, 2173:16, 2173:19,
2190:8, 2194:25, 2195:23, 2196:10,
2218:12, 2219:12, 2219:15, 2219:16,
2220:2, 2220:8, 2220:10, 2221:3,
2233:1, 2233:2, 2233:5, 2236:20,
2246:18, 2248:24, 2249:21, 2249:25,
2250:4, 2250:7, 2254:11
percent [14] - 2046:16, 2108:22,
2111:25, 2112:1, 2113:16, 2168:20,
2181:18, 2184:5, 2184:22, 2185:17,
2192:11, 2232:16
percentage [2] - 2108:19, 2244:11
perception [2] - 2163:15, 2163:23
perfect [1] - 2151:5
perfectly [2] - 2224:5, 2224:6
perform [1] - 2176:13
performed [1] - 2031:22
Perhaps [1] - 2091:6
perhaps [3] - 2050:1, 2078:6, 2138:16
period [4] - 2070:17, 2084:24, 2085:7,
2129:1
permit [2] - 2206:19, 2206:23
person [9] - 2011:23, 2025:23, 2094:5,
2203:17, 2204:21, 2223:9, 2244:20,
2246:3, 2247:3
personal [16] - 2070:5, 2074:25,
2075:11, 2081:9, 2093:13, 2093:15,
2122:3, 2122:16, 2127:1, 2127:5,
2145:20, 2146:17, 2161:9, 2167:15,
2243:25
personality [1] - 2172:24
personally [3] - 2112:7, 2126:22,
2173:8
persons [3] - 1995:24, 2008:10,
2094:21
perspective [1] - 2242:2
Peter [1] - 2043:14
philosophy [2] - 1981:13, 2215:5
photo [4] - 2080:4, 2080:13, 2136:13,
2136:25
photograph [3] - 2053:9, 2231:1,
2231:4
photographs [1] - 2231:3
photos [1] - 2020:22
phrase [2] - 2068:6, 2068:8
physically [2] - 2093:11, 2094:13
pick [3] - 2083:17, 2083:19, 2172:20
picked [2] - 2094:13, 2172:20
picking [1] - 2172:25
picture [9] - 2077:18, 2119:5, 2119:6,
2144:20, 2195:4, 2196:25, 2197:2,
2213:10, 2215:15
pictured [1] - 2236:15
pictures [5] - 2023:4, 2023:5, 2093:24,
2119:4, 2214:23
piece [2] - 2212:14, 2256:3
pieces [4] - 1975:24, 1979:3, 1987:19,
2034:1
ping [1] - 2078:25
ping-pong [1] - 2078:25
pitch [4] - 2082:11, 2082:12, 2082:13,
2083:8
pitcher [1] - 2082:21
place [23] - 1993:10, 2012:5, 2018:7,
2035:22, 2040:18, 2042:6, 2053:10,
2062:25, 2088:23, 2138:11, 2178:6,
2178:7, 2178:22, 2190:25, 2193:2,
2196:11, 2213:10, 2213:11, 2213:12,
2218:3, 2218:11, 2219:12
placed [2] - 1979:11, 2102:24
places [10] - 2005:15, 2011:11,
2018:10, 2020:3, 2020:25, 2085:20,
2087:9, 2087:19, 2195:24, 2213:19
plain [1] - 2039:20
plaintiff [1] - 2002:12
plaintiffs [1] - 2002:14
plan [11] - 1996:9, 2005:20, 2006:6,
2010:25, 2190:17, 2192:24, 2194:2,
2195:6, 2195:10, 2196:17, 2198:8
plane [1] - 2144:23
planes [5] - 2137:10, 2137:21,
2137:23, 2209:2
planned [2] - 2031:22, 2219:10
Planning [1] - 2007:9
planning [5] - 2010:11, 2010:12,
2130:2, 2138:20, 2220:5
plans [7] - 2112:9, 2140:1, 2140:2,
2219:21, 2219:25, 2220:1, 2221:2
plant [3] - 2210:2, 2210:5, 2210:9
platform [1] - 2041:21
play [1] - 2214:1
played [6] - 2143:18, 2144:5, 2144:14,
2213:24, 2213:25, 2214:9
players [1] - 2019:4
pleasures [1] - 2096:18
plenty [1] - 2224:13
plumbing [1] - 2164:14
plus [2] - 2212:10, 2244:12
PO [2] - 1971:14, 1972:7
Point [5] - 2138:11, 2138:14, 2196:25,
2212:8, 2218:7
point [19] - 2006:15, 2009:13, 2011:18,
2017:23, 2020:15, 2049:11, 2050:1,
2057:17, 2057:20, 2075:4, 2077:13,
2079:8, 2085:20, 2101:8, 2103:23,
2132:12, 2155:6, 2163:1
point-by-point [1] - 2057:17
pointed [1] - 2001:10
points [4] - 2038:11, 2040:10,
2040:12, 2057:8
police [1] - 2094:25
policies [1] - 2031:18
pong [1] - 2078:25
pool [1] - 2136:20
poor [1] - 2168:10
popular [1] - 2213:19
portfolio [20] - 1977:19, 1978:9,
1978:13, 1980:17, 1981:2, 1981:6,
1981:13, 1981:19, 1982:7, 2059:3,
2062:23, 2111:21, 2111:24, 2113:12,
2115:2, 2115:9, 2126:7, 2126:19,
2129:4, 2149:4
portfolios [1] - 1979:17
portion [13] - 1977:1, 2045:13, 2058:9,
2058:11, 2076:23, 2080:24, 2113:9,
2148:24, 2151:4, 2154:21, 2156:1,
2157:14, 2208:14
position [26] - 2047:16, 2050:20,
2051:24, 2053:15, 2060:20, 2060:22,
2060:24, 2069:8, 2069:16, 2072:15,
2102:21, 2103:4, 2103:16, 2104:16,
2106:14, 2130:11, 2130:20, 2130:23,
2131:1, 2168:11, 2173:10, 2173:17,
2173:20, 2175:14, 2175:18, 2183:2
positions [5] - 1982:7, 1982:10,
2072:17, 2072:18, 2073:18
positive [1] - 2199:25
possession [3] - 2033:22, 2033:24,
2034:19
possibilities [1] - 2219:14
possibility [1] - 2219:16
possible [11] - 1986:24, 2008:22,
2011:3, 2038:14, 2048:10, 2048:15,
2053:17, 2088:25, 2089:1, 2171:8,
2216:6
possibly [3] - 2026:22, 2102:8,
2146:18
potential [2] - 2068:4, 2166:6
power [5] - 2048:17, 2048:20,
2052:19, 2092:3, 2232:13
predecessor [1] - 2072:16
predecessors [1] - 2076:14
predominately [1] - 2236:16
prefaced [1] - 2089:6
preference [1] - 1997:19
premier [1] - 2019:9
premises [1] - 2094:17
preparation [5] - 2031:4, 2031:16,
2033:20, 2034:12, 2199:4
prepare [4] - 2034:15, 2041:19,
2041:21, 2101:20
prepared [2] - 2028:13, 2032:23
prerequisite [1] - 1996:12
presence [1] - 1993:15
present [4] - 2000:10, 2064:21,
2094:15, 2142:15
presentation [1] - 2032:6
presented [3] - 2007:5, 2101:21,
Johnny C. Sanchez, RMR, CRR - [email protected]
2282
2199:5
presenting [1] - 1982:16
president [13] - 2062:16, 2094:3,
2101:16, 2101:21, 2123:9, 2132:14,
2139:4, 2149:15, 2153:4, 2155:23,
2158:10, 2167:22, 2174:17
president's [1] - 2133:19
presidents [1] - 2106:25
Preston [1] - 1972:3
pretty [6] - 1989:21, 2087:24, 2154:8,
2189:14, 2216:8, 2256:20
prevent [1] - 2082:17
prevents [2] - 1977:15, 1977:21
previously [5] - 1980:5, 1980:8,
1980:10, 2053:13, 2200:4
Price [3] - 2161:3, 2161:5, 2161:17
price [2] - 2126:13, 2212:18
primarily [5] - 2108:5, 2108:6,
2120:10, 2162:16, 2209:20
primary [2] - 2168:25, 2207:2
principal [3] - 2063:23, 2151:21,
2244:12
principle [2] - 2241:18, 2251:2
principles [2] - 2221:22, 2222:11
priority [2] - 2041:2, 2041:3
private [13] - 2010:18, 2011:14,
2068:12, 2074:22, 2137:23, 2138:5,
2144:20, 2160:10, 2195:25, 2196:6,
2196:11, 2209:1
prize [1] - 2216:21
problem [16] - 1977:2, 2068:16,
2068:19, 2069:1, 2082:17, 2160:17,
2164:15, 2191:13, 2191:16, 2207:9,
2226:21, 2235:18, 2235:19, 2249:2,
2250:19, 2251:1
problems [6] - 1994:13, 1995:13,
2059:10, 2186:10, 2215:19, 2225:24
procedures [1] - 2015:23
proceed [2] - 1975:5, 2155:14
Proceedings [2] - 1972:13, 1972:20
proceedings [1] - 2257:11
proceeds [1] - 2250:23
process [10] - 1979:8, 2060:1, 2060:8,
2178:1, 2183:6, 2183:8, 2202:2,
2206:4, 2206:12, 2206:25
processes [1] - 2015:24
processing [1] - 2053:18
produce [2] - 2164:21, 2250:7
produced [8] - 1972:13, 1972:21,
1978:17, 2035:18, 2037:3, 2055:22,
2091:22, 2221:12
product [3] - 2108:4, 2108:25, 2252:12
production [3] - 2038:9, 2039:14,
2039:15
products [7] - 1982:2, 2197:4, 2197:9,
2233:6, 2233:8, 2233:10, 2252:6
profession [1] - 2099:23
professional [4] - 2029:2, 2029:4,
2047:10, 2053:11
profit [5] - 2133:25, 2242:18, 2242:25,
2250:2, 2250:7
profitability [1] - 2234:25
profitable [6] - 2242:9, 2242:12,
2242:15, 2249:14, 2250:6, 2250:13
profits [1] - 2250:17
program [1] - 2079:17
progress [1] - 2141:12
progressed [1] - 2005:1
prohibition [2] - 1976:16, 1979:20
prohibits [1] - 1979:24
project [12] - 2106:8, 2120:22, 2121:2,
2135:2, 2135:3, 2186:15, 2186:17,
2187:9, 2200:16, 2209:7, 2209:10,
2210:6
projections [2] - 2249:16, 2249:17
projector [1] - 2085:22
projects [29] - 2129:5, 2135:6, 2135:7,
2135:13, 2135:19, 2135:23, 2136:1,
2142:11, 2146:13, 2152:7, 2167:12,
2171:13, 2171:16, 2185:22, 2186:3,
2189:3, 2189:5, 2191:25, 2192:1,
2197:12, 2197:15, 2210:10, 2211:16,
2211:19, 2211:21, 2211:22, 2211:24,
2243:14
Promindon [1] - 2108:10
promise [1] - 2246:4
promises [2] - 2063:19, 2151:20
Promissory [1] - 2151:16
promissory [12] - 2063:17, 2063:18,
2064:3, 2088:17, 2150:3, 2151:16,
2151:17, 2153:7, 2154:12, 2155:19,
2156:3, 2156:19
promote [4] - 2212:12, 2212:16,
2217:13, 2233:13
promoting [1] - 2217:2
promotion [2] - 2076:15, 2077:3
promotional [12] - 2109:2, 2109:7,
2109:9, 2109:11, 2110:6, 2112:15,
2119:3, 2129:11, 2235:6, 2251:15,
2251:19, 2252:4
pronoun [1] - 2143:21
pronounced [1] - 2201:16
proper [2] - 2008:1, 2164:19
properly [1] - 2120:20
properties [11] - 2120:18, 2122:21,
2134:7, 2139:15, 2183:22, 2191:8,
2191:10, 2191:13, 2205:15, 2206:3,
2210:7
property [11] - 2120:8, 2125:19,
2126:13, 2188:1, 2192:15, 2209:18,
2212:14, 2218:18, 2218:25, 2256:7,
2256:16
propose [1] - 1990:23
proposed [3] - 1988:9, 2086:7,
2092:16
prosecution [2] - 2079:1, 2177:15
prosecutor [5] - 1987:7, 2086:16,
2112:23, 2213:6, 2221:10
prosecutors [1] - 2078:25
proud [1] - 2055:8
prove [1] - 2112:9
provide [8] - 2031:24, 2091:19,
2091:20, 2132:13, 2132:19, 2177:19,
2185:5, 2185:17
provided [8] - 2002:11, 2034:3,
2034:5, 2041:21, 2051:15, 2062:22,
2207:5, 2212:24
provision [2] - 2049:9, 2049:12
proviso [1] - 2152:24
public [11] - 1975:25, 1976:1, 2100:2,
2100:6, 2100:15, 2103:5, 2125:23,
2163:15, 2163:22, 2196:6, 2253:18
publicized [1] - 2164:1
published [2] - 2039:2, 2063:5
Puerto [1] - 2009:18
pull [5] - 2030:7, 2062:6, 2093:18,
2102:8, 2128:13
purchase [10] - 2076:15, 2103:20,
2106:12, 2120:18, 2121:16, 2122:6,
2206:13, 2208:16, 2208:20, 2244:19
purchased [6] - 2122:21, 2123:1,
2192:16, 2192:18, 2210:21, 2210:22
purchasers [1] - 2166:6
purchases [2] - 2122:24, 2208:19
pure [1] - 2113:6
purely [1] - 2078:24
purported [1] - 2003:1
purportedly [1] - 2086:13
purpose [12] - 1994:24, 1998:7,
1998:18, 2058:19, 2058:24, 2059:7,
2076:24, 2170:14, 2213:8, 2220:19,
2236:13, 2251:15
purposes [3] - 2150:18, 2151:2,
2209:19
pursuant [2] - 1980:11, 2016:4
pursuit [1] - 2001:22
put [37] - 1981:21, 1982:17, 1982:22,
1983:12, 1987:13, 2012:5, 2021:3,
2038:5, 2040:18, 2044:23, 2045:15,
2049:13, 2062:24, 2078:18, 2085:12,
2085:13, 2094:8, 2108:19, 2109:2,
2141:20, 2148:3, 2148:4, 2150:25,
2165:13, 2187:21, 2188:10, 2189:22,
2191:10, 2200:1, 2200:5, 2211:2,
2212:14, 2216:20, 2216:21, 2223:24,
2251:19, 2252:3
putting [4] - 2017:18, 2042:10,
2237:17, 2239:2
Q
qualified [2] - 1977:3, 2125:7
quality [5] - 2140:18, 2140:20,
2140:22, 2140:23, 2236:23
quarterly [1] - 1978:10
quarters [1] - 2034:23
Queeley [3] - 2064:17, 2064:25,
2065:4
Quelley [6] - 2042:24, 2042:25,
2043:2, 2043:14, 2043:19
queries [1] - 2060:4
questioned [5] - 2128:8, 2128:9,
2128:11, 2128:19, 2128:20
questioning [3] - 2068:9, 2083:23,
2112:9
questions [32] - 1980:16, 1987:6,Johnny C. Sanchez, RMR, CRR - [email protected]
2283
1987:23, 1988:16, 2047:18, 2061:12,
2061:14, 2061:16, 2061:21, 2064:8,
2064:12, 2066:18, 2066:19, 2068:15,
2072:22, 2074:8, 2075:21, 2076:6,
2078:19, 2084:19, 2084:23, 2097:21,
2125:10, 2178:2, 2183:9, 2183:13,
2200:8, 2222:5, 2227:6, 2234:13,
2237:9, 2244:2
quick [3] - 2006:6, 2042:2, 2156:16
quicker [3] - 2012:12, 2116:3, 2245:15
quickly [4] - 2012:21, 2056:11,
2140:16, 2254:23
quit [5] - 2068:7, 2170:4, 2176:17,
2176:21, 2206:5
quite [5] - 1979:2, 2007:14, 2008:22,
2019:6, 2105:6
quote [3] - 1994:8, 2065:20, 2194:12
quote-unquote [1] - 2194:12
quoted [1] - 2183:4
R
raging [1] - 2004:12
raining [1] - 2082:18
raise [4] - 2079:18, 2099:2, 2140:6,
2186:8
raised [4] - 2016:15, 2069:10,
2119:20, 2160:11
range [8] - 1979:16, 1979:18, 2006:20,
2006:25, 2007:1, 2007:3, 2012:5,
2184:22
ranging [1] - 2018:17
rapidly [1] - 2140:17
rate [3] - 2063:25, 2151:23, 2212:21
rather [1] - 2084:1
Ravenscroft [2] - 1999:22
raw [2] - 2209:18, 2209:20
re [1] - 2204:3
reached [1] - 2055:3
reaction [3] - 1981:23, 2142:1, 2163:7
read [60] - 1976:25, 1977:1, 1980:20,
1981:4, 1982:8, 1990:5, 1992:6,
1992:16, 1994:10, 1994:23, 1999:1,
2000:6, 2002:7, 2003:20, 2028:7,
2030:4, 2030:17, 2041:8, 2042:2,
2050:4, 2053:22, 2058:17, 2059:3,
2063:16, 2065:21, 2067:12, 2067:14,
2073:16, 2074:16, 2076:22, 2076:23,
2080:22, 2080:24, 2084:4, 2084:8,
2086:19, 2092:7, 2096:4, 2109:2,
2109:9, 2109:17, 2109:20, 2109:23,
2110:6, 2110:12, 2110:17, 2111:2,
2112:15, 2112:16, 2157:7, 2208:18,
2209:4, 2216:17, 2216:25, 2228:22,
2229:5, 2230:7, 2247:20, 2252:5
reading [21] - 1981:11, 1981:18,
1982:14, 1993:22, 1993:24, 1994:18,
1994:21, 1994:22, 1997:11, 2030:4,
2041:10, 2044:5, 2045:25, 2046:3,
2046:19, 2050:15, 2112:19, 2113:10,
2180:14, 2217:2, 2241:25
ready [8] - 1975:5, 2035:6, 2038:18,
2097:7, 2155:10, 2253:20, 2254:12,
2257:5
real [80] - 2101:8, 2103:6, 2103:19,
2104:9, 2104:22, 2106:7, 2106:8,
2106:12, 2106:19, 2107:18, 2119:12,
2119:16, 2119:25, 2120:4, 2120:6,
2120:13, 2120:16, 2120:17, 2121:11,
2121:13, 2121:22, 2122:4, 2122:11,
2123:12, 2123:15, 2123:22, 2124:13,
2125:1, 2125:2, 2125:12, 2125:15,
2125:17, 2126:1, 2126:8, 2126:11,
2126:12, 2126:17, 2126:20, 2126:23,
2129:5, 2133:21, 2149:12, 2156:15,
2170:8, 2170:10, 2170:17, 2170:24,
2171:1, 2171:3, 2171:5, 2171:17,
2171:20, 2172:2, 2176:4, 2185:14,
2186:7, 2186:12, 2190:21, 2191:3,
2191:6, 2191:21, 2200:14, 2222:20,
2222:23, 2233:25, 2235:9, 2235:17,
2239:2, 2239:9, 2239:10, 2242:8,
2245:12, 2249:3, 2250:18, 2255:17,
2255:18, 2255:23, 2256:3, 2256:19
reality [1] - 2093:7
realization [1] - 2005:4
realized [1] - 2005:2
really [7] - 1987:4, 2013:24, 2019:20,
2042:2, 2096:16, 2170:20, 2231:20
reapply [1] - 2060:10
reason [20] - 1985:10, 2029:19,
2037:4, 2050:18, 2071:12, 2071:20,
2071:21, 2071:24, 2071:25, 2085:24,
2086:5, 2147:21, 2150:15, 2166:24,
2167:6, 2189:1, 2194:11, 2202:1,
2202:4, 2225:22
reasonable [1] - 2031:25
reasonably [1] - 2013:2
reasons [4] - 2071:12, 2086:6,
2123:17, 2251:25
rebuttal [1] - 2241:2
receipt [5] - 2046:4, 2051:12, 2052:15,
2092:1, 2092:8
receive [1] - 2092:4
received [5] - 1993:2, 2055:25,
2063:18, 2149:17, 2151:19
receiver [4] - 2025:20, 2026:3, 2026:4,
2026:5
recent [1] - 2065:3
recently [1] - 2039:2
Recessed [4] - 2035:8, 2079:21,
2155:11, 2257:7
recognize [34] - 2020:23, 2020:25,
2021:4, 2021:5, 2021:7, 2023:3,
2023:8, 2023:23, 2024:19, 2024:22,
2025:6, 2044:6, 2045:8, 2045:11,
2045:22, 2050:14, 2055:14, 2055:19,
2057:2, 2058:8, 2058:11, 2081:15,
2081:18, 2111:14, 2136:13, 2137:6,
2138:9, 2139:1, 2139:9, 2142:13,
2148:11, 2149:22, 2156:3, 2182:6
recognized [1] - 2023:5
recollection [4] - 2044:2, 2050:1,
2137:18, 2198:22
recommendation [2] - 2059:8,
2059:13
recommendations [1] - 2056:18
recommended [1] - 2042:15
record [6] - 2084:5, 2104:2, 2104:3,
2183:18, 2228:13, 2257:11
recorded [2] - 1972:13, 1972:20
records [6] - 2034:11, 2074:23,
2127:6, 2147:5, 2160:6, 2174:25
RECROSS [6] - 1973:10, 1973:23,
1974:2, 2084:17, 2244:3, 2255:3
recross [2] - 2098:4, 2241:3
recruit [1] - 2041:19
red [3] - 2000:2, 2085:17, 2186:8
redact [1] - 2045:13
Redhead [9] - 1988:19, 1990:13,
1994:5, 1994:7, 2002:4, 2002:9,
2002:10, 2003:19, 2086:5
redirect [3] - 2086:18, 2088:13,
2088:17
REDIRECT [8] - 1973:8, 1973:12,
1973:21, 1973:25, 2062:2, 2098:2,
2233:16, 2251:6
reduce [1] - 2088:11
reel [1] - 2205:7
reference [4] - 1991:11, 2047:10,
2053:11, 2181:7
referenced [5] - 1980:6, 1989:7,
2056:7, 2117:10, 2157:3
references [1] - 2053:5
referencing [2] - 1980:11, 2117:16
referred [3] - 2002:24, 2082:10,
2186:14
referring [4] - 2010:8, 2049:1,
2105:18, 2255:7
refers [2] - 2083:7, 2255:10
reflect [1] - 2104:3
refresh [5] - 2044:2, 2049:25, 2087:3,
2180:24, 2184:18
regard [11] - 2000:25, 2015:20,
2034:8, 2072:3, 2078:12, 2193:6,
2201:9, 2209:8, 2210:6, 2215:21,
2220:22
regarding [15] - 1992:8, 1996:20,
2004:10, 2010:19, 2011:21, 2016:4,
2036:6, 2036:7, 2052:11, 2069:25,
2070:18, 2096:1, 2196:17, 2220:15,
2225:17
regardless [2] - 2239:1, 2243:21
regime [6] - 2011:8, 2011:24, 2013:16,
2033:17, 2071:23, 2088:22
region [3] - 2024:11, 2042:2, 2064:19
regret [1] - 2168:16
regrets [1] - 2168:17
regulate [4] - 2003:8, 2005:2, 2007:2,
2052:15
regulated [4] - 1978:8, 1996:4, 2005:5,
2061:7
regulating [3] - 2011:25, 2054:23,
2065:11
regulation [3] - 1985:8, 2004:4,
2066:10
regulations [15] - 1982:10, 2003:24,
Johnny C. Sanchez, RMR, CRR - [email protected]
2284
2005:7, 2007:19, 2010:19, 2011:21,
2060:6, 2065:13, 2065:14, 2073:24,
2206:18, 2223:20, 2223:23, 2224:9,
2224:10
regulator [10] - 1991:1, 1996:18,
1997:4, 2000:24, 2001:13, 2040:5,
2047:20, 2051:12, 2052:10, 2072:7
regulators [3] - 1981:5, 1981:9,
1981:20
regulatory [29] - 1976:2, 2001:22,
2007:3, 2009:18, 2010:1, 2011:8,
2013:16, 2014:13, 2015:14, 2028:21,
2029:1, 2029:12, 2030:14, 2033:17,
2038:12, 2040:13, 2040:23, 2042:6,
2042:19, 2043:24, 2065:13, 2066:16,
2068:22, 2069:17, 2071:23, 2072:19,
2088:21, 2249:9
rehabilitate [1] - 2120:20
Rehnquist [1] - 2039:8
relate [1] - 1979:1
related [11] - 2138:5, 2158:7, 2158:14,
2238:23, 2239:11, 2239:13, 2239:23,
2239:24, 2240:14, 2240:22, 2241:19
related-party [8] - 2238:23, 2239:11,
2239:13, 2239:23, 2239:24, 2240:14,
2240:22, 2241:19
relates [1] - 1976:6
relation [1] - 2131:11
relationship [3] - 2131:7, 2131:13,
2131:14
relative [2] - 2139:24, 2169:3
released [6] - 1975:17, 1975:19,
1975:20, 1975:23, 1975:24, 2098:18
releasing [1] - 1979:23
relevance [2] - 2128:10, 2147:15
relevant [6] - 2031:13, 2066:12,
2148:5, 2148:7, 2251:22, 2253:18
relocate [1] - 2164:13
relying [2] - 2164:22, 2252:8
remember [60] - 1979:1, 1988:5,
1988:11, 1989:21, 2005:19, 2009:23,
2012:16, 2013:4, 2013:8, 2013:18,
2014:7, 2014:9, 2014:10, 2026:13,
2040:7, 2041:4, 2041:13, 2043:8,
2044:10, 2049:3, 2075:22, 2076:11,
2079:17, 2086:18, 2086:24, 2088:16,
2089:8, 2092:1, 2092:25, 2102:24,
2108:7, 2115:12, 2117:6, 2176:24,
2177:6, 2177:9, 2178:5, 2180:8,
2180:18, 2180:21, 2181:9, 2182:8,
2182:12, 2182:21, 2183:25, 2184:1,
2184:6, 2184:7, 2186:1, 2188:25,
2196:4, 2219:2, 2223:2, 2223:4,
2233:18, 2234:2, 2235:14, 2242:10
remind [2] - 2064:16, 2097:12
reminding [1] - 2035:1
removal [3] - 2094:11, 2094:16,
2095:10
removed [4] - 2093:2, 2093:7,
2093:11, 2095:5
removement [1] - 2094:10
removing [2] - 2093:21, 2093:25
render [1] - 2072:11
rental [2] - 2120:8, 2171:18
repair [1] - 2164:11
repealed [3] - 2071:7, 2071:10,
2071:12
repeat [3] - 1992:21, 2110:25, 2124:6
repeatedly [1] - 2240:22
rephrase [4] - 2072:9, 2083:19,
2116:6, 2123:20
replaced [3] - 2064:23, 2064:25,
2199:23
replied [1] - 2012:11
report [60] - 2007:5, 2008:4, 2011:1,
2011:4, 2011:6, 2011:9, 2013:5,
2027:12, 2028:18, 2028:20, 2029:16,
2030:9, 2030:11, 2031:7, 2040:8,
2040:9, 2049:13, 2056:17, 2057:2,
2058:4, 2058:9, 2058:12, 2064:9,
2094:25, 2109:22, 2111:15, 2125:21,
2148:12, 2148:24, 2156:9, 2156:23,
2157:7, 2157:12, 2158:1, 2158:3,
2158:6, 2158:17, 2158:21, 2158:25,
2159:15, 2159:19, 2160:2, 2177:19,
2180:12, 2180:15, 2180:24, 2184:18,
2188:21, 2228:6, 2228:22, 2229:1,
2229:8, 2229:14, 2229:21, 2230:13,
2238:19, 2246:17, 2246:24, 2248:7,
2248:16
Report [1] - 2030:21
reported [3] - 2095:1, 2107:3, 2222:6
Reporter [2] - 1972:10, 1972:17
reporter [1] - 2099:12
REPORTER'S [1] - 2257:8
reporting [11] - 2015:24, 2028:14,
2032:24, 2088:22, 2106:25, 2158:11,
2158:14, 2221:15, 2222:2, 2222:16,
2238:13
Reporting [1] - 2239:20
reports [23] - 2012:10, 2027:6, 2027:8,
2027:10, 2027:11, 2033:4, 2033:7,
2033:20, 2034:14, 2035:2, 2074:11,
2109:17, 2159:17, 2174:25, 2177:12,
2185:24, 2187:11, 2187:12, 2221:11,
2222:18, 2239:5, 2241:25, 2251:16
represent [4] - 1980:2, 1980:14,
1992:7, 2252:11
representation [1] - 2119:10
representations [1] - 2252:12
representative [1] - 2119:10
representing [2] - 1981:20, 2032:14
reputation [2] - 2026:18, 2026:19
request [14] - 1975:18, 1996:16,
1997:10, 1997:18, 1998:6, 2046:4,
2047:5, 2047:7, 2049:10, 2049:12,
2091:20, 2091:21, 2092:3, 2092:20
request/application [1] - 2059:5
requested [9] - 1996:19, 1997:14,
2034:2, 2043:25, 2053:16, 2080:24,
2084:8, 2091:13, 2091:15
Requested [2] - 1977:1, 2076:23
requesting [3] - 2046:6, 2103:3,
2161:6
requests [2] - 2042:5, 2047:19
require [5] - 2049:6, 2066:10, 2206:12,
2206:15, 2206:17
required [18] - 1976:7, 1978:9, 1979:2,
2040:17, 2048:22, 2050:7, 2066:15,
2091:22, 2109:19, 2112:14, 2112:17,
2118:6, 2158:15, 2205:20, 2222:13,
2222:17, 2224:11, 2252:4
requirement [5] - 2028:24, 2041:1,
2051:7, 2078:15, 2247:1
requirements [7] - 2046:23, 2047:17,
2047:19, 2048:6, 2051:3, 2222:3,
2222:16
requires [4] - 2047:23, 2048:3, 2065:8,
2252:12
research [1] - 2231:6
residence [1] - 2178:22
residential [2] - 2120:8, 2183:22
resign [2] - 2166:16, 2167:25
resigning [1] - 2166:25
resort [16] - 2164:18, 2164:20, 2165:2,
2165:5, 2165:6, 2165:14, 2166:1,
2218:13, 2218:14, 2218:17, 2218:24,
2219:5, 2219:17, 2237:6, 2237:10,
2237:18
resorts [8] - 2162:17, 2162:19, 2163:4,
2163:9, 2163:11, 2163:19, 2164:17,
2165:1
resources [9] - 1979:9, 2122:3,
2122:16, 2127:1, 2127:5, 2142:9,
2145:20, 2243:25
respect [7] - 2011:25, 2019:18,
2026:20, 2026:22, 2071:22, 2234:4,
2234:8
respectfully [2] - 2053:20, 2112:22
Respective [1] - 2031:1
respond [4] - 2070:9, 2128:22,
2128:24, 2189:22
responding [1] - 2060:5
response [16] - 1982:8, 1987:22,
2037:1, 2040:10, 2057:16, 2057:17,
2058:5, 2058:14, 2059:2, 2078:21,
2078:23, 2079:7, 2089:2, 2110:4,
2116:24, 2116:25
Responsibilities [1] - 2031:2
responsibility [2] - 2031:5, 2079:4
responsible [6] - 2031:4, 2101:18,
2133:19, 2176:9, 2199:1, 2199:4
rest [4] - 2059:20, 2122:1, 2131:18,
2247:20
restated [1] - 2071:1
restaurant [7] - 2081:21, 2236:10,
2236:11, 2236:13, 2236:14, 2236:19,
2249:18
Restaurant [3] - 2137:1, 2211:13,
2211:16
result [5] - 1985:8, 2013:20, 2015:16,
2028:11, 2095:11
resulted [2] - 2011:1, 2064:10
results [2] - 2014:23, 2032:21
resume [3] - 2035:6, 2155:10, 2257:5
resumé [2] - 2103:7, 2103:8
retired [1] - 2100:12
return [5] - 2183:24, 2184:2, 2184:5,
2184:20, 2185:17Johnny C. Sanchez, RMR, CRR - [email protected]
2285
returned [1] - 2093:5
revealed [1] - 2014:23
revealing [1] - 1977:15
Revenue [5] - 2225:13, 2225:16,
2225:24, 2226:1, 2226:9
reverse [1] - 2147:25
review [6] - 2028:22, 2086:12,
2095:25, 2109:7, 2118:6, 2229:17
reviewed [8] - 2032:11, 2109:12,
2110:23, 2185:24, 2228:25, 2229:14,
2229:15, 2241:6
reviewing [1] - 2119:3
reviews [1] - 2033:9
revise [1] - 2076:7
revive [1] - 2020:18
revocation [5] - 2002:24, 2067:1,
2068:4, 2098:9, 2098:11
revoke [5] - 1988:9, 1990:23, 2087:2,
2087:4, 2130:2
revoked [9] - 1988:20, 1988:22,
1991:3, 1992:9, 1992:13, 2002:22,
2067:20, 2086:13, 2086:22
Rican [1] - 2009:18
rich [2] - 2220:10, 2221:3
richest [1] - 2218:11
Richmond [2] - 2178:6, 2178:7
rid [1] - 2014:19
right-hand [1] - 2073:12
rights [6] - 2096:21, 2097:4, 2217:15,
2225:21, 2247:8
rise [4] - 2019:14, 2019:16, 2019:18,
2176:17
risk [13] - 2113:14, 2113:22, 2126:4,
2126:5, 2126:10, 2126:13, 2126:17,
2126:18, 2163:19, 2163:20, 2163:24,
2237:18, 2251:17
river [1] - 2119:5
RMR [3] - 1972:10, 1972:18, 2257:14
roads [1] - 2164:20
robe [4] - 2000:2, 2039:9, 2039:16,
2039:21
Robert [6] - 1971:21, 2046:7, 2047:3,
2157:13, 2157:17, 2169:12
ROBERT [1] - 1971:6
Roberts [2] - 2039:19
Roche [1] - 2014:11
Rock [1] - 2122:7
Roe [4] - 2000:24, 2001:2, 2001:3,
2001:7
roll [1] - 2062:22
rolled [1] - 2069:22
roommates [1] - 2131:9
Ross [1] - 2220:23
round [2] - 2240:25, 2241:1
RPR [2] - 1972:10, 1972:18
rule [3] - 2051:17, 2078:22, 2079:12
rules [4] - 2017:3, 2222:8, 2223:18
ruling [4] - 1980:12, 2083:20, 2098:19,
2147:25
run [8] - 2082:18, 2120:20, 2214:13,
2214:15, 2215:19, 2233:12, 2249:8
running [9] - 1983:11, 2015:15,
2019:10, 2042:6, 2043:24, 2083:22,
2083:24, 2211:6, 2233:24
Rusk [2] - 1972:11, 1972:18
Russian [1] - 2014:19
Ryan [1] - 2220:24
S
safe [1] - 2185:4
salary [4] - 2168:10, 2169:21, 2169:25,
2170:2
sale [8] - 2134:11, 2135:12, 2171:15,
2171:16, 2171:18, 2187:3, 2187:12
sales [1] - 2207:1
salespeople [2] - 2108:2, 2108:3
San [3] - 2102:3, 2102:4, 2134:20
Sanchez [4] - 1972:10, 1972:18,
2257:10, 2257:14
Sandra [1] - 2014:10
sat [1] - 2167:3
Saturday [1] - 2103:14
save [1] - 2156:11
savings [1] - 2102:1
saw [21] - 1987:18, 1988:13, 2011:6,
2108:16, 2108:20, 2125:20, 2131:15,
2131:16, 2142:1, 2144:20, 2156:19,
2158:3, 2196:25, 2197:2, 2205:5,
2211:3, 2234:11, 2239:5, 2239:10,
2239:16, 2241:10
Scardino [16] - 1971:21, 1971:21,
2072:7, 2113:5, 2169:12, 2233:19,
2234:13, 2235:11, 2236:2, 2237:21,
2238:5, 2239:18, 2242:8, 2243:11,
2252:24, 2254:13
SCARDINO [86] - 2027:20, 2105:17,
2105:25, 2110:2, 2110:11, 2110:22,
2111:11, 2112:5, 2112:22, 2113:3,
2113:18, 2114:13, 2116:1, 2116:14,
2117:22, 2121:4, 2123:18, 2124:4,
2125:5, 2128:10, 2134:23, 2142:25,
2145:9, 2145:12, 2146:19, 2147:11,
2147:15, 2150:5, 2150:7, 2150:9,
2152:9, 2152:18, 2153:18, 2161:9,
2169:9, 2173:24, 2174:1, 2175:23,
2176:2, 2180:17, 2180:22, 2180:23,
2181:5, 2184:13, 2184:17, 2197:10,
2200:12, 2203:13, 2207:4, 2207:17,
2207:21, 2208:6, 2208:9, 2208:13,
2208:15, 2227:1, 2227:4, 2227:17,
2227:20, 2227:22, 2228:3, 2228:20,
2229:22, 2230:1, 2230:4, 2231:11,
2231:18, 2232:4, 2232:6, 2233:15,
2239:25, 2240:19, 2244:2, 2244:4,
2245:23, 2246:1, 2247:11, 2247:16,
2251:5, 2251:21, 2254:2, 2254:4,
2254:23, 2255:1, 2255:4, 2256:21
Scardino's [1] - 2111:8
SCARDINO........... [2] - 1973:23,
1974:2
SCARDINO............. [1] - 1973:19
scenes [1] - 2039:11
schedule [3] - 1979:2, 1979:10,
2034:22
School [1] - 2100:3
school [2] - 2102:7, 2102:8
schools [1] - 2100:2
Schramm [2] - 2216:3, 2216:8
scope [5] - 2035:22, 2036:22, 2088:13,
2240:19, 2251:22
screen [7] - 1980:21, 2004:1, 2035:5,
2079:19, 2156:21, 2159:11, 2257:3
scroll [2] - 2059:19, 2059:23
scrolling [1] - 2059:22
scrub [2] - 2013:22, 2014:19
seal [1] - 2207:20
seat [2] - 2035:11, 2099:3
seated [3] - 1975:2, 1985:2, 2155:13
second [33] - 1989:15, 1996:1, 2011:1,
2013:5, 2021:8, 2026:4, 2035:25,
2037:7, 2038:8, 2038:17, 2040:8,
2051:17, 2052:25, 2058:23, 2067:14,
2076:19, 2079:19, 2114:5, 2121:13,
2121:20, 2122:2, 2123:23, 2124:13,
2149:23, 2150:5, 2153:16, 2153:25,
2154:10, 2163:22, 2181:6, 2182:18,
2182:21, 2201:25
seconds [2] - 1983:9, 1983:10
secrecy [3] - 1975:12, 2016:14,
2072:22
secretary [1] - 2000:11
Section [16] - 2046:8, 2050:23,
2050:24, 2051:2, 2051:4, 2051:11,
2052:14, 2058:8, 2062:19, 2065:17,
2065:20, 2066:5, 2089:3, 2089:19,
2091:3, 2091:25
section [7] - 2030:9, 2050:16,
2051:11, 2059:7, 2086:19, 2089:22,
2092:11
Sections [1] - 2090:4
sections [6] - 1987:20, 1994:8,
2003:21, 2090:15, 2090:18, 2090:22
sector [12] - 2005:4, 2006:8, 2006:13,
2006:14, 2011:7, 2011:8, 2011:13,
2042:1, 2065:11, 2065:12, 2068:10,
2069:25
Sector [3] - 2005:20, 2006:2, 2007:9
Sectoral [3] - 2010:9, 2010:22,
2068:25
sectoral [3] - 2069:2, 2069:3, 2069:13
sectors [1] - 2042:1
securities [6] - 2247:14, 2247:18,
2253:9, 2254:7, 2255:6, 2255:9
security [3] - 1981:21, 1982:16,
1987:3
see [65] - 1976:1, 1981:1, 1989:2,
1990:3, 1990:8, 1990:10, 1990:12,
1999:23, 2001:9, 2003:3, 2004:1,
2006:12, 2017:25, 2020:23, 2028:17,
2030:11, 2035:6, 2035:7, 2044:3,
2055:18, 2057:6, 2057:14, 2063:12,
2073:17, 2073:21, 2073:22, 2079:11,
2079:19, 2089:12, 2093:17, 2093:19,
2096:22, 2096:24, 2097:1, 2103:21,
2110:14, 2117:12, 2120:3, 2127:6,
2147:5, 2148:6, 2148:21, 2149:3,Johnny C. Sanchez, RMR, CRR - [email protected]
2286
2149:12, 2151:19, 2151:24, 2155:10,
2156:24, 2157:6, 2157:12, 2173:1,
2177:19, 2181:6, 2195:12, 2207:22,
2208:10, 2208:16, 2219:19, 2229:12,
2230:5, 2235:11, 2250:21, 2257:2,
2257:5
seek [5] - 2001:14, 2054:24, 2103:19,
2162:12, 2162:15
seeking [1] - 1994:25
seem [3] - 2131:20, 2131:25, 2215:23
Seidman [1] - 2009:5
seized [1] - 1998:20
selected [1] - 2162:24
sell [12] - 2103:20, 2120:20, 2125:22,
2126:2, 2133:25, 2134:8, 2166:5,
2251:13, 2253:21, 2253:22, 2254:11,
2256:17
selling [5] - 2108:4, 2108:25, 2115:22,
2116:11, 2246:16
sells [3] - 1982:2, 2256:4, 2256:8
semiretired [1] - 2099:21
sending [3] - 2015:21, 2167:4
senior [1] - 2043:16
sense [4] - 2144:12, 2235:4, 2235:5,
2243:6
sent [9] - 2013:9, 2013:13, 2042:24,
2062:14, 2065:5, 2103:8, 2130:1,
2166:21, 2167:19
sentence [5] - 2058:23, 2087:19,
2087:24, 2091:15, 2230:7
separate [13] - 2104:19, 2104:20,
2107:18, 2119:24, 2120:22, 2137:13,
2137:19, 2162:1, 2162:4, 2165:12,
2210:17, 2210:18, 2225:2
separately [4] - 2121:10, 2121:22,
2122:11, 2123:12
September [3] - 2043:10, 2043:12,
2056:24
series [3] - 2020:22, 2064:8, 2075:21
serves [1] - 2025:1
Service [6] - 2016:4, 2225:13,
2225:16, 2225:24, 2226:1, 2226:9
service [1] - 2006:23
services [11] - 1976:15, 2004:19,
2005:3, 2006:20, 2006:21, 2041:20,
2132:13, 2132:20, 2203:21, 2203:24,
2220:16
Services [11] - 2023:11, 2068:25,
2102:15, 2106:17, 2107:15, 2107:23,
2114:12, 2123:3, 2133:5, 2133:6,
2188:5
set [13] - 2013:3, 2033:17, 2040:14,
2060:1, 2063:25, 2088:21, 2120:22,
2121:14, 2121:20, 2122:18, 2122:23,
2140:22, 2151:23
sets [5] - 2042:17, 2082:10, 2082:12,
2082:13
seven [2] - 2171:19, 2171:20
several [5] - 2064:18, 2071:12,
2197:17, 2209:9, 2232:2
sewn [1] - 2039:10
shade [3] - 2141:16, 2141:18, 2141:20
shading [1] - 2141:23
shall [1] - 2046:14
shape [1] - 2211:1
share [1] - 2055:5
shared [1] - 1976:2
shareholder [8] - 2192:11, 2222:18,
2222:24, 2223:2, 2228:10, 2242:6,
2249:4, 2254:19
shareholders [1] - 2222:6
shares [3] - 2046:16, 2253:21, 2253:22
sharing [1] - 2055:1
shift [1] - 2221:9
shocked [2] - 2180:2, 2180:4
short [4] - 1999:25, 2007:12, 2038:25,
2039:23
shorter [1] - 2217:6
shortly [1] - 2108:12
shot [1] - 2139:9
show [29] - 1988:4, 1988:24, 1990:22,
2000:24, 2017:7, 2020:21, 2023:7,
2027:16, 2030:8, 2045:5, 2049:25,
2055:11, 2055:16, 2056:11, 2066:21,
2087:9, 2106:3, 2111:9, 2114:14,
2140:16, 2142:10, 2149:21, 2152:15,
2153:13, 2180:24, 2194:15, 2229:7,
2229:18, 2239:12
showed [18] - 1990:23, 2003:13,
2039:9, 2065:17, 2067:13, 2080:13,
2086:17, 2154:13, 2221:10, 2223:1,
2223:2, 2228:7, 2228:8, 2228:10,
2228:11, 2228:23, 2229:9, 2249:8
showing [6] - 1979:25, 2127:7,
2139:11, 2149:12, 2196:5, 2252:24
shown [12] - 1980:8, 1986:14,
1986:16, 1987:19, 1988:5, 1988:19,
2003:14, 2074:11, 2088:16, 2196:3,
2228:23, 2229:6
shows [3] - 2139:13, 2139:14, 2149:2
shut [2] - 2004:22, 2102:2
SIB [2] - 2026:5, 2058:18
SIBL [15] - 1981:5, 1981:12, 1982:2,
1982:9, 1985:8, 2003:8, 2015:12,
2016:2, 2020:18, 2025:2, 2027:11,
2033:4, 2033:18, 2042:22, 2085:10
sic [2] - 1981:21, 2134:25
side [10] - 1984:14, 1984:18, 2016:1,
2058:2, 2073:12, 2073:13, 2079:1,
2114:5, 2126:1
side-by-side [1] - 2058:2
sidebar [1] - 2076:1
sides [1] - 2240:24
signature [13] - 2027:23, 2029:21,
2029:24, 2030:1, 2030:22, 2032:11,
2044:8, 2149:22, 2149:25, 2156:1,
2156:3, 2156:6
signed [9] - 1994:4, 2002:4, 2027:7,
2027:14, 2027:15, 2033:1, 2057:13,
2150:12, 2150:18
significant [2] - 1989:15, 2031:15
signing [1] - 2160:1
similar [1] - 2154:12
simple [1] - 1996:13
simply [2] - 1985:11, 2078:14
single [2] - 1977:18, 2027:8
sit [3] - 1991:11, 2128:13, 2166:18
site [1] - 2033:11
sits [1] - 1983:4
sitting [2] - 1984:5, 1984:12
situation [2] - 2082:20, 2083:7
six [1] - 2099:17
sixteen [1] - 2169:16
sixth [1] - 2021:16
skill [1] - 2042:16
skip [3] - 1991:6, 2002:19, 2002:23
Slate [21] - 2010:6, 2012:7, 2013:19,
2013:22, 2013:25, 2014:3, 2014:8,
2014:15, 2014:18, 2014:22, 2015:5,
2015:11, 2015:16, 2069:21, 2069:22,
2069:24, 2070:2, 2070:8, 2070:13,
2070:22, 2072:3
Slater [3] - 2107:2, 2109:14, 2181:11
sleeves [1] - 2039:10
slide [7] - 2058:6, 2059:16, 2059:17,
2059:18, 2059:19, 2059:20
slides [1] - 2059:15
slight [1] - 2084:2
slow [4] - 2046:11, 2173:23, 2175:22
small [10] - 2107:20, 2107:24, 2109:6,
2121:2, 2135:11, 2141:2, 2160:16,
2164:9, 2186:14, 2192:21
smart [3] - 2173:2, 2173:5, 2191:6
smell [1] - 2205:8
SO [1] - 2121:5
Society [1] - 2168:8
sold [7] - 2125:19, 2233:6, 2233:8,
2233:9, 2242:18, 2244:13
sole [2] - 2242:6, 2254:19
solicitor [1] - 2095:4
someone [7] - 1985:11, 2045:11,
2086:11, 2104:7, 2130:23, 2196:16,
2241:24
sometime [4] - 2040:9, 2042:21,
2043:10, 2198:14
sometimes [7] - 2203:6, 2223:7,
2245:12, 2245:18, 2248:11, 2249:25,
2250:4
somewhat [3] - 2012:18, 2183:3,
2221:18
somewhere [4] - 2026:17, 2093:21,
2229:22, 2251:24
soon [4] - 2053:17, 2097:3, 2099:18,
2099:19
sorry [31] - 1978:22, 1981:12, 1989:12,
1992:20, 1999:3, 2004:1, 2004:7,
2029:7, 2061:19, 2067:10, 2069:4,
2069:14, 2070:10, 2073:13, 2077:23,
2080:8, 2084:10, 2127:20, 2127:24,
2128:3, 2128:17, 2148:13, 2157:4,
2173:24, 2175:23, 2178:9, 2227:15,
2230:19, 2240:3, 2246:23, 2254:2
sort [5] - 2078:15, 2164:1, 2164:5,
2182:1, 2206:17
sorts [1] - 2096:23
sought [1] - 2095:8
soul [1] - 2019:19
Johnny C. Sanchez, RMR, CRR - [email protected]
2287
sound [1] - 1993:18
sounds [3] - 2000:12, 2007:7, 2014:16
source [1] - 2142:7
sources [1] - 2127:7
South [5] - 2004:13, 2020:6, 2213:18,
2231:24, 2232:2
SOUTHERN [1] - 1971:1
southwest [3] - 2121:2, 2121:19,
2122:9
Southwest [2] - 2186:18, 2186:19
space [1] - 2233:3
speaking [12] - 1975:21, 1975:22,
1996:3, 1996:13, 2000:14, 2000:18,
2001:1, 2023:2, 2055:21, 2055:24,
2206:20, 2228:7
speaks [2] - 2058:21, 2163:21
specialize [1] - 1979:17
specific [11] - 2166:24, 2170:14,
2183:9, 2183:10, 2183:12, 2184:7,
2184:24, 2197:17, 2203:16, 2226:2,
2247:1
specifically [11] - 1976:9, 2042:22,
2047:1, 2056:7, 2115:10, 2115:12,
2172:4, 2183:23, 2199:8, 2203:24,
2210:25
specification [1] - 2059:7
specifications [2] - 2201:2, 2201:4
specifics [2] - 1981:6, 2013:18
specified [1] - 2239:6
specify [1] - 2107:9
speculation [1] - 2200:9
speculative [3] - 2163:8, 2163:12,
2165:24
speech [3] - 2142:16, 2143:9, 2144:17
speed [1] - 2062:22
spell [3] - 2099:12, 2121:4, 2134:23
spend [5] - 2120:19, 2136:8, 2183:1,
2219:20, 2250:5
spending [1] - 2136:5
spent [8] - 2160:22, 2160:23, 2167:10,
2168:20, 2211:24, 2220:6, 2243:18,
2243:20
sport [4] - 2213:13, 2213:14, 2214:11,
2217:2
sports [9] - 2213:12, 2214:21,
2215:24, 2216:5, 2216:6, 2216:7,
2216:13, 2217:14, 2250:24
spot [1] - 2214:16
spread [1] - 2162:11
spreads [1] - 2164:2
spring [2] - 2016:2, 2040:6
Springs [4] - 2122:7, 2135:12,
2197:19, 2242:21
Square [1] - 2121:17
St [2] - 2063:21, 2168:8
stable [2] - 2187:4, 2187:6
stacked [1] - 2097:2
staff [6] - 2041:19, 2042:11, 2042:13,
2042:15, 2042:16
staffing [1] - 2163:17
stage [1] - 2162:22
stand [1] - 2196:13
standard [7] - 2140:21, 2140:23,
2150:15, 2239:13, 2239:22, 2241:17,
2249:9
standards [19] - 2028:14, 2031:12,
2032:24, 2125:10, 2158:11, 2158:14,
2222:22, 2230:9, 2230:15, 2230:18,
2238:6, 2238:12, 2238:13, 2238:22,
2240:22, 2241:19, 2249:6, 2249:7
Standards [1] - 2239:21
standing [20] - 1984:11, 1984:14,
1984:18, 1994:25, 1995:2, 1995:6,
1995:19, 1996:10, 1996:12, 1998:7,
2036:6, 2043:25, 2046:4, 2046:22,
2053:19, 2054:16, 2054:19, 2054:21,
2103:25, 2195:4
Stanford [339] - 1976:12, 1976:13,
1976:16, 1977:17, 1978:16, 1978:22,
1979:13, 1979:20, 1980:3, 1980:15,
1984:22, 1988:21, 1990:8, 1990:9,
1992:15, 1992:19, 1992:23, 1993:6,
1993:7, 1993:12, 1993:14, 1994:10,
1994:12, 1994:14, 1995:8, 1995:12,
1997:13, 1997:18, 1998:6, 1998:10,
1999:3, 2000:9, 2000:17, 2000:19,
2000:23, 2001:2, 2002:14, 2007:22,
2008:6, 2015:8, 2015:9, 2016:10,
2020:17, 2023:11, 2024:3, 2025:2,
2025:3, 2043:5, 2043:23, 2046:1,
2046:20, 2054:2, 2054:5, 2056:18,
2057:3, 2057:8, 2063:19, 2063:20,
2064:3, 2065:2, 2068:21, 2069:5,
2069:9, 2069:16, 2069:23, 2071:19,
2072:17, 2072:18, 2074:5, 2075:9,
2075:18, 2076:6, 2076:14, 2077:3,
2081:22, 2086:11, 2086:17, 2087:10,
2088:21, 2093:2, 2093:10, 2093:17,
2093:21, 2093:24, 2094:12, 2094:15,
2095:20, 2097:17, 2102:20, 2103:12,
2103:16, 2103:21, 2104:4, 2104:6,
2104:23, 2105:9, 2105:15, 2105:21,
2106:8, 2106:10, 2106:21, 2107:3,
2107:6, 2107:7, 2107:11, 2109:10,
2109:15, 2109:19, 2109:24, 2110:7,
2110:9, 2110:18, 2111:3, 2112:14,
2112:18, 2113:10, 2114:25, 2115:8,
2115:13, 2115:18, 2115:22, 2116:12,
2116:20, 2117:1, 2117:16, 2117:20,
2118:1, 2119:1, 2119:8, 2119:18,
2120:2, 2121:21, 2122:1, 2122:10,
2122:15, 2123:11, 2124:8, 2126:21,
2127:3, 2127:9, 2128:6, 2128:19,
2129:3, 2129:13, 2129:15, 2129:22,
2130:5, 2130:19, 2132:14, 2132:19,
2133:1, 2133:12, 2134:19, 2135:2,
2135:14, 2135:20, 2135:21, 2135:23,
2136:3, 2136:17, 2137:3, 2137:10,
2137:12, 2137:13, 2137:15, 2137:16,
2137:23, 2137:24, 2138:4, 2139:3,
2139:14, 2139:25, 2140:3, 2140:13,
2140:18, 2141:7, 2141:11, 2141:15,
2142:7, 2142:8, 2142:11, 2142:13,
2142:18, 2144:1, 2144:7, 2144:16,
2144:25, 2145:24, 2146:1, 2146:22,
2147:8, 2148:11, 2148:15, 2148:17,
2149:17, 2149:18, 2150:1, 2150:18,
2151:14, 2151:20, 2152:4, 2152:11,
2153:1, 2154:25, 2156:7, 2156:23,
2157:6, 2157:13, 2157:17, 2158:8,
2158:9, 2158:10, 2159:22, 2160:11,
2160:14, 2160:23, 2161:4, 2161:12,
2161:23, 2161:25, 2162:4, 2162:9,
2164:25, 2165:11, 2166:11, 2166:14,
2166:18, 2167:3, 2167:20, 2168:14,
2168:20, 2168:23, 2169:5, 2169:6,
2169:15, 2169:18, 2169:24, 2170:2,
2170:8, 2171:6, 2171:14, 2172:7,
2174:15, 2174:20, 2174:22, 2175:4,
2176:8, 2176:13, 2179:13, 2180:9,
2181:8, 2183:22, 2184:19, 2185:4,
2185:14, 2186:2, 2187:8, 2187:16,
2187:22, 2188:11, 2188:22, 2189:19,
2190:15, 2191:6, 2191:14, 2191:22,
2192:9, 2194:12, 2195:11, 2195:16,
2198:15, 2199:18, 2200:14, 2201:15,
2202:18, 2202:19, 2202:21, 2203:1,
2204:24, 2205:15, 2206:2, 2208:24,
2209:8, 2209:17, 2210:7, 2210:11,
2210:15, 2210:16, 2210:19, 2211:12,
2211:25, 2214:21, 2216:11, 2218:10,
2219:4, 2221:12, 2222:6, 2222:17,
2222:24, 2225:14, 2227:7, 2227:12,
2228:6, 2229:4, 2229:20, 2230:21,
2231:14, 2232:16, 2232:24, 2233:11,
2233:23, 2234:7, 2234:17, 2234:20,
2234:24, 2235:7, 2236:12, 2237:8,
2237:9, 2238:1, 2238:11, 2238:16,
2241:10, 2242:6, 2243:5, 2243:22,
2246:16, 2246:25, 2251:9, 2251:18,
2252:3, 2253:15, 2254:14
STANFORD [1] - 1971:6
Stanford's [35] - 1997:19, 1998:3,
2023:6, 2024:4, 2068:16, 2072:14,
2075:2, 2105:11, 2106:3, 2107:5,
2108:15, 2121:9, 2131:7, 2131:11,
2131:13, 2132:6, 2132:9, 2138:23,
2146:17, 2160:18, 2161:16, 2166:7,
2167:15, 2196:17, 2202:20, 2204:25,
2209:18, 2215:24, 2229:7, 2231:23,
2232:14, 2232:21, 2232:24, 2249:7
Star [2] - 2138:3, 2146:10
start [15] - 2029:6, 2040:14, 2041:18,
2045:25, 2046:3, 2056:12, 2077:15,
2084:19, 2102:10, 2146:1, 2146:8,
2224:14, 2249:22, 2249:25, 2250:4
started [33] - 2010:25, 2015:19,
2015:21, 2037:23, 2042:19, 2054:24,
2060:7, 2100:15, 2101:15, 2107:14,
2123:4, 2124:1, 2124:8, 2127:3,
2129:13, 2130:5, 2132:25, 2133:4,
2133:13, 2133:20, 2135:1, 2138:1,
2139:20, 2140:9, 2141:11, 2170:2,
2181:12, 2190:6, 2193:11, 2201:24,
2228:2, 2228:14, 2249:19
starting [2] - 2063:17, 2209:3
State [1] - 2055:4
state [4] - 1976:24, 2028:10, 2032:20,
Johnny C. Sanchez, RMR, CRR - [email protected]
2288
2160:8
statement [21] - 1981:8, 1981:16,
1981:24, 1982:4, 1982:12, 1982:18,
1995:20, 2030:23, 2047:11, 2047:14,
2074:1, 2087:5, 2087:7, 2089:24,
2091:8, 2091:10, 2092:22, 2105:18,
2105:21, 2150:19, 2256:18
statements [25] - 2028:9, 2028:12,
2030:24, 2031:5, 2031:6, 2031:14,
2031:17, 2031:25, 2032:7, 2032:12,
2032:13, 2032:19, 2033:10, 2074:13,
2074:17, 2101:20, 2133:14, 2160:9,
2174:11, 2199:5, 2211:4, 2222:7,
2228:8, 2229:4, 2238:17
STATES [3] - 1971:1, 1971:4, 1971:10
states [2] - 2046:13, 2054:21
States [11] - 1986:22, 2011:10, 2013:9,
2013:12, 2016:3, 2026:4, 2081:25,
2098:24, 2136:4, 2221:21, 2222:1
stating [1] - 2053:6
status [2] - 2100:11, 2100:12
statute [4] - 1976:22, 2049:5, 2065:10
statutes [2] - 2052:14, 2065:8
statutory [4] - 2046:9, 2046:22,
2048:5, 2050:6
stay [3] - 2102:11, 2141:11, 2218:3
stayed [1] - 2185:11
Stellmach [1] - 1971:16
stenography [2] - 1972:13, 1972:20
step [3] - 2098:16, 2190:4, 2256:24
Stevens [1] - 2039:3
stick [4] - 2011:19, 2012:9, 2082:5,
2098:18
sticker [2] - 2045:15, 2158:24
sticks [2] - 2082:1, 2082:3
Sticky [19] - 2081:18, 2081:20,
2081:21, 2081:23, 2082:4, 2083:12,
2084:10, 2084:25, 2085:12, 2085:13,
2137:1, 2139:13, 2211:12, 2213:5,
2213:8, 2214:22, 2215:13, 2243:3,
2249:14
sticky [5] - 2082:8, 2082:19, 2083:7,
2084:11, 2214:16
still [27] - 2015:5, 2015:7, 2015:12,
2024:5, 2062:4, 2071:4, 2090:10,
2090:16, 2099:21, 2101:4, 2112:25,
2123:11, 2124:9, 2134:7, 2153:15,
2155:2, 2157:20, 2168:25, 2172:22,
2197:11, 2211:6, 2211:9, 2211:10,
2221:4, 2249:6, 2251:2
stock [2] - 2246:7, 2246:10
stockbroker [1] - 2253:21
stocks [4] - 2111:7, 2126:19, 2239:5,
2245:10
stole [1] - 2083:1
stop [13] - 1981:7, 1981:15, 1982:11,
1987:13, 1993:18, 1995:25, 2046:18,
2047:17, 2127:12, 2143:19, 2193:2,
2202:19
stopped [1] - 2038:24
stopping [2] - 2077:12, 2155:6
store [1] - 1999:21
story [4] - 2038:25, 2039:7, 2039:22,
2135:3
strange [1] - 2014:16
strategy [2] - 2165:19, 2165:22
Street [2] - 1971:22, 2103:1
streets [1] - 2187:11
strengthen [2] - 2007:19, 2011:8
strictly [3] - 2137:23, 2217:20,
2219:16
strip [2] - 2023:12, 2023:13
stripes [2] - 2039:10, 2039:16
strong [1] - 2214:8
structure [1] - 2219:10
structures [1] - 2217:12
studies [1] - 2250:15
stuff [1] - 2125:11
stumps [1] - 2082:12
stupid [2] - 2225:5, 2245:18
style [5] - 2132:10, 2180:10, 2181:9,
2183:3, 2194:1
subdivision [2] - 2135:11, 2197:23
subject [9] - 1980:12, 2018:20,
2028:21, 2056:6, 2083:25, 2163:14,
2239:22
submit [3] - 1978:9, 2053:16, 2103:7
submits [1] - 1979:22
submitted [5] - 2028:23, 2046:8,
2053:12, 2053:13, 2092:19
Subparagraph [1] - 2066:4
Subsection [6] - 2091:5, 2091:7,
2091:10, 2091:11, 2091:12, 2091:25
subsection [2] - 2050:9, 2089:5
subsections [2] - 2051:7, 2091:17
subsequent [1] - 2043:11
subsequently [1] - 2065:3
subsidiaries [1] - 2101:11
success [1] - 2019:15
successful [16] - 2015:14, 2121:9,
2121:21, 2122:10, 2171:23, 2171:24,
2171:25, 2185:12, 2191:3, 2191:5,
2203:17, 2224:15, 2246:5, 2250:19,
2250:25
sufficient [1] - 2031:24
suggested [1] - 2074:3
suing [2] - 1992:10, 2097:5
Suisse [1] - 1979:14
Sullivan [1] - 2039:14
sum [3] - 2063:23, 2151:21, 2244:10
Sun [2] - 2138:3, 2146:10
super [7] - 2165:6, 2165:14, 2166:1,
2236:14, 2237:5, 2237:10, 2237:17
supervise [1] - 2094:20
supervised [1] - 2094:16
supervisor [5] - 2049:9, 2049:10,
2049:12, 2094:3, 2095:13
support [5] - 2038:15, 2041:22,
2132:20, 2146:23, 2162:19
suppose [2] - 1986:24, 2089:1
supposed [3] - 2149:2, 2162:4,
2191:18
Supreme [2] - 2009:21, 2039:2
surprise [1] - 2035:20
surprised [1] - 2180:1
surrender [2] - 1998:18, 2067:23
surrendered [3] - 2068:3, 2087:12,
2098:7
surrounding [1] - 2164:17
suspect [1] - 2203:23
suspicion [1] - 2146:17
sustain [3] - 2070:25, 2076:25, 2106:5
sustained [13] - 2038:16, 2052:8,
2072:9, 2075:16, 2081:1, 2088:14,
2116:2, 2116:15, 2146:20, 2147:17,
2180:16, 2200:11, 2251:24
swearing [1] - 2096:17
swimming [1] - 2136:20
Swiss [3] - 2075:2, 2075:11, 2115:17
switch [5] - 2027:20, 2062:7, 2067:9,
2073:7, 2252:17
Switzerland [8] - 2115:16, 2118:7,
2118:16, 2230:22, 2231:22, 2231:24,
2232:1, 2232:3
sworn [2] - 2099:2, 2099:5
Sydney [2] - 2108:8, 2108:11
system [3] - 2037:21, 2040:22,
2221:15
T
table [2] - 2080:8, 2080:10
Takara [1] - 2121:3
TAKARA [1] - 2121:5
tape [3] - 2143:18, 2144:5, 2144:14
target [1] - 2120:2
targeting [1] - 2120:17
task [4] - 2012:3, 2013:24, 2041:1,
2042:13
tasks [3] - 2040:12, 2040:17, 2040:21
tax [5] - 2088:5, 2088:7, 2088:11,
2088:22, 2226:23
taxable [1] - 2223:11
taxes [2] - 2225:7, 2226:5
team [17] - 2010:6, 2010:25, 2012:6,
2012:7, 2014:3, 2014:5, 2019:9,
2019:10, 2019:15, 2020:12, 2043:17,
2213:21, 2213:24, 2216:18, 2217:16
teams [2] - 2213:23, 2214:5
technically [2] - 2203:7, 2203:10
technology [1] - 2220:9
television [1] - 2217:15
tempting [1] - 2088:1
ten [4] - 2020:18, 2036:19, 2135:5,
2241:7
ten-dollar [1] - 2241:7
tens [6] - 2212:2, 2215:12, 2216:13,
2219:20, 2219:22, 2219:23
tenure [1] - 2039:16
term [5] - 2088:9, 2120:15, 2140:21,
2158:5, 2254:7
terminology [5] - 2137:19, 2195:21,
2195:22, 2209:1, 2218:8
terms [9] - 1996:22, 2013:17, 2041:2,
2063:25, 2103:4, 2108:15, 2128:6,
2132:10, 2151:23
test [1] - 2031:13Johnny C. Sanchez, RMR, CRR - [email protected]
2289
testified [13] - 1988:14, 1992:24,
1994:14, 1998:11, 2042:23, 2064:23,
2068:21, 2069:9, 2099:5, 2184:4,
2184:8, 2184:11, 2228:4
testify [3] - 1984:23, 2177:16, 2228:21
testimony [9] - 2034:12, 2034:16,
2035:21, 2038:15, 2052:14, 2078:11,
2084:8, 2113:6, 2168:18
tests [1] - 2160:7
Tex [1] - 2216:3
TEXAS [1] - 1971:1
Texas [19] - 1971:4, 1971:15, 1971:23,
1972:4, 1972:7, 1972:11, 1972:19,
2055:4, 2055:5, 2101:25, 2102:2,
2105:2, 2120:10, 2171:19, 2178:7,
2186:7, 2190:10, 2190:23, 2201:16
THE [308] - 1971:10, 1971:13, 1971:20,
1972:2, 1975:2, 1976:20, 1976:24,
1977:2, 1977:5, 1977:8, 1977:9,
1977:11, 1977:12, 1980:4, 1980:9,
1983:1, 1983:3, 1983:6, 1983:10,
1983:24, 1984:2, 1985:20, 1985:22,
1985:25, 1986:2, 1986:4, 1987:8,
1987:11, 1989:7, 1989:9, 1989:12,
1989:17, 1989:20, 1989:23, 1991:15,
1991:19, 1991:21, 1991:22, 1991:23,
1991:24, 1991:25, 1992:1, 1996:24,
1997:1, 1997:2, 1997:22, 1999:6,
1999:9, 1999:12, 1999:15, 1999:20,
2017:11, 2017:16, 2017:19, 2020:14,
2022:14, 2022:17, 2022:19, 2022:23,
2027:21, 2034:20, 2035:4, 2035:9,
2035:25, 2036:3, 2036:9, 2036:13,
2036:16, 2036:23, 2037:1, 2037:5,
2037:9, 2037:15, 2037:18, 2037:22,
2037:24, 2038:3, 2038:16, 2038:22,
2038:24, 2044:14, 2044:19, 2044:21,
2045:6, 2045:15, 2045:20, 2046:11,
2049:20, 2051:17, 2051:21, 2052:1,
2052:8, 2054:11, 2056:5, 2059:21,
2061:13, 2061:17, 2061:19, 2061:20,
2061:22, 2061:23, 2062:8, 2062:10,
2063:6, 2066:1, 2067:6, 2070:4,
2070:9, 2070:12, 2070:15, 2070:24,
2071:9, 2071:11, 2071:14, 2071:15,
2072:9, 2073:9, 2075:6, 2075:7,
2075:13, 2075:16, 2076:4, 2076:9,
2076:19, 2076:24, 2077:7, 2077:10,
2077:14, 2078:4, 2078:9, 2078:20,
2079:2, 2079:11, 2079:15, 2079:23,
2080:7, 2080:10, 2080:22, 2080:25,
2081:11, 2081:12, 2081:23, 2082:4,
2082:5, 2082:6, 2082:7, 2082:9,
2082:15, 2082:16, 2082:21, 2082:22,
2082:23, 2082:25, 2083:1, 2083:5,
2083:15, 2083:16, 2083:24, 2084:6,
2084:16, 2085:5, 2085:6, 2086:1,
2088:14, 2089:16, 2090:3, 2090:6,
2090:9, 2090:12, 2090:13, 2090:17,
2090:22, 2091:1, 2092:11, 2096:6,
2096:11, 2096:13, 2097:9, 2097:22,
2097:25, 2098:13, 2098:15, 2098:21,
2098:22, 2098:25, 2100:23, 2100:25,
2102:16, 2102:17, 2103:25, 2104:1,
2104:3, 2105:19, 2106:1, 2106:5,
2110:4, 2110:13, 2110:24, 2110:25,
2112:11, 2112:19, 2113:2, 2113:20,
2113:21, 2114:16, 2114:19, 2115:5,
2116:2, 2116:7, 2116:15, 2117:24,
2119:22, 2121:5, 2123:20, 2124:5,
2124:6, 2124:15, 2124:18, 2124:22,
2125:13, 2127:18, 2127:20, 2127:22,
2127:24, 2127:25, 2128:1, 2128:12,
2128:15, 2134:24, 2138:13, 2138:15,
2143:1, 2143:3, 2143:7, 2143:11,
2143:13, 2143:16, 2144:4, 2145:11,
2145:14, 2146:20, 2147:17, 2147:19,
2147:22, 2148:3, 2148:6, 2150:6,
2150:8, 2150:13, 2150:20, 2151:6,
2152:13, 2152:23, 2153:15, 2153:17,
2153:20, 2153:22, 2153:25, 2155:8,
2155:13, 2155:15, 2161:11, 2161:13,
2161:14, 2166:24, 2167:1, 2173:23,
2175:22, 2175:25, 2180:16, 2181:4,
2184:10, 2184:14, 2184:16, 2197:7,
2197:8, 2200:11, 2203:5, 2207:7,
2207:9, 2207:16, 2227:3, 2227:16,
2227:19, 2227:21, 2227:24, 2228:1,
2228:13, 2228:18, 2229:25, 2231:10,
2231:15, 2231:16, 2231:17, 2240:1,
2240:5, 2240:8, 2240:11, 2240:24,
2245:24, 2251:24, 2252:19, 2252:21,
2254:5, 2254:25, 2256:23, 2256:25,
2257:1
the.. [1] - 2251:4
theme [1] - 2011:9
thereafter [1] - 2108:12
thereby [1] - 2062:25
therefore [3] - 1997:15, 1997:18,
2087:11
they've [3] - 2035:19, 2125:9, 2248:10
thinking [3] - 2019:2, 2071:21,
2165:14
third [10] - 2021:10, 2052:24, 2096:10,
2122:4, 2122:11, 2123:23, 2124:13,
2164:7, 2203:7, 2256:4
thousand [1] - 2170:3
thousands [1] - 2037:24
three [24] - 1991:12, 2034:23, 2047:15,
2071:24, 2071:25, 2082:12, 2085:20,
2087:9, 2087:18, 2100:12, 2107:21,
2108:8, 2122:19, 2123:6, 2135:6,
2171:15, 2171:16, 2171:18, 2179:3,
2179:9, 2190:7, 2192:17, 2202:5,
2251:25
three-quarters [1] - 2034:23
throughout [4] - 2064:14, 2064:22,
2159:21, 2234:10
ticket [2] - 2213:20, 2213:21
tie [1] - 1987:14
tighter [1] - 2004:18
timeframe [5] - 2013:3, 2081:9,
2231:9, 2231:10, 2231:12
timeline [1] - 2012:24
timelines [1] - 2012:19
timely [1] - 2035:18
tiny [1] - 2236:20
tired [1] - 2176:21
title [4] - 2030:21, 2100:9, 2123:8,
2199:24
titled [3] - 2050:23, 2050:24, 2050:25
today [9] - 1997:7, 1997:8, 2014:12,
2034:12, 2034:16, 2103:21, 2207:10,
2229:6, 2257:4
together [11] - 2003:22, 2008:10,
2019:20, 2059:14, 2063:24, 2151:22,
2187:21, 2188:10, 2188:11, 2189:22,
2191:11
Tom [2] - 1985:4, 2008:23
tomorrow [1] - 2257:5
took [12] - 2040:10, 2072:7, 2094:5,
2094:9, 2168:13, 2170:4, 2178:6,
2178:7, 2187:16, 2210:19, 2210:24,
2225:13
top [17] - 1982:7, 1990:3, 2056:15,
2058:3, 2058:9, 2058:11, 2061:24,
2063:9, 2117:12, 2148:24, 2151:4,
2152:1, 2154:21, 2159:12, 2207:19,
2208:7, 2225:16
topic [2] - 2115:22, 2116:9
total [4] - 2149:3, 2171:18, 2171:20,
2190:11
totally [1] - 2109:21
tough [1] - 2189:14
tour [1] - 2043:2
tourists [1] - 2164:1
tournament [1] - 2216:20
towards [8] - 2085:1, 2105:6, 2111:21,
2144:16, 2145:25, 2148:14, 2238:2,
2238:5
townhomes [1] - 2134:20
tracked [2] - 2140:8, 2140:12
traded [1] - 2125:22
traditionally [1] - 2244:13
train [1] - 2041:19
trained [2] - 1991:13, 1991:18
transaction [9] - 2125:7, 2125:8,
2158:7, 2240:18, 2241:6, 2241:7,
2241:8, 2256:5, 2256:13
transactions [9] - 1976:10, 2158:15,
2171:21, 2191:21, 2206:10, 2206:11,
2209:16, 2225:17, 2255:24
transcript [1] - 2257:11
Transcript [2] - 1972:13, 1972:20
transcription [2] - 1972:13, 1972:21
transfer [4] - 2223:11, 2224:17,
2226:3, 2226:9
transferred [1] - 2225:4
transferring [1] - 2225:15
Traurig [1] - 2009:7
travel [4] - 2018:14, 2064:18, 2166:12,
2167:1
traveled [2] - 2019:23, 2020:3
traveling [3] - 2176:22, 2189:8, 2190:6
treasurer [2] - 2199:9, 2199:12
treasury [9] - 2149:8, 2149:10,
2149:11, 2247:21, 2247:23, 2253:23,
2255:13, 2255:14, 2255:15
Johnny C. Sanchez, RMR, CRR - [email protected]
2290
treatment [1] - 2210:8
treaty [1] - 1976:5
Trevor [2] - 2043:16, 2043:19
trial [2] - 1992:23, 2153:24
TRIAL [1] - 1971:7
tried [4] - 1999:20, 1999:23, 2002:8,
2140:7
Trinidad [1] - 2018:17
trip [2] - 2064:20, 2064:21
tripling [1] - 2169:25
true [25] - 2001:12, 2003:25, 2004:9,
2005:18, 2007:8, 2009:25, 2011:10,
2016:8, 2017:1, 2018:19, 2019:14,
2025:8, 2025:9, 2028:10, 2032:20,
2040:20, 2050:5, 2054:23, 2057:16,
2095:21, 2095:22, 2196:17, 2233:22,
2234:4, 2253:23
Trust [1] - 2211:12
trusts [1] - 2007:2
truth [6] - 2035:3, 2093:7, 2106:2,
2110:9, 2150:9, 2203:8
truthful [1] - 2252:13
try [8] - 1984:1, 2000:1, 2030:4,
2045:4, 2059:17, 2096:19, 2168:2
trying [14] - 2011:14, 2029:18, 2042:2,
2049:11, 2049:19, 2060:2, 2076:6,
2112:24, 2120:2, 2123:11, 2124:9,
2134:8, 2206:3
turn [18] - 1980:18, 1990:19, 2047:18,
2049:6, 2067:3, 2073:18, 2077:5,
2077:15, 2080:5, 2081:14, 2081:17,
2086:2, 2095:8, 2095:12, 2095:13,
2111:17, 2148:23, 2159:3
turned [4] - 2012:10, 2057:21, 2216:8,
2250:18
TV [1] - 2079:17
twice [2] - 2127:11, 2177:3
two [50] - 1979:2, 1989:15, 1998:24,
1999:2, 2010:14, 2010:15, 2013:5,
2030:18, 2035:14, 2053:5, 2057:24,
2069:11, 2071:20, 2071:21, 2073:11,
2082:10, 2082:12, 2082:13, 2090:14,
2090:18, 2090:22, 2096:9, 2101:11,
2106:22, 2117:6, 2123:6, 2125:24,
2134:11, 2138:1, 2146:8, 2146:23,
2157:18, 2166:21, 2166:23, 2167:4,
2167:20, 2171:7, 2172:19, 2173:19,
2190:7, 2210:18, 2211:16, 2217:8,
2217:9, 2220:23, 2228:7, 2246:12,
2252:24, 2255:2
two-month [1] - 2167:20
tying [1] - 2070:22
type [13] - 1982:20, 2112:3, 2120:7,
2135:7, 2146:23, 2150:2, 2154:17,
2158:5, 2165:8, 2165:17, 2203:24,
2213:12, 2244:20
types [11] - 1975:19, 1975:20,
2006:20, 2125:11, 2137:21, 2141:7,
2162:14, 2209:13, 2217:8, 2217:9,
2236:22
typically [1] - 2159:18
U
U.S [14] - 1971:17, 1985:15, 1985:16,
1986:19, 1987:1, 1987:4, 2008:25,
2034:9, 2034:12, 2063:23, 2097:5,
2100:22
U.S.-style [1] - 2197:23
UK [1] - 2011:11
unable [1] - 2058:24
undependable [1] - 2164:24
under [29] - 1975:17, 1975:23, 1976:3,
1985:23, 2006:1, 2030:22, 2042:19,
2048:1, 2060:10, 2086:7, 2091:5,
2092:9, 2092:11, 2138:12, 2184:9,
2184:12, 2190:8, 2190:13, 2211:16,
2211:17, 2211:18, 2215:4, 2222:8,
2223:18, 2224:9, 2224:10, 2238:20,
2249:7
underlined [1] - 2208:14
underneath [1] - 2033:1
understandings [1] - 2124:3
understood [6] - 2071:18, 2106:3,
2110:9, 2112:12, 2168:24, 2235:7
undertook [1] - 2013:22
unfortunately [1] - 1982:9
uNITED [1] - 1971:1
United [13] - 1986:22, 2011:10,
2013:8, 2013:9, 2013:12, 2013:13,
2016:3, 2026:4, 2081:24, 2098:24,
2136:4, 2221:21, 2222:1
UNITED [2] - 1971:4, 1971:10
units [5] - 2134:22, 2171:15, 2171:16,
2186:18, 2186:20
University [2] - 2100:3, 2100:13
unless [5] - 2063:7, 2107:9, 2112:9,
2164:21, 2229:5
unpaid [2] - 2063:25, 2151:22
unquote [1] - 2194:12
unreasonable [1] - 2012:19
untoward [1] - 2205:5
unusual [2] - 2174:2, 2174:3
up [93] - 1983:12, 1983:13, 1985:17,
1987:20, 1992:16, 1996:4, 2003:17,
2003:19, 2007:18, 2015:15, 2018:18,
2021:2, 2028:8, 2030:7, 2031:19,
2032:3, 2033:17, 2035:5, 2035:12,
2039:9, 2040:14, 2040:22, 2042:9,
2043:24, 2045:4, 2049:20, 2053:3,
2057:6, 2058:2, 2059:18, 2060:1,
2061:15, 2062:6, 2062:22, 2077:10,
2083:17, 2083:19, 2083:25, 2088:21,
2089:22, 2094:13, 2097:2, 2097:16,
2102:5, 2102:13, 2103:25, 2105:3,
2105:6, 2111:24, 2112:9, 2115:23,
2116:9, 2116:18, 2120:19, 2120:22,
2121:14, 2121:20, 2122:15, 2122:18,
2122:23, 2126:14, 2126:15, 2126:24,
2136:5, 2141:20, 2144:13, 2152:14,
2154:10, 2156:1, 2157:14, 2167:19,
2168:7, 2169:25, 2175:23, 2176:1,
2187:13, 2188:11, 2188:22, 2190:14,
2190:19, 2211:6, 2214:13, 2216:21,
2217:1, 2224:14, 2228:18, 2230:1,
2231:2, 2247:11, 2253:11, 2255:7,
2256:15, 2257:3
up-to-date [1] - 2053:3
upset [2] - 2012:17, 2142:2
US [1] - 1971:14
V
V.C [1] - 2208:21
Valley [3] - 2135:11, 2197:19, 2242:21
value [6] - 2063:18, 2126:13, 2151:19,
2212:11, 2212:15
variances [2] - 2206:17, 2206:22
various [11] - 1978:13, 1978:15,
2011:25, 2012:13, 2041:23, 2041:25,
2185:22, 2243:14, 2245:7, 2253:10,
2255:6
venue [1] - 2129:25
verbatim [1] - 2065:20
verification [1] - 2017:9
verify [2] - 1989:4, 2058:25
version [1] - 1986:10
versus [3] - 2125:1, 2126:7, 2126:18
vice [2] - 2101:16, 2106:25
vice-president [1] - 2101:16
vice-presidents [1] - 2106:25
video [10] - 2093:21, 2142:10,
2142:13, 2142:18, 2143:11, 2143:12,
2144:25, 2145:25, 2234:24, 2243:5
view [11] - 1981:20, 1995:6, 1996:12,
2000:14, 2025:7, 2028:10, 2032:20,
2113:17, 2128:7, 2165:17, 2254:20
Vincent [1] - 2168:8
Vingerhoedt [1] - 2057:13
violation [2] - 1982:22, 2052:3
violations [1] - 2056:17
vision [4] - 2194:23, 2215:24, 2218:15,
2218:17
visionary [1] - 2193:6
visit [4] - 1984:24, 2064:18, 2116:4,
2182:18
visited [3] - 1994:16, 2018:7, 2182:4
visitors' [1] - 2138:17
vitae [1] - 2053:4
void [1] - 2003:2
VOISANGE [1] - 2134:25
Voisinage [1] - 2134:21
VOLUME [1] - 1971:8
volunteered [1] - 2183:14
VS [1] - 1971:5
W
wait [3] - 2035:25, 2051:17, 2125:18
waiting [1] - 2096:15
walk [1] - 2021:2
Wall [1] - 2103:1
Walter [1] - 1984:15
wants [3] - 1979:8, 2059:23, 2078:17
war [1] - 2004:12Johnny C. Sanchez, RMR, CRR - [email protected]
2291
warehouse [1] - 2208:20
Warren [1] - 1971:16
WARREN [85] - 1975:7, 1975:9,
1977:13, 1980:7, 1980:13, 1980:18,
1980:19, 1982:25, 1983:2, 1983:8,
1989:6, 1989:8, 1992:20, 2017:15,
2022:11, 2022:16, 2022:21, 2034:24,
2035:13, 2036:2, 2036:5, 2036:11,
2036:15, 2036:17, 2036:25, 2038:2,
2038:20, 2044:25, 2051:19, 2051:25,
2052:2, 2062:1, 2062:3, 2062:6,
2062:9, 2062:11, 2063:4, 2063:9,
2063:11, 2065:24, 2066:2, 2066:21,
2066:23, 2067:7, 2067:11, 2070:10,
2070:16, 2071:3, 2071:16, 2072:10,
2073:5, 2073:10, 2073:15, 2075:8,
2075:17, 2076:5, 2076:12, 2077:1,
2077:5, 2077:9, 2077:12, 2077:15,
2077:17, 2078:8, 2078:11, 2079:5,
2079:14, 2079:25, 2080:1, 2080:5,
2080:8, 2080:11, 2080:12, 2081:5,
2081:13, 2083:4, 2083:6, 2084:4,
2084:9, 2084:14, 2088:12, 2090:14,
2098:1, 2098:3, 2098:12
WARREN............ [2] - 1973:8, 1973:12
Washington [1] - 1971:18
waste [1] - 2210:8
watch [2] - 2059:23, 2098:18
watched [4] - 2179:23, 2214:10,
2214:11
water [3] - 2164:22, 2164:23, 2197:24
Waterhouse [3] - 2161:3, 2161:5,
2161:17
Watkins [1] - 2220:23
ways [4] - 1999:10, 2112:24, 2223:12,
2227:16
weakened [1] - 2071:22
weaknesses [1] - 2013:16
wealth [1] - 2146:17
wealthy [2] - 2165:9, 2220:2
wear [4] - 1999:17, 1999:24, 2000:2,
2039:20
wearing [4] - 1999:13, 2039:1,
2039:16, 2103:23
weather [1] - 2102:4
week [2] - 2026:1, 2035:19
week's [1] - 2035:19
welcome [2] - 2082:25, 2255:20
well-established [1] - 2053:5
well-publicized [1] - 2164:1
well-to-do [1] - 2195:15
Well-to-do [1] - 2195:17
West [10] - 2018:15, 2018:24, 2019:9,
2019:17, 2019:25, 2063:22, 2134:22,
2213:24, 2214:1
Westies [2] - 2019:20, 2019:23
whereby [1] - 2088:22
whipped [1] - 2020:8
whole [15] - 1983:14, 1987:15,
2019:19, 2030:17, 2030:19, 2065:12,
2121:24, 2139:19, 2159:22, 2162:7,
2162:8, 2213:25, 2216:14, 2217:6,
2217:13
Wicket [20] - 2081:18, 2081:20,
2081:21, 2081:23, 2082:4, 2083:12,
2084:10, 2084:11, 2084:25, 2085:12,
2085:13, 2137:1, 2139:13, 2211:13,
2213:6, 2213:8, 2214:22, 2215:13,
2243:3, 2249:14
wicket [10] - 2081:25, 2082:5, 2082:7,
2082:8, 2082:13, 2082:19, 2082:20,
2083:7, 2214:16
wickets [3] - 2082:3, 2082:10, 2082:14
wide [2] - 1979:18, 2007:3
wife [1] - 2166:20
wig [3] - 1999:13, 1999:21, 2000:2
wigs [2] - 1999:18, 2039:1
William [2] - 1971:16, 2039:7
willing [1] - 2120:3
Windies [1] - 2019:25
Winter [2] - 2046:7, 2047:3
winter [2] - 2053:2, 2053:14
winter's [1] - 2053:8
wish [1] - 2046:5
withdraw [1] - 2133:15
withdrawn [3] - 2245:23, 2245:24
WITNESS [48] - 1973:3, 1977:8,
1977:11, 1985:20, 1986:4, 1991:21,
1991:23, 1991:25, 1997:1, 2061:19,
2061:22, 2062:10, 2071:11, 2071:15,
2075:7, 2075:13, 2081:12, 2082:4,
2082:6, 2082:9, 2082:16, 2082:22,
2082:25, 2083:15, 2085:6, 2090:12,
2097:9, 2098:21, 2100:25, 2102:17,
2104:1, 2110:25, 2113:21, 2116:7,
2121:5, 2124:6, 2124:15, 2127:20,
2127:24, 2128:1, 2128:15, 2134:24,
2138:15, 2161:13, 2167:1, 2197:8,
2231:16, 2256:25
witness [25] - 1983:2, 1989:15,
1995:19, 2052:6, 2054:11, 2076:25,
2078:24, 2084:14, 2090:15, 2098:12,
2098:23, 2112:6, 2112:7, 2112:25,
2113:6, 2123:19, 2152:15, 2152:18,
2152:19, 2169:7, 2228:17, 2233:15,
2244:1, 2251:23, 2254:22
witness's [1] - 2079:3
witnesses [2] - 2037:23, 2098:17
wondered [1] - 2146:3
wonderful [1] - 2039:4
wood [1] - 2141:9
word [8] - 2001:23, 2010:11, 2134:24,
2180:1, 2200:19, 2200:20, 2214:5,
2248:9
word's [1] - 2205:4
worded [1] - 2238:19
words [4] - 1996:24, 2063:17, 2090:9,
2235:1
workers [1] - 2164:12
works [2] - 2009:1, 2227:16
world [27] - 1976:3, 1977:18, 2004:12,
2013:10, 2013:13, 2019:10, 2025:10,
2076:10, 2140:20, 2141:21, 2142:8,
2164:2, 2193:18, 2193:19, 2193:22,
2194:2, 2194:3, 2194:12, 2194:21,
2213:14, 2215:16, 2218:12, 2218:17,Johnny C. Sanchez, RMR, CRR - [email protected]
2292
2221:25, 2234:18, 2234:21, 2236:17
world-class [2] - 2215:16, 2218:17
worth [6] - 2195:21, 2195:22, 2195:23,
2196:10, 2225:20
wound [2] - 2175:23, 2176:1
write [3] - 1999:9, 1999:10, 2227:12
writing [3] - 2005:19, 2034:15,
2044:10
written [1] - 2057:7
wrote [7] - 1999:14, 2007:5, 2016:2,
2040:8, 2183:8, 2185:1
Y
y'all [1] - 2189:22
yachts [1] - 2218:4
year [27] - 2026:13, 2028:12, 2028:17,
2029:1, 2029:9, 2030:7, 2030:8,
2032:22, 2040:4, 2043:8, 2090:9,
2101:22, 2102:16, 2130:10, 2154:4,
2154:18, 2154:20, 2156:18, 2164:3,
2167:24, 2177:1, 2182:16, 2185:11,
2239:25, 2244:14, 2249:10
years [55] - 1977:8, 2019:10, 2020:9,
2020:18, 2039:3, 2039:13, 2074:11,
2084:20, 2100:10, 2100:12, 2101:15,
2108:17, 2109:18, 2115:3, 2123:6,
2129:17, 2129:18, 2134:8, 2135:5,
2136:7, 2139:19, 2142:19, 2144:1,
2145:21, 2148:17, 2157:18, 2161:22,
2168:1, 2168:19, 2169:16, 2170:1,
2176:8, 2176:16, 2180:4, 2187:5,
2188:19, 2190:7, 2191:21, 2202:23,
2204:20, 2204:22, 2216:11, 2219:7,
2221:7, 2229:2, 2229:5, 2234:5,
2234:8, 2237:9, 2251:8, 2253:11,
2255:7
yesterday [4] - 2042:23, 2064:23,
2068:21, 2069:9
York [3] - 1971:17, 2220:19, 2220:20
yourself [4] - 2041:8, 2043:3, 2096:4,
2099:11
Z
Zealand [1] - 2020:6
zoom [6] - 1985:19, 2027:22, 2028:18,
2029:21, 2030:2, 2030:18