FILED: NEW YORK COUNTY CLERK 06/14/2018 11:10 AM NYSCEF DOC. NO. 10 INDEX NO. 451130/2018 RECEIVED NYSCEF: 06/14/2018 INDEX NO. 451130/2018 FILED: NEW YORK COUNTY CLERK 06/14/2018 11:10 AM NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 06/14/2018 Page 1 1 2 STATE OFFICE 3 ERIC NEW OF OF YORK ATTORNEY THE GENERAL SCHNEIDERMAN T. ----------------------------------------x 4 IN MATTER THE DONALD OF TRUMP J. INVESTIGATION THE OF INC. FOUNDATION, 5 ----------------------------------------x 6 October 10:14 7 2017 4, a.m. 8 9 CONFIDENTIAL 10 EXAMINATION 11 WEISSELBERG, held 12 State of 13 120 14 10271, 15 Professional 16 State Office at the before Anthony New of The York, a Giarro, and a Notary New York located General, New Floor, Reporter of offices Attorney 3rd Broadway, the ALLEN of New at York Registered Public of the York. 17 18 19 20 21 22 23 24 25 Veritext 212-267-6868 Legal Solutions wvvw.veritext.corn 516-608-2400 INDEX NO. 451130/2018 FILED: NEW YORK COUNTY CLERK 06/14/2018 11:10 AM NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 06/14/2018 Page ALLEN 1 2 3 with 4 operation 5 Foundation? Mr. 7 you that the very 12 occasional 13 would 14 issued. 15 the 16 than be was and a That was really doing. on a an there, contribution a check would the be extent wasn't There was it ago, for mean? anything going made operation. you do years request When clarify? Foundation operation of much more that. 17 So 18 conversation 19 being issued, 20 check being 21 22 either 23 any 24 Foundation 25 A sent Did in the of a making grants recall don't I beyond Q check a having just maybe a signed being check and a out. ever you play decision a that any or the role discussing Trump made? No. Veritext 212-267-6868 you Trump broadly, Well, simple 11 can mean Trump A 10 J. what I the concerning "operation," Q discussing Donald Sir, say 8 9 the A 6 recall anything Trump of WEISSELBERG you Do Q 13 Legal www.veritext.corn Solutions 516-608-2400 INDEX NO. 451130/2018 FILED: NEW YORK COUNTY CLERK 06/14/2018 11:10 AM NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 06/14/2018 Page 2 Char 500s? 3 4 Char I Q So was did not review them here, at 11 after 12 you you cover A Sign Q Did all with he received it? return the That it. And 15 that 16 least 17 did it's 18 board 19 Foundation? your for did is last before around the or time testimony that or 10 directors I 21 Q During 15 did the that you the board did not. 24 A I 25 Q Aside at you years, were on the Trump not. years, of 15 you of A or your it that 20 meeting either understanding the of 10 return the not. understand not discuss it? Q from Veritext 212-267-6868 sign but it 14 any page, you signed I 23 at Trump, A last look and Mr. 13 22 would it. 9 10 the 500, 7 8 A no. 5 6 WEISSELBERG ALLEN 1 23 Legal www.veritext.corn time did of whether the period, not attend directors? you Solutions 516-608-2400 INDEX NO. 451130/2018 FILED: NEW YORK COUNTY CLERK 06/14/2018 11:10 AM NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 06/14/2018 Page 2 attended 3 that. or your To 5 board 6 Foundation 8 we' re 9 It isn't Well, all 10 around 11 for 12 discussions 13 there for 14 could have the 15 the A I 20 Q Do been have may But or wasn' wasn't I But -- not not, Okay. did I whether it the you 23 Q During they just -- not attend. to know. know. who know the Foundation Trump Currently? you asking you not do A who together come they I'm 22 know office. scattered there Yeah. of corporate informal. been 19 directors -- informal discussions. Q the past are? 15 years, do were? based Well, Veritext 212-267-6868 an all whether A was and those 18 ' it people. of A you Trump And 17 24 the they're meeting. speculate 21 did of same country Q 16 the in like a strike meet? A 7 -- if knowledge, directors of know you do not, 4 25 WEISSELBERG ALLEN 1 2 4 Legal www.veritext.corn on the first Solutions 516-608-2400 INDEX NO. 451130/2018 FILED: NEW YORK COUNTY CLERK 06/14/2018 11:10 AM NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 06/14/2018 Page ALLEN 1 3 showed 4 different 5 about 6 whether 7 2013. 8 to him a After But arguments 11 the 12 knowledge. 13' 13 facts 14 what 15 are 17 he a let's witness our get went I into facts. And as from his to talk are arguments about the later and those facts later. Was Rhona succeeded Graff? Do the Foerderer Ms. Q you know board if directors of Graff Ms. was the of Foundation? 22 A I 23 Q Do 24 discussing 25 children with whether believe don't you recall Mr. Trump or not VeritextLegal 212-267-6868 a in only can they 19 Trump not the we what Correct. 21 along, testify And and Ms. on all not will A ever him recall, over 18 20 asking didn't here Q by was director a for document. 9 10 I was 2013 in directorship he I Actually, document the reason. that 16 WEISSELBERG SHIFFMAN: MR. 2 29 www.veritext.corn so. ever or the any of his Trump Solutions 516-608-2400 INDEX NO. 451130/2018 FILED: NEW YORK COUNTY CLERK 06/14/2018 11:10 AM NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 06/14/2018 Page WEISSELBERG ALLEN 1 2 Foundation 3 veterans' 4 January fundraiser A know. 7 in 8 issue 9 morning There got that 11 actually 12 to 13 able to 14 was going 15 anywhere 16 anything. 17 could have a 18 write some checks 19 somebody 20 should 21 to 22 McConney 23 he 24 checkbook. 25 Moines, have to dental a and And go. I So go. had on said sure. So And I I that we have to thought grabbed we might like Jeff asked with go to later, -- of may you'd And he I why department thought like be gone night. accounting he'd had to know possible We okay. order kind any that I I I never it's our evening. to fundraiser. from late I in wanted I said He if it Donald with some appointment. Iowa. to was that through get was it that do I possibility Iowa to what there call a go had I phone me. And the flew to Des Iowa. Veritext 212-267-6868 in think I And there's might said held you time. a a 10 rush was tell 2016. of I can I was January go. that So -- the in 2016? of 5 6 participate would 30 Legal Solutions vvvvvv.veritext.corn 516-608-2400 INDEX NO. 451130/2018 FILED: NEW YORK COUNTY CLERK 06/14/2018 11:10 AM NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 06/14/2018 Pagre ALLEN 1 2 3 about? 4 fundraiser? Is same 6 phone you talking the of day happened all It And call 10 that who from that A I Q Was A Again, don't did you you just receive the described? recall. from it Mr. Trump himself? 11 12 13 could 14 I been have just don't ' from recall. through Rhona Could the don't I It Trump. Mr. recall. Q 17 18 same Yes. Q 9 16 are day. 7 8 WEISSELBERG day the it A 5 15 What Q 31 been have it somebody campaign? Trump A Could Q What have been. don't I recall. 19 told 20 being 21 checkbook? A 22 23 checks 24 reason, 25 us, that we in case about the If there had should there recall need to was be to was the bring be to for any money any some checkbook a Legal about going issued have Veritext 212-267-6868 you do with being Solutions wvvw.veritext.corn 516-608-2400 INDEX NO. 451130/2018 FILED: NEW YORK COUNTY CLERK 06/14/2018 11:10 AM NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 06/14/2018 Page ALLEN 1 2 collected, 3 doesn't 4 boss. which matter what was Mr. 7 request, whether 8 relaying the Trump it He's my one told instigated who he not or request to A Sorry. Say Q I that was this one the you? that one more time. 10 11 ' could was Mr. 14 request, 15 communicating 16 fair Trump the even the A I 18 from. It 19 don't know. 20 something 21 that 23 If clerk have not the making person the to that is you; way, I wanted been anybody. me think to I why said you I me Legal www.veritext.corn guess to it my boss. go. want to at to. asked would didn't telling I he's I go, was it answer the reason Yeah. somewhere where know don't me know asking Veritext 212-267-6868 was request The A 24 was You're I he who don't could Q 22 he that understanding one if it. say? to 17 rephrase your It's 13 25 were the 6 12 thought. I you So Q 9 -- was went. I 5 WEISSELBERG thought I 32 go some to Iowa 1 Solutions 516-608-2400 INDEX NO. 451130/2018 FILED: NEW YORK COUNTY CLERK 06/14/2018 11:10 AM NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 06/14/2018 Page ALLEN 1 2 3 A I don't one recall, going 6 actually 7 or way 10 went re that to preparing was it not. aside first out go day was the only day. Q It was the only day -- the to It that you Iowa? 12 A Correct. 13 Q But 14 aside what 15' 15 there, did 16 Foundation 17 the 18 funds you heard was at 21 to -- 22 in trying 23 another individual 24 receive contributions 25 veteran groups. to you be involved that the in of recall. is though, think tell day fundraiser? don't recall, first distribution the the 20 I to Putting that ever or I is: on going fundraiser raised question my anybody A Jeff What was trying McConney was involved Web a site order in that And I believe Legal www.veritext.corn do I somebody create Veritext 212-267-6868 or was if A to 19 know happen to assumed I didn't Putting you' 9 what I going Q when recall happen. to 5 11 You WEISSELBERG another? 4 8 Q 35 with to be would able go to to the Solutions 516-608-2400 INDEX NO. 451130/2018 FILED: NEW YORK COUNTY CLERK 06/14/2018 11:10 AM NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 06/14/2018 Page ALLEN 1 2 Foundation 3 mentioned 4 Mr. 6 individual A 7 8 the 9 recall were we which 10 after the A Correct. 13 Q Do A 15 begins 17 like 18 spelling Iowa. to I don't recall if was it fundraiser? you recall who he was -- that. Brad don't I his of the fellow, last Pascal or recall the name something exact name. Q And he was A Independent Q Do independent an contractor, yeah. 23 24 been contractor? 21 22 A with 19 20 have with? working 16 site? couldn't don't 12 14 Web flying You or another one. Q before with it Well, time when the up and site. working set to used recall you was be to Web Do McConney WEISSELBERG going that in Q 5 11 was 36 Mr. Pascal A 25 you his or I know retained company? don't. Veritext 212-267-6868 who Legal www.veritext.corn Solutions 516-608-2400 INDEX NO. 451130/2018 FILED: NEW YORK COUNTY CLERK 06/14/2018 11:10 AM NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 06/14/2018 Page 2 Mr. Q 3 A Correct. 5 Q Did to work the on A 7 the person 9 Web site, 10 did 12 actually 13 you -- on him you started to Q As A I wanted 19 going 20 been 21 Iowa, 22 we knew 23 it happened. to do upon it we exact you as can time recall. I because So return it knew that to now we have may from we knew be a had started thing Legal www.veritext.corn he was it immediately going when that? recall. Veritext 212-267-6868 an fast. So this want do knew you recall that? quickly was you on don't it the once get the he work best happen to 24 and with when when do it, to Do 18 25 work recall aside worked we 17 site? create to you do putting A 1 Web to going McConney the of Well, was And assigned when Mr. yes. that 14 assign did. who Q 11 you creation I 8 15 to right? you; 6 reported McConney 4 16 WEISSELBERG ALLEN 1 37 -- once fundraiser, to get going so the money Solutions 516-608-2400 INDEX NO. 451130/2018 FILED: NEW YORK COUNTY CLERK 06/14/2018 11:10 AM NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 06/14/2018 Page 2 A I 3 Q Did 4 ~ you were didn't. needed Nope. 6 Q Did 9 to assist site with 11 what did 12 to this you you role in asked Mr. preparation tell McConney the of Mr. him the -- second. a contractor, Web Pascal, Web site needed have? 13 A I 14 Q Did 15 should 16 Foundation 17 A get all at 19 individual 20 ground. 21 you him tell anything. him from gave I who he the on Trump the And needed I 24 recall who 25 needed in told order Web how did be to was Veritext this site off know that Legal www.veritext.corn the that a up? that. have to with you set told him, instructions no work to get to site him than A 23 tell side? Q Web didn't information other 18 212-267-6868 any back you the in play go When 10' 10 22 you I'll that. 8 tell there? A strike ever anybody 5 7 WEISSELBERG ALLEN 1 39 I a the site money don't was flow Solutions 516-608-2400 INDEX NO. 451130/2018 FILED: NEW YORK COUNTY CLERK 06/14/2018 11:10 AM NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 06/14/2018 Page 2 through it. 3 4 You Q you A I 6 Q Do 7 organization, 8 that you Q 12 you needed 13 you don't who told you you repeat with? I'm sorry. Can So somebody told get to recall who Correct. 15 Q Do 16 who told 17 Trump 18 campaign you that recall Q Do up and person the if affiliated was with the the Trump else? something I set that was? with A you site it you Organization, or Web a A don't. I don't recall that. 21 Mr. Trump A 23 24 which person 14 22 told question? 11 20 recall affiliated A 19 who don't. the was 9 the recall don't that? 5 10 WEISSELBERG ALLEN 1 40 Mr. 25 you recall Donald himself, No. was Trump? was It it not definitely Trump. Q So was it Veritext 212-267-6868 if somebody Legal www.veritext.corn working Solutions 516-608-2400 ††INDEX NO. 451130/2018 FILED: NEW YORK COUNTY CLERK 06/14/2018 11:10 AM NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 06/14/2018 Page ALLEN 1 2 3 4 A Correct. Q He ' ) on the 5 was employee an A He Q You worked or right? worked the on campaign, correct. 6 7 8 administrator 9 veterans' said with was he respect just an the to right? fundraiser; 10 A Yeah. 11 Q It's It's -- just just yes-or-no a question. 12 13 SITARCHUK: MR. 14 15 WEISSELBERG campaign; Trump 46 to going l sees he Yeah. particular 17 this 18 perceived 19 issue. 20 fundraising-type 21 was working 22 the information 23 to 24 veteran 25 This the way Lewandowski Corery the this was was not issue. us the And on to us funds I way campaign a purely with a in out order to -- was able being in he to the he to get be able various organizations. Q What is Veritext 212-267-6868 question situation, him, dispense the fit. A 16 answer He's No. your Legal www.veritext.corn understanding Solutions 516-608-2400 INDEX NO. 451130/2018 FILED: NEW YORK COUNTY CLERK 06/14/2018 11:10 AM NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 06/14/2018 Page ALLEN 1 2 that 3 to that was based what 5 had with 6 was it, 7 getting 8 else. his It's him just funds instructions on how 11 funds; A give it 14 you 15 telling 16 distribute 17 fundraiser; taken 22 distribute to how Mr. Lewandowski the Just to. whom to the is organization your the to funds how the veterans' us, here's from one to correct? He's of care knowledge 24 to 25 those come let's and drawn, 23 telling organizations, of with get get a some these folks away. you what of up let's right And Q had no was doing he the lists do instructions, Veritext 212-267-6868 nothing you Not and A 21 did to. Q checks gave on right? 12 20 I That He out. 10 list involvement information us giving just 19 limited fundraiser. He 18 was only this Q 13 role the on the 9 WEISSELBERG on? A 4 47 personal and in order give you you? Legal www.veritext.corn Solutions 516-608-2400 †INDEX NO. 451130/2018 FILED: NEW YORK COUNTY CLERK 06/14/2018 11:10 AM NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 06/14/2018 Page 2 it. 3 Q 4 Mr. 5 sign was Trump for the the Yes, 7 Q And checks 9 cut signed A No. 12 Q It cut the the 17 any 18 accounts 19 which 20 payment? 23 was 24 charity 25 name your approve check being Mr. Trump who would them? wasn't I Were the of staff present policies use to for was appeared a how (3) an IRS Legal www.veritext.corn your determine particular was really I 501(c) in setting instructions. simplistic, was a in process. in would there Well, pretty involved staff There the concerning payable account involved of you Veritext 212-267-6868 a operation A policy. ever before Yeah. Q 22 you approve and day-to-day 16 21 did was checks A 14 15 correct. it? 11 13 to right? Foundation the just: authorized one only -- before from was Foundation; A 8 question My 6 10 WEISSELBERG ALLEN 1 53 no And must charity publication say. it If and a their that Solutions 516-608-2400 INDEX NO. 451130/2018 FILED: NEW YORK COUNTY CLERK 06/14/2018 11:10 AM NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 06/14/2018 Page 2 we 3 there, 4 the had at the then a in 7 the 8 from check would the Mr. that you was 17 gave our accounts 18 They had to 19 they didn't 20 no 21 Foundation. the really that just policy, your check that so What did come Did recipient Trump out give ever first. 501(c) Foundation Legal www.veritext.corn If that on book, the of an staff payable a we book you was That department. based accounts the sorry. payable Veritext 212-267-6868 in policy instruction only would Q 25 all. instructions. qualify check 22 I'm General 16 the come Instructions? A 24 from to at a no Then say? 15 to have there appear issued come There's Q 23 be not understand. 13 you to -- the if A 11 was So in issued did would not or Q place name It Trump be could Foundation. were they Foundation. that check no there, 9 14 if If 6 12 time, from charity 5 10 WEISSELBERG ALLEN 1 54 (3) should instruction that if charity, be the Solutions 516-608-2400 INDEX NO. 451130/2018 FILED: NEW YORK COUNTY CLERK 06/14/2018 11:10 AM NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 06/14/2018 Page 1 2 payor? A 3 4 piece 5 a 6 Donald 7 authority, 8 Tarasoff, 9 would of paper from that was payment do is go 11 she was 12 the Foundation. not had Deborah payable that allowed not question If the If that in write to My person, publication. was Q someone, by thing, to a requesting that accounts institution that book, check a is from different a one. 15 16 in 17 charity book that and A 19 Q was -- Foundation 21 department's 22 check 501(c) be to would the one (3) the that Trump pursuant instructions to make to your the charity? 23 A Correct. 24 Q And to was there any whether determine Veritext 212-267-6868 a was charity Okay. 20 instruction recipient -- 18 25' 25 okayed first our was charity, else the there if a someone or 13 -- the If 10 14 WEISSELBERG ALLEN ! 55 Legal www.veritext.corn the Solutions 516-608-2400 †INDEX NO. 451130/2018 FILED: NEW YORK COUNTY CLERK 06/14/2018 11:10 AM NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 06/14/2018 Page 2 purpose 3 business the of A 5 as 6 issued the payment the of 4 was in from the Foundation, 10 about 11 take o' five 13 MR. the 17 long. 18 410-A And 19 for 22 document ' 25 what's taken.) go back that Yes. Q And three pages a Char 2016. 20th, above-referred-to marked as AW Exhibit as of this recognize you we' we've A next called identification, Do the as is that www.veritext.corn 3 date.) the marked VeritextLegal 212-267-6868 was that's October was Q 23 we Let's mark (The 21 recess SHIFFMAN: it's from document It's don't Why document a 20 Sure. minutes. short Let's exhibit we record. 15 16 Could clock. ten or (A on was yes. SHIFFMAN: eleven 12 14 check a book, long break? MR. 9 the As no. SITARCHUK: quick a -- not name take the to Foundation? was MR. 8 related Trump That 7 24 WEISSELBERG ALLEN 1 56 as your Exhibit 3? signature Solutions 516-608-2400 INDEX NO. 451130/2018 FILED: NEW YORK COUNTY CLERK 06/14/2018 11:10 AM NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 06/14/2018 Page ALLEN 1 2 3 Foundation 4 A We do 5 Q Do you 6 -- return strike 8 10 know are you Q What 12 A Well, been 14 out 15 excess 16 money 17 interest 18 put various to market the 20 would be the assets account 23 put does of that would to have account get to we been have may have? it If had put some pay some into a small money. know you the in We No. at a local who Trump determined Foundation open bank, a and market money money was there. 24 Q And 25 A It who may Veritext 212-267-6868 type held? A 22 What operating account Do where the in to? cash it funds, 19 assets charities. on the cash? assets an into Q 21 the referring 11 13 are Specific assets what held? A 9 policy9 that. Foundation Trump Trump not. Where 7 the if investment an has WEISSELBERG know you Do Q 63 made have Legal www.veritext.corn that been decision? Jeff Solutions 516-608-2400 INDEX NO. 451130/2018 FILED: NEW YORK COUNTY CLERK 06/14/2018 11:10 AM NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 06/14/2018 Page 1 2 McConney, 3 was, 4 any or you real 5 over 7 in a its WEISSELBERG could have it know, ministerial. study that The Q 6 ALLEN million Not 9 Q Often? 10 A At 11 Q Let's 13 look at 14 page 9 A 15 for take the take page Q It's under for the 21 A Okay. 22 Q The over was that; A 25 $1.5 I that at tell can't say? Roman return for Numeral X. 2013. . average monthly a million, cash little bit right? In this Veritext 212-267-6868 a 9. 19. 24 look a SITARCHUK: did balance take exhibit. What 23 at Let's you if that's is usually look a example. A This had assets of 18 20 Foundation always. MR. if did. Okay. 16 17 wasn' wasn't times. that, under It right? A 2, we dollars 8 Exhibit me. It Trump accounts; 12 been 64 particular Legal www.veritext.corn year. . Solutions 516-608-2400 INDEX NO. 451130/2018 FILED: NEW YORK COUNTY CLERK 06/14/2018 11:10 AM NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 06/14/2018 Page 2 3 Was Q amount initial 6 many 7 large 8 years, 9 so I -- years on 10 opening ago, we grew. and to 12 Mr. Who 14 Q But your Over the money was the decision made million? the you expended, where Was you it or not at director a that to time, right? knowledge; A Correct. 18 Q As 19 responsible 20 Foundation's 21 were Foundation Trump 17 the for were treasurer, where determining would assets A It was Q My question held be in you the held? a bank, FDIC insured. 23 24 have McConney? Yes. 16 Foundation always that. $1.5 A of the to the didn't And 13 15 back forth. so that keep account? of like large unusually going the Q 11 mean balances it an the in A 5 that cash of 4 22 WEISSELBERG ALLEN 1 65 different, not where Was 25 it Veritext 212-267-6868 was was part Legal www.veritext.corn a it held. of your little Solutions 516-608-2400 INDEX NO. 451130/2018 FILED: NEW YORK COUNTY CLERK 06/14/2018 11:10 AM NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 06/14/2018 Page 2 responsibilities 3 where really 6 I 8 would be A 5 i My outlined would companies: in 9 a 10 reasonable 11 $1.5 12 getting 13 higher Keep the safe place. Did million at The certain a I'm 19 Q You're regulations regulations 23 amounts a opposed that would to have a risk. no Foundation had of not give to each money aware not not year, of what the are? the of out giving specific money. Do a it. aware aware regarding of of foundations you reference see in Veritext 212-267-6868 was keep as was I'm Q there's it governing A 22 25 think it? A 24 relatively bank amount 18 21 our of money what return? Q 20 did I one any to something 15 didn't you a There 17' 17 So investment A out are for do 14 16 responsibilities carefully. Q decide to held? normally liquid treasurer as it 4 7 WEISSELBERG ALLEN 1 66 on line Legal www.veritext.corn this 6 page, of the Solutions 516-608-2400 INDEX NO. 451130/2018 FILED: NEW YORK COUNTY CLERK 06/14/2018 11:10 AM NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 06/14/2018 Page 2 section 3 No. 4 return? we that 6 were just has has It Okay. 6 Q Do 74,000 8 there. 9 the was And you then Does 12 requirement 13 Foundation had 15 Q Do 17 document, 18 return 19 of it's here how you was was much the page 1 a out? see on third page over just of the of this investment actual the $4,000? Line 3 1. 20 A I 21' 21 Q Do 22 reasonable 23 that the A 24 to your there give the that Part refresh that to No. so return reference a concerning A 990, about investment that all at 14 16 says amount. 10 recollection that there's distributable 11 number. see minimum the investment percent 5 line at, minimum a A 7 looking the 5 25 WEISSELBERG ALLEN 1 67 return see it you think on that the Are you was a million $1.5 Foundation Trump yes. now, held? asking for an opinion? Veritext 212-267-6868 Legal www.veritext.corn Solutions 516-608-2400 INDEX NO. 451130/2018 FILED: NEW YORK COUNTY CLERK 06/14/2018 11:10 AM NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 06/14/2018 Page ALLEN 1 2 3 thought 4 $1.5 5 6 more 7 8 I'm Q was it million of A I with percent 11 toward the 12 didn't choose 14 Mr. 15 assets 16 other 17 market? I return, kind or Trump September did which manner or you money with familiar that the For All the Foundation Trump in or about 2013? I'm familiar 24 Q And how did you Veritext Legal Solutions 212-267-6868 the any account A that we with 23 25 go not. Justice of get to to discuss bank a payment 22 have in Are And we'd invested in more do. be Q to done order whether 19 made in children I 21 mean his A $25,000 the risk? you 18 20 done Did should than on have investments of to Q could have undue No. a 13 we you assuming 10 return held. think Could A 5 reasonable you risk. Q 9 whether yes, assets more without WEISSELBERG asking, a 68 with it. learn about payment? www.veritext.corn 516-608-2400 INDEX NO. 451130/2018 FILED: NEW YORK COUNTY CLERK 06/14/2018 11:10 AM NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 06/14/2018 Page ALLEN 1 2 The Q 3 shown 4 the 5 different 6 referred 7 right? on exhibit for in A Correct. 9 Q So the It's called 13 Q Is 14 A Three 12 in is a was files; different The Perfect Storm. 15 correct. 16 one 17 with a name 19 the 20 right? is that different Donald one one same in Correct. 22 Q And that the different the return for one name; yes. Foundation A is listed for 2013; as right? All; 24 A Justice 25 Q D.o For you Veritext 212-267-6868 with that's Trump For the name, 21 Justice entities, are different The the right? two Well, Q 18 23 is that three A 11 2, entity there's right? we Exhibit as have; 10 not which Tarasoff's Ms. 8 was 2013, than entity entities that marked we to WEISSELBERG entity return the 108 All. know how Legal Solutions www.veritext.corn that error 516-608-2400 INDEX NO. 451130/2018 FILED: NEW YORK COUNTY CLERK 06/14/2018 11:10 AM NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 06/14/2018 Page occurred? 2 A 3 is 5 Q 6 accountants 7 Foundation 9 ' letter ' the Did out 12 March 13 came up, 14 look at 15 asked 16 did 17 that information 18 They may 19 the 20 because 21 to come gives at we just a put didn't thing that a find in first return to And did not give firm. accounting and that off left For Justice I where time, mistake give All information them. What to did you accountants? the believe I them information is a what general Veritext 212-267-6868 whole return. the made and back You to of to that, the the from. have back to McConney your 2016? this on the preparation went back was A 24 25 what this the 28th, when went we Jeff in before 2016 of prepare We actually, Q give The Trump to June Yes. 11 23 assist from with Donald order to letter And answer. speak the in A 22 you for -- could I no. or 10 wish I answer 4 8 WEISSELBERG ALLEN 1 109 ledger Legal www.veritext.corn Jeff normally with a Solutions 516-608-2400 INDEX NO. 451130/2018 FILED: NEW YORK COUNTY CLERK 06/14/2018 11:10 AM NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 06/14/2018 Page ALLEN 1 2 saw 3 form? the second and WEISSELBERG third page in 4 A Not before -- 5 Q Not before preparing 6 this A Correct. 8 Q Do 10 we Mr. talked about Lewandowski A I 12 Q He for 14 right? you know him before was A Correct. 16 Q Who's know A No, 19 Q Have with for president; Stuart Jolly? Do you don't. I ever you corresponded him? 21 A I 22 Q Do Lewandowski 23 Mr. 24 that were 25 the veterans' to be don't no. recall, you recall sent a that list recipients of of charities grants from fundraiser? Veritext 212-267-6868 manager campaign him? 18 20 think I -- the campaign Trump's -- who do. 15 17 for is? 11 13 any examination? 7 9 121 Legal www.veritext.corn Solutions 516-608-2400 INDEX NO. 451130/2018 FILED: NEW YORK COUNTY CLERK 06/14/2018 11:10 AM NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 06/14/2018 Page ALLEN 1 Mr. 3 clearly, 4 contribution 5 veteran 6 directing 7 list 8 approved 9 to He guess the veterans that one A going. And Mr. was going what I Trump out groups. Q And that's How do not asked you. 12 13 Mr. 14 went out he But Q 18 knowledge that 19 that out 20 you? went A 21 22 around 23 involved, 24 their 25 involved said he to the office approved you don't sure money. And in the he 212-267-6868 payment every mean groups I he was or do hear did was these entire Veritext list. personal have veteran I I'm this approved that making what on has the that groups? based Well, that payment veterans I that know every the to reading, 17 you approved Trump A 15 16 payment a the was prepared. every to was money this, every out going clearly the see I approved was where that had Trump group. I WEISSELBERG Now that was 10 11 Yeah. A 2 122 clearly groups got definitely process Legal www.veritext.corn of getting Solutions 516-608-2400 ††INDEX NO. 451130/2018 FILED: NEW YORK COUNTY CLERK 06/14/2018 11:10 AM NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 06/14/2018 Page ALLEN 1 A 2 3 Mr. Do get to Trump 4 Q Yes. 5 A I next don't SHIFFMAN: exhibit the 8 document 9 through 380. And 10 January 29th, 2016 11 Mr. for 16 17 18 A Okay. 20 Q This between you and 22 A Yes. 23 Q And 24 Mr. . Lewandowski 25 Mr. . Trump; Exhibit as of this 9 date.) read to mind. and is Mr. just an e-mail Lewandowski; tell me when chain correct? . at was the time, campaign manager for correct? Veritext 212-267-6868 AW ready. re 19 21 as going don't Sure, Q you' just you if from Lewandowski. Mr. marked I'm it a e-mail identification, through a above-referred-to was A 15 It's DJTF-VETS378 it's to (The 14 mark order. Stamped Weisselberg document to Let's in Bates 12 spoke know. 7 13 who approved? it MR. 6 WEISSELBERG know I 127 Legal www.veritext.corn Solutions 516-608-2400 †INDEX NO. 451130/2018 FILED: NEW YORK COUNTY CLERK 06/14/2018 11:10 AM NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 06/14/2018 Page 2 A Correct. 3 Q At 4 seeking 5 how 6 from this he from wanted was I 8 whether 9 and passed it on 10 how he got me the 11 needed the information 12 able 13' 13 got cut to the 15 e-mail 16 the from to first pages the on morning 18 Q There, want 21 for 23 "We to the 24 25 your is is your 10:28 in right? ask start him thinking -- you how you collected funds right? The Yeah. Mr. Lewandowski. Did you general refer to you, anyone not else e-mail? Veritext 212-267-6868 be to from the vets"; Q in just which 380, you distribute specifically to 29th; should A ! order Lewandowski Mr. Correct. 20 care I e-mail, 379 A state, didn't I in 17 19 me. directly Trump checks. on to Mr. information. The one proceeds direction, seeking it Q 14 the on fundraiser? A he you Lewandowski Mr. distribute to veterans' the weren't time, direction 7 22 WEISSELBERG ALLEN 1 128 Legal www.veritext.corn Solutions 516-608-2400 INDEX NO. 451130/2018 FILED: NEW YORK COUNTY CLERK 06/14/2018 11:10 AM NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 06/14/2018 Page A 2 on 4 You Mr. 6 disbursements 7 advance the that e-mail 10 in 11 him he And when he Q Did 13 A No. some A 18 tell that? from I'm what Lewandowski Mr. was he wanted Iowa? in what on 21 going 22 correct? for to be held A 23 do 24 to 25 anything. were They campaigning I with I'm reading just Iowa in on 1st; February don't know. I side wanted Legal www.veritext.corn was that primary political the I the Veritext 212-267-6868 with checks you That's Based Q ' be yes. here, 19 20 to going some he when checks 17 wrote there. So Q 16 he here. reading 15 were they wanted went 12 14 in when caucus knew I Iowa. events making you? to A 9 Iowa to referring campaign at of be to nature. understand didn't Lewandowski 5 wasn't really that of anything Q ~ I Truthfully, focused 3 8 WEISSELBERG ALLEN 1 133 to had nothing of get checks Solutions 516-608-2400 INDEX NO. 451130/2018 FILED: NEW YORK COUNTY CLERK 06/14/2018 11:10 AM NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 06/14/2018 Page 2 prepared. 3 wanted 4 for 5 It 6 was. Whenever be to date 8 write back 9 after he 10 disbursements 11 "You 12 time to asks can use Donald's you about 16 million 17 Foundation. 18 that 19 amount. 20 checks 21 It's did was He dollars 24 checks from that very definite 25 But access to we have I the number know the out could do that. number. other he a wanted could I use I moneys, if So written, to a make I number, to. be is to a into money because want Veritext 212-267-6868 by clearly with The have this contribute to own his you if 22 23 say, at mean you that work could So a You million going of And I the Iowa. $1 then shortly making in it million? 1 A 15 you Lewandowski What been. week the of Mr. Donald's 13 have Weisselberg, while checks may day I them, those it what Mr. Q have to ready matter didn't wanted they whatever them, 7 14 WEISSELBERG ALLEN 1 134 million Legal www.veritext.corn didn't some do dollars that. that Solutions 516-608-2400 †INDEX NO. 451130/2018 FILED: NEW YORK COUNTY CLERK 06/14/2018 11:10 AM NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 06/14/2018 Page ALLEN 1 Lewandowski Mr. 2 4 document 5 for to marked was identification, A Okay. 7 Q Is A Yes. Q Do 9 10 this 11 e-mail AW Exhibit as of this e-mail an don't 13 17 date.) you Q 15 check 16 requested? for it, it cut a don't So many Do you says check. that's I'm a a reading we' we'll check, we assuming cut being I'm what on withdraw we you if $100,000 did. I know. MR. 22 the 23 Stamped next 24 document SHIFFMAN: Let's DJTF-VETS206 was mark document a document, (The through as Bates 209. above-referred-to marked Veritext 212-267-6868 I conversations, recall Based 21 25 discussing anybody? this A 17 l recall recall. ' 18 you with A 12 20 this as received? 8 19' 19 you. to 6 14 WEISSELBERG (The 3 148 Legal www.veritext.corn as AW Exhibit 18 Solutions 516-608-2400 †INDEX NO. 451130/2018 FILED: NEW YORK COUNTY CLERK 06/14/2018 11:10 AM NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 06/14/2018 Page ALLEN 1 A 2 4 another 5 This 6 Mr. 7 2016. one from is document for 10 identification, 12 Q This 14 A I 15 Q In 16 is 17 veterans' 18 sent to 19 each charity. and this 19 date.) you Q And e-mail list A of on much Mr. he have you see do see that. this we that of funds sent to that? looked approved list wants after is McConney a you Do the it. for that how 21 that at that had charities; Okay. Veritext 212-267-6868 of e-mail, charities I 25 as copied this A right? Exhibit Lewandowski Mr. asking was 20 24 AW e-mail an is as correct? received; the 16th, February marked was Okay. 23 to above-referred-to A earlier e-mail. McConney dated 111 22 mark one-page Mr. Lewandowski, (The 9 We'll a document, 8 13 recall. SHIFFMAN: MR. 3 WEISSELBERG don't I 150 Legal Solutions vvww.veritext.corn 516-608-2400 ††††INDEX NO. 451130/2018 FILED: NEW YORK COUNTY CLERK 06/14/2018 11:10 AM NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 06/14/2018 Page WEISSELBERG ALLEN 1 2 A Yes. 3 Q Who 4 A He's 5 work 6 worked 7 for us the on 9 request? 11 him that MR. SHIFFMAN: 13 Stamped DJTF-VETS196 14 document 17 18 be A Okay. 20 Q Did e-mails 22 which in you I'm 24 Q Which Exhibit as of this 23 date.) let just receive me ' the of any chain? numbers at CC'd the Veritext 212-267-6868 AW And if so, ones? A the as you e-mail this 23 25 202. ready. re 19 21 Bates through don't Why you' next document a identification, when this The marked was Q know he above-referred-to (The for then recall. I will 16 to any about Not exhibit ' used And have 12 15 who ago. you with A 10 years Did conversations fellow a campaign. Q 8 he? is many 159 on an page? You bottom of Legal www.veritext.corn e-mail. could the use page. Solutions 516-608-2400 ††INDEX NO. 451130/2018 FILED: NEW YORK COUNTY CLERK 06/14/2018 11:10 AM NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 06/14/2018 Page 2 A Three. 3 Q So that's on it 4 DJTF-VETS198 5 A Yes, 6 Q So the three 7 as 8 chronologically, 9 page Yes. 12 my 198. that is my name's on there The Q doesn't whether 18 bottom 19 McConney. 20 And 21 too. 197? I'm of the you' 24 sent 25 re we Q same This to way or the e-mails the at one from it's know who from Larry the Jeff it's to. Glick thing. -- was e-mail this is now, that the one iPhone? The ones Veritext 212-267-6868 received one the my it. one don't it. 197 received about referring from page on where 200, That's know, page yet. And well. as another That's there there. on you But A 23 towards gotten talking there's 22 back going you Do on well as CC'd, e-mails, who 15 17 is e-mail indicate another, one haven't I name 16 bottom? 200. 199, 13 with one the at preceding A 11 the so 199, 10 14 WEISSELBERG ALLEN 1 160 that Legal www.veritext.corn are from the Solutions 516-608-2400 †INDEX NO. 451130/2018 FILED: NEW YORK COUNTY CLERK 06/14/2018 11:10 AM NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 06/14/2018 Page ALLEN 1 2 Does Q 3 and 4 campaign, 5 track 6 communicating 7 receiving 8 recollection 9 than Mr. 11 made? A she 14 helping 15 given 16 to 17 they had 18 role where 19 it 20 And 21 along. 22 us out Corey make was sure I think be a record the would the got he being administrator where to administrative an have done had been just no that if helping assistance from him. Lewandowski Mr. had no role right? Foundation; Correct. VeritextLegal 212-267-6868 was situation. have may Corey, help in -- Corey keeper, he funds be that organizational-type Campbell to would . to more Trump donations because Rhona was Mr. as get to an A 25 to these Q in campaign responsibility 23 24 just may your the Yeah. and organizations the the keeping and conduit how the on people refresh a Burr Ms. were organizations that 13 that the of grants, concerning fact who about merely 12 the part the of 10 WEISSELBERG Lewandowski, were 164 www.veritext.corn Solutions 516-608-2400