Case Document 462-2 Filed 03/03/16 Page 1 of 129 EXHIBIT 1 Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 2 of 129 Transcription of Clip from Arkansas Rally 2/26/16 That’s right…Thank you. But just remember this – Politicians are never going to get you to the promise land. They’re never, ever going to get you to the promise land. And things were said in previous speeches – and probably by Cruz also – but I didn’t get to see Cruz, which is just false. So many things I’ve done so well. For instance, they talked Trump University. It’s a small deal – very small. But, I got sued by a lawyer who sues – they sue – because they want to see if they can get some money back. I could have settled this suit numerous times – I could settle it now. But I don’t like settling suits because when you settle lawsuits everybody sues you – it’s a little business story. I have friends, they settle lawsuits and they can’t understand why are they always sued. I don’t settle lawsuits. We have people at Trump University that wrote – most of them – that wrote statements – and they wrote the statement where “I loved the school, I love this.” For some reason, I never saw this before, we call them report cards. They did, like, report cards, essentially report cards, where at the end of the class – at the end of the period of time – they did a study – they did a report card on how you like it. Some even did film clips where they actually would film them saying great things. The person that started the suit wrote a great statement saying it was fantastic and did a film clip saying that it was fantastic and they just asked that she be taken out of the case. She doesn’t want to be in the case anymore. And the reason they want is because she’s a terrible plaintiff because she said all these great things about Trump University and she’s on film saying how great it is. So, they put in a motion, which the papers don’t write this, they put in a motion saying to take her – her name is “Tarloff” or something – take her out of the case. The reason they want her out of the case is she is a horrible, horrible, witness. She’s got in writing that she loves it. And I could have settled it and when I saw her documentation, I said why would I give her money, she loved the case and she’s on tape. Why would I give her money? Probably should have settled it, but I just can’t do that. Mentally I can’t do it. I’d rather spend a lot more money and fight it. We [crowd cheering]…No you got to – you go to. Hey, would have been much easier if I settled. Would have probably been cheaper, but I don’t care. It would have been much easier – it would have been cheaper – it would have been much easier – but just so you understand – so these people – all of this is people put up something and now they get letters, oh, can you get your money back, oh, we’ll get our money back, yeah, let’s join. The attorney-general of New York – this is all a civil case by the way – a simple civil case – the attorney-general of New York, meets with Barack Obama in Syracuse. The following day he sues me. What they don’t say is, I believe, $15,000 or a lot of money was paid to the attorney general by the law firm in California that’s suing me. See, I’m giving you sort of a life experience because it’s, isn’t this more interesting than talking about trade? A trade is easy for us. Trade is easy, but this is sort of like, this is almost like a story on success. Because this is the way the world works. This is sort of the way the world works. So, the attorney general gets a campaign contribution from the law firm that’s suing me. All of a sudden the attorney-general, his name is Eric Schneiderman – not respected in New York, doing a terrible job, probably is not electable in New York but who knows. And, he meets with Obama, gets the campaign contribution, I think – I think it’s $15,000, and all of a sudden he meets with Obama in I believe Syracuse, and the following day or two he brings a lawsuit against me. Now, much of that lawsuit has been won by me. He’s appealing it – it’s on appeal right now. But much of that case – it’s a long time already – but much of that case, we won. It’s won. I don’t mean we settled – we’ve won much of that case. They missed the statute of limitations and most of it is going away but nobody writes that – nobody wants to write that. The rest of it we’re doing very well. 1123311_1 Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 3 of 129 We have a very hostile judge because to be honest with you the judge should have thrown the case out on summary judgment but because it was me and because there’s a hostility towards me by the judge – tremendous hostility – beyond belief – I believe he happens to be Spanish, which is fine – he’s Hispanic, which is fine, and we haven’t asked for recusal, which we may do, but we have a judge who’s very hostile. It should have been thrown out, wasn’t thrown out, and I say I’d rather go to court. Because when you go to court and you have witnesses get up there and then they have to say but why did you sign a document saying that you loved the school, etc. etc., why shouldn’t you pay money for that. So, I just wanted to give you a little bit of the parameters because you keep hearing about Trump University, so, it’s a civil case, it’s a sleazebag law firm that does these class action cases – they’re very routine – and, I will win the case at the end. I just didn’t want to be forced to settle and I could have settled it before I did this and I knew somebody would try and to use it for publicity, but I believe I can turn it around just to show you how dishonest these people are. And that’s the case. [Crowd Cheers] And, just to finish, if I didn’t have a hostile judge in California this case would have ended years ago – would have ended a long time ago. Okay, are you ready? So, that took place with Rubio, Rubio is going nowhere. I think he’s going nowhere. Hasn’t won at all. They’re fighting. Now what they want to do is they want to take Trump on individually. They’re all fighting and I saw this morning “we should get out this…….[recording ends]. 1123311_1 Case Document 462-2 Filed 03/03/16 Page 4 of 129 EXHIBIT 2 Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 5 of 129 Confidential Donald Trump Art Cohen, et al. vs. Donald J. Trump ·1 · · · · · · UNITED STATES DISTRICT COURT ·2 · · · · · ·SOUTHERN DISTRICT OF CALIFORNIA ·3 ·4 · · ·5 · · ·6 · · ·7 · · ·8 · · ·9 · · 10 ART COHEN, Individually) ·and on Behalf of All· ·) Others Similarly· · · ·)No. 3:13-cv-02519-GPC-WVG ·Situated,· · · · · · · ) · · · · · · · · · · · ·)· CLASS ACTION ·· · · · · ·Plaintiff,· ) · · · · · · · · · · · ·) ·VS.· · · · · · · · · · ) · · · · · · · · · · · ·) ·DONALD J. TRUMP,· · · ·) · · · · · · · · · · · ·) ·· · · · · ·Defendant.· ) 11 · · · · ·** CONFIDENTIAL ** CONFIDENTIAL ** 12 · · · · · ORAL AND VIDEOTAPED DEPOSITION OF 13 · · · · · · · · · DONALD J. TRUMP 14 · · · · · · ·Thursday, December 10, 2015 15 · · · · · · 725 Fifth Avenue, 16th Floor 16 · · · · · · · · ·New York, New York 17 18 19 20 21 Reported By: 22 EILEEN MULVENNA, CSR/RMR/CRR 23 Job No. 10020374 24 25 Page 1 www.aptusCR.com Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 6 of 129 Confidential Donald Trump Art Cohen, et al. vs. Donald J. Trump ·1 · · · · · · UNITED STATES DISTRICT COURT ·2 · · · · · ·SOUTHERN DISTRICT OF CALIFORNIA ·3 ·4 · · ·5 · · ·6 · · ·7 · · ·8 · · ·9 · · 10 ART COHEN, Individually) ·and on Behalf of All· ·) Others Similarly· · · ·)No. 3:13-cv-02519-GPC-WVG ·Situated,· · · · · · · ) · · · · · · · · · · · ·)· CLASS ACTION ·· · · · · ·Plaintiff,· ) · · · · · · · · · · · ·) ·VS.· · · · · · · · · · ) · · · · · · · · · · · ·) ·DONALD J. TRUMP,· · · ·) · · · · · · · · · · · ·) ·· · · · · ·Defendant.· ) 11 12 13 · · VIDEOTAPED DEPOSITION of DONALD J. TRUMP, 14 Defendant in the above-captioned matter, taken 16 by Plaintiffs, held at the offices of the Trump 17 Organization, 725 Fifth Avenue, New York, New 18 York, beginning at 10:05 a.m. and ending 5:02 19 p.m., on December 10, 2015, before Eileen 20 Mulvenna, CSR/RMR/CRR, Certified Shorthand 21 Reporter, Registered Merit Reporter, Certified 22 Realtime Reporter and Notary Public of the State 23 of New York. 24 25 Page 2 www.aptusCR.com Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 7 of 129 Confidential Donald Trump ·1 Art Cohen, et al. vs. Donald J. Trump A P P E A R A N C E S: ·2 ·3 · · ·4 · · ·5 · · ·6 · · ·7 · · ·8 · · ·9 ·· · ·· · ·· · ·· · ·· · ·· · · · · · · · · · · · ·ROBBINS GELLER RUDMAN & DOWD, LLP ·Attorneys for Plaintiffs · · · ·655 West Broadway · · · ·Suite 1900 · · · ·San Diego, California· 92101 ·BY:· ·JASON FORGE, ESQ, · · · ·jforge@rgrdlaw.com · · · ·DANIEL PFEFFERBAUM, ESQ. · · · ·dpfefferbaum@rgrdlaw.com · · · ·RACHEL JENSEN, ESQ. · · · ·rjensen@rgrdlaw.com 11 · · · ·· 12 · · · ·· 13 · · · ·· 14 · · · · · · · · ·O'MELVENY & MYERS, LLP ·Attorneys for Defendant · · · ·Century City · · · ·1999 Avenue of the Stars, 7th Floor · · · ·Los Angeles, California 90067 ·BY:· ·DANIEL PETROCELLI, ESQ. · · · ·dpetrocelli@omm.com 10 15 16 17 A L S O· P R E S E N T: 18 19 · · · · ·Ryan Asanas, Videographer 20 21 22 23 24 25 Page 3 www.aptusCR.com Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 8 of 129 Confidential Donald Trump Art Cohen, et al. vs. Donald J. Trump ·1 opened. ·2 · · · Q.· · ·And that was sometime -- some number ·3 of years after it opened; correct? ·4 · · · A.· · ·I believe so, yes. ·5 · · · Q.· · ·Can you identify a single person who ·6 was a live events instructor for Trump ·7 University? ·8 · · · A.· · ·You'd have to give me a list.· You'd ·9 have to show me the list.· I actually went -- I 10 would go and just walk in and just stand in the 11 back of the room on occasion just to see how they 12 were doing, but it's been so many years, I 13 wouldn't be able to do that. 14 · · · Q.· · ·Let me just give you some names and 15 you tell me whether this could be a live events 16 instructor, a student, neither -- 17 · · · A.· · ·Okay. 18 · · · Q.· · ·-- any of those three. 19 · · · A.· · ·Fine. 20 · · · · · · ·MR. PETROCELLI:· What's the 21 · · · question, Jason? 22 BY MR. FORGE: 23 · · · Q.· · ·The question is, this individual I'm 24 saying here, can you tell me whether this person 25 is a student, live events instructor or neither? Page 100 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 9 of 129 Confidential Donald Trump Art Cohen, et al. vs. Donald J. Trump ·1 · · · · · · ·Johnny Harris. ·2 · · · A.· · ·Too many years. ·3 · · · Q.· · ·Tim Gorsline. ·4 · · · A.· · ·Too many years. ·5 · · · Q.· · ·Mike Dubin. ·6 · · · A.· · ·It sounds very familiar.· Names -- ·7 the names sound familiar, just too many years. ·8 · · · Q.· · ·Darren Liebmann. ·9 · · · A.· · ·The name sounds familiar, but it's 10 too many years. 11 · · · Q.· · ·Johnny Burkins. 12 · · · A.· · ·I don't know. 13 · · · Q.· · ·Johnny Horton. 14 · · · A.· · ·Too many years. 15 · · · Q.· · ·Tim Voss. 16 · · · A.· · ·Again, you can go through this whole 17 list.· And I'm sure you'd like to so you can take 18 this for a long time, but these are -- some of 19 those names sound familiar to me, but it's too 20 many years ago. 21 · · · Q.· · ·Chris Goff? 22 · · · A.· · ·Are you going to go through a whole 23 list of names? 24 · · · Q.· · ·You're the one that said give me a 25 list. Page 101 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 10 of 129 Confidential Donald Trump Art Cohen, et al. vs. Donald J. Trump ·1 · · · · · · ·MR. PETROCELLI:· Do you want to show ·2 · · · it to him? ·3 · · · · · · ·THE WITNESS:· You're right. ·4 · · · · · · ·MR. PETROCELLI:· Do you want to show ·5 · · · it to him? ·6 · · · · · · ·MR. FORGE:· I'm going through the ·7 · · · names. ·8 · · · · · · ·THE WITNESS:· If you want to show it ·9 · · · to me, I can save you a lot of time. 10 BY MR. FORGE: 11 · · · Q.· · ·I'll go through the list. 12 · · · · · · ·We left off with Chris Goff. 13 Instructor, student -- 14 · · · A.· · ·Again, some of those -- 15 · · · Q.· · ·-- neither? 16 · · · A.· · ·Some of these names sound familiar 17 to me.· It's too many years ago. 18 · · · Q.· · ·Sound familiar as in might have been 19 an instructor, might have been a student -- 20 · · · A.· · ·Could have been.· Could have been. 21 · · · Q.· · ·Could have been neither? 22 · · · A.· · ·No, it would have been more likely 23 instructors.· I would have known the instructors 24 much more so than the students.· We have -- we'll 25 have a lot of students testifying, but we have -Page 102 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 11 of 129 Confidential Donald Trump Art Cohen, et al. vs. Donald J. Trump ·1 but as far as that list is concerned, I would ·2 have -- the name's familiar, it's just too -- ·3 · · · · · · ·MR. PETROCELLI:· When you say "that ·4 · · · list," we don't have any document to -- ·5 · · · · · · ·THE WITNESS:· I don't know what ·6 · · · you're reading from. ·7 · · · · · · ·MR. PETROCELLI:· The lawyer is just ·8 · · · reading from a piece of paper -- ·9 · · · · · · ·MR. FORGE:· I'm just -- 10 · · · · · · ·THE WITNESS:· Shouldn't you have a 11 · · · document before -- 12 · · · · · · ·MR. PETROCELLI:· -- that's not -- 13 · · · · · · ·Excuse me. 14 · · · · · · ·-- that has not been put in front of 15 · · · you.· The record will reflect that and the 16 · · · testimony will be evaluated in light of his 17 · · · refusal to let you see a list or represent 18 · · · what the list means.· So just answer his 19 · · · questions and we'll take it from there. 20 · · · · · · ·Next question, please. 21 BY MR. FORGE: 22 · · · Q.· · ·Ken Berry. 23 · · · A.· · ·Too many years. 24 · · · Q.· · ·James Webb. 25 · · · A.· · ·I don't remember the names -- don't Page 103 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 12 of 129 Confidential Donald Trump Art Cohen, et al. vs. Donald J. Trump ·1 remember the name. ·2 · · · Q.· · ·James Casper. ·3 · · · A.· · ·Too many years.· Too many years. ·4 · · · Q.· · ·Mike Casper. ·5 · · · A.· · ·Too many years. ·6 · · · Q.· · ·Kerry Martin. ·7 · · · A.· · ·Some of the names, by the way, sound ·8 familiar, but too many years to know. ·9 · · · Q.· · ·Paul Lucas. 10 · · · A.· · ·Same thing. 11 · · · Q.· · ·Kerry Lucas. 12 · · · A.· · ·Same answer. 13 · · · Q.· · ·Mike Peterson. 14 · · · A.· · ·Same answer. 15 · · · Q.· · ·Troy Peterson. 16 · · · A.· · ·Same answer. 17 · · · Q.· · ·Chris Gillem. 18 · · · A.· · ·Same answer. 19 · · · Q.· · ·Steve Gilpin. 20 · · · A.· · ·Same answer. 21 · · · Q.· · ·Scott Miller. 22 · · · A.· · ·Same answer. 23 · · · Q.· · ·Steve Miller. 24 · · · A.· · ·Are you going to do this all day? 25 · · · Q.· · ·Same answer? Page 104 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 13 of 129 Confidential Donald Trump Art Cohen, et al. vs. Donald J. Trump ·1 · · · A.· · ·Same answer. ·2 · · · Q.· · ·Derek McNulty. ·3 · · · A.· · ·Same answer. ·4 · · · Q.· · ·Rick McNally. ·5 · · · A.· · ·How many more do you have?· How many ·6 more names do you have? ·7 · · · Q.· · ·Mr. Trump, you're the one who wants ·8 to get through this quickly.· Just answer the ·9 questions and we'll get through it quickly. 10 · · · A.· · ·You're not going to get anything 11 through quickly.· You don't want to get anything 12 through quickly. 13 · · · · · · ·Same answer. 14 · · · Q.· · ·Jerry Stanton. 15 · · · A.· · ·Same answer. 16 · · · Q.· · ·Johnny Burkins. 17 · · · A.· · ·Same answer. 18 · · · Q.· · ·Gerald Martin. 19 · · · A.· · ·Same answer. 20 · · · Q.· · ·Chris Lefrance. 21 · · · A.· · ·Same answer. 22 · · · Q.· · ·Steve Goff. 23 · · · A.· · ·Same answer. 24 · · · Q.· · ·James Webb. 25 · · · A.· · ·Same answer to your harassment Page 105 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 14 of 129 Confidential Donald Trump Art Cohen, et al. vs. Donald J. Trump ·1 questions. ·2 · · · Q.· · ·Chris Lombardo. ·3 · · · A.· · ·Same answer to your harassment ·4 questions. ·5 · · · Q.· · ·Keith Holley. ·6 · · · A.· · ·Same answer. ·7 · · · Q.· · ·Keith Sperry. ·8 · · · A.· · ·Same answer. ·9 · · · Q.· · ·Howard Bell. 10 · · · A.· · ·Same answer. 11 · · · Q.· · ·Howard Haller. 12 · · · A.· · ·Same answer. 13 · · · Q.· · ·Bob Serafine. 14 · · · A.· · ·Same answer. 15 · · · Q.· · ·Bob Steenson. 16 · · · A.· · ·Same answer. 17 · · · Q.· · ·Jerry Moore. 18 · · · A.· · ·Same answer. 19 · · · Q.· · ·Joe Labore. 20 · · · A.· · ·Same answer. 21 · · · Q.· · ·Mike -- 22 · · · A.· · ·Same answer. 23 · · · Q.· · ·Mike McMenamy. 24 · · · A.· · ·Same answer. 25 · · · Q.· · ·Rick McNally. Page 106 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 15 of 129 Confidential Donald Trump Art Cohen, et al. vs. Donald J. Trump ·1 · · · A.· · ·Same answer. ·2 · · · Q.· · ·Mike Casper. ·3 · · · A.· · ·Same answer. ·4 · · · Q.· · ·Tim Gorsline. ·5 · · · A.· · ·Same answer. ·6 · · · Q.· · ·Geoff Nowlin. ·7 · · · A.· · ·Same answer. ·8 · · · Q.· · ·Steve Gilpin. ·9 · · · A.· · ·Same answer. 10 · · · Q.· · ·James Christ. 11 · · · A.· · ·Same answer. 12 · · · Q.· · ·Alex Grist. 13 · · · A.· · ·Same answer. 14 · · · Q.· · ·Mike Weber. 15 · · · A.· · ·Same answer. 16 · · · Q.· · ·Don Sexton. 17 · · · A.· · ·Same answer -- well, I know the 18 name, but same answer.· Still a long time. 19 · · · · · · ·MR. PETROCELLI:· Don Sexton -- could 20 · · · you repeat the question just so he has it 21 · · · in mind. 22 · · · · · · ·THE WITNESS:· I heard the question. 23 BY MR. FORGE: 24 · · · Q.· · ·Don Sexton, do you know if he was a 25 live events instructor, a student or neither? Page 107 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 16 of 129 Confidential Donald Trump Art Cohen, et al. vs. Donald J. Trump ·1 · · · A.· · ·I remember the name, but it's many ·2 years ago.· I'd have to check the facts. ·3 · · · Q.· · ·Gary Stanton. ·4 · · · A.· · ·Same answer. ·5 · · · Q.· · ·Gary Sturgeon, S-T-U-R-G-E-O-N. ·6 · · · A.· · ·Same answer. ·7 · · · · · · ·MR. FORGE:· Tab 9.· Let's mark this ·8 · · · as Exhibit 475. ·9 · · · · · · ·(Plaintiffs' Exhibit 475, No Bates 10 · · · numbers, Sheet of Photographs, marked for 11 · · · identification.) 12 BY MR. FORGE: 13 · · · Q.· · ·Mr. Trump, let's get away from the 14 names and see if you recognize any faces.· I've 15 placed in front of you a photo lineup marked as 16 Exhibit 475 with three rows of eight photos per 17 row, so that's a total of 24 photos. 18 · · · · · · ·Do you recognize any of the people 19 depicted on this exhibit? 20 · · · A.· · ·What year was this picture taken? 21 · · · Q.· · ·Different years. 22 · · · A.· · ·I think I should be entitled to know 23 what year it was taken.· When were they taken? 24 How many years ago? 25 · · · Q.· · ·Different years. Page 108 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 17 of 129 Confidential Donald Trump Art Cohen, et al. vs. Donald J. Trump ·1 · · · A.· · ·Well, I think you should find out. ·2 I mean -- ·3 · · · Q.· · ·Do you recognize any of the -- ·4 · · · · · · ·THE WITNESS:· Are you allowed to ·5 · · · find out -- ·6 · · · Q.· · ·-- people whose pictures -- ·7 · · · · · · ·THE WITNESS:· Are you allowed to ·8 · · · find out when they were taken? ·9 · · · · · · ·MR. PETROCELLI:· You know, you just 10 · · · have to answer the questions and get 11 · · · through this. 12 · · · · · · ·THE WITNESS:· Okay. 13 · · · · · · ·MR. PETROCELLI:· These questions are 14 · · · what they are.· If you're not able to 15 · · · recognize someone because he won't tell you 16 · · · when the pictures are taken, that's on him. 17 · · · Okay. 18 BY MR. FORGE: 19 · · · Q.· · ·Do you recognize anyone whose photo 20 is on here? 21 · · · A.· · ·No.· No, I don't. 22 · · · Q.· · ·Do you know whether any of these 23 individuals are students? 24 · · · A.· · ·No, I don't. 25 · · · Q.· · ·Do you know whether any of these Page 109 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 18 of 129 Confidential Donald Trump Art Cohen, et al. vs. Donald J. Trump ·1 individuals are live events instructors? ·2 · · · A.· · ·I can't -- I can't tell from these ·3 small pictures now.· And they were taken ·4 obviously many, many years ago. ·5 · · · Q.· · ·Why is that obvious? ·6 · · · A.· · ·Because you can't give me the ·7 answer. ·8 · · · Q.· · ·Why does that make it obvious it was ·9 taken many, many years ago? 10 · · · A.· · ·Because if they were taken recently, 11 you'd probably remember. 12 · · · Q.· · ·When did I say I didn't remember? 13 · · · A.· · ·I don't know.· You wouldn't give me 14 the answer. 15 · · · Q.· · ·So why is it obvious they were 16 taken -- 17 · · · A.· · ·I would like to know when the 18 pictures were taken. 19 · · · Q.· · ·So why is it obvious they were taken 20 many years ago? 21 · · · A.· · ·Because if they were taken recently, 22 you would remember, I would imagine. 23 · · · Q.· · ·When did I say I couldn't remember? 24 · · · A.· · ·Well, then tell me who they are, 25 tell me when they were taken. Page 110 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 19 of 129 Confidential Donald Trump Art Cohen, et al. vs. Donald J. Trump ·1 · · · Q.· · ·Did I ever say that -- ·2 · · · A.· · ·Tell me when they were taken. ·3 · · · Q.· · ·Did I say I can't remember? ·4 · · · A.· · ·Tell me when they were taken.· How ·5 many years ago were they taken? ·6 · · · Q.· · ·I told you they were different ·7 years, Mr. Trump. ·8 · · · A.· · ·Are you sure about that? ·9 · · · Q.· · ·And you don't recognize -- 10 · · · A.· · ·Are you sure about that? 11 · · · Q.· · ·You don't recognize any of them; 12 right? 13 · · · A.· · ·Are you sure that they're different 14 years? 15 · · · Q.· · ·Yes. 16 · · · A.· · ·You're sure about that? 17 · · · Q.· · ·Sure. 18 · · · A.· · ·Okay.· Okay.· We'll find out. 19 · · · Q.· · ·Do you recognize any of them? 20 · · · A.· · ·I don't, no. 21 · · · · · · ·(Discussion off the record.) 22 · · · · · · ·MR. FORGE:· Eileen, if you could 23 · · · mark this 476. 24 · · · · · · ·(Plaintiffs' Exhibit 476, No Bates 25 · · · number, Color Photograph, marked for Page 111 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 20 of 129 Confidential Donald Trump Art Cohen, et al. vs. Donald J. Trump ·1 know? ·2 · · · A.· · ·No. ·3 · · · Q.· · ·We've tried names.· We've tried ·4 pictures.· Let's try voices now. ·5 · · · · · · ·MR. PETROCELLI:· You don't need the ·6 · · · editorial comments about we tried. ·7 · · · object.· It's inappropriate.· Just ask ·8 · · · questions, please. ·9 · · · · · · ·MR. FORGE:· Oh, so no editorial? 10 · · · That's what you're saying? 11 · · · · · · ·MR. PETROCELLI:· By you, correct. 12 · · · · · · ·MR. FORGE:· Only you. 13 · · · · · · ·MR. PETROCELLI:· That's not your 14 · · · role. 15 · · · · · · ·MR. FORGE:· Could we get 201, 202 16 · · · and 203, please. 17 · · · · · · ·The next document we're going to 18 · · · use -- next exhibit, I'm sorry, we're going 19 · · · to use is Exhibit 477. 20 · · · · · · ·Dan, we have a number of audio/video 21 · · · exhibits.· My intention is to give you a 22 · · · disc of each one individually because I 23 · · · don't know how many we're going to go 24 · · · through.· And then the court reporter will 25 · · · get all of them on a flash drive just so I Page 117 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 21 of 129 Confidential Donald Trump Art Cohen, et al. vs. Donald J. Trump ·1 · · · it's easier for her to maintain them. ·2 · · · So -- ·3 · · · · · · ·MR. PETROCELLI:· What are you ·4 · · · marking this as? ·5 · · · · · · ·MR. FORGE:· This is going to be ·6 · · · Exhibit 477. ·7 · · · · · · ·(Plaintiffs' Exhibit 477, No Bates ·8 · · · numbers, Video Clip, marked for ·9 · · · identification.) 10 · · · · · · ·(Plaintiffs' Exhibit 478, No Bates 11 · · · numbers, Video Clip, marked for 12 · · · identification.) 13 BY MR. FORGE: 14 · · · Q.· · ·Mr. Trump, I'm going to play for you 15 this video.· And just tell me -- it's short. 16 Tell me whether you recognize this individual. 17 · · · · · · ·MR. PETROCELLI:· Can you turn it to 18 · · · face us. 19 · · · · · · ·MR. FORGE:· Sure. 20 · · · · · · ·(Video is played.) 21 · · · · · · ·MR. FORGE:· Just for the record, 22 · · · that's going to be Exhibit 478.· Dan, what 23 · · · I handed you is 477.· This is 478. 24 · · · · · · ·MR. PETROCELLI:· Is what you just 25 · · · played, which says, "Jay Morrison - How to Page 118 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 22 of 129 Confidential Donald Trump Art Cohen, et al. vs. Donald J. Trump ·1 · · · Get Rich in Real Estate," Exhibit 478? ·2 · · · · · · ·MR. FORGE:· Yes. ·3 BY MR. FORGE: ·4 · · · Q.· · ·Mr. Trump, can you tell me whether ·5 or not that individual was a student at Trump ·6 University, a live events instructor or neither? ·7 · · · A.· · ·Well, it looked like -- I don't know ·8 him, but I don't disagree with what he was ·9 saying, either, by the way.· But he would look 10 like he was an instructor more than a student, 11 but I don't know him.· But I don't disagree with 12 what he was saying, and I thought his 13 presentation was quite interesting, actually. 14 · · · Q.· · ·But you don't know whether he was an 15 actual instructor at Trump University? 16 · · · A.· · ·I don't know, but I might have -- if 17 you showed me his résumé, perhaps I could tell 18 you. 19 · · · · · · ·MR. PETROCELLI:· Mr. -- 20 · · · · · · ·MR. FORGE:· Now I'm going to play 21 · · · 477. 22 · · · · · · ·MR. PETROCELLI:· Time out. 23 · · · · · · ·MR. FORGE:· Sure. 24 · · · · · · ·MR. PETROCELLI:· Miss Reporter, are 25 · · · you transcribing the words?· You're just Page 119 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 23 of 129 Confidential Donald Trump Art Cohen, et al. vs. Donald J. Trump ·1 · · · waiting for the flash drive; right?· Okay. ·2 · · · Thank you. ·3 · · · · · · ·He's not making any -- don't make ·4 · · · any assumptions about what you're seeing. ·5 · · · · · · ·THE WITNESS:· No, I'm just looking. ·6 · · · · · · ·MR. PETROCELLI:· There's been no ·7 · · · representation -- ·8 · · · · · · ·THE WITNESS:· I found it very ·9 · · · interesting, actually, to be honest with 10 · · · you. 11 · · · · · · ·MR. PETROCELLI:· Now you're going to 12 · · · play 478? 13 · · · · · · ·MR. FORGE:· 477.· I played them out 14 · · · of order.· The first one was 478.· This one 15 · · · is 477. 16 · · · · · · ·MR. PETROCELLI:· Okay. 17 · · · · · · ·(Video is played.) 18 BY MR. FORGE: 19 · · · Q.· · ·Do you recognize that individual as 20 a Trump University live events instructor, 21 student or in any other way? 22 · · · A.· · ·I'd have to see the résumé. 23 · · · Q.· · ·You don't know whether or not he was 24 a Trump University instructor? 25 · · · A.· · ·No. Page 120 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 24 of 129 Confidential Donald Trump Art Cohen, et al. vs. Donald J. Trump ·1 instructor? ·2 · · · A.· · ·Based on his experience as opposed ·3 to -- ·4 · · · Q.· · ·You mean if his résumé said, I was ·5 an instructor with Trump University, that would ·6 help you put it together? ·7 · · · A.· · ·If his résumé said he's been in the ·8 real estate for many years, it's unlikely he'd be ·9 a student, which is what you're asking me. 10 · · · Q.· · ·But make sure you understand. 11 · · · · · · ·With these videos, it's not 12 necessarily an either/or.· I said it's -- I'm 13 asking you whether the person was a live events 14 instructor, a student or neither one. 15 · · · · · · ·MR. PETROCELLI:· In other words, 16 · · · they could be a guy off the street or an 17 · · · actor. 18 · · · · · · ·MR. FORGE:· Yeah. 19 BY MR. FORGE: 20 · · · Q.· · ·Yeah, exactly. 21 · · · A.· · ·I don't know. 22 · · · Q.· · ·Okay. 23 · · · · · · ·MR. PETROCELLI:· Or -- or a 24 · · · convicted felon. 25 · · · · · · ·MR. FORGE:· Yes, could be that too. Page 122 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 25 of 129 Confidential Donald Trump Art Cohen, et al. vs. Donald J. Trump ·1 you. ·2 · · · Q.· · ·Okay. ·3 · · · · · · ·MR. PETROCELLI:· I think you're ·4 · · · being pitched another television show. ·5 · · · · · · ·THE WITNESS:· Yeah. ·6 · · · · · · ·MR. FORGE:· This is 479. ·7 · · · · · · ·(Plaintiffs' Exhibit 479, No Bates ·8 · · · numbers, Video Clip, marked for ·9 · · · identification.) 10 · · · · · · ·(Video is played.) 11 BY MR. FORGE: 12 · · · Q.· · ·Mr. Trump, do you recognize the 13 individual depicted in Exhibit 479 as a Trump 14 University instructor, student or neither? 15 · · · A.· · ·I don't recognize him. 16 · · · Q.· · ·One of the names I mentioned to you 17 earlier was James Harris.· You said you didn't 18 recognize that name? 19 · · · · · · ·MR. PETROCELLI:· To be clear, when 20 · · · did you mention his name? 21 · · · · · · ·MR. FORGE:· In the list, one of the 22 · · · names I mentioned in the list, James 23 · · · Harris. 24 · · · · · · ·THE WITNESS:· No, I didn't recognize 25 · · · it. Page 124 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 26 of 129 Confidential Donald Trump Art Cohen, et al. vs. Donald J. Trump ·1 BY MR. FORGE: ·2 · · · Q.· · ·Do you know or have you known anyone ·3 named James Harris? ·4 · · · A.· · ·I don't know, but I don't recognize ·5 that name. ·6 · · · Q.· · ·Do you know whether or not any Trump ·7 University instructors were caught cussing out ·8 and verbally berating a group of elderly ·9 students? 10 · · · A.· · ·No, I don't. 11 · · · · · · ·MR. FORGE:· Let's do 20 and 21. 12 · · · · · · ·(Pause from the record.) 13 · · · · · · ·MR. FORGE:· Mark this as 480. 14 · · · · · · ·(Plaintiffs' Exhibit 480, Bates Nos. 15 · · · TU154580 through 86, E-mail Chain, marked 16 · · · for identification.) 17 BY MR. FORGE: 18 · · · Q.· · ·Mr. Trump, I've placed in front of 19 you a document marked as Exhibit 480, which is a 20 document that you have produced in discovery in 21 this case.· The Bates number for the first page 22 is TU154580. 23 · · · · · · ·MR. PETROCELLI:· When you said 24 · · · "you," do you mean Trump University 25 · · · produced it? Page 125 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 27 of 129 Confidential Donald Trump Art Cohen, et al. vs. Donald J. Trump ·1 · · · A.· · ·No, I don't. ·2 · · · Q.· · ·The ultimate hiring authority at ·3 Trump University was Mr. Sexton; correct? ·4 · · · A.· · ·Yes, that's correct. ·5 · · · · · · ·MR. FORGE:· Tab 11, please.· This ·6 · · · will be 481. ·7 · · · · · · ·(Plaintiffs' Exhibit 481, No Bates ·8 · · · numbers, Transcript Excerpt, marked for ·9 · · · identification.) 10 BY MR. FORGE: 11 · · · Q.· · ·Mr. Trump, I've -- 12 · · · · · · ·MR. PETROCELLI:· Can you identify 13 · · · this. 14 BY MR. FORGE: 15 · · · Q.· · ·-- placed in front of you a document 16 marked as Exhibit 481, which is an excerpt from 17 Mr. Sexton's sworn testimony to the Office of the 18 New York State Attorney General. 19 · · · · · · ·If you could, please, direct your 20 attention to the second page, which is page 157. 21 · · · · · · ·At line 10, Mr. Sexton is asked: 22 · · · · · · ·"QUESTION:· And were any of those -- 23 · · · any of these other speakers at any of those 24 · · · events handpicked by Donald Trump?" 25 · · · · · · ·Mr. Sexton's answer: Page 135 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 28 of 129 Confidential Donald Trump Art Cohen, et al. vs. Donald J. Trump ·1 · · · · · · ·"ANSWER:· None of our instructors at ·2 · · · the live events were handpicked by Donald ·3 · · · Trump." ·4 · · · · · · ·Do you have any basis to dispute ·5 Mr. Sexton's testimony in this regard? ·6 · · · A.· · ·No.· That's correct. ·7 · · · · · · ·MR. PETROCELLI:· The question is ·8 · · · vague. ·9 · · · · · · ·MR. FORGE:· You can take out -- 10 · · · · · · ·THE WITNESS:· I looked at résumés 11 · · · and things, but I didn't pick the speakers. 12 · · · · · · ·MR. FORGE:· -- 12. 13 BY MR. FORGE: 14 · · · Q.· · ·Again, Mr. Trump, I want to make 15 sure that you are distinguishing -- you're 16 understanding the distinction between the Trump 17 University instructors when it was a distance 18 learning -- 19 · · · A.· · ·Yeah. 20 · · · Q.· · ·-- versus live events. 21 · · · A.· · ·Okay. 22 · · · · · · ·THE WITNESS:· Just off the record, 23 · · · I'm sure we're going to take some breaks 24 · · · also in addition to lunches because I have 25 · · · to make calls also, so -Page 136 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 29 of 129 Confidential Donald Trump Art Cohen, et al. vs. Donald J. Trump ·1 BY MR. FORGE: ·2 · · · Q.· · ·Well, I've just got to -- ·3 · · · A.· · ·This is the longest deposition I've ·4 ever done in terms of no break.· So I need breaks ·5 because I have to make some calls. ·6 · · · Q.· · ·No problem.· We haven't taken a ·7 break because you want to get through this. ·8 · · · A.· · ·We do, but breaks are very standard, ·9 so -- 10 · · · Q.· · ·We'll do one more. 11 · · · · · · ·MR. FORGE:· This we're going to mark 12 · · · as Exhibit 482. 13 · · · · · · ·(Plaintiffs' Exhibit 482, No Bates 14 · · · numbers, Transcript Excerpt, marked for 15 · · · identification.) 16 · · · · · · ·MR. FORGE:· Just for the record, 17 · · · Exhibit 482 is an excerpt from deposition 18 · · · testimony of Michael Sexton. 19 BY MR. FORGE: 20 · · · Q.· · ·And if you could, please -- in this 21 case, if you could, please, turn to page -- what 22 is page 161 of the deposition. 23 · · · A.· · ·Paragraph line? 24 · · · Q.· · ·I'll -- again keeping in mind the 25 distinction between the remote learning Page 137 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 30 of 129 Confidential Donald Trump Art Cohen, et al. vs. Donald J. Trump ·1 instructors and live events instructors -- ·2 · · · A.· · ·Okay. ·3 · · · Q.· · ·-- if you see, beginning at line 14: ·4 · · · · · · ·"QUESTION:· Mr. Sexton, you ·5 · · · mentioned Donald Trump did not review any ·6 · · · of the auditions of the instructors; ·7 · · · correct? ·8 · · · · · · ·"ANSWER:· That's correct." ·9 · · · · · · ·Do you have any basis to dispute 10 that testimony? 11 · · · · · · ·MR. PETROCELLI:· With respect to the 12 · · · live events? 13 · · · · · · ·MR. FORGE:· Yes, this is live events 14 · · · instructors. 15 · · · · · · ·THE WITNESS:· No, I didn't.· And 16 · · · that's correct.· What he said is correct. 17 BY MR. FORGE: 18 · · · Q.· · ·Again, these are all focusing on 19 live events instructors, Mr. Trump. 20 · · · A.· · ·Okay. 21 · · · Q.· · ·Next: 22 · · · · · · ·"QUESTION:· To your knowledge, he 23 · · · didn't review any of their school 24 · · · transcripts; correct? 25 · · · · · · ·"ANSWER:· That's correct." Page 138 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 31 of 129 Confidential Donald Trump Art Cohen, et al. vs. Donald J. Trump ·1 · · · · · · ·Any basis to dispute that? ·2 · · · A.· · ·I would say that's correct. ·3 Generally speaking, I might have seen something, ·4 but mostly correct, yes. ·5 · · · Q.· · ·Are there any live events ·6 instructors whose school transcripts you believe ·7 you saw?· Live events instructors. ·8 · · · A.· · ·Well, transcripts -- I don't know. ·9 Are you talking about résumés or transcripts? 10 · · · Q.· · ·We'll get to résumés, but I'm saying 11 live -- anyone who was actually hired as a live 12 events instructor. 13 · · · A.· · ·Yeah.· What do you mean by 14 "transcripts"? 15 · · · Q.· · ·School transcripts.· You know, the 16 grades -- transcript from your school that tells 17 the classes that you took, the semester and the 18 grade. 19 · · · A.· · ·Oh, I think I've seen them, but not 20 in particular, no.· Not in particular. 21 · · · Q.· · ·What he says here is Mr. Trump 22 didn't review any of their school transcripts. 23 · · · A.· · ·Yeah, "review" is a different word. 24 But I think -- you know, I would see.· I mean, 25 they had transcripts -- when you say Page 139 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 32 of 129 Confidential Donald Trump Art Cohen, et al. vs. Donald J. Trump ·1 "transcripts," you're talking about the grades of ·2 students and things like that? ·3 · · · Q.· · ·Grades and classes taken. ·4 · · · A.· · ·I'd see stuff around, but I ·5 didn't -- yeah, I didn't -- I didn't know the ·6 students. ·7 · · · Q.· · ·(Reading): ·8 · · · · · · ·"QUESTION:· He did not" -- ·9 · · · · · · ·Next question, line 21: 10 · · · · · · ·"QUESTION:· He did not review any of 11 · · · the real estate deals; correct? 12 · · · · · · ·"ANSWER:· That's correct." 13 · · · · · · ·Do you have any basis to dispute 14 that part of his testimony? 15 · · · A.· · ·No, not at all. 16 · · · Q.· · ·Line 24.· Again, we're talking live 17 events instructors. 18 · · · · · · ·"QUESTION:· He did not review their 19 · · · résumés? 20 · · · · · · ·"ANSWER:· That's correct." 21 · · · A.· · ·No, I saw résumés.· I would see 22 résumés.· They would come to me.· I mean, I would 23 dispute that because I would see -- I also met 24 with instructors prior to their hiring or around 25 the time of their hiring. Page 140 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 33 of 129 Confidential Donald Trump Art Cohen, et al. vs. Donald J. Trump ·1 different, but the word "quality" I think would ·2 have to stay there.· And I think the quality -- I ·3 think the quality remained.· I think it was very ·4 important to Mr. Sexton to have the quality ·5 remain. ·6 · · · Q.· · ·You did not do any sort of quality ·7 control over the materials, did you -- ·8 · · · A.· · ·Well -- ·9 · · · Q.· · ·-- personally? 10 · · · A.· · ·-- look, the original concepts and 11 everything else.· But we would give, as you 12 presented to me, different statements.· I mean, I 13 did things like that.· I think that's very 14 important, right. 15 · · · Q.· · ·What I'm getting at is -- I just 16 want to confirm one way or the other -- you did 17 not actually do a quality control -- you, Donald 18 Trump, personally did not do a quality control -- 19 · · · A.· · ·Most of that would be Mr. Sexton and 20 his staff. 21 · · · Q.· · ·And Mr. Sexton, he had no background 22 in terms of buying and selling real estate for 23 profit, did he? 24 · · · · · · ·MR. PETROCELLI:· Lacks foundation. 25 · · · Lacks foundation. Page 154 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 34 of 129 Confidential Donald Trump Art Cohen, et al. vs. Donald J. Trump ·1 · · · · · · ·THE WITNESS:· He was more of an ·2 · · · educational person. ·3 BY MR. FORGE: ·4 · · · Q.· · ·As far as you knew, he did not have ·5 any background buying and selling real estate? ·6 · · · A.· · ·I -- it was long time ago that I ·7 talked to him.· You're talking about many, many ·8 year ago.· But he was a -- he's a high-quality ·9 person who -- frankly, who was very much into the 10 world of education. 11 · · · Q.· · ·But as you sit here today, do you 12 know whether or not he had any experience buying 13 and selling -- 14 · · · A.· · ·It was limited.· It was limited. 15 think it was much more so in the school world 16 rather than the real estate world. 17 · · · Q.· · ·Do you have any understanding as to 18 whether he had ever run a school before this? 19 · · · A.· · ·That I don't -- it's too long ago. 20 I don't remember. 21 · · · Q.· · ·Do you have any understanding as to 22 whether he'd ever been an actual teacher before 23 this?· And "this" being Trump University. 24 · · · A.· · ·I had the information many, many 25 years ago, and I was very impressed with him. I Page 155 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 35 of 129 Confidential Donald Trump Art Cohen, et al. vs. Donald J. Trump ·1 bad example for the students -- for the ·2 instructors? ·3 · · · · · · ·MR. PETROCELLI:· Improper opinion ·4 · · · testimony, lacks foundation, improper ·5 · · · hypothetical, vague and ambiguous. ·6 · · · · · · ·You can answer. ·7 · · · · · · ·THE WITNESS:· It might be hyperbole ·8 · · · where he just is talking, bragging or ·9 · · · something, but I don't think it has any 10 · · · impact on the student whatsoever.· I think 11 · · · the instructor -- it's probably hyperbole. 12 BY MR. FORGE: 13 · · · Q.· · ·That's still not what I'm asking you 14 mean. 15 · · · A.· · ·Go ahead.· Try again. 16 · · · Q.· · ·Encouraging an instructor to lie to 17 the students, do you believe that sets a good or 18 a bad example for the instructor? 19 · · · · · · ·MR. PETROCELLI:· Same objections. 20 · · · · · · ·THE WITNESS:· I didn't encourage 21 · · · anybody.· I don't even know who the 22 · · · instructor is.· So, you know, I didn't 23 · · · encourage anybody. 24 BY MR. FORGE: 25 · · · Q.· · ·You have no idea what Gerald Martin Page 185 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 36 of 129 Confidential Donald Trump Art Cohen, et al. vs. Donald J. Trump ·1 represented to students; right? ·2 · · · A.· · ·No, I don't know that. ·3 · · · Q.· · ·You have no idea what James Harris ·4 represented to students; right? ·5 · · · A.· · ·No, I didn't -- I don't know that. ·6 I don't know that. ·7 · · · Q.· · ·And you have no idea what Keith ·8 Sperry represented to students; correct? ·9 · · · A.· · ·No. 10 · · · Q.· · ·You have no idea what Steve Goff 11 represented to students; correct? 12 · · · A.· · ·I know you're in classes for hours 13 and hours.· No, I don't know what they said to 14 the various students. 15 · · · Q.· · ·You don't know what Chris Goff -- 16 · · · A.· · ·Many people are very happy with the 17 courses, I know that. 18 · · · Q.· · ·You don't know what Chris Goff 19 represented; correct? 20 · · · A.· · ·No. 21 · · · Q.· · ·You don't know what any of these 22 live events instructors represented to students; 23 correct? 24 · · · A.· · ·Well, they represented real estate 25 and real estate knowledge.· That's what they Page 186 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 37 of 129 Confidential Donald Trump Art Cohen, et al. vs. Donald J. Trump ·1 represented.· And many people are very happy with ·2 those classes. ·3 · · · Q.· · ·Do you have personal knowledge of ·4 anything these live events instructors ·5 represented to students? ·6 · · · A.· · ·I must tell you I had it for a long ·7 time and I had very few complaints. ·8 · · · Q.· · ·Do you have personal knowledge of ·9 anything an instructor -- 10 · · · A.· · ·Usually if people have problems with 11 something that I have, I will be inundated with 12 letters and phone calls and other things. 13 received almost nothing for years from Trump 14 University. 15 · · · Q.· · ·Just try to focus on my question -- 16 · · · A.· · ·I'm just telling you, I received 17 very few complaints over years with thousands of 18 students. 19 · · · Q.· · ·Do you have personal knowledge of 20 any of the representations that the live events 21 instructors made to the students? 22 · · · · · · ·MR. PETROCELLI:· By "personal 23 · · · knowledge," do you mean did he hear them 24 · · · himself? 25 · · · · · · ·MR. FORGE:· Hear them, read them. I Page 187 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 38 of 129 Confidential Donald Trump Art Cohen, et al. vs. Donald J. Trump ·1 · · · · · · ·THE WITNESS:· Hear them myself, no. ·2 · · · Read them myself, no. ·3 BY MR. FORGE: ·4 · · · Q.· · ·Have you ever -- have you ever been ·5 deceived? ·6 · · · A.· · ·Yes.· Sure. ·7 · · · Q.· · ·Have there ever been instances in ·8 which you didn't realize you had been deceived ·9 until some time later? 10 · · · A.· · ·I can't think of any.· I mean, 11 normally -- I can't think of any. 12 · · · Q.· · ·But you agree with me that there's 13 typically a period -- if you're deceived, it 14 takes time before you realize you've been 15 deceived; correct? 16 · · · · · · ·MR. PETROCELLI:· Improper 17 · · · hypothetical, lacks foundation, improper 18 · · · opinion testimony. 19 · · · · · · ·THE WITNESS:· Yeah, I really can't 20 · · · answer a question like that.· I mean, 21 · · · deceived -- I can't even -- I'd have to 22 · · · think about even being deceived, first of 23 · · · all.· And then after that, I'd have to 24 · · · start thinking about timing. 25 · · · · · · ·MR. FORGE:· Can we have Tab 65, 208 Page 188 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 39 of 129 Confidential Donald Trump Art Cohen, et al. vs. Donald J. Trump ·1 · · · · · · ·MR. PETROCELLI:· Excuse me. ·2 · · · · · · ·In my [sic] book, I don't know what ·3 · · · that means.· I object to that on vague and ·4 · · · ambiguous. ·5 BY MR. FORGE: ·6 · · · Q.· · ·Do you consider that to be ·7 potentially an acceptable -- ·8 · · · A.· · ·It depends on the materials -- ·9 · · · · · · ·MR. PETROCELLI:· Improper opinion 10 · · · testimony, vague and ambiguous. 11 · · · · · · ·THE WITNESS:· The instructors have 12 · · · great materials to work with.· It depends 13 · · · on the materials they use.· It depends on 14 · · · the books they've been given.· It depends 15 · · · on a lot of other information. 16 BY MR. FORGE: 17 · · · Q.· · ·So construct for me a scenario -- 18 · · · A.· · ·And we did have a lot of very good 19 instructors.· I mean, you can always find someone 20 who's maybe not so good or -- 21 · · · Q.· · ·Can you name for me one good live 22 events instructor? 23 · · · · · · ·MR. PETROCELLI:· Objection; asked 24 · · · and answered. 25 · · · · · · ·THE WITNESS:· I don't know the Page 210 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 40 of 129 Confidential Donald Trump Art Cohen, et al. vs. Donald J. Trump ·1 · · · instructors. ·2 BY MR. FORGE: ·3 · · · Q.· · ·Do you know a single good live ·4 events instructor? ·5 · · · · · · ·MR. PETROCELLI:· Asked and answered. ·6 BY MR. FORGE: ·7 · · · Q.· · ·Do you? ·8 · · · · · · ·THE WITNESS:· Am I supposed to ·9 · · · answer that? 10 · · · · · · ·MR. PETROCELLI:· You've answered it 11 · · · many times. 12 · · · · · · ·THE WITNESS:· All I can say is -- 13 · · · · · · ·MR. PETROCELLI:· Answer it again. 14 · · · · · · ·THE WITNESS:· All I can say is it's 15 · · · many years ago.· I've had very, very few 16 · · · complaints -- until this whole thing 17 · · · started, I've had very, very few complains. 18 · · · And I always have complaints if there's a 19 · · · problem with something I'm involved in. 20 · · · I've had very, very few complaints over the 21 · · · years having to do with this. 22 BY MR. FORGE: 23 · · · Q.· · ·Mr. Trump, I'm just asking you to 24 back up your own words.· You said, we -- 25 · · · · · · ·MR. PETROCELLI:· Time out. Page 211 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 41 of 129 Confidential Donald Trump Art Cohen, et al. vs. Donald J. Trump ·1 accurately describe your thoughts on promotion ·2 and bravado? ·3 · · · A.· · ·Sure. ·4 · · · · · · ·MR. PETROCELLI:· Vague and ·5 · · · ambiguous. ·6 · · · · · · ·THE WITNESS:· Sure. ·7 BY MR. FORGE: ·8 · · · Q.· · ·Mr. Trump, you never reviewed the ·9 scripts that were provided to the live events 10 instructors, did you, sir? 11 · · · A.· · ·I don't believe so, no. 12 · · · Q.· · ·Did you -- did you ever instruct 13 Mr. Sexton to deny the existence of those 14 scripts? 15 · · · A.· · ·No.· Scripts?· No.· I don't even 16 know about scripts.· I'm not -- I'm not familiar 17 with the scripts. 18 · · · · · · ·MR. FORGE:· Can I have Tab 27, 28 19 · · · and 29, please.· Mark this as Exhibit 492. 20 · · · · · · ·(Plaintiffs' Exhibit 492, Bates Nos. 21 · · · TU154665 through 702, E-mail dated 4/14/09 22 · · · from Sexton to Harris with attachments, 23 · · · marked for identification.) 24 BY MR. FORGE: 25 · · · Q.· · ·Mr. Trump, I've placed in front of Page 216 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 42 of 129 Confidential Donald Trump Art Cohen, et al. vs. Donald J. Trump ·1 BY MR. FORGE: ·2 · · · Q.· · ·Is this consistent -- ·3 · · · A.· · ·As I said about five times, I didn't ·4 know about it. ·5 · · · Q.· · ·Understood. ·6 · · · · · · ·But were you -- did you approve this ·7 type of false statement being made to students? ·8 · · · A.· · ·No.· Nobody ever asked me about it, ·9 but, no. 10 · · · Q.· · ·Did you convey to Michael Sexton 11 that it would be okay to engage in this type of 12 false representation to students? 13 · · · A.· · ·No, but I don't remember ever having 14 even talked to him about something like this. 15 · · · Q.· · ·That's because you don't know what 16 representations Mr. Sexton was encouraging people 17 to make; correct? 18 · · · A.· · ·I don't.· I don't. 19 · · · Q.· · ·You don't know anything that any of 20 the live events instructors said to the students; 21 correct? 22 · · · · · · ·MR. PETROCELLI:· Asked and answered. 23 · · · · · · ·THE WITNESS:· No, I wasn't involved 24 · · · in the -- in the classes. 25 · · · · · · ·MR. PETROCELLI:· Question's also Page 228 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 43 of 129 Confidential Donald Trump Art Cohen, et al. vs. Donald J. Trump ·1 answer my question. ·2 · · · A.· · ·I'm trying to. ·3 · · · Q.· · ·What I'm asking you, is this -- this ·4 information about Mr. Sexton's lack of background ·5 in real estate, is that consistent with your ·6 understanding back when Trump University was ·7 operating? ·8 · · · A.· · ·Yes, because he was -- he was a ·9 manager. 10 · · · Q.· · ·So that's a yes? 11 · · · A.· · ·Yeah.· I knew he didn't have much of 12 a background in real estate, yes. 13 · · · Q.· · ·Or any background in real estate? 14 · · · A.· · ·Or -- yes, I think any background. 15 Just like -- I mean, I could give you examples. 16 I won't waste your time, but many times people 17 get hired -- they build cars and now they're 18 building airplanes.· You know, there are -- 19 people are competent, they're competent.· And he 20 had a very high reference. 21 · · · Q.· · ·From somebody you can't remember. 22 · · · A.· · ·From somebody -- if I can find it, 23 I'll let you know. 24 · · · Q.· · ·Mr. Trump, you never did anything to 25 certify any of the Trump University mentors, did Page 234 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 44 of 129 Confidential Donald Trump Art Cohen, et al. vs. Donald J. Trump ·1 you? ·2 · · · · · · ·MR. PETROCELLI:· Question is vague. ·3 · · · · · · ·THE WITNESS:· Me personally? ·4 BY MR. FORGE: ·5 · · · Q.· · ·Yes. ·6 · · · A.· · ·No. ·7 · · · Q.· · ·Can we go back to Exhibit 475. ·8 That's the photo spread. ·9 · · · · · · ·Mr. Trump, looking at that photo 10 spread, which is Exhibit 475, do you know if 11 there are any top Trump certified mentors in that 12 exhibit? 13 · · · A.· · ·I can't tell from these pictures, 14 no. 15 · · · Q.· · ·Do you recognize Kerry Lucas in 16 those pictures? 17 · · · A.· · ·No. 18 · · · · · · ·MR. FORGE:· Tab 58, please. 19 · · · · · · ·This is now 496. 20 · · · · · · ·(Plaintiffs' Exhibit 496, No Bates 21 · · · numbers, Transcript Excerpt, marked for 22 · · · identification.) 23 BY MR. FORGE: 24 · · · Q.· · ·Mr. Trump, I've handed you 25 Exhibit 496, which contains excerpts from the Page 235 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 45 of 129 Confidential Donald Trump Art Cohen, et al. vs. Donald J. Trump ·1 · · · · · · ·MR. PETROCELLI:· He indicated it was ·2 · · · a mentor. ·3 BY MR. FORGE: ·4 · · · Q.· · ·It could be both.· It could be ·5 neither. ·6 · · · A.· · ·No.· No.· Is this person a mentor or ·7 an instructor? ·8 · · · Q.· · ·You don't know; right? ·9 · · · A.· · ·I don't know. 10 · · · Q.· · ·Okay.· So do you know any of the 11 mentors that worked for Trump University? 12 · · · A.· · ·No, I don't.· That was up to 13 Mr. Sexton. 14 · · · Q.· · ·Did you do anything personally to 15 confirm the expertise of any of the Trump 16 University mentors? 17 · · · A.· · ·No, I didn't. 18 · · · Q.· · ·Did you do anything personally to 19 confirm the qualifications of any of the Trump 20 University mentors? 21 · · · A.· · ·There was Mr. Sexton. 22 · · · Q.· · ·So that's a no for you? 23 · · · A.· · ·No for me, yes. 24 · · · Q.· · ·Did you do anything personally to 25 confirm the qualifications of any of the Trump Page 240 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 46 of 129 Confidential Donald Trump Art Cohen, et al. vs. Donald J. Trump ·1 the fact -- to dispute testimony that you did not ·2 meet with the live events instructors? ·3 · · · · · · ·MR. PETROCELLI:· Asked and answered. ·4 · · · · · · ·THE WITNESS:· Again, I can't ·5 · · · differentiate between the live and the pre ·6 · · · live. ·7 BY MR. FORGE: ·8 · · · Q.· · ·And you can't differentiate based on ·9 name? 10 · · · A.· · ·That's right. 11 · · · Q.· · ·And you can't differentiate -- 12 · · · A.· · ·Too many years ago. 13 · · · Q.· · ·And you can't differentiate based on 14 the face? 15 · · · A.· · ·Too many years ago. 16 · · · Q.· · ·So no. 17 · · · A.· · ·It's ancient history. 18 · · · Q.· · ·So no, you can't differentiate based 19 on the name. 20 · · · A.· · ·That's right. 21 · · · Q.· · ·No, you can't differentiate based on 22 the face. 23 · · · A.· · ·That's right.· Too long ago. 24 · · · Q.· · ·So going back to Kerry Lucas and his 25 testimony that he -- prior to working for Trump Page 247 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 47 of 129 Confidential Donald Trump Art Cohen, et al. vs. Donald J. Trump ·1 University, he had no experience buying and ·2 selling real estate -- ·3 · · · · · · ·MR. PETROCELLI:· Again, you're ·4 · · · representing that he testified to that. ·5 · · · · · · ·MR. FORGE:· I am.· I am representing ·6 · · · that. ·7 · · · · · · ·MR. PETROCELLI:· We haven't seen ·8 · · · that -- ·9 · · · · · · ·MR. FORGE:· I'm representing that. 10 · · · · · · ·MR. PETROCELLI:· -- except that you 11 · · · showed that us. 12 BY MR. FORGE: 13 · · · Q.· · ·Prior to working as an instructor or 14 mentor with Trump University, he had no 15 experience buying or selling real estate. 16 · · · A.· · ·I think he was a mentor, not -- I 17 think he was not -- you said -- 18 · · · · · · ·MR. PETROCELLI:· He was a mentor. 19 · · · · · · ·THE WITNESS:· You said he was a 20 · · · mentor. 21 BY MR. FORGE: 22 · · · Q.· · ·You don't think he was also an 23 instructor? 24 · · · A.· · ·I don't know.· But I think you said 25 that he was a mentor, the first top certified Page 248 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 48 of 129 Confidential Donald Trump Art Cohen, et al. vs. Donald J. Trump ·1 mentor. ·2 · · · Q.· · ·I'm asking you.· You don't know, ·3 though? ·4 · · · A.· · ·I don't know.· I don't know who he ·5 is. ·6 · · · Q.· · ·Is that the type of qualification ·7 that you were looking for for a Trump University ·8 mentor? ·9 · · · · · · ·MR. PETROCELLI:· Assumes facts not 10 · · · in evidence. 11 · · · · · · ·THE WITNESS:· An instructor, no.· As 12 · · · a mentor, I think it's -- a mentor takes 13 · · · people around.· I think it's a little bit 14 · · · different. 15 BY MR. FORGE: 16 · · · Q.· · ·Do you know that it cost 17 significantly more money for the student to work 18 with a mentor than to sit in with an instructor? 19 · · · · · · ·MR. PETROCELLI:· Assumes facts not 20 · · · in evidence. 21 · · · · · · ·THE WITNESS:· I think it's a 22 · · · different -- it's a whole different feel. 23 · · · But there was a certain mentoring program. 24 · · · I don't have the numbers in front of me, 25 · · · no. Page 249 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 49 of 129 Confidential Donald Trump Art Cohen, et al. vs. Donald J. Trump ·1 BY MR. FORGE: ·2 · · · Q.· · ·Do you have any idea? ·3 · · · A.· · ·About what? ·4 · · · Q.· · ·How much it costs for a three-day ·5 mentorship with a Trump University mentor? ·6 · · · A.· · ·No, I don't.· It was a long time ·7 ago.· I don't know.· I don't know currently. ·8 · · · Q.· · ·For someone who had no experience ·9 buying or selling real estate, do you consider 10 that person to be qualified to charge tens of 11 thousands of dollars for a three-day real estate 12 mentorship? 13 · · · · · · ·MR. PETROCELLI:· It assumes many 14 · · · facts not in evidence and is argumentative. 15 · · · And it's an improper hypothetical and seeks 16 · · · improper opinion testimony. 17 · · · · · · ·Subject to my objections, you may 18 · · · answer. 19 · · · · · · ·THE WITNESS:· I really -- I really 20 · · · can't answer.· I don't know what his 21 · · · background is.· I really don't know.· Maybe 22 · · · he's a super genius in so many ways. 23 · · · don't know.· I mean, I can't tell you. 24 · · · just can't tell you that.· I would think 25 · · · that you'd really have to ask that question I I Page 250 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 50 of 129 Confidential Donald Trump Art Cohen, et al. vs. Donald J. Trump ·1 · · · of Mr. Sexton because -- ·2 BY MR. FORGE: ·3 · · · Q.· · ·So you have no idea if he was ·4 qualified or not? ·5 · · · A.· · ·I don't know.· I don't know. ·6 don't know anything about him.· I never met him. ·7 · · · Q.· · ·You don't know if he's qualified to ·8 be an instructor? ·9 · · · A.· · ·I never met him. 10 · · · Q.· · ·So you don't know if he was 11 qualified to be an instructor? 12 · · · A.· · ·No, because I never met him. 13 · · · Q.· · ·And you don't know if he's qualified 14 to be a mentor? 15 · · · A.· · ·I never met him. 16 · · · Q.· · ·How about Keith Sperry; do you know 17 if he -- 18 · · · A.· · ·Who? 19 · · · Q.· · ·Keith Sperry. 20 · · · A.· · ·I don't know who that is. 21 · · · Q.· · ·So you don't know if he was 22 qualified to be an instructor? 23 · · · A.· · ·Don't know. 24 · · · Q.· · ·Don't know if he was qualified to be 25 a mentor? I Page 251 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 51 of 129 Confidential Donald Trump Art Cohen, et al. vs. Donald J. Trump ·1 · · · A.· · ·Don't know. ·2 · · · Q.· · ·Chris Goff, do you know if he was ·3 qualified to be an instructor? ·4 · · · A.· · ·Okay.· No, I don't. ·5 · · · Q.· · ·Qualified to be a mentor? ·6 · · · A.· · ·I don't know. ·7 · · · Q.· · ·Steve Goff, do you know if he was ·8 qualified to be an instructor? ·9 · · · A.· · ·I don't know who they are. 10 · · · Q.· · ·Do you know if he was qualified to 11 be a mentor? 12 · · · A.· · ·I don't know who they are. 13 · · · Q.· · ·James Harris, do you know if he was 14 qualified to be an instructor? 15 · · · A.· · ·I don't know who it is. 16 · · · Q.· · ·So that's a no? 17 · · · · · · ·(Reporter seeks clarification.) 18 · · · A.· · ·I don't know who he is. 19 · · · Q.· · ·And therefore you don't know if he 20 was qualified to be an instructor? 21 · · · A.· · ·I don't know. 22 · · · Q.· · ·Okay.· So you don't know. 23 · · · A.· · ·I don't know the people.· I wasn't 24 running it.· I don't know the people. 25 · · · Q.· · ·And you don't know whether they were Page 252 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 52 of 129 Confidential Donald Trump Art Cohen, et al. vs. Donald J. Trump ·1 qualified? ·2 · · · A.· · ·I don't know that because I was not ·3 running it.· I don't know who the people are. ·4 · · · Q.· · ·And you also don't know whether they ·5 were qualified. ·6 · · · A.· · ·I don't know whether or not they ·7 were qualified, no. ·8 · · · Q.· · ·Now, do you know whether or not ·9 instructors with Trump University had prior 10 judgments entered against them from former 11 students? 12 · · · A.· · ·No, I don't. 13 · · · Q.· · ·Is that the type of -- 14 · · · A.· · ·You mean former students, before me? 15 · · · Q.· · ·Before Trump University, yes. 16 · · · A.· · ·That I don't know. 17 · · · Q.· · ·Okay.· Is that the type of -- 18 · · · · · · ·MR. PETROCELLI:· Can you repeat the 19 · · · question?· I'm sorry. 20 · · · · · · ·MR. FORGE:· Sure. 21 BY MR. FORGE: 22 · · · Q.· · ·Instructor with Trump University had 23 a judgment entered against him by former 24 students. 25 · · · · · · ·MR. PETROCELLI:· A former student Page 253 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 53 of 129 Confidential Donald Trump Art Cohen, et al. vs. Donald J. Trump ·1 · · · A.· · ·Or resolve the matter -- or to ·2 resolve the matter, yes. ·3 · · · Q.· · ·Do you recall Mr. Sexton bringing to ·4 your attention in 2005 issues with the New York ·5 State Department of Education regarding the ·6 legality of using the name "University" in the ·7 State of New York? ·8 · · · A.· · ·Very vaguely, but I thought he had ·9 it all worked out. 10 · · · Q.· · ·So you remember the issue coming up 11 back then, but you thought he worked it out? 12 · · · A.· · ·I thought he worked it out. 13 remember the issue, but I thought it was all 14 worked out. 15 · · · Q.· · ·And what -- what do you recall him 16 doing to work out the issue back in 2005? 17 · · · A.· · ·It wasn't a question of what he did. 18 But I just thought he had it worked out. 19 didn't know what he did, but I did not think it 20 was an issue. 21 · · · Q.· · ·So from 2005 -- from 2006 forward, 22 you thought that issue had been resolved? 23 · · · A.· · ·I did not think it was an issue. 24 remember hearing about the issue, but I thought 25 that it was all worked out.· Unfortunately, maybe I I I Page 273 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 54 of 129 Confidential Donald Trump Art Cohen, et al. vs. Donald J. Trump ·1 it wasn't. ·2 · · · Q.· · ·What, if anything, did you do to ·3 verify that it had been resolved in 2005? ·4 · · · A.· · ·Nothing.· I thought it was worked ·5 out. ·6 · · · Q.· · ·Okay.· And you thought it was worked ·7 out based on what? ·8 · · · A.· · ·Just based on the fact that I didn't ·9 hear much about it anymore, if anything.· Until 10 later, I didn't hear about it.· I thought that 11 this is -- I mean, this is a thing that is not 12 very difficult to work out one way or the other, 13 and I would have assumed that Mr. Sexton would 14 have been able to work that out. 15 · · · Q.· · ·So other than assuming he would have 16 been able to work it out, did you actually do 17 anything to confirm -- 18 · · · A.· · ·No. 19 · · · Q.· · ·-- whether or not it had been worked 20 out? 21 · · · A.· · ·No, because I didn't think it was 22 necessary.· I thought he was -- he was in charge, 23 he was doing a job.· And I thought he would have 24 gotten this taken care of. 25 · · · Q.· · ·And you later learned that was not Page 274 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 55 of 129 Confidential Donald Trump Art Cohen, et al. vs. Donald J. Trump ·1 the case; correct? ·2 · · · A.· · ·Well, I later learned it was ·3 continuing onward, which -- I was surprised ·4 because I thought it was something that could ·5 have been routinely handled. ·6 · · · Q.· · ·But you understand now that it was ·7 not, in fact, resolved in 2005; correct? ·8 · · · A.· · ·I guess it wasn't, but -- I thought ·9 it was, but I guess it wasn't.· And I heard that 10 only later on. 11 · · · Q.· · ·And so do you believe Mr. Sexton's 12 failure to resolve this in 2005 is consistent 13 with him being competent and capable? 14 · · · · · · ·MR. PETROCELLI:· Vague, improper 15 · · · opinion testimony. 16 · · · · · · ·THE WITNESS:· I only know I was 17 · · · surprised that it wasn't worked out because 18 · · · it's not a hard thing to work out. 19 BY MR. FORGE: 20 · · · Q.· · ·Were there any repercussions for 21 Mr. Sexton once you found out that it had not 22 actually been worked out? 23 · · · A.· · ·Well, I think it was years later 24 that I actually found out.· Yeah, I was not 25 happy.· I was not happy.· Because it's so easy to Page 275 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 56 of 129 Confidential Donald Trump Art Cohen, et al. vs. Donald J. Trump ·1 work out.· It's not like a big deal. ·2 · · · Q.· · ·Did you express your displeasure to ·3 anyone? ·4 · · · A.· · ·Maybe to Mr. Sexton.· Maybe to ·5 Mr. Garten.· Could have been Mr. Garten. ·6 · · · Q.· · ·Anyone else you can think of? ·7 · · · A.· · ·No.· I think it was mostly to ·8 Mr. Garten actually, a lawyer. ·9 · · · · · · ·MR. PETROCELLI:· Don't talk about 10 · · · your communications with -- 11 BY MR. FORGE: 12 · · · Q.· · ·Approximately when was that? 13 · · · A.· · ·When I found out it wasn't worked 14 out.· I assumed this was worked out a long -- I 15 don't know. 16 · · · Q.· · ·Give me a year. 17 · · · A.· · ·Years ago.· I have no idea, but 18 years ago. 19 · · · Q.· · ·So years -- let me make sure because 20 we're talking about a pretty wide span of time. 21 · · · · · · ·2005 you found out there was an 22 issue; right? 23 · · · A.· · ·Yes. 24 · · · Q.· · ·You think that issue is resolved. 25 · · · A.· · ·I don't know -Page 276 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 57 of 129 Confidential Donald Trump Art Cohen, et al. vs. Donald J. Trump ·1 · · · Q.· · ·You assume that issue is -- ·2 · · · A.· · ·I don't know if it was 2005, but I ·3 heard there was an issue a long time ago. ·4 heard the issue was worked out.· It wasn't hard ·5 to work out.· It's not even a big penalty if you ·6 don't work it out, but it's something that wasn't ·7 hard to work out. ·8 · · · · · · ·And I would have assumed they worked ·9 it out, and then I found out they didn't work it 10 out.· I think I spoke to my lawyer about it. 11 think I spoke to Sexton about it. 12 · · · Q.· · ·What I'm trying to place is, when 13 did you find out that they hadn't worked it out, 14 what year? 15 · · · · · · ·MR. PETROCELLI:· Asked and answered. 16 · · · · · · ·THE WITNESS:· Years ago, but 17 · · · ultimately they made the name change or 18 · · · something. 19 BY MR. FORGE: 20 · · · Q.· · ·2010?· I'll tell you that 2010 is 21 when the name change came into effect. 22 · · · A.· · ·Sometime prior to that. 23 · · · Q.· · ·So sometime prior to then you found 24 out that it hadn't been resolved? 25 · · · A.· · ·That's right. I I Page 277 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 58 of 129 Confidential Donald Trump Art Cohen, et al. vs. Donald J. Trump ·1 that you didn't approve; correct? ·2 · · · A.· · ·I don't know.· I mean, I don't know ·3 what the -- I can't answer that question. ·4 think I looked at these two. ·5 · · · Q.· · ·Are you aware of any marketing ·6 materials for Trump University bearing your name ·7 that you didn't approve? ·8 · · · A.· · ·I'm not aware. ·9 · · · Q.· · ·Any marketing materials for Trump 10 University bearing your picture that you did not 11 approve? 12 · · · A.· · ·I'm not aware of any, no. 13 · · · Q.· · ·Any marketing materials for Trump 14 University bearing your signature that you did 15 not approve? 16 · · · A.· · ·I'm not aware of any, no. 17 · · · Q.· · ·If you turn, please, to 18 page 10921 -- 102921.· This is -- it appears to 19 be an ad for fast-track foreclosure investing 20 seminars that were going to take place in Saddle 21 Brook, New Jersey in March of 2008. 22 · · · · · · ·Do you see that at the bottom? 23 · · · A.· · ·Yes.· Okay. 24 · · · Q.· · ·Mr. Trump, you have no idea who the 25 instructor was for these seminars, do you? I Page 280 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 59 of 129 Confidential Donald Trump Art Cohen, et al. vs. Donald J. Trump ·1 · · · A.· · ·I don't know that, no. ·2 · · · Q.· · ·And you have no idea whether they ·3 presented any of your personal real estate ·4 strategies, do you? ·5 · · · A.· · ·Well, I certainly think they ·6 probably did.· Again, you'd have to ask that ·7 question of Mr. Sexton. ·8 · · · Q.· · ·Okay.· So -- but I'm asking it to ·9 you now. 10 · · · · · · ·Do you have any personal 11 knowledge -- 12 · · · A.· · ·No. 13 · · · Q.· · ·-- as to whether or not they 14 presented any of your actual real estate 15 strategies? 16 · · · A.· · ·No.· I would think Mr. Sexton would 17 be able to give you that answer. 18 · · · Q.· · ·And you are not able to? 19 · · · A.· · ·You're talking about years ago.· In 20 2007, you're talking about many, many years ago. 21 · · · Q.· · ·But even at the time, you didn't do 22 anything to make sure you knew exactly what they 23 were going to be presenting; correct? 24 · · · A.· · ·Well, I would discuss things with 25 Mr. Sexton and with, you know, attorneys at the Page 281 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 60 of 129 Confidential Donald Trump Art Cohen, et al. vs. Donald J. Trump ·1 time and Mr. Weisselberg, et cetera, et cetera, ·2 Alan Weisselberg.· And, you know, I knew -- I ·3 knew generally speaking, but, no.· Mr. Sexton was ·4 in charge of the school. ·5 · · · Q.· · ·So you did not know what was being ·6 presented at this seminar; correct? ·7 · · · A.· · ·I told you you'd have to ask ·8 Mr. Sexton. ·9 · · · Q.· · ·I realize that, Mr. Trump, but I 10 still have to get on the record you did not know; 11 correct? 12 · · · A.· · ·I was not aware of the exact 13 details, no. 14 · · · Q.· · ·You weren't aware of any of the 15 details; correct? 16 · · · A.· · ·Probably true.· Again, it's a long 17 time ago, I'd have to check, but probably -- 18 · · · Q.· · ·But as far as you know, you weren't 19 aware -- 20 · · · A.· · ·As far as I know, that's right. 21 · · · Q.· · ·Do you have any sort of unique 22 foreclosure investing system? 23 · · · · · · ·MR. PETROCELLI:· The question is 24 · · · vague. 25 · · · · · · ·THE WITNESS:· I think more than Page 282 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 61 of 129 Confidential Donald Trump Art Cohen, et al. vs. Donald J. Trump ·1 money back.· I would sign up too.· Give me my ·2 money back, even if I liked it. ·3 · · · Q.· · ·Mr. Trump, my question was, do you ·4 know the identity of the instructors for any of ·5 these -- ·6 · · · A.· · ·It's too many years ago. ·7 · · · Q.· · ·So that's a no; right? ·8 · · · A.· · ·I guess, yes.· It's too many years ·9 ago. 10 · · · Q.· · ·So it's a no? 11 · · · A.· · ·It's ancient history. 12 · · · Q.· · ·You don't know whether the 13 instructors for these seminars ever bought and 14 sold real estate prior to giving these 15 presentations; correct? 16 · · · A.· · ·You have to -- don't forget.· It 17 wasn't only about the instructors; it was about 18 the material that the instructors gave out.· That 19 was a very important element -- 20 · · · Q.· · ·Is that correct, Mr. Trump? 21 · · · A.· · ·-- the material that they gave out. 22 · · · · · · ·Yes, that's correct. 23 · · · Q.· · ·That's correct you don't know 24 whether they bought or sold real estate? 25 · · · A.· · ·No. Page 300 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 62 of 129 Confidential Donald Trump Art Cohen, et al. vs. Donald J. Trump ·1 · · · first. ·2 · · · · · · ·MR. PETROCELLI:· Of Michael Sexton's ·3 · · · examination? ·4 · · · · · · ·MR. FORGE:· Yes, the Michael Sexton ·5 · · · examination. ·6 BY MR. FORGE: ·7 · · · Q.· · ·The next portion begins at line 22: ·8 · · · · · · ·"QUESTION:· Did Donald Trump ever ·9 · · · review any of the materials that you 10 · · · prepared at Trump U to be used at the 11 · · · preview sessions? 12 · · · · · · ·"ANSWER:· I don't believe so." 13 · · · · · · ·Again, do you have any personal 14 knowledge that -- as to the accuracy or 15 inaccuracy of that testimony? 16 · · · A.· · ·I'd have to see the materials. 17 · · · · · · ·MR. PETROCELLI:· Asked and answered. 18 BY MR. FORGE: 19 · · · Q.· · ·Next question.· This is page 161. 20 · · · A.· · ·You're -- you used the word 21 "prepare" or did you use the word "review" the 22 materials? 23 · · · Q.· · ·It said: 24 · · · · · · ·"QUESTION:· Did Donald Trump ever 25 · · · review any of the materials that you Page 312 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 63 of 129 Confidential Donald Trump Art Cohen, et al. vs. Donald J. Trump ·1 · · · prepared at Trump U to be used at the ·2 · · · preview sessions?" ·3 · · · · · · ·MR. PETROCELLI:· Meaning that ·4 · · · Michael Sexton prepared. ·5 BY MR. FORGE: ·6 · · · Q.· · ·And the answer is: ·7 · · · · · · ·"ANSWER:· I don't believe so." ·8 · · · A.· · ·I would have to look at the material ·9 before I could answer that question. 10 · · · Q.· · ·Got it.· Okay. 11 · · · · · · ·So without looking at materials, you 12 can't -- 13 · · · A.· · ·I can't -- 14 · · · Q.· · ·-- refute or confirm that? 15 · · · A.· · ·That is correct.· I have to see the 16 material. 17 · · · Q.· · ·(Reading): 18 · · · · · · ·"QUESTION:· Switching over then to 19 · · · the three-day workshops/seminars" -- 20 · · · · · · ·MR. PETROCELLI:· Let the record 21 · · · reflect you're still reading from the 22 · · · testimony? 23 · · · · · · ·MR. FORGE:· Yes.· This is now 24 · · · page 161, line 3. 25 Page 313 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 64 of 129 Confidential Donald Trump Art Cohen, et al. vs. Donald J. Trump ·1 ago. ·2 · · · Q.· · ·Line 4, page 163: ·3 · · · · · · ·"QUESTION:· Did anybody at Trump ·4 · · · Organization work on the curriculum for the ·5 · · · three-day workshops? ·6 · · · · · · ·"ANSWER:· No, they did not." ·7 · · · · · · ·Do you have any basis to dispute -- ·8 any personal knowledge to dispute that testimony? ·9 · · · A.· · ·No.· I would have to see the 10 information you're talking about, but other than 11 that, no. 12 · · · · · · ·MR. PETROCELLI:· I also would like 13 · · · the record to reflect, since we don't have 14 · · · a copy of the testimony in front of us and 15 · · · Mr. Forge read that out loud from his 16 · · · mobile device and it was a lengthy, lengthy 17 · · · passage -- 18 · · · · · · ·MR. FORGE:· That last passage wasn't 19 · · · lengthy. 20 · · · · · · ·MR. PETROCELLI:· Well, the whole 21 · · · thing you read was pretty long. 22 · · · · · · ·MR. FORGE:· That's just because I 23 · · · wanted to make sure -- 24 · · · · · · ·MR. PETROCELLI:· I know, it's all 25 · · · context. Page 316 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 65 of 129 Confidential Donald Trump Art Cohen, et al. vs. Donald J. Trump ·1 · · · · · · ·MR. FORGE:· -- I was putting it in ·2 · · · context. ·3 · · · · · · ·MR. PETROCELLI:· It's all context. ·4 BY MR. FORGE: ·5 · · · Q.· · ·Next question and answer -- this is ·6 on page 163, line 8: ·7 · · · · · · ·"QUESTION:· Did Mr. Trump himself ·8 · · · participate in the creation of the ·9 · · · materials used at the three-day workshops? 10 · · · · · · ·"ANSWER:· No, he did not." 11 · · · · · · ·Do you have any basis or personal 12 knowledge to dispute that testimony? 13 · · · A.· · ·No, I don't.· I'd have to look at 14 the material, but I don't. 15 · · · · · · ·MR. FORGE:· Can we get Tab 47, 16 · · · please.· This is Exhibit 500. 17 · · · · · · ·(Plaintiffs' Exhibit 500, Bates Nos. 18 · · · TU102409 through 415, E-mail dated 10/27/08 19 · · · from Sexton to Graff with attachments, 20 · · · marked for identification.) 21 BY MR. FORGE: 22 · · · Q.· · ·Mr. Trump, I've placed in front of 23 you a document marked as Exhibit 500.· It begins 24 at TU102409 and continues to TU102415. 25 · · · · · · ·Do you see that? Page 317 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 66 of 129 Confidential Donald Trump Art Cohen, et al. vs. Donald J. Trump ·1 · · · · · · ·MR. FORGE:· I'm sorry.· Let me be ·2 · · · more specific. ·3 BY MR. FORGE: ·4 · · · Q.· · ·Did you ever instruct any of the ·5 Trump University live events instructors or ·6 mentors to represent to students that you had ·7 handpicked them? ·8 · · · A.· · ·Again, I can't differentiate between ·9 the live event and the other.· I mean, I met with 10 numerous instructors -- 11 · · · Q.· · ·Okay. 12 · · · A.· · ·-- but I don't know the dates. 13 don't know whether, as you say, it's live events 14 or other events.· But I met with numerous people 15 over the years. 16 · · · Q.· · ·Let's pull 483 out again, 17 Exhibit 483. 18 · · · · · · ·MR. PETROCELLI:· Is that the 2012 19 · · · interrogatories? 20 BY MR. FORGE: 21 · · · Q.· · ·Again, referencing at page 3, those 22 individuals listed there, that's -- you can -- 23 did you ever instruct any of those individuals to 24 represent to students that you had handpicked 25 them? I Page 329 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 67 of 129 Confidential Donald Trump Art Cohen, et al. vs. Donald J. Trump ·1 · · · A.· · ·I don't believe so.· I mean, I don't ·2 think -- I'm not sure that I used that ·3 expression.· I don't think I said, oh, you've ·4 been handpicked.· But -- and, again, it's many ·5 years ago and I recognize the names and I had ·6 people up to my office. ·7 · · · Q.· · ·Other than -- ·8 · · · A.· · ·I think to my office, but I met ·9 people beyond the office, I think.· But, anyway, 10 go ahead. 11 · · · Q.· · ·Beyond these folks, who are the only 12 ones listed that you met -- beyond these folks, 13 some of the names you mentioned earlier -- Joe 14 Martin, the guy who was talking about the dinner, 15 did you ever authorize him to represent to 16 students that he had been handpicked by you? 17 · · · A.· · ·I don't really know who he is.· It's 18 too long ago. 19 · · · Q.· · ·Keith Sperry, did you ever authorize 20 him to represent -- 21 · · · A.· · ·I don't know.· Too long ago. 22 · · · Q.· · ·So the answer is no as to all? 23 · · · A.· · ·I did meet with people. 24 · · · Q.· · ·Did you authorize anyone to falsely 25 represent to students that they had been Page 330 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 68 of 129 Confidential Donald Trump Art Cohen, et al. vs. Donald J. Trump ·1 handpicked by you? ·2 · · · A.· · ·No.· I would never do that. ·3 · · · Q.· · ·So if Steve Goff represented he had ·4 been handpicked by you and admitted that that ·5 wasn't true, is that something you would not have ·6 authorized? ·7 · · · A.· · ·Say it again -- ·8 · · · · · · ·MR. PETROCELLI:· Improper -- time ·9 · · · out. 10 · · · · · · ·Improper opinion testimony. 11 BY MR. FORGE: 12 · · · Q.· · ·If Steve Goff has admitted that he 13 was not handpicked by you -- 14 · · · A.· · ·He had said he wasn't. 15 · · · Q.· · ·He's admitted that he was not 16 handpicked by you.· But we have recordings of him 17 saying differently to the students. 18 · · · · · · ·What I'm saying is, him representing 19 differently to the students, is that something 20 that wouldn't have been authorized by you? 21 · · · · · · ·MR. PETROCELLI:· You can answer 22 · · · that. 23 · · · · · · ·THE WITNESS:· What? 24 · · · · · · ·MR. PETROCELLI:· You can answer the 25 · · · question whether you authorized this fellow Page 331 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 69 of 129 Confidential Donald Trump Art Cohen, et al. vs. Donald J. Trump ·1 · · · to say he was handpicked by you. ·2 · · · · · · ·THE WITNESS:· Well, I don't know ·3 · · · because, you know, it depends on the ·4 · · · definition of what that means, handpicked. ·5 · · · I wanted very good instructors.· So on the ·6 · · · basis of good instructors, if he's a good ·7 · · · instructor and if he was -- you know, if he ·8 · · · was in there, then he was a good ·9 · · · instructor. 10 · · · · · · ·So I don't know.· I mean, I don't 11 · · · know what he said, but as far as I'm 12 · · · concerned, I just -- I wanted good 13 · · · instructors.· And I wanted good material. 14 · · · And I wanted books.· I wanted them to study 15 · · · the books. 16 BY MR. FORGE: 17 · · · Q.· · ·But you never actually sat down with 18 these live events instructors to make sure they 19 were good? 20 · · · A.· · ·I don't know.· Because I sat down 21 with instructors.· I don't know who they were. 22 It was so many years ago that I don't know who 23 they were. 24 · · · Q.· · ·They've testified they never met 25 you. Page 332 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 70 of 129 Confidential Donald Trump Art Cohen, et al. vs. Donald J. Trump ·1 · · · A.· · ·Oh, that's fine. ·2 · · · · · · ·MR. PETROCELLI:· You know, we don't ·3 · · · have the testimony -- ·4 BY MR. FORGE: ·5 · · · Q.· · ·So for someone like Steve Goff, do ·6 you have any basis to dispute his testimony that ·7 he never met you? ·8 · · · · · · ·MR. PETROCELLI:· Lacks foundation. ·9 · · · · · · ·THE WITNESS:· I don't think I would, 10 · · · no. 11 · · · · · · ·MR. FORGE:· Let's go to Tab 205. 12 · · · · · · ·MR. PETROCELLI:· Is that a new 13 · · · exhibit? 14 · · · · · · ·MR. FORGE:· Yes.· I'll give it an 15 · · · exhibit number in a minute. 16 · · · · · · ·MR. PETROCELLI:· We're up to 501. 17 · · · · · · ·MR. FORGE:· This is going to be a 18 · · · video and audio exhibit or maybe just 19 · · · audio.· Let's see.· I'm going to play 20 · · · what's going to be Exhibit 501. 21 · · · · · · ·So, Eileen, we will get that on the 22 · · · drive to you, and that's on the disc. 23 · · · · · · ·(Plaintiffs' Exhibit 501, No Bates 24 · · · numbers, Audio Clip, marked for 25 · · · identification.) Page 333 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 71 of 129 Volume II Donald Trump Confidential Art Cohen, et al. vs. Donald J. Trump ·1· · · · · · · ·UNITED STATES DISTRICT COURT ·2· · · · · · · SOUTHERN DISTRICT OF CALIFORNIA ·3 ·4· · · ·5· · · ·6· · · ·7· · · ·8· · · ·9· · · 10 ·ART COHEN, Individually) ·and on Behalf of All· ·) ·Others Similarly· · · ·)No. 3:13-cv-02519-GPC-WVG ·Situated,· · · · · · · ) · · · · · · · · · · · · )· CLASS ACTION · · · · · · Plaintiff,· ) · · · · · · · · · · · · ) ·VS.· · · · · · · · · · ) · · · · · · · · · · · · ) ·DONALD J. TRUMP,· · · ·) · · · · · · · · · · · · ) · · · · · · Defendant.· ) 11 12 13 14· · · · · · · · ·CONFIDENTIAL TRANSCRIPT 15· · · · ·VIDEOTAPED DEPOSITION OF DONALD J. TRUMP 16· · · · · · · ·VOLUME II (Pages 371 to 485) 17· · · · · · · · · · ·January 21, 2016 18· · · · · · · · · · Las Vegas, Nevada 19 20 21 22· Reported By: 23· Gale Salerno 24· RMR, CSR No. 12375 25· Job No.: 10021313 Page 371 www.aptusCR.com Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 72 of 129 Volume II Donald Trump Confidential Art Cohen, et al. vs. Donald J. Trump ·1· · · · · · · ·UNITED STATES DISTRICT COURT ·2· · · · · · · SOUTHERN DISTRICT OF CALIFORNIA ·3 ·4· · · ·5· · · ·6· · · ·7· · · ·8· · · ·9· · · 10 ·ART COHEN, Individually) ·and on Behalf of All· ·) ·Others Similarly· · · ·)No. 3:13-cv-02519-GPC-WVG ·Situated,· · · · · · · ) · · · · · · · · · · · · )· CLASS ACTION · · · · · · Plaintiff,· ) · · · · · · · · · · · · ) ·VS.· · · · · · · · · · ) · · · · · · · · · · · · ) ·DONALD J. TRUMP,· · · ·) · · · · · · · · · · · · ) · · · · · · Defendant.· ) 11 12 13 14 15· · · · ·VIDEOTAPED DEPOSITION OF DONALD J. TRUMP 16· · · · · · · ·VOLUME II (Pages 371 to 485) 17 18 19· Deposition of DONALD J. TRUMP, taken on behalf of the 20· Class Counsel at 2000 Fashion Show Drive, Room 6104, 21· Las Vegas, Nevada, 89109, beginning at 8:01 a.m. and 22· ending at 10:53 a.m. on Thursday, January 21, 2016, 23· before Gale Salerno, Registered Merit Reporter, 24· Certified Shorthand Reporter No. 12375. 25 Page 372 www.aptusCR.com Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 73 of 129 Volume II Donald Trump Confidential Art Cohen, et al. vs. Donald J. Trump ·1· APPEARANCES: ·2· For the Plaintiff and the Class: ·3· · · ·4· · · ·5· · · ·6· · · ·7· · · ·8 · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · JASON A. FORGE, ESQUIRE RACHEL L. JENSEN, ESQUIRE CHARLES M. McCUE, ESQUIRE Robbins Geller Rudman & Dowd, LLP 655 West Broadway, Suite 1900 San Diego, California· 92101 (619) 231-1058 jforge@rgrdlaw.com rjensen@rgrdlaw.com chuckmccue@rgrdlaw.com ·9· For the Defendant, Donald J. Trump: 10· · · 11· · · 12· · · 13 · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · DANIEL PETROCELLI, ESQUIRE O'Melveny & Myers, LLP 1999 Avenue of the Stars, 7th Floor Los Angeles, California· 90067 (310) 246-6850 dpetrocelli@omm.com 14· For the Defendant, Mr. Trump and Trump University: 15· · · 16· · · 17· · · 18 · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · JILL A. MARTIN, ESQUIRE Trump National Golf Club One Trump National Drive Rancho Palos Verdes, California· 90275 (310) 303-3225 jmartin@trumpnational.com 19· Also Present: 20· · · · · · MS. BECKY ULREY, Videographer 21 22 23 24 25 Page 373 www.aptusCR.com Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 74 of 129 Volume II Donald Trump Confidential Art Cohen, et al. vs. Donald J. Trump ·1· Plaintiff and the Class. ·2· · · · · · MR. PETROCELLI:· Daniel Petrocelli, for ·3· Mr. Trump. ·4· · · · · · MS. MARTIN:· Jill Martin, for Mr. Trump and ·5· Trump University. ·6· · · · · · · · · · · ·-· · -· · ·7· · · · · · · · · · DONALD J. TRUMP, ·8· · · · · · having been first duly sworn, was ·9· · · · · · examined and testified as follows: 10· · · · · · · · · · · ·-· · -· · 11 12· · · · · · · · · ·EXAMINATION RESUMED 13· BY MR. FORGE: 14· · · ·Q.· ·Good morning, Mr. Trump. 15· · · ·A.· ·Good morning. 16· · · · · · MR. FORGE:· If I could ask the court 17· reporter to please mark this document as 18· Exhibit 504. 19· · · · · · · · ·(Exhibit 504 was marked for 20· · · · · · · · ·identification.) 21· BY MR. FORGE: 22· · · ·Q.· ·I have just handed to you Exhibit 504. 23· It's a National Review article from December 8th, 24· 2015, which is titled, "No one was more influential 25· than Donald Trump this year." Page 377 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 75 of 129 Volume II Donald Trump Confidential Art Cohen, et al. vs. Donald J. Trump ·1· · · · · · Are you familiar with that article? ·2· · · ·A.· ·No, I'm not. ·3· · · ·Q.· ·Do you consider yourself an influential ·4· person? ·5· · · ·A.· ·Yes. ·6· · · ·Q.· ·And in what way are you influential? ·7· · · ·A.· ·Well, I think I've set a certain standard. ·8· I think I have certain leadership abilities.· I think ·9· in business I'm respected, and I would say that I 10· guess now in politics I'm respected, because I'm the 11· leading candidate on the Republican side. 12· · · ·Q.· ·Do you want people to consider you 13· trustworthy? 14· · · ·A.· ·Yes. 15· · · ·Q.· ·Do you want people to consider you 16· reliable? 17· · · ·A.· ·Yes. 18· · · ·Q.· ·Did you get a sense that your level of 19· influence grew after The Apprentice show started? 20· · · · · · MR. PETROCELLI:· The question is vague. 21· · · · · · THE WITNESS:· I would say not really.· The 22· reason I was chosen for The Apprentice is my level of 23· influence. 24· · · · · · But it possibly -- I think not necessarily 25· influence, I think I became even better known. Page 378 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 76 of 129 Volume II Donald Trump Confidential Art Cohen, et al. vs. Donald J. Trump ·1· BY MR. FORGE: ·2· · · ·Q.· ·And by "better known," do you have fans? ·3· · · ·A.· ·Yeah, I do. ·4· · · ·Q.· ·And if you consider someone to be a fan, ·5· what does that mean to you? ·6· · · ·A.· ·People that really like a person and ·7· respect a person.· I guess generally respect, but ·8· certainly like. ·9· · · ·Q.· ·Now, over the years you've promoted a 10· variety of products, properties and services; is that 11· fair to say?· Golf courses? 12· · · ·A.· ·Yes. 13· · · ·Q.· ·Resorts? 14· · · ·A.· ·Correct. 15· · · ·Q.· ·Condominium projects? 16· · · ·A.· ·Right. 17· · · ·Q.· ·Books? 18· · · ·A.· ·Yes. 19· · · ·Q.· ·Products such as ties? 20· · · ·A.· ·Uh-huh. 21· · · ·Q.· ·Is that a yes? 22· · · ·A.· ·Yes. 23· · · ·Q.· ·Chocolates? 24· · · ·A.· ·Yes. 25· · · ·Q.· ·And a fragrance, I believe? Page 379 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 77 of 129 Volume II Donald Trump Confidential Art Cohen, et al. vs. Donald J. Trump ·1· · · · · · · · ·identification.) ·2· ·(Playing Video From Thumbdrive Marked Exhibit 509.) ·3· BY MR. FORGE: ·4· · · ·Q.· ·Mr. Trump, you shot that video to promote ·5· Trump University, right? ·6· · · ·A.· ·Yes.· A long time ago. ·7· · · ·Q.· ·So you made that video to influence people ·8· to enroll in Trump University? ·9· · · ·A.· ·Yes. 10· · · ·Q.· ·Now, at one point you mentioned that there 11· would be professors and adjunct professors.· Do you 12· have any idea what, if any, criteria determined who 13· would be a professor versus an adjunct professor? 14· · · ·A.· ·Well, I see resumes, but mostly that was up 15· to Michael Sexton, who was the president who ran 16· Trump University. 17· · · ·Q.· ·So that's not a decision process you were 18· involved in, who would be a professor versus -19· · · ·A.· ·I would see resumes, but I told him, you 20· know, I want very good people, yes. 21· · · ·Q.· ·But in terms of determining this person 22· will be a professor versus an adjunct professor -23· · · ·A.· ·No, that was not me. 24· · · ·Q.· ·Do you know if any of the adjunct 25· professors at Trump University were ever promoted to Page 388 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 78 of 129 Volume II Donald Trump Confidential Art Cohen, et al. vs. Donald J. Trump ·1· become professors? ·2· · · ·A.· ·That I wouldn't know.· I was not running ·3· the school. ·4· · · ·Q.· ·Do you know the identities of any of the ·5· adjunct professors? ·6· · · ·A.· ·I know names, but I really don't know the ·7· identities, no. ·8· · · ·Q.· ·Were all the instructors at Trump ·9· University either a professor or an adjunct 10· professor? 11· · · ·A.· ·I would rather have you ask Mr. Sexton.· He 12· ran the school. 13· · · ·Q.· ·So you personally don't know? 14· · · ·A.· ·No, I don't know that. 15· · · ·Q.· ·You mentioned in there that the people at 16· Trump University that you were going to be putting 17· forward were going to be the best of the best. 18· · · · · · What does that mean to you? 19· · · ·A.· ·Well, I mean, they had to be good 20· instructors.· And I wanted them to be good 21· instructors, and I so instructed the people. 22· · · · · · I instructed Mr. Sexton we want to really 23· have really great people working there.· He was 24· running it.· I wasn't running it, but I wanted to 25· have really good people. Page 389 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 79 of 129 Volume II Donald Trump Confidential Art Cohen, et al. vs. Donald J. Trump ·1· · · ·A.· ·Right. ·2· · · ·Q.· ·Are there -- do any of those names, have ·3· you had a recognition of any of those names?· Any of ·4· those names come to mind now as we sit here? ·5· · · ·A.· ·No. ·6· · · ·Q.· ·So same memory or lack thereof, whatever ·7· your answers were still stand? ·8· · · ·A.· ·It's a long time. ·9· · · · · · THE WITNESS:· Just off the record for a 10· second. 11· · · · · · (A discussion was held off the record.) 12· · · · · · MR. FORGE:· If we could please mark this 13· next exhibit as 510. 14· · · · · · · · ·(Exhibits 510, 511 and 512 were 15· · · · · · · · ·marked for identification.) 16· BY MR. FORGE: 17· · · ·Q.· ·Mr. Trump, starting with Exhibit 510, does 18· that appear to be a true copy of a special invitation 19· from Donald J. Trump, and an attached letter that 20· begins Dear Friend? 21· · · ·A.· ·It does seem to be.· I don't remember this, 22· but it does seem to be, yes. 23· · · ·Q.· ·And that appears to be your signature at 24· the bottom of that invitation on the second page? 25· · · ·A.· ·Yes. Page 391 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 80 of 129 Volume II Donald Trump Confidential Art Cohen, et al. vs. Donald J. Trump ·1· · · ·Q.· ·And this invitation is all part of the ·2· promotion of Trump University; is that fair to say? ·3· · · ·A.· ·It looks like it. ·4· · · ·Q.· ·So again, this is something that was ·5· intended to influence people to enroll in Trump ·6· University? ·7· · · ·A.· ·It would look that way, yes. ·8· · · ·Q.· ·Were you personally aware of any sort of ·9· proven real estate system that students would be 10· learning at Trump University? 11· · · · · · MR. PETROCELLI:· The question is vague. 12· · · · · · THE WITNESS:· Well, what I did is we gave a 13· lot of big packages out.· Again, it's a long time 14· ago, but -- and including books that I've written, 15· et cetera, et cetera.· You have the information. 16· · · · · · But there is -- you know, there are methods 17· that have been very successful for me, and that's 18· what I would talk about.· And, you know, starting 19· with location.· Starting with, you know, various 20· forms of debt.· We talked about the kind of debt you 21· can put on properties. 22· · · · · · And we talked about a lot of different 23· things.· You can look at the books.· But I've 24· always -- and very strongly told them to stress 25· location. Page 392 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 81 of 129 Volume II Donald Trump Confidential Art Cohen, et al. vs. Donald J. Trump ·1· · · ·Q.· ·You don't know how much the mentorship ·2· cost? ·3· · · ·A.· ·I don't know. ·4· · · ·Q.· ·And you don't know what was provided during ·5· that three-day one-on-one mentorship? ·6· · · ·A.· ·No.· And I don't know Mr. Cohen. ·7· · · ·Q.· ·Or Mr. Lucas? ·8· · · ·A.· ·Or Mr. Lucas, no. ·9· · · · · · MR. FORGE:· I'm going to play for you 10· now -- we're going to mark this as -- this is going 11· to be 515.· Mr. Trump, I'll warn you in advance, it's 12· about 13 and a half minutes of Mr. Lucas' deposition 13· testimony.· So if you want to make some calls before 14· we do it, you tell me. 15· · · ·A.· ·Let's do it after.· We'll take off after. 16· · · · · · MR. PETROCELLI:· What's the file number? 17· · · · · · MR. FORGE:· The file number is 213. 18· · · · · · THE WITNESS:· He's a mentor, not a 19· professor, is what you're saying?· He's not a class 20· person? 21· · · · · · MR. FORGE:· I think he was brought in for 22· both.· But with Mr. Cohen, he was a mentor. 23· · · · · · MR. PETROCELLI:· This is Kerry Lucas' 24· deposition? 25· · · · · · MR. FORGE:· This is Kerry Lucas' Page 407 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 82 of 129 Volume II Donald Trump Confidential Art Cohen, et al. vs. Donald J. Trump ·1· give financing for things that I've bought. ·2· · · · · · I feel strongly about seller financing. ·3· And you don't have to pay points.· You don't have to ·4· pay big legal fees.· But you know, a lot of the ·5· institutions wanted points.· With seller financing, ·6· rarely does the seller ask for points.· So good ·7· thing. ·8· · · · · · Okay.· Go ahead.· I'll watch this. ·9· · · · · · · · ·(Playing video.) 10· · · · · · MR. PETROCELLI:· Just to be clear, we're 11· not listening to a continuous examination? 12· · · · · · MR. FORGE:· Exactly. 13· · · · · · MR. PETROCELLI:· These are edited clips? 14· · · · · · MR. FORGE:· Exactly.· But they're complete 15· questions and answers. 16· · · · · · MR. PETROCELLI:· Okay.· Because I noticed 17· the time code is jumping around. 18· · · · · · MR. FORGE:· Yeah, it jumps around.· But 19· none of the questions or answers are -20· · · · · · MR. PETROCELLI:· You'll give me the file? 21· · · · · · MR. FORGE:· Yes. 22· · · · · · MR. PETROCELLI:· The CD, and then I can go 23· back and review the transcript? 24· · · · · · MR. FORGE:· Yes. 25· · · · · · MR. PETROCELLI:· Thank you. Page 412 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 83 of 129 Volume II Donald Trump Confidential Art Cohen, et al. vs. Donald J. Trump ·1· · · · · · · · · · ·(Playing video.) ·2· · · · · · MR. PETROCELLI:· Take our break now? ·3· · · · · · THE WITNESS:· Do you want to go through ·4· this first? ·5· · · · · · MR. FORGE:· Let me ask just a few ·6· questions. ·7· · · · · · THE WITNESS:· I would rather go through ·8· this. ·9· BY MR. FORGE: 10· · · ·Q.· ·And I think you were chomping at the bit to 11· say this, but Mr. Trump, you did not select this man 12· to be a Trump University instructor or mentor, did 13· you? 14· · · ·A.· ·No, I didn't. 15· · · ·Q.· ·And you did not consider him to be a top 16· certified mentor, did you? 17· · · ·A.· ·No. 18· · · ·Q.· ·You did not certify him in any way, did 19· you? 20· · · ·A.· ·No, I didn't. 21· · · ·Q.· ·Now, you could have actually insisted upon 22· meeting and interviewing each of the mentors, right? 23· · · ·A.· ·I could have.· Other than I'm doing, 24· running a massive company that everybody knows that. 25· · · ·Q.· ·But so you could have, but you didn't? Page 413 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 84 of 129 Volume II Donald Trump Confidential Art Cohen, et al. vs. Donald J. Trump ·1· · · ·A.· ·I did not, no. ·2· · · ·Q.· ·And so you didn't know that a man with this ·3· kind of background was being held out as a top Trump ·4· certified mentor, did you? ·5· · · ·A.· ·No.· But in watching, it sounded to me like ·6· he would have embellished his record and he slipped ·7· through the cracks.· Frankly, I think he probably, ·8· just by the way he had answered a couple of the ·9· questions reminded me of Saturday Night Live. 10· · · · · · But I think he probably embellished his 11· record to the people that did the hiring.· And 12· nevertheless, they all got the materials, and they 13· got very good advice as far as real estate is 14· concerned. 15· · · · · · And I have to say this, and I was just 16· thinking it as I was going by, some of the biggest 17· real estate developers in the country, and I can tell 18· you in New York and elsewhere, don't have licenses. 19· They build.· They're developers.· And they build. 20· And they never went to school, and they never went 21· for licensing and they didn't do all of the things, 22· many of the things that you're asking. 23· · · · · · That's not to say anything positive or 24· negative.· But I will say that many, many real estate 25· people don't have licenses.· They're not salesmen, Page 414 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 85 of 129 Volume II Donald Trump Confidential Art Cohen, et al. vs. Donald J. Trump ·1· they're not brokers, and they just don't have ·2· licenses.· They just build. ·3· · · ·Q.· ·But he also lacked experience? ·4· · · ·A.· ·He doesn't have great experience, no. ·5· · · ·Q.· ·He doesn't have any experience buying or ·6· selling? ·7· · · ·A.· ·He has a little with his house or whatever ·8· it was, but not a lot. ·9· · · ·Q.· ·And this is not someone you would have 10· found to be fairly described as a top Trump certified 11· mentor? 12· · · ·A.· ·No, I would not have hired him. 13· · · ·Q.· ·Now, were you aware that Trump University 14· charged Mr. Cohen and others tens of thousands of 15· dollars for three days of one-on-one walking around 16· looking at properties with this man? 17· · · ·A.· ·Well, you know, frankly, the fact that he's 18· not -- if he took the advice of this particular sheet 19· right here, Mr. Cohen would have made a fortune.· He 20· would have bought real estate. 21· · · ·Q.· ·Putting that aside -22· · · ·A.· ·They're walking around looking at property, 23· and somebody has to walk around. 24· · · · · · A real estate broker oftentimes will 25· use children.· I mean, they will use people that are Page 415 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 86 of 129 Volume II Donald Trump Confidential Art Cohen, et al. vs. Donald J. Trump ·1· · · ·A.· ·No. ·2· · · ·Q.· ·Now, as you mentioned, Mr. Lucas could have ·3· slipped through the cracks in getting into Trump ·4· University as an instructor or mentor; is that right? ·5· · · ·A.· ·I don't know how.· I mean, I don't know ·6· how.· I think he could have embellished.· Or maybe ·7· they thought he did a good job. ·8· · · · · · You said he worked for another company for ·9· quite a while.· Maybe he did a great job there. 10· · · · · · I don't know exactly why they hired him or 11· how they hired him.· But I know that he worked for 12· another company named Dyna-something. 13· · · ·Q.· ·Dynatech? 14· · · ·A.· ·Dynatech.· And perhaps he was outstanding 15· at Dynatech.· So you would really have to ask the 16· people.· I mean, maybe he was really good at what he 17· did.· I just don't know. 18· · · ·Q.· ·And you don't know whether other people 19· slipped through the cracks to get in as live event 20· instructors or mentors, do you?· Personally? 21· · · ·A.· ·In every business, people slip through the 22· cracks.· No matter how well run a business, people 23· come in and they're not good, and you wonder, you 24· know, how did they get there, et cetera.· No matter, 25· you can take the best business where they just come Page 425 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 87 of 129 Volume II Donald Trump Confidential Art Cohen, et al. vs. Donald J. Trump ·1· back and, you know, they embellish or they for some ·2· reason something happens. ·3· · · · · · But there's no business in America where ·4· people don't slip through the cracks. ·5· · · ·Q.· ·So you don't know, for example, if ·6· Steve Goff is one of the guys who slipped through the ·7· cracks? ·8· · · ·A.· ·I don't know. ·9· · · ·Q.· ·You don't know if Chris -10· · · ·A.· ·It happens.· It does happen. 11· · · ·Q.· ·And you don't know if Chris Goff is one of 12· the guys that -13· · · ·A.· ·I don't know him. 14· · · ·Q.· ·James Harris, you don't know if he slipped 15· through the cracks? 16· · · ·A.· ·Don't know him. 17· · · ·Q.· ·So you don't know if he slipped through the 18· cracks? 19· · · ·A.· ·Don't know. 20· · · ·Q.· ·So you don't know one way or the other? 21· · · ·A.· ·No.· I know we had very good people, too. 22· We have a lot of good people.· But some people, you 23· know, when you're running a business, it happens that 24· you don't always get tens. 25· · · ·Q.· ·Gerald Martin, you don't know if he slipped Page 426 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 88 of 129 Volume II Donald Trump Confidential Art Cohen, et al. vs. Donald J. Trump ·1· through the cracks? ·2· · · ·A.· ·Don't know him. ·3· · · ·Q.· ·And if I didn't say, Keith Sperry, you ·4· don't know if he slipped through the cracks? ·5· · · ·A.· ·Don't know him. ·6· · · ·Q.· ·Mr. Trump, you could have sat down and ·7· personally interviewed each of these folks, correct? ·8· · · ·A.· ·I think from a time standpoint, I think it ·9· would have been very difficult.· Because of my 10· schedule and because of the fact that I am doing many 11· deals all over the world, I think it would have been 12· very tough. 13· · · · · · I mean, this was a very important thing for 14· me.· It wasn't a big monetary thing, the Trump, the 15· school.· But it was very important to me. 16· · · · · · And actually, more important to -- you 17· know, you can impart certain wisdom that you learn 18· the hard way.· And you can impart that to people. I 19· love the idea of the educational aspect of it. 20· · · · · · But to be honest, I wouldn't have had the 21· time to interview everybody because my business is 22· too big. 23· · · · · · I don't do it on any business.· I hire 24· people, and hopefully they're the right people at the 25· top, and they'll hopefully do a good job. Page 427 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 89 of 129 Volume II Donald Trump Confidential Art Cohen, et al. vs. Donald J. Trump ·1· · · ·Q.· ·And I'm just going to ask you to accept ·2· this as true.· You can check your own records to ·3· confirm it, but there were fewer than -- there were a ·4· half a dozen or so people who did the majority of the ·5· live events for Trump University. ·6· · · · · · And accepting that as true, I'm not asking ·7· you to endorse it, but you certainly had time to do a ·8· final interview of six people, right? ·9· · · ·A.· ·Well, look, I have people at the top who I 10· know.· And, you know, as an example, Mr. Sexton, who 11· I have confidence in.· And I would have assumed they 12· would have done that.· And frankly, I got so many 13· good reviews, and I would see the reviews a lot.· You 14· know, they would send me, when people leave the 15· course, they would send -- I call them report cards. 16· I don't know what the official name is, but they 17· would give us so many good marks. 18· · · · · · I actually thought that people were very 19· happy at the school.· I was very surprised.· That's 20· why I didn't settle this case, which I could have 21· settled very easily a long time ago. 22· · · ·Q.· ·And we'll get to the reviews and the 23· settlement.· All -24· · · ·A.· ·I'm just saying it seemed like things were 25· going very good. 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Trump ·1· · · ·Q.· ·But you certainly had time to do a, conduct ·2· a final interview for the six most prolific live ·3· events? ·4· · · ·A.· ·It didn't seem necessary, because I always ·5· thought the school was doing well. ·6· · · · · · You know, when I have a job that's not ·7· going well, people tell you.· Like if you have ·8· unhappy tenants, or if you have unhappy -- an office ·9· building where the tenants aren't happy, or an 10· apartment house where tenants -- you always find out. 11· They write you letters. 12· · · · · · I just -- I've heard so -- I heard so many 13· good things about the school that I honestly thought 14· that it was really being well, you know, well run. 15· · · · · · Even since then, I still have people 16· calling saying they love the school. 17· · · ·Q.· ·But I'm talking about before they're 18· actually being put out -19· · · ·A.· ·There's a reason I didn't do that.· I could 20· have found the time, but the reason I didn't do that 21· is I heard the school was running very well. 22· · · ·Q.· ·But I'm talking about before being put out 23· as instructors.· Before you say my handpicked 24· instructor is going to be there, you could have sat 25· down and personally interviewed the person, right? Page 429 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 91 of 129 Volume II Donald Trump Confidential Art Cohen, et al. vs. Donald J. Trump ·1· · · ·A.· ·I guess I could have.· I just thought that ·2· the school was doing so well, you know, from all of ·3· the reviews it's gotten.· And, you know, just people ·4· telling me. ·5· · · · · · I don't know that I've ever heard one ·6· person, you know, back then say anything bad about ·7· it. ·8· · · ·Q.· ·But you realize that the school shifted ·9· models.· It shifted models from an Internet learning 10· model to a live events model.· Do you understand 11· that? 12· · · ·A.· ·Right, sure. 13· · · ·Q.· ·And do you understand that there's a 14· complete disparity between the instructors for the 15· Internet model versus the new wave of instructors for 16· the live events? 17· · · · · · MR. PETROCELLI:· The question is vague. 18· · · · · · THE WITNESS:· Well, to me it's one school, 19· though.· I understand what you're saying.· And I 20· heard great things about the Internet.· And to me 21· it's one school, Jason. 22· · · · · · You know, I mean, it was just overall, it 23· was a positive experience, I felt.· And I didn't feel 24· they needed a lot of more guidance, other than I 25· would tell them, you know, like this ad, talking Page 430 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 92 of 129 Volume II Donald Trump Confidential Art Cohen, et al. vs. Donald J. Trump ·1· happy with something.· Another way is that they'll ·2· see you.· They'll say -·3· · · ·Q.· ·That's certainly -·4· · · ·A.· ·People will see you.· They say, Mr. Trump, ·5· I live in your building here, and it's not good.· The ·6· superintendent is not good, and it's not clean.· And ·7· I'll go and check and I'll make sure. ·8· · · · · · With this, I had so many positive reports, ·9· especially when the people leave the course, they 10· were writing these beautiful reports. 11· · · ·Q.· ·But you understand though, generally 12· speaking, one way of expressing dissatisfaction, say 13· with the stay at a hotel, is to request a refund? 14· · · ·A.· ·Yeah. 15· · · ·Q.· ·Okay.· And -16· · · ·A.· ·And by the way, we did give refunds. 17· · · ·Q.· ·Well, do you know what the percentage was 18· of the refunds -19· · · ·A.· ·No, I didn't.· I know we gave a lot of 20· refunds, yeah. 21· · · ·Q.· ·But did you know -- hold on, Mr. Trump. 22· Did you know it was over 25 percent? 23· · · ·A.· ·I didn't know what the percentage, but I 24· know we gave them. 25· · · · · · By the way, most people wouldn't give them. 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Trump ·1· There was no reason to give them.· We could have let ·2· you sue for the rest of our lives. ·3· · · ·Q.· ·But when you say you're not familiar with ·4· any sort of expressions of dissatisfaction, you ·5· weren't aware that over 25 percent of the people who ·6· paid for live -·7· · · ·A.· ·I heard -·8· · · ·Q.· ·-- received refunds? ·9· · · ·A.· ·I heard people received refunds.· But I 10· think that's instinctual.· If people think they can 11· get a refund, they're going to ask. 12· · · · · · And I probably foolishly gave it to them. 13· I shouldn't have given it to them because, frankly, 14· they could have been tied up all in this litigation 15· and, you know, whatever happens happens. 16· · · · · · I viewed that as a lot of times that 17· happens.· You go to the Home Shopping Network, 18· whatever it's called.· The refunds are unbelievable. 19· The people use the product, wear the product, and 20· then they send it back. 21· · · · · · The refunds are massive.· That's their 22· biggest problem is the refunds. 23· · · · · · So you know, when people were asking for 24· their money back, frankly -- and I would have these 25· good reports, but people would ask for their money Page 433 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 94 of 129 Volume II Donald Trump Confidential Art Cohen, et al. vs. Donald J. Trump ·1· back.· We gave them their money back. ·2· · · · · · I shouldn't have given their money back. I ·3· gave back millions of dollars because I'm an honest ·4· guy.· I should have said I'm not giving it back, and ·5· you would have it in your litigation. ·6· · · ·Q.· ·We're here in one of your hotels right now, ·7· right? ·8· · · ·A.· ·Right. ·9· · · ·Q.· ·Would you be satisfied with the performance 10· of this hotel if it had a refund rate of 25 percent? 11· · · ·A.· ·But it's different, though.· It's 12· different. 13· · · ·Q.· ·Would you be satisfied? 14· · · ·A.· ·With Home Shopping Network, if you look, 15· their refunds are tremendous.· They're tremendous. 16· They buy a dress, and you're allowed to give it back. 17· I don't know what they call it.· They send it back. 18· They just send it back.· They give their money back. 19· I don't know if they use the dress, if they don't use 20· the dress.· Probably they do, but it's different. 21· · · · · · And with this one, they take the course, 22· and they'll ask for a refund.· But why do so many 23· people, why have so many people, including your 24· client on this case, signed these letters that were 25· so beautiful about the course? Page 434 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 95 of 129 Volume II Donald Trump Confidential Art Cohen, et al. vs. Donald J. Trump ·1· · · · · · I mean, I think, I'm not sure, but I ·2· haven't read it in a long time, but I think your ·3· client on this case, and certainly your client on the ·4· other cases, signed these incredible letters about ·5· how good the course was. ·6· · · ·Q.· ·And, Mr. Trump, you're an interesting guy. ·7· I could talk to you all day long.· But I have to ask ·8· you specific questions I need to get answers for. ·9· · · · · · So what I'm asking you now is would you be 10· satisfied if the refund rate at your hotel was 11· 25 percent? 12· · · · · · MR. PETROCELLI:· The question is vague, and 13· lacks foundation. 14· · · · · · THE WITNESS:· It doesn't happen.· It 15· doesn't happen.· It's a different business.· It 16· doesn't happen.· With hotels it doesn't happen. 17· BY MR. FORGE: 18· · · ·Q.· ·So you would find that to be unacceptable? 19· · · ·A.· ·No.· People wouldn't come back to the 20· hotel.· They wouldn't ask for a refund because they 21· wouldn't get it.· You wouldn't give a refund on a 22· hotel.· But they won't come back.· And your number 23· would go way up.· Your vacancy number.· Your 24· unoccupied -25· · · ·Q.· ·Would you consider it acceptable if the Page 435 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 96 of 129 Volume II Donald Trump Confidential Art Cohen, et al. vs. Donald J. Trump ·1· rate of requesting refunds was 25 percent of ·2· people who were staying in the hotel? ·3· · · ·A.· ·Wouldn't happen.· They don't come back.· In ·4· the hotel business, they don't come back. ·5· · · ·Q.· ·But would you be satisfied if that ·6· happened? ·7· · · ·A.· ·The Home Shopping Network they give ·8· refunds. ·9· · · · · · No, because -- yeah, I would be unhappy if 10· they didn't come back, and my vacancy factor would go 11· up, up, up, up, and then all of a sudden the hotel 12· would do very badly. 13· · · ·Q.· ·And you would have to change something to 14· satisfy them? 15· · · ·A.· ·Yeah, well, it's a different thing.· It's a 16· different business. 17· · · ·Q.· ·But the bottom line is if you found out one 18· of your hotels had a rate of refunds being requested 19· at 25 percent, you would not consider that to be 20· acceptable? 21· · · ·A.· ·I told you, they don't do that with the 22· hotel business.· They don't ask for refunds.· They 23· don't come back. 24· · · ·Q.· ·But what I'm asking you, though, is if that 25· happened -Page 436 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 97 of 129 Volume II Donald Trump Confidential Art Cohen, et al. vs. Donald J. Trump ·1· · · ·A.· ·You can't go after it.· It's not in that ·2· business.· It's a different business.· Home Shopping ·3· Network has tremendous percentages of refunds, and ·4· yet it's a very successful enterprise. ·5· · · ·Q.· ·How about Wharton, do you think that the ·6· folks -- where you attended, do you think the folks ·7· at Wharton would be happy, would be satisfied if the ·8· students requested refunds at a 25 percent rate? ·9· · · ·A.· ·Well, again, it's a much different kind of 10· a thing.· It's a school where you go and you go. 11· · · · · · I mean, we had a lot of -- a lot of people 12· started complaining after they heard about the 13· lawsuit because they figured they can get their money 14· back.· That's a natural business instinct. 15· · · ·Q.· ·So Wharton and the hotel is over here, and 16· the Home Shopping Network -17· · · ·A.· ·I think it's more Home Shopping Network. 18· It's a short-term situation.· You're not staying at 19· the school and living there and everything else. 20· · · · · · · · ·(Exhibit 516 was marked for 21· · · · · · · · ·identification.) 22· BY MR. FORGE: 23· · · ·Q.· ·Mr. Trump, I'm handing you an exhibit 24· that's been marked as Exhibit 516.· It's an index of 25· materials from Trump University's live events.· And Page 437 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 98 of 129 Volume II Donald Trump Confidential Art Cohen, et al. vs. Donald J. Trump ·1· · · · · · And you said earlier, you could have ·2· settled this case very early on. ·3· · · · · · Did you express that sentiment -·4· · · ·A.· ·Yes. ·5· · · ·Q.· ·-- to Mr. Brill, the plaintiff's lawyer? ·6· · · ·A.· ·Yes. ·7· · · ·Q.· ·And what is that basis -·8· · · ·A.· ·I said that's based on what Mr. Garten told ·9· me. 10· · · · · · MR. PETROCELLI:· Well, we can't get into 11· what -12· BY MR. FORGE: 13· · · ·Q.· ·It's based on conversations with 14· Alan Garten? 15· · · ·A.· ·With a lawyer, yes. 16· · · ·Q.· ·And you don't know the basis of -17· · · ·A.· ·No.· It's what I was told. 18· · · ·Q.· ·Mr. Trump, are you aware that one of the 19· benefits that students were promised at Trump 20· University was networking opportunities? 21· · · · · · MR. PETROCELLI:· Assumes facts. 22· · · · · · THE WITNESS:· I would say that that would 23· be a natural benefit, yeah. 24· BY MR. FORGE: 25· · · ·Q.· ·Are you aware that one of the promises that Page 452 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 99 of 129 Volume II Donald Trump Confidential Art Cohen, et al. vs. Donald J. Trump ·1· was made to students that the Trump University ·2· mentors would be their mentors for life? ·3· · · ·A.· ·I wasn't aware of that.· But it depends on ·4· the mentor.· Some of the mentors may have become ·5· friendly with them.· I mean, you never know. ·6· · · · · · But, no, I wasn't aware of it. ·7· · · ·Q.· ·Are you aware that the surveys were not ·8· anonymous? ·9· · · ·A.· ·What does that mean? 10· · · · · · MR. PETROCELLI:· Assumes facts. 11· BY THE WITNESS: 12· · · ·Q.· ·The surveys that Trump University took, 13· they were not anonymous?· They had students actually 14· put their names on them? 15· · · ·A.· ·Oh, yeah.· Well, that's much better, I 16· think. 17· · · ·Q.· ·So in other words, if the students said 18· something critical about an instructor or about 19· someone who is supposed to be their mentor for life, 20· that person would see the critical comment?· You're 21· aware of that? 22· · · ·A.· ·Oh, I think the other way, they don't mean 23· anything, actually.· I think it's much better when a 24· student puts their name on it. 25· · · · · · You mean they don't want to hurt anybody's Page 453 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 100 of 129 Volume II Donald Trump Confidential Art Cohen, et al. vs. Donald J. Trump ·1· feelings, is what you're saying? ·2· · · ·Q.· ·Well, Trump University, one of the selling ·3· points was networking, and another one was having a ·4· mentor for life. ·5· · · · · · And so if the mentor for life was someone ·6· you had just got done criticizing -·7· · · ·A.· ·Only a lawyer could think of that. ·8· · · ·Q.· ·So you don't think that anticipating -·9· · · ·A.· ·I think the surveys are much more important 10· with a signature.· I think it's -- it's more 11· meaningful. 12· · · ·Q.· ·You don't think the anticipation of 13· possibly needing help from these folks in the future 14· would influence the students to -15· · · ·A.· ·You mean that's why they said such great 16· things about the school? 17· · · ·Q.· ·Yeah. 18· · · ·A.· ·I don't think so.· I think they really 19· meant it was very good.· Until they found out they 20· could get their money back.· And then they said, 21· Oh, wow, you got money back?· Let's get our money 22· back. 23· · · ·Q.· ·Do you think Bill Clinton was a great 24· president? 25· · · ·A.· ·He had moments.· He had some moments.· But Page 454 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 101 of 129 Volume II Donald Trump Confidential Art Cohen, et al. vs. Donald J. Trump ·1· overall, he was hurt very badly by Monica Lewinsky ·2· and all of the scandal.· I think it hurt his ·3· presidency very much. ·4· · · ·Q.· ·But do you think he was a great president? ·5· · · ·A.· ·Well, I think it's inappropriate for here, ·6· because we're not talking about politics now.· We're ·7· talking about something else. ·8· · · · · · So I don't think that's a question that ·9· pertains to this.· But I would say that he was hurt 10· by the scandal. 11· · · ·Q.· ·But do you think he was a great president? 12· · · · · · MR. PETROCELLI:· Just for the record, I 13· would object to this line of questioning as 14· completely irrelevant, and the kind of examination 15· that should be subject to a protective order. 16· · · · · · I would let it continue.· The Magistrate 17· has indicated to me that only instructions based on 18· privilege can be made, a ruling with which I 19· disagree, but will abide by at the moment. 20· · · · · · So you can continue your examination, but 21· it's subject to my continuing objection. 22· · · · · · MR. FORGE:· Thank you. 23· BY MR. FORGE: 24· · · ·Q.· ·Do you believe Bill Clinton was a great 25· president? Page 455 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 102 of 129 Volume II Donald Trump Confidential Art Cohen, et al. vs. Donald J. Trump ·1· · · ·A.· ·I think he was hurt very badly by the ·2· scandals, his escapades.· I think it hurt him very ·3· badly.· I think that, you know, I have no feeling one ·4· way or the other, but I think he was hurt very badly ·5· by the scandals. ·6· · · ·Q.· ·So aside from the scandals, do you think he ·7· was a great president? ·8· · · ·A.· ·I can't say aside.· It's part of his ·9· legacy.· I mean, the scandals were devastating.· He 10· was impeached.· He was impeached.· He was brought 11· before Congress.· I mean, he was impeached.· And that 12· was -- very few people -- very few presidents that 13· were impeached.· So that hurt him very much. 14· · · · · · The scandals were a big part of his legacy, 15· unfortunately, for him. 16· · · · · · · · ·(Exhibit 519 was marked for 17· · · · · · · · ·identification.) 18· · · · · · THE VIDEOGRAPHER:· We are off the video 19· record.· The time is 9:58 a.m. 20· · · · · · · · ·(A recess was taken from 9:58 a.m. 21· · · · · · · · ·to 10:13 a.m.) 22· · · · · · THE VIDEOGRAPHER:· We are back on the video 23· record, and the time is 10:13 a.m. 24· BY MR. FORGE: 25· · · ·Q.· ·Welcome back, Mr. Trump. Page 456 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 103 of 129 Volume II Donald Trump Confidential Art Cohen, et al. vs. Donald J. Trump ·1· · · ·A.· ·Thank you. ·2· · · ·Q.· ·Mr. Trump, you have Exhibit 519 in front of ·3· you.· Does it appear to be a true and correct copy of ·4· a Trump blog -·5· · · ·A.· ·Yes. ·6· · · ·Q.· ·-- that you posted on December 2nd, 2008? ·7· · · ·A.· ·Seems to be.· It's a long time ago. ·8· · · · · · Shall I read it?· Shall I read the whole ·9· thing? 10· · · ·Q.· ·I'm going to direct your attention to the 11· fourth paragraph, but you're welcome to read whatever 12· you want. 13· · · · · · The fourth paragraph you wrote of Hillary 14· Clinton:· "Hillary is smart, tough and a very nice 15· person and so is her husband." 16· · · · · · And then you wrote, "Bill Clinton was a 17· great president." 18· · · · · · Did you believe that sentiment when you 19· wrote it in this blog? 20· · · ·A.· ·When was this done? 21· · · ·Q.· ·December 2nd, 2008. 22· · · ·A.· ·It was a long time ago.· I mean, at the 23· time -- I mean, I was fine with it at the time. I 24· think in retrospect, looking back, it was not a great 25· presidency because of his scandals.· That was 2008. Page 457 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 104 of 129 Volume II Donald Trump Confidential Art Cohen, et al. vs. Donald J. Trump ·1· I say that's a long time ago. ·2· · · ·Q.· ·So you posted it, but you believed it then, ·3· but you don't believe it now?· Or you didn't believe ·4· it then and you still don't believe it? ·5· · · ·A.· ·I might have said it.· I don't think it was ·6· a very important statement made then.· I wasn't in ·7· politics.· It didn't matter to me. ·8· · · · · · If I was to think about it with all that he ·9· went through, I would probably not call him a great 10· president anymore because of all of the scandal and 11· the turmoil that he had.· It was a very tumultuous 12· period of time, and then he was impeached. 13· · · · · · I mean, I would probably say that it's not 14· something I gave very much thought to then because I 15· wasn't in politics.· But if you were asking me the 16· question now, too much turmoil. 17· · · ·Q.· ·But all that turmoil and the impeachment 18· and the scandal, that all predated your posting of 19· this blog, though?· But you're saying you just didn't 20· think about it that much? 21· · · ·A.· ·It's something I wouldn't have thought 22· about.· I've been thinking about a lot of things over 23· the last couple of years when I was deciding to do 24· this. 25· · · ·Q.· ·How about Hillary Clinton, do you think she Page 458 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 105 of 129 Volume II Donald Trump Confidential Art Cohen, et al. vs. Donald J. Trump ·1· would make a great vice president? ·2· · · · · · MR. PETROCELLI:· Is there a reference to ·3· that in here, Jason? ·4· · · · · · MR. FORGE:· I'm just -- you can put that ·5· aside.· It doesn't matter. ·6· · · · · · MR. PETROCELLI:· Again, I have my ·7· continuing objection to this line of questioning. ·8· · · · · · And you're required to answer at this ·9· juncture. 10· BY MR. FORGE: 11· · · ·Q.· ·Do you believe that Hillary Clinton would 12· make a great vice president, Mr. Trump? 13· · · ·A.· ·No. 14· · · ·Q.· ·Did you believe she would make a great vice 15· president back in 2008? 16· · · ·A.· ·I don't know.· Did I say that here? 17· · · ·Q.· ·Not in here, no.· I'm just asking you, did 18· you believe that back in 2008? 19· · · ·A.· ·No, I didn't think I said that. 20· · · · · · No, I don't think she would be a good vice 21· president. 22· · · ·Q.· ·Do you believe she would make a great 23· president? 24· · · ·A.· ·Did I say that in here? 25· · · ·Q.· ·No, not in here. Page 459 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 106 of 129 Volume II Donald Trump Confidential Art Cohen, et al. vs. Donald J. Trump ·1· · · · · · MR. PETROCELLI:· "In here," we're talking ·2· about Exhibit 519? ·3· · · · · · MR. FORGE:· Correct. ·4· · · · · · THE WITNESS:· Do I think she would make a ·5· great president? ·6· BY MR. FORGE: ·7· · · ·Q.· ·Yes. ·8· · · ·A.· ·No.· No, I don't. ·9· · · ·Q.· ·Back in the year 2008, did you think she 10· would be a great president? 11· · · ·A.· ·I don't think I said anything.· I don't say 12· it here. 13· · · · · · Let's see, if we go back many, many years 14· ago, do I think she would have?· Probably not. I 15· don't think she's got the gravitas. 16· · · · · · MR. PETROCELLI:· Jason, I'm marking this 17· transcript confidential again.· We're going to have 18· to, I guess -19· · · · · · THE WITNESS:· I don't want those answers 20· to -21· · · · · · MR. PETROCELLI:· I guess we're going to 22· have to work out a designation process. 23· · · · · · MR. FORGE:· We actually have a designation 24· process, and I don't think that fits within it, 25· but -Page 460 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 107 of 129 Volume II Donald Trump Confidential Art Cohen, et al. vs. Donald J. Trump ·1· · · · · · MR. PETROCELLI:· But you know what, I'll -·2· · · · · · MR. FORGE:· We can discuss that later. ·3· · · · · · MR. PETROCELLI:· Correct. ·4· · · · · · MR. FORGE:· For the time being, you are ·5· designating this as confidential, and we will treat ·6· it accordingly. ·7· · · · · · MR. PETROCELLI:· Whatever the court order ·8· requires, we will comply with it in terms of the ·9· designation process. 10· · · · · · MR. FORGE:· Let's mark this as Exhibit 520, 11· please. 12· · · · · · · · ·(Exhibit 520 was marked for 13· · · · · · · · ·identification.) 14· · · · · · MR. PETROCELLI:· I did note that maybe one 15· or two of the exhibits were marked "confidential for 16· counsel only" also. 17· · · · · · MR. FORGE:· Most of them have been 18· de-designated, although the financial ones probably 19· were not.· That was the only one that -20· · · · · · MR. PETROCELLI:· Those were the ones that 21· were -22· · · · · · MR. FORGE:· Yeah. 23· BY MR. FORGE: 24· · · ·Q.· ·Mr. Trump, does Exhibit 520 appear to be a 25· true and accurate copy of a Trump blog that you Page 461 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 108 of 129 Volume II Donald Trump Confidential Art Cohen, et al. vs. Donald J. Trump ·1· posted on March 13th, 2008? ·2· · · ·A.· ·Yes. ·3· · · ·Q.· ·Now, if you look at the end of the second ·4· paragraph, you wrote, "I know Hillary, and I think ·5· she would make a great president or vice president." ·6· · · · · · You do know Hillary Clinton, correct? ·7· · · ·A.· ·Yes. ·8· · · ·Q.· ·And you knew her back in 2008? ·9· · · ·A.· ·Yeah.· Pretty much. 10· · · ·Q.· ·So did you believe this sentiment when you 11· expressed it in March of 2008? 12· · · ·A.· ·Well, I didn't think too much about it. 13· · · · · · Where are you asking me to read? 14· · · ·Q.· ·If you look at the end of the second 15· paragraph, there's a parenthetical at the end of it. 16· And it says, "I know Hillary, and I think she would 17· make a great president or vice president." 18· · · ·A.· ·Yeah, at the time I might have.· I didn't 19· give it a lot of thought, because I was in business. 20· And as a businessman, I think it was something I 21· never really gave much thought to. 22· · · · · · Now that I see what she's done and how 23· she's handled herself and how she's handled her 24· e-mails and all of the problems that she's got, I 25· would say she wouldn't make a very good vice Page 462 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 109 of 129 Volume II Donald Trump Confidential Art Cohen, et al. vs. Donald J. Trump ·1· president or president. ·2· · · ·Q.· ·So but back then you thought she would? ·3· · · ·A.· ·Well, back then -- how long ago was that? ·4· How many years ago? ·5· · · ·Q.· ·That's March of '08. ·6· · · ·A.· ·That was a long time ago. ·7· · · ·Q.· ·Almost eight years ago. ·8· · · ·A.· ·It's something I didn't give much thought ·9· to. 10· · · ·Q.· ·But you did express it in this blog 11· posting? 12· · · ·A.· ·It's just something I wouldn't have thought 13· about.· I mean, I expressed it.· But where is it? 14· · · ·Q.· ·The last sentence of the first paragraph -15· or second paragraph. 16· · · ·A.· ·After -- when I looked at the history of 17· the Clintons, I think that they've really let the 18· country down. 19· · · ·Q.· ·So you think they've let the country down 20· since March of 2008? 21· · · ·A.· ·Well, since I've really started to watch 22· and study politics as opposed to just thinking about 23· business and not thinking about politics. 24· · · ·Q.· ·Now, you've said of Jeb Bush previously 25· that he is exactly the kind of political leader this Page 463 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 110 of 129 Volume II Donald Trump Confidential Art Cohen, et al. vs. Donald J. Trump ·1· country needs now, and we very much need in the ·2· future.· He's bright, tough and principled. ·3· · · · · · Was that an honest sentiment when you ·4· expressed that about Jeb Bush? ·5· · · ·A.· ·No, I didn't know him very well when I said ·6· that.· I mean, I hardly knew him at all.· Now I know ·7· him well, and I think he would be a disaster as ·8· president, frankly. ·9· · · ·Q.· ·So did you not believe it when you said it 10· before?· Or you just simply didn't have a basis and 11· you -12· · · ·A.· ·I didn't have much of a basis.· But I said 13· it to be nice, and it didn't matter, but I said it to 14· be nice and to be respectful.· But I didn't really 15· know him. 16· · · · · · Now that I've gotten to know him, I think 17· he would be not very good at all. 18· · · ·Q.· ·Of George Pataki, you said he was the most 19· underrated guy in American politics. 20· · · · · · Is that a sentiment that you said to be 21· nice, but not because you necessarily believed that? 22· · · ·A.· ·He had a period of time when he was doing a 23· good job, but I think he ended badly.· And then when 24· I got to know him -- because I didn't know him very 25· well -- when I got to know him, I'm not a fan. Page 464 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 111 of 129 Volume II Donald Trump Confidential Art Cohen, et al. vs. Donald J. Trump ·1· · · ·Q.· ·So when you said he was the most underrated ·2· guy in American politics, did you believe it ·3· sincerely or was that -·4· · · ·A.· ·No, I think I would have believed it at the ·5· time.· But I'm not a fan, you know, as I got to know ·6· him.· I didn't know him very well.· But as I got to ·7· know him and I got to see him when I became political ·8· and involved politically, as opposed to not knowing ·9· people in business, I would say that no, he's not -10· I don't think he would be very good. 11· · · ·Q.· ·So you didn't have a basis for what you 12· said, but once you educated yourself more -13· · · ·A.· ·But now I've gotten to know people a lot 14· better.· I've gotten to know the political system a 15· lot better.· I've gotten to know the ins and outs of 16· politics, and I've gotten to know the history of 17· politics a lot better.· And I think he would not 18· have -- I do not think he was very good. 19· · · ·Q.· ·Rick Perry, you've said that he was a very 20· effective governor? 21· · · ·A.· ·Where is that? 22· · · ·Q.· ·Where did you say that about Rick Perry? 23· · · ·A.· ·Where is it again?· Can you find it? 24· · · ·Q.· ·Yeah.· Hold on a second. 25· · · ·A.· ·Well, I thought he was a nice guy. I Page 465 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 112 of 129 Volume II Donald Trump Confidential Art Cohen, et al. vs. Donald J. Trump ·1· thought Rick Perry was a very nice guy.· But, you ·2· know, obviously he didn't do too well when he ran for ·3· president.· And you get to know people better under ·4· pressure.· Under pressure they're not so good. ·5· · · ·Q.· ·So you formed a different opinion of him ·6· later? ·7· · · ·A.· ·Yeah, as I got to know him. ·8· · · · · · MR. PETROCELLI:· Also for the record, ·9· Jason, the reference to Jeb Bush, who -- there was 10· apparently a document, but not shown to the witness, 11· I don't know where you were reading from.· But just I 12· want the record to be clear there was nothing in 13· front of him on that. 14· · · · · · MR. FORGE:· I just need to find the 15· exhibit number. 16· · · · · · THE WITNESS:· It's okay.· It doesn't 17· matter.· Who cares? 18· BY MR. FORGE: 19· · · ·Q.· ·Mr. Trump, I have the transcript and the 20· video of this appearance on this.· Let's start with 21· the transcript.· And if you want to actually see it 22· and hear it -23· · · ·A.· ·Of what? 24· · · ·Q.· ·Of your appearance on This Week. 25· · · ·A.· ·When? Page 466 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 113 of 129 Volume II Donald Trump Confidential Art Cohen, et al. vs. Donald J. Trump ·1· · · ·Q.· ·With John Carl, from I guess December 5th. ·2· · · ·A.· ·Of last year? ·3· · · ·Q.· ·Yeah. ·4· · · ·A.· ·Okay, I can see the transcript. ·5· · · ·Q.· ·Hold on one second.· Sorry, I apologize. ·6· These pages are not Bates numbered.· I want to get to ·7· the right point.· But you're welcome to look through ·8· whatever you want. ·9· · · · · · Okay.· This was previously marked as 10· Exhibit 489 to your deposition.· Again, if you want 11· to look at any other portion, Mr. Trump, that is 12· absolutely your right and entitlement. 13· · · · · · · · ·(Exhibit 489 was identified.) 14· BY MR. FORGE: 15· · · ·Q.· ·I have opened this up to the fifth page, 16· and it's near the bottom of the page, where it 17· begins, you said of Jeb Bush, and there's a quote. 18· · · ·A.· ·When is this?· How long ago is this? 19· · · ·Q.· ·This is a month and a half ago. 20· · · · · · And if you go to the next page for your 21· response. 22· · · ·A.· ·This is him asking me the question? 23· · · ·Q.· ·Yeah, him asking you the question about 24· your past praise for -25· · · ·A.· ·It's already been out there. Page 467 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 114 of 129 Volume II Donald Trump Confidential Art Cohen, et al. vs. Donald J. Trump ·1· · · · · · MR. PETROCELLI:· What page are you on? ·2· · · · · · MR. FORGE:· The fifth page, now to the ·3· sixth. ·4· · · · · · MR. PETROCELLI:· Okay.· After he talks ·5· about the America We Deserve, the book? ·6· · · · · · MR. FORGE:· Yeah. ·7· BY MR. FORGE: ·8· · · ·Q.· ·Your response, Mr. Trump, was it's -- your ·9· response to the questions about your praise for these 10· folks that you no longer have praise for is, "It's a 11· very simple answer to that.· I was a businessman all 12· my life.· I've made a tremendous fortune.· I had to 13· deal with politicians and I would contribute to them 14· and I would deal with them and certainly I'm not 15· going to say bad things about people because I needed 16· their support to get projects done.· I needed their 17· support for lots of things, or I may have needed 18· their support, put it another way.· I mean, you're 19· not going to say horrible things and then go in a 20· year later and say, Listen, can I have your support 21· for this project or this development or this 22· business?· So I say nice about almost everybody, and 23· I contributed to people because I was a smart 24· businessman.· I built a tremendous company, and I did 25· that based on relationships." 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Trump ·1· · · · · · Was your response there that I just read ·2· honest?· Was it true? ·3· · · ·A.· ·That's true.· And you view people ·4· differently.· When you're in business you view ·5· people -- you don't think about it.· Whereas when ·6· you're in politics, you think about the qualities of ·7· a person, and the -- you really think much deeper ·8· about a politician. ·9· · · · · · I could -- like a Jeb Bush as a governor of 10· Florida and say, you know, because I don't think 11· about it. 12· · · ·Q.· ·So one of the reasons why you said these 13· nice things about people like Jeb Bush and Hillary 14· Clinton was because you didn't think about it that 15· much, and because you might need their help for 16· something in the future? 17· · · ·A.· ·You want to always be friendly with 18· politicians.· If you're a businessman, I'm a 19· businessman, you always -- you want to be as nice as 20· you can to politicians whenever possible. 21· · · ·Q.· ·Because you might need their assistance? 22· · · ·A.· ·Well, you don't want to have them go 23· against you.· You want to have -- I don't think about 24· Jeb Bush one way or the other, frankly.· But when I 25· was in business, I had no problems with Jeb Bush. 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Trump ·1· · · · · · So if somebody would ask me, I would ·2· think -- now, when you're in politics, and you get to ·3· know them better, because you get to know these ·4· people better, and you see what you're dealing with, ·5· you can answer a question I think a lot more ·6· accurately. ·7· · · ·Q.· ·So you didn't want these people against ·8· you? ·9· · · ·A.· ·No, you don't want them against you. 10· · · ·Q.· ·And you would rather have them on your 11· side? 12· · · ·A.· ·You would rather have them on your side, 13· politicians.· When you're in business, you would like 14· to have the politicians on your side. 15· · · ·Q.· ·And so you say nice things about them? 16· · · ·A.· ·You don't want to say bad about them, 17· ideally you don't want to say badly. 18· · · · · · And you don't think about it as deeply 19· either.· I mean, when you asked me about different 20· people, they're nice, they're very good, they could 21· be very good. 22· · · · · · When you start thinking about people in a 23· much deeper fashion, when it's updated and you've 24· seen what they've done, you've seen where they've 25· been, you can answer it I think much different Page 470 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 117 of 129 Volume II Donald Trump Confidential Art Cohen, et al. vs. Donald J. Trump ·1· politically than you would as a businessman.· As a ·2· businessman, you're not thinking that much about it. ·3· You want them to like you, and that's pretty ·4· important for business. ·5· · · ·Q.· ·Mr. Trump, when we spoke last month, you ·6· mentioned that within your Trump organization, you ·7· generally delegate to other people the task of ·8· selecting and hiring people; is that true? ·9· · · ·A.· ·Yeah.· Largely. 10· · · ·Q.· ·And you said that you didn't personally 11· select most of the people that work within Trump 12· organization; is that true? 13· · · ·A.· ·Generally speaking, yes. 14· · · ·Q.· ·Can you think of anyone that you did 15· personally select to work for you? 16· · · ·A.· ·Yeah.· Mr. Garten, lawyer. 17· · · ·Q.· ·He's your general counsel? 18· · · ·A.· ·Yeah.· Lawrence Glick. 19· · · ·Q.· ·What's his -20· · · ·A.· ·He's an attorney. 21· · · · · · Allen Weisselberg. 22· · · ·Q.· ·He's your CFO? 23· · · ·A.· ·Right.· Jason Greenblatt, an attorney. 24· · · · · · Matthew Calamary, a security person; 25· security people.· And others. Page 471 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 118 of 129 Volume II Donald Trump Confidential Art Cohen, et al. vs. Donald J. Trump ·1· thing that they see and then they found out that they ·2· made a mistake. ·3· · · · · · So see as many -- even if it's 25 or ·4· 30 things, see as many as you can. ·5· · · ·Q.· ·Before you buy? ·6· · · ·A.· ·Before you buy, yeah. ·7· · · ·Q.· ·Don't rush in? ·8· · · ·A.· ·Don't rush.· I mean, rush if you think ·9· you're making a great deal on something, but it would 10· be good if you knew some comparables. 11· · · ·Q.· ·So do your homework? 12· · · ·A.· ·Do your homework. 13· · · · · · · · ·(Exhibit 521 was marked for 14· · · · · · · · ·identification.) 15· BY MR. FORGE: 16· · · ·Q.· ·Mr. Trump, does Exhibit 521 appear to be a 17· true and correct -18· · · ·A.· ·Yes. 19· · · ·Q.· ·-- copy of a collection of ads for Trump 20· University? 21· · · ·A.· ·Looks like it. 22· · · ·Q.· ·We can go through as many as you want or as 23· few as you want. 24· · · ·A.· ·I take your word. 25· · · ·Q.· ·Okay.· I'm just going to represent to you Page 476 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 119 of 129 Volume II Donald Trump Confidential Art Cohen, et al. vs. Donald J. Trump ·1· that these are ads for 2009 seminars, live events. ·2· · · · · · You do not know who the instructors were ·3· for these individual events, correct? ·4· · · ·A.· ·I may know the names, but I don't know the ·5· individual instructors. ·6· · · ·Q.· ·You didn't personally select these ·7· instructors, correct? ·8· · · ·A.· ·No. ·9· · · ·Q.· ·That's correct? 10· · · ·A.· ·That is correct. 11· · · ·Q.· ·And you don't personally know what they 12· told the students at these events, correct? 13· · · ·A.· ·I think we have concepts and ideas, but no, 14· I don't.· Every instructor has a different method of 15· teaching. 16· · · ·Q.· ·And you don't know what they told the 17· students before these events? 18· · · ·A.· ·No. 19· · · ·Q.· ·Now, you could have called them in and 20· said, Okay, present to me what you're going to 21· present to the students? 22· · · ·A.· ·Well, but that's what I had Michael Sexton 23· and the people -- that's what you have management 24· for. 25· · · ·Q.· ·So you use other people to do that? Page 477 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 120 of 129 Volume II Donald Trump Confidential Art Cohen, et al. vs. Donald J. Trump ·1· · · ·A.· ·I do. ·2· · · ·Q.· ·You did not do that yourself? ·3· · · ·A.· ·I did not. ·4· · · ·Q.· ·But you could have? ·5· · · · · · MR. PETROCELLI:· The question is vague and ·6· ambiguous.· Lack of foundation. ·7· · · · · · THE WITNESS:· Well, I could have; I guess ·8· I could have.· But I think, you know, I have ·9· management.· And again, I was getting good marks on 10· what we saw. 11· · · · · · So, you know, I guess I could have.· But 12· the management seemed to me to be doing a very good 13· job. 14· · · · · · MR. FORGE:· Let's take a quick break. 15· · · · · · THE VIDEOGRAPHER:· We are off the video 16· record at 10:38 a.m. 17· · · · · · · · ·(A recess was taken from 10:38 a.m. 18· · · · · · · · ·to 10:50 a.m.) 19· · · · · · THE VIDEOGRAPHER:· We are back on the video 20· record.· The time is 10:50 a.m. 21· BY MR. FORGE: 22· · · ·Q.· ·Mr. Trump, at any time during the period 23· that Trump University was offering classes, did you 24· ever ask anyone to provide you with information as to 25· what percentage of students were requesting refunds? Page 478 www.aptusCR.com YVer1f Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 121 of 129 Volume II Donald Trump Confidential Art Cohen, et al. vs. Donald J. Trump ·1· · · ·A.· ·Not as to a percentage.· I knew they were ·2· requesting refunds, and I told my accounting people ·3· if they wanted the refunds, and it was in the period ·4· of time for the refunds, to give it to them. ·5· · · · · · And I paid millions.· I don't know exactly ·6· what the numbers -- you would know.· But I paid ·7· millions and millions of dollars in refunds.· I mean, ·8· frankly, if I would have known that I was going to be ·9· in litigation, probably I wouldn't have done it, 10· although it was the honorable thing to do. 11· · · ·Q.· ·And you knew that in realtime you were 12· paying millions of dollars in refunds? 13· · · ·A.· ·I was paying a lot in refunds.· Yeah, I 14· knew that.· And I also understand why.· I mean, you 15· do it because people want to get their money back. 16· It's one of those things. 17· · · ·Q.· ·Like you said, it's the honorable thing to 18· do? 19· · · ·A.· ·I did the honorable thing. 20· · · · · · · · ·(Exhibit 522 was marked for 21· · · · · · · · ·identification.) 22· BY MR. FORGE: 23· · · ·Q.· ·Mr. Trump, I will represent to you that 24· Exhibit 522 is a printout of an e-mail chain that 25· your representatives provided to us in discovery. Page 479 www.aptusCR.com YVer1f Case Document 462-2 Filed 03/03/16 Page 122 of 129 EXHIBIT 3 Case Document 462-2 Filed 03/03/16 Page 123 of 129 NUETHCAL MEDFA. LLB TRUMP SectinnJFageiEone: ?iT?I?tt?lm? hi EL: mm wt at 212mm nm? ail-EEO THE TIME INVEST lit! TE ?escripiinn: Enter Type: Mamie Exprm?ms 101'9832099 Publication Date This E-Sh-aa?R} is pmuidads as widens that the ad appeared In the pubtlcah?on noted an the date and page Indicated. ?rnu may n?t create derivalhra Wallis, at in any way epril: na- repurpuse any mutant, The time to invest in Texas real estate is Learn tram Dnnalct Trump's handpicked experts how you can pm?t from the largest real estate iiquiclation in history. Attend our FREE investor warkshup! tint We must celebrated untrepmnaur an earth, He: earned mum in a day than mutt. mart]: cit:- int: He?s .1 lift: Witty mm ithtl wanted nnly durum nlanI?yl-Id now he?s ready in share?with Ameritans like yuu?thc Trump pincess foil in ma estate mark-ct, ?rnmr: tn 'il?ll? FREE alumni: yuu?ll Dannld Trump't a systematic mart-Ian tar in that anyane can we You'll learn lnun?tlnq from the mama nut. ?I?nu'll learn Haw ynur dealt: Hating; mile-t mum-3'5 mnney. 'l'ml'll learn haw in Human: yuIIr foarnl gummy; mer I can turn anyone intu a successiui real estate investor. intiuding ynu. Donald Trump ?lnrl-w's and crectlt I'm: pnimmnn: rind t-a t'Il?Htl'E. lm they?ve glUt bitilnulr: Mid retcue but whn?: you? We?! help ynu how to [Irth l'rnm the dollar that npnm?tl the dam for Lmurecedn-ntcd investment appartunitles. With hunt: pricct. thmugh the ?gor, historicaliy 5W Imam: tatu?, Il?d new?? high may I: the Ml PERI estate Every income and level. But mu need It:- Ihk the ?lnd at prawn tarantula!) ln Donald Trump': Imd ttmleglcs. MONDAY TUESDAY Utl?ber 12th 5 Dctobtt lith ma Pittm?li PM San Antonio 5 Hyatt Regency Matriutt liltrerwaik 5 Hill Country Item and Spa 339 BEDDHyattReson Britta San AntoniuTll San Antnnio? Til Cash in on the Greatest Pmpert'y Liquidatiun in History! Discover how to . . . Buy real estate: Hum bani-:wnnt up to mitt. below mnricn-t value! your deals menivnly ln tnday?? tight credit market! ?uy the prupcrtics nt thr: rlt-Iht time?and know When to sail! t?tf?zment by generatlng passive- lncamel Invest in run! thr'nugh yaui' i?A?mx frnn! ?anks. Fll?ld pru?l?muclmurr?r. in yam area! ?Within six months i put a dam payment m1 my ?rst pmperty which I bought far 51 WIRED. I then rahahhed and ?ippEd the 3g0?ti+ 5quare foul: harm! for a pro?t of mum than gamma.? m- Scott T. Phuenix. Arizona Flctulu. lyman Attendees receive a FREE Secrets 9mm Estate Marketing EDanm-ua 5119 value-m talus a bunus clatter: probate 3U nitra- Sit:ny WEDNESDAY October 14th 1:00 mmutm Hiltan San Antaniu Hotel ?ll Northwest Lump-tin San Anrnnial UNIVERNITY h?lii?f- mlur tlnri mum-y pl: 15mm.? mm?, mt. Mmm? m: Emmi. TRUMP TU 62091 Case Document 462-2 Filed 03/03/16 Page 124 of 129 EXHIBIT 4 Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 125 of 129 1 2 3 4 5 6 ZELDES & HAEGGQUIST, LLP AMBER L. ECK (177882) HELEN I. ZELDES (220051) ALREEN HAEGGQUIST (221858) 625 Broadway, Suite 906 San Diego, CA 92101 Telephone: (619) 342-8000 Facsimile: (619) 342-7878 ambere@zhlaw.com helenz@zhlaw.com alreenh@zhlaw.com aarono@zhlaw.com 7 12 ROBBINS GELLER RUDMAN & DOWD LLP RACHEL L. JENSEN (211456) THOMAS R. MERRICK (177987) 655 West Broadway, Suite 1900 San Diego, CA 92101 Telephone: (619) 231-1058 Facsimile: (619) 231-7423 rjensen@rgrdlaw.com tmerrick@rgrdlaw.com 13 Attorneys for Plaintiffs and the Proposed Class 8 9 ZELDES & HAEGGQUIST, LLP 10 11 14 UNITED STATES DISTRICT COURT 15 SOUTHERN DISTRICT OF CALIFORNIA 16 17 18 19 20 21 22 23 24 25 26 27 28 TARLA MAKAEFF, et al., on Behalf of Themselves and All Others Similarly Situated, Plaintiffs, vs. Case No.: 3:10-CV-00940-CAB(WVG) CLASS ACTION DECLARATION OF CORINNE SOMMER DECLARATION IN SUPPORT OF PLAINTIFFS’ MOTION FOR CLASS CERTIFICATION TRUMP UNIVERSITY, LLC, et al., Defendants. District Judge: Hon. Cathy Ann Bencivengo Magistrate Judge: Hon. William V. Gallo Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 126 of 129 1 I Corinne Sommer, hereby declare and state as follows: 2 1. 3 4 would competently testify as to all facts within my personal knowledge. 2. I worked for Trump University from May 2007 through October 2007. My title 5 was Manager of Events Department. I worked at Trump University’s headquarters located at 6 40 Wall Street, New York, New York, which is also where Trump Organization is located. 7 My job duties as Manager of the Events Department included the coordination of Trump 8 University live events, seminars and training. 9 ZELDES & HAEGGQUIST, LLP I am a resident of New York, New York. If called as a witness, I could and 3. The first Trump University live event took place in Florida in May of 2007, and 10 the second one took place in Los Angeles, California approximately one month later. Before 11 these two live events, my understanding is that Trump University “courses” were only offered 12 online. These two events had approximately 500 attendees each. After that, Trump University 13 held live seminars nearly every week in different areas of the country. 14 4. In my experience, the focus of Trump University was on making sales rather 15 than on providing quality educational services. Trump University would lure consumers into 16 the initial free course based upon the name and reputation of Donald Trump, and then once 17 they were there, Trump University personnel would try to up-sell consumers to the next course 18 using high-pressure sales tactics. Far from providing a “complete real estate education,” as 19 advertised, Trump University personnel only provided enough information to get students to 20 sign up for the next seminar or program. I recall instances in which consumers had paid for a 21 class to learn how to make money investing in real estate, ask for more information, and the 22 teacher would say, “if you want to get that, you have to buy the next package.” I don’t 23 remember who said it, but this is the general gist of things. 24 5. During the time that I was employed at Trump University, many of the 25 speakers, instructors, and mentors lacked real estate experience. Many of them did not even 26 own houses, and had no experience buying or selling real estate. For example, I recall that 27 David Stamper had no real estate experience; he was a jewelry salesman. However, after 28 1 No. 3:10-CV-00940-CAB(WVG) Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 127 of 129 1 working for Trump University for approximately a year on the sales team, he began speaking 2 as an instructor at seminars. 3 Trump University instructors and mentors were not hand-picked by Donald 4 Trump. I believe that in many instances Donald Trump had neither met the instructors or 5 mentors, nor did he know who they were. Instead, I recall that Trump University hired its 6 speakers and mentors through Mark Dove in New Hampshire who hired and trained a number 7 of real estate salespeople that he provided to Trump University. 8 necessarily have real estate experience, but they were skilled at high-pressure sales. I recall 9 that Trump University fired two of Mike Dove’s salespeople because they kept trying to get 10 ZELDES & HAEGGQUIST, LLP 6. 11 These people did not Trump University students to invest in their own personal businesses. 7. I am aware that instructors were trained to, and witnessed them, asking students 12 during the $1,500 seminars to call their credit card companies and raise their credit limits two, 13 three or four times so that they would be able to invest in real estate. They would tell students 14 to max out their credit card because they would make their money back. They couldn’t raise 15 their limit and use it the same day. 16 8. While Trump University’s advertisements claimed it wanted to help consumers 17 make money in real estate, in fact, based upon my experience, I believe that Trump University 18 was only interested in selling every person the most expensive seminars they could possibly 19 buy on credit. I recall that some consumers had showed up who were homeless and could not 20 afford the seminars, yet I overheard Trump University representatives telling them, “it’s ok; 21 just max out your credit card.” I also witnessed representatives instructing consumers to 22 charge the course to multiple credit cards if they lacked a high enough limit on one credit card 23 to pay for the seminar. In fact, I recall representatives telling consumers to open up as many 24 credit cards as they could to increase their credit score. 25 9. Trump University used a standardized PowerPoint presentation and scripts for 26 all of its seminars, so that the seminars were standardized and substantially the same across the 27 country regardless of the particular speaker or location. A few speakers had their own, but 28 those who did not were given presentations. 2 No. 3:10-CV-00940-CAB(WVG) Case 3:10-cv-00940-GPC-WVG Document 462-2 Filed 03/03/16 Page 128 of 129 1 Trump University did not provide one-year of real estate mentoring as promised 2 to the public. My understanding is that mentors were paid up front on commission before the 3 student completed their mentorship. Because of the pay structure, mentors had no incentive to 4 call consumers back or work with them once the consumer signed up and the mentor was paid. 5 The focus of the mentors seemed to be on getting new sales and new commissions. As a 6 result, I recall that mentors rarely returned phone calls from students or spent much time 7 talking with them. I received calls from many angry students telling me that they had been 8 trying to reach their mentor to no avail. 9 ZELDES & HAEGGQUIST, LLP 10. 11. I do not believe that Trump University taught Donald Trump’s investing 10 “secrets.” Donald Trump came from a wealthy family and had resources at his disposal to 11 purchase real estate – that is the secret – one that the average consumer could not replicate. 12 12. At the seminars I attended, Trump University presenters pressured consumers 13 into purchasing the Elite program because they said that students would make their money 14 back in the first deal or two. They told students that even though $25,000 or $35,000 for the 15 Elite program sounded like a lot of money, “Don’t worry, you’ll get your money back right 16 away in your first deal, or first two deals.” 17 13. In the time that I worked for Trump University, I only met Donald Trump once. 18 He was not an active presence there; though he occasionally went over numbers with Michael 19 Sexton. Based upon my interaction with Donald Trump, he seemed only concerned with 20 Trump University’s revenues and profits. 21 14. In my experience, many students were dissatisfied with Trump University. 22 When consumers first signed up and took the course, they were hyped up due to the high- 23 drama atmospherics of the seminars, and they tended to give positive reviews as they were 24 asked for them. But, after purchasing the Elite Program, I saw many students who realized 25 they did not get what they were promised, and they were unable to get through to their mentor, 26 and then they became more and more dissatisfied over time. 27 28 3 No. 3:10-CV-00940-CAB(WVG) ZELDES HAEGGQUIST, LLP Case Document 462-2 Filed 03/03/16 Page 129 of 129 I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Executed this day of September, 2012, at New York, New York. CORINNE SOMMER 4 No.