Case Document 100-3 Filed 03/16/15 Page 1 of 217 EXHIBIT EXHIBIT RANDAZZAILEOALOROUP Case Document 100-3 Filed 03/16/15 Page 2 of 217 Case Document 90 Filed 03/03/15 Page 1 of 3 Marc J. Randazza (NV Bar #12265) Theresa M. Haar (NV Bar #12158) RANDAZZA LEGAL GROUP 3625 S. Town Center Drive, Suite 150 Las Vegas, NV 89135 Telephone: 702?420?2001 Facsimile: 305?437?7662 ecf@randazza.com Attorneys for Jorge Lanata IN THE UNITED STATES DISTRICT COURT DISTRICT OF NEVADA Case No.: NOTICE OF FILING NML CAPITAL, LTD. Plaintiff, vs. THE REPUBLIC OF ARGENTINA Defendant. On February 19, 2015, this Court granted Jorge Lanata?s Motion to Unseal the Deposition Transcript of Ms. Amunategui, ordering counsel for Mr. Lanata and Ms. Amunategui to meet and confer to redacf the transcript. ECF 82. On March 3, 2015, Mr. Randazza and Mr. Woods met and conferred, and settled Upon proper and necessary redactions. Attached as Exhibit 1 is the redacted copy of Ms. Amunategui?s deposition transcript. Dated: 3 March 2015 Respectfully Submitted, RANDAZZA LEGAL GROUP Marc J. Randazza Marc J. Randazza (NV Bar #12265) Theresa M. Haar (NV Bar #12158) -1- RANDAZZAILEGALGROUP \0 CD 0\ 01 A (JO Case Document 100-3 Filed 03/16/15 Page 3 of 217 Case Document 90 Filed 03/03/15 Page 2 of 3 RANDAZZA LEGAL GROUP 3625 S. Town Center Drive, Sui?re 150 Los Vegas, NV 89135 Telephone: 702-420?2001 Facsimile: 305?437?7662 ecf@rondozzo.com A?r?rorneys for Jorge Lono?ro RANDAZZAILEGALGROUP Case Document 100-3 Filed 03/16/15 Page 4 of 217 Case Document 90 Filed 03/03/15 Page 3 of 3 CERTIFICATE OF SERVICE I hereby certify that the foregoing document was filed electronically on 3 March 2015 and served electronically via Employee Randazza Legal Group 3625 3. Town Center Drive, Suite 150 Las Vegas, Nevada 89135 Tel: 702?420?2001 Fax: 305?437?7662 ecf@randazza.com Case Document 100-3 Filed 03/16/15 Page 5 of 217 Case Document 90-1 Filed 03/03/15 Page 1 of 50 EXHIBIT 1 Document 100?3 Filed 03/16/15 Page60f 217 Case 2 Document 90-1 Filed 03/03/15 Page20f50 Case Page 1 UNITED STATES DISTRICT COURT DISTRICT OF NEVADA CERTIFIED COPY NML CAPITAL LTD., Plaintiff, i vs. Case No. ?g THE REPUBLIC OF ARGENTINA, Defendant. VIDEOGRAPHED DEPOSITION OF PATRICIA AMUNATEGUI Taken on Thursday, September 11, 2014 By a Certified Court Reporter At 8:51 a.m. Held at Woods Erickson Whitaker 1349 Galleria Drive Suite 200 Henderson, Nevada 25 OASIS REPORTING SERVICES, LLC Eloctronlcally slgned by Ellen Goldstoln (001-3416734457) Reported by: Ellen A. Goldstein, CCR 829 702-476-4500 Page 2 1 APPEARANCES: 2 3 For the Plaintiff NML CAPITAL, LTD.: 4 DENNIS H. HRANITZKY, ESQ. *1 DECHERT, LLP 5 1095 Avenue of the Americas New York, New York 10036 6 Phone: (212)698-3500 Fax: (212)698-3599 7 dennis.hranitzky@dechert.com 8 For the Defendant MF CORPORATE SERVICES, LTD.: 9 KENT P. WOODS, ESQ. 10 WOODS ERICKSON WHITAKER, LLP 1349 Galleria Drive 11 Suite 200 Henderson, Nevada 89014 12 Phone: (702)433?9696 Fax: (702)434-0615 13 kwoods@woodserickson.com 14 15 For the 123 NONPARTY CORPORATIONS: 16 JASON M. WILEY, ESQ. KOLESAR LEATHAM 17 400 South Rampart Boulevard Suite 400 18 Las Vegas, Nevada 89145 Phone: (702)362?7800 19 Fax: (702)362?9472 jwilekalnevada.com 20 21 Also Present: 22 John Johnson, videographer Gracia M. Feldman, Spanish interpreter 23 Patrick Corcoran 24 25 OASIS REPORTING SERVICES, LLC Electronlcally by Ellen Golditaln (001-3414134457) 702?476-4500 Document 100-3 Filed 03/16/15 Page 7 Of 217 Case 2 Document 90-1 Filed 03/03/15 Page3of50 Case 2 Page 3 1 I 2 3 WITNESS PAGE 4 PATRICIA AMUNATEGUI 5 Examination by MR. HRANITZKY NUMBER DESCRIPTION INTRODUCED ll 0 Subpoena for Patricia Amunategui 14 (18 pages) 12 1 Employment Agreement between 14 13 MF Corporate Services and Patricia Amunategui (PSA 000051 14 PSA 000063; 13 pages) 15 2 Go Back to Get Ahead (no Bates; 79 1 page) 16 3 1-16-14 E?mail chain (PSA 000001; 86 17 1 page) 18 4 The MF Group Web page (no Bates; 92 2 pages) 19 6 Trust Services Web page (no Bates; 95 20 1 page) 21 7 Administrative Services Web page 99 (no Bates; 1 page) 22 8 Mossack Fonseca marketing 103 23 literature (no Bates; 36 pages) 24 9 MF Corporate Services International 114 Web page (no Bates; 2 pages) 25 OASIS REPORTING SERVICES, LLC 702-476-4500 Electronlcally signod by Ellen (001-3414784451) Page 4 1 (I Continued) 2 NUMBER DESCRIPTION INTRODUCED 3 11 Nevada USA Web page (no Bates; 115 2 pages) 4 12 Mossack Fonseca marketing of Nevada 116 5 limited?liability companies (no Bates; 4 pages) 6 13 Declaration of Patricia Amunategui 141 7 (6 pages) 8 14 September 2008 E?mail chain 147 (misc. Bates numbers; 9 pages) 9 15 11-11-05 E-mail (TRANSLATION MFCS 150 10 000535; 1 page) 11 16 5-22?06 E-mail chain (TRANSLATION 152 MFCS 000311 - TRANSLATION MFCS 12 000313; 3 pages) 13 17 Miscellaneous E?mails 163 (TRANSLATION MFCS 000899 l4 TRANSLATION MFCS 000904; 6 pages) 15 18 6?12?13 E?mails (MFCS 002223 - 168 MFCS 002229; 7 pages) 16 19 October 2007 E-mail chain 172 17 (TRANSLATION MFCS 006580 TRANSLATION MFCS 006584; 5 pages) 18 22 8?4-06 E-mail chain (TRANSLATION 180 19 MFCS 004065) 20 23 Miscellaneous E-mails 182 (MFCS 005308 MFCS 005322; 15 pages) 21 24 Miscellaneous E?mails (TRANSLATION 187 22 MFCS 006487 TRANSLATION MFCS 006490; 4 pages) 23 25 11-13-04 E?mail chain (TRANSLATION 190 24 MFCS 005025; 1 PAGE) 25 OASIS REPORTING SERVICES, LLC Electronically :lgned by Ellen Goldslein (001-341-678-7457) 702-476-4500 Document 100-3 Filed 03/16/15 Page8of 217 Case 2 14-CV-OO492-RFB-VCF Document 90-1 Filed 03/03/15 Page 4 0f 50 Case Continued) NUMBER DESCRIPTION 26 6-10-08 E?mail with attachment (TRANSLATION MFCS 004533 and TRANSLATION MFCS 004525 - TRANSLATION MFCS 004538; 15 pages) 27 4?5?06 E-mail chain MFCS 001932; 1 page) 31 9?29?05 E?mail chain (TRANSLATION MFCS 002842 - MFCS 002843; 2 pages) (TRANSLATION 32 6?5-13 letter from Patricia Amunategui to Aldyne board of directors (PSA 000005; 1 page) 33 6-5?13 letter from Patricia Amunategui to Fergus International board of directors (PSA 000006; 1 page) 34 6-5-13 letter from Patricia Amunategui to Plascot Limited board of directors (PSA 000007; 1 page) Page 5 INTRODUCED 192 195 200 201 201 201 Electronlcally slgnad by Ellen Goldstoln (OM-3416151451) OASIS REPORTING SERVICES, LLC 702-476-4500 Page 6 1 THURSDAY, SEPTEMBER 11, 2014 - HENDERSON, NEVADA 2 8:51 A.M. 3 4 Exhibits 0 and 1 were pre-marked 5 for identification by the Certified Court Reporter) 6 (All answers by the witness were given in 7 English unless otherwise indicated.) 8 9 THE VIDEOGRAPHER: This begins the deposition of 10 Patricia Amunategui. Today's date is September 11, 2014. 11 The time is 8:51 a.m. We are at the law offices of Woods 12 Erickson Whitaker, 1349 West Galleria Drive, Suite 200, 13 Henderson, Nevada. This case is in the United States 14 District Court, District of Nevada, entitled Capital 15 Limited versus The Republic of Argentina," case 16 No. My name is John Johnson. The 17 court reporter is Ellen Goldstein. We're with Oasis 18 Reporting Services. 19 Will counsel please identify yourselves and then 20 the reporter will administer the oath. 21 MR. HRANITZKY: I?m Dennis Hranitzky from Dechert, 22 LLP in New York. I'll be examining the witness on behalf 23 of NML Capital Limited. 24 MR. WOODS: Kent Woods, Woods Erickson Whitaker, and 25 I represent Patricia Amunategui and MF Corporate Services OASIS REPORTING SERVICES, LLC slgnod by Ellen Golan-in (001-341-678-1451) 702-476-4500 Document 100-3 Filed 03/16/15 Page9of 217 Case 2 Document 90-1 Filed 03/03/15 PageSofSO Case Page 7 Nevada, Limited. MR. WILEY: Jason Wiley on behalf of the 123 entities that are interested parties in this litigation. GRACIA M. FELDMAN, an interpreter of the Spanish language, was duly sworn to translate the following proceedings from English into Spanish and from Spanish into English. PATRICIA AMUNATEGUI, called as a witness by and on behalf of the Plaintiff, was first duly sworn by the Certified Court Reporter and testified as follows: EXAMINATION BY MR. HRANITZKY: Good morning, Miss Amunategui. A Good morning. My name is Dennis Hranitzky. I'm an attorney with a law firm in New York called Dechert, LLP. I represent NML Capital Limited and I?m going to be asking you some questions this morning regarding the matters set forth in the subpoena that I?ll show you in a moment. I'm going to ask you that if there's anything in the questions I ask that doesn't make sense to you, that you 25 Electronically Ilgnod by anon sown (001-3414157451) OASIS REPORTING SERVICES. LLC a1u2154-n441a-mmzmo 702-476-4500 Page 8 please say so so that I can make my questions more clear to you. A A point, A is that right? A yes? Does that make sense? Yes. Okay, thanks. First, could you state your name for the record. Patricia Amunategui. (Through the interpreter) Patricia Amunategui. And you were born in Chile; is that right? Yes. And you moved to the United States at some Yes. In fact you?ve come to the United States twice: Yes. mm by Ell-n Baldwin (om-3414751451) 7024764500 aauns-?n-un-un?cmmzam OASIS REPORTING SERVICES, LLC Document 100-3 Filed 03/16/15 Page 10 of 217 Case 2 Document 90-1 Filed 03/03/15 Page60f50 Case Page 9 Okay. A And I always come back here periodically. To the United States? A To the United States, yes, because my husband still was here at that time. I see. Were you working during that period? A During the period of - with my first arrived, no. I don't speak English, so I didn't work; but I work from 2005 probably or 2006 part time in different casino. I work with - my first job was here at the casino, at Bally's. Okay. Can you just very briefly take us through your employment history up through the time you went to work for Bally's around 2005. A In this country, not what I do in Chile? In Chile and in this country. A Okay. In Chile I work for Bank Santander, was my last job when I moved here. I worked as a secretary And when I move here I of one of the vice president. don't work right away. I wait two year or something my by E?on Gawain (am-3414154451) OASIS REPORTING SERVICES, LLC daumsuWAnaummuuaamn 702-476a4500 Page 10 1 because, one thing, my document of the legal residence 2 take longer for work, but at the same time I don't have 3 English enough. So I went to school. I Went to a 4 college to learn English during that period of time. 5 Was that community college in 7 San Francisco. I lived in San Francisco at that time. 8 I see. Before you worked at Santander in Chile, 9 did you have other jobs? 10 A Oh, yeah, many. I try to give you the short 11 way. I work for a radio station, insurance company, and 12 then I had my own business too. 13 What was your business? 14 A I have a tanning-bed salon in Chile and I bring 15 machine from this country. That was my second period 16 when I went to Chile. I bought some tanning bed here 17 from California and I start a I was the first one open 18 a tanning-bed salon in Chile. It was very fun. 19 An innovator. 20 A Very innovator, very fun. 21 All right. And that was sometime between - 22 A Between 2005 and 2007. In between the time I 23 moved I open a business there, when I was living here and 24 then moving back. 25 Do you mean 1995? OASIS REPORTING SERVICES, LLC Ebetronlca?y signed by Ellen Gold-mu (m1-u1mum 702?476~4500 Document 100-3 Filed 03/16/15 Page 11 of 217 Case 2 Document 90-1 Filed 03/03/15 Page70f50 Case Page 11 A Oh, yeah, nineties. Before probably I'm not exist. It's okay. And in Chile did you have did you go to university or college in Chile? A No. I went for private school for secretary, business secretary, assistant. And in your jobs before Santander, you mentioned an insurance company? A Uh-huh. And another position? Yes. Were those secretarial or 0 0 Yeah, all secretarial. MR. WOODS: Let him finish his questions before you answer. It will make it easier for the court reporter. THE WITNESS: Okay. MR. WOODS: Hopefully, as things progress you know, wait for him to finish his question so the translator can do her job THE WITNESS: Okay. MR. WOODS: and translate before so she makes sure you understand. THE WITNESS: Okay. BY MR. HRANITZKY: Your counsel has asked that we have the OASIS REPORTING SERVICES, LLC Electronlcally algnod by Ellen Goldsleln (001-341-678-7457) 702-476-4500 Page 12 1 translator's assistance for all of the questions 2 A Okay. 3 so we should do it that way. 4 A Okay. 5 So you said you came back to the United States 6 in around 1997. Is that right? 7 A Yes, the second time. 8 Okay. And when you returned, at some point 9 following your return, you went to work for a casino here 10 in Las Vegas; is that right? 11 A (Through the translator) Yes, the second time. 12 Okay. And for how long did you work in the 13 casino? 14 A Eleven year maybe. 15 Okay. So until when? i 16 A 2006. 17 I see. At one point did you obtain an education 18 at 19 A Yes. 20 And when was that? 21 A I don't remember exactly the years 'cause I 22 started different - 23 THE REPORTER: Started what? 24 THE WITNESS: Different other stuff, I mean English a 25 second language, and then I went to UNLV for the 702-476-4500 OASIS REPORTING SERVICES, LLC Electronlcally signed by Ellen GoldsIelrI (001-341-618-7457) Document 100-3 Filed 03/16/15 Page 12 of 217 Case 2 Document 90-1 Filed 03/03/15 Page80f50 Case Page 13 paralegal course; but I don't remember when I started. I remember when I finished. It was a long way. BY MR. HRANITZKY: And when did you finish? A I think I finish in 2000, 2000 probably. In 2000? A I can't give you sure, but I think it was 2000. And do you have a degree from A I have a certification of paralegal from UNLV, yeah. Other than paralegal studies, did you study anything else at A I went for more classes of paralegal and I take corporate law, I think they offer, and I take that class. I think so. I take classes. I don't remember exactly which ones, but I take more classes after. Okay. And how - approximately how long did you study at A I will say I was in and out for two year probably. Yeah, probably, yeah. Okay. So and you say you graduated from UNLV in 2000? A Uh-huh. And you said you worked in the casino until 2006? Electronically signed by Ellen Goldsuln (001-3416104451) OASIS REPORTING SERVICES, LLC 702-476-4500 Page 14 1 A Yes. 2 Between 2000 and 2006, did you have any other 3 employment besides the casino? 4 A Can you repeat again. Sorry. 5 Yes. Between 2000 and 2006 did you have any 6 other employment 7 A Yes. 8 - besides the casino? 9 A Yes, yes. I worked two job for six for more 10 than six years. 11 Okay. What was the other job? 12 A I work for ME Corporate Service and I work for 13 the casino. 14 I see. When did you start to work for 15 MF Corporate Services? 16 A 2001 I believe, 2001 probably. 17 Okay. I'm going to ask the court reporter to 18 hand you two documents. One has been marked as Exhibit 0 19 and one has been marked as Exhibit 1. I'd ask you to 20 look at them and let me know if you recognize them. 21 A Can I take my glasses? 22 Of course. 23 (Discussion held off the stenographic record in 24 Spanish.) 25 THE WITNESS: I recognize this one, like the subpoena Electronically signed by Ellen Goldsuln(001-341-GTB-1457) OASIS REPORTING SERVICES, LLC 702-476?4500 Document 100-3 Filed 03/16/15 Page 13 of 217 Case 2 Document 90-1 Filed 03/03/15 Page90f50 Case Page 15 I receive, and I believe it is mine. BY MR. HRANITZKY: Okay. So you recognize Exhibit 0 as a subpoena that you received? A I'm looking for my name. Look on the first page. Your name should be there. Do you see on the first page it says NML Capital, Republic of Argentina? A Yeah, yeahname, yes. Okay. I was looking for my name. Okay. You can put that aside. A I don't want to get that confused with the other one. Exhibit 1, do you recognize Exhibit 1? A Well, I believe it's my contract agreement, my employee contract agreement. So you recognize this as your employment contract with MF Corporate Services Nevada Limited? A Yes. I want to be sure. Yeah. Could I ask you to look on the last page. A Uh?huh. Actually it's not the last page of the exhibit. It?s the last page of the contract. A Okay. Ehctromly signed by anon 6mm 0 Sorry. It is the last page of the exhibit. OASIS REPORTING SERVICES, LLC 702w47?m4500 Page 16 1 A You're talking this page (indicating)? 2 Yes. 3 A Okay. 4 Do you recognize your signature? 5 A Yes, I do. 6 All right. And you recognize the signatures of 7 Mr. Mossack and Mr. Fonseca? 8 A I never see the signature before, so I assume. 9 Okay. 10 A I can?t recognize the signature. This is the 11 only time I see the signature. 12 Okay. So if we could turn to the first page of: 13 Exhibit 1 14 A This (indicating)? 15 Yes, yes. In the first paragraph it lists a 16 Social Security number and U.S. Certificate of 17 Citizenship number. 18 A Yesecu-mu (om-w-m-mn OASIS REPORTING SERVICES, LLC 702-476-4500 Document 100-3 Filed 03/16/15 Page 14 of 217 Case 2 Document 90-1 Filed 03/03/15 Page 10 of 50 Case Page 17 Okay. So how did you become aware of this potential position with ME Corporate Services Nevada that you were later hired for? A I don't remember where. Was a person my son know I think, something meet, and people from ME Corporate Service was here and introduce me and called me for an interview: and I have to be meet them in a restaurant for with my resume. I think they went to UNLV for ask people they speak Spanish. Okay. So - A And the paralegal service, sometime they put potential offer job for the student that are ready to graduate. So you think you learned about the opportunity through A I don't learn about opportunity. They have the list probably of the students speak Spanish. They give it to them because I get called. I see. So you were contacted - A I get contacted, yeah. I get contact. I never in fact I never was looking for the second job. I was very tired at that time finish my school, but I Page 18 1 All right. And I think you mentioned that your 2 son may have had some role in this. What was his role? 3 A Well, no. My son got married, and one of the 4 invited person for the wedding was in the same 5 restaurant/hotel where these people stay; and because 6 they speak Spanish in fact they are from Argentina I 7 think, so they - you know, they asked if they know 8 somebody with Spanish language in this town. That's what 9 the first information I know about it. 10 I see. So people from the - people from ll MP Corporate Services asked people at the hotel - 12 A At the hotel if they 13 - if they knew of people - 14 A Somebody. 15 If you would, just let me finish my question so 16 we have a clear record. 17 So you think that people from MF Corporate 18 Services asked people from the hotel if they knew of :9 anyone in the area who spoke Spanish and who might be 20 suitable for a job with MP Corporate Services Nevada? 21 A Yes. 22 Is that right? 23 A Yes. 24 Do you recall who from ME Corporate Services 25 Nevada made these inquiries? OASIS REPORTING SERVICES, LLC Mannie-I1 by Ellen Baldwin (OM-341mqu thought it was a good opportunity. I say yes. 702-476-4500 Electronically Ilgnod by Elm Gold-tom (?manna-1451) OASIS REPORTING SERVICES, LLC 702-476-4500 Document 100-3 Filed 03/16/15 Page 15 of 217 Case 2 Document 90-1 Filed 03/03/15 Page 11 of 50 Case Page 19 A Yes, the lady I meet after. Who what was her name? A Her name was Nancy, but I don't remember the last name. And did Nancy work for MF Corporate Services Nevada? A Nancy worked For MP Corporate Services Nevada? A Yes. Do you know if Nancy worked for any other company at that time? A Probably. I training and she hire That's the person was for another company. I see. MF Corporate Services A She work up here - she work a long time after. She take vacation and touch with her in case I need something when she was not here. Does she still work for MF Corporate Services Nevada? A I don?t know. payroll, so no. Was a long time ago. And how long did Nancy work at for ME Corp., yeah. don't know. I meet her. She do my me. She sign this contract. here. I don't know if she worked Probably. I don't know. Nevada after you started there? then come back, and I always was in I don't know. It's not in the OASIS REPORTING SERVICES, LLC Elacuonlcally signed by Ellen Goldslain (001-341-673-7457) 702-476-4500 Page 20 1 Do you ever hear from Nancy nowadays? 2 A No. I hear long time ago because she had a 3 surgery. Probably she get retired, but - because she 4 was not a young person, but I don't know anything about 5 her. 6 I see. Did you meet or speak with anyone else 7 about the job at MF Corporate Services Nevada before you 8 were hired? 9 A No. Only with Nancy. 10 Only with Nancy, all right. 11 Did you speak with Mr. Mossack or Mr. Fonseca? 12 A Never. 13 Did you meet with them? 14 A Not in that time. Later, very later. 15 Okay. At what time have you met Mr. Mossack or 16 Mr. Fonseca? 17 A During my period of work I learn a lot about the 18 Nevada jurisdiction and I have to market this Nevada, and 19 one - couple time I have to be in some event where you 20 do PowerPoint presentation about what is your product and 21 how it's so I meet them in one of my trip to Panama 22 Okay. 23 A - explaining and offer the product and give a 24 presentation about the jurisdiction. 25 So you met them in connection with OASIS REPORTING SERVICES, LLC Electronically algnad by Ellen Goldiloln (001-3416784457) 702-476-4500 Document 100-3 Filed 03/16/15 Page 16 of 217 Case 2 Document 90-1 Filed 03/03/15 Page 12 Of 50 Case Page 21 presentations A I met with them like that? A with many other people. I can't remember names, but I meet at that time. I see. Just if you would, let me finish my question before you answer so the court reporter can get everything down. than one A and marketing event. MR. WOODS: She said "siempre in the same kind of setting." THE INTERPRETER: Oh, she said in Spanish, "always in the same type of setting." MR. HRANITZKY: Well, I think this is still - it's working. And always in Panama? A Yes. How often do you go to Panama? Have you met Mr. Mossack and Mr. Fonseca on more occasion? Yes, yes. Approximately how many times? I will say three time. Was it always in the same kind of setting? Uh-huh, yes, siempre in the same kind of setting Can you translate so the court reporter can - OASIS REPORTING SERVICES, LLC Electronically slgnod by Ellen Goldsiein (001-341-678-1451) 702-476-4500 Page 22 1 A Well, don't depend on me. Depend on if they 2 have this how they call it marketing event or 3 summit. 4 Summit? 5 A Summit so we can learn about different 6 everybody bring myself, I bring whatever is new here 7 about any new change of product. Normally it's one a 8 year, but it's all depend when is the event. I don't 9 recall when is the last time, but I think my last time 10 was last February probably when I went. 11 MR. WOODS: If I can, Patricia, like happened before, 12 if there's a word that you don't quite know what it is, 13 that's what the translator is forSpanish, if you don't know what it is, and she'll 15 translate it. 16 THE WITNESS: Oh, okay, okay. 17 BY MR. HRANITZKY: 18 In fact, if your counsel doesn't mind, there may 19 be times when I actually suggest that perhaps you answer 20 the question in Spanish 21 A Yeah. 22 and the translator translates it. 23 A Okay. 24 For the short answers and the easy answers, I 25 think English is working, but for the more complicated OASIS REPORTING SERVICES, LLC Electronically slgned by Ellen Goldeleln (001-341-618-1451) 702-476-4500 Document 100-3 Filed 03/16/15 Page 17 of 217 Case 2 Document 90-1 Filed 03/03/15 Page 13 of 50 Case Page 23 answers - A Okay. - it may be best if we go through the interpreter. A Okay. Okay? A Okay. (Through the interpreter) So is it something that I didn't understand? I think we're fine. Just going forward. A Okay. Do you go to Panama for any purpose other than to attend these kinds of symposiums? A I like Panama. MR. WOODS: So is that a "no" or is that a "yes"? THE WITNESS: I will say yes. I like to go for other purpose if I would. BY MR. HRANITZKY: But in the past, have you gone for business purposes other than to attend the kinds of symposiums you described? A I don't remember, Emit-ally ligand by Ell-n Gown (001-3414134451) OASIS REPORTING SERVICES, LLC m1u215-4a71447o-bu24m2au 70247e4am Page 24 2 They have nice beaches in Panama. 3 A Very, and I'm a beach person so and the warm 4 water. 5 Me too, especially in the winter. 6 So do you know why Mr. Mossack and Mr. Fonseca signed the employment contract on behalf of ME Corporate 8 Services Nevada? 9 A No, I don't know. 10 0 All right. Do you know if they have any 11 position with MF Corporate Services Nevada? 12 A No. 13 You didn't ask anyone that question? 14 A No, I didn't ask. 15 In your history working for ME Corporate 16 Services Nevada, have there been other instances where 17 Mr. Mossack and Mr. Fonseca - or Mr. Fonseca acted on 18 behalf of NF Corporate Services Nevada? 19 A No. 20 None that you 21 A Not that I see it, no. 22 Other than signing employment contracts? 23 A Uh-huh. 24 Have you seen any corporate formation documents 25 or things of that nature for Corporate Services OASIS REPORTING SERVICES, LLC 702-476-4500 tlgnod by (001-341-615-7457) dc74c275-4l77-4475bll2-mm Document 100-3 Filed 03/16/15 Page 18 of 217 Document 90-1 Filed 03/03/15 Page 14 Of 50 I5 8 Case 2 Case 2 Page 25 Page 26 1 Nevada?. 1 Let me start with the second part. 2 A No, no. I don't have any document of corporate 2 A OkaY- 3 formation, just only the Article of Organization and the 3 50 MF Nevada MF corporate serViceS NeVada: 4 initial list what I have in the office_ 4 which I'm going to call Nevada" if that's okay 5 In the Articles of Organization, are Mr. Mossack 5 A Yeah, Okay. 6 or Mr. Fonseca identified in any capacity? 6 just to make it easier. 7 A No. 7 A Okay. 8 Their names appear nowhere? 8 MF Nevada has no other employees as far as you 9 A No, nowhere. 9 know? 10 So - strike that. 10 A No. 11 What is your title at MF Corporate Services 11 IS that What you're saying? 12 Nevada, if you have oneknow, no. 13 A I'm a secretary of the director, 13 As secretary to the board, would you know if 14 THE REPORTER: Of the what? 14 MF Nevada had other employees? 15 THE WITNESS: Secretary. 15 A No, no. I don't do anything on the payroll 16 THE INTERPRETER: "I'm a secretary of the director." 16 here, but I don't know anything if they have, no. 17 BY MR, 17 Who handles the payroll for ME Nevada? 18 Of the board? 18 A Myself. 19 A Of the board; and also I'm running the office by 19 You do: OkaY- 20 myself, so 20 A I pay the payroll taxes and I pay the payroll. 21 (Through the interpreter) I'm the only 21 Do YOU Sign Your Own salary CheCkS? 22 administrator. 22 A Yes, Sir. 23 (In English) And the only employee_ 23 Do you sign salary checks for anyone else? 24 (Through the interpreter) And the only 24 A Yes- 25 employee. 25 (Through the interpreter) Just for the 702-476-4500 OASIS REPORTING SERVICES, LLC OASIS REPORTING SERVICES, LLC 702-476-4500 Electronically signed by Ellen Goldetein (001-341-678-1451) Electronically signed by Ellen Goldsteln (001-341-673-7457) Document 100-3 Filed 03/16/15 Page 19 of 217 Case 2 Document 90-1 Filed 03/03/15 Page 15 of 50 Case Page 27 services, the services. So you sign your own salary checks, but you do not sign salary checks for anybody elseyou know, you're the only employee of ME Nevada? A Yes. How does MF Nevada receive the money that is used to pay your salary and other expenses? A Every month myself or my secretary, if I use one, a temp, we do a spreadsheet with our work and we send it to our client, Mossack Fonseca, and they need to deposit the money of our work, and that's the way it work. So I have my wire transfer on the money I charge for MF it's not myself, but MF Nevada, like you call charge and we get the money every month. So the money to pay your salary and the other expenses A Is in If you would just let me finish. A Yeah, sorry. That's okay. The deposition is funny because in conversation people interrupt each other, but in it's hard for the court reporter. A Yeah, yeah, I understand. Electronlcally slgnod by Ellen Goldstoin (001-341-678-7451) OASIS REPORTING SERVICES, LLC 702-476-4500 Page 28 1 So the money to pay your salary and the other 2 expenses of NE Nevada comes from Mossack Fonseca; is that 3 right? 4 A Come from the client. They pay Mossack Fonseca 5 for the service we provide for them. 6 Okay. But does the wire that you mentioned a 7 moment ago to ME Nevada does the wire come from the 8 clients or did it come from Mossack FonsecaNevada have in a bank account in 10 Panama, so they deposit the sales every month to the same 11 account and we reconcilliate the account every end of the 12 month. 13 I see. So who deposits the money every month? 14 A We pay a collection company to do that in 15 Panama, to collect company - to collect the money. 16 Okay. So a collection company collects money 17 from clients? 18 A No, collect money from Mossack Fonseca. 19 I see. 20 A And deposit in the account of ME Nevada in 21 Panama. 22 Okay. So the money goes from Mossack Fonseca to 23 the collection company and then from the collection 24 company into MF Nevada's bank account in Panama? 25 A Yes. Electronically slgnod by Ellen Goldsteln (001-341-670-7451) OASIS REPORTING SERVICES, LLC 702-476-4500 Document 100-3 Filed 03/16/15 Page 20 of 217 Case 2 Document 90-1 Filed 03/03/15 Page 16 of 50 Case Page 29 I mean what is the name of the collection company? A I don't know. I don't know the name of the collection company because it's a service we pay, but I don't know the name of the collection company. But you said that it's the collection company that deposits the money in ME Nevada's bank account in Panama, yes? A Yes. So do you have access to the records of the bank account - A No. in Panama? A No, I don't have any no. I have the record of the balance in the money, yes, because I get my statement. I get the bank statement every month on the mail, but I don't I don't know the company. It?s a service. At this point I don't know. Probably is in the list of the people we pay services, but I don't remember the name. So the bank statements you receive don't reflect who the collection service A Probably do, but I don't see that because all these document I send it to the accounting here. So you never look at that? Elacironically slgnod by Ellen Goldstoln (001-3414754457) OASIS REPORTING SERVICES, LLC 702-476-4500 Page 30 1 A No. 2 You're the secretary of ME Nevada though; right? 3 A Uh?huh. 4 And you report to the board of directors of 5 ME Nevada with respect to certain matters, yes? 6 A Uh-huh. 7 Do you understand that part of your 8 responsibility as secretary is to be familiar with the 9 finances of ME Nevada? 10 MR. WOODS: Object to that question. I think that 11 mischaracterizes the - mischaracterizes what she said. 12 You haven't laid a foundation about what her duties are. 13 You can answer the question. 14 BY MR. HRANITZKY: 15 You can answer the question. 16 A Oh, I didn't know he finished talking. 17 MR. WOODS: Yes, if you understand it. 18 THE WITNESS: (Through the interpreter) Yes, I 19 understood it. 20 The job does not include the finances for ME. 21 I'm not good at finances. 22 (In English) I give everything to a CPA who 23 work for us when we started. He prepare everything. I 24 give all the expense for every month and she prepare the 25 report for me to send it to the president of the company. Electronically signed by Ellen Goldstein (001-341-678-7457) OASIS REPORTING SERVICES, LLC 702-476-4500 4o.- Document 100-3 Filed 03/16/15 Page 21 of 217 Case 2 Document 90-1 Filed 03/03/15 Page 17 of 50 Case Page 31 So if something is an error or something, they will find out and they ask me probably; but the moment, so far so good. BY MR. HRANITZKY: You mentioned the president of the company. Who was that? A Mrs. Imogene Wilson. Imogene? A Imogene Wilson. Wilson? A Yes. And where is Imogene Wilson located? A In Panama office. In the Panama office? The Panama office of Mossack Fonseca? A I don't know. The address is Panama office, where it is, but I don't know if she work for Panama office. When you send documents to Imogene Wilson, do you send it to A I send it by E-mail. You send them by E?mail? A Yeah. What is Ms. Wilson's E?mail address? A I don't remember at this point. OASIS REPORTING SERVICES, LLC Electronically slgnad by Ellen Goldaleln (001-341-678-1457) 702?476~4500 Page 32 1 How often do you send E?mails to Miss Wilson? 2 A Probably once a month. 3 But you don?t remember her E?mail address? 4 A I don't remember the E?mail address, no. I have 5 many E?mail address I send it to her. 6 And she's the president of NF Nevada? 7 A Uh?huh. 8 Is that reflected in the Articles of 9 Incorporation of MF Nevada? 10 A Yes. She's the person. 11 And that appears in the Articles of 12 Incorporation? 13 A In the list I believe. I don't know the 14 articles. In the list I believe she's the president. 15 What list are you 16 A The annual list, the annual list. 17 (Through the interpreter) Annual list. 18 The annual list provided to the Nevada Secretary 19 of State? 20 A Uh?huh. 21 Before when I was asking you about the bank 22 statements for ME Nevada's bank account in Panama 23 A Uh?huh. 24 - you said that you receive them but you don't 25 look at them and then you send them to somebody else. Is Electronlcally signed by Ellen Gold?aln (001-341-67&1451) OASIS REPORTING SERVICES, LLC 702-476-4500 Document 100-3 Filed 03/16/15 Page 22 of 217 Case 2 14-CV-OO492-RFB-VCF Document 90-1 Filed 03/03/15 Page 18 0f 50 Case Page 33 that right? A The CPA. You send them to the CPA. Who is the A Sharples Associates, Sharples Associates. Sharpie? Sharpless? And Associates. Are they based 3:4 IO 3? IO Yes. 115 are part of the accounting or collection, but I don't remember how many they are, but they are a part of people they need to receive it. Who are those people? A They have the name of the company more collection, collection, for Sharples Associates who is the bookkeeper for us. I see. So collections and bookkeeping, are they at Mossack Fonseca or the accounting? A My accounting here and Mossack Fonseca in Panama, yes someone . Okay. So you send the bank statements to various people at your Nevada accountant and also Sharples Associates. Do you send them to anybody else? I think it?s more people in the E-mail. They here in Nevada? bookkeeper, another person work OASIS REPORTING SERVICES, LLC Electronically signed by Ellen Gold?lln (001-341-675-7457) 702-476d4500 Page 34 A Yes. 2 - there's various people at Mossack Fonseca; is 3 that right? 4 A Yes. 5 Okay. Who are those people at Mossack Fonseca? 6 A They are different department. They're 7 accounting or something accounting. 8 I see. But you don't remember any of their 9 names? 10 A Well, the names I don't remember because I only i 11 see the E?mail; and the E?mail, they are always not the I 12 name. You know, it's some so I don't remember 13 exactly. 14 So it?s like accounting@Mossack.com? 15 A Yeah, or collection and another company. So I 16 can't yeah, I don't remember exactly, yeah. 17 I see. But it doesn't list any person? 18 A Yeah, yeah, not person specific, yeah. 19 I see. 20 A Controller or something. 21 So you said that - I asked you what your 22 position or positions are at MF Nevada and you said 23 you're the secretary to the board, you're the only 24 administrator, and you?re the only employee; right? 25 A Uh-huh. Eloctronlcally slgned by Ellen Galdslaln (001-3414784457) OASIS REPORTING SERVICES, LLC 702-476-4500 l? Document 100-3 Filed 03/16/15 Page 23 of 217 Case 2 14-CV-OO492-RFB-VCF Document 90-1 Filed 03/03/15 Page 19 of 50 Case Page 35 But you mentioned before a woman named Imogene who?s the president of MP Nevada? A Uh?huh. You don't consider Imogene to be an employee of ME Nevada? A I don't know if she's employee. She's not in my payroll. I see. So you're in charge of the payroll? A Yes, here in this place. I don't know anything about more than here. Do payroll checks get paid out of the account in Panama A No. or do they get paid out of an account here in Nevada? A No. All our business coming in a bank account here. All the bank account, they're running here. I see. So is money transferred from the bank account in Panama to the bank account in Nevada periodically? A Yes. And who is responsible for transferring that money? A The collection department we pay because they collect our invoices. Eloctronlcally Ilgned by Ellen Goldsteln (001-341-6754457) 702-476-4500 OASIS REPORTING SERVICES, LLC Page 36 1 The collection department at Mossack Fonseca? 2 A I don't know. I don't know if it's Mossack 3 Fonseca or a private company. I never speak with them. 4 I see. So when 5 A The reason I know is because I get a bill from 6 them. 7 I see. So if, as the person in charge of 8 payroll in Nevada, you see that MF Nevada needs funds to 9 meet its expenses, who do you call or E?mail to ask that 10 funds be transferred? 11 A I send an E?mail 12 (Through the interpreter) I send an E-mail to 13 the person of the collection asking for payment of the 14 invoice for the jobs that we have done during that time. 15 And who do you send that E?mail to? 16 A To the collection department. 17 All right. And who is that? 18 A I think it's a name - I don't know exactly the 19 name. I can give you wrong name. I don't know the name. 20 But how often do you send E-mails of that 21 nature? 22 A Normally I don't have to send much E?mail of 23 that because the sale and the payment of invoices is very 24 on time, but when we have to pay an extra something, we 25 request they go more straight to collect the money with 702-476?4500 OASIS REPORTING SERVICES, LLC Electronically signed by Ellen Goldstein [001-341-618-7451) Document 100-3 Filed 03/16/15 Page 24 of 217 Case 2 Document 90-1 Filed 03/03/15 Page 20 of 50 Case Page 37 the people they don't pay on time; like, you know, sometime take later, pay after 30 days. But even though you said before that paying this service is one of the expenses of MP Nevada that you're responsible for and that you have to communicate with them periodically to see that funds get transferred to ME Nevada's account, you don't remember the name of that collection service? A (Through the interpreter) Okay. What happens is you speak to different people THE REPORTER: Start again. I didn't understand you. THE INTERPRETER: "What happens is you speak to whoever is there, whoever happens to answer the phone." THE WITNESS: (In English) Or I send an E-mail. BY MR. HRANITZKY: Well, and I'm asking, when you send the E?mail, who do you send the E-mail to? A Collection department or what is their name? Can be accounting, but I don't I'm not sure. I'm not sure. I need to - I Is that accounting and collections at Mossack Fonseca or someplace else? A No. It's I don't know. I don't know. It's probably in Mossack Fonseca, but I don't know if they are at Mossack Fonseca. Electronically signed by Ellen Goldsloin (001-3414784457) OASIS REPORTING SERVICES, LLC 702-476-4500 Page 38 1 when you call, understanding that different 2 people answer the phone, are you calling to the Panama 3 country? 4 A Yeah, I call the Panama country, yeah. 5 Okay. Do you recall the name of any of the .6 people that you speak to? 7 A I have the feeling I speak more often with one 8 name they call Jodeli. Jodeli, I think that's the name 9 of the person I been speaking, Jodeli. I don't know even 10 how to spell it, Jodeli. 11 Jodeli? 12 A Jodeli. 13 Is that a man or a woman? 14 A A woman. 15 A woman. 16 A And I don?t know her E-mail because it?s in the 17 department. 18 Her proper name doesn't appear when you send the 19 E-mail? 20 A Yeah. The only thing I know is Jodeli, because 21 when I can it's the person I speak in the phone. 22 I see, okay. What are your responsibilities 23 with MF Nevada, your job responsibilities? 24 A Since open the door in the morning - 25 (Through the interpreter) Since I open the door Electronically slgnad by Ellen Goldsteln (001-3414134457) OASIS REPORTING SERVICES, LLC 702-476-4500 1.1-1 .v Document100-3 Filed 03/16/15 Page 25 of 217 Case 2 Document 90-1 Filed 03/03/15 Page 21 of 50 Case Page 39 in the morning (In English) be in charge of all (Through the interpreter) I'm in charge of the office operations, bring all the documents in front of the Secretary of State of all the documents that we receive. (In English) We request, to incorporate company, service of process for companies we're having and comply with the regulation for the office in Nevada and learn about jurisdiction of Nevada. (Through the interpreter) If there has been any change. If a change has been made, I have to make a change so the business can run. So when you refer to "changes," you mean changes in the laws and regulations A Changes to the law and regulations. Just allow me to finish. I A Yeah. Changes to the laws and regulations governing A Governing. - Nevada corporations? A (Through the interpreter) Yes. I So you can make sure that all of the Nevada corporations that you're overseeing are in full compliance with Nevada law? Eh?ronlcally slgnad by Ellen Goldmin (001-341-513-1451) OASIS REPORTING SERVICES, LLC 702-476-4500 Page 40 1 A Correct, correct. 2 And how do you learn about those changes? 3 A (Through the interpreter) I'm involved with the 4 Secretary of State. 5 (In English) We are a commercial registered 6 agent, so we get mail every week or every month if 7 something is changed; and also - 8 (Through the interpreter) I participate as a 9 member of the associated agents of the state of Nevada, 10 registered agents association of the state of Nevada. 11 And that organization provides some educational 12 functions? 13 A They provide some education and they advise you 14 if there any change coming and they give you ahead of 15 time to prepare yourself and prepare your client. The 16 more important is to I need to inform Mossack Fonseca 17 what's going to change in order to prepare the document. 18 Okay. So you mentioned your job 19 responsibilities are to open the door in the morning, you 20 manage the office operations, you handle filing of 21 documents with the Nevada Secretary of State, sometimes 22 you arrange for service of process of documents. 23 A Uh-huh. 24 You're generally responsible for staying 25 informed of changes to Nevada laws and complying with Electronically signed by Ellen Goldsleln (001-341-678-1457) OASIS REPORTING SERVICES, LLC 702-476-4500 dg? Document 100-3 Filed 03/16/15 Page 26 of 217 Case 2 Document 90-1 Filed 03/03/15 Page 22 of 50 Case Page 41 those Nevada laws. Is there anything else? A (Through the interpreter) Yes. We have a service between Mossack Fonseca and MF Nevada that in some cases we must sign documents for the purpose to legalize them in the state of Nevada, acting as a nominee service. So if I understand correctly, in some instances you're granted Powers of Attorney to sign documents on behalf of various entities. Is that right? A If the client requests signature to have legalized in Nevada, they authorize me and they put on I act on behalf to sign it as nominee service. They authorize you by granting you a Power of Attorney? A They grant me a Power of Attorney to sign this specific document here when they need to legalize, because otherwise it's no way to legalize document in this country or by consulate. THE REPORTER: Or by? THE INTERPRETER: Consulate. BY MR. HRANITZKY: Is part of your job to hold the position of assistant secretary, deputy secretary, or some other position in entities other than MF Nevada? A I was - I was Electronlcally slgnod by Ellen Golduoln (001-341-673-7457) 702-476-4500 OASIS REPORTING SERVICES, LLC Page 42 1 (Through the interpreter) I was assigned to 2 have the position of assistant secretary to other with 3 other corporations, nominee corporations, nominee 4 services, with the purpose to accelerate the process of 5 an incorporation or a legalization, but not anymore, but 6 I'm not doing that anymore. 7 On behalf of what entities did you perform that 8 role at one time? 9 A In the past I sign a document. I was signed 10 for Aldyne. 11 MR. HRANITZKY: A?l?d-y-n-e. You're going to hear 12 that one a lot. 2 13 THE WITNESS: Plascot. 14 BY MR. HRANITZKY: 15 Sorry. What was that? 16 A Plascot. i 17 Plascot? 18 A I think I give you some paper in that. I don't 19 remember right now. You need to have 20 Plascot, P-l-a?s?c?o?t? 21 A Uh-huh. 22 Okay. Any others? 23 A I don't remember any other ones, but normally if 24 they need some specific on that company, they mention or 25 they change they put me as the secretary just to sign, Eloctronlcally signed by Ellen Goldstain (001-341-678-7457) OASIS REPORTING SERVICES, LLC 702-476-4500 Document 100-3 Filed 03/16/15 Page 27 of 217 Document 90-1 Filed 03/03/15 Page 23 of 50 Page 43 Page 44 1 but in the past I don't do it. I resign it. 1 THE REPORTER: In What? 2 okay. Who asked you to take on that 2 THE INTERPRETER: "In some occasions." 3 responsibility? 3 BY MR. HRANITZKY: l" 4 A Well, Mossack Fonseca have agreement with 4 When did You become aSSiStant secretary to . .3 5 ME Corporate Service we need to provide the service. 5 Aldyne? 6 It's part of the service we need to provide to them. 6 A I have no idea- I don't know because I never 5 7 I see. So but 7 have the document with me. 8 A They can sign, anybody in my office. Because 8 Did You have to Sign any document in order t0 9 the only one I am, I have to sign it; but if I have 9 become aSSiStant secretary to Aldyne? 10 another one, they will Sign it too_ 10 A I don't remember. No, I don't remember. 11 So where does the request come from? 11 But you've signed documents as assistant 12 A (Through the interpreter) Usually it comes from 12 secretary to Aldyne? 13 the client. 13 A Uh-huh, in the past, yeah. 14 All right. So it was the client that requested 14 HOW frequently? 15 that you be made assistant secretary to Aldyne in order 15 A Depend how they it- 16 to Sign documents on behalf of Aldyne? 16 apprOXimate1Yr t0 the bESt 0f your 17 A (Through the interpreter) The customer request 17 reCOlleCtion' how Often did that happen? 18 Mossack Fonseca, and Mossack Fonseca uses the service 18 A In the Past was more Often than in the last 19 that is requested. 19 three or four year because they use this nominee more i? 20 So how did you learn that it was requested that 20 Often- 21 you become assistant secretary for Aldyne? 21 They used Aldyne more Often? _pq; 22 A Since the beginning they told me I need to sign 22 A Uh?hUhI for nominee SerViceS- I 1 23 document because this is part of the service, the 23 When You say "theyr" YOU mean Fonseca? 24 contract service they have in 24 A The client or Mossack Fonseca. I don't know 25 25 because I don?t know who. That's the instruction I . Case 2 Case 2 702-476-4500 OASIS REPORTING SERVICES, LLC OASIS REPORTING SERVICES, LLC 702-476?4500 Eloctronlcally slgnod by Ellen Goldman (001.341.673.157) Electronically signed by Ellen Goldsleln (001-341-678-7457) Document 100-3 Filed 03/16/15 Page 28 of 217 Case 2 14-CV-OO492-RFB-VCF Document 90-1 Filed 03/03/15 Page 24 0f 50 Case receive. I have the instruction more of But when you received instructi needed to sign documents as assistant se Aldyne, those came from Mossack Fonseca? A Yes. All the document came from Mossack Fonseca. MR. HRANITZKY: Okay. Why don't we second so that the videographer can chan THE VIDEOGRAPHER: This is the end 0 the deposition of Patricia Amunategui. record at 9:47 a.m. (Brief recess taken.) (At this time the video record The following proceedings were recorded only:) MR. HRANITZKY: 80, Miss Amunategui discussed over the break that we are no use the videographer. So you understand that? A (Through the interpreter) Yes, And that's okay with everybody? MR. WOODS: That's fine. BY MR. HRANITZKY: Okay. Just one follow?up quest the break: You mentioned that MF Nevada Page 45 ten in the past. ons that you cretary to break for a ge the tape. tape No. in Going off the was terminated. by stenography and Kent, we longer going to I understand. ion from before has a bank Electronically slgnod by Ellen Gold?ain (001-341-678?7457) OASIS REPORTING SERVICES, LLC 702-476-4500 How often do you get the bank statements? Page 46 1 account in Panama. 2 A Uh?huh. 3 And you get the bank statements but you don't 4 really study them; correct? 5 A No. Correct, yes. 6 What's the name of the bank? 7 A I don't know. 8 You get the bank statements and you don't 9 remember the name of the bank? 10 A You ask me the name. I need to have the paper 11 in my front to see the name. I don't know, 12 remember at this point. Once a month. And yet you don't have any idea what the bank No. I recognize the color of the paper, but I 18 don't remember at this time the name of the bank. Is it a Panamanian bank? No, Is it a U.S. Probably is a U.S. bank, not Panamanian. I don't know the name. A But it's not a Panama bank? No. bank with a branch in Panama? but I'm not sure. So, no. I don't' Elactronlcally signed by Ellen Goldslain (001-341-618-7451) OASIS REPORTING SERVICES, LLC 702~476?4500 Document 100-3 Filed 03/16/15 Page 29 of'217 Case 2 Document 90-1 Filed 03/03/15 Page 25 of 50 Case Page 47 But the account is in Panama? A Yes. And you just as you sit here now, you don't have a clue what the name of the bank is? A (Shakes head.) MR. WOODS: Is that a THE WITNESS: If I give you a name, probably I give you a wrong name. BY MR. HRANITZKY: Well, I don't want you to give me a wrong name. How about the bank that you use here in Nevada; what's the name? A Bank of America. Bank of America, but the bank in Panama is not Bank of America? A I don't think they have Bank of America in Panama, but it's not Bank of America. Okay. If you don't remember, you don't remember. A It's not a simple name, so probably that's the reason I don?t remember. Is it an English name? Probably. I don't know. A Is it a Spanish name? A No, not Spanish. OASIS REPORTING SERVICES, LLC Electronically signed by Ellen (001-341-075-7451) 702-476-4500 Page 48 1 So you don't think it's a Latin American bank? 2 A No. 3 Okay. I'd like you to look now at the second 4 page of your Employment Agreement, which is Exhibit 1. 5 Do you see paragraph Noreads, "The existence and substance of this agreement 7 shall not be made known to anyone other than the parties 8 thereto and their professional advisors unless mutually 9 agreed"? 10 A I think I'm lost. I'm in the wrong page. 11 MR. WOODS: Part of the problem is it starts on 12 page 4 or starts on one page and goes to the next. 13 MR. HRANITZKY: Sure. 14 Look at the second page of the contract. 2 15 A This one (indicating)? I 16 MR. WOODS: Right. 17 BY MR. HRANITZKY: 18 Yes, the paragraph No. 4. 19 A Okay. 20 Now, on the bottom of that page, that last line: 21 it reads, "The existence and substance of this agreement? 22 shall not be made known to anyone other than the parties) 23 thereto and their professional advisors unless mutually 24 agreed." Do you see that? 25 A Yes. Electronically slgned by Ellen Goldstoln (001-341-613-1457) OASIS REPORTING SERVICES, LLC 702-476?4500 Document 100-3 Filed 03/16/15 Page 30 of 217 Case 2 Document 90-1 Filed 03/03/15 Page 26 of 50 Case Page 49 Did I read that right? A Yes. Before today, do you recall reading that provision? A No. Were you aware that that provision was in this contract? A I was aware that they have some privacy on the contract, but I was not aware of that, and I read the contract with my attorney before I provide it to him. So you asked an attorney to review this contract A Uh?huh. before you signed it; is that right? A Yes, before, like many years ago. Who was the attorney? A Was one professor I have at the UNLV and I asked him if he can that will be okay to sign this contract. He say it look like it's fine and, yes, I sign it. Who was that? A Mr. Richard Linstrom. Linstrom? A Linstrom, yes. L-i-n-s-t-r-o-m? A Yeah. Was an attorney from UNLV. OASIS REPORTING SERVICES, LLC Electronically signed by Ellen (001-341-575-7457) 702-476-4500 Page 50 1 I see. Do you know if Richard Linstrom inquired 2 into how Mr. Mossack or Mr. Fonseca had authority to sign 3 the contract on behalf of MF Nevada? 4 A No. I only bring this as a draft and just to 5 give me an advice is it okay to sign this contract. 6 Did the draft have Mr. Mossack and Mr. Fonseca's 7 names on the signature lineonly bring the draft before the 9 document was ready. 10 So but just to be clear, I understand you showed 11 it to him before it was signed. 12 A Yes. 13 What I'm asking is if their names appeared below 14 the signature linesthe document you showed Mr. Linstrom didn't 19 identify who would be signing on behalf of ME Nevada? 1 20 A Uh?huh. 21 And Mr. Linstrom thought that was fine? 22 A Yeah. They say that whatever the contract say 23 is fine, yeah. I sign it and I send it back. 24 Okay. But before just today, you don't recall 25 ever seeing the language that we just went through at the Electronically slgned by Ellen Goldsleln (om-3414134451) OASIS REPORTING SERVICES, LLC 702-476-4500 Document 100-3 Filed 03/16/15 Page 31 of 217 Case 2 Document 90-1 Filed 03/03/15 Page 27 of 50 Case NevadaOkay. 25 Fonsecadidn't ask that. 22 whether well, 23 A Yeah. 24 1 bottom of paragraph 4 - is that right? Do you have an understanding about whether it's 6 okay for you to publicly disclose the fact that you work I understand that if you have by the Court 9 order, you need to disclose when they ask you. I'm asking a different question. Do you have an understanding as to whether 13 you're prohibited from disclosing publicly the fact that 14 you work for Mossack - or work for MF Nevada? This is the first time I realize that. Do you have an understanding about 17 whether you're prohibited from disclosing publicly that 18 you work sometimes with Mossack Fonseca? I never work for Mossack Fonseca. 21 I asked whether you have an understanding about let me strike that. You've said that you don't work for Mossack I didn't say "work for." Page 51 OASIS REPORTING SERVICES, LLC Eloctronlcally signed by Ellon Goldstain (001-341-875-1457) 702-476-4500 dam2754a7vM7o-baaz-tmod92daso Page 52 1 A No, I don't. 2 But you do work with Mossack Fonseca; correct? 3 A I don't know what to say. I feel like I work 4 for this company, MF Corporate Services, and I work for a 5 client called Mossack Fonseca. 6 Okay. So you do work with Mossack Fonseca? 7 A As a client, yes. 8 Okay. Do you have an understanding about 9 whether you have an obligation to keep the fact that you 10 work with Mossack Fonseca as a client confidential? 11 A Oh, yes, yes, we have a confidentiality. Yes, I 12 do. I have I mean I can't disclose that 4- if I 13 decide don't work for them anymore, of course I can't 14 disclose anything. 15 All right. But are you permitted to disclose I 16 the fact that Mossack Fonseca is a client that you work i 17 for? 18 A Say that again. i 19 THE INTERPRETER: Say it again. 3 20 BY MR. HRANITZKY: 21 Are you permitted to disclose the fact that 22 Mossack Fonseca is a client that you work for sometimes? 23 A I hope so, yeah. I don't know. 24 You've never thought about that? 25 A I never thought about it. Electronically slgned by Ellen Goldstain (001-341-673-1457) OASIS REPORTING SERVICES, LLC 702-476-4500 Document 100-3 Filed 03/16/15 Page 32 of 217 Case 2 Document 90-1 Filed 03/03/15 Page 28 of 50 Case Page 53 So you don't have any understanding of whether you're supposed to keep that confidential? A No. I don't know. So going back to the first page, the paragraph numbered 1, the final sentence it reads, "The employer shall direct and control all of the details of the employee's work and the employee shall report, with respect to her work assignments, to the employer." Do you see that? A Uh?huh. Is that consistent with your understanding of your Employment Agreement? A Uh?huh. Okay. And the employer is MF Nevada; correct? A Yes. So who directs and controls all of the details of your work? A Myself. I mean I am my own boss. I am responsible for all the thing I need to do. So you give yourself instructions? A No, I don't give myself instructions, but I get; the instruction for my client what they need. But the contract says, "The employer shall direct and control all of the details of the employee's work." Do you see that? OASIS REPORTING SERVICES, LLC Electronically signed by Ellen Goldsleln (001-3414784457) 702-476-4500 Page 54 A Uh?huh. 2 Okay. So where do the directions come from? 3 A From the client request. 4 So the clients communicate directly to you their 5 instruction? 6 A The only client we have. We don't have multiple 7 clients. We have only one client. They send instruction 8 to us. 9 And that's Mossack Fonseca? 12 10 A (Nods head.) 11 Is that Mossack Fonseca Company? 12 A Mossack Fonseca is the only thing I know. 13 So an entity called Mossack Fonseca Co., 14 that's what you're referring to by "Mossack Fonseca"? 15 A Yes. That's the only company I know. 16 Okay. And that's where you get the directions 17 from; right? 18 A Uh-huh. I get the direction for the Nevada sale 19 because - 20 Probably better to do it in Spanish. 21 A Yeah. I get the direction for the office 22 (Through the interpreter) There's instructions. 23 I receive them from the department and the client, who 24 has specific instructions for the client in Nevada. 25 Okay, sorry. I'm sorry, I didn't understand OASIS REPORTING SERVICES, LLC Electronically slgned by Ellen Goldmaln (001-3416184457) 702-476-4500 Document 100-3 Filed 03/16/15 Page 33 of 217 Case 2 Document 90-1 Filed 03/03/15 Page 29 0f50 Case Page 55 that answer. You get some directions and instructions from Mossack Fonseca; correct? A (Nods head.) Do you get directions and instructions from anybody else? A Only for one department. They specify and attend clients buy Nevada companies. I'm sorry. I don't understand the answer. A The only person I'm in contact for instruction there are how do I explain department. Try it in Spanish and if let me suggest A (Through the interpreter) The people, the customers that are going to buy the companies in Nevada - (In English) They have assign to one person, two person, in one small department from Mossack Fonseca. This person are in contact with me to give me, "Check this name," "Please incorporate this," client need a company with this characteristic." That's the only person that I in contact. So you're saying that your directions come from one particular department within Mossack Fonseca? A (Through the interpreter) Sales. The sales department? Electronically slgnod by Ellen Goldaloln (001-341-616-7457) OASIS REPORTING SERVICES, LLC 702-476-4500 Page 56 A Yesyour directions 3 and instructions come from the sales department - 4 A Department. 5 at Mossack Fonseca? 6 A The sale department for the only product I sell, 7 for Nevada. 8 The sales department for Nevada? 9 A Yeah. 10 Okay. So all of your instructions and 11 directions come from the Mossack Fonseca sales department 12 for Nevada; is that right? 13 A Oh, yes. 14 And who is that? 15 A Can be they change it many times, so it's not 16 always the same, but right now it's one person they call 17 Iris Vergara. 18 Like iris the flower? 19 A Iris Vergara. 20 Vergara? 21 A Vergara. 22 THE INTERPRETER: V-e-r?g-a?r-a, Vergara. 23 BY MR. HRANITZKY: 24 It's a funny last name. 25 A In Chile we have a lot of those. Everybody OASIS REPORTING SERVICES, LLC Electronically signed by Ellen Goldsteln (001-341-678-7457) 702-476-4500 Document 100-3 Filed 03/16/15 Page 34 of 217 Case 2 Document 90-1 Filed 03/03/15 Page 30 of 50 Case Page 57 called Vergara. Okay. I'd like you to look now at paragraph No. 8 in Exhibit 1. A We still in the contract, no? Yes. A Okay. Do you see towards the end after the semicolon it reads, "It is understood that the employee" - that's you "shall have all of her communication solely with the employer and its representatives"? A Oh, yeah, okay. Do you see that? A Uh-huh. Is that consistent with your understanding of your employment arrangement? A Yes. So you have all of your communications solely with MF Nevada and its representatives? A Uh?huh. So the people in the Nevada sales office at Mossack Fonseca are representatives of NE Nevada; correct? A No, I don't think so they're representatives. But your employer is MF Nevada; right? A MF Corporate Nevada. Electronically slgnod by Ellen Goldslaln (001-341-618-7451) OASIS REPORTING SERVICES, LLC 702-476-4500 Page 58 contract says that you shall have all of your communications solely with the employer, NE Nevada, or its representatives; right? A employees. A the additional option to pay bonus compensations to the employee at its discretion"? A A or does somebody else make that decision? A getting paid a bonus since you've worked for ME Nevada? A they sent me a letter with the option that I can get paid Right. And this provision in your employment Maybe they are representatives. They're not Okay. Can you turn to paragraph 15. Fifteen? The last one here? Yes. You see it says, "The employer reserves Uh?huh. Have you ever been paid a bonus? Yeah, sometimes. Do you decide on whether to pay yourself a bonus The president of the company take the decision. And that's Imogene? Imogene Wilson. Imogene Wilson? Uh-huh. Have you ever spoken to Imogene Wilson about No. I never ask for it. There's some Christmas Electronltally signed by Ellen Goldslain (001-341-678-7451) OASIS REPORTING SERVICES, LLC 702-476-4500 Document 100-3 Filed 03/16/15 Page 35 of 217 Case 2 Document 90-1 Filed 03/03/15 Page 31 of 50 Case Page 59 bonus. I see. The option to be paid a bonus you said? A Uh-huh. So they asked you, "Would you like to be paid a bonus this year, Patricia," and you say "yes" or A I will say yes of course. Are there any strings attached? A Sometimes they request if I recommendation on what I believe I deserve for bonus for Christmas or when we have employees. In the past we have employee working for us. Now we have Manpower temp, but they ask what will be our recommendation, if we feel it, for Christmas. How often has that happened? A Not very often. Not very often? A Not very often. When was the last time MF Nevada had other employees? A Let's see. 2011 probably, 2011 and '12 probably. I'm not sure. And after, with all this inconvenient to hire and fire, we decide to use Manpower temp. It's more easy. How many other employees did MF Nevada have during that time? A We used to have three, myself and two more. Electronlcally slgnod by Ellen Goldnoln (001-3414784457) OASIS REPORTING SERVICES, LLC 702-476-4500 Page 60 1 And what did the other two people do? 2 A Work office help. When I?m very busy I can't do 3 all the document by myself. So they help to prepare 4 Article of Organization, Excel with invoices, and all the 5 other stuff, the office things we need. 6 So they did the same things that you do? 7 A Not all the same things but almost. They're 8 very well trained in almost the same but no signing of 9 course; but they help me in all the office things, answer 10 the phone and prepare stuff and I sign. 11 MR. HRANITZKY: You got the "pero" as a but. 12 THE WITNESS: Oh. 13 BY MR. HRANITZKY: 14 The court reporter picked that one up. Believe 15 it or not, sometimes even I do that. 16 A Really? 17 Yeah. There's something about "pero" that just 18 slides right off the tongue. 19 A In the casino they call me Mrs. Pero because I 20 always say "pero." 21 MR. WOODS: Because it uses the same parts of your 22 mouth. 23 THE WITNESS: Yeah. 24 MR. HRANITZKY: "But" sort of gets in the way and 25 "pero" just sort of slides. Electronically slgned by Ellen Goldslain (001-341-678-7457) OASIS REPORTING SERVICES, LLC 702-476-4500 Document 100-3 Filed 03/16/15 Page 36 of 217 Case 2 14-CV-OO492-RFB-VCF Document 90-1 Filed 03/03/15 Page 32 Of 50 Case Page 61 THE WITNESS: Pero slides. BY MR. HRANITZKY: Could you look now at paragraph 16. A That will be a good review of my contract. It's always good to look at it again. A It's always good, yeah. You see there's a reference to commission compensation? A Uh?huh. Do you ever receive commission compensation? A No, and I'm very mad. No, never. Never? A No. Have you ever discussed the possibility of being A Yes. Being paid 3:4 Yes, but never happened. Who did you discuss that with? A With the marketing department in one of my presentation; and they say will be an option, but I never have. Who in the marketing department? A I don't remember who was at that time because it's a long time ago. Probably is not there anymore, but Electronically algned by Ellen Goldstoln (001-341-673-1451) OASIS REPORTING SERVICES, LLC 702-476-4500 Page 62 I requested and they say, "Well, maybe," and it never 2 happen. 3 And that's the marketing department at Mossack 4 Fonseca? 5 A Yes. 6 Are they based in Panama, that department? 7 A I believe so. 8 All right. Could you look now at paragraph 19, 9 the second sentence. It reads, "The employee shall be 10 provided the name of a contact person in the employer 11 organization regarding each assigned project." a 12 A Uh-huh. 13 The "employer organization," does that refer to? 14 Mossack Fonseca? 15 A I don't know, but 16 But in practice that's the way it works; right?; 17 A I don't know. 5 18 Well, when you get the name of a contact person: 19 for each assigned project, you get it from somebody at I 20 Mossack Fonseca; right? 21 A With the only person I get 22 THE REPORTER: I'm sorry. I didn?t understand that. 23 THE WITNESS: (Through the interpreter) The only 24 person that I have contact with for an assignment or job, 25 instructions is Mrs. Vergara. Electronically signed by Ellen Goldsteln (001-341-618-1457) OASIS REPORTING SERVICES, LLC 702-476-4500 Document 100-3 Filed 03/16/15 Page 37 of 217 Case 2 Document 90-1 Filed 03/03/15 Page 33 of 50 Case Page 63 BY MR. HRANITZKY: Iris Vergara? A Iris Vergara. So that's in practice A In practice. the contact you receive the names of contact persons for each assigned project from Iris Vergara; correct? A For all the incorporation, because (Through the interpreter) The only instruction that I receive daily is preparations for companies that need to be incorporated. You see what the client needs. The other instructions I have on my own by myself. (In English) I manage the office. I don't have nobody give me instructions how I do. So but you don't give yourself the name of the contact person at the client, do you? A No, no, no. The only contact and instruction I have daily is from the sale department. And Iris Vergara? A Iris Vergara or whatever is replacing her at this point. I don't remember name, but she is the person who tell me, "This is the company we need. Check, please. Give me a name and ability," or whatever, whatever regarding sale. OASIS REPORTING SERVICES, LLC Eloctronically signed by Ellen (001-341-613-7457) 702-476-4500 Page 64 1 Do you ever get requests from people at Mossack 2 Fonseca's affiliates in Uruguay or in Peru or in 3 Switzerland? 4 A I probably get phone call from them to request 5 something, but I need to I'm prohibited to accept 6 instruction from them. So I need to tell them go back 7 and tell Iris give me the instruction. 8 So you never get E-mails from any of those 9 places with requests for 10 A Probably I will do one time in the past. I 11 don't remember, but if that happened, it's because 12 they the time sometimes. They want to get the 13 information first to me and I need to forward to Iris 14 Vergara or the person in charge at that time. I can't 15 respond them. 16 But the standard practice is that the 17 instructions would come from Iris Vergara? 18 A Yes. 19 Could I ask you you see after the employment; 20 contract in Exhibit 1 there's a letter 21 A Uh?huh. 22 on MF Corporate Services Nevada Limited 23 letterhead? Do you see that? 24 A Uh?huh. 25 And the letter is signed Katia Solano. signed by Ellen Goldsleln (001-341-673-7457) OASIS REPORTING SERVICES, LLC 702-476-4500 Document 100-3 Filed 03/16/15 Page 38 of 217 Case 2 Document 90-1 Filed 03/03/15 Page 34 of 50 Case Page 65 A Uh-huh. Who is Katia Solano? A Katia Solano was the person in human resource I believe. Well, it says on the letter she's in human resources and the letter is on MF Nevada letterhead. A Uh-huh. Does NF Nevada have a human resources department? A No, not here, but in the contract agreement we share some services with them, Mossack Fonseca. So Mossack Fonseca provides some back?office services to ME Nevada? A Sometimes, yes. And one of those is human-resources support? A Uh-huh. Do you know where Katia Solano was based? A No. I can assume in Panama, but I don't know. Did you ever speak with Katia Solano on the phone? A A couple time in my life, yes. How often? A Maybe two or three time in my entire life. Okay. Do you know who employed her? A No, no idea. Electronically signed by Ellen Goldstoin (001-341-670-7457) OASIS REPORTING SERVICES, LLC 702-476-4500 Page 66 page of A referenc A A and some correct? A A So if I could ask you to turn back to the first the letter There (indicating)? Right there, right. Do you see in the very first paragraph there?s a to "your letter dated July lst, 2007"? Yes. Did you write a letter on July lst, 2007? To her? Yes, I think so, yeah. And in the letter you were asking for a raise other improvements to your compensation package; Uh?huh. Is that "yes"? Yes. Just for the benefit of the court reporter. I'm not trying to be difficult. A No, no, no, yeah. Her job is challenging as is. You see in the next sentence it says, "Please find below the partners' response to the different subjects A A Yes. Who are "the partners"? I don't know. I don't know. OASIS REPORTING SERVICES, LLC Elactronlcally slgned by Ellen (001-341-678-1457) 702-476-4500 Document 100-3 Filed 03/16/15 Page 39 of 217 Document 90-1 Filed 03/03/15 Page 35 of 50 Page 67 Page 68 1 You have no idea? 1 MR. HRANITZKY: And I'm challenging that and I'm 2 A I don't know any idea_ 2 going to continue to do that. 3 Do you think it's the partners of Mossack 3 MR. WOODS: It's an objection. I made my objection. 4 Fonseca? 4 MR. HRANITZKY: I hear you. 5 A No. I probably believe that's the partner of 5 so You're saying that: as Secretary Of MF Nevada 6 MF Corporate ServiceS. 6 for 13 years, you have no idea who the partners of 7 Well, you're the secretary of ME Corporate 7 ME Nevada are bot You think they 8 Services; so if they had any partners, you would know 8 A well: the only reason I know it'3 exist is 9 about them, wouldn't y0u? 9 because I have some document of MP Corporate Services, 10 A They have another company who is the 10 not here but in the office, where I have the Article of 11 shareholder. 11 Organization and some information who is the shareholder, 12 What is that company? 12 but I don't have any other document. So I assume that 13 A I'm sorry, but I don't know exactly the name, 13 partners are the SharehOlder- 14 but Timberlane Associates or something. 14 Bot the Word here is "Partner-" It's not 15 Timber? 15 "shareholder"; right? 16 A Timberlane Associates, 16 A Well, I will tell you, the Spanish people, they 17 Timberline Associates? 17 call "partner" everything. So partner can be the 18 A Timberlane Associates is all I remember_ 18 shareholder. Partner can be the couple. I understand 19 And you think the reference to ?the partners" is 19 their Vocabulary or they try to say- 20 the partners in Timberline Associates? 20 so Your underStanding Of this letter is that 21 A I think the partners of MP Corporate Services. 21 Ms- SOlano meant SharehOlderS 122 But - 22 A Yeah. 23 MR. WOODS: We're going to do an objection. I mean 23 when she used the word "partners"? 24 she's said that she doesn't know what it means many 24 A Yeahl that's What I think 50- 25 times. 25 And that would be the shareholders in ME Nevada Case 2 Case 2 702-476-4500 OASIS REPORTING SERVICES, LLC OASIS REPORTING SERVICES, LLC 702-476-4500 Electronically slgnod by Ellen Goldsteln (001-341-618-1457) slgned by Ellen Goldateln (001-341-618-1451) Document 100-3 Filed 03/16/15 Page 40 of 217 Case 2 Document 90-1 Filed 03/03/15 Page 36 of 50 Case Page 69 listed in the Articles of Incorporation? A Not the Articles of Incorporation because I believe they are not listed there. Listed in the document? A Whatever document they have. I don't have any document of that. So they probably refer to any party. I don't know. Well, you said a few minutes ago that you have a document, not here but back in the office, that lists the shareholders in MF Nevada; right? A Yeah. Didn?t you just say that? A Uh?huh. So do you or do you not have that document back at the office? A I have the name, but I don't have any documents, documents. I don't have any bylaw of this company on me. But you have the names? A But I have the name. And those names presumably are on a document, yes? A No. They are in the writing, not in a document. Well, if it?s in a writing, that?s a document, isn't it? A Well - Electronically signed by Ellen Goldsteln (001-3416784457) OASIS REPORTING SERVICES, LLC 702-476-4500 Page 70 1 Unless it's on a cassette tape; right? 2 A No, no cassette tape. 3 So there's a document with those names somewhere 4 back in your office? 5 A Somewhere, yeah. 6 And the names 7 A With the name of the company I tell you, 8 Timberlane Associates. I don't remember even the name, 9 the correct name. 10 And that document lists the names of the 11 shareholders in ME Nevada? 12 A No, that document don't list any shareholders. 13 It's a name with a document with a company, that's all, 14 and lists who are the shareholders. I don't know nothing 15 about it. I know the name because that's what they say 16 in the little corporate kit I saw. And I came to work 17 for this company after it was incorporated, after 18 everything was settled, so I don't have that information. 19 Never give it to me. 20 Okay. So when you said before that you have a 21 document that lists the names of the shareholders, you 22 didn't mean that. Is that what you're saying? 23 A Say that again, please. 24 I said, when you testified before that you have 25 a document back in the office that lists the Electronically slgned by Ellen Goldsteln (001-341-673-1457) OASIS REPORTING SERVICES, LLC 702-476-4500 Document 100-3 Filed 03/16/15 Page 41 of 217 Case 2 Document 90-1 Filed 03/03/15 Page 37 of 50 Case Page 71 shareholders, you didn't mean that? A Yeah, no. You're changing your answer now? A Yeah, I change my answer. I never have a document with a list of the shareholders, never. I only know the name of the one, that one. That?s Timberline? A Yeah, but I have no idea who are the name of that company. You said you only have one and you identified Timberline? A Well, Timberlane is the only company I familiar with who is the shareholder. If you ask me who own thatk company, I don't have no idea. Are there any other shareholders besides Timberline? A I don't have no - You don't know? No, I don?t know. But you're the secretary of MP Nevada? YesAnd you don't View that as being part of your job as the secretary to the board of directors of ME Nevada? Electronically signed by Ellen Goldslaln (001-341-678-7451) A Probably was part find OASIS REPORTING SERVICES, LLC 702-476-4500 Page 72 1 it, but they never give it to me. 2 Okay. Could you look at paragraph 3 of this 3 letter. 4 A Of this one? 5 Yes. It's the letter dated August Blst, 2007 6 that we've been talking about. 7 A Uh-huh. 8 You see paragraph 3? 9 A Yeah. 10 It refers to Mossfon International Retirement 11 Plan. 12 A Uh-huh. 13 So are you covered under the Mossfon 14 International Retirement Plan? 15 A Well, I try to find my 401K or something here 16 and it was not convenient, and they say they have some in 17 Panama for the other employee, and voluntary I choose to 18 be in this one. i 19 So you're covered by the Mossfon International 20 Retirement Plan? 2 21 A But my plan is separate. It's a voluntary plan, 22 I mean not with the rest of them, because I'm not part of 23 Mossfon. 24 I didn't ask you that. I asked you are you 25 covered by the Mossfon International Retirement Plan? Electronically signed by Ellen Goldslain (001-3414784457) OASIS REPORTING SERVICES, LLC 702-476-4500 Document 100-3 Filed 03/16/15 Page 42 of 217 Case 2 Document 90-1 Filed 03/03/15 Page 38 of 50 Case Page 73 A I have a different plan of retire in Panama. They don't call Mossfon International Retirement Plan. They call different. So this letter is wrong; is that what you're saying? A I believe the letter is wrong because they probably offer the 4 percent of contribution to their international plan, but in myself, I'm in different plan with a 4 percent. So I'm not employed with them, so I have to be in separate plan. So where Ms. Solano from human resources says in her very carefully written letter that Mossfon will contribute 4 percent of your salary as long as you save the same amount, you're saying that she's just wrong. Is that right? A Probably she's wrong. Probably she?s wrong? A Uh-huh. You're not sure? A I'm not sure because she called the retirement plan different than the plan I have. Do you receive any statements or other documents - A Yes, I receive my statements. from the retirement plan? OASIS REPORTING SERVICES, LLC Eloclronically signed by Ellen Goldslein (001-341-318-1451) 702-476-4500 Page 74 1 A Yeah. 2 Does it have sort of a name of a plan on the 3 statement? 4 A Yeah. It's called different. Well, do you know where the 4 percent comes From my check. I send it from my check. But you give 4 percent and somebody else gives 9 4 percent; right? 10 A Mossfon MF Corporate Service pay the 11 4 percent. 12 So in this letter where Ms. Solano says Mossfon 13 will contribute 4 percent of your salary as long as you 14 save the same amount, you?re saying she's wrong? 15 A She's probably wrong on this paragraph because 16 she mention the Mossfon International Retirement Plan 17 when I have different plan. The only thing is the amount 18 is correct. 19 But it's not Mossfon that contributes 4 percent? 20 That's what you're saying? 21 A No, yeah. 22 So you're saying she's wrong about that? 23 A She's wrong about the name of the retirement 24 plan. 1 25 But I'm not asking you that now. You already 702-476~4500 OASIS REPORTING SERVICES, LLC Electronlcally algnad by Ellen Goldsloln (001-341-613-7457) Document 100-3 Filed 03/16/15 Page 43 of 217 Case 2 Document 90-1 Filed 03/03/15 Page 39 of 50 Case Page 75 said that. Now I'm asking who contributes the other 4 percent to the retirement plan. A MF Corporate Service. Okay. So when Ms. Solano says it's Mossfon that contributes 4 percent - A It's wrong. You're saying she's wrong? A Yeah. So Ms. Solano is wrong about a lot of things in this letter. A Yeah. Even the address of the letter is wrong too. We don't have an office in Nevada in Reno, Nevada, never. I never was in Reno, Nevada. How did you get this letter? By E?mail. Could you look at the last paragraph of the letter. A Uh-huh. Do you see it says, "The partners are very pleased with your performance and commitment and count on your assistance for many years to come"? A Uh?huh. You're saying that you have no idea who those partners are. Is that right? A Yeah. I assume it's Timberlane. OASIS REPORTING SERVICES, LLC Electronlcally signed by Ellen Goldsleln (001-341-673-7451) 702-476-4500 Page 76 1 You think that it's Timberline is very pleased 2 with your performance and commitment and counts on your 3 assistance for many years to come? 4 A Uh?huh. 5 Have you ever met anyone from Timberline? 6 A No. 7 Then how could they possibly be very pleased 8 with your performance and commitment? 9 MR. WOODS: Objection; that's obviously speculation. 10 THE WITNESS: Well, because they believe how I manage 11 the company. That's what I believe it is. 12 BY MR. HRANITZKY: 13 Well, if you don't know who they are, how could 14 they possibly know how you manage the company? 15 A They have - I don't know. I do a good 16 performance on the work and they probably know. 17 But you don't know who they are? 18 A No, I don't know who they are. 19 And they're making the decisions about your 20 employment package? 21 A Yes. 22 And they're pleased with your performance? 23 A Uh?huh. 24 And your fate is in their hands, as it were, but 25 you have you don't have a clue who they are? 702-476-4500 OASIS REPORTING SERVICES, LLC Electronically signed by Ellen Goldslain (oo1-341-o1a-1457) re" 1? Document 100-3 Filed 03/16/15 Page 44 of 217 Case 2 Document 90-1 Filed 03/03/15 Page 40 of 50 Case Page 77 A No. I don't know where they are and I never meet them. Does that make you uncomfortable at all? A Many times, yeah, I wish I know them, where they are. Do you ever read in the newspaper reports about Mossack Fonseca being involved in money-laundering activities? A I don't read the newspaper for foreign, but I get some information about it; but when I decide to get hired for this work and they told me who will be the client, I checked them and was a very prestigious law firm. So I really don't believe they are in any - you know, laundering money. Okay. Well, but you've read those allegations in the news, have you not? A Yeah. I read many allegations about everything and maybe I sometimes have to believe half of what they say. All right. But you don't believe them even though you don't really know who the people are; is that right? i A Well, I know other people there and I know they're very good attorneys when I go for my meeting. So and I learn that their job they do and it's Electronically signed by Ellon Goldslaln (001-341-6757457) OASIS REPORTING SERVICES, LLC 702-476?4500 Page 78 1 completely against to that, so they're very particular to 2 choose a client. 3 MR. HRANITZKY: Why don't we take a break. 4 (Brief recess taken.) 5 (Plaintiff's Exhibits were 6 marked for identification by the Certified Court 7 Reporter.) 8 BY MR. HRANITZKY: 9 Just a couple of quick follow?up questions from 10 before the break and then 11 A So go back to the same paper? 12 No, you don't have to go back. 13 A Okay. 14 Do you know when ME Nevada was created? 15 A Probably May 2000 or 2001. I'm not sure. 16 Not long before you started there? 17 A Uh?huh. 18 And one other question: You said before that 19 you're currently the only employee of NE Nevada that you 20 know about? 21 A At the moment. 22 There were two others in 2011 and 2012? 23 A Yeah, and 25 and 26 before we got employees 24 THE REPORTER: I didn't understand you. 25 THE WITNESS: (Through the interpreter) During 2005 OASIS REPORTING SERVICES, LLC Electronlcally signed by Ellen Goldsteln (OM-34143184451) 702-476-4500 dc74a27 5-4317-4479-b032-fc406d92d860 Document 100-3 Filed 03/16/15 Page 45 of 217 Case 2 Document 90-1 Filed 03/03/15 Page 41 of 50 Case Page 79 or that I don't recall. (In English) I have we have more employees. All right. And what did those employees do? A The same. They are assistant, like a clerk. Was there ever a time where you reported to someone at MF Nevada who was an employee of ME Nevada? A (Through the interpreter) Can you please repeat the question. Sorry. Was there ever a time when you reported to another employee at MF Nevada? A (Through the interpreter) That I would have had to report to another MF Nevada employee? Yes, another MF Nevada employee who was senior to you at MF Nevada. A Yeah, I believe Nancy. At the very beginning? A At the very beginning, yeah, she was my direct boss. And that was for a short time? A Yeah, that was for a short time, yeah. All right. So I'd like you to take a look at the document that's been marked as Exhibit 2. I think you have them out of order. You may have them out of order. Do you recognize Exhibit 2? OASIS REPORTING SERVICES, LLC Elecuonlcally Ilgned by Ellen Goldsleln (001?341-613?7451) 702?476-4500 Page 80 1 A I recognize my picture. 2 Other than your picture, you've never seen this 3 document? 4 A No. I see this document was in magazine at 5 UNLV . 6 Did you speak to UNLV about this advertisement 7 before it was released? 8 A Yes. They call me if I can help them to give my 9 story in order to promote paralegal course. 10 The paralegal program at 11 A Uh?huh, and I say yes and I'm glad to do it, so 12 I speak with different two people in the phone I 13 believe. I don't remember many detail because that's 14 long time ago; and I give a little bit of my story, but a 15 lot of these thing, they're not true. 16 Okay. When was that? 17 A May 2010 or 2009. I don't remember. 18 Did they take the picture for this or did you 19 give them a picture? 20 A No. They take my picture. I have to go to a 21 special place to take the picture. 22 It's a good picture. 23 A Yeah. I keep it. 24 But you think it was about 2009? 25 A I don't remember. 2009 maybe. I don't OASIS REPORTING SERVICES, LLC Electronically slgnad by Ellen Goldstoln (001-341-618-1451) 702-476-4500 Document 100-3 Filed 03/16/15 Page 46 of 217 Case 2 Document 90-1 Filed 03/03/15 Page 42 of 50 Case Page 81 remember. Was like around Christmastime probably because I remember being very busy around that time. Did you discuss the fact that you had been asked to agree to this advertisement with anyone at Mossack Fonseca before you - A No. said yes? A No, no, I never discuss with them because I thought it was something personal of myself and I don't. No, I didn't. Well, when you spoke to the people who prepared this advertisement, did you mention Mossack Fonseca? A Maybe. I don't remember, but I mentioned there I was working for MF Corporate Services and I provide service for Mossack Fonseca maybe. I don't remember exactly, but here is not right. So what in this advertisement do you believe is mistaken? A Okay. The vice president and vice president for MF Corporate Services; I was at that time, because now I'm a secretary. And also, I didn't work for Mossack Fonseca. I worked for MF Corporate Services when I was vice president at that time and I provide service for a very prestigious law, Mossack Fonseca International. You've never seen MF Nevada referred to as the Electronically signed by Ellen Goldslein (001-341-678-1457) OASIS REPORTING SERVICES, LLC 702-476-4500 Page 82 1 Nevada office of Mossack Fonsecaletter before, you see 3 they calling - 4 You're talking about Exhibit 1? 5 A Talking about this. 6 At the end, the letter 7 A They call Mossfon Nevada. Well, it's a big 8 mistake. 9 I'm asking something different. I See that. 10 Let's put it back in order. I'm asking something 11 different. 12 The letter in Exhibit 1 dated August 31, 2007 13 refers to Mossfon Nevada and you say that's wrong? 14 A That's very wrong. 15 Okay. I'm asking you something different. I'm? 16 asking you whether you've heard ever heard MF Nevada 17 referred to as the Nevada office of Mossack Fonseca? 18 A Not from me. 19 You've never heard it referred to that way? 20 A I don't refer Nevada office of Mossack Fonseca.; 21 MR. WOODS: Just make sure you're answering the 22 question. 23 BY MR. HRANITZKY: 24 I didnasked you if you5 25 had ever seen it referred to that way. 5 Electronically signed by Ellen Goldstein (001-341-673-7457) OASIS REPORTING SERVICES, LLC 702-476?4500 Document 100-3 Filed 03/16/15 Page 47 of 217 Case 2 Document 90-1 Filed 03/03/15 Page 43 of 50 Case Page 83 A Not that I can remember, nor can I pay attention. So you don't recall ever seeing that? A Well, I don't pay attention probably, no. You don't pay attention even though you're the secretary of ME Nevada? A I am, but no. You said that you used to be the vice president of ME Nevada? A Uh?huh, secretary and vice president. How long were you vice president? A Don't remember. For a short period of time because probably in the next renewal I changed. I don't like to be a vice president of anything, so I changed. All right. But you said this letter or this advertisement dates from around 2009? A Yeah. So probably at that time probably I changed after that. You know, at that time I was vice president of MP Corporate Service Nevada. Had you been vice president all the way from 2001 to the time that this advertisement came out? A Maybe. You don't remember? A I need to check. Were you vice president when you started at OASIS REPORTING SERVICES, LLC Electronically sigma by Ellen Goldsleln (om-341.013.1451) 702-476-4500 Page 84 1 MP Nevada? 2 A Yes. 3 And you were vice president when this 4 advertisement came out? 5 A Probably. I don't know, yeah. 6 Were you vice president and secretary at the 7 same time? 8 A Yes. 9 Did you have any other titles? 10 A No. Just manager like I do now. 11 So you had three titles, manager, secretary and 12 vice president? 13 A Uh-huh, yes. 14 And now you have two titles? 15 A Yes. 16 Manager and secretary? 17 A Yes. 18 And it was your decision to stop being vice 19 president? 20 A Was not my decision, but the person hire me, 21 Nancy, she file the document with the Secretary of State 22 and she put that title; and then I decide - I don?t 23 remember when - I decide it was too much title. The 24 Secretary of State only asks you for secretary, president 25 and treasurer. Why I want to use two titles? Even I OASIS REPORTING SERVICES, LLC Electronically slgnod by Ellen Goldslain (001-341-678-7457) 702-476-4500 Document 100-3 Filed 03/16/15 Page 48 of 217 Case 2 Document 90-1 Filed 03/03/15 Page 44 of 50 Case 2 Page 85 1 don't have space to put it in, so I decide to choose for 2 secretary. 3 But it was your decision - 4 A My decision. 5 - to stop being vice president? 6 A Yes. 7 And it was as simple as that. You just had too 8 many titles and you wanted a shorter title? 9 A Yeah. 10 Who did you discuss that with? 11 A Don't remember that time. Probably with the 12 president at the time and I told him this look ridiculous 13 to have two title. In the Secretary of State file it's 14 not needed. And at that time told me, "Yes, go ahead, 15 change it." 16 So you probably discussed it with the president 17 of MP Nevada? 18 A Yeah. Probably I informed him I want to make 19 some change. 20 And then you just did it? 21 A And I did it, yeah. 22 Did anyone else have to sign off you just did it? 25 A No. I have to sign it, but I informed them. Electronically slgned by Ellen Goldsteln (001-341-675-7457) OASIS REPORTING SERVICES, LLC 702-476-4500 Page 86 . 1 Okay. Could you look now at the document that's 2 been marked as Exhibit 3. 3 Sorry. One last question about Exhibit 2. 4 A Uh?huh. 5 Have you ever discussed this advertisement with 6 anyone at Mossack Fonseca? 7 A No. No, I didn't. How would be any related? I 8 thought, you know, they're going to use - I tried to 9 call in and correct that but say it's not that important. 10 But as far as you know, does anyone at Mossack ll Fonseca even know about that advertisement? 5 12 A Probably not. 13 Did you ever consider that mentioning Mossack 14 Fonseca in an advertisement like that might have been a 1 15 breach of paragraph 4 of your employment contract? 16 MR. WOODS: I'm going to object. She testified 17 earlier she didn't know about the employment contract. 18 THE WITNESS: I didn't pay attention probably. I 19 don't thought it was necessary, but - 20 BY MR. HRANITZKY: 21 Okay. So Exhibit 3, Exhibit 3 is an E-mail from 22 you to "Nevada office dated January 17, 2014; is that 23 right? 24 A Can I ask you, when you refer to is 25 MF Corporate Services? Electronically signed by Ellcn Goldstein (001-341-6734457) OASIS REPORTING SERVICES, LLC 702-476?4500 Document 100-3 Filed 03/16/15 Page 49 of 217 Case 2 Document 90-1 Filed 03/03/15 Page 45 of 50 Case Page 87 I?m reading from the top of the document itself. A Nevada office MF Corporate Services, yeah. It says "Nevada office Yeah. Right? 35 '0 ME Corporate Services. It doesn't say Corporate Services." It says "Nevada office A Well, this is our domain name. Okay. But the document says "Nevada office A Uh?huh. Okay. Then next to it is an E-mail address, Nevada@mfcorpserv.com. A Uh-huh. Do you see that? A Yes. That's our domain name. So mfcorpserv.com is the domain name for ME Nevada; right? A Yes. Does anyone other than MF Nevada use that domain name? A Myself, because I use pamunategui@mfcorpserv.com. They mean MF Corporate Services Nevada. That's Electronlcally signed by Ellen Goldsleln (001-341-678-7457) OASIS REPORTING SERVICES, LLC 702?476-4500 Page 88 1 just a short name of the company and the domain name. 2 So who is Nevada@mfcorpserv.com? Who is that? 3 Whose E?mail address is that? 4 A It?s the general E-mail from ME Corporate 5 Service Nevada. My secretary can see it and I can see 6 it, and difference of the other one what is my personal 7 E-mail. 8 Who besides you and your secretary can see 9 E?mail that comes in to Nevada@mfcorpserv.com? 10 A (Through the interpreter) Incoming E?mails or 11 outgoing E-mails? 12 Let me ask the question again. 13 Who besides you and your secretary has access to 14 E-mail that goes to Nevada@mfcorpserv.com? 15 A Me and her. 16 Nobody else? 17 A Nobody else. 18 Is there anyone besides you and then this 19 Nevada@mfcorpserv.com that has an E?mail address with the 20 mfcorpserv.com domain name? 21 A No. 22 Those are the only two E?mail addresses in the 23 world 24 A I have another E?mail address with the 25 mfcorpserv.com, but it's us two. OASIS REPORTING SERVICES, LLC Electronically signed by Ellen Goldstein (001-341-678-7457) 702-476-4500 Document 100-3 Filed 03/16/15 Page 50 of 217 Case 2 Document 90-1 Filed 03/03/15 Page 46 of 50 Case Nevada@mfcorpserv.com and that's it? A We have an office in Wyoming called So it's Pamunategui@mfcorpserv.com and No. It's another one from my office in Wyoming. A the head A Wyoming@mfcorpserv.com? Uh-huh. How long has the Wyoming office been around? Two or three year. Do you have a position with the Wyoming office? Yeah, the same. office of the Wyoming office. So you're the secretary of the No, because it's different company. It's different entity. A maybe I'm the manager. Do you have a position with that entity? I don't remember. any position. A manager. A Okay. Yeah, a manager. (Through the interpreter) I also manage that office too. Is that managed - is that office in Wyoming? Yes, it is. I'm running the office. I'm I don't think so. I don't know. But you said you're the manager? Page 89 Maybe, No, I don't have I work as the Electronlcally slgnod by Ellen Goldstoin (001-3414134457) OASIS REPORTING SERVICES, LLC 702-476~4500 Page Wyoming for that? 2 A Uh?huh. 3 How often? 4 A Depend on how I need it. Once a month or less 5 than once a month. 6 Do you have a separate employment contract for 7 that job? 8 A Not at all, no. 9 That?s part of your overall job? 10 A My overall. 11 Okay. And when you receive do you receive 12 directions or instructions on behalf of clients in your 13 job with the Wyoming entity? 14 A Well, Wyoming is another product. I sell it, so 15 I try 16 THE REPORTER: I'm sorry. I'm not understanding. 17 THE WITNESS: (Through the interpreter) It is a 18 marketing product that I thought it would be useful; and 19 the effort to sell it, it's my own. If someone asks a 20 company in Nevada, I also say why not offer them one in 21 Wyoming. 22 BY MR. HRANITZKY: 23 Well, when you get do you ever get 24 instructions to set up a Wyoming corporation? 25 A Yes. Electronlcally slgned by Ellen Goldstain (001-341-678-7457) OASIS REPORTING SERVICES, LLC 702-476-4500 Document 100-3 Filed 03/16/15 Page 51 of 217 Case 2 Document 90-1 Filed 03/03/15 Page 47 of 50 Case Page 91 Who do those come from? Same, Iris Vergara. That's all I was asking. Same production or marketing. Do you see at the bottom of Exhibit 3 it says, "Patricia Amunategui, head of Nevada office"? A Uh?huh. So I asked you before have you ever heard MF Nevada referred to as the Nevada office and you said no. MR. WOODS: I need to object. I think that mischaracterizes what you said before. You asked whether it had been referred to as the head of the Nevada office of Mossack Fonseca, which is not the same question that you just asked. THE WITNESS: I will respond this question. I choose to bring all my signature "head of the office Nevada" or "head of the office Wyoming" because it look better on marketing. I don't want anybody in the client thinks I'm the only person in the back. You look better if you put head of the office. BY MR. HRANITZKY: office" A So it was your decision to put "head of Nevada Yes. Electronically signed by Ellen Goldsleln (001-3414184451) OASIS REPORTING SERVICES, LLC 702-476-4500 Page 92 1 - under your signature on E?mails? 2 A Yeah. 3 Okay. So you have seen MF Nevada referred to as 4 the Nevada office? 5?7< A 6 That's what he say. I call head of the office because Yeah, but I don't mean to repeat on that. 7 I know there are more people under me, the president, but 8 I want to know this is the head of this - the people, I 9 mean my I'm the only one work, so I want to look like 10 I have more people, look more professional. 11 So you decided to do that so that it's not 12 obvious to people who receive these E-mails that you're 13 the only person working? 14 A Yeah, yeah. 15 I see. 16 A I think look more professional. It's a 17 marketing thing. 18 I see. 19 A (Through the interpreter) I think the I.T. 20 person had proposed that to me and I thought it would be 21 a good idea. 22 Okay. Could you look now at Exhibit 4. 23 A Okay. 24 This is a have you seen Exhibit 4 beforeread it in that time. This is the 702-476-4500 OASIS REPORTING SERVICES, LLC Electronically signed by Ellen Goldsmin (001-341-678?7457) Document 100-3 Filed 03/16/15 Page 52 of 217 Document 90-1 Filed 03/03/15 Page 48 of 50 Page 93 Page 94 1 first time I have this document in my hand. 1 A OkaY- 2 Okay. By the way, I forgot to ask, had you seen 2 Have you heard of Mossfon Trust Corporation? 3 Exhibit 3 before I showed it to you? 3 A I heard the name, yes. 4 A Yeah. I provide that. 4 What is Mossfon Trust Corporation? 5 Okay. So back to Exhibit 4, you've never seen 5 A I think it's another company. They do different 6 Exhibit 4 before? 6 service, but I don't know. 7 A No, never. 7 Have you ever interacted with anyone 8 Do you see in the second paragraph - you see 8 A NO- 9 there's a reference to a virtual client portal and the 9 at Trust Corporation? 10 client information portal? 10 A No. 11 A Uh?huh. 11 Have you ever been to Mossfon Trust Corporation? 12 Do you know what that?s talking about? 12 A No- 13 A Something. I'm not familiar, but I think 13 MR- WOODS: Was that a 14 something. 14 THE WITNESS: No, no. I know exist, but I don't 15 well, so what do you think? 15 know. I don't know even what they do. I don't have no 16 A The client can pay invoices for whatever 16 idea What it iS- 17 their they buy in a portable thing so it's easy for 17 BY MR- HRANITZKY: 18 them to pay. 18 Well, if you don't know what they do, it's 19 So they could pay invoices online? 19 possible that you may have been there and not know it? 20 A Online, yeah, something like this. I never know 20 A Well: maybe: but I don't knOW- I don't deal 21 how is. I don't have access to do it, but I think 21 With this department- 22 something like this. 22 As far as you know? 23 Okay. Then reading down, you see in the oneknow, Yes- 24 two, three fifth paragraph there's a reference to 24 What abOUt in the neXt Paragraph: do YOU see the 25 Mossfon Trust Corporation? 25 reference to Mossfon Asset Management Case 2 Case 2 702-476?4500 OASIS REPORTING SERVICES, LLC OASIS REPORTING SERVICES, LLC 702?476-4500 Electronically signed by Ellen Goldstaln (001-3416184457) Electronlcally slgned by Ellen Goldaleln (001-341-678~7457) Document 100-3 Filed 03/16/15 Page 53 of 217 Case 2 14-CV-OO492-RFB-VCF Document 90-1 Filed 03/03/15 Page 49 0f 50 Case Well, I believe it's another department and I don't know either. You believe that's another department? A Sorry, another company. Another company? A Uh-huh. Do you know what Mossfon Asset Management does? A No, Have you ever interacted with anyone from Mossfon Asset Management? A No. Okay. we're skipping Exhibit 5. A So no more here? Yeah, we're done with 4. We're skipping 5, so - A (Through the interpreter) We're skipping 5? 5 Yeah, we don?t have a 5 because I'm not going to i use my 5. A Okay. So you see have you seen the document marked as Exhibit 6 before today? A Uh-huh. You have seen this before today? A No. Page 95 The same. not even close. We can move to Exhibit 6 and, by the way, Elactronlcally algnod by Ellen Goldaleln (001-341-675-7457) OASIS REPORTING SERVICES, LLC 702-476-4500 Page 96 1 Today is the first time you've seen this? 2 A Today is the first time I see that, yes. 3 Do you see it's called Trust Services? Do you 4 see that? 5 A Trust Services? Oh, yeah, okay. 6 I'm going to represent to you that this is a 7 document that's available on Mossack Fonseca's Web site. 8 I'm not asking you to agree. I just want you to 9 A Yeah, yeah. 10 I'll just represent to you that we found it 11 there. 12 You see the under "Trust Services" first it 13 reads, "As part of the Mossack Fonseca Group, Mossfon 14 Trust Corporation is a fiduciary entity regulated by the 15 banking superintendence of Panama since 1993." Do you 16 see that? 17 A Yes. 18 And then below it lists various services, trust 19 services 20 A Uh-huh. 21 that that entity provides. 22 A Uh-huh. 23 And one of them is "corporate services." Do you 24 see that? 25 A Yes, uh-huh. Electronically signed by Ellen (001-341-678-7457) OASIS REPORTING SERVICES, LLC 702-476~4500 Document 100-3 Filed 03/16/15 Page 54 of 217 Document 90-1 Filed 03/03/15 Page 50 of 50 Page 97 Page 98 1 That?s what MF Nevada does; right? It provides 1 All right- And this document: EXhibit 6: 2 corporate services? 2 describes the trust services provided by Mossfon Trust 3 A I understand different, we do incorporatiOn and 3 Corporation and one of them is corporate services. So 4 they do corporate services. 4 I'm asking you, is the kinds of corporate services that 5 All right, But my Nevada is called MF Corporate 5 ME Nevada provides also the sort of thing that this 6 Services Nevada, isn't it? 6 document says Mossfon Trust Corporation does? 7 A Yeah. I want to make it distinguish here. 7 MR. WOODS: I'm going to object as to foundation that 8 Incorporation document, you file document with Secretary 8 She knows What this document is meant to say or What it 9 of State and you get the company ready. It's completely 9 means by "corporate services." She testified she didn't 10 different than prepare corporate document. They do this 10 Prepare it- 11 job. I don?t. This is corporate service what I 11 Answer if YOU can- 12 understand. Maybe I'm wrong. 12 THE WITNESS: I don't know what Mossfon Trust do. I 13 okay, But I thought you 13 only do what I do, MF Corporate Services. 50 I can't 14 A Maybe I'm wrong in the definition, but for me 14 answer to you that, no. To me, no, I don't know. 15 corporate service is a big thing, services. 15 MR- HRANITZKY: Okay- 16 I thought you said just a minute ago that you 16 SO You don't know What's meant by "corporate 17 didn't really know that much about what Mossfon Trust 17 serVices" in this document?' 18 Corporation does. 18 A Yeah. Corporate service for me can be very 19 A oh, no, I don't know; but when talking about 19 different than for you and you, so I don't know. 20 corporate services, I know what I'm doing and I don't do 20 It also be the same; right? 21 corporate documents. I do incorporate documents, but I 21 A It can: but I don't know- 22 don't prepare any other document after. 22 YOU just don't knOW? 23 Okay. MF Corporate Services Nevada has the 23 A I'm nOt very familiar With this company do: 24 words "corporate services" in the name; right? 24 SO ?Ot at all- 25 A Uh-huh_ 25 Okay. But you couldn't say for sure that in Case 2 Case 2 702-476-4500 OASIS REPORTING SERVICES, LLC OASIS REPORTING SERVICES, LLC 702-476-4500 Eloclronically signed by Ellen Goldstein (001-341-678-7457) EIactronlcally slgned by Ellen Goldsuln (001-341-678-7457) Case Document 100-3 Filed 03/16/15 Page 55 of 217 Case Document 90-2 Filed 03/03/15 Page 1 of 51 EXHIBIT 1 Document 90-2 Filed 03/03/15 Page20f 51 Document 100-3 Filed 03/16/15 Page 56 of 217 Case 2 Case 2 page 99 Page 100 1 this document, Mossfon Trust Corporation isn't marketing 1 Officer nothing With Nevede- We have the registered 2 MP Nevada as one of its services, can you? 2 agent in Nevada- 3 A But I don't know. 3 But how do you know that this reference is to 4 You can't say for sure they're not? 4 registered?agent services only in Panama? 5 A I don't have - on my knowledge, I don't know 5 A Beceuse I assume- 6 nothing whether use my product, 6 Why do you assume that? Were you involved 7 Okay, Let's go to Exhibit 7_ 7 A To be a registered agent, you have to have 8 A Oh, you want it there? 8 residence in this place. So how they can be registered 9 Yeah, It's better for her, 9 agent in Nevada, like you say, if they don't are here? 10 A Yeah. 10 Very difficult. The law tells you you need to be 11 All right. So Exhibit 7 is - 1'11 represent 11 physical in a place. 12 that this also comes from Mossack Fonseca's Web site. 12 All right- said before that 13 It's a document that describes administrative services. 13 Fonseca is MF Nevada's Client? right? A 14 See, first it reads, "Preparation of accounts, financial 14 A can be a Client: but they can't be a registered 15 records, annual returns and tax declarations"? I 15 agent- 16 A Uh-huh. 16 Just answer my questions. 17 Does MF Nevada do any of those things? 17 So you said before that Mossack Fonseca is 18 A No. 18 MF Nevada's client; right? 19 Next it says, "registered agent service." 19 A Yes- 20 A Uh-huh. 20 So it could be that Mossack Fonseca is marketing 21 ME Nevada does provide registered?agent 21 MF Nevada's register-agent services as part of a broad 22 services, doesn't it? i 22 package of services that they can - clients can go to 23 A For the Nevada company only; and I believe, I 23 MOSsack Fonseca to get? 24 believe, this service is mentioned for the Panamanian 24 A This is I don't know- I don't have any idea 25 company. Remember, there are registered agent in Panama 25 about the serViCeS they d0- OASIS A 702476-45,er OASIS REPORTING SERVICES, LLC 702?476-4500 Electronically elgned by Ellen Goldeleln (001-341-616-7451) Elec'ronically signed by Ellen Goldstein (001-M1-67B-7457) Document 100-3 Filed 03/16/15 Page 57 of 217 Case 2 Document 90-2 Filed 03/03/15 Page 3 Of 51 Case Page 101 You also said before that you go to symposiums in Panama where Mr. Mossack and Mr. Fonseca are also there every year and you talk about the services that NE Nevada provides; right? A I talk about the advantage of the Nevada LLC, was the only thing we sell, Nevada limited?liability company, but I don't talk about registered agent. I'm talking about the advantage of the product, that Nevada LLC. That's all I talk about, the only thing I talk, or the Wyoming LLC. So you never discuss registered-agent services? A No, because what I know, registered agent you have to be local in the place, so - But the fact that you have to be local in the place wouldn't prevent you, since you're local in the place, from talking about it in Panama, would it? A Well, maybe. I don't know. I don't talk aboutf that. They never ask me for. You never ever ever talk about registered?agent: services in Panama? A No. Ever? A No. I only talk about Nevada LLC in my presentation and in my talk. But isn't MF Nevada a registered agent for Electronically signed by Ellen Goldsmin (001-341-678-7451) OASIS REPORTING SERVICES, LLC 702-476-4500 Page 102 1 Nevada 2 A MF Corporate Services, yes, it is registered 3 agent for the Nevada LLC here. 4 Okay. So if you're talking about Nevada LLCs, 5 you really are talking about MF Nevada's registered?agent 6 services, aren't you? 7 MR. WOODS: I'm going to object to that because she's 8 testified many times that she hasn't spoken about 9 registered-agent services. 10 MR. HRANITZKY: I know that's what she said, but it's 11 inconsistent 12 THE WITNESS: Registered agent - I'm sorry. Maybe 13 I'm wrong, but registered agent for me is the service you 14 provide here for the entity or you provide there for the 15 entity. So how I never speak about registered agent. i 16 Only with the people here in Nevada. 17 MR. HRANITZKY: Okay. 18 THE WITNESS: Maybe I'm wrong, I'm mal-informed, but 19 that's what I 20 BY MR. HRANITZKY: 21 We'll see what the judge thinks. 22 It also refers to opening of bank accounts. 23 Does MF Nevada open bank accountsthe bottom it refers to strike Electronically signed by Ellen Golduoin (001-341-878-7457) OASIS REPORTING SERVICES, LLC 702-476-4500 Document 100-3 Filed 03/16/15 Page 58 of 217 Case 2 Document 90-2 Filed 03/03/15 Page4of 51 Case Page 103 that. Okay, I'm done with Exhibit 7. A Keep the same way? Okay. Now I'd like you to look at Exhibit 8. Have you ever seen Exhibit 8 before? A I only see different document with this page, that's all, but not But you don't recall - I see the logo, that logo, but not that. But you don't recall ever seeing Exhibit 8 No. the rest of it? No. This is my first timeWell, I'd like you to look at - unfortunately the pages aren't numbered. Okay. Look at the sixth page. Uh-huh. There's a futuristic?looking building on it. You're going to the sixth page? C) E) K) The sixth page. MR. WOODS: It looks like this (indicating). THE WITNESS: Okay, yeah. BY MR. HRANITZKY: You see that, the building that looks like a spaceship? OASIS REPORTING SERVICES, LLC Electronically signed by Ellen Goldsteln (001-341-618-7457) 702-476?4500 Page 104 1 A Yeah. 2 Then it talks about Mossfon Group services. 3 A Uh?huh. 4 I'd like you to look in the third paragraph. It 5 says, "The Mossack Fonseca technology platform is 6 state-of?the?art and secure. Our Web?based client 7 platform [sic] portal application allows clients to 8 reserve companies online." It's that last thing that I 9 want to ask you about. 10 Do you have any understanding of what "reserve 11 companies online" means? 12 A No. I'm not familiar with this system, no, and 13 I never no. I don't even I don't know how to use 14 the Web page; but reserve company online, no. 15 Forget about the online part. Do you have an 16 understanding of what the term "reserve companies" means? 17 A Yeah. Make a reservation like you make in a 18 restaurant. 19 So what does that mean when you're reserving a 20 company as opposed to making a reservation in a 21 restaurant? What does that mean? 22 A I don't know what they mean, no. 23 Have you ever seen a reference to reserving 24 companies in a document? 25 A No. OASIS REPORTING SERVICES, LLC Electronically signed by Ellen Gold-Cain (001-M1-678-7457) 702-476-4500 i'ag? Document 100-3 Filed 03/16/15 Page 59 of 217 Case 2 Document 90-2 Filed 03/03/15 Page 5 Of 51 Case subpoena in this case? A not - in my office. I don't understand anything about you ask me here, but I'm asking you a different question. A Maybe a document that you produced in response No. I'm not asking you about this document anymore. Reserve company Have you ever seen the expression "reserve companiesdocuments that MF Nevada produced to my client contained any references to reserving companies? A A documents that you produced. Maybe that will remind you. In my office? Yes. NO. Never seen We don't see this term, no, not this term. Okay. So you don't think that any of the No. Okay. We'll see. I'm We'll see in a minute when we look at some other Page 105 The only thing I can think can be, but I'm Reserving company? No, I don't use. not familiar with this term. Maybe Electronically signed by Ellen Goldstein (001-3416784457) OASIS REPORTING SERVICES, LLC 702-476-4500 Page 106 provides 25 A 5 the words "Company Formations" at the top. A 8 it says "Company Formations." A A MR. WOODS: Page 11. THE WITNESS: Yeah, I find it. MR. HRANITZKY: Okay. 16 services? A 18 understand "company formation," when you form a company. A A A Still on the same page; right? No. I've moved to another page. Oh. Could you turn to there's a document that has What page? Well, just keep scrolling through and you'll see Form corporations? Company Formations. Company formation? Does MF Nevada provide company-formation Yes. We incorporate companies. That's what I Yes. Yeah. I incorporate Nevada LLC. 50 that's something that MF Nevada does? Uh?huh. Okay. And you said before that MF Nevada registered?agent services too; right? You can't incorporate without registered agent, OASIS REPORTING SERVICES, LLC Elemronlcally signed by Ellen Goldstein (001-341-678-1451) 702?476-4500 Document 100-3 Filed 03/16/15 Page 60 of 217 Case 2 Document 90-2 Filed 03/03/15 Page60f 51 Case Page 107 so you have to have a registered-agent services, yeah. Okay. So on this page you see in the second paragraph it talks about advantages of using Mossack Fonseca as your registered agent? A Uh?huh. Do you have an opinion as to whether they're referring to registered?agent services offered by MF Nevada in this document? It's just A No. It can be many - can be them. them. Don't have to be MF Corporate Service Nevada. But you don't know that they're not talking about MF Nevada though? A They're not talking about Nevada. You're sure of that? Were you involved in preparing this document? A No, not at all. Have you ever seen it before? A Never see that document, but I insist I don't I only prepare document and incorporate and I do registered agent for the Nevada entity. All right. But you take instructions to do that from people at Mossack Fonseca; right? A Yeah. They sell entity. The clients come to you through Mossack Fonseca; right? 10 11 12 13 14 Eloctronically slgnod by Ellen Goldstoln (001-341-678-7457) OASIS REPORTING SERVICES, LLC 702-476m4500 Uh?huh. MR. WOODS: I'm going to object that mischaracterizes testimony. MR. HRANITZKY: I don't think it does and the witness just agreed to it. So I mean if you want to change your testimony, then the judge we'll see what the judge thinks. But so you've said previously that actually I think we've got what we need. forget it. Now I'd like you to look at look for the page that starts with "Exclusive Online Services." It's several pages A Same document? Same document, several pages into it. It starts with "Exclusive Online Services." Keep going. A Exclusive Online Services, yeah. Perfect. Now go to the next page. A Uh-huh. You see at the bottom where it talks about shelf-company reservation? A Yes. It says, "With the Mossfon client information portal, you can view an updated list of the shelf companies available at your nearest Mossfon office and you can reserve companies directly online." OASIS REPORTING SERVICES, LLC Electronically slgnod by Ellen GoldsteIn (001-341-678-7451) 702?476?4500 Document 100-3 Filed 03/16/15 Page 61 of 217 Case 2 Document 90-2 Filed 03/03/15 Page 7 of 51 Case Page 109 So here's another reference to reserving companies; right? A Uh?huh. Do you have an understanding of what they're talking about by "shelf companies"? A Yes, I know. What's a shelf company? A What I have it in my office, not what this document says. Okay. But do you have an understanding of what shelf company is? A Yes. Shelf company is when you incorporate company and you keep it in your shelf waiting until you sell it. Okay. So sometimes you have companies waiting on the shelf at NE Nevada to sell; is that right? A Yes, because sometimes client need the company in less than 24 hours. You don't need to wait the period for Secretary of State to get incorporated. Okay. When somebody wants to buy a company that's on your shelf at MF Nevada, do they call you directly? A No. I never contact any client directly. I don't have any contact directly. How do you find out about it? Electronically slgnod by Ellen GoldsIein (001-341-618-7457) OASIS REPORTING SERVICES, LLC 702-476-4500 Page 110 1 A Mossack Fonseca request what I have on stock on 2 my shelf. 3 Okay. So if the client wants a Nevada company 4 that's on your shelf, they go to Mossack Fonseca and then 5 Mossack Fonseca goes to you; right? 6 A Mossack Fonseca go to maybe everywhere, maybe. 7 I don't think I'm the only one provide them, but I have 8 shelf company. I incorporate shelf company. 9 You're saying that there's other companies that 10 provide Nevada shelf companies to Mossack Fonseca? 11 A Maybe. I don't know. 12 Are you aware of any? 13 A I don't have no idea. It would be an opinion, 14 but I have no idea. If they looking for something and I 15 don't have it, probably they need to go to somebody else. 16 Are you aware of any instance when that's 17 actually happened? 18 A No. 19 So the only shelf companies you know of - 20 A They are in my packet that I have control. 21 Let me finish asking the question. 22 So the only Nevada shelf companies you know of 23 that Mossack Fonseca can market to its clients are the 24 Nevada shelf companies on your shelf; rightany other. Electronically slgnod by Ellen Goldsteln (001-341-613-1457) OASIS REPORTING SERVICES, LLC 702-476-4500 Document 100-3 Filed 03/16/15 Page 62 of 217 Case 2 14-CV-00492-RFB-VCF Document 90-2 Filed 03/03/15 Page 8 Of 51 Case Page 111 I said that you know of. A Oh, that I know, yes. Okay. So there could be any others, but you don't know that there are? A Yeah. And you know that they that it happens with your shelf companies; right? A Yeah. I sell shelf companies like any other registered agent. So connecting their clients with you to purchase a Nevada shelf company is a service that Mossack Fonseca is providing to its clients? A Can you repeat that question. Yeah. A Sorry again. I was not paying attention. One of the services that Mossack Fonseca provides to its clients is connecting them with you so they can buy one of your Nevada shelf companies? A They never connect me to. I can't allow to connect to have any connection with their client. Okay. Well, then how does the client get one of your shelf companies? A I sell it to Mossack Fonseca. And Mossack Fonseca sells it to them? A (Nods head.) Eloclronlcally slgnod by Ellen Goldstaln (001-341-616-7457) OASIS REPORTING SERVICES, LLC 702-476-4500 Page 112 1 MR. WOODS: Is that a "yes"? 2 THE WITNESS: Yeah, I'm sorry. That's a yes. I 3 don't have any contact with any client. 4 BY MR. HRANITZKY: 5 But from the client's perspective, they're 6 getting one of your Nevada shelf companies? 7 MR. WOODS: Objection. She can't speculate what the 8 client is thinking. 9 THE WITNESS: I don't have no idea what the client 10 and I don't have no idea what other jurisdiction the 11 client can buy. 12 BY MR. HRANITZKY: 13 But you go to Panama every year to talk about 14 Nevada right? 15 A Uh-huh. 16 And that?s a symposium that's organized by 17 Mossack Fonseca; right? 2 18 A Sometime, yeah. 19 All right. And the clients who go to that 3 2O symposium are clients of Mossack Fonseca? 21 A No client. It's no client. 7 22 Their clients never ever go? A 23 A Never there, no. There are not client in this 24 symposium. I don't meet the client. They are other 25 people work for Mossack Fonseca but not clients. I never Electronically signed by Ellen Goldslein (001-341-678-1457) OASIS REPORTING SERVICES, LLC 702-476-4500 Document 100-3 Filed 03/16/15 Page 63 of 217 Case 2 Document 90-2 Filed 03/03/15 Page90f 51 Case Page 113 meet any client, no. In this symposium I don't meet clients. No clients ever go to the symposiums? A No, no, no, no. They go and meet the client, but in this symposium they are all people they are attorneys. They are all attorneys. They like to learn more of the product because they can go and sell it. I don't meet any client on the symposium, no client. So the symposiums are all Mossack Fonseca people? A Maybe there are onethat one. I only go on - they are completely no client. The symposiums you go to are all Mossack Fonseca people? A Yes. They are attorneys, most of them i attorneys. And they and your understanding is that they take what they learn from you about Nevada companies and then they go sell Nevada companies? A Go to law firm or whatever. They are all attorneys. And they go and sell Nevada companies? A Offer the sale, yeah. I never meet client. MR. HRANITZKY: Why don't we break for lunch now. It Electronically algnod by Ellen Goldstoin (001-341-678?7457) OASIS REPORTING SERVICES, LLC 702-476-4500 Page 114 1 would be a good time. 2 (Lunch recess taken from 11:51 a.m. to 3 12:51 4 (Plaintiff's Exhibits 9, 11 and 12 were marked 5 for identification by the Certified Court Reporter.) 6 BY MR. HRANITZKY: 7 So good afternoon, Ms. Amunategui. 8 A Hi. Good afternoon. 9 So I'd like you to take a look at the document 10 that's been marked it's in front of you. It's been 11 marked as Exhibit 9. 12 A Uh?huh. 13 I'm just going to represent to you that this I 14 is this also comes from Mossack Fonseca's Web site. 15 Do you see at the top there's a reference to ME 16 Corporate Services International and it gives an address 17 in Miami? 18 A Uh-huh. 19 Have you ever had any interaction with that 7 2O entity? 21 A No. 22 Do you know of anybody who works at that entity? 23 A I have a rumor of someone who works there, but I 24 don't know. I don't know anything. This is my first 25 time 1 see the name. Electronlcally slgned by Ellen Goldutaln (001-341-673-1457) OASIS REPORTING SERVICES, LLC 702?476-4500 Document 100-3 Filed 03/16/15 Page 64 of 217 Case 2 Document 90-2 Filed 03/03/15 Page 10 of 51 Case Page 115 I see. Okay. A MF Corporate Service International, I don't have any idea they have a name like this. Have you ever received an E?mail from that E-mail address, Florida@mossfon.com? A Not that I remember. Is mossfon.com is that the domain name for Mossack Fonseca? A Yes. Okay. A I believe so. Moving to Exhibit 12, the next - MR. WOODS: You're skipping 11? MR. HRANITZKY: Yes, we're skipping 11 no, sorry. We?re skipping 10. Exhibit 11. A Okay. Here I am. Have you ever seen Exhibit 11 before? A No. First time. Okay. I'll represent to you that this is another document that comes from Mossack Fonseca?s Web site. A Uh?huh. Do you see that this provides information about Nevada limited?liability companies? Electronically signed by Ellen Goldsloln (001-341-678c7451) OASIS REPORTING SERVICES, LLC 702-476?4500 Page 116 1 A Uh?huh. 2 Are you aware that Mossack Fonseca markets 3 Nevada limited-liability companies? 4 A Yes. 5 Including companies that are on the shelf at 6 MF Nevada; right? 7 A Yeah, probably, yes. 8 Then you see at the bottom of the first page it 9 talks about highlights of Nevada? 10 A Oh, here. 11 And then moving on to the next page, the last 12 bullet point says "skilled personnel." 13 A Uh?huh. 14 Is that you? 15 A Yes, I hope so. 16 Okay. We can move to Exhibit 12. 17 Hold on a second. Do you see 18 A We're going to same document or moving to 19 No, new document. Now we're on Exhibit 12. 20 A Uh?huh. 21 Have you ever seen Exhibit 12 before? 22 A Similar but not the same. 23 Okay. Does this appear to be a Mossack Fonseca: 24 document marketing features of Nevada limited?liability 25 companies? Eloctronlcally slgnad by Ellen Goldsteln (001-341-818-7457) OASIS REPORTING SERVICES, LLC 702-476-4500 Document 100-3 Filed 03/16/15 Page 65 of 217 Case 2 Document 90-2 Filed 03/03/15 Page 11 of 51 Case Page 117 A Uh-huh. Okay. I'd like you to look down under the section on "Managers and Members." A Uh-huh. You see the fourth bullet it says A Yeah. "Register of manager and member is required and must be kept at the registered office of the A Uh-huh. What does that mean? A What it mean for me? Yes, for you. What do you understand that to mean? A (Through the interpreter) The administrators and members - or managers and members must be registered. They must be - they must be at the office to the registered agent. THE REPORTER: Did you say "at the office to the registered agent?? 9 THE WITNESS: (Through the interpreter) No. The name of the manager, the administrator, and the member must be at the registered office of the LLC. BY MR. HRANITZKY: Does MF Nevada serve as a registered office for_ some Nevada Electronlcally signed by Ellen Goldstoln (001-341-613-1451) OASIS REPORTING SERVICES, LLC 702-476-4500 Page 118 A For some. For some they choose to be there 2 they?re using our address not for all of them. 3 But with respect to those, is there a register 4 of the manager and the member maintained at MF Nevada's 5 office? 6 A (Through the interpreter) We keep the name of 7 the manager with the current with the most current 8 address in our files after the corporation has been 9 renewed. 10 So you keep a register of the manager and 11 member - a current register of the manager and member - 12 at your office for all of the LLCs for which MF Nevada is 1 13 the registered office? 14 A (Through the interpreter) I only maintain the 15 record of the active entities with the name and the 16 address. I don't maintain the records, just the name and 17 the address. 18 Okay. Well, let me ask this a different way. 19 Does with respect to the LLCs for which 20 MF Nevada is the registered office, does MF Nevada comply 21 with the requirements under Nevada law? 22 A Yes. 23 Okay. And according to this document, one of 24 those requirements is that a register of the manager and 25 member is required to be kept at the registered office. Electronlcally signed by Ellen Goldstoln (001-341-675-7457) OASIS REPORTING SERVICES, LLC 702-476-4500 Document 100-3 Filed 03/16/15 Page 66 of 217 Case 2 Document 90-2 Filed 03/03/15 Page 12 of 51 Case Page 119 A Correct. And MF Nevada complies with that? A Uh?huh. "Yes"? A Yes. And what information is contained in the register? A (Through the interpreter) The name and the address of the last administrator and the address and where the documents should be found. You referred to the "administrator." A (Through the interpreter) Administrator means manager. So the register includes the name and the address of the current manager? A Uh~huh. And the address where the records can be found? A Can be found, yes. Okay. Is MF Nevada currently the registered office with respect to any of the 123 entities that NML has sought information about through the subpoena to ME Nevada? MR. WOODS: Do you want to show her the subpoena so she doesn't have to remember what the 123 entities are? MR. HRANITZKY: This is just a "yes" or I'd be Elactronlcally signed by Ellen Goldsleln (001-341-675-1457) OASIS REPORTING SERVICES, LLC 702-476-4500 Page 120 1 happy to show her the subpoena. 2 MR. WOODS: I don?t know that she knows exactly which 3 of the 123 entities which they are. 4 THE WITNESS: I can tell you right now - 5 THE REPORTER: I'm sorry, I'm not understanding. You 6 said, can tell you right now" and then I didn't 7 understand. 8 MR. HRANITZKY: Nevada is still the registered 9 agent for all of them," I think is what she said. 10 THE WITNESS: I'm not sure if we still the registered 11 agent for all of them. 12 BY MR. HRANITZKY: 13 You're not sure? 14 A Yeah. 15 I see. i 16 A Because I need to go and check one by one. I I 17 respond to subpoena where we was the registered agent a 18 long time ago. 19 Do you know if MF Nevada is still the registered 20 agent for some of them? 21 A Yes, some ones but I don't know which one. 22 But you don't know which? Okay. That's enough 23 for now. I'm not going to take you through the list. 24 We'll be here all day. 25 A And I don't memorize all this 130 whatever. slgned by Ellen Goldsleln (001-341-675-7451) OASIS REPORTING SERVICES, LLC 702-476-4500 Document 100-3 Filed 03/16/15 Page 67 of 217 Case 2 Document 90-2 Filed 03/03/15 Page 13 of 51 Case Page 121 Could I ask you to turn to the second page of Exhibit 12 now. Do you see under "Incorporation and Administration" A Okay, yes, I'm here. the second bullet says, "Excellent availability of company names for incorporation"? A Uh?huh. Do you know what that means? A What I personal is like Nevada have many available on names. It's not very restrict on names because it?s a small any name you can find is sometimes available to incorporate. I'm still not entirely sure I'm understanding. A Okay. Are you saying that in Nevada A Uh-huh. there aren't strict rules about what name you give to an A No. What I say is Nevada there are not many company incorporate, so you still can find name available. I see. A If you go to Delaware, probably that name is busy. You cannot use it. I see. OASIS REPORTING SERVICES, LLC signed by Ellen (001-341-618-7451) 702-476-4500 Page 122 A That's what I believe it is. 2 I see. So okay. That makes sense. 3 A Maybe in ten years Nevada the same. 4 Okay. Could I - look on the same page. Close 5 to in the middle do you see "Continuation 6 (domestication)"? 7 A Yes. 8 The first bullet reads, "Foreign companies can 9 be speedily continued to Nevada." 10 A Uh-huh. 11 Do you have an understanding of what that means? 12 A A little bit, what I think. 13 What's your understanding? 14 A Foreign company can become a Nevada LLC. 15 "Domestication" is the word from Secretary of State when a 16 you bring a company from another country or another 17 state. 18 So, for example, if somebody has a company 19 that?s incorporated in Panama, they can transform it into 20 a Nevada company? That's what you're saying? 21 A Yes. 22 And there?s a process in Nevada for doing that? 23 A Uh?huh. Also company from another state U.S. 24 I see. Is there any record kept anywhere that 25 the company used to be a Panama company before it was a .vww.oasisreporting.com Electronlcally slgned by Ellen Goldstein (001-341-673-1457) OASIS REPORTING SERVICES, LLC 702-476-4500 Document 100-3 Filed 03/16/15 Page 68 of 217 Case 2 Document 90-2 Filed 03/03/15 Page 14 of 51 Case Page 123 Nevada company? A Uh-huh. Secretary of State, they require the original document from the original jurisdiction before it accept the incorporation. We need to provide it. Is there any due~diligence process that goes on before a company is allowed to be continued into Nevada? A They need to be in good standing in their original jurisdiction and need to provide a certificate of good standing to be elected to be here. Okay. Well, just speaking hypothetically, if a foreign corporation were involved in criminal activity and maybe its officers are under investigation for criminal activity and it wanted to continue to Nevada, to cease to be a foreign corporation and become a Nevada corporation, would that be allowed in Nevada? MR. WOODS: Are you asking her to testify to what Nevada law is? MR. HRANITZKY: I'm just asking her understanding. THE WITNESS: Under the Nevada law, they don't ask you more, just the name and the original of the company is in good standing. MR. HRANITZKY: I see. THE WITNESS: And the manager and the member of that entity need to sign the Article of Organization first so that at least they know who is the name of the person, EIocIronlcally slgnod by Ellen Goldslaln (001-341-673-7457) OASIS REPORTING SERVICES, LLC 702-476-4500 Page 124 but I don't know what Secretary of State do more about that. MR. HRANITZKY: Okay. Do you know if there?s any requirement that books and records from the company before it came to Nevada have to be maintained somewhere after it's incorporated in Nevada? A No, I don't know. I don't know. I only believe you have to maintain since the company came here, not in the past. So books and records from before it came to Nevada, as far as you know, there's no requirement A No requirement. preserved? A Yeah. Can I ask something? The Nevada registered agent ethics association follow some ethic like how you know your client. If you we are not allowed to investigate the client because we don't have the tools, but at least we have to know if the person is not a public person or if you feeling something is not right, of course you need to not follow their incorporation. That's the ethic of the registered agent association. Well, if you received instructions to incorporate a foreign corporation as a Nevada LLC and you OASIS REPORTING SERVICES, LLC Electronlcally signed by Ellen Goldsteln (001-341-673-1457) 702-476-4500 Document 100-3 Filed 03/16/15 Page 69 of 217 Case 2 14-CV-OO492-RFB-VCF Document 90-2 Filed 03/03/15 Page 15 0f 51 Case 2 4 going to do that"? 5 A Yes. Yes, I can. 7 document. 8 going to do it." 12 reject it. 13 Okay. 16 Clearly. 18 it's your understanding that when a 23 A Yeah, I don't know. 24 not. I never see that we have to, 25 Okay. Page 125 1 thought something was suspicious or not quite right 2 A Okay. 3 - about the entity, could you say, "Nocan tell 6 Mossack Fonseca, don't feel comfortable with this I think something is wrong here, so I'm not 9 Has that ever happened? 10 A Not really, no, nothing I remember; but when I 11 feel like a document is not very clear or something, I There's just one thing that I wanted to 14 clarify because I was just looking at the transcript and 15 I'm not sure that it captured the question and answer 17 If I understood your testimony before correctly, 19 is continued to Nevada and becomes a Nevada corporation, 20 there's no requirement that its books and records from 21 before it became a Nevada corporation must be maintained 22 after it becomes a Nevada corporation? So far I don't know, it's but I don't know. Do you see on the last page of foreign corporation OASIS REPORTING SERVICES, LLC Electronlcally slgned by Ellen Goldslein (001-341-678-7451) 702-476-4500 4 to be Kept." 5 A Uh-huh. 6 7 required." What is that talking about? 8 A 10 document the company. 11 because we can't afford it. 12 think, tools to do it, but that's what they do. 13 check every client before they decide to make an 17 Okay. So if I've got this right, your 20 due diligence? 21 A Yes. 22 And it's only if the client clears that 24 to go forward? 25 A Allowed to be his client. Page 126 1 Exhibit 12 or the second-to?last page, I'm sorry 2 A Here (indicating)? 3 Yeah. It?s a section called "Documents Required The first bullet is "due?diligence documents as Due?diligence documents required that Mossack 9 Fonseca do on his client before decide to organize the I don't have that service here It?s a very expensive, I 14 incorporation. 15 Okay. So your understanding is that 16 A That's what I think is the name due diligence. 18 understanding is, before a client is permitted to 19 incorporate a Nevada corporation, Mossack Fonseca does a 23 diligence, that Mossack Fonseca allows the incorporation They due OASIS REPORTING SERVICES, LLC Electronically signed by Ellen Goldsteln (001-3414184451) 702-476-4500 Document 100-3 Filed 03/16/15 Page 70 of 217 Case 2 Document 90-2 Filed 03/03/15 Page 16 of 51 Case 2 1 2 diligence maintained at MF Nevada? 3 A No. I don't have any idea. 4 diligence, so I don't have anything. 5 idea how that process work. 6 11 documents." 12 A 21 MF Nevada? 22 A No. 23 24 formation of the Nevada 25 A I see. Are documents generated in that due Well, here this document it says, "Documents 7 required to be kept at MF Nevada in accordance with the 8 law." Do you see that? 9 A Yeah, I see it. 10 And the first item listed is "due-diligence Well, they put in this it's now required by the 13 law, but I don't do the due diligence. We don't have the 14 due diligence. The client do it. In this case Mossack 15 Fonseca do the due diligence. We don't. 16 So you don't keep due-diligence documents 17 A No, I don't. 18 at MP just let me finish asking the 19 question. 20 You don't keep due-diligence documents at Can you describe for me what the process is for You need to prepare the Article of Organization Page 127 We don't do the due I don't have no Eloclronically ilgnad by Ellen Goldsteln (001-341-618-1451) OASIS REPORTING SERVICES, LLC 702-476-4500 Page 128 1 form with Secretary of State, check that the name is 2 available, get all the information about the manager, the 3 address. 4 You get the manager?s address? 5 A The manager address and the name, a correct 6 name. 7 In some cases I request they send me the 8 passport of the name, of the ID, so I match the name what 9 they told me is correct, because otherwise I need to 10 repair, and cost money. After that I prepare the annual 11 list and I send it by E?mail well, by the electronic 12 service to them so they found the signature for that 13 person. 14 When you refer to "them," you're talking about 15 the Secretary of State? i 16 A No, to Mossack Fonseca. 17 Okay. 18 A The client sign the final list and then after 19 that they have everything in order, the Article of 20 Organization from Secretary of State and the Article of 21 Organization from MF Corporate Service you probably have 22 in your subpoena. 23 THE REPORTER: I'm sorry. I didn't hear the last 24 part of that. The Articles of Organization - 25 THE WITNESS: The Article of Organization. We call Electronically signed by Ellen Goldsteln (001-341-678-7457) OASIS REPORTING SERVICES, LLC 702?476-4500 Document 100-3 Filed 03/16/15 Page 71 of 217 Case 2 14-CV-00492-RFB-VCF Document 90-2 Filed 03/03/15 Page 17 of 51 Case Page 129 ME Corporate Service Article of Organization because it?s a little bit more MR. WOODS: What she said is she has a document called MF Corporate Services Articles of Organization that's a little more - THE WITNESS: Looks better than the form from Secretary of State. BY MR. HRANITZKY: It's more thorough? MR. WOODS: She's saying it looks better. THE WITNESS: It looks better. MR. WOODS: It's more attractive. BY MR. HRANITZKY: It's prettier? A Yeah, it's prettier. Well, it has more page and say the same but it's more elegant. Okay. A And we print these two document when they say the same with the same information, send it to Secretary of State by E-mail, and then Secretary of State process. After the document is ready and processed and done, I receive the original document in my office by Fed EX. Okay. That's the whole process? A Well, after the company come in, the original document, I review that everything is matched the Electronically signed by Ellen Goldsiuin (001-3414184451) OASIS REPORTING SERVICES, LLC 702-476-4500 Page 130 1 name, the address, and the name of the entity and then 2 I add these document of the case, fill out the form that 3 Mossack Fonseca own so the client can have access 4 Mossack Fonseca have the access - for the company's 5 incorporate. And then they give me instruction where 6 they need to be sent, to their office because they will 7 do the rest of the document or wait until we have some 8 other mail or something; but normally I send it to them 9 by DHL courier. So they prepare the corporate kit and 10 send it to them. 11 What is the corporate kit? 3 12 A We call it the corporate kit when everything is a 13 inside: Article of Organization, charter, initial list, 14 Operating Agreement, assistant manager, assistant member, 15 and all of that. The thing is, normally we send it, they 16 prepare it there, and send it to the client. 17 When you refer to "they," you're talking 18 about 19 A Well, Mossack Fonseca. 20 Mossack Fonseca? 21 A I prepare the incorporation process here. 22 And they prepare the corporate kit? 23 A The corporate kit. 24 Using documents that you provide to them? 25 A No, no. I don't prepare these document. I only Electronically signed by Ellen Goldsteln (001-3414184457) OASIS REPORTING SERVICES, LLC 702-476-4500 Document 100-3 Filed 03/16/15 Page 72 of 217 Document 90-2 Filed 03/03/15 Page 18 of 51 Page 131 Page 132 1 send the set of the Article of Organization, the charter, 1 I see' 2 and that's it, and they 2 A That's what I call corporate service here. 3 I see. They prepare the corporate kit and 3 Thatsee. And what's involved in the renewal of 5 A The Operating Agreement and that kind of stuff. 5 the corporation? 6 They prepare the corporate kit and you send it 6 A Obtain the annual list, sign it by the manager, 7 off to the Secretary of State? 7 by the current manager we think stillprepare the document, the first 8 opportunity to the person in Panama to check with the 9 document, Article of Organization and all the Secretary 9 Client if this is the same manager for this Year or the 10 of State require to incorporate an entity. I send it to 10 neXt' I prepare the annual liSt again! the annual?liSt 11 Secretary of State. Secretary of State send it to me to 11 form from secretary Of State- I Send it to Panama: and 12 my Office_ Then when the document in original come in 12 Panama have one or two months to give me that document to 13 because I request legalization of each document I put 13 re?Sign it from the Client so I can renewal- 14 all together very nice and I put it back in an envelope 14 Okay' 15 to Mossack Fonseca. They prepare the rest of the 15 A I Charge the inVOicev because if the Client 16 corporate kit to give it to whatever client is. 16 don?t Pay the feel we don't renew- 17 And that's the end of your involvement? 17 I see' And What's the fee? 18 A That's my end of the involvement until the 18 A Secretary of State charge $325 for renewal every 19 client next year need the company next year need to 19 Year? 20 renew_ 20 Does MF Nevada charge a fee for the renewal? 21 I see_ 21 A It isn't a flat fee, but I don't know exactly 22 A Or in the meantime, when the company is alive, 22 the prices because I don't deal with prices. We charge 23 maybe they ask me tO obtain a certificate of good 23 our fee for that through the accounting though. 24 standing or a change of manager. That's what the 24 so bUt 25 involvement. That's the involvement our office. 25 A We Charge MossaCk Fonseca' we don't Charge the Case 2 Case 2 702?476-4500 OASIS REPORTING SERVICES, LLC 702-476-4500 OASIS REPORTING LLC Electronically algnod by Ellen Goldstoln (001-3414704451) by Document 100-3 Filed 03/16/15 Page 73 of 217 Case 2 Document 90-2 Filed 03/03/15 Page 19 of 51 Case Page 133 Page 134 client. 1 back?office accounting services for ME Nevada? 1 see, 2 A Probably, yes, but I'm not sure. I don't know A Because Mossack Fonseca charge probably another 3 exaCtlY What kind 0f serViceS- fee to the client, 4 Okay. Do you know of any other back?office Okay. But you said that accounting takes care 5 services that Mossack Fonseca provides to NE Nevada? of that? 6 A Sometime I.T. services if we have some major A Yes. 7 problem. Does MF Nevada have an accounting department? 8 A Yeah, here, yeah, we have a CPA, Sharples 9 A I.T. Cost less than call somebody here. If Associates. 10 they can fix it, we ask for some services. I see, So when you refer to "accounting," 11 Any other services you can think of? you're talking about the 12 A We have to pay the courier. They charge the A Yeah, In the end of year and the end of month, 13 client, but we pay first; so they we collect the money they see how much money deposit for annual and they see 14 after for the courier- if they need something, if they forgot to pay something_ 15 They collect the courier fees from the clients We have an accountant specially for annuals, for 16 for renewals. 17 A So that include their return back because we pay Okay. Earlier today we were talking about 18 for that- human-resource services and you said that Mossack Fonseca 19 I see- 50 With reSPeCt t0 SOer- Strike provides some back?office human-resources services to 20 that- MF Nevada? 21 Are you ever asked to serve as a director or A Uh_huh_ 22 secretary or in some other capacity personally for any of Is that right? 23 the Nevada LLCs that A Uh?huh. 24 A Incorporate. Does Mossack Fonseca also provide any 25 MF Nevada incorporateS? OASIS REPORTING SERVICES, LLC Electronically slgned by Ellen Goldstein (001-341-878-7457) 702-476-4500 Electronically slgned by Ellen Galdstein (001-341-618-1457) OASIS REPORTING SERVICES, LLC 702-476?4500 Document 100-3 Filed 03/16/15 Page 74 of 217 Document 90-2 Filed 03/03/15 Page 20 of 51 page 135 Page 136 1 A No. A No, never. 2 That never happens? 2 That's never happened? 3 A Say again your question, please. 3 A Never happened- 4 Sure, 4 Do you ever learn anything about what the Nevada 5 So we've been talking about what MF Nevada does 5 LLCS You help to set up do] What functions the LLCS 6 to set up a Nevada corporation. 5 perform? 7 A Uh?huh, 7 A No. You mean you're talking the company I 8 And you testified earlier that MF Nevada 8 incorporate, if I know after that what they're doing as a 9 sometimes serves as registered agent for some Nevada 9 bUSineSS? 10 corporations; correct? 10 Yes. 11 A Uh?huh. We always serve as a registered agent 11 A No- 12 of the company here; otherwise they can't be 12 or if they aCtuallY do anything as a bUSineSS? 13 incorporated. 13 A I believe everybody do something. Why they 14 Okay. So my question is, do you personally, 14 spend the money to incorporate? 15 Patricia Amunategui, ever serve in any other capacity for 15 You don't knOW? 16 these Nevada For example, are you ever the 16 A No: I don't have no idea. I lose the contact of 17 secretary of 17 the company as soon as left my office. 18 A No. 18 Until it's time to renew? 19 any of these Nevada 19 A YesNevada subject to any know?your-client 21 or a director? 21 rules or regulations under Nevada law? 22 A No. Personal? 22 MR. WOODS: Objection. She can testify to her 23 Yes, 23 knowledge, but she can't testify to Nevada law. 24 A No. 24 MR. HRANITZKY: To her knowledge. 25 Or a manager? 25 MR. WOODS: To her knowledge. Case 2 Case 2 702-476-4500 OASIS REPORTING SERVICES, LLC 702-476-4500 OASIS REPORTING LLC Electronically signed by Ellen Goldsloin (001-341-615-7457) Electronically signed by Ellon Goldsloin (001-3414784457) Document 100-3 Filed 03/16/15 Page 75 of 217 Case 2 Document 90-2 Filed 03/03/15 Page 21 of 51 Case Page 137 THE WITNESS: By my knowledge by myself, what I've been learning with the association, it's not required, but we still I still tell you again we have an ethic how you know your client; and when we see suspicious act like they change the manager very often or some kind of stuff they give you an idea, we need to pay attention and do something, resign the company or contact, do something. That's required for our association, try to keep, you know, this business very serious. BY MR. HRANITZKY: But those are guidelines? A Guidelines like we Best practices? A Best practice for a registered agent, but it's not any law that I know that require to check. Do you know who owns the shares or the equity in ME Nevada? MR. WOODS: She?s testified to that a hundred times already. THE WITNESS: I already told you that I don't remember exactly the name. BY MR. HRANITZKY: I'm sorry. I A Timberlane Associate or something. I'm sorry. So when you were talking earlier Elaclronically signed by Ellen Goldsteln (001-341-673-7457) OASIS REPORTING SERVICES, LLC 702-476-4500 Page 138 1 about shareholders 2 A Yeah. 3 that's what you you're right. 4 A Sorry. I don't remember exactly the name. It's 5 a long name, but I know it is. 6 Problem is that James Wald wrote this outline 7 and he used a different word. 8 A Well, it's very confusing because shareholder is 9 one thing and another oneNevada, that refers to Mossack 11 Fonseca, doesn't it? 12 A I really don't know, but I don't like to have 13 this name. I'm sure have a lot of problem with this 14 name. 15 What do you think? 16 A Maybe, maybe not. Something I don't know. I 17 don't choose the name and I don't incorporate that 18 company. I 19 Okay. Does MF Nevada have any clients other 20 than Mossack Fonseca? 21 A We have a couple, but they're not anymore 22 because the fee got more expensive. 23 So if I understand your testimony, MF Nevada 24 used to have clients other than Mossack Fonseca but it no 25 longer does? Electronically slgned by Ellen Goldsteln (001-341-678-7457) OASIS REPORTING SERVICES, LLC 702-476-4500 Document 100-3 Filed 03/16/15 Page 76 of 217 Case 2 Document 90-2 Filed 03/03/15 Page 22 of 51 Case ago. No longer does, yeah. That's very long What percentage of MF Nevada?s business those other clients represent when you had them? A now, and away the A I forgot MF Nevada and Mossack Fonseca, MF Nevada is not permitted 0.5 percent maybe, a little bit. A tiny piece? A very tiny piece. So Mossack Fonseca is MF Nevada's only client even when it had other clients, largest client; right? Yes, plus the contract agreement they ask for the word I needed. (Through the interpreter) Exclusivity. Okay. to provide services to other clients? that; A contract? A is It's better not. The contract says that it's better that Not, yeah. But it doesn't prohibit MF Nevada from doing that what you're saying? Well, we need to have permission. I seeunder the current agreement between Have you ever seen a copy of that Page 139 time did 1 it not? Elochonlcally slgnod by Ellen Goldsleln (001-341-613-7457) OASIS REPORTING SERVICES, LLC 702-476-4500 Page 140 original, 9 10 A 11 12 contract, 13 of the contract? 14 A 15 do, what company. 25 MR. WOODS: 3 in my hand. No? No. I know exist, but I don't ever have a copy But MF Nevada is a party to the contract? Yes, yes, yes. Who signed the contract on behalf of MF Nevada? I don't know. I don't never see the copy or the so I can't say that. I don't know. So it wasn't you? No, no, it was not me. Okay. And even though you've not seen the you have an understanding of some of the terms Yeah, of course because maybe tell me what I can I cannot do under this contract. Who tells you that? i The president of the company. Is that Imogene? Imogene Wilson, yeah. Anybody else? No, not that I remember. Does MF Nevada have a legal department? No. We hire external office of legal, his What is the name of it? I forgot. Woods Erickson Whitaker. OASIS REPORTING SERVICES, LLC Electronlcally slgnod by Ellon (001-341-613-7457) 702-476-4500 Document 100-3 Filed 03/16/15 Page 77 of 217 Case 2 Document 90-2 Filed 03/03/15 Page 23 of 51 Case Page 141 MR. HRANITZKY: Only the best. THE WITNESS: Only the best, yeah. They do everything. They do the contract, they do everything, so the rest of the questions they can answer to you. If you have a legal department, we'll need to make more money. They charge a lot of money. MR. WOODS: I'm the cheapest guy at the table. Don't complain. I THE WITNESS: Well, that's the reason I keep you. MR. HRANITZKY: There's no fairness in billing rates for attorneys. Why don't we take a five-minute break. (Brief recess taken.) (Plaintiff's Exhibits 13 through 19 were marked for identification by the Certified Court Reporter.) BY MR. HRANITZKY: So I'd like you to look at the document that's been marked as Exhibit 13. That's this one. A Oh, okay. Sorry. Do you recognize this document? A Was this my subpoena or not? No. I see it one time, but I don't - sorry. I see so many of these, I'm so confused. I don?t know which one is. Is this a Declaration that you signed? A Oh, okay. Yeah, yes, okay. Elocu'onically signed by Ellen Goldsloin (001-341-618-7457) OASIS REPORTING SERVICES, LLC 702-476-4500 Page 142 1 I assume that you had some assistance from your 2 attorneys in putting this together? 3 A Yes, yes, yes. He prepare. 4 If you could look at paragraph 5 5 A Uh-huh. 6 you see there's a reference to you produced 7 several thousand pages of documents to NML in response to 8 a subpoena? 9 A Uh-huh. 10 You remember that? 11 A Yes, I remember. A lot of work. 12 Okay. Did anyone help you in looking for 13 documents that are responsive to the subpoena or did you 14 do it all yourselfmyself. Of course I hire somebody 16 to help me to stack it by company, and then I meet with 17 him to review everything is compliant with the request 18 and then I hire company to scan it. 19 Okay. When you refer to "him," you gestured 20 towards Kent? 21 A I'm sorry. My attorney. 22 Mr. Woods? 23 A Mr. Woods, yeah. 24 How did you go about looking for the documents? 25 A I went to my physical file first and then I OASIS REPORTING SERVICES, LLC Electronically slgnod by Ellen Goldsloin (001-341-615-1457) 702-476-4500 Document 100-3 Filed 03/16/15 Page 78 of 217 Case 2 Document 90-2 Filed 03/03/15 Page 24 of 51 Case check if mainly they are the same. have so many duplication, I only pick up what is the one page per document, you know, and then I organize it by date. on the scanner don't charge me double to organize the document and was very clear. perfect from the A to until the end, I pack it very well and deliver it to scan people because I don't want the mess, not organized like this. that it was all there, you delivered it to the people who scanned it? A A pick up, didn't want any document get lost. hard?copy files and electronic files; correct? A because, in the office in electronic because was very long time ago. These document, they are very old. I organize it they're organized so the people Page 143 any electronic file was there and realized that So I print it all; and when I And after everything is the papers. You know, I was afraid that was So the last thing you said, after you made sure I deliver it. You deliver it to the people who scanned it? To scan, the company I hire. They offer me to but I decide to deliver it myself because I Okay. You said that you looked at your Yeah. Some electronic I have. Some were not like I say before, we don't keep much document So I check my Electronically signed by Ellen Goldsloin (001-341-6754457) OASIS REPORTING SERVICES, LLC 702-476?4500 and I check the electronic and then I find out the same, so - Does MF Nevada keep hard copies of everything? We supposed to, but I'm not. You aspire to that? There are very old ones. So sometimes we don't hard copy for that, but I try to keep most of in a physical copy. I'm going in the process to change everything for electronic. I see. When you say you looked at the electronic files, are those your personal electronic MF Nevada? MF Nevada electronic file. I don?t have any electronic document myself. Okay. And where are those stored? Is there an NE Nevada network? No. Some of them they have in some CD we've been saving in the past and we find out that the CD was My file was more current than the CD. Okay. But I'm asking, so you used to save documents on CD but you don't do that anymore? Yeah. It's a very long process, so we planning to hire a company to do it and we don't have to have so Page 144 1 physical 2 they are have the 8 the time 9 10 11 12 files not currentmuch paper. 25 I see. So how do you store the electronic Electronlcally slgned by Ellen Goldslein (001-341-613-1451) OASIS REPORTING SERVICES, LLC 702-476?4500 Document 100-3 Filed 03/16/15 Page 79 of 217 Document 90-2 Filed 03/03/15 Page 25 0f 51 Page 145 Page 145 1 documents? Are they on a 1 someplace else? 2 A In the past? 2 A On the Mossack Fonseca platform, most of them, 3 currently, 3 because I told you, when they open the instruction, it's 4 A Current? current electronic going on how 4 like a platform instruction. So we put everything there, 5 they call the name I explain to you platform from 5 the instruction and everything; and after the company is 6 Mossack Fonseca, platform. When they open the case, we 6 incorporated and it's gone: 00 more access to that 7 attach to there. So some document with my document, I 7 Platform anymore 0? that PartiCUlar company for me- I 8 keep it in my office. Some other document, they are not 8 don't know how they call- It'3 a System- It'5 a 9 mine anymore, like the Operating Agreement and that kind 9 comPUter: YOU know- 10 of stuff, so I don't keep it. 10 So did you search the Mossack Fonseca 11 Okay. But you said that you 11 platform 12 A The document I prepare, I keep it all the time. 12 A I searChEd my 13 I do copies. 13 Hold on. 14 so you keep hard copies, right, and you said 14 Did you search the Mossack Fonseca platform for 15 that you have 15 any documents when you were collecting documents to 16 A Physical and hard. 16 respond to this subpoena? 17 You have some electronic 17 A I search my access, my access what I have, and 18 A Uh?huh. 18 my access what I have was also the same I have in my 19 copies? 19 file, physical file. 20 A Uh?huh. 20 Okay. So you searched the documents on the 21 Are the electronic copies that you just referred 21 Mossack Fonseca platform that you have access to? 22 to looking through, are they stored on 22 A Yes- 23 A Some one they stored on CD. Some one they 23 I see. And they were the same 24 stored in the computer. 24 A Same, exactly the same. 25 But is it on the Mossack Fonseca platform or 25 as the documents in the file? Case 2 Case 2 702-476-4500 OASIS REPORTING SERVICES, LLC OASIS REPORTING SERVICES, LLC 702-476-4500 Electronically signed by Ellen Goldstain (001-341-678-7451) Elecvonlcally slgned by Ellen Goldsleln (001441-673?7457) Document 100-3 Filed 03/16/15 Page 80 of 217 Case 2 Document 90-2 Filed 03/03/15 Page 26 of 51 Case Page 147 A Uh-huh. Okay. And then there are other documents in the Mossack Fonseca platform that you don't have access to? A I can't have access, yeah. I understand. Do you know if the Mossack Fonseca platform is shared with all the Mossack Fonseca affiliates? A I don't know. I don't know. The only thing I know is my access. Do you know where the platform is maintained? Is it on the server in Panama or A No idea. No idea? A I don't know. Is the platform that you're talking about, is that the same thing as the electronic filing cabinet that's referred to in some - take that back. Have you ever heard the term "electronic filing cabinet"? A No. My first time. Sorry. Now could you please turn to Exhibit 14. A Turn to first page? Exhibit 14. A Oh, sorry. So on the first page do you see this is an OASIS REPORTING SERVICES, LLC Electronically signed by Ellen Goldslein (001-341-618-7451) 702-476-4500 Page 148 1 E-mail from World Compliance Corporations to Suzy Ramos 2 Corporations? 3 A Uh-huh. 4 Do you know what World Compliance Corporations 5 is? 6 A No. 7 Never heard of that? 8 A No well, no, I heard but probably I don't 9 have no idea what it is in a long time. 10 Do you know who Suzy Ramos is? 11 A Yes. 12 Who is Suzy Ramos? 13 A She work in the same place as Iris Vergara. 14 Iris Vergara, is she in the corporations group 15 at Mossack Fonseca? 16 A Yeah, the same as Suzy Ramos. I 17 I see. Okay. So could you turn to the fourth 18 page of Exhibit 14, which confusingly has the number 1 at 19 the bottom. 20 A Oh, yeah, okaythe lower right corner it 22 says TRANSLATION MFCS 002132. Do you see that? 23 A Uh-huh. 24 Okay. You see at the top the E?mail is from 25 Mossack Fonseca Company (corporations Nevada)? Eleclronically signed by Ellen Goldstein (001-341-613-7457) OASIS REPORTING SERVICES, LLC 702-476-4500 Document 100-3 Filed 03/16/15 Page 81 of 217 Document 90-2 Filed 03/03/15 Page 27 of 51 Page 149 Page 150 1 A Uh?huh. 1 - Vergara works? 2 And it's to ME Corporate Services Nevada. See 2 A SUZY Ramos and somebOdY else maybe- I don't 3 that? 3 know. 4 A Yeah. 4 Is Suzy Ramos still at Mossack Fonseca? 5 MF Corporate Services Nevada, that's you; right? 5 A A Yes- 6 A Yes. MF Corporate Service Nevada is me. 5 50 in addition to getting requests from Iris 7 So what is Mossack Fonseca Company 7 Vergara, you also sometimes get requests from Suzy Ramos? 8 (corporations Nevada)? 8 A Yeah, because they help each other, one or the 9 A This is the department of selling Nevada. This 9 Other one- 10 is where Iris is. 10 Okay. You can go to Exhibit 15 now. 11 That's where Iris is? 11 A 50 I keep going? 12 A Yeah. It's the department of sale of Mossack 12 It's the next exhibit- 13 Fonseca Nevada. 13 A So we're done with this one? 14 I see. So this is the sales group that sells 14 Yes- 15 Nevada 15 A 15, here it is. 16 A Yes, sell Nevada. We only offer Nevada LLC, but 16 15- Do you recognize Exhibit 15? 17 that's what they sell. They are in touch with me because 17 A I don't see it before: bUt here it iS- Okay, 18 that's what they they are in charge to do. 18 maybe I see it- I don't remember- OkeY- 19 That group may do other things too 19 MR. WOODS: Is that a "yes" or a 20 A Yeah, I don?t know, 20 THE WITNESS: No. I mean I don't understand the 21 Let me finish. 21 question. If I recognize this document? 22 One of the things they do is sell Nevada 22 BY MR- HRANITZKY: 23 A Yes. 23 Have you seen this document before? 24 And that's where Iris 24 A I don't remember. 25 A Vergara 25 You don't remember. 702-476-4500 OASIS REPORTING SERVICES, LLC OASIS REPORTING SERVICES, LLC 702-476-4500 signed by Ellen Goldsleln (001?341-678-7457) Case 2 Case 2 Electronically slgnod by Ellen Goldstoln (001-341-815-1451) 27'? in . Document 100-3 Filed 03/16/15 Page 82 of 217 Case 2 Document 90-2 Filed 03/03/15 Page 28 of 51 Case Page 151 Do you know if MF Nevada produced this document in response to the subpoena? A Probably. You don't know as you sit here now? A I produce so many documents, I don't remember each one. Okay. You see it's from a woman named Monica Ycaza? Uh?huh. Did I pronounce that right, Ycaza? Yeah. A Do you know Monica Ycaza? A I don't, but I see her name. I see. Have you ever interacted with Monica A No. No? Have you ever E?mailed with Monica Ycaza? I don?t know. Maybe. Maybe. Maybe? 3? IO 3? 10 She work in Peru. Okay. You say you see at the bottom it's signed "Monica, Mossfon Peru"? A Uh?huh. Do you know what Mossfon Peru is? A No. Electronically slgned by Ellen Goldstain (001-341-515-1451) OASIS REPORTING SERVICES, LLC 702?476-4500 Page 152 1 No? 2 A No. 3 But you've heard of it before? 4 A I heard, yeah, the name. I heard but I don't 5 know what it is. 6 You don't know what it is, okay. 7 Exhibit 16, do you recognize Exhibit 16? 8 A Same thing on the other one. I see a document. 9 Probably it's in the document I produced, but 10 You don't have a specific memory? 11 A Specific memorythe top it's an E-mail from Jost 13 Dex in the Luxembourg rep office to you? Do you see 5 14 that? 15 A Oh, to me, yeah. 3 16 Dated May 22nd, 2006? 17 A Uh-huh. 18 Who is Jost Dex? 19 A Was the person work at the Luxembourg office for 20 a long time, but in the beginning I don't know. 21 Did you communicate from time to time with Jost 22 Dex when he was at the Luxembourg 23 A Not very often. 24 But sometimes? 25 A Sometime when he need something. Electronically signed by Ellen Goldslain (001-3416184451) 702-476-4500 OASIS REPORTING SERVICES, LLC v; Document 100-3 Filed 03/16/15 Page 83 of 217 Case 2 Document 90-2 Filed 03/03/15 Page 29 of 51 Case Page 153 So sometimes you would get requests from Jost Dex? A Sometime in the past. And were the requests for to set up Nevada A Uh-huh. For clients of the Mossack Fonseca Luxembourg office? A I believe so. I don't know. He request he's part of the same like the Panama office. They requested the name or something, yeah. So you're saying that he's part - A I don't know for which client, but I believe it's for the same client. He's part of the same office. So you mean he's part of Mossack Fonseca you're saying? A Yeah. Otherwise I can't answer. Okay. But he's in the Luxembourg representative office of Mossack Fonseca? A Uh-huh, I believe so. That's your understanding? A That's what I understand. I'm not sure. Okay. Do you see towards the bottom of this first page it says, "Dear Patricia, please proceed with the incorporation of a new LLC named Agroglob Equity, Electronically signed by Ellen Goldsteln(oo1-341-67B-1451) OASIS REPORTING SERVICES, LLC 702-476-4500 Page 154 1 2 A Yeah. 3 MR. WOODS: Great name. 4 BY MR. HRANITZKY: 5 Do you know how the clients choose these names? 6 A No idea, trust me, which I know they are very 7 crazy names. Don't make sense to me many time, yeah. 8 Okay. And then you see below it says they'd 9 like it with the following features: Speedy 10 incorporation service? 11 A That mean expedite service, like I need to pay 12 extra money at the Secretary of State for expedite 13 service. 14 And then does MF Nevada get paid an extra fee 15 for doing expedition? 16 A No, I don't think so. We only charge the 17 expedite fee for Secretary of State. I don't know. 18 Myself, no, we don't. We just charge an extra of the 19 Secretary of State. That's what I understand what they 20 say. 21 Then it says the manager is Aldyne? 22 A Uh?huh. 23 And then the member is Gairns? 24 A Uh-huh. 25 So Aldyne serves as the manager for many Electronlcally signed by Ellen Goldstain (001-341?513-7457) OASIS REPORTING SERVICES, LLC 702-476-4500 Document 100-3 Filed 03/16/15 Page 84 of 217 Case 2 Document 90-2 Filed 03/03/15 Page 30 of 51 Case Page 155 A Yeah. - many Nevada LLCs for which MF Nevada is the registered agent; right? A Uh-huh. Do you know why? A I don't know why, but I have a common sense. It's a nominee service, so they use it for many company with no no specific reason. When you say it's nominee services, can you explain what you mean by that? A Yeah. They use a nominee service in order to expedite the document to be sign here or incorporate. I told you in the past I was director of one these, and that's the only reason they use nominee service. I'm sorry. I'm just - you probably did answer this before. I'm just not completely understanding. So you say that they use Aldyne A Aldyne. as a manager because you were the assistant secretary for Aldyne? A No, no. They use a nominee services, MF Corporate. Mossack Fonseca offer to the client, and in our contract we supposed to serve it as a signature. I sign for them in order to expedite the process, and I think at that time was the nominee service for many Electronically signed by Ellen Goldsleln (001-341-013-1457) OASIS REPORTING SERVICES, LLC 702-476-4500 Page 156 1 entities. 2 I see. So it was just a 3 A It's not like because Aldyne is a beautiful 4 name, no. Aldyne was the manager for many entities. 5 When you say "nominee services," just explain to 6 me again what you mean by that. 7 A Nominee service is a service that you use in 8 order to expedite the documentation. If I'm a director 9 or secretary of this, I can Sign document here quickly 10 and legalize and I can send the company more quick then. 11 So if I understand what you're saying, by making 12 Aldyne the member, because you used to be the secretary i 13 for Aldyne 14 A Uh?huh, yes. 15 you could then sign documents on behalf of 16 Aldyne? 17 A Yeah, like the annual list. 18 So that made the process of setting up the 19 Nevada LLC 20 A Quick. 21 smoother and quicker? 22 A Uh-huh. 23 Is it your understanding that that's the only 24 reason that Aldyne was designated as 25 A That's what I get explained. Electronically signed by Ellen Galdsleln (001-341-678-7451) OASIS REPORTING SERVICES, LLC 702-476?4500 Document 100-3 Filed 03/16/15 Page 85 of 217 Case 2 Document 90-2 Filed 03/03/15 Page 31 of 51 Case chosen as the manager for many of these Nevada A MR. WOODS: THE WITNESS: Yes, that's a yes. BY MR. HRANITZKY: Aldyne? A A LLCs that you set up through MF NevadaPage 157 Just let me finish. Is it your understanding Yeah. - that that's the only reason why Aldyne was (Nods head.) Is that a "yes"? You're no longer the assistant secretary for No, I'm not. Do you have any position with Aldyne now? No. Is Aldyne used as the manager for new Nevada No. 5 No? That I see, no. Is there a new entity that you're the secretary: No. that does that? No? OASIS REPORTING SERVICES, LLC Electronically signed by Ellen Goldstein (001-3414134451) 702-476?4500 'Page 158 don?t remember that. 18 I see. 19 placeholder manager 20 A For many companies? 21 Yes. 22 A No. 23 That's not done anymore? 24 A No. 25 What is Gairns Limited? Is there any entity that frequently is 3 designated as the manager for new Nevada LLCs that you 5 A No, I'm not sure. They're all different kind, 6 no. In the present you're asking, now? 7 In the present, yes. 8 A No. Different kind. 9 It's always different names? 10 A Different name. 11 Never the same name is never used 12 A No. 13 twiceyou know? 16 A Well, maybe twice if it's the same client, but I But the practice of sort of using a OASIS REPORTING SERVICES, LLC Electronlcally algned by Ellen Goldsteln (001-341-678-1457) 702-476-4500 Document 100-3 Filed 03/16/15 Page 86 of 217 Document 90-2 Filed 03/03/15 Page 32 of 51 Page 159 Page 150 1 A I think I don't know_ It's another company, 1 the document. There are - that's the service we 2 but I don't know anything about it. 2 provide. 3 Did you have you ever had any position with 3 Did you ever so you never undertook any kind 4 Gairns Limited? 4 of investigation to satisfy yourself that Aldyne wasn't 5 A I don't remember_ I don't know, Maybe, but I'm 5 involved in some kind of criminal activity or wrongdoing? 6 not sure. I don't remember Sign anything for Gairns. 6 A Well: the thing ?_Enew abOUt Aldyner it 7 How long were you assistant secretary of Aldyne 7 wasn't a company incorporated asla shell:)because I see 8 Limited? 8 the address and I never thought it?w111 don't know. The only thing I remember is my 9 aCtiVitY- 10 resignation was in 2013, June; so that's all I remember. 10 You've never heard 0f Aldyne being inveStigated 11 Okay. Did you ever interact with anyone else at 11 criminally by Criminal Prosecutors in Argentina or 12 Aldyne 12 elsewhereNo, not until now, not until I will say until 14 - when you were the assistant just let me 14 I received the SUbPOena in August 2013- 15 finish. 15 So it's only because of the litigation 16 when you were the assistant secretary, you never 15 A Yeah- 17 interacted with anyone else at Aldyne? 17 inVOlVing just let me finish. 18 A No. 18 It wasn't until the litigation involving my 19 No? 19 client that you became aware 20 A No. 20 A Uh-huh. 21 Did that seem strange to you at all? 21 that Aldyne was being investigated 22 A No, they don't sound strange because I don't 22 A Yeah- 23 have to interact with anybody. 23 - by prosecutors in Argentina? 24 All you do is just sign on behalf of Aldyne? 24 A Yes- 25 A That's the contract of MF. I have to just sign 25 OkaY- And naVe YOU ever interacted 0r 702?476-4500 OASIS REPORTING SERVICES, LLC OASIS REPORTING SERVICES, LLC 702-476-4500 Electronically signed by Ellen Goldslein (001-3414184457) Case 2 Case 2 Electronlcally slgned by Ellen Goldstein (001-341-618-1451) Document 100-3 Filed 03/16/15 Page 87 of 217 14-CV-OO492-RFB-VCF Document 90-2 Filed 03/03/15 Page 33 0f 51 Page 161 Page 152 1 communicated with anyone else at Gairns? 1 available in their office but the following companies are 2 A No. 2 available from the stock in the Nevada office and it 3 Could you go to the second page of Exhibit 15_ 3 lists two, Exton International, LLC and Everina 4 Do you see in the middle there's an E?mail to Mr. Dex and 4 A Everina- 5 it's signed Gabor Kacsoh, K?a-c?s-o-h, from Experta 5 Everina HOIdingS Limited? 6 Corporate and Trust Services? 6 A Uh?huh. 7 A Uh?huh. 7 Does this mean that Exton International and 8 Have you ever heard of Experta corporate and 8 Everina Holdings were on the shelf at NE Nevada? 9 Trust Services? 9 A Probably. 10 A Never. I just pay attention this moment. 10 OkaY- waiting for 50m9b0dy to buy them? 11 Never. 11 A Uh?huh. 12 Do they appear to be a client of Mossack 12 Do you know who chooses the names for the 13 Fonseca? 13 entities that are sitting on the shelf at MF Nevada? 14 A Look like it's a client there_ 14 A No. I only check the request, what is the name 15 Okay. Now, read down below, You see at the 15 available and how they look. Some one I try to make it 16 bottom of the page it says, "Please be advised that we do 16 more make sense: bUt n0: ?Othing is SpeCifiC- I think 90 17 not have any company available in our office at this 17 by the ABC: like mix name- Nothing is 18 time. However, the following companies are from the 18 OkaY- 50 I'm jUSt I'm not sure I understand 19 stock of our Nevada office," right, and this is an E?mail 19 Your answer- 20 from Jost Dex. 20 Are you saying you don't choose the names 21 A "Please be advised" - okaydon't Choose- 22 This is an E-mail from Jost Dex to this person 22 Let me jUSt finiSh- 23 at Experta?Lux. 23 You don't choose the names of the companies that 24 A Uh-huh. 24 you keep on the shelf at MF Nevada? 25 And he says they don't have any companies 25 A Uh'hUh- Case 2 Case 2 702-476-4500 OASIS REPORTING SERVICES, LLC Electronically signed by Ellan Goldsteln (001-341-673-1451) OASIS REPORTING SERVICES, LLC 702-476-4500 Elactronlcally signed by Ellen Goldsuln (001-341-613-1457) Document 100-3 Filed 03/16/15 Page 88 of 217 Case 2 Document 90-2 Filed 03/03/15 Page 34 of51 Case stupid name"? A Well, I say every day this is a stupid long name, but well, but if the client like it Well, but this is before the client buys it; right? A Well, but I think the marketing department, they study what name they like it more, like E, B. check the people with double Y. other letters, so it's interesting. company names they like best? You never know. I15 A it because sometimes the name is too long and nobody see it in their document, so I recommend shorter. A A Page 163 Do you know who chooses those names? Probably the sale department. At Mossack Fonseca? The Iris and Suzy, they propose some name and I But you never say, "Oh, come on, Iris. This is Myself, I They like it more than Do they do focus groups and ask people what Maybe. You know, marketing is for everything. It?s a big business. Okay. Let's move to Exhibit No. 17. Oh, I'm lost. 17. Oh, 17, here. OASIS REPORTING SERVICES, LLC Elucironically slgnod by Ellen Goldsleln (OM-34145134451) *5 702-476-4500 Page 164 1 Have you seen Exhibit 17 before? 2 A Uh?huh. 3 Okay. At the top, this is an E?mail from 4 Mossack Fonseca Company (corporations Nevada) to 5 Mossack Fonseca Company Uruguay and there's a copy to 6 you. Do you see that? 7 A Uh-huh. 8 And it's signed by Iris Vergara? 9 A Vergara. 10 Do you know what Mossack Fonseca Uruguay is? 11 A I believe it's an office there, but that's all I 12 know. 13 An office of Mossack Fonseca in Uruguay? 14 A Uh-huh. 15 Do you sometimes receive E-mails from Mossack 16 Fonseca Uruguay? 2 17 A No, not very often. 18 But occasionally? 19 A Well, like you say this one, this one is like a 20 copy for some. I get copy of the E-mail, not directly 21 from them. 22 But do you ever get requests to set up Nevada 23 LLCs for clients of the Mossack Fonseca Uruguay office? 24 A Not direct to me. 25 But this is a request that's coming through Iris OASIS REPORTING SERVICES, LLC Electronically signed by Ellen Goldslein (001-341-678-7457) 702-476?4500 Document 100-3 Filed 03/16/15 Page 89 of 217 Document 90-2 Filed 03/03/15 Page 35 of 51 Page 165 Page 166 1 for a Mossack Fonseca Uruguay client; right? 1 A We don't deal With the quote to them, no. 2 A Uh-huh. 2 Now go to the second page. Do you see this is 3 Is that "yes"? 3 an E-mail from Lorena Miranda? 4 A Yes. 4 A Uh?huh. 5 Y0u agree? 5 And she appears to be a lawyer; right? 6 A I believe so. 6 A I don't know. 7 So occasionally you do get these kinds of 7 W611: it says "liCda-" 8 requests for clients of Uruguay; right? 8 A LicenCiada- 9 A Indirectly, yeah. 9 Licenciada, doesn't that mean lawyer? 10 Indirectly through Iris? 10 A Yeah, probably. Don't mean - it could be a 11 A Uh_huh, through Iris_ 11 lawyer, but it's a I don't know. In Latin American I 12 You see that there's a number of fees listed? 12 thiNk they call licenCiada any People Who are from 13 A Uh?huh. 13 university I believe. I don't know. 14 For example, under the paragraph numbered 1, you 14 OkaY- 50 YOU don't knOW? 15 see ?The cost is as follows," and then the first item is 15 A Yeah- 16 "our fee" 16 You don't know if Lorena is a lawyer? 17 A Uh?huh. 17 A No, I don't have no idea. 18 $175? 18 But this is an E-mail that she is sending to you 19 A Uh-huh. 19 and to Iris - 20 Does that go to ME Nevada or does that go to 20 A Uh'hUh- 21 Mossack Fonseca? 21 right? 22 A Mossack Fonseca. We don't touch any of this. 22 A Uh?hUh- 23 That's completely different amount that we charge. This 23 sayingI "Please address the Client's question 24 is different. 24 and send your comments. Thank you." You see that? 25 I see. 25 A Yes. Case 2 Case 2 702-476-4500 OASIS REPORTING SERVICES, LLC Electronically signed by Ellen Goldeleln (001-341-613-7457) OASIS REPORTING SERVICES, LLC 702-476-4500 Electronically signed by Ellen Goldeteln (001-341-613-7457) Document 100-3 Filed 03/16/15 Page 90 of 217 Case 2 Document 90-2 Filed 03/03/15 Page 36 of 51 Case Page 167 So this is a request that's coming to you from Uruguay. It's going to Iris at the same time, but Uruguay is making a request to you directly to address the client's question; right? A Uh?huh. Did you address the client's question? A Probably not, because I don't allow to respond directly. Probably I give whatever answer is to Iris and Iris respond. It's all depend on request. Okay. Now could you go two pages two more pages. Now we're on the page TRANSLATION MFCS 000902. A Oh, 902. See that? A Uh?huh. This is an E-mail from Mossack Fonseca Corporations Nevada to Mossack Fonseca Uruguay. A Uh-huh. Do you see that? A Uh?huh. 2 All right. And it's signed by someone named Edison Teano. A Tee-an?o. Teano. Who is Edison Teano? A It's a lawyer in Panama. He works at Mossack Fonseca in Panama? OASIS REPORTING SERVICES, LLC Eloctranlcally by Ellen Golditaln (001-341-078-7457) 702-476-4500 Page 168 A E-mail says at the top, "Dear Odile." A Uruguay office, but I don't know either. A of Exhibit 18. bottom. A 3? 10 3510 Geneva to you. A A names I don't recall, but A I don't know. I think so. Okay. And then do you know who Odile is? This Do you see that? No, I don't know. Probably he work at the Okay. Go to Exhibit - did we mark 18? So we're going to yes, okay. Now I'd like you to turn to the very last page It has the number MFCS 002229 at the Do you see that? You're saying the last page? The last pagehas MFCS Yeah, 2229. 002229. Do you see that? Uh?huh. This is an E?mail from Miguel Diaz at Mossfon Do you see that? Uh-huh. Who is Miguel Diaz? I don't know. Like I say, they have so many But here Miguel Diaz is sending you an E?mail. Yeah. Electronically signed by Ellen Goldstoin (001-341-613-1457) 702-476-4500 OASIS REPORTING SERVICES, LLC Document 100-3 Filed 03/16/15 Page 91 of 217 Case 2 14-CV-OO492-RFB-VCF Document 90-2 Filed 03/03/15 Page 37 of 51 Case 2 1 2 A Uh-huh. 3 8 9 itabout this company? 17 18 validity of the business license? 19 A 20 license what year is this, 2013? 21 '13. 22 A 24 they can be legalized, yeah. 25 Is this He appears to work at Mossack Fonseca in Geneva. And he's asking you about setting up a Nevada 4 company called Eastfer International for a client of 5 Mossack Fonseca's Geneva office; correct? 6 A Well, they ask me to identify the validity, 7 authenticity, of the business license. So it's not this isn't to set up the company; You're being asked to look for some information 13 A No. I understand was checking the business 14 license, if the business license - they can be legalized 15 or something from official company from official 1 16 registration, meaning Secretary of State. 50 can you explain, what does that mean, the What does that mean? 3 They want to know probably that the business They probably need to prove that the business 23 license at Secretary of State extend for each company; Page 169 Electronically signed by Ellen Goldslein (001-341-673-7451) OASIS REPORTING SERVICES, LLC 702-476-4500 Page 170 ?1 A Authenticity, if you can authenticate the 2 document, ask for apostille. Authentication of document 3 is when you get any paper from here and I want to show 4 you in another country, validate; and the only way you Secretary of State and apostille to 6 certify for that. That's what I understand here what is 7 they try to say. 8 I see. So they're asking you to go to the 9 Secretary of State and - 10 A And 11 Hold on. Just let me finish. I 12 and get an apostilled copy of the business 13 license of this company? 14 A I don't know if they say. They ask me if it's 15 possible to authentication of this document. That's what I 16 I understand. 5 17 They're asking you if it's possible to obtain 18 A To obtain. 19 an authenticated document? 20 A Of the business license. 21 Is Eastfer International a Nevada LLC for which I 22 MF Nevada serves as registered agent? 23 A At this time I can't answer it because I don't 24 know. Maybe, yes, but I don't know. I need to go and 25 check my list. Electronically signed by Ellen Goldelein (001-3414734457) OASIS REPORTING SERVICES, LLC 702-476-4500 Document 100-3 Filed 03/16/15 Page 92 of 217 Case 2 Document 90-2 Filed 03/03/15 Page 38 of 51 Case Page 171 If it wasn't, do you know why Miguel Diaz would have been asking you this question? A Because probably say itit's not, probably I don't do it. Well, do you remember if you did or not? A No, I don't remember. I just remember I mean I just see this now. I don't have no idea about it before. Probably I don't recollect memory to this question. So you don't remember, as you sit here now, being asked by Miguel Diaz the question in this E-mail? A Yes, I don't. And you also don't remember what you did - A I don't remember if I did it or I don't did it, if I answer or I don't answer, no. Okay. And you don?t remember whether Eastfer International, LLC is a company for which MF Nevada is a registered agent? A I have many companies, okay? I don't remember if this one is in my list. Probably was and now it's not, so I don't remember. Okay. If it was, just assuming that it was, would you have do you think you would have given Miguel Diaz the information that he was asking for? A Of course I will give the information and I will Electronically signed by Ellen Goldaleln (001-341-675-1457) OASIS REPORTING SERVICES, LLC 702-476-4500 Page 172 1 check if the company is in good standing before. 2 So is that part of your responsibility? 3 A My work, yeah, because the business license - 4 you can't obtain a business license if the company is not 5 good standing. Secretary of State is not going to give 6 me a copy if the company don't have current. 7 But for companies where MF Nevada is the 8 registered agent, is responding to inquiries like this 9 part of what MF Nevada is contractually obligated to 10 do - 11 A Yes. 12 for Mossack Fonseca? 13 A Yes. That's part of the service. 14 Okay. So now if you could go to Exhibit 19, so 15 could you take a look at Exhibit 19. 16 A Uh?huh. 17 Have you seen Exhibit 19 before? 18 A Not until now. It?s a long?time document, so I 19 don't know. 20 You see in the second towards the bottom of 21 the first page 22 A Uh-huh. 7 23 - there's an E?mail from Monica Ycaza from the 24 Peru representative office 25 A Uh-huh. 702-476-4500 OASIS REPORTING SERVICES, LLC Electronically signed by Ellen Goldsloin (001-341-678-7451) Document 100-3 Filed 03/16/15 Page 93 of 217 Case 2 Document 90-2 Filed 03/03/15 Page 39 of 51 Case Page 173 to ME Corporate Services Nevada and to Mossack Fonseca Company (corporations Nevada)? Do you see that? A Uh-huh. Let me see where oh, yeah, copy to me, yeah, MF Corporate Services. I see it, copy to me. Actually I'm asking you - I'm not asking you to look at the E?mail at the top of the page. A Oh. I'm asking you to look at the E-mail towards the bottom of the page. You see it's an E?mail from Monica Ycaza to MF Corporate Services Nevada and to Mossack Fonseca Company (corporations Nevada) dated October 29th, 2007 at 12:30 A Okay. You see that? A Uh-huh. So this is an E?mail that Monica Ycaza from the Peru representative office is sending to you and to the 3 Nevada marketing department at Mossack Fonseca. A Uh?huh. Right? A Yes. And in this E?mail Ms. Ycaza is telling you that a client wants to incorporate a company called Permanel Investment Limited. Do you see that? Electronically slgnod by Ellen Goldamin (001-341-678-7457) OASIS REPORTING SERVICES, LLC 702?476-4500 Page 174 1 A Uh-huh. 2 And it's an expedited request. Do you see that? 3 They want it 4 A Yeah. 5 Okay. So you said before during your deposition 6 that you didn't recall ever getting any requests from 7 Monica Ycaza in the Peru representative office. Does 8 this refresh your recollection that sometimes you did? 9 A Sometime I did, but sometime I like you see, 10 I get copy from the E-mails, from the back E?mails, and I 11 don't supposed to respond because the sale department 12 need to deal with that so it's only one hand go to 13 answer; but I received sometime, yes. 3 14 Okay. So you wouldn't respond to Ms. Ycaza, but 15 sometimes you'd get requests like this from Ms. Ycaza? 16 A Uh-huh. 17 Is that sorry just "yes"? 18 A Yes. 19 All right. Do you see again in that E-mail 20 towards the bottom of the first page it says - Ms. Ycaza 21 says, "Can we also make Murriel with Aldyne and the other 22 two with Plascot"? Do you see that? 23 A Yes. 24 Do you know why she would want to do that? 25 A I don't know. Electronically signed by Ellen Goldstein (001-3414784457) OASIS REPORTING SERVICES, LLC 702-476-4500 dc74e27 5-4a77-4470-b382-fc426d92d360 Document 100-3 Filed 03/16/15 Page 94 of 217 14-CV-OO492-RFB-VCF Document 90-2 Filed 03/03/15 Page 40 of 51 Page 175 Page 176 1 No idea? 1 A I don't manage the shelf stock. I incorporate 2 A No idea, She choose what she want_ 2 my shelf stock, but the client do it; Mossack Fonseca do 3 Okay, Could you go to the page that at the 3 it. So I don't have no control about that, so I can't 4 bottom says TRANSLATION MFCS 006582. 4 answer that question- 5 A Uh?huh. 5 You don't know? 6 Are you there? 6 A I don't have no control of that. 7 A 6532? 7 And then in the next paragraph it says, am 8 Yes, 8 also attaching our listing of available LLCs in 9 A okay, I am_ 9 Panama" strike that. Forget I asked that. 10 You see the E?mail that begins in the middle 10 When an LLC is created to be 0? the Shelf, 11 from Mossack Fonseca (corporations Nevada) to Ms. Ycaza 11 does it have a manager or member? 12 at Peru representative office with a copy to Mossack 12 A head-) 13 Fonseca Peru representative and to you? Do you see that? 13 "Yes"? 14 A Yeah. I'm in the copy of the E?mail. 14 A Manager- 15 Okay. And in this E-mail Iris Vergara asks 15 It has a manager- Does it have any member? 16 Monica Ycaza - or tells Monica Ycaza that, first, that 16 A I mean I don't do the document- PrObablY 17 there's two companies, two LLCs, on the shelf at Mossack 17 they have: bUt I don't do the document- I incorporate it 18 Fonseca Peru; right? 18 with a manager and I pack it and I send it to Panama. I 19 A Uh_huh_ 19 keep copies on my shelf, but I send all the companies to 20 okay. And then in the next paragraph it says 20 Panama. They can sell it at any time. I don't sell 21 there's another company which was incorporated for Peru 21 anything here myself- 22 but was sent to Panama. Do you see that? 22 I see- 50 it has a - you know it has a 23 A Uh?huh. 23 manager - 24 What does that mean, it was incorporated for 24 A Yeah- OtherWise I can't incorporate- 25 Peru but it was sent to Panama? 25 when you incorporate it. You send it to Case 2 Case 2 702-476-4500 OASIS REPORTING SERVICES, LLC OASIS REPORTING SERVICES, LLC 702-476-4500 Electronically signed by Ellen Goldstein (001-341-618-7457) Electronlcally slgned by Ellen Goldsteln (001-341-613J457) Document 100-3 Filed 03/16/15 Page 95 of 217 Case 2 Document 90-2 Filed 03/03/15 Page 41 of 51 Case Page 177 Page 178 Panama. Maybe Panama designates a member. You don't 1 OkaY' so MF Nevada doesn't use the MOSSfon-com know? 2 domain name; right? It does not? A I don't know. 3 A No. We don't have no. We're a different But it sits on the shelf of stock until it gets 4 Company' sold? 5 Right. But the Peru representative office does A Until it gets sold, yeah. 6 and the Florida representative office does. Do you know Okay. Now if you could turn to the page that 7 if there?s any other Mossack Fonseca representative says at the bottom TRANSLATION MFCS 006583. 8 offices that have their own domain name besides Nevada? A 0h, 83, okay. 9 A I don't know. I don't have any idea about it. 83_ DO you see the last E_mail on that page is 10 I only have about my domain name, MF Corporate Services. from Monica Ycaza to ME Corp. and there?s a copy to 11 Do You know Why Nevada has its own domain name Nevada?Panama office and Peru@Mossfon.com? Do you see 12 and the others don't? that? 13 A Because we are a different company. A you're talking the last E_mail? 14 Whereas the others are not separately The last E-mail, yes. 15 incorporated? A From Monica Ycaza to ME Corp., me, and copy to 16 A PrObablY Nevada_Panama_ i 17 Does Wyoming have its own domain name? And My Corp_ is you; right? 18 A No. They have the same us because it's part ofg A Yes_ 19 us, like mfcorpserv.com. It's Wyoming mfcorpserv.com. i And that's 20 50 MF Nevada and MF Wyoming are the same Iris; right? 21 company? A yes_ 22 A No, not the same. And then Peru@Mossfon.com, that's the Peru 1 23 representative Office? 24 A They are I don't know how it's called. A Uh_huh, I believe so. I don't know_ 25 MR. WOODS: Use the translator. Eloctronlcally signed by Ellen Goldsmin (001-341-670-1457) OASIS REPORTING SERVICES, LLC 702-476-4500 Electronically signed by Ellen Goldslein (001-341-678-1457) OASIS REPORTING SERVICES, LLC 702-476-4500 Document 100-3 Filed 03/16/15 Page 96 of 217 Case 2 Document 90-2 Filed 03/03/15 Page 42 of 51 Case THE Page 179 WITNESS: (Through the interpreter) A subsidiary. BY MR. HRANITZKY: A So MF Wyoming is a subsidiary of MF Nevada? Yes. Is MF Wyoming a wholly owned subsidiary of ME Nevada, if you know? MR. THE THE MR. percent A know. WOODS: Do you understand the question? WITNESS: No, I don't understand the question. INTERPRETER: Could you repeat the question. HRANITZKY: Wholly owned subsidiary, a hundred owned by. Is MF Wyoming 100 percent owned by ME Nevada? I understand, yes, but I?m not sure. So I don't Okay. Have you ever seen any of the corporate documents from MF Wyoming, the organization documents? A The Article of Incorporation only, the signed corporate, but I don't know the rest. A A MR. Who is the manager of MF Wyoming? MF Nevada. Okay. And - And I sign in behalf. And who are the members of MP Wyoming? WOODS: You went over that; right? Electronlcally nlgnod by Ellen Goldsleln (001-3414184457) OASIS REPORTING SERVICES, LLC 702-476-4500 Page 180 1 MR. HRANITZKY: No. Wyoming we're talking about. 2 MR. WOODS: Right. You asked if it's a hundred 3 percent subsidiary. 4 MR. HRANITZKY: Well, maybe it wasn't obvious to me 5 that 6 MR. WOODS: That it's not the same thing? 7 Okay. Well, if you know the answer, you can 8 answer. 9 THE WITNESS: I believe - I'm not sure 10 MF Corporate Service Nevada is the manager and I can sign 11 on behalf and MF Corporate Services Nevada is the member. 12 I'm not sure. 13 MR. HRANITZKY: Okay. Why don?t we take a short 14 break. 15 (Brief recess taken.) 16 (Plaintiff's Exhibits 22 through 27 were marked 17 for identification by the Certified Court Reporter.) 18 BY MR. HRANITZKY: i 19 So, Miss Amunategui, I'd like you to look at the i 20 document that's been marked as Exhibit 22. I 21 A Uh-huh. 22 Do you recognize this document? 23 A I recognize the E?mail. 24 Okay. So do you see your signature on one of 25 the E-mails here? Electronlcally slgned by Ellen Goldstoln (001-341-618-7457) OASIS REPORTING SERVICES, LLC 702-476-4500 Document 100-3 Filed 03/16/15 Page 97 of 217 Case 2 Document 90-2 Filed 03/03/15 Page 43 of 51 Case Page 181 A Uh?huh. It's an E?mail from you to Odile Frederick? A Uh?huh. And to Mossack Fonseca (corporations Nevada), which is Iris? A Iris Vergara, yes. Do you recall I asked you before if you ever communicated with Odile in the Uruguay office? Do you recall that? A No, but I see the E-mail; and sometimes happen with the company, when they looking for a package that I send it, the office would call me to give me again the number, and I'm hundred percent get it in the mail because they don't receive it right away. So that happen sometime. They contact to refer to the DHL number, whatever it is. But this was a DHL package you would have would you have sent this to Panama or to Uruguay? A To send it to I don't remember. You don't remember, but sometimes do you send DHL packages to Uruguay? A Yes. I say, I think in the beginning, sometime I send the package straight to Panama or whatever address Panama indicates to send it. If I send it to Uruguay, it's because Panama want the package go there and then OASIS REPORTING SERVICES, LLC Electronically signed by Ellen Goldetein (001-341-673-7457) 702-476-4500 Page 182 1 they go back again. Some document need to be rush that 2 place. 3 When you send it to Uruguay, do you send it to 4 the Mossack Fonseca Uruguay office or do you 5 A Normally, yes. That's the only address I have. 6 Sometimes do you send packages directly to the 7 Mossack Fonseca Peru office? 8 A Sometime, yeah, if they request it. 9 Have you ever sent packages to the Mossack 10 Fonseca Miami officedon't remember, no. 14 50 Exhibit 23, so the next document 15 A Oh, okay. 16 - this is an E-mail from Edison Teano. 17 A Tee?an?o. 18 Teano, sorry. 19 A It's okay. 20 And he's in the marketing office at Mossack 21 Fonseca; is that right? 22 A I don't know where he is. I know he's an 23 attorney, but I don't know where he is. 24 He's an attorney? 25 A Uh?huh. OASIS REPORTING SERVICES, LLC Electronically signed by Ellen Goldslein (001-3414784457) 702-476-4500 Document 100-3 Filed 03/16/15 Page 98 of 217 Document 90-2 Filed 03/03/15 Page 44 of 51 Page 183 Page 184 says it's from ME 1 "Yes"? 2 Company - Corporations (Nevada). Do you see that? 2 A Yes- 3 A From in the top? 3 Do you get E?mail when it goes to that E-mail 4 Yes, 4 address? Are you copied when it goes to that E-mail 5 A Yeah. 5 address? 6 Okay, 6 A No, I don't copy. Maybe somebody copy from that 7 A At that time 7 E-mail address, yeah, but I don't copy. 8 That's the E-mail you sometimes use for Iris 8 If that's a Shared E?mail address: You're not 9 too; right? 9 one of the people that it's shared with. That's what 10 A Sometime he work in that section I believe. 10 You're saying? 11 But he's a lawyer? 11 A Okay. If I have to communicate with Iris, I use 12 A He's a lawyer, yes. I know he's a lawyer. 12 that E'mail- 13 Okay. Do you know if the E?mail address 13 Okay. But if somebody sends an E?mail to that 14 is that an E?mail that 14 E'mail address! You don't get 15 goes to several people or is it just does it just go 15 A always If they Put me there - 16 to one person? 16 sometime they copy something - I can't control. 17 A I don't know. That's the only E_mail I use, but 17 I see, okay. Could you go in the same exhibit 18 I don't know if it go to several people or only one. 18 t0 the Page MFCS 005311- 19 That's something I don't know. 19 A Okay. 20 But we've seen from the documents that several 20 DO You see at the top this is an E-mail from 21 people use that E-mail address; right? 21 Dex to DO YOU see that? 22 A Right, but I don't know. 22 A Uh-huh. 23 But we've seen from the documents that several 23 So is this another instance where Jost Dex is 24 people do? 24 asking you a question, on behalf of one of his clients, 25 A Uh?huh. 25 about Nevada Case 2 Case 2 702-476-4500 OASIS REPORTING SERVICES, LLC OASIS REPORTING SERVICES, LLC 702-476-4500 Electronically signed by Ellen Goldsloin (001-341?618-1457) Electronically Ilgnod by Ellen (001-341-678-1457) Document 100-3 Filed 03/16/15 Page 99 of 217 Case 2 Document 90-2 Filed 03/03/15 Page 45 of 51 Case Page 185 A Yes. Sometime I get this E?mail when they don't have the answer right away from the other office. And when you get an E?mail like this from Jost Dex, do you usually respond to it? A Normally not. You just ignore it? A No, not ignore. Probably I forward or I make a phone call and I call Iris, somebody in the department, and say, "Please taking care. This person needs some help or need respond to E-mail." Okay. Because you're not supposed to respond directly to Jost? A I'm not involved on the entire rest of the marketing thing. I don't have to deal with them; but sometime for better services I answer, I will respond right away, but I call the people to respond. Okay. A It's not my job to respond though. It's no% your job to respond to Jost? A Yes. ?wCould you now in the same exhibit go to the page MFCS 005316. A Okay. Do you see at the top it's an E?mail from Jost Dex - OASIS REPORTING SERVICES, LLC Electronically signed by Ellen Goldslaln (001-341-618-1451) 702-476-4500 Page 186 A YesNevada department? Do you 3 see that? 4 A In the beginning you say? 5 At the top. 6 A Yeah. 7 It's an E-mail dated Monday November 22, 2004 at 8 6:46 a.m. from Jost Dex to you with a cc to PA Nevada 9 department. Do you see that? 10 A Uh?huh. 11 Who is PA Nevada department? 12 A I don't know. This is the first time I see that 13 E?mail. 14 Well, it's not the first time you've seen it, 15 but it's the first time you've seen it in a long time? 16 A Yeah, it's a long time. I didn't pay attention 17 to the cc copy; but I don't know what it is. 18 Could it be Power of Attorney? 19 A No. I think sounds like a more Panama?Nevada 20 department or something. 21 It's my name but it's not my E?mail, so 22 Well, it was sent to you though; right? 23 A The only address I have it for many years is 24 MF Corporate Service Nevada. I don't have any other. I 25 don?t have any other. Electronically signed by Ellon Goldnoin (001-341-678-7457) OASIS REPORTING SERVICES, LLC 702-476?4500 Document 100-3 Filed 03/16/15 Page 100 of 217 Case 2 Document 90-2 Filed 03/03/15 Page 46 of 51 Case Page 187 But this was sent to you, right, because it says A Yeah, but they sent "Dear Patricia." A But the top is for something else. Right. I'm just talking about the A Oh. I thought you were talking about the top. So this went to you and it was copied to PA Nevada department, whatever that is? A Yeah, uh?huh. Okay. We can go to Exhibit 24. MR. WOODS: It's the next document, Patricia. We're' done with that one. THE WITNESS: Okay. We're done with this one? MR. HRANITZKY: Yes. On this one I'd like you to go to the page thatk says at the bottom TRANSLATION MFCS 006489. I A Okay. Now, you see at the bottom there?s an E?mail from Edison Teano? A The bottom or the beginning? No. This is at the bottom of the page called TRANSLATION MFCS 006489, the E-mail that begins at the bottom of that page. See that? MR. WOODS: But it continues to the next page. OASIS REPORTING SERVICES, LLC Electronically signed by Ellen Gold?oln (001-341-678-1457) 702-476-4500 Page 188 1 MR. HRANITZKY: And continues to the next page. 2 THE WITNESS: Oh, okay. I see that, okay. 3 BY MR. HRANITZKY: 4 See what I'm talking about? 5 A Yeah. 6 And it's an E?mail from Edison Teano to Odile in 7 the Uruguay office. 8 A Uh?huh. 9 See that? 10 A Uh?huh. 11 And it begins, "Dear Odile, as we do each year, 12 we are organizing the incorporation of reserves for our 13 various jurisdictions. We are pleased to inform you that 14 the partners have approved the following stock for your 15 office for 2006 as listed below," and then you see 16 there's a little chart? 17 A Uh?huh. 18 It says it lists the jurisdiction, the stock 19 approved, and the stock for the beginning of the year. 20 Do you see that? 21 A Uh-huh. 22 And then it lists first it lists Samoa and 23 there's one - the stock approved is 1 and the stock for 24 the beginning of the year is 1; and then it lists Bahamas ?25 and then Seychelles, Panama, Nevada and Uruguay. Do you OASIS REPORTING SERVICES, LLC Electronically signed by Ellen Goldstaln (001-341-673-7457) 702-476-4500 Document 100-3 Filed 03/16/15 Page 101 of 217 Case 2 Document 90-2 Filed 03/03/15 Page 47 of 51 Case 2 9 the beginning of the year, 2. 10 A (Nods head.) 11 What does that mean? 12 A 13 don't handle this. 14 know. 15 16 that you have on the shelf? 17 A 18 know what it is. I don't know. 19 talking about I don't understand. 20 21 to the beginning again. Page 189 1 see that? 2 A Uh-huh. 3 And you see for Nevada - which is MF Nevada; 4 right? 5 A Uh?huh. 6 It lists - was that a "yes"? 7 A Yes. 8 Okay. It lists stock approved, 3, and stock for Do you see that? I don't have no idea what it can mean because I I never understand this. No, I don't Is it a reference to the number of companies Probably but, no, I don't think it's - I don't It's some language they All right. Well, see, it says let's go back "As we do each year, we are 22 organizing corporation reserves for our various 23 jurisdictions. We are pleased to inform you that the 24 partners have approved the following stock for your 25 office for 2006 as listed below." Electronically signed by Ellen Goldeteln (001441-675-1457) OASIS REPORTING SERVICES, LLC 702?476-4500 Page 190 1 A This is from me to Odile? No. 2 No, I realize this is not an E-mail to you. 3 A Yeah. This is a conversation for them. 4 I?m asking you if this helps you to understand 5 what Edison is talking about when he refers to the stock 6 of reserves. 7 A I don't know. It's hard to understand. I don't 8 know if they talking about all these jurisdictions that 9 incorporate in that jurisdiction or a company they want 10 to have. I don't have no idea. I don't know. Very 11 confusing. 12 If you don?t know, then we can just move on. 13 A Yeah, I don't know. 14 Let's move on. 15 So Exhibit 25, you see Exhibit 25? In the 16 middle there's an E?mail from Morelia Jaspe in the 17 Venezuela office to ME Company Corporations (Panama). 18 Do you see that? 19 A Uh?huh. 20 And in this Ms. Jaspe asks Verna at MF 21 Company Corporations, "Please, we urgently need two 22 Panamanian companies for the year 2003. A client needs 23 them with utmost urgency." Do you see that? 24 A Uh-huh. 25 And the E?mail is dated November 2004. Electronically slgned by Ellen Goldsleln (001-341-673-1457) OASIS REPORTING SERVICES, LLC 702-476-4500 Document 100-3 Filed 03/16/15 Page 102 of 217 Case 2 Document 90-2 Filed 03/03/15 Page 48 of 51 Case Page 191 Do you ever receive requests from Panama for companies that were created some year in the past? A Say it again. I'm sorry, I don't understand the question. Sure. Do you ever receive requests from Mossack Fonseca in Panama for a Nevada LLC that was created in some specific year in the past? A Not that I know of. You don't recall that ever happening? A when we get requests company for shell, they only ask for the name and how many we have and we inform information, but not actually looking for company on specific date. That?s what you try to tell me, no, date? Yes, that's what I'm asking. A No, not can I recall. You get requests for a particular company on the shelf? A Yes. But you don't get requests for a company on the shelf that was created in a specific year? A No. That's what you're saying? A That I cannot recall. So you don't recall ever getting any requests OASIS REPORTING SERVICES, LLC Electronically signed by Ellen Goldshin (001-341-618-7451) 702-476-4500 Page 192 1 A Maybe, but I don't remember. 2 You don't recall getting any requests like this? 3 A This is the first time I saw this name. 4 Well, you weren't copied on it, so it didn't go 5 to you. I'm just asking if you ever got a request like 6 this. 7 A No. 8 Okay. Let's move to Exhibit 26. Exhibit 26, 9 you see this is an E?mail from Iris Vergara to you dated 10 June 10th, 2008 and it attaches a Power of Attorney and 11 Resolution. Do you see that? 12 A Attached - yeah, okay. 13 Okay. And then you see if you flip past 14 this, do you see that there's a 15 A Oh, here it is. I 16 Power of Attorney that's attached? 17 A Uh?huh, uh-huhthe Power of Attorney it says 19 signed by you, deputy secretary on behalf of Aldyne. 20 A Uh-huh. 21 Do you see that? 22 A Yes. 23 While you were secretary of assistant 24 secretary or deputy secretary of Aldyne, did you get 25 requests like this from time to time? OASIS REPORTING SERVICES, LLC Electronically signed by Ellen Goldsleln (001-341-678-7457) 702-476-4500 Document 100-3 Filed 03/16/15 Page 103 of 217 Case 2 Document 90-2 Filed 03/03/15 Page 49 of 51 Case Page 193 A Yes. So this was fairly common? A Yes, very common because I need to legalize the document here. Do you see the apostille in the bottom? Uh?huh. A That's what this is. And you said that you're no longer assistant secretary - A Yeah. of Aldyne? A No. Why did you cease to be assistant secretary of Aldyne? A Why I was? Why did you stop being assistant secretary of Aldyne? A In the past couple years, three or four years ago, the law on United States changing a little bit. It's coming with new regulation, and I feel like I need to check with the attorneys here about if it will be any concern for me, and I was recommended to don't do it anymore. So you were advised to request that you no longer be assistant secretary A Yeah. OASIS REPORTING SERVICES, LLC Electronically signed by Ellen Goldstoln (001-3416784457) 702?476-4500 Page 194 1 - to Aldyne? 2 A Yeah. I feel more confident I don't do it 3 because there are FER, what they call Foreign Bank 4 Report 5 Regulation? 6 A - and regulation and FATCA is coming in effect 7 July this year for any U.S. person; and I don't have 8 nothing to do with this client, so I don't want to, you 9 know, have any concern about it. So I decided to resign. 10 You referred to FATCA. What is that? 11 A FATCA. 12 13 A I don't know exactly what that mean, but it's a 14 request I think it's coming in July lst, 2015 that 15 any U.S. person need to report whatever is involved 16 outside the country, so I don't feel comfortable to Sign 17 on this document. 18 Okay. 19 A I?m a U.S. person and I want to follow the law. 1 20 Right. Well, I won't ask you what you were 21 advised by your lawyers. 22 A But I get advice from my lawyer to don't sign it 23 anymore. It will be better. 24 Okay. 25 A I didn't study a lot about this one. Sorry, I OASIS REPORTING SERVICES, LLC Electronically signed by Ellen Goidslein (001-341-673-1457) 702-476-4500 Document 100-3 Filed 03/16/15 Page 104 of 217 Case 2 Document 90-2 Filed 03/03/15 Page 50 of 51 Case Page 195 don't know the site, but it's So you're talking about the Yes, FATCA. The Foreign Account Tax Compliance Act. I see, okay. document. A at Mossfon Peru to you and to Iris or whoever was A A know what she do. i A E-mail before. to time? A Now could you turn to Exhibit 27. It's the next Oh, okay. You see Exhibit 27 is an E-mail from Susana Kam Iris Vergara. in her job at that time? Uh-huh. Do you see that? Uh?huh. Oh, it is to Iris, right. Who is Susana Kam? I think she work in Peru office, but I don?t Okay. Do you recall getting - E-mail with her, yeah. I see this name in the So you recall getting E-mails from her from time Yeah. OASIS REPORTING SERVICES, LLC Eloctronlcally algned by Ellen Goldsloln (001-341-678-7457) 702-476-4500 Page 196 1 Okay. Now, do you see the E?mail reads, "Dear 2 Iris, the client has confirmed he wants the company. 3 Please move forward with the incorporation," and then the 4 first line reads, "The company will have a capital of 5 $500,000." Do you see that? 6 A Uh-huh. 7 Why is that information relevant to you or to 8 Iris? 9 A Nothing to me. To Iris, yes, because Iris in 10 charge to collect all this information to make the 11 document, to prepare the document, the Operating 12 Agreement and all the rest. 30 it's not related to me, 13 but it's related to her. 14 So that's information for 15 A Iris. 16 That's information that Iris will use to prepare 17 the Operating Agreement? 18 A Uh?huh. 19 Do you have any role in deciding what the 20 capital of the company will be? 21 A Oh, no. 22 Okay. And then if you go down to the E?mail at 23 the bottom of the page, at the bottom of the page is an 24 E-mail from Iris to you. Do you see that? 25 A Uh-huh. OASIS REPORTING SERVICES, LLC Electronically signed by Ellen Goldstein (001-341-613-1457) 702-476-4500 Document 100-3 Filed 03/16/15 Page 105 of 217 14-CV-OO492-RFB-VCF Document 90-2 Filed 03/03/15 Page 51 of 51 Page 197 Page 198 1 It says, would appreciate it if you can 1 knows if somebody incorporate a company with that name 2 confirm that the name Cosmetech, LC is still available in 2 two months after I CheCk- 3 Nevada." 3 Okay. Well, so she gave you the case number, so 4 A Yes. 4 what do you 5 "Please refer to case No. 1314907." What is she 5 A She opened the case. 6 talking about when she refers to case No. 1314907? 6 She Opens the case? 7 A Normally what happen, the client jump with a 7 A I don't- 8 name and they call name check, and you check the name and 8 IS the case number how You find the file for the 9 then nobody answered. In the next six months, the client ?9 requeSt? 10 come back to Iris and say, "Oh, now we want Cosmetech, 10 A It's the Platform number- 11 So she's asked me if the name is still available 11 I see- 12 because probably I check six months before. 12 A 50 we talking abOUt this request that 13 So that number refers to the Check that you did 13 probably is still open because the request is still open 14 six months before? 14 until a period of time they decide, "Well, the client 15 A Yes. 15 never asked it again, so we close it." But that put me 16 I see. So there's a number 16 as a refereDCe. 17 A Name availability can be six months before the 17 so it You 90 t0 the MossaCk Fonseca Platform and 18 person decide to really go forward to incorporation. 18 You pUt in that number! it Will take You to 19 I see, But so you assign a number to the names 19 A It will take me to name?check availability and I 20 you check? 20 will say, "Oh, I check this name in May" or "two weeks 21 A No. They assign a case number. They assign a 21 ago-" 22 case number on any request; and probably that case number 22 so it gives You it's bBSically the file 23 is a name check I already answered long time ago 23 A Yes- 24 probably, because when they say still available, it mean 24 on that PartiCUlar matter? 25 I already answered but I need to check it again. But who 25 A That partiCUlar request- Case 2 Case 2 702-476-4500 OASIS REPORTING SERVICES, LLC OASIS REPORTING SERVICES, LLC 702-476-4500 Electronically signed by Ellen (001-341-678-7457) Elamronlcally slgnad by Ellcn Goldsloln (001-3414757457) Case Document 100-3 Filed 03/16/15 Page 106 of 217 Case Document 90-3 Filed 03/03/15 Page 1 of 50 EXHIBIT 1 Document 100-3 Filed 03/16/15 Page 107 of 217 Case 2 Document 90-3 Filed 03/03/15 PageZofSO Case 2 ?a?g 0 Ana she way yam {Lad it :3 ?y g?i?g ta ih? 2 piazlarz an? typI?Q in that num?ar - 3 A Carrexi. 5 a Uh-Hun, 6 Qiay, when yaw want an accuau the psattaza ta 7 ?ez ;n!mrnm:zna abaa: an Lag. 13 shera a neat?: nanb?r that's maxiqne? ta the Li? that veg yaw euxzeh a ditter??t any? 13 ?ay 1: v? plaaea rep?at it agate. :1 {?5E6aq5 the intezpteiarg ?gul? yea p?eaa? :qpaa: i: aqatn, :3 xhan veg want 5% arits$ the ta get 14 internatign abau: an LLC. dm yea i?pu: a matte! awake: in 25 accegs 25% intotnatzmn an tn: LLC at am yea 125$ 36 at aa%& ethar way? 2? 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RWTING stinvactzs. m: Hanan??staininntanubana?4HJa? 302.4%4300 Document 100-3 Filed 03/16/15 Page 112 of 217 Case 2 Document 90-3 Filed 03/03/15 Page7of 50 Case 2 Page 20? nunrvr, and thaw ?rewldw Lb? rest a! new ini?r?a?i?? they 2 wantv? 13 the tertifarate. 3 2 see? gawk yuu aver been gramtu? Fever: at 4 ?ttarngy gm tqhalf a! an? a! the 1:55 that gen - a that Nevada aarvua ha gagiszared aqe?: A a: Attax?ay l? bu?ai: at ?ldyna hm: am: he 7 b?haif a! an LLE that 1 amn't ?hi?k a 9 30 gain; bank Se 233 ewgitzea aha: 1% the guhgn?ma ask? fer inf?r$at??a a?o?k. d9 yea knew it 22 yea? of {heat anhzbies are we i?aqgr Havana 1&55? A tan at the Seazczary at 5:455, and :a?y 33 ?re active. :evake a? diaaulvoa {hey qa {a :ena 2 r?qiazarad aqewt. ?%ay aam': yam. $5g? can heave i? u??hmut yam. z? clay. Eu they ?euid aqaxe am he a Ravage 12$ 1? ans yam w?uid nave: 2earn a?gw! it? :3 tha? aha: yau're 3? A ?ne: I say. a Neva?a LLC amdar a: as a 23 zeniazerw? agent man fh??i? ever gazica at ti%? w325?uz 31 tell us as 23? zegzataraa aqa?t. ?2 2 jaw. 23 th an}? way 2 fxm? Qua. ii gg a?ery eanth :5 24 the ?aszet?ry m! ?za?p Be?xazt? aha rhgek {he na5?5 and at that campaay 39*: me wizh?u: zeti gave 1% anathgr ?1?anm GASES Rmnxa SKEW. (All? ?aga 220 zeqiy?9??d agent as mewe 2e J??iher #Lat? 3 knew, dan': have re?trei m5 that. 3 0' 30%: that happtn aha: a cangany 5 E95. 753: happen vary Gites. aux yea wee?d Ign? an: - yea dia?'t ?15m am: ?b?uf 1: ya; uauzd ting an: 2t mane 1a be?ana Lih? 2e {anew tea :kgixaraiie?: agrracz? a fhaf?g anly Sig? whi? fi?? nut: at the 3 tin! when I was warigng an the $8$?vwna. 3 eha?k a1; 13 a? aha. 9kg?. 3? A Red 2 didn?t thank :5 againkea?t tum ?t three Lsnas a gear ta gee hay maay cea?anzas 24 2312: Raga az, 25 KS, Rh? ae??t an {aka gag: a xg?xt bye;: :6 an? 347 be :3 {Er?af reggae taxan.1 2% Ha. have n5 feather :3 3?21 ?ak a ??upit qucgti?nai 5a. ?avat 2% Bind. aha?qed my mzrd. 2; Wa'i? gaa? slam. 2: {augmeitza? a: 1:3? 23 34 33 WES REPORTING LLC 14124364300 Document 90-3 Filed 03/03/15 Page 8 of 50 Document 100-3 Filed 03/16/15 Page 113 of 217 Case 2 Case 2 Page 213* 232 1 er amen? 1? a?ma?m'a 2 I. Sizen Zeldstai?, a ?aky gear? 3 FASE LIKE 3 repeztey in Eat the iamn?y at ?laxk. State at 4 4 am hereby cartiiy: 5 5 :nat Lh? $2 the aepaaxtiam e: 5? a; mmaraezsr at was him; we 1:33am: afar?aaz?: 7 Ema: ?fi?t :e bazng {ta witness wa? by 6 an ad}? am teatity ta kg? trath, wheia truth a a?d ??ihi?g ha: ?ne 2?ut?f 19 :3 ?ba? aha exznasa tequ??tma, at 1: was reqeaeted 1? 3; an he! tahaif; rm taa? and 5133 the :xana?ript ?1 i; i? ?kez i thereagzmr grangaribee 5y sherzna?a aetea a I I :3 33:3 zypauxiaan and {?ea the aype? :zanaergpr a; saz? E4 I, PATRECIK deg?naaz herein, 3% . . ii a?p??itl?? 13 a :53; accarate aranacrigtlan 25 hater? certity and detiara 3mg?: peaalzy at p?r?eyy in; i A 1% as m? :bQIZRawg gates tanan devn a: Tag psaega?i?qg. 36 and atanacrigtien an be a? eepeaitzen 1a :6 I fui??e: eez?Lfy tea: I in net a ratatxve at i? 552$ aetism: that i have read. carzecte? and am bezeby :1 a! am atrezney e: a! my a! the ?azazes. :5 asfix my ?tqattuxa {a 3515 aeyuaigian. 2% net a relative a: eg?layee at any atterney a: cwa?gnl . 2? invmiem? ih xai? aefzee. a geraan Fh?f?ii?z? A?imhfi?fi. Marne?t Ee intataizeg aatxam. 20 2: I ha"e a?z?b?t? set ry her? 2% 3? :n the ?a ark ?tat? 95 Ravaga gh,$ 125% ?t 23 3a?5ff?re$ and awern 15 before 15wgf?l??mf 24 mm WW FUELEC 32$ if; a a A 1 cams newsman annauc Owls ?Ma?a L16 maiw?m enwwnauwuhaunuuaannu awamsawuunanmua?l??h was a; gym). guy-mm m?xa?nmu?mm; I mmi?? wa'mzm ?may; magmanm,qn" ?Wmli??miw 5JngfiU rwWV?w? rmwzi? PW 4? m?m saw. ?ikmm?l vms-qwm?agnmmammwimu?mmwmaw; 3mm, Fr ?mm mama 2 mg. 3cm ?waggwiumm Mai} ?3"in a "a mama up: mm.- i i wait-Mm. Ian mun w?w? mm ?m ?um um 1.8571131) mmsza saws (1511,1910 ?mm Case Document 100-3 Filed 03/16/15 Page 114 of 217 Case Document 90-3 Filed 03/03/15 Page 9 of 50 rg?ai?iw?g?g.? igiw?ri. e?wgitguhaivt??g?d {await-git 3 vii; wrwliamfs 3% Ksmu?. in a 2% gi .unumgu? fawn ilq?k?w 5.. .aui?itu??ii?u?fxg?gi ag?g?n??lgtn?rk?sg? ??uwge?um?tnw??i: 53$ ?13512!? pea?i??x?wgegzg? tiukguiixiwiagtw . . ?mil ?Fara .3. a . a .1 ?ma?a? ?View anggamu?mgwm? . a. stint r, ?k . my?. n, am Quinta? Im??gn?e ?gk??lt i . A - ng?w?wg?gtt??nx?i gag?! Q3 gaggngiigtege $.1i?iluugf. ?)gii?ng?g?t i293 ma Aer-:33? a a a?ii?tifguliiai I I .igsigmgig 3% ?25? gain?. 35: (3393-353gilifa .iki?tli?g itiv?a? . is? ?gmm??u?iJggi gu?gii?ai?gii? I: I: A signi?vcnmu ifi?ii?mg?ihglg 13% gal; ??i?gizmitl? lief?mg}: guilii $1 .2. Siigxeggl-ltg 3 A in! ?Kailglwiluif?i?i? ix?is?u?iguswimhwk A 333$ f. It!? .1: ?El 4 A inf?! 2 ?as? i?141g?w?g?g?hig?s?g? is.? 5 E. if; i?gu?igu?ggw ?iki?j; A a! gis?uiin:il?? gi?fgxi?b 2.. gaging A i. A i . than}: A I .5 ill?. t. .. a link!? A .l a ?gutiltha trig? gulfiyaiv?L?ws grit: iu?asa? 635. #:5101333; Swazkaw??giu its: . 1&til. 33:3 Case Document 100-3 Filed 03/16/15 Page 115 of 217 Case Document 90-3 Filed 03/03/15 Page 10 of 50 Case Document 100-3 Filed 03/16/15 Page 116 of 217 Case Document 90-3 Filed 03/03/15 Page 11 of 50 wwq?nu?uum "imam I?it?ud hk? Fm tun 106 City Many. $3.11: 1m. Lu Vegan NV $305-$511 i mam. minim! WW {3mm cum :23 mm, wwtihLWm Mam/imam mm?awmwuz i, in?. Es?. 1.me a: m. B) m; Tum gem ans. as, mung, e?mg I ?x ?Datum-t" in! Ea be $1 meWyW $151 3. 7? Ha?z/111% ad minim mints. dam; WK :m may. ?atware: an be WM zi?a a, %f may. 3921 unamn by the: mafia: 5m? 1. Isaak!? {m A a sawsme my :5 a Miami warm 15:: aunmg; an!? m. hurl 111%.? ?gm 5 ?ne ?Mater/?Ii Fume? may: in 13w 5m Maggi meat?; 25; ?a ?5 33.42%; 1x hm?: Ema ?rimming a: 9:4, Ea mm;- iu hem, ewe: a: w: kizi?l a; ?33: mm (Nulth as; Hf Cam? W?a?i} Lm?z?. Email?! 4% 51?! 3? Mm Sm m. but; Veg)? ?1213! 1.332593% 5% mam-g; mi m& mam/away, ml as In in anng 1 "?ne-Irv wmm? if 554: da- 11:: - ?u 'Pmu? was my mm? Mm a say Wm, anti. a? yucky. at W. i. The Manama. I and: 1% wmma gem an! aria; {thins mm mm; WW. mu. imm a 63m? hame: ?tam, 11mins; was. mm: the?. m4 Ema: milk magnum. Mum imamiwa W1. m?ma??m mm? m.m an?; we, W1, rm: Muumm Wmm?y??awtw? if?zsnm?hi:wumiu 3, Th! Wi?wm a! as; ?th 1: he {mutant isxwaw 5:13:21 me:th Em. we eh: 93?ng km my semi ?rm! m! was; Wain; ewe made 22M: {at mmfz?kts *mi? and ?at? :1ng in: ??mgmea??e,? 4:41.59, 1. . a. A magma: mag/Mm Ila? mm ethnicity: tn: a: he ?mm at it: mm; :51; math 7 Vi.? m5 "ma" m5 he amewj ?any a: in News; mam DKW, that? 1.8 {Wan gamma tam-$3, ngxs?m a! 51,445,; ?atware: k? 3 raw 339%,; "t a) EWM 3.: {13 3am; m; Mw? 5.311% 241 mg arms 9% W3 gm;mm5??9? was WW1 ?a 1? {as} 'Wm W?s W31 my: $31 mam am? mam; tier: am mm as; m; anguw: gm Sam :2 my: in warm was: vwmma ?m mm mmxamim?mwt?w me as WWanwmmammi?mm-am?m mammij mange memww mum?xix Wi?im?me?I?amm??hiwtiimwa? W?e?mm mmww? MWvamar-szw 1 mummxu 'mewmm??ma'mm?maa 019% a: ?3 a? 3 1 ?div QUV-J?thh?wiw i 1 mm: magmas warm: army; mine mm! a it: wm?g 433% we Wren: JWm?ggangi r: A New?? 253032; g: Jags-gt: 13% We W?iif??i? 3:255:33: a; yaizgwt fk??f?z?l at; unmww??; - ?5 Wm *?m?zm z; km ?g mama ?5th :4 [53 3:5; mm 51:13:65 mm m?MW?tmw ?mm?mwmn wmmeqmuWWmazmm 1in ?rm? In mam W: mm?l W1 Wm ?f 1mm? Wt mm Wamme Case Document 100-3 Filed 03/16/15 Page 117 of 217 Case Document 90-3 Filed 03/03/15 Page 12 of 50 Case Document 100-3 Filed 03/16/15 Page 118 of 217 Case Document 90-3 Filed 03/03/15 Page hula Human?prawns.? 219 23? ?211 w: m. a: an aim. m. an! ma?mxu I14 Wm win-aim! 29:5?qu afdimm ?fmofmm t1 Hams; TnheminWV-zw Mildw?m a! 5m Fawn at! MP Min/m rm kg my arm: ?55m; main?! aim: My 3* 2531:: A M: rm Cusp Lu; 1 MM: mm: m; am Tm: [All 2 Mn 3m ?113; Eu UEA 1? Aims??h $22qu 1,117; 5 mm; a, a?mfm Li. 3mm 1339;? ma?a; 131, mm (map L11 amt/:1 14) NW Sammy t: Ma Bm? Mi Amiga 11:52:21? Mm ?ew-m LUIS 51m; 2: 5 5 limkth?i WMMEWWM WI Light (mm Mm WWII Lift: Mir Tm L113. Elm Ila/83m! ?am: but (13:31am Lu: Cum 1km: 1.137: ?If: and mac any; 116; CW ?mmadm LL62 cm L141: (mm: AW (?Wt am; Unit; mm m?n Tum; LAC: WM 113% 1.1.5; 1mm LUZ, mam imam 33.4 Exit Am LUIS Biz? Teakmk-ggia L595. 1% we; {am-111ml Lain. Elm battle: . mm L537 is #numvhuuw 3 :5 351 3 2 ?u ?q?mhwuw? Case Document 100-3 Filed 03/16/15 Page 119 of 217 Case Document 90-3 Filed 03/03/15 Page 14 of 50 fmvda ?2 HAL Lu; n5, Wan?Wszm Lu; 3 m: imam; Wet: Lu: LUZ110? In!? Han Pyth- erz; 5 3 Hakim 3% 0,3, (waiting ?LL11, .4. 534 [13* Lil)! My? Fit-mum?s 1254 MyL21: PM A ?:21 mm 1W1 :14: Farm MW LL11. ?i 223. mm Why m; 11%. ?ndWWILL Mari Emma? 1m mm 1m WWLIQ 1; mg mfg-arm 5m: Wis 334? 3 WIWW cu LL11. ?1in (in-qr muumm i 13?. Gotta Nil; :39 Carp Tam Kml?mia? 1? (3.9mm; tum t; am A can!? ?nd Cup. :44: 3" w: mm 119:; mm :31: 36, Km LIE. ma?a-amber: Lu; Mi Kr;mefo 221: HT mvmmug; . 1 Guam 159 1.3g: My LLC. 1.15; .51, H9 unmmug Hut f?emmw gm Twig/1:2 its-aim Wm: ?241 33 i?z? my WM . gm ?2 1,35ngMaxi i 1:25 [5mm LLEL i113; ?5 L316: 32:: LLC. M55 Emm LLQ Lmruan 2a; i me amt; :1 a? 2 HmWw? :45: Ly?! Hm mam am 2'3: 1w- Mm?; {Wr? um; Case Document 100-3 Filed 03/16/15 Page 120 of 217 Case Document 90-3 Filed 03/03/15 Page 15 of 50 ??quumwmm 93257693 1 {11m Capital Uri; mm? $545135" LEQ any? (has; LL43 LI Wicca: {11%st Wis; WWI Ff?:sz mt, E?w?vr if: 912% wa?m that Was it Amt? Pm! imam227. me 2:9. mm: L113. My: E316: ML 5m 955% L511: 131. ?rm LUZ: 23:! ?at] ?3112 2% 3m Imam 23-3 [3.153; 2% 133,. TM Ham! 231 a: lathe (1mg: LUZ: 2.3 Til-fag 23* 2mm WA m; :43 Tran Emilia; Lu; mm Cm; ?131 a ?24: 1:11. 213 Vatm had: 32:! await . Vania: acumen 35:. 24 i. am 247. VM Miami 1.111.?. 24! Wme {mm 1M 34:; mm titer; 33% #:4513335? 15% In: 35:, arms: Wu: Lu: :51 3?21: thaw Last 255 rmmram f; ?153. Katie! [Jig me; A ?sher MW Lat. . Saga Wm: main; {in ?151; smumm Lag; Case Document 100-3 Filed 03/16/15 Page 121 of 217 Case Document 90-3 Filed 03/03/15 Page Yauhaw Wm Hm?mi?thl? mm vim; it? in mm I $91: Mining m, 1 {him Eliza; z. 3kg, 1 (funk; 4: 51am: mam: (mu 5 Met: 09:: Chum; a a 1" Cam; 3. Juan games? My. 11? am Frat; 23 an my Farm. cm Gianni rm: :1 Van; [31:Bimini! mm. 21! 2. S. New: 33qu9 W. 22, PM Vim?h: ma and 1m Mum; vm ?n?:ng Wm xawmk met mam we We w} my 51$ 51% 5225:3312? Wm fa; m: Va ?m?ami am :1 3 Am Lu: (5m Km, wag: mm mm; an, mama. 5mg Se; (Eff), 1W9. {m (Mira. AM: (2m Mite with?! 1m 1. 1:13:15. an. Fl 3-3153}. Luv, frag/31W Am?; (Mk, ?12 Fax?! 337%): 21 3 may: Hm {Va 5% ?Km Sin/Ewing?. FE 3mm 1. WWILCGM may?; 33111}. 3. AM Am Flim?t??h?kil?h Exclaim 1&me3. l9; PM (Vin MW 111. SW It, ?m IWN Sal. has: 331532? 5441: 3L WW3: 2mm Vina? Trad-n 13m. PM my, Pang-aft; ?ameruq?ugmmh an: $91,132: "Mi ?3 Hiram 551M342 mam SW 3; El mm (hum?r?h All; SW 5m tat, 329$ I?m 6 A. Elms Aim. hm 257 Em W3: Sta/?0. 140%, Can: (18118, $31331?: ii MP: Wk mm, F1 3113:}; Hm: 2am? twain. Jul?; Si. will: EL First ?31m. 0&1in The}: (team ma?a; mm 39m Mm} :32, W4 Home LLC {Vin Sm w, 9309 Exam. SW: 23 2&1 Sgi mgr/1f;th Fm?: Aw. Km. 31 ??331 WVkamssumkm-mnmm 2&1 Wm Mimi?; 7* Wm)? Him: List We. gm mum; 1% law. Sarthde a {Mimlt mf?aim 332+ mam? w; m; :41 Maris} m! 2h: ?nm at?? ??334: PawnsmiSu?M in awnia mu ?mama ml 42: ui 1 2; 111mm ta smug w; m! 11$ In Em: 23$ ?aw f??llt?i?? Case Document 100-3 Filed 03/16/15 Page 122 of 217 Case Document 90-3 Filed 03/03/15 Page ?iwgm It} 1:2 MWwamw?manmmavm.m?m 12 W: af?rm Magnify PM wan Wk H. {mm in mexuduu?mi N, Wmewm.mewmqu mm ML wmmimg Ki?, mt KW mm {Ma?a} Wu CW '11: ?inmate; Wu ?aw-g4: m. :21: m: 3m and Yaw: mien 311? am {has my :1 bum {may the cams? Hm km?! in! I?m, mm Fawn Wm ma?a}; W- M: ?3 Magma 213:3:qu ?E'xm, mm Emma My: mehg ?351 at! mea this 2W2: We?? 4! :nzr W4: an Ila?: TWEMSWH ha?m??w. MWmem?w?m?mwaymm St: mm at 3:12 mat/3t a z?w?wn . "m 13 Fw?nm mam 3! 73. 21213 in ME 5% k5. u: 33 QWW Fm? Preemie! 1m: ?mm 2Q. ?aw mmwau. ??uni W1 2.3. mama 1a math :11 mama tmwu, :m ZS 24, mammww?d ?Wm 25? Mi Dam Warning 15am as: any m'swm; Yam ?9 mint 5% $1 {Whit} Mm it: ?dun; 24h, mm Eh: Drama Wm 131? {Wish} a 33; ?ne mm ?Mitzi 34 Case Document 100-3 Filed 03/16/15 Page 123 of 217 Case Document 90-3 Filed 03/03/15 Page xx? erg Case 2:14-cv Case Document 100-3 Filed 03/16/15 Page 124 of 217 Document 90-3 Filed 03/03/15 Page 19 of 50 iglg?gz??g?gg a; .5 52.3358 18. a i gi?zig glans-HIE; ?aggiguuiigtiittgl? .o i 5.333133% {Ii I: Epo??g .itg??iasiaa?lslagi aggig?lggagi-?n gsinggz?ggrl 3333 Bu .u Case Document 100-3 Filed 03/16/15 Page 125 of 217 Case Document 90-3 Filed 03/03/15 Page 20 of 50 Sin-681% 3 fuel?; {msalg?niaiaxolgisgma? tilig?iigina hissing-139mm a a. 3.23% igug?gg?. {usual-aligning? suggerl?uaigg 352m. thin-5383 i?t?iuglggagilli?tn 22% *lsiu?agnlg?znteeagsg?ml? ?1 gzil?gtgiglggagi gzgiaegtggigzgg? .9 EE- isgigiigangg-ig gg?sgsiigiili?gaz a? gagglnE-?ilgzulni. 5.839. Case Document 100-3 Filed 03/16/15 Page 126 of 217 Case Document 90-3 Filed 03/03/15 Page 21 of 50 Sgtgaag?ug?fl?wla?i agnosia?niulsgiaii?ng: Eig?tg?l?i an an .53.!qu .gtguigh giggiaii?I?iigg gagging Egg-8.98 giggifgkg Aggigigsc gauge-558.3; ggigu?liigliili 53:51.38.? ggi?gzai??m a iggii?giigmluili?g 3 ggazgl? .si?uiz?icm?i .t Eggi?ggiti?ml? Case Document 100-3 Filed 03/16/15 Page 127 of 217 Case Document 90-3 Filed 03/03/15 Page 22'0f 50 was: ?l?m?a?mm 5 . iiz??h my: 3 . 1mm. tau-?3; - 3&1? mm mamas-4 ?9 1m: mazn?w?n?Nm-pm Wm WA mame *v WW ?mat WJGW WW?wm? magma ?{vavnzwi sasmaas givaOdaOB 3 Hanna 331.0?! 031mm mm mamas 31mm '1 ?n 31:01am .u namnmm W4 3 Warm ?49m mum wmmima mammwna Case Document 100-3 Filed 03/16/15 Page 128 of 217 Case Document 90?3 Filed 03/03/15 Page 23 of 50 Case Document 100-3 Filed 03/16/15 Page 129 of 217 Case Document 90-3 Filed 03/03/15 Page 24 of 50 . age we ign?g? a?g ngi??w?u?i, a? ?ui?il?ti in, Case Document 100-3 Filed 03/16/15 Page 130 of 217 Case Document 90-3 Filed 03/03/15 Page 25 of 50 Win-u 'm?mnwupm.am?m?pmmd maul-1r Wm cam (mm) am am '5 'l mad ?ammo-tau Wham-mp am 10mm 1:1. mun-am Case Document 100-3 Filed 03/16/15 Page 131 of 217 Case Document 90-3 Filed 03/03/15 Page 26 of 50 2m :91?;me ?y m, a Case Document 100-3 Filed 03/16/15 Page 132 of 217 Case Document 90?3 Filed 03/03/15 Page 27 of 50 Instruction Dissolution Magnum Fm mm Sm; Fri #25 AM 1a.; at! at 12m: 09:? 1633112034 19:52:17? ?am his! 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Nd cm enema ems 1m access is: mama, Wm mm mm a mg MOSSFUN Mm MOSSFOM mem mew: mmung mez in? 3510 gt: @3911; m: ammepamw 946173 ?661 111 $563 W11 "ft: W3 mama-am mm. 10 mm m: 1? swam ma 61 as;in mew? awmw 2mm Wit ?zm W5 mm HWJM amrwaramp?um mew acme ?Wme JG mi Malena:me paws-WW at; nwmuwanmm WW wauund mo Case Document 100-3 Filed 03/16/15 Page 152 of 217 Case Document 90-3 Filed 03/03/15 Page 47 of 50 Document 100-3 Filed 03/16/15 Page 153 of 217 Case 2 Document 90-3 Filed 03/03/15 Page 48 of 50 Case 2 Case Document 100-3 Filed 03/16/15 Page 154 of 217 Case Document 90-3 Filed 03/03/15 Page 49 of 50 ?mar may 3 1-5 ii?Mi 1 304 um?g #1 13311 3113*!? 39* ?43 1 5337-91133'min-5mm WW mu: ma 5'30? mm ma?a{05* nan-?gawmo 2mm: UOQDUJJONI DDLUOI) Case Document 100-3 Filed 03/16/15 Page 155 of 217 Case Document 90-3 Filed 03/03/15 Page 50 of 50 Case Document 100-3 Filed 03/16/15 Page 156 of 217 Case Document 90-4 Filed 03/03/15 Page 1 of 62 EXHIBIT 1 Document 100-3 Filed 03/16/15 Page 157 of 217 Case 2 Document 90-4 Filed 03/03/15 Page 2 of 62 Case 2 UHIBIT 11 N1 12014 NEVADA. USA EVADA, SA Nevada is considered one of the best jurisdictions in the United States for the incorporation of companies due to its versatility, low costs and fast service. Nevada Limited Liability Companies (LLCs) can conduct business outside the United States and employ any currency of their choice. HIGHLIGHTS OF LIMITED LIABILITY COMPANIES - Nevada has no state tax, annual franchise tax, inventory tax, estate tax, uni?ed tax, gift tax or taxes for chain store branches. - Low taxes on property, contributions or payments for occupational accidents and unemployment bene?ts. - No taxes levied on offshore and banking transactions. - No exchange control regulations. - No capital gains, income or any other kind of tax. - No requirement to record maximum or minimum capital contributions. - More than one class of member interests are permitted, which makes for a ?exible structure. - Excellent name availability for company incorporations. - An LLC can have a perpetual duration. HIGHLIGHTS OF NEVADA .- Excellent corporation law. . - No taxes levied on offshore and banking transactions. - Political and economic stability. Document 100-3 Filed 03/16/15 Page 158 of 217 Case 2 Document 90-4 Filed 03/03/15 Page30f 62 Case 2 8/11/2014 NEVADA. USA Serviced by major world ai ines. Excellent 'worldwide communication faci Skilled personnel. SOCIAL AND ECONOMIC INDICATORS Location: Nevada is a Western state, lying in the Great Basin and Plateau section of the United States. It is bordered on the north by Oregon and Idaho. Calilornia is to the west and southwest. To the southeast i5 Arizona, with the Colorado River forming part of the boundary. Nevada's eastern neighbour is Utah. Area: 110,540 square miles, 485 miles long, 315 miles wide; seventh in size. Population: 2,758,931 (2013 est.) Climate: Arid and there is abundant sunshine, light rainfall and snow. Official Language: English. Government: Nevada has a bicomeral (two houses) Legislature consisting of the Senate and the Assembly. The two houses are jointly designated in the State Constitution as "The Legislature of the State of Nevada". Living Standard: High. Banking: Worldwide banking facil ies available. Legal Tender: US Dollar. Industry: Mining, Construction, Manufacturing, Transportations, Communications 81 Public Util "es, Trade/ wholesale and Retail, Finance, Insurance and Real Estate. Services: Hotel, gaming and recreations. :Al?ll?l I 12 Document 100-3 Filed 03/16/15 Page 159 of 217 Case 2 Document 90-4 Filed 03/03/15 Page4of 62 Case 2 MOSSACK FONSECA NEVADA Features of Nevada Limited Liability Companies BUSINESS TRANSACTIONS I may engage in any lawful business outside the USA and make use of any currency that they may choose. I Trademark registration. TAXATION I Nevada has no State tax, no franchise tax, no inventory tax, no inheritance tax, no unitary tax, no gift ?ax and no chain store tax. I Low property tax, workers' compensation and unemployment insurance tax. I Nevada has no IRS information-sharing agreement (there is no exchange of information between the State of Nevada and any other State or Federal agency). I Members that conduct no business in the US and have no US source income, deductions, or credits are not subject to US federal income tax, and are not required to ?le US federal income tax return. I could be subject to taxation by the United States of America or its individual States. It may include, trading in, with or through any territory of the USA, opening bank accounts, applying for a federal identi?cation number hiring employees or agents, and owning business interests and/or property in the United States of America. I Minimizing disclosures and ?lings: the key distinction is keeping separate Persons" (the Nevada LLC) and the all ?non- U.S. Persons" (the foreign Member). If the U.S. Person has foreign accounts, then it may have to ?le FBAR disclosures. The non-U.S. Persons remain con?dential and do not, simply by virtue of owning an interest in a U.S. entity, have to ?le or disclose. Only when the non-U.S. Person receives U.S. income should that person ?le and disclose. I Obtaining an EIN number does not trigger tax liability on the company or its members. Filing a "zero return" is a very good idea, it puts a deadline an IRS actions and shows compliance with standard industry practice. A single-member LLC is a disregarded entity meaning that the IRS will look directly to the member for payment of taxes due. Without US Income, there is no liability, but if there is US income, then the taxes for that income are payable by the member. I Layered Nevada LLCs: this arrangement will be successful for limiting liability. However, the member-LLC will be a U.S. Person and will be subject to all the regulations. Any U.S. income will pass thru to the ultimate member. This solution does not have federal tax advantages. CAPITAL CONTRIBUTION I No need to register a minimum or maximum capital contribution. I More than one class of Membership interest is allowed, which provides the ?exible structuring. MANAGERS AND MERGERS I Managers and Members can be either corporate entities or natural persons. I Initial or ongoing changes in Manager or Member (the latter, if they are handling the management of the LLC) need to he ?led at the Secretary of State in Nevada. I The Manager may grant special or general powers of attorney. I Register of Manager and Member is required and must be kept at the Registered Of?ce of the LLC. I The LLC may have one or more Managers, who do not need to be Members. I One or more persons may form a limited-liability company. I Managers or Members may be of any nationality and may be residens of any country. The required minimum being one Manager and one Member. I Managers and Members may hold their meetings in any country and may attend such meetings by proxy. DATE 5 Ellen A. Goldstein, CCR 8 9 ANNUAL FILDIG I No requirement to ?le ?nancial statements; nor to hold annual general meetings of Managers or Members. I The ?ling of an annual list of Managers or Members is mandatory. INCORPORATION AND ADMINISTRATION I An LLC may have a perpetual duration. I Excellent availability of company names for incorporation. I The words "Limited Liability Company", ?Limited Company", or "Limited", or the abbreviations "Ltd", or may be used in a name. The word "Company" may be abbreviated as I Incorporation procedure takes ?om 10 to 15 days. I A 24-hour Company Name Reservation Service. RECORD KEEPING I The books, records and minutes of the company may be kept in any place or country at the Manager?s or Member's choice if they are handling the management of the LLC. I An LLC must keep copy of the following records at its registered of?ce in Nevada: Articles of Organization and amendments (if 1113'), Annual list re?ecting the Mmager(s) or Member(s) and business address, Operating agreement, Power of attorney (if any), Copy of Register of manager(s) Copy of Register of ruember(s). An LLC must keep the following records at the of?ce of the Secretary of State in Nevada: Articles of Organization and amendments (if any), details of Resident Agent, Annual list re?ecting the Manager(s) or Member(s) and business address. REGISTERED OFFICE, CORPORATE SEAL AND LEGALISATION I Registered Of?ce in Nevada is required. I Corporate seal is optional. I The Apostille is normally used to legalise documentation. Legalisation via a Consulate is also available for some countries. COSTS AND FEES I Reasonable formation and maintenance costs and fees for annual list ?ling of Managers or Members and for Business Licence). CONTINUATION (DOMESTICATION) I Foreign companies can be speedily continued to Nevada. I Conversion of a U.S. company from any State to Nevada is allowed. USES OF NEVADA LIMITED LIABILITY COMPANIES I Sue and be sued, complain and defend, in its name. Purchase any real or personal property, or an interest therein, wherever situated. Sell, mortgage, pledge. lease, exchange, transfer and otherwise dispose of all or any part of its property and assets. Lend money to and otherwise assist its members. Deal in and with shares or members' interests. Make contracts and guarantees and incur liabilities, borrow money at such rates of interest as the LLC may determine. Lend, invest and reinvest its money. Conduct its business, carry on its operations and have and exercise the powers granted in any foreign country. Appoint managers and agents. Cease its activities and surrender its Articles of Organization. Exercise all powers necessary or convenient to achieve any of the purposes for which the LLC is organized HIGHLIGHTS OF NEVADA I Excellent corporation law. I Flexible company law. I No taxes levied on offshore and banking transactions. Case Document 100-3 Filed 03/16/15 Page 160 of 217 Case Document 90-4 Filed 03/03/15 Page 5 of 62 Skilled personnel. No exchange control regulations. Political and economic stability. Serviced by major world airlines. Excellent hotel accommodations. Excellent worldwide communication facilities. No capital gains, income or any other kind of tax. DOCUMENTS REQUIRED TO BE KEPT AT M.F. CORPORATE SERVICES (NEVADA) LIMITED OFFICE, IN ACCORDANCE WITH THE LAW Operating agreement, Power of attorney (if any); Due diligence documents, as required. Articles of Organization and amendments (if any). Annual list re?ecting the Manageds) or Member(s) and business address, Copy of the Register of Manager re?ecting complete name and business address of the Manager(s). Copy of the Register of Members re?ecting complete name and business address of the Membeds). SOCIAL AND ECONOMIC INDICATORS Location: Area: Populah'on: Climate: Of?cial Language: Government: Living Standard: Banking: Legal Tender: Industry: Services: Nevada is a Western state. lying in the Great Basin and Plateau section of the United States. It is bordered on the north by Oregon and Idaho. California is to the west and southwest. To the southeast is Arizona, with the Colorado River forming part of the boundary. Nevada's eastern neighbor is Utah. 110,540 square miles, 485 miles long, 315 miles wide; seventh in size 2,723,322 (2011 est.) Arid and there is abundant sunshine, light rainfall and snow English Nevada has a bicameral (two houses) Legislature consisting of the Senate and the Assembly. The two houses are jointly designated in the State Constitution as "The Legislature of the State of Nevada". High Worldwide banking facilities available US dollar Mining, Construction, Manufacturing, Transportations, Communications Public Utilities, Trade/ wholesale and Retail, Finance, Insurance and Real Estate Hotel, gaming and recreations M.F. CORPORATE SERVICES (NEVADA) LIMITED. Z-MF MOSSACK FONSECA Monfon East 54th Street KO. Bu! 0832-0886, W. T. C. Plnaml, Republlc u! Pan-m- 011 (507) 205-588! I 206-9400 011 (507) 263-9210 I 263-7914 01] (507) 263-7327 MF@moufon.eoln Case Document 100-3 Filed 03/16/15 Page 161 of 217 Case Document 90-4 Filed 03/03/15 Page 6 of 62 man Id Case Document 100-3 Filed 03/16/15 Page 162 of 217 Case Document 90-4 Filed 03/03/15 Page 7 of 62 I :ase Document 14-10 Filed 07/10/14 Page 1 of 6 KENT P. WOODS, ESQ. Nevada Bar l2306 WOODS ERICKSON WHITAKER LLP 1349 Galleria Drive #200 Henderson, NV 89014 Email: kw Tel: (702) 33-9 Fax: (702) 434-0615 A tiomeys for MF. Corporate Services (Nevada) Limited and Patricia Amunategui U.S. DISTRICT COURT FOR THE DISTRICT OF NEVADA NMI. CAPITAL, LTD, 3 2: Plainti??, vs_ DECLARATION OF PATRICIA IN SUPPORT 0F ssassemsaw THE REPUBLIC OF ARGENTINA, PATRICIA MOTION TO HASH SUBPOENAS FOR ORDER Patricia Amunategui makes this Declara?on pursuant to 28 U.S.C. 1746: l. am Patricia Amunategui, the general manager and sole full-time employee of M.F. Corporate Services (Nevada) Limited Nevada"). Nevada and I are non-parties to this proceeding. I submit this declaration in support of M.F. Nevada?s and Patricia Amunatcgui?s Motion to Quash Subpoenas and/or for Protective Order (the ?Motion?). I have personal knowledge of the facts set forth herein, and if called upon to do so, would testify thereto. I have reviewed the Motion, and to the best of my knowledge, information, and belief, the tactile] statements contained therein are true and correct. 2. On or about August 13, 2013, NML Capital, Ltd. served a Subpoena to Testify at a Deposition or to Produce Documents in a Civil Action on M.F. Nevada. Case Document 14-10 Filed 07/10/14 Page 2 of 6 Simultaneously, NML served subpoenas on approximately 123 entities for which M.F. Nevada serves as resident agent. 3. The appearance fee check for the August 13 subpoena was unsigned. On August 23, 2013, NML served on M.F. Nevada a new copy of the subpoena (the ?Original Subpoena"), with a proper appearance fee check enclosed. 4. M.F. Nevada is a commercial resident agent service. The services it provides also include formation and maintenance of corporations. MF Nevada is an independent service provider to Mossack Fonseca Co., a law ?rm based in the Republic of Panama. 5. In response to the Original Subpoena, I produced several thousand pages of documents to NML. I estimate that in preparing these documents for production, I was required to expend approximately forty (40) hours of ?me. Additionally. I retained the services of an outside contractor to assist in the scanning and conversion of the documents to a producible format and employed the services of a temporary employment agency to obtain assistance. I estimate the total cost of producing documents in response to the Original Subpoena to be approximately $12,000, which amount includes compensation for my time, payments to outside wonders and for temporary help, and certain fees and expenses. This is in addition to time attorney fees incurred by M.F. Nevada with respect to this process. 6. I have reviewed the New MF Subpoena and the Amunategui Subpoena?as those terms are de?ned in the Motion?and believe that compliance with them would be signi?cantly more burdensome than complying with the Original Subpoena. I have reviewed the list of entities for which documents are demanded under the New MF Subpoena and the Original Subpoena, and they appear to comprise all or substantially all of the corporations for which M.F. Nevada serves as resident agent, in addition to several other entities and individuals. In estimate the total cost of compliance with these subpoenas to exceed $25,000. Case Document 100-3 Filed 03/16/15 Page 163 of 217 Case Document 90-4 Filed 03/03/15 Page 8 of 62 Ease Document 14-10 Filed 07/10/14 Page 3 of 6 Pursuant to 28 U.S.C. 1746. I declare under penalty of peljury that, to the best of my knowledge and a?er reasonable inquiry, the foregoing is true and correct. Dated this 102 day ofJuly, 2014. Case Document 14-10 Filed 07/10/14 Page 4 of 6 EXHIBIT EXHIBIT Case Document 100-3 Filed 03/16/15 Page 164 of 217 Case Document 90-4 Filed 03/03/15 Page 9 of 62 910 a?ed PGIH IUSWHDOG 959:) 9 10 9 359d pend xuawnooa 3590 Case Document 100-3 Filed 03/16/15 Page 165 of 217 Case Document 90-4 Filed 03/03/15 Page 10 of 62 Diego Sep?lveda - Corporations From: World Compliance Corporations Sent: Friday, September 5, 2008 3:08 PM To: Suzy Ramos - Corporations Subject: WORLD CHECK Attachments: Results for search GYORGY No results found From: Suzy Ramos - Corporations Sent: Thursday, September 4, 2008 10:17 AM To: World Compliance Corporations Subject: MR. GYORGY LASZ Good morning, lam about to carry out a world compliance for Mr. GYORGY LASZ. Thank You, Suzy Ramos Corporations mossmx FONSECA Mossfon Building 54th Street Marbella P.O Box 0832-0886 W.T.C Panama Panama, Republic of Panama WITNESS DATE IT Ellen A. oldstein, 829 TRANSLATION MFCS 002129 Diego Sepulveda - Corporations From: results@worldcompllance.com Sent: Friday, September 5, 2008 3:08 PM To: Mayka Villareal - Corporations Subject: Results for search LASZ Attachments: headengBlue.gif; headeng.gif; groupPanel.gif GYORGY ism? LASZ Revuwed Paola Br Vem?io *Mossfon ?Wa?dGomp/mnce my Corporation WAI IM 9/5/2008 1 5:7: 1 Comments: NO RESULTS FOUND TRANSLATION MFCS 002130 Document 100-3 Filed 03/16/15 Page 166 of 217 Case 2 Document 90-4 Filed 03/03/15 Page 11 of 62 Case 2 Diego Sepiilveda - Corporations From: World?Check Sent: Friday, September 5, 2008 3:07 PM To: Mayka Viliareal - Corporations Subject: LASZ N0 RESULTS FOUND USERNAME: SENT: 05?09-2008 22:06 CET NAME: GYORGY IASZ none: Part Match MALOS Laszio Gyorgy - INDIVIDUAL . KIMLY Lanlo Gyongy INDIVIDUAL mam - Gyurgy - :7 -. INDIVIDUAL - zsruun' Laszio Margy INDIVIDUAL 1) General Legal Notlue All Information Identi?ed or correlated In this pro?le, appears In the listed sources. We are not responsible for the coth of dilrd party sites or sources. Information correlated is madly brief and should be read by users in the context of the fuller dot-ails available In the external sources to which hypertext links are provided. Users should also can-y out independent checks In order to verify the Information correlated. 2) Cam? legal Notice Category is based on lnfon'natlon conizined In the scum provided. 3) Reported Link Legal Notice Where an individual or entity ls listed as being .Reported to be linked to' other pro?les, the nature of the vary considerably and users should not draw negative Inferenoes merely from that association. You are strictly prevented from disclosing or copying to third parties the content of this database in accordance with our Terms Conditions. Content Is protected by quali?ed privilege. Legal action will be taken against users that disclose content to third parties other than regulatory and government agendas. TRANSLATION MFCS 002131 Diego Sepulveda - Corporations From: Mossack Fonseca Co. (Corporations - Nevada) Sent: Monday, September 8, 2008 3:31 PM To: MF CorpServ (Nevada) Ltd. Cc: Patricia Amunategui - MF CorpServ (Nevada) Subject: DYNAMIC LLC 1587149 Er/iv/sr Dear Patricia: We are referring to the client's instructions for the preparation of 2 powers of attorney in English in favor of the following gentlemen: LASZ TAMAS MOLNAR Attached you will ?nd the models for the powers of attorney; each must be legalized by Apostille. a NEV- 51m POWER OFATL. POWER OF Note that the power of attorney for Tama's Moina'r is missing the passport number. I am verifying the exact number and I will con?rm. Regards, Suzy Ramos/Iris Vergara Corporations Mossfon Building 54th Street Marbella PO Box 0832-0886 W.T.C Panama Panama, Republic of Panama 3- (507) 205?5888 (507) 253-7327 TRANSLATION MFCS 002132 Document 100-3 Filed 03/16/15 Page 167 of 217 Case 2 Document 90-4 Filed 03/03/15 Page 12 of 62 Case 2 Diego Sepulveda - Corporations From: MF CorpServ (Nevada) Ltd. Sent: Monday, September 22, 2008 11:42 AM To: Mossack Fonseca 8: Co. (Corporations - Nevada) Cc: Patricia Amunategui MF CorpServ (Nevada) Subject: RE: DYNAMIC LLC 1587149 Dear Suzy: It is not a problem we?re going to correct the date and then we replace the page it will be sent today as soon as the corrections are made we will attach them to the case. Regards From: Mossack Fonseca Co. (Corporations Nevada) Sent: Monday, Septiembre 22, 2008 9:11 AM To: MF CorpServ (Nevada) Ltd. Cc: Patricia Amunategul - MF CorpServ (Nevada) Subject: DYNAMIC FITTNESS LLC 1587149 Importance: High Dear Patricia: Please con?rm whether the powers of attorney were already sent to the client. I noticed that these have an error in the section on the duration of the power of attorney; this is my error. The power of attorney is valid for 3 years until 2011, not until 2008 as indicated in the documents. I would greatly appreciate your URGENT con?rmation on whether the documents were already picked up by the Courier company. Regards, Suzy Ramos Corporations MOSSACK FONSECA Mossfon Building 54th Street Marbella PO Box 0832?0886 W.T.C Panama Panama, Republic of Panama 2+ 507 205-5888 5 507 263-7327 TRANSLATION MFCS 002133 Diego Sep?lveda - Corporations From: MF CorpServ (Nevada) Ltd. Sent: Monday, September 22, 2008 1:31 PM To: Mossack Fonseca Co. (Corporations - Nevada) Subject: RE: DYNAMIC ESS LLC 1587149 Attachments: Dear Suzy, Please ?nd attached the power of attorney with the correct date. In order to attach it to the case, it will be sent to the client today. Regards, PWAWW From: Mossack Fonseca Co. (Corporations - Nevada) Sent: Monday, September 22, 2008 9:11 AM To: MF CorpServ (Nevada) Ltd. Cc: Patricia Amunategui - MF CorpServ (Nevada) Subject: DYNAMIC LLC 1587149 Importance: High Dear Patricia: Please con?rm whether the powers of attorney were already sent to the client. I noticed that these have an error in the section on the duration of the power of attorney; this is my error. The power of attorney is valid for 3 years until 2011, not until 2008 as indicated in the documents. I would greatly appreciate your URGENT con?rmation on whether the documents were already picked up by the Courier company. Regards, Suzy Ramos Corporations MOSSACK rouscu Mossfon Building 54th Street Ma rbella P.O Box 0832?0886 W.T.C Panama Panama, Republic of Panama 2+ 507 205-5888 5 507 263?7327 TRANSLATION MFCS 002134 Document 100-3 Filed 03/16/15 Page 168 of 217 Case 2 Document 90-4 Filed 03/03/15 Page 13 of 62 Case 2 Messrs, MF CORPORATE SERVCES (NEVADA) LIMITED 520 s. 7?h Street, Suite Las Vegas, NV 89101 Dear Sirs: RE: DYNAMIC LLC The undersigned, KENDE LAW FIRM (hereinafter referred to as the "client"), do hereby declare the following: a. DYNAMIC FITTNESS LLC does not operate a trade or business in the United States of America. Therefore no EIN has been issued. 1). The member is not US citizen and not US resident. c. The above information is true, correct and complete. Dated this 14'h October, 2008. K5 FIRM - wt hath r1rlae%??7' TRANSLATION MFCS 002135 Diego Sepulveda - Corporations From: MF CorpServ (Nevada) Ltd. Sent: Monday, September 8, 2008 5:27 PM To: Mossack Fonseca Co. (Corporations - Nevada) Cc: Patricia Amunategui - MF CorpServ (Nevada) Subject: RE: DYNAMIC ESS LLC 1587149 ET/iv/Sr Dear Suzy: Many thanks we await Mr. Tamas Moln?r?s passport number. Kind Regards PM AWW From: Mossack Fonseca at C0. (Corporations? Nevada) Sent: Monday, September 8, 2008 1:31 PM To: MF CorpServ (Nevada) Ltd. Cc: Patricia Amunategui - MF CorpServ (Nevada) Subject: DYNAMIC FITTNESS LLC 1587149 ET/iv/sr Dear Patricia: We are referring to the client?s instructions for the preparation of 2 powers of attorney in English in favor of the following gentlemen: GYORGY LASZ TAMAS MOLNAR Attached you will ?nd the models for the power of attorney; each must be legalized by Apostille. Note that the power of attorney for Tamas Molnar is missing the passport number. I am verifying?the exact number and I will con?rm. Regards, Suzy Vergara Eorporatlons I MOSSACK rowsraca I Massron Blaming 54m Slmat. Mum?: P.O. 30: 0832-0838. W.T.C. Panama Panama, Newbie of Panama Tamas?sans E's: wanes-7327 8W ssfonnom TRANSLATION MFCS 002162 Case Document 100-3 Filed 03/16/15 Page 169 of 217 Case Document 90-4 Filed 03/03/15 Page 14 of 62 17 19190 10112le98 932d A?a?eawe@?d@@ er 6031793 ISUJII EAf'll?l I 13 Case Document 100-3 Filed 03/16/15 Page 170 of 217 Case Document 90-4 Filed 03/03/15 Page 15 of 62 COMPANIES 2005 (7879/ET/mv) Case #1269723 Page 1 of 1 Mf corp From: Monica Ycaza - Peru Representative Of?ce Sent: Friday, November 11, 2005 8:01 PM To: Mossack Fonseca Co. (Corporations - Nevada) Subject: Arisa Business Dear Mayka: The client tells me that he/she needs to enter into a stock purchase agreement with the owner of Arisa Business. Arisa would buy stock in a Peruvian company. This needs to be signed by Arisa?s representative in Nevada. Can you give me his details so that the contract can be prepared? Many thanks! Monica MOSSFON PERU MEI-Lexus? WITNESS DATE Ellen A. Goldstein, CCR 29 12/23/2005 TRANSLATION MFCS 000535 EXHIBIT 16 Case Document 100-3 Filed 03/16/15 Page 171 of 217 Case Document 90-4 Filed 03/03/15 Page 16 of 62 .. Page 1 of 3 I corp From: Jost Dex - Luxembourg Rep. Of?ce Sent: Monday, May 22, 2006 7:37 AM To: Patricia Amunategul - MF CorpServ (Nevada) Cc: Mo'ssack Fonseca Co. (Corporations - Nevada) Subject: URGENT: AGROGLOBE EQUITY LLC Dear Patricia, the client made a mistake in the spelling. The correct name should be Agroglobe Equity LLC Thank you and best regards, MOSSACK FONSECA CO. (LUXEMBOURG) SARL Jost Dex Original Message SubjectzNEW INCORPORATION: AGROGLOB EQUITY LLC Date:Mon, 22 May 2006 15:16:31 +0200 From?ost Dex Reply-Toimxdo?cr?m?oa-?m Organ'mltionzMossack Fonseca Co. Luxembourg Nevada O?ice URGENT-URGENT Dear Patricia, Please proceed with the incorporation of a new LLC named Agroglob Equity LLC (In case this name should not be available please use Intercom Equity LLC instead.) with the following features: speedy incorporation service at extra charge (please con?rm incorporation asap) . manager: ALDYNE LTD. 0 member: GAIRNS LTD. 0 capital: standard EXHIBIT i Details foraPOAwill be sentlater. WITNESS Egg I DATE Scanning; 3 on! Ellen A. Goldstein, CCR 829 5/22/2006 Page 2 of 3 PLEASE CONFIRM WHEN THE DOCUMENTS WILL LEAVE Thank you and best regards, MOSSACK FONSECA C0. (LUXEMBOURG) SARL Jost Dex Original Message Subjecti Order request for a Nevada LLC Date:Mon, 22 May 2006 14:42:06 +0200 From:Kacsoh Gabor (Experta?Lux) To:Jost Dex <'ost mossfon.lu> CC:Jacoby Myriam (Experta?Lux) . rta.lu> Kettmann Guy (Bxperta-Lux) WW Schroeder Sylviane (Experta-Lux) chroeder ex erta.lu> Dear Mr. Dex: We would kindly like to place an order for a Nevada LLC company to be established on an expedited basis. The company's name should read Agroglob Equity LLC, but if that name is not available. then Intercam Equity LLC. Could you please inform me of the company's address and the name of the company's manager as expeditiously as possible? Many thanks for your efforts. Kind regards, Gabor Kacsoh Experta Corporate and Trust Semioes SA. Tel.: +352 269255-4095 Fax: +352 289255-3542 Esmail: Web: wwexgeriaju From: JostDex [mailto:' st mossfon. Sent: Monday, May 22, 2006 11:09 AM To: Kacsoh Gabor (Experta-Lux) Subject: NEVADA LLG Hi Mr. Kacsoh. Please ?nd below the details on Nevada LLCs. As you can see our people in Panama even work during the night from Sunday to Please be advised that we do not have any company available in our of?ce. at this time. However, the following companies are from the stock of our Nevada Of?ce: 5/22/2006 Case Document 100-3 Filed 03/16/15 Page 172 of 217 Case Document 90-4 Filed 03/03/15 Page 17 of 62 Page 3 of 3 EXTON INTERNATIONAL LLC EVERINA HOLDINGS LTD. Kindly note. that copy of this message is being sent to our Nevada Of?ce in order to obtain their con?rmation on the availability of these companies. Please be advised that the Manager is ALDYNE LTD. and the Member GAIRNS LTD. both registered at Suite 13, First Floor, Oliaji Trade Centre Francis Rachel Street \?ctoria, Mahe Seychelles Kind regards, MOSSACK FONSECA C0. (LUXEMBOURG) SARL Jost Dex Tel: +352 349 888-] Fax: +352 349 889 Email' jog??ngssiang An electronic message is not binding on its sander. Any message referring to a binding engagement must be con?rmed in writing and duly signed. An electronic message is not binding on its sender. Any message referring to a binding engagement must be con?rmed in writing and duly signed. 5/22/2006 EXHIBIT 17 Document 100-3 Filed 03/16/15 Page 173 of 217 Case 2 Document 90-4 Filed 03/03/15 Page 18 of 62 Case 2 Page 1 of 3 MI corp From: Mossack Fonseca Co. (Corporations - Nevada) Sent: Wednesday. January 10, 2007 12:54 PM To: Mossack Fonseca 8. Co. (Uruguay) Cc: Patricia Amunategui - MF CorpServ (Nevada) Subject: BANFORD PROPERTIES Attachment: Annual list 2007.pdf Dear Lorena: Following are answers to the client?s questions: 1. With respect to the power of attorney, we?d be gratefu they could provide us with full details and a copy of the designated agent?s passport. We also need confirmation as to whether it would be legalized by Apostille in Nevada and whether they would want to opt for expedited processing (approximately 36 once the Secretary of State has received the request) at an additional cost of The cost is as follows: Our fee Legalization expenses Courier Expedited processing (optional) Turnaround time for standard processing is approximately 7 to 10 working days. 2. With respect to the change of Manager, the new Manager must send us the signed annual list form. I?m attaching it for your convenience. It can take between 2 and 4 weeks to register this document. The cost is as follows: Our fee USSZBODO Registration fees Expedited processing (optional) We look forward to hearing from you. Kind regards, iris Vergara HOSSACK FONSECA CO. Imam: Tel.: (507) 205-5838 am: Fax: (507) 263-7327 E-mail: General e?rnail: mgme Website: Mmg??fomcom From: Mossack Fonseca a C0. (Uruguay) Sent: Wednemay, January 1.0, 2007 11:30 AM To: Mossack Fonseca Co. (Corporations - Nevada) Cc: Patricia Arnunategui - MF CorpServ (Nevada) ?2007 TRANSLATION MFCS 000899 Pagc20f3 Subject: FW: SANFORD PROPERTIES LLC. Dear iris and Patr Good morning! Please address the client's question and send us your comments. Thank you. Regards, Licda. Lorena Miranda p/Mouack Fonseca 8 Co. (Uruguay) S.A. Edi/icio Tupi Juncoi 1305, Of. 902 C. P. (.000 Montevideo - URUGUAY Tel: (598] 2 No 0588 Fax. 593) 2 916 0642 email: urug uay@mossfon.com Web page: Thank you for selecting Mossack Fonseca Co. to meet your corporate needs Our office in Panama will be closed on Tuesday, January 9, 2007. Service will resume on Wednesday, January 10, 2007. From: Clara Capote Sent: Wednesday, January 10, 2007 1:27 PM To: Licda. Lorena Miranda Mossack Fonseca Co. (Uruguay) S.A. Cc: vespel@estudiobianchi.com.uy Subject: BANFORD PROPERTIES LLC. Dear Lorena, 1) We need you to please inform us of the steps and documentation necessary for effecting a change of representative, together with the costs and time involved. The company currently has ALDYNE LTD. as Manager and Jos? Miguel Piaggio as Designated Agent. It is necessary to replace Piaggio with another person provided by the client. 2) Please inform us what steps and documentation would be necessary in the event that it is also necessary to replace the Manager of the company with an individual provided by the client who would no doubt be the new agent, although in that case a modi?cation of the Manager would perhaps make a power of attorney unnecessary, since the administration of the company would be in the hands of that person. Please also inform us about costs and time. I look forward to hearing from you. Many thanks, Clara Capote cca ote estudiobianchi.com.u TRANSLATION MFCS 000900 Document 100-3 Filed 03/16/15 Page 174 of 217 Case 2 Document 90-4 Filed 03/03/15 Page 19 of 62 Case 2 Estudio Bianchl Telefax (005982) 401.6952 - 402.57.16 - interno 208 Avda. 18 de Jullo 2037 c?dna 101 Montevideo - UNQW CP. 11.200 Page 3 of 3 TRANSLATION MFCS 000901 Lew? From: Mossack Fonsem 5. Co. (Corporations - Nevada) Sent Thursday. August 04. 2005 5:47 PM To: Mossaok Fonsam Co. (Uruguay) Subject: SANFORD PROPERTIES LLC I CASE 1252031 NEV - POWER OF ATTORNEY GENERAL explratlon datadoc: Letter 0! Undertaldngooc Dear 0dile: We?ve taken note of the acqu on of the company in question. With respect to the client's request, we can confirm the following: 1. Please note that our manager is appointed starting on the date of incorporation of the LLC (Le. April 20, 2005) 2. Please note that we require the following information/documentation in order to go ahead and issue the power of attorney. - Copy of the designated agent?s passport Act? ies to be carried out by the LLC (we note that it will be a shareholder in a Uruguayan company). Meanwhile, we enclose a model of the Power of Attorney to be issued and legalized (dated August 1, 2005) for approval by the client. NEV POWEROF 3. I would be grateful if you could confirm whether or not the legalization of the Power of Attorney should be processed directly in Nevada and whether expedited service is required (additional charges apply). 4. Letter of undertaking duly signed by the client in which the latter undertakes to inform us in the event that the blank endorsement we have signed on the reverse of the Membership Certificate is completed. Letter of ndertakingdoc (34 . We await your instructions. Kind regards, Edison E. Teano Tel.: (507) 263-8399. 264-2322 TRANSLATION MFCS 000902 Document 100-3 Filed 03/16/15 Page 175 of 217 Case 2 Document 90-4 Filed 03/03/15 Page 20 of 62 Case 2 Fax: (507) 263-7327 o?mall: lull: Mossadr For-set: 8: Co. (Urugtzy) salt: Thursday, Nam 01, 2005 an: AM To: mssack Form a: Ca. (Comm-aunts - Nevada) RV: LLIS DE EIUDIO BIANCHI- 106mlET/Iv Dear Mayka, I?m forwarding you the email from the client which is self-explanatory. I await your comments, 0dile -?Original Message--?- From: Verbnica Espel - Estudio Bianchi Sent: Thursday, August 4, 2005 10:38 AM To: 'Mossack Fonseca Co. (Uruguay) CC: bianchi@adinet.com.uy Subject: FW: RESERVE BIANCHI LAW FIRM - 10608/ET/iv Importance: High Good morning, 0dile. They con?rmed the Nevada company PROPERTIES for us. The board of directors shall be supplied by yourselves and the appointment must take effect on August 1, 2005. They must also grant a general power of attorney empowering the designated agent to act on behalf of the company. The details of the desi nated a ent are as follows: JOSE MIGUEL PIAGGIO MAEARA Uruguayan Identity Card No. 1.957.917?3 Domicile: Tomas Diago 607 apartamento 301 The LLC will be shareholder of a Uruguayan company. ALL THE DOCUMENTATION MUST BE DULV LEGALIZED BY APOSTILLE AND SENT TO MONTEVIDEO WITH THE GREATEST POSSIBLE URGENCY. Many thanks, Veronica Espel vespel@estudiobianchi.com.uy Estudio Bianchi Telefax (005982--?-Original Message?~? From: Mossack Fonseca 8: Co. (Uruguay) S.A. Sent: Friday, July 29, 2005 5:35 PM To: Verbnica Espel - Estudio Bianchi Subject: FW: RESERVE BIANCHI LAW FIRM - 10608/ET/iv 0k Odile Message-? From: Veronica Espel - Estudio Bianchi Sent: Friday, July 29, 2005 17:18 To: 'Mossack Fonseca 8: Co. (Uruguay) TRANSLATION MFCS 000903 Subject: FW: RESERVE BIANCHI LAW FIRM - 10608/ET/iv 0dile, We need you to please keep the Nevada company PROPERTIES reserved. Many thanks. Veronica Espel vespel@estudiobianchi.com.uy Estudio Bianchi Telefax (005982??-Original Message-? From: Mossack Fonseca &Co. (Uruguay) S.A. [mailtozuruguay@mossfon.com] Sent: Friday, July 29, 2005 1:14 PM To: Estudio Bianchi Subject: FW: RESERVE LLCS BIANCHI LAW FIRM - 10608/ET/iv Dear Jorge: I can con?rm that the following LLC (currently in Panama) was released and will be reserved for you together with ARISA BUSINESS until August 3, 2005: NAME OF THE LLC DATE OF INCORPORATION BANFORD PROPERTIES LLC April 20, 2005 I await your instructions. Regards, 0dile Frederick TRANSLATION MFCS 000904 Case Document 100-3 Filed 03/16/15 Page 176 of 217 Case Document 90-4 Filed 03/03/15 Page 21 of 62 Therly Ramirez - Corporations :om: World-Check Sent mi?rcoles, 12 dejunio de 2013 05:19 am To: Enma Rojas - Corporations Subject NECMI ALPER SUMER USERNAME: mn1 SENT: 12?06-2013 10:19 UTC NAME: NECMI ALPER SUMER . MODE: Exact Match There are no entries matching the above search criteria. I 1) General Legal Notlce All information identi?ed or correlated In this pro?le, appears In the listed sources. We are not responsible for the content of third party sites or sources. Information correlated is necessarily brief and should be read by users in the context of the fuller deizils available in the external seams to which hypertext links are provided. Users should also out independent checks in order to verify the information oorrelaind. 2) (hosiery Legal Notice Category ls based on information contained in the sources provided. 3) Reported Legal Notice Where an individual or entity is listed as being 'Reported to be linked to" other pro?les, the nature ofthe links vary considerably and users should not draw negative inferenos merely from that association. You are strictly prevented from disclosing or copying to third parties the content of this database in accordanoe with our Tems Bi Conditions. Content is protected by quali?ed privilege. Legal adion will be taken against users that disclose content to third parties other than regulatory and government agencies. gimgmg EXHIBIT [8 WITNESS DAT Ellen A. oldstein, Case Document 100-3 Filed 03/16/15 Page 177 of 217 Case Document 90-4 Filed 03/03/15 Page 22 of 62 Therly Ramirez - Corporations om: World-Check Sent: mi?rcoles, 12 dejunio de 2013 05:20 am. To: Enma Rojas Corporations Subject EMRE KUZUBASIOGLU no rsults found. Therly Ramirez - Corporations lrom: World?Check Sent: mi?rcoles, 12 dejunio de 2013 05:20 am. To: Enma Rojas - Corporations Subject: SERHAT FIRAT no rs.? USEKNANE: mn1 SENT: 12-06-2013 10:19 UTC NAME: EMRE KUZUBASIOGLIJ MODE: Exact Match There are no entries matching the above seamh criteria. . I 1) General Legal Notlm All information identi?ed or correlated In this pro?le, appears In the listed sourcs. We are not responsible for the content of third party sits or sources. Information correlated ls necessarily brief and should be read by users In the concert of the fuller details available In the extemal sources to hypertext "an are provided. Users should also carry out Independent checks In order to verify the Inforrnab?on correlated. 2) Caugory Legal Notice Category Is based on Information contained In the sourcs provided. 3) Reported Link Legal Notlce Where an or entity Is listed as being 'Reported to be linked to' other pro?les, the nature of the linls vary considerably and users should not draw negative Inferencs merely from that asodab'on. You are strictly prevented from disclosing or copying to third parb'es the content of this database in accordance with our Terms 11 Condltions. Content is protected by quali?ed privilege. Legal action will be taken against users that disclose content to third parties other than regulatory and government agencies. USERNAME: mn1 SENT: 12-06-2013 10:19 UTC NAME: SERHAT FIRAT MODE: Exact Match There are no entries matching the above search criteria. I 1) General Legal Notice All information identi?ed or correlated In this pro?le, appears In the listed sources. We are not responsible for the content of third party sites or sources. Information oonelated ls numrily brief and should be read by umrs In the context of the fuller details available In the external sources to which hypertext are provided. Users should also carry out Independent checls in order to verify the Information correlated. 2) Category Legal Notice Category Is based on Information contained In the scum-rs provided. 3) Reported Legal Notloe Where an individual or entity is listed as being 'Reported to be linked to' other pro?lw, the nature of the links vary considerably and users should not draw negative Inferenas maely from that assoclatlon. You are strictly prevented from disclosing or copying to third parties the content of this database in accordance with our Terms 8: Conditions. Content Is protected by quali?ed privilege. Legal action will be taken against users that disclose content to third parties other than regulatory and government agencies. Case Document 100-3 Filed 03/16/15 Page 178 of 217 Case Document 90-4 Filed 03/03/15 Page 23 of 62 UNOIOA llnI ll Case Document 100-3 Filed 03/16/15 Page 179 of 217 Case Document 90-4 Filed 03/03/15 Page 24 of 62 - Therly Ramirez - Corporations IA A . ., wank-.4 I, ram: Miguel Diaz - Mossfon Geneva Sent: mi?rcoles, 12 dejunio de 2013 09:46 am. To: Patricia Amunategui MF CorpServ (Nevada) no mule found. Subject EASTFER INTERNATIONAL LLC - 2154697 - MD Dear Patricia. For the Nevada company EASTFER INTERNATIONAL LLC. the client wishes to know ifwe an con?rm the authenticity of the validity of business licence from of?cial company registration page of Nevada. fl" "ll-"Is! item!" 'il-il-a- . Em. Marblde Can! a is thereaweb a elink. so the client can veri himselfPlease we need urgently a reply today. Kind Regards. Miguel Diaz Mossack Fonseca 8. Co. (Geneva) SA MOSSACK FONSECA 4, rue Micheli-du?Crest 1205 Geneva Switzerland ?ei. +4122 809 5020 . ax. +4122 809 5030 We value y0ur feedbackl 9W Document 100-3 Filed 03/16/15 Page 180 of 217 Case 2 Document 90-4 Filed 03/03/15 Page 25 of 62 Case 2 I3 EAHIDI Page 1 of 5 Mf corp From: Mossack Fonseca Co. (Corporations - Nevada) Sent: Monday, October 29, 2007 12:30 PM To: Mossack Fonseca Co. (Peru Representative) Cc: MF CorpServ (Nevada) Ltd. Subject: INCORPORATION OF A NEVADA Good Afternoon: This is in reference to your instructions. We are con?rming that we I move forward with the incorporation of the LLCs, regarding MURRIEL TRADING LLI PERMANEL INVESTMENT LIMITE I both be incorporated with AIdyne Ltd., as Manager. We will keep you updated. Kind Regards, Oneissa Osorio Corporations MOSSACK, 3'51) Moss'on Building 54m Street, Marbella Po. Box 0832-0806, W.T.C. Panama Panama, Republic of Panama 2 507 2057583! 507 263-7327 From: Mdnica Ycaza - Peru Representative Office Sent: Monday, October 29, 2007 12:30 PM To: MF CorpServ (Nevada) Ltd.; Mossack Fonseca 8: Co. (Corporations Nevada) Cc: Mossack Fonseca 8: Co. (Peru Representative) Subject: Re: INCORPORATION OF A NEVADA Dear Patricia, The client wants to incorporate PERMANEL INVESTMENT LIMITED with the new manager (ALDYNE). Please proceed to incorporate ASAP Can we also make MURRIEL with ALDYNE and the other two with I look forward to hearing your comments. Warm regards, EXHIBIT CRBZ Monica de Ycaza WITNESS MOSSFON PERU DATE Ellen A. Goldstein, Message--?-?- From: Me 10/29/2007 TRANSLATION MFCS 006580 Document 100-3 Filed 03/16/15 Page 181 of 217 Case 2 Document 90-4 Filed 03/03/15 Page 26 of 62 Case 2 Page 2 of 5 To: 'Mossack Fonseca Co. Cor orations - Nevada 'M?nica Ycaza - Peru Rem'esentative Office' Cc: 'Mossack Fonseca 8t Co. Peru Re resentative Sent: Monday, October 29, 2007 12:10 PM Subject: RE: INCORPORATION OF A NEVADA Dear Monica: We are confirming that the names proposed below are currentely available in the jurisdiction of Nevada, we await your instructions. Regards PM AWM From: Mossack Fonseca Co. (Corporations - Nevada) Sent: Friday, October 26, 2007 7:39 AM To: Monica Ycaza Peru Representative Of?ce Cc: Mossack Fonseca Co. (Peru Representative); MF CorpServ (Nevada) Ltd. Subject: INCORPORATION OF A NEVADA Dear Monica: The LLCs in our stock are incorporated with PLASCOT LIMITED as manager, if you agree we can request the verification of the four (4) names below for subsequent incorporation as shelf for the Peru stock. Please note that we can appoint ALDYNE LTD. to one of them, as Manager, please indicate which one, we appoint PLASCOT to the others. MURRIEL TRADING LLC PERMANEL INVESTMENT LIMITED MAKALA ENTREPRISES LTD. GUBAY CONSULTANTS LIMITED We look forward to the aproval of the names to proceed with their verification. Kind Regards, Onelssa Osorio Corporations Mossfon Building 54th street, Marbella PO. Box 0831-0586, W.T.C. Panama Panama, Republic of Panama 507 205-588! 507263?7327 3 Cor rat From: Monica Ycaza - Peru Representative Office Sent: Thursday, October 25, 2007 04:30 PM To: Mossack Fonseca Co. (Corporations - Nevada) Cc: Mossack Fonseca 8. Co. (Peru Representative); MF CorpServ (Nevada) Ltd. 10/29/2007 TRANSLATION MFCS 006581 Page 3 of 5 Subject: Re: FULLTECH INVESTMENTS LLC Hi Iris, .IESPER and GIRANDELL are reserved. The thing is that we want one LLC with a manager other than FULLTECH. Which could it be?? YES, we need more shelf but with another managerll Warm regards, Monica MOSSFON PERU Message?- From: Mossack Fonseca Co. Cor orations - Nevada Cc: Mossack Fonseca Co. Peru Re resentative Cor Serv Nevada Ltd. Sent: Wednesday. October 24, 2007 12:15 PM Subiect: FULLTECH INVESTMENTS LLC Dear Monica: According to our records Mossfon Peru has two LLCs: IESPER EQUITIES LLC from May 2, 2007, and GIRANDELL TRADING LTD., from September 20, 2007 Aditionally, we have the LLC, OLVEX CAPITAL LTD., which was incorporated for your stock; however, it was sent to Panama. Please confirm if your client is interested in OLVEX, so that we can send it to you as soon as we receive instructions on its sale. I am also attaching our listing of available LLCs in Panama, if your client is interested in any of them we can send it to you; meanwhile, please let me know which one we should reserve for you. Also, please con?rm if we should proceed to incorporate 3 more shelfs for you. Kind Regards, Iris Vergara Corporations Mossfon BuIIdIng 54th Street, Marbella P.O. Box 0832-0386, W.T.C. Panama Panama, Republic of Panama i 507 205-5883 507 2634327 10/29/2007 TRANSLATION MFCS 006582 Document 100-3 Filed 03/16/15 Page 182 of 217 14 Case 2 Document 90-4 Filed 03/03/15 Page 27 of 62 Case 2 10/29/2007 Page 4 of 5 From: Monica Ycaza - Peru Representative Office Sent: Wednesday, October 24, 2007 12:07 AM To: MF CorpServ (Nevada) Ltd. Cc: Mossack Fonseca Co. (Corporations - Nevada); Mossack Fonseca 8: Co. (Peru Representative) Subject: Re: FULLTECH INVESTMENTS LLC Many thanks dear Patr Ia! We have already sold FULLTECH and LYNUS (we will be providing instructions as soon as we receive the documents from the clients); therefore the only one I have left is PURPLE. Do you have other names? Because the client who purchased FULLTECH needs another onel Warm regards, Monica MOSSFON PERU Original Message From: Mf corp To: 'Monica de Ycaza? Cc: Nevada-PanamaOffice Mossfon.com Peru Sent: Monday, October 22. 2007 3:06 PM Subject: RE: FULLTECH INVESTMENTS LLC Dear Monica: I ?ll be sending your of?ce the shelf[s] that are ready other than FULLTECH INVESTMENTS LLC LYNUS OVERSEAS LTD. PURPLE HOLDINGS LLC Most of our recent incorporations have PLASCOT LIMITED as manager, I'm waiting for corporations to give me other instructions in this regard. Regards Palm Ari/Amid; From: Monica de Ycaza (mailtozDeYcaza@mossfon.com] Sent: Monday, October 22, 2007 9:12 AM To: Mf corp Cc: Nevada-PanamaOffice Mossfon.com; Peru mossfon.com Subject: Re: FULLTECH INVESTMENTS LLC Hi Patricia, Then I need other names for companies that are ready (recent ones) and that have another manager, so that the client can choose the second company. Many thanks! Warm regards, Monica MOSSFON PERU 10/29/2007 TRANSLATION MFCS 005533 Page 5 of 5 Original Message From: Mf corp To: ?Monica de Ycaza' Cc: Nevada-Panamaoffice Mossfoncom Peru mossfon.com Sent: Monday, October 22, 2007 4:27 AM Subject: RE: FULLTECH INVESTMENTS LLC Dear Monica: This company has PLASCOT LIMITED as manager, we await your instructions. Regards PWAWM From: Monica de Ycaza Sent: Sunday, October 21, 2007 9:44 PM To: NEVADA (Patricia Amunategui) MOSSFON Cc: Nevada?Panamaoffice Mossfon.com- Peru mossfon.com Subject: FULLTECH INVESTMENTS LLC Dear Patricia and Iris, We have sold the company FULLTECH INVESTMENTS LLC We need to know the name of the manager company so that the client can choose another NEVADA company but with a different manager. Thank you very much! Monica de Vcaza MOSSFON PERU TRANSLATION MFCS 006584 Case Document 100-3 Filed 03/16/15 Page 183 of 217 Case Document 90-4 Filed 03/03/15 Page 28 of 62 EXHIBIT 22 Emerith De Leon - Executive Assistant From: Patricia Amunategui - MF CorpServ (Nevada) Sent: Friday, August 4, 2006 9:43 pm. To: 'Odile Frederick?; Mossack Fonseca Co. (Corporations - Nevada) Subject: RE: HUSTON MANAGEMENT LTD Dear Odile: We?re pleased to inform you that we have personally left the package at DHL for the aforementioned company, courier 8899914881, we?re not 100% certain that it will actually go out today, but we?ve done all we can to send it today. Regards PM AW From: Odile Frederick Sent: Fnday, August 04, 2006 12:45 PM To: - Corporations (Nevada) Cc: Patricia Amunategui - MF CorpSeN (Nevada) Subject: HUSTON MANAGEMENT LTD Dear Iris, Our client Estudio Damiani has con?rmed the acquisition of the aforementioned company. Please coordinate with the Nevada of?ce to ensure that you dispatch it without fail to our Montevideo of?ce today. I look forward to hearing from you. Odile Frederick MOSSACK FONSECA 8. CO. Juncal 1305. o?cina 902 Montevideo. Uruguay Tel.: +595?2 916-0588 Fax: +598?2 916.0642 email: uruguameossfonoom ldm_"" TRANSLATION MFCS 004065 DATEW Ellen A. Goldstein, CCR 829 Case Document 100-3 Filed 03/16/15 Page 184 of 217 Case Document 90-4 Filed 03/03/15 Page 29 of 62 EXHIBIT 23 ;uav . corp From: - Corporations (Nevada) [Nevada?PanamaOf?erMoesfoncom] Sent: Tuesday. November 30. 2004 11:04 AM To: Just Dex - Luxembourg Rep. Of?ce Cc: Patltcia Amunategul - MF CorpServ (Nevada) Subject: MEDINVEST LLC - Importance: High Dear Mr. Dex: We refer to your e-mail dated 26"1 November 2004. We have reviewed the Form W-9 and we understand that it is a form that Is completed by persons who bassically any on activities in the US. In fact. in order to ?le this form the must obtain an Individual Taxpayer Identi?cation Number (ITIN) through its Manager or Member. As you are aware in cases like this whether the LLC will have any connection with the IRS and! or with activities connected to USA. Mossfon does not provide the Manager and or Member services. Please con?rm us the reason the client would like us to complete the Form W-9 and whether the LLC will carry activities or will have any connection in the USA Best regards, Edison Teano MOSSACK FONSECA 8- CO. TELS.: (507) 263-8899 264-2322 FAX: (507) 263-7327 E-mail Ws?n.m General e?mail: MF@mossfon.com Good A 24-hour service ls being provided by our Pana BVI cities from 23:30 (BVI local time) on. You may contact us will be happy to assist you. For more information about these ma of?ce as well as a night service at our anytime by telephone. e?mail or tax. We schedules. please visit our website at From: Jost Dex - Luxembourg Rep. Of?ce Sent: Friday, November 26, 2004 6:06 AM To: - Corporations (Nevada) Subject: INFO: MEDINVEST Import-nee: High Dear friends. please ?nd attached documents received today from my cllent. Kindly Inform me whether you could sign these documents or not. What would it imply if documents are signed? The client Informed me that he would need two sets signed. 11/30/2004 WEXHIBITA WITNESS mm DATE Ellen A. Goldstein, Case Document 100-3 Filed 03/16/15 Page 185 of 217 Case Document 90-4 Filed 03/03/15 Page 30 of 62 Thank you and best regards. M088ACK FONSECA 8. co. (LUXEMBOURG) SARL Jest Dex 11/30/2004 rage 4 01 1. Page 1 of 1 Mf corp From: Lugeno Representative Office Sent: Wednesday. December 01, 2004 11:52 AM To: - Corporations (Nevada) Subject: Williamson-Nevada importance: High Justinian Germany Inn- File Nun" Die 01 Reg. NEV WLLIAMBON INTERNATIONAL Lc 120144 MAR-03 Mm In connection with lhe above company. will the manager Fergus International SA issue: 1- one resolution. not legalised nor epoe?lled. bearing date 11 Feb 2004. revoking to power of attorney issued on 4 July 2003 In favour of the company Winlour SA. Nlue 008896; 2- one resolu?on. not legallsed nor apos?lled, bearing date 11 Feb 2004, revoking to power of allomey issued on 6 March 2003 in favour of Mr. Charles Kalopungi. Pis. con?rm your delivery of documents by weekly-courier. Kind regards, De Grandl, Lugano 12/1/2004 Case Document 100-3 Filed 03/16/15 Page 186 of 217 Case Document 90-4 Filed 03/03/15 Page 31 of 62 Page 1 of 2 Mt corp From: Jest Dex [luJoetQmossfoncom] Sent: Thursday, November 18, 2004 2:31 AM To: Mf corp Subject: RE: MEDINVEST LLC Dear Patricia, I thought that when we order a standard incorporation that you would have a standard program. The client asks for our members and managers. I assume that this answers the question regarding the contributions and number of membership certi?cates. Legelisa?on and expedite fee are not needed. Thank you and best regards, MOSSACK FONSECA GO. (LUXEMBOURG) SARL Jost Dex ?-?Original Message?? From: Mf corp Sent: Thursday, November 18, 2004 3:26 AM To: 'Jost Dex? Cc: Subject: RE: NEW INCORPORATION: MEDINVEST LLC Dear Jost: Thanks for your mail below, lam please to inform you that the names requested are available. To proceed with this incorporation I appreciate you con?rmation as fellows; Name: MEDINVEST LLC Manager ,Member and their complete address in the event that it is not our nominees Amount of Contributions Number of Membership Certi?cates Legations needed Expedite fee required (Yes or Not) if other instruction apply I look forward to hear from you Kindly ??Origlnal Masage? From: Just Dex Sent: Wednesday, Novaan 17, 2004 8:08 AM To: MF Nevada Of?ce Sulziact: NEW INCORPORATION: MEDINVEST LLC Dear Paticia, 1 1/18/2004 Please proceed with the Incorporation of an LLC named MEDINVEST LLC attemative names: GROUP LLC or MEDINVEST MANAGEMENT LLC I will confirm to you later how to issua the FDA. Our client for this company is Mr. Sergio Lorenzi. Thank you and best regards, MOSSACK FONSECA CO. (LUXEMBOURG) SARL Jest Dex 11/18/2004 Page 2 of 2 Case Document 100-3 Filed 03/16/15 Page 187 of 217 Case Document 90-4 Filed 03/03/15 Page 32 of 62 Page 1 of 1 Mt corp 333%] From: Joet Dex - Luxembourg Rep. Of?ce Sent: Sunday, January 30, 2005 7-25 AM a To: - Corporations (Nevada) Subject: Dear friends, send us a Certi?cate of lncumbency for ALDYNE LTD. with epedel articles stating that Yvette Rogers has sole signature right for ALDYNE LTD. that the signature hereafter is the own. true and proper of Yvette Rogers return the document via weekly courier Thank you and best regards. FONSECA l. 00. (LUXEMDOURG) SARL Joat Dex 1/31/2005 Page 1 of 1 3 Mf corp 1? From: Joet Dex Sent: Wednesday, January 19. 2005 12:01 AM To: MF Nevada Of?ce Co: PA Nevada Department Subject: URGENT: MEDINVEST LLC importance: High Dear Patricia, kindly print out the attached POA (simply add the signature line as I don't know who will sign for ALDYNE) have the FDA signed a have the document legalsed via Apoe?lie (exactly the same procedure as for the ?rst two return the document once completed by courieHo MF Luxembourg Of?ce Do you think we could receive the FDA before the end of January? Thank you and best regards, MOSSACK FONSECA co. (LUXEMBOURG) SARL Jest Dex 1/19/2005 Case Document 100-3 Filed 03/16/15 Page 188 of 217 Case Document 90-4 Filed 03/03/15 Page 33 of 62 Pagclofl Mt corp i From: (Nevada) i? sour: Thursday, December 10. 2004 3:02 PM a To: Jest Dex - Luxembourg Rep. Of?ce Subject: REQUEST FOR NEVADA COMPANY FROM CLIENT CIBG- Case Dear Mr. Dex: Thanks for your e-mail below. As per Mrs. ?Escobar?s instructions. the argument you can give to the client is that the LLCs and companies we incorporate and sale are for commercial activities. On the other hand, we are not experts in this matter and therefore, the client will have to look for the advice of a Nevada solicitor since these matters must be well ruled in USA. We do not even know if a LLC an be used for the client's purposes. We hope the above may help. I take this opportunity to inform you that we are waiting for your instructions in regard to MEDINVEST LLC (please refer to our comments through the CIS). Best regards, Iris Vergara 12/22/2004 ragetotr Mfcorp From: Jest Dex [limiostOrrtoeefoncom] Sent: Monday, November 22, 2004 6:46 AM To: MF Nevada Of?ce Co: PA Nevada Department Subject: URGENT: MEDINVEST LLC Dear Patricia, PLEASE KEEP THE DOCUMENTS ON HOLD. DO NOT SEND THE COURIER My client has some additional requests for more documents and we are sorting outwhet is still required. Once all is clear I will send you those new instructions and you may send all documents in one courier. Mssage? From: Jest Dar Sent: Friday, Novanber 19, 2004 9:58 AM To: MF Nevada onioe Cc: PA Nevada Department Subject: LLC Dear Patricia. further to the instruction to Incorporate the subject LLC please ?nd hereatter instructions regarding the issuance of two POAs: Elm In favour of Mr. Pierre HAMEL, 50 rue des Pommiers. 2343 Cents, Luxembourg -to enterlnto a ?duciary agreement with BIM Flductarte di Revisions ('Flducieria'), Via Gramsci, 7 - 20121 Torino with the purpose to take over and holding a controlling stake in the equity of SRL. Via i Maggio, no. 10/3 - 20152 Busto Arelzio (Varese); - to sign all the necessary deeds, documents and fame as well as to perform all the necessary acts that Fidudarta considers necessary for the execution of the ?duciary agreement; - this PM is to be malntened with the Fiducierle without any maturity, If not CANCELLED by the Director/s. mm in favour of Mrs. Cesarina CERANA. Via Orazio Fiaoo no. 37 - 21052 Bueto Arsizio (Varese) - to open and operate a bank accountw?h BIM (SUISSE) S.A., Lugano, Switzerland These both POAs need to be legeiised via Also please send photocopy of passports ofthe LLC managing director showing validation and apostilie. Thank you and best regards. MOSSACK FONSECA 8. CO. (LUXEMBOURG) SARL Jest Dex 1 1/22l2004 Case Document 100-3 Filed 03/16/15 Page 189 of 217 Case Document 90-4 Filed 03/03/15 Page 34 of 62 a Page 1 of 2 Mt corp From: Jost Dex [lux.jost@moseton.com] Sent: Monday, December 08, 2004 1:29 AM To: Mt corp Subject: RE: URGENT: MEDINVEST LLC Dear Patricia. The draft was relayed to my client for approval. i will revert to you with the answer soonest Yes. the passport of the manager needs to be legatieed via Thank you and best regards, MOSSACK FONSECA a. co. (LUXEMBOURG) SARL Jest Dex ?-Originai Mmge? From: Mf corp Sent: Saturday, Dme'nber 04, 2004 1:09 AM To: 'Jost Dar' Co: Nevada Department' Subject: RE: URGENT: MEDINVEST LLC Dear Jest: Enclosed please ?nd draft of the Power of attorney in favour of Mr. Pierre HAMEL for your approval. Also please con?rm you will need a copy of the passport legalized by Apostille of the manager. Best regards PM AW ?-Origtnal Maega? From: Just Dar Sent: Monday, November 22, 2004 6:46 AM To: MF Nevada Of?ce Cc: PA Nevada Department Subject: URGENT: MEDINVEST LLC Dear Patricia, PLEASE KEEP THE DOCUMENTS ON HOLD. DO NOT SEND THE COURIER YEi't My clent has some additional requests for more documents and we are sorting outwhat is still required. Once all is clear I will send you those new instructions and you may send all documents in one courier. 12/6/2004 I Page 2 of 2 -??0riginat Message?? From: Jost Dar Sent: Friday, Novunba 19, 2004 9:58 AM To: MF Nevada Office Co: PA Nevada Department Subject: MEDINVEST LLC Deer Patricia, further to the instruction to incorporate the subject LLC please find hereafter instructions regarding the issuance of two POAs: first PQA in favour of Mr. Plane HAMEL, 50 me dos Pommlers. 2343 Cents, Luxembourg - to enter into a ?duciary agreement with Fiduciaria di Revisions ('Fiduciaria'). Via Gramsot. 7 - 20121 Torlno with the purpose to take over and holding a controlling stake In the equity of SRL, Vla Maggie, no. 10/3 - 20152 Busto Arelzlo (Varese): -to sign all the necessary deeds, documents and fonrrs as well as to perform all the necessary acts that Flduclarta considers necessary for the execution of the ?duciary agreement; -DI this PM is to be maintened with the Flduciarla without any maturity, If not CANCELLED try the rector/e. we in favour of Mrs. Cesarlne CERANA, Vie Orazio Fieco no. 37 - 21052 Busto Arsizio (Varese) - to open and operate a bank account with (SUISSE) 3A.. Lugano, Switzerland These both POAs need to be legallsed via Also please send photocopy of passports of the LLC managing director showing validation and apostlite. Thank you and best regards. MOSSACK FONSECA 8- CO. (LUXEMBOURG) SARL Jest Dex 12/6/2004 Case Document 100-3 Filed 03/16/15' Page 190 of 217 Case Document 90-4 Filed 03/03/15 Page 35 of 62 Page 1 of4 Mf corp From: Joet Dex (lm.jost@mossfon.com] Sent: Monday, December 13. 2004 7:06 AM To: MF Nevada Ottlce Co: PA Nevada Department Subject: URGENT: MEDINVEST LLC Importance: High RG T: Patricia, NEW INSTRUCTIONS FROM MY Please send the corporate documents which are already completed (except for the by DHL courier directly to this eddren: Sergio Lorenzl Benn lntermobillere Via Meravlgl, 4 20123 Milano, Italy Tel. 0039 02 77191011 (business) Kindly send copies of these documents and also of the (not yet iegellsed) to my of?ce via email. The POAs once they have been iegaleed should be sent by separate courier to MF Luxembourg Ottice. Thank you and best regards. MOSSACK FONSECA 1. co. (LUXEMBOURG) SARL Jost Dex Sent: Monday, December 13, 2004 8:52 AM To: Mf corp Subject: RE: URGENT: MEDINVEST LLC Dear Patricia. please send all the documents In one package. Just a private tsue: you are residing in Las Vegas, coneot? Did you ever meet there Stef? Graf, our German tennle legend? She ehoul Ive there with her fanin and husband Andre Agassi. Beet regards. MOSSACK co. (LUXEMBOURG) SARL Joe! Dex Tel: +352 I 349 888-1 12/13/2004 Page 2 of4 Fax: +352 I 349 389 Message?? From: Mf corp Sent: Friday, Member 10, 2004 9:06 PM To: 'Jost DBKI Cc: Nevada Depamnent? Subject: RE: URGENT: MEDINVEST LLC Dear Jos?c Enclosed please ?nd the documents of MEDINVEST LLC. i will proceed with the legalizations by Apostille of the Power of Attorney. in reference with the time frame the regular time is between 7 to 10 working days but I remind you that in between of this incorporation were two holidays. Please confirm if i wait for the legalizations to send the Corporate Kit all together. In case I send them separately i will incur, in an extra courier. Best regards PM AW Visage?- From: Jost Der Sent: Friday, December 10, 2004 6:07 AM To: MF Nevada omce Cc: PA Nevada Department Subject: FW: URGENT: MEDINVBT u.c Dear Patricia. The client approved the attached version. Kindly proceed. The client complained that between his original request (and our order) and the actual incorporation date almost three weelos Is this a regular time frame? Kindly indicate when the dowments will leave Nevada. Thank you and best regards. MOSSACK FONSEGA It co. (LUXEMBOURG) SARL Jest Dex Wage?? From: Jest De: Sent: Monday, Deca'nber 06, 2004 10:28 AM To: Mf corp Subject: RE: URGENT: MEDINVEST LLC 12/13/2004 Case Document 100-3 Filed 03/16/15 Page 191 of 217 Case Document 90-4 Filed 03/03/15 Page 36 of 62 Page 3 of4 Dear Patricia, The dratt was relayed to my client for approval. I will revert to you with the answer soonest Yes, the passport of the manager needs to be Iegaltsed via Apostilie. Thank you and best regards. MOSSACK FONSECA CO. (LUXEMBOURG) SARL Jost Dex --0rtginal Mssage? From: Mf corp [mallmmendaaimfcorpsemcom] Sent: Saturday, Dmember 04, 2004 1:09 AM To: 'Jost: Dex? Cc: Nevada DepartmentJ Subject: RE: URGENT: MEDINVEST LLC Dear Jest: Enclosed please ?nd draft of the Power of attorney in favour of Mr. Pierre HAMEL for your approval. Also please con?rm you will need a copy of the passport legalized by Apostiile of the manager. Best regards PM 12/13/2004 ?Origtna Manage? From: Just Der Sent: Monday, November 22, 2004 6:46 AM To: MF Nevada 0111a: Co: PA Nevada Departmart Subjed: URGENT: MEDINVEST LLC Dear Patrtcia, PLEASE KEEP THE DOCUMENTS ON HOLD. DO NOT SEND THE COURIER My client has some additional requests for more documents and we are sorting out what is still required. Once all is clear I will send you those new Instructions and you may send all documents In one courier. Message? From: Just Dex Sent: Friday, November 19, 2004 9:58 AM To: MF Nevada Of?ce Cc: PA Nevada Department Subject: MEDINVEST LLC 12/13/2004 Page 4 of 4 5 Dear Patricia, further to the instruction to Incorporate the subject LLC please tind hereatter Instructions regarding the Issuance of two POAB: EILSLEQA In favour of Mr. Plerre HAMEL. 50 rue des Pommlers. 2343 Cents. Luxembourg ?to enter Into a ?duciary agreement with BIM Fiduclan'a dl Revisions Via Gramsci, 7 - 20121 Torlno with the purpose to take over and holding a controlling stake In the equity of SRL. Via Maggie, no. - 20152 Buato Arsizio (Varese); - to sign all the neceuary deeds, documents and forms as well as to perform all the necessary acts that Fidua?aria considers necessary for the execution of the Iiduciary agreement; - this PM is to be maintened with the Fiduciaria without any maturity. it not CANCELLED by the Director/s. In favour of Mrs. Cesartna CERANA. Via Orazio Fiaco no. 37 - 21052 Busto Arsizio (Varese) - to open and operate a bank account with BIM (SUISSE) S.A.. Lugano. Switzerland These both POAs need to be Iagalised via Apostiile. Also please send photocopy of passports of the LLC managing director showing validation and Thank you and best regards. MOSSACK FONSECA CO. (LUXEMBOURG) SARL Just Dex Document 100-3 Filed 03/16/15 Page 192 of 217 Case 2 14-CV-00492-RFB-VCF Document 90-4 Filed 03/03/15 Page 37 Of 62 Case 2 STOCK OF 2006 NEVADA SHELF COMPANIES 1256298 (ET/iv) Page 1 of 4 Mf corp From: Mossack Fonseca Co. (Corporations Nevada) Sent: Thursday, January 12, 2006 7:46 AM To: Mossack Fonseca 8L Co. (Uruguay); Patricia Amunategui MF CorpServ (Nevada) Cc: Mossack Fonseca Co. (Corporations Nevada) Subject: STOCK OF 2006 NEVADA SHELF COMPANIES 1256298 (ET/iv) Dear Patricia: Please incorporate: [checkmark] OVILLE GROUP LLC (legalized by Apostille) [checkmark] HILLBAY MANAGEMENT LLC (copies legalized by Uruguayan Cons.) The Manager/Member will be GAIRNS. Regards, lris Vergara MOSSACK FONSECA 8: C0. E-mail nevada- anamaof?ce mossfon.com General e-mail: MFQmossfoncom From: Mossack Fonseca 81 Co. (Uruguay) Sent: Thursday, January 12, 2006 10:46 AM To: Mossack Fonseca Co. (Corporations Nevada) Subject: RE: STOCK OF 2006 NEVADA SHELF COMPANIES 1256298 (ET/iv) That's perfect Iris. Regards, Odile Message?? From: Mossack Fonseca Co. (Corporations Nevada) Sent: Wednesday, January 11, 2006 7:40 PM To: Mossack Fonseca Bl. Co. (Uruguay) Cc: Patricia Amunategui MF CorpServ (Nevada) . Subject: STOCK OF 2006 NEVADA SHELF COMPANIES 1256298 (ET/iv) Dear Odile: Thank you for your prompt reply. Please con?rm whether you have any preference on names. Otherwise we will request the availability and incorporation of two (2) of these names: EXHIBIT 2 it OVILLE GROUP LLC HILLBAY MANAGEMENT LLC YALE HOLDINGS LTD. 1/12/2006 TRANSLATION MFCS 006487 Document 100-3 Filed 03/16/15 Page 193 of 217 Case 2 Document 90-4 Filed 03/03/15 Page 38 of 62 Case 2 STOCK OF 2006 NEVADA SHELF COMPANIES - 1256298 (ET/iv) Page 2 of 4 I look fon/vard to your instructions. Regards, Iris Vergara MOSSACK FONSECA CO. E-mailnevada- anamaof?ce mossfon.com General e-mail: MFQmossfoncom From: Mossack Fonseca 8: Co. (Uruguay) Sent: Wednesday, January 11,2006 11:09 AM To: Mossack Fonseca 8: Co. (Corporations Nevada) Subject: FOLLOWUP IRIS STOCK OF 2006 NEVADA SHELF COMPANIES 1256298 (Er/iv) Dear Iris, Your suggestion seems perfect. Incorporate 2 by Apostille and one by Uruguay. We I be sending the aforementioned companies in the next courier. Regards, Odile -?-Original Message-w- From: Mossack Fonseca Co. (Corporations Nevada) Sent: Tuesday, January 10,2006 7:33 PM To: Mossack Fonseca Co. (Uruguay) Subject: STOCK OF 2006 NEVADA SHELF COMPANIES 1256298 (ET/iv) Dear Odile: In reference to the foregoing exchange: Thank you for your comments with regard to Nevada. If you agree, we would appreciate it if you would confirm the names you prefer so that we may go ahead and verify them. In this case we wi proceed with the incorporation of: a) One LLC legalized by Apost b) The other with copies ofthe documents legalized by the Uruguayan Consulate as we have been doing. As you will note, the stock approved for Uruguay is 3 LLCs. According to our records, the following LCCs, GROUP LLC and OLDEMAR TRADING LLC, which were legalized pursuant to option were not sold, and therefore we suggest that the stock be varied for 2006, in other words: two (2) legalized by Apostille, option and one using option with copies of the documents legalized by the Uruguayan Consulate since, as you will understand, the legalization expenses are non-recoverable for each LLC that is not sold with those characteristics. At this time I would also ask you to return to us the two aforementioned LLCs, 1/1 2/2006 TRANSLATION MFCS 006488 STOCK OF 2006 NEVADA SHELF COMPANIES 1256298 (ET/iv) Page 3 of 4 and I await your instructions on the stock for 2006. Cordial regards, Iris Vergara MOSSACK FONSECA C0. E-mail nevada- anamaof?fice mossfon.com General e-mail: MF@mossfon.com From: Mossack Fonseca Co. (Corporations Nevada) Sent: Monday, December 5, 2005 11:27 AM To: Mossack Fonseca Co. (Uruguay) Subject: STOCK OF 2006 NEVADA SHELF COMPANIES 1256298 (ET/yp/cw) Dear Odil In reference to our November 7, 2005 message: In this regard, we would appreciate it if you would confirm whether you agree with the number of companies to be incorporated in the jurisdictions of Nevada, Bahamas, Uruguay, Samoa, Seychelles and Panama for 2006. We look forward to your comments and your suggestions for names in order to proceed to search for availability. Regards, Mirzella Tu??n Companies Department Our of?ce in Panama will be closed on Thursday, December 8, 2005. We will resume work on Friday, December 9, 2005 according to our usual schedule. From: Mossack Fonseca Co. (Corporations - BVI) Sent: Monday, November 7, 2005 4:46 AM To: Mossack Fonseca Co. (Uruguay) Subject: STOCK OF 2006 BVI SHELF COMPANIES - 1256298 (ET/yp/cw) Dear Odile: As we do each year, we are organizing the incorporation of reserves 1/ 12/ 2006 TRANSLATION MFCS 006489 Document 100-3 Filed 03/16/15 Page 194 of 217 Case 2 Document 90-4 Filed 03/03/15 Page 39 of 62 Case 2 STOCK OF 2006 NEVADA SHELF COMPANIES 1256298 (ET/iv) Page 4 of 4 [Logo] for our various jurisdictions. We are pleased to inform you that the Partners have approved the following stock for your office for 2006, as listed below: JURISDICTION STOCK APPROVED STOCK FOR THE BEGINNING OF THE YEAR SAMOA 1 1 BAHAMAS 1 1 SECHELLES [sic] 2 1 PANAMA 20 12 NEVADA 3 2 URUGUAY 3 2 We would appreciate it if you would con?rm whether the stock approved for this year suits your needs. Othenuise, we would appreciate receiving your suggestions in order to evaluate them. We remind you that each reserve represents an investment for Mossack Fonseca therefore, we are trying to limit the number of reserves to be incorporated. If you are in agreement with the stock approved and have available the names of the companies to be incorporated, please contact the appropriate of?ce directly so that they may verify whether the desired names are available for incorporation. We look forwards to your instructions. Best regards, Edison Teano Tel.: (507) 263-8899, 264-2322 Fax: (507) 263-7327 email: bahamas- anamaof?ce mossfon.com 1/12/2006 MFCS 006490 EXHIBIT 25 Case Document 100-3 Filed 03/16/15 Page 195 of 217 Case Document 90-4 Filed 03/03/15 Page 40 of 62 FW: PANAMANIAN COMPANIES (12477/ET/m1v) VERY URGENT Page 5 of 5 companies listed below are reserved for you until November 18, 2004. ALANSVILLE OVERSEAS S.A. incorporated on November 19, 2003 RALEIGH ENTERPRISES INC. incorporated on November 20, 2003 The cost to acquire each one of these companies is We look forward to your comments/instructions on this matter. Best regards, Mayka Villarreal Verna Lee de Nelson COMPANIES DEPARTMENT From: Morelia Jaspe - Venezuela Rep. Office Sent: Saturday, November 13, 2004 4:13 AM To: Corporations (Panama) Subject: F.A. SD PANAMANIAN COMPANIES Importance: High Dear Verna: Please, we urgently need two Panamanian companies from the year 2003, a client needs them with the utmost urgency. Thank you very much, Morelia aspe Mossfon de Venezuela C.A. EXHIBIT :2 ,5 WITNESS My DATE Ellen A. ldstein, 82 11/18/2004 TRANSLATION MFCS 005025 I LU Document 100-3 Filed 03/16/15 Page 196 of 217 Case 2 Document 90-4 Filed 03/03/15 Page 41 of 62 Case 2 Pagel of] Hf corp From: Mosaack Fanseca Co. c" - Nevada) mm] Son: Tuesday. June 10. 2008 12:58 PM To: MF CorpServ (Nevada) Ltd. Co: Massack Fonaom 8. Co. (Peru Representative) Subject: IZALCO TRADING LLCI m15?13?5 A?aohmonb: IZALOO TRADING pedandoq IZALCO TRADING roa.doc Dear Patricia: I?m attaching the power of attorney and the resolution. Please proceed in accordance with the instructions from our of?ce in Peru following standard procedure. Please refer to the case for dispatching instructions. Regards, Vargara Corporations MOSSACK FONSECA . am. ?In sum. "alt-"l P.o. Bax 0332-0886. W.T.C. Panama Panama. Ropuhn: u! Pan-m i 501 new 501 263?7327 Wm From: Hassock Form 5C0. (Peru We) Saul: lesday, June 05, 2008 To: IZALCO IRADING LLC Dear Sirs, We require the following for this company: 1 Original power of attorney in Spanish, duly in the name of MARCO ANDRES AVILA RODAS, Ecuadorian, holder of citizenship card 010218380-3. Copy the model power of attorney utilized for WESTMINE MANAGEMENT. 2 - certi?cate of good standing. BEFORE PROCEEDING WITH THE ORIGINAL, PLEASE SEND THE FINAL DRAFT SO THAT THE CLIENT CAN GIVE FINAL OK. Best regards, Susana Kam WITNESS 6/10/2008 DATE Ellen A. Goldstein, CCR 829 TRANSLATION MFCS 004533 credit; open and/or close bank accounts, whether checking accounts, savings accounts and, generally, all types of accounts legally permitted in banking, financial or insurance institutions in the country, state or sovereign territory in which this power of attorney is exercised; make fixed-term or indefinite deposits, pledge or deposit securities in custody and withdraw them as many times as necessary, open safe deposit boxes and manage them without any limitation or restriction whatsoever, issue checks drawn on checking accounts belonging to the LLC, on either debit or credit balances, cash and endorse Checks issued on behalf of the LLC, enter into loan agreements on the checking account with or without specific guarantees, establish mortgages or pledges of any kind by setting the terms and conditions, order payments and charges debited to the applicable accounts of the LLC, post bonds with or without the assets of the LLC as collateral. And generally exercise the broadest and fullest representation of the LLC before banks, financial institutions and insurance companies without the slightest restriction or limit, as well as perform all those commercial, financial and banking operations that the aforementioned financial intermediaries may perform with their clients in accordance with the laws regulating them on the basis of the territory in which this Power of Attorney is being exercised (in Peru: the Ley General de Instituciones Bancarias, financieras de Seguros [General Law of Banking, Financial and Insurance Institutions], together with their regulatory, supplementary, amending and related standards) and the pertinent provisions of the public body or bodies entrusted with supervising the aforementioned financial intermediaries (the Superintendencia de Banca 3/ Seguros [Superintendency of Banking and Securities and/or the Banco Central de Reserva [Central Reserve Bank in Peru); exercise all those commercial and financial powers that are compatible with the authority and powers received and with legal provisions, as well as comply with those responsibilities individually conferred by the constituent company by granting special powers in his/her favor. SEVEN: Carry out all administrative formalities and/or procedures necessary to request and obtain the TRANSLATION MFG 004525 Document 100-3 Filed 03/16/15 Page 197 of 217 Case 2 14-CV-OO492-RFB-VCF Document 90-4 Filed 03/03/15 Page 42 of 62 Case 2 share capital, member shares, bonds, coupons, mortgages, obligations, securities, promissory notes, payment orders, acceptances, bills of exchange and evidence of debt issued or created by other corporations, limited companies or associations, whether public, private, municipal or of any corporate entity or issued by any state, province, municipality, city or political subdivision of the countries in which the present power of attorney is enforceable. FIVE: Enter into all types of company or association agreements on behalf and in representation of the LLC granting the present Power of Attorney, as well as constitute any type of legal entity, and also participate as a shareholder or partner in those already in existence. Represent the LLC before those executive and/or administrative bodies of legal entities of any type or nature, such as, but not limited to, General Shareholders? Meetings (ordinary and/or special, obligatory or voluntary, general or universal), General Partners' Meetings, Partners? Meetings, Boards of Directors, etc. Therefore, by these presents the LLC authorizes the Designated Agent to exercise on its behalf and representation all those rights, powers and privileges of ownership, including the right to vote, challenge, waive rights and exercise any other rights that may be applicable, with respect to any shares, bonds and/or securities owned or held by the LLC, and may to this end personally exercise the right to vote inherent in those securities. In addition, he/she may serve as director and/or officer in any corporation or company in which the LLC has an interest. Contribute money and assets owned by the LLC in the event of increases in capital or the constitution of companies or other types of legal entities, with sufficient authority and powers to act as signatory on behalf and in representation of the LLC granting this Power of Attorney on all those private and public documents required for that purpose. SIX: Accept, issue, guarantee, endorse and deduct bills of exchange, vouchers, promissory notes and any other credit instrument or mortgage TRANSLATION MFCS 004526 documents, encumbrances and/or liens; encumber, exchange, bail, loan or use, pledge or mortgage any personal property or real estate that may belong to or be owned by the LLC now or in the future, of any type or nature, whether in cash or by installments, agreeing on the conditions of payment and any other clauses and conditions as they see fit. With respect to the real estate that may be owned by the LLC now or in the future, it is clearly established in these presents that the Designated Agent is expressly empowered to take all steps and carry out all formalities and/or procedures that are required and are necessary to regularize all demolitions, constructions, building, modifications and/or extensions that have been carried out, or may in the future be carried out on the aforementioned properties, at municipal and/or registry level. For these purposes, the Designated Agent enjoys the fullest powers tO'submit all requests and/or forms required before the competent bureaus, directorates and/or agencies of local government and/or the competent Public Registry Offices, and, generally, to carry out all kinds of formalities, actions and/or procedures before the competent municipal and/or registry authorities that are necessary to regularize the situation of the aforementioned properties and, with respect to these, to empower him/her to be a signatory and/or sign all documents that are necessary to ensure that the aforementioned formalities, actions and/or procedures conclude in a manner satisfactory to the interests of the LLC. THREE: Lease or sublease assets on behalf of the LLC, and/or lease or sublease assets belonging to the LLC, for a fixed or indefinite term, and, should it be necessary, evict (dispossess) lessees, and settle or request the settlement of any lease agreements that may been entered into. FOUR: Buy and sell all types of assets and rights on behalf of the LLC, in public auctions, whether by court order or otherwise, on exchanges of any type, for those prices and under the terms and conditions that he/she deems appropriate, being authorized to sell, acquire, purchase in that way or in any other the TRANSLATION MFCS 004527 Case Document 100-3 Filed 03/16/15 Page 198 of 217 Case Document 90-4 Filed 03/03/15 Page 43 of 62 The LLC authorizes and empowers the Designated Agent in order that this Power of Attorney be acknowledged in his/her name and as an act and instrument of the LLC and in order that it may be entered and registered in the appropriate office and registry and so that he/she may secure the fulfillment of any other act or item of any kind that may be required or necessary to authenticate and give full effect to this Power of Attorney as fully and as effectively as would the LLC itself. Dated June 10, 2008. Signed by [signature] Patricia Veronica Amtmategui Deputy Secretary On behalf of ALDYNE LTD. Administrator STATE OF NEVADA SS COUNTY OF CLARK On this 10th day of June 2008, before me the undersigned, a Notary Public in and for .eaid County and state, personally appeared Patricia Veronica Amunategui, known to me or proved to me to he the person described in and who executed the foregoing instrument Who acknowledged to me that she executed the same freely and voluntarily and for the purpose therein mentioned. KATIE VESCO Notary Public in and for said County and state TRANSLATION MFCS 004528 APOSTILLE (Convention de La Hay: du 5 ocmbre 1961) 1. Country United States of America This public document 2. has been signed by KATIE VESCO 3. acting 'm the capacity of NOTARY PUBLIC STATE OF NEVADA 4. has the seal/stamp of KATIE VESCO CERTIFIED 5. at Carson City, Nevada, USA. 6. the TWELFTH DAY OF JUNE, 2008 7. by Ross Miller, Summary ofState, Slate of Nevada, U.S.A. 8. Number 110738 Ross Miller Secretary of sum TRANSLATION MFCS 004529 Case Document 100-3 Filed 03/16/15 Page 199 of 217 Case Document 90-4 Filed 03/03/15 Page 44 of 62 In accordance with Article 6 of the Operating Agreement of IZALCO TRADING LLC (the RESOLUTION OF THE ADMINISTRATOR OF IZALCO TRADING LLC Limited Liability Company of Nevada the undersigned, ALDYNE LTD., being the sole administrator of the LLC, by these presents resolves as follows: 1. 2. To hereby grant a Power of Attorney in favor of MARCO ANDRES AVILA RODAS, Ecuadorian, identi?ed by Ecuadorian ci?zenship card 010218380-3. To hereby authorize Patricia Amunategui, Deputy Secretary of ALDYNE LTD., Administrator of the LLC, so that on its behalf she may grant the aforementioned power of attorney in favor of MARCO ANDRES AVILA RODAS, Ecuadorian, identi?ed by Ecuadorian citizenship card 010218380-3. Signed this tenth day of Jime, 2008. On behalf of LTD. Administrator [signature] PATRICIA AMUNATEGUI Deputy Secretary TRANSLATION MFCS 004530 TA CERTIFICATE OF EXISTENCE WITH STATUS IN GOOD STANDING l. ROSS MILLER. the duly aimed and quali?ed Nevada Secretary of Suite. do hereby earm'fy non-pro?t sob. limited-[ilein mmanimJimited IN WITNESS WHEREOF, Ihave hermit: set my of?ce on June 16. 2008. ROSS MILLER Summary (?5121; catianCletk ., . . .. TRANSLATION MFCS 004531 Case Document 100-3 Filed 03/16/15 Page 200 of 217 Case Document 90-4 Filed 03/03/15 Page 45 of 62 9F . . APOSTILLE (Convention de La Hana du 5 octobre 1961) 1. Country: UnitedStm ofAma-iur This public document 21ml 3. acting in the atrocity of CLERK 4. beats seal/stump of STATE OF NEVADA CERTIFIED 5.21 City, Nevada, ELSA. 6. the SIXTEENTH DAY OF JUNE, 2008 7. by ROSS MILLER, Secretary amele, Slate afNevada. USA. 8. 10. Signature: sec RETAIFY STA T15 TRANSLATION MFCS 004532 Page 1 of 1 If corp From: Mossack Fonseca Co. - Nevada) 1.. Sam: Tuesday. June 10. 2008 1258 PM To: MF CorpServ (Nevada) Ltd. Mossack Fonseca Co. (Peru Representative) Subject TRADING LLCI Oaso1561895 Athohmonts: IZALCO TRADING poder.dac; IZALCO TRADING rea.doc Dear Patricia: l?m attaching the power of attorney and the resolution. Please proceed in accordance with the instructions from our of?ce in Peru following standard procedure. Please refer to the case for dispatching instructions. Regards, Iris Val-gen Corporation: MOSSACK FONSECA From: Fonseaa at C0. (Peru Repraenlz?ve) Slant: Thumby, June 05, 21308 11:18 AM To: Massack Fvnsem Co. (Corporations- Nevada) Subject IZALCO TRADING LLC Dear Sirs, We require the following for this company: 1 - Original power of attorney in Spanish, duly APOSTILLED in the name of MARCO ANDRES AVILA I RODAS, Ecuadorian, holder of citizenship card 010218380-3. Copy the model power of attorney utilized for WESTMINE MANAGEMENT. 2 - APOSTILLED certi?cate of good standing. BEFORE PROCEEDING WITH THE ORIGINAL, PLEASE SEND THE FINAL DRAFT SO THAT THE CLIENT CAN FINAL OK. Best regards, Susana Kam 6/10/2008 TRANSLATION MFCS 004533 Document 100-3 Filed 03/16/15 Page 201 of 217 Case 2 Document 90-4 Filed 03/03/15 Page 46 of 62 Case 2 TRANSLATION MFCS 004534 fiv/oo Page 1 of 2 corp From: Moesack Fonseca 8. Co. (Corporations - Nevada) [neveda?panamaol?oembnnom] Sent: Monday. February 19, 2007 6:54 AM To: Patricia Amunategul - MF CarpServ (Nevada) Co: Mosadc Fonsem a. (Peru Representative) Subject: IZALCO TRADING Attachment: A?idavit Spanishdoc. English- Spanish resolution for issuance of the POAdoc; POder SPAdoo Dear Patricia: This is in connection with the instructions from our of?ces in Peru. Please proceed with the attached instructions. Please organize this as necessary together with the requested Certi?cate of Good Standing. <> <> <> POA.doc] Please don't hesitate to contact us with any questions or queries. Regards Oneleaa Oeorlo Corpora?om Mouton Building 54:11 and. Morbella PO. Box 0832-0386. Panama Panama. Rapublc of Pmma 507 205-5355 501 253-9213 8 mm Egg/mu.anme From: Monica Ycaza - Peru Representative Of?ce Sent: Monday, February 19, 2007 12:08 am. To: Patricia Amunategui - MF CorpServ (Nevada) Cc: Mossack Fonseca Co. (Corporations - Nevada); Mossack Fonseca 81 Co. [Peru Representative) Subject: IZALCO POWER OF ATTORNEY Dear Patricia and Iris, The client has approved the model power of attorney; only one small correction has been made to the enclosed model (highlighted in red), to the name and number of the documents. Please go ahead and issue it. 12/20/2007 TRANSLATION MFCS 004535 Document 100-3 Filed 03/16/15 Page 202 of 217 Case 2 Document 90-4 Filed 03/03/15 Page 47 of 62 Case 2 This power of attorney must be legalized by the Peruvian Consulate along with a certificate of good standing for the company, since it will be registered with the Peruvian RRPP [Registro de Partes Registry of Certi?cates]. It should also be accompanied by the af?davit we normally use in these cases. Many thanks for your help! Hugs, Mo'nica de Ycaza MOSSFON PERU 2/20/2007 TRANSLATION MFCS 004536 Page I of 1 ll! corp From: Monica da Ycaza [deycaza@mossfon.oom] 50m: Sunday, February 18. 2007 9:08 PM To: NEVADA Corporate Services Cc: Nwada-Pammo?oaQMossfonmnu PeruQmossioncom Subject: POWER OF ATTORNEY Attachments: BORRADOR PODER IZALCO [draft power of attorney] feb 07.doc Dear Patricia and Iris, The client has approved the model power of attorney; only one small correction has been made to the enclosed model (highlighted in red), to the name and number of the documents. Please go ahead and issue it. This power of attorney must be legalized by the Penrvian Consulate along with a certi?cate of good standing for the company, since it will be registered with the Peruvian RRPP [Registro de Partes Registry of Certi?cates]. it should also be accompanied by the affidavit we normally use in these cases. Many thanks for your help! Hugs Monica cle Ycaza MOSSFON PERU 2/20/2007 TRANSLATION MFCS 004537 Case Document 100-3 Filed 03/16/15 Page 203 of 217 Case Document 90-4 Filed 03/03/15 Page 48 of 62 Name Ream-Various Page 1 of1 corp From: carpal-stemminmm sum: Monday, October ZS. 2008 7:52 AM To: ambled: Mossack Fonseca Co. [Name Resetva?ons INCORPORATION OF NEVADA SHELF COMPANIES Please check the avalabilny of he following name(a) and than update the thrmaIIon received ma (Mme ,Intha'SheIfl? IZALCO TRADING Thank you. Yours Sincerely. I?l Vorgan Moss-cu Form.? In Co. (Plum) 10/25/2006 TRANSLATION MFCS 004538 n?nu Inc. I -- Document 100-3 Filed 03/16/15 Page 204 of 217 Case 2 Document 90-4 Filed 03/03/15 Page 49 of 62 Case 2 an: - COSMETECH LC Page 1 of 2 Mf corp From: Susana Kam - MOSSFON PERU [peru@mossfon.com] Sent: Wednesday, April 5, 2006 10:37 AM To: 'Mf corp'; 'Mossack Fonseca Co. [Corporations Nevada)? Subled: COSMETECH LC Dear lris, The client has con?rmed he wants the company, please move forward with the incorporation. - The company will have a capital of 500,000. - The member and the manager will be assigned by MOSSFON. - issue 5 certificates divided in equal parts. Best Regards, Susa a Kam ?-?-0riginal Message??- From: Mf corp Sent: Wednesday, April 5, 2006 12:19 PM To: 'Mossack Fonseca Co. (Corporations - Nevada)? CC: 'Mossack Fonseca Co. (Peru Representative)? Subject: RE: COSMETECH LC Dear I am con?rming that the name COSMETECH LC is still available. Kind Regards Pad/Tibial Amid-{z From: Mossack Fonseca Co. (Corporations- Nevada) Sent: Wednesday, April 5, 2005 9:46 AM To: Patricia Amunategui -MF CorpServ (Nevada) Cc: Mossack Fonseca Co. (Peru Representative) Subject: COSMETECH LC Dear Patricia: I would appreciate ifyou can confirm that the name COSMETECH LC is still available in Nevada. Please refer to case 1314907. Regards, IrisVergara WEXHIBIT WITNESS 0? DATE 5 Ellen A. 4/5/2006 TRANSLATION MFG 001932 Case Document 100-3 Filed 03/16/15 Page 205 of 217 Case Document 90-4 Filed 03/03/15 Page 50 of 62 A, at" 4ND INTERNATIONAL LLC Page I of 2 Mfcorp From: Moscack Fonseca Co. (Corporations Nevada) 89M: Thursday, September 29. 2005 8:03 AM To: Amunategul - MF CorpServ (Nevada) Subloct: FAIRLAND INTERNATIONAL Patricia: See below the email received from Dr. De Grandi. Please ?nd out and let us know the requirements and the cost for obtaining a license plate in the state of Nevada. The owner of the car will be the LLC. Once you have obtained that information, please send it directly to our of?ce in Panama. Regards. Mayka Villarreal COMPANIES DEPARTMENT From: Andrea De Grandi - Mossfon Lugano Sent: Thursday, September 29, 2005 5:34 am. Wu mum mum. macs-an moan-u rev FAIRLAND INTERNATIONAL LLC 12039: 014mm Luna-o4 ACT Inn Palm: also: on Amen-n luau-d FERGUS INTERNAUONAL. SA Manger mm Hul- mull u??l?l Huh Illa-d nil-MW HILLARD SA. 100 1 07-04-2004 In n-mm- Wy- su- Dll'illun Duhth Enlth Mumb- Medan GMNPIRO ms MENU Gm POA Tampa-y 36 M2007 Dear Nevada dept. regarding the above company the customer is asking if it is to get a USA-NEIADA-LAS VEGAS plain or a El?. The ownership of this ar will be of the above Falrland. Pls. hform: If we are able to provlde this service terms-commandime for the servlee. 9/29/2005 EXHIBIT I oldstein, Ellen A. TRANSLATION MFCS 002842 Case Document 100-3 Filed 03/16/15 Page 206 of 217 Case Document 90-4 Filed 03/03/15 Page 51 of 62 oue?m ?Pug-'9 50 ma?a: ma 0T1 We 878300 2.102413% uz Case Document 100-3 Filed 03/16/15 Page 207 of 217 Case Document 90-4 Filed 03/03/15 Page 52 of 62 June 5,2013 To the Board of Directors of ALDYNE LTD. Dear Sirs, I, PATRICIA AMUNATEGUI, hereby resign as ASSISTANT SECRETARY of ALDYNE LTD. This resignation shall be effective at the end of the board meeting in which it is accepted. Yours sincerely, PATRICIA AMUNATEGUI Assistant Secretary MEXHIBITLZ- WITNESS DATE Ellen A. Goldstein, 829 a EATIIDI 00 Case Document 100-3 Filed 03/16/15 Page 208 of 217 Case Document 90-4 Filed 03/03/15 Page 53 of 62 June 5,2013 To the Board of Directors of FERGUS INTERNATIONAL S.A Dear Sirs, I, PATRICIA AMUNATEGUI, hereby resign as ASSISTANT SECRETARY of FERGUS INTERNATIONAL S.A This resignation shall be effective at the end of the board meeting in which it is accepted. Yours sincerely, PATRICIA AMUNATEGUI Assistant Secretary Ll Ellen A. Go dstein, CCR 829 I Document 100-3 Filed 03/16/15 Page 209 of 217 Case 2 Case 2 Document 90-4 Filed 03/03/15 Page 54 of 62 June 5. 2013 To the Board of Directors of PLASCOT LIMI I ED Dear Sirs. I, PATRICIA AMUNATEGUI. hereby resign as ASSISTANT SECRETARY of PLASCOT LIMI I ED. This resignation shall be effective at the end of the board meeting in which it is accepted. Yours sincerely, . PATRICIA AMUNATEGUI Assistant Secretary EXHIBIT WI TNESS DATE 1 Ellen A. 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