Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 1 of 386 Page ID #:5171 EXHIBIT 18 REDACTED Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 2 of 386 Page ID #:5172 Page 1 UNITED STATES DISTRICT COURT C E N T R A L D I S T R I C T OF C A L I F O R N I A -----------------------------------------BROIDY CAPITAL M A N A G E M E N T LLC and ELLIOTT BROIDY, Plaintiff, Case No.: 18-cv-02421 v. S T A T E OF Q A T A R , S T O N I N G T O N S T R A T E G I E S L L C , N I C O L A S D. M U Z I N , G L O B A L R I S K A D V I S O R S L L C , KEVIN CHALKER, DAVID MARK POWELL, MOHAMMED B I N H A M A D B I N K H A L I F A AL T H A N I , A H M E D AL-RUMAIHI, and DOES 1-10, Defendants. -----------------------------------------CONFIDENTIAL ATTORNEYS' EYES ONLY VIDEOTAPED DEPOSITION JOSEPH ALLAHAM T U ES D AY , JUNE 19, 9:00 a.m. 320 OF 2018 MAGNA LEGAL SERVICES West 37th Street, 12th Floor New York, New York 10018 (866)624-6221 Reported Job by: Number: Adrienne 411069 M. M i g n a n o , RPR Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 3 of 386 Page ID #:5173 Page 2 1 2 3 June 19, 2018 4 9:00 a.m. 5 New York, New York 6 7 CONFIDENTIAL 8 Videotaped 9 held at 10 Flexner, 11 York, 12 Mignano, 13 York. 14 15 16 17 18 19 20 21 22 23 24 25 Deposition the 575 offices ATTORNEYS' of of Lexington pursuant to a Notary Boies New before of the ONLY ALLAHAM, Schiller Avenue, Notice, Public JOSEPH EYES & York, Adrienne State of New M. New Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 4 of 386 Page ID #:5174 Page 3 1 2 A P P E A R A N C E S: 3 4 5 6 7 8 BOIES SCHILLER & FLEXNER A t to r ne ys for P l a i n t i f f s LLP 575 L e xi n gt on Avenue New York, New York 10022 LEE W O LO S KY , ESQ. SAMUEL KLEINER, ESQ. SCOTT GLASS, ESQ. R O B E R T J. D W Y E R , E S Q . BY: 9 10 11 ARENT FOX LLP Attorneys for 12 Joseph Allaham 13 1675 Broadway 14 New York, New York 10019 15 BY: TEMITOPE MOHAMMED COVINGTON Attorneys & BURLING LLP f o r D e f e n d a n t - S t a t e of Q a t a r 620 Eighth Avenue New York, New York 10018 M A R K P. G I M B E L , E S Q . KATHERINE PULLEY ONYSHKO, ESQ. 16 17 18 19 20 21 22 23 24 25 BY: K. Y U S U F , FAROOQUI, ESQ. ESQ. Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 5 of 386 Page ID #:5175 Page 4 1 2 APPEARANCES (Continued) 3 WILMER CUTLER PICKERING HALE AND DOOR LLP 4 Attorneys 5 Advisors for and Defendants Kevin 6 7 World 7 8 9 BY: - Global Chalker Trade Center 250 Greenwich Street New York, York BRENDAN Risk New 10007 R. M c G U I R E , ESQ. 10 WILEY REIN LLP 11 Attorneys 12 Nick for Defendants Muzin 13 1776 14 Washington, 15 - Stonington K Street NW DC 2 0 0 0 6 BY: STEPHEN OBERMEIER, A L S O P R E S E N T : 16 17 18 19 RUDOLFO Legal 20 21 22 23 24 25 DURAN Video Specialist ESQ. and Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 6 of 386 Page ID #:5176 Page 5 1 2 THE 3 start 4 the 5 Joseph 6 Capital 7 State 8 States 9 district VIDEOGRAPHER: of m e d i a video labeled recorded Allaham of Q a t a r , 10 Boies 12 at 5 7 5 13 York on J u n e 14 9:08 a.m.. Schiller Lexington in t h e for United the central My n a m e legal is b e i n g Avenue, 19, 2018 video 17 reporter 18 we're both 19 Legal Services. counsel located York, Duran. New with please I'm The Mignano, in a s s o c i a t i o n Will at at a p p r o x i m a t e l y specialist. is A d r i e n n e held LLP, New is R u d o l f o the court and Magna introduce themselves. 22 MR. 23 Schiller 24 Broidy 25 Broidy et al v e r s u s & Flexner, 16 21 Court of of matter, LLC, deposition 11 20 one of C a l i f o r n i a . This 15 number et a l , District is t h e deposition in t h e Management This WOLOSKY: and and MR. Lee Flexner Broidy KLEINER: Wolosky, for Boies Elliott Capital Samuel Management. Kleiner, Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 7 of 386 Page ID #:5177 Page 6 1 2 Boies Schiller 3 4 MR. Schiller 5 6 GLASS: DWYER: Schiller 7 MR. Wiley 9 Stonington and MR. from 12 Advisors MR. 14 Covington 15 Qatar. 16 17 18 from 20 Allaham. 21 22 23 24 25 for Kevin Global McGuire Risk Chalker. Mark Gimbel ONYSHKO: Katherine Covington & Burling. Fox, FAROOQUI: Fox LLP for ALLAHAM: the Joey of Pulley Farooqui of J o s e p h Temitope Joey of State Mohammed on b e h a l f YUSUF: of Muzin. for Arent MR. on b e h a l f & Burling MS. Arent J. D w y e r , Brendan GIMBEL: MR. 19 Nick Hale and MS. Onyshko, Boies Stephen Rein McGUIRE: Wilmer 13 Robert OBERMEIER: Obermeier, 11 Glass, & Flexner. 8 10 Scott & Flexner. MR. Boies & Flexner. Yusuf Allaham. Allaham. from Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 8 of 386 Page ID #:5178 Page 7 1 2 Allaham - ATTORNEYS' J O S E P H witness, 4 by a N o t a r y 5 testified EXAMINATION 7 MR. 8 having been Public, duly was as a sworn examined and as f o l l o w s : BY WOLOSKY: Q Good 9 MR. morning, GIMBEL: 10 out, 11 statements 12 Mr. 13 do so f o r Counsel Allaham. I think on t h e to p u t record. did, and 15 Qatar, I would 16 State some I know I would 17 deposition 18 sovereign of t h e like of Q a t a r like State to s a y objects to that of the to t h i s as an i n t r u s i o n on i t s immunity. Qatar 20 dismiss, 21 against 22 lacks 23 against 24 Immunities will asking be f i l i n g that all subject Qatar a motion The court matter jurisdiction in t h e Foreign Sovereign Act. the reasons to claims it be d i s m i s s e d . For to s t a r t my c l i e n t . So on b e h a l f 19 Mr. wanted Obermeier 14 25 ONLY A L L A H A M, c a l l e d 3 6 EYES that are set Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 9 of 386 Page ID #:5179 Page 8 1 Allaham - ATTORNEYS' in Q a t a r ' s EYES 2 forth 3 stay 4 further 5 deposition, 6 District 7 forthcoming 8 threshold issue of s o v e r e i g n 9 The State of Q a t a r discovery, pending ONLY Qatar discovery, until Court examination 11 use of d o c u m e n t s , 12 involves 13 by t h e 14 Diplomatic 15 Allaham 16 Registration 17 conducted work 18 of Q a t a r , and 19 consultant 20 documents 21 his 22 protections 23 Vienna make 25 not and fall on t h e sure that are I saw or a n y it Consular and by M r . Agent State testimony record, to protected He of t h e in c o n j u n c t i o n and relating the Act as a to and Conventions. I would simply it on t h e State of Q a t a r , Vienna point the immunity. as s t a t e d on b e h a l f within and extent filings. of t h e last as t h e Allaham Foreign to t h e this objects to t h e Relations, Act to a n y to d i s m i s s of M r . to on t h e Conventions in h i s work time ruled materials The 24 such motion any objects including has 10 motion like to because transcript I'm at Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 10 of 386 Page ID #:5180 Page 9 1 Allaham 2 the 3 should 4 Only" 5 that 6 parties - ATTORNEYS' outset is, this be d e s i g n a t e d there "Attorneys' defendants also 9 deposition taking 10 It is p r e m a t u r e 11 stated 12 the 13 over in o u r stay personal 16 to s t a t e 17 to d i s m i s s on a l l 18 The as I s a i d , 19 jurisdiction 20 defendants. a claim. over By a p p e a r i n g reasons including jurisdiction defendants Mr. time. defendants. from waiving of t h e motion, 15 Court, Stonington at t h i s all Stonington and by t h e to t h e place for Stonington 21 I believe The object lacks suit, Eyes point. 8 the And OBERMEIER: Court transcript is an a g r e e m e n t on t h a t MR. ONLY entire provisionally. 7 14 EYES Broidy has We w i l l of t h o s e the lacks not 23 jurisdiction 24 Stonington defendants. 25 to p r o t e c t my c l i e n t s ' immune failed be m o v i n g grounds. personal Stonington here 22 are today, I am personal objections on b e h a l f I'm here right, of only to t h e Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 11 of 386 Page ID #:5181 Page 10 1 2 Allaham extent 3 - ATTORNEYS' they become Stonington 4 all rights 5 right 6 the to c a l l case 7 that 9 the Mr. YUSUF: record, will all 10 this 11 as " A t t o r n e y s ' 12 can 13 plaintiff's 14 case? just defendants defenses, as a g r e e d ONLY an i s s u e . again, I would to p r i o r Eyes just agree counsel WOLOSKY: 16 MR. GIMBEL: 17 Qatar, hearing 18 statement, 19 also 20 objections 21 all Mr. from that Yes, we a g r e e . the is t h e State of Obermeier's the need waive any of o u r and if I that For on that And I feel do n o t add designated Only". confirmation MR. if to g e t t i n g parties 15 the if n e c e s s a r y . be p r o v i s i o n a l l y get reserve including Allaham proceeds, MS. 8 and EYES immunities to a d d , and we reserve rights. 22 MR. 23 Advisors 24 those 25 the McGUIRE: and Kevin objections. deposition Global Risk Chalker join We a l s o object is p r e m a t u r e in that at t h i s Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 12 of 386 Page ID #:5182 Page 11 1 Allaham - ATTORNEYS' 2 time, and that 3 Mr. 4 Advisors 5 similarly 6 case 7 Obermeier. Obermeier and We a r e 9 jurisdiction 10 appearing 11 ensure Kevin 12 noticed, 13 will 14 accordingly 15 schedule. not and 17 MR. here rights and to t h e A Call me J o e y . Mr. move Court's Allaham. My g r a n d f a t h e r Mister. 21 Q State 22 A Joseph Street, Q business New your York, Is t h a t address? name and address. Allaham, 114 East New York 10021. a residential or to are WOLOSKY: 19 25 by BY morning, 24 by M r . -- o b v i o u s l y , pursuant the personal merely rights Good 23 our clients' those are arguments We're Q was Risk to d i s m i s s waving 18 20 Global articulated we w i l l reserve what Chalker or o t h e r our ONLY as w i t h the to m o v e here. that EXAMINATION stated, grounds 8 16 similarly going on t h e EYES 71st we Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 13 of 386 Page ID #:5183 Page 12 1 Allaham - ATTORNEYS' 2 A Residential. 3 Q And 4 address that 5 A No. 6 Q Did 7 Madison do y o u you 8 A Yes. 9 Q And 10 use that have at o n e as y o u r what A Hospitality. 12 Q What that you ran are from 14 A Prime 15 Q I should 16 asking you 17 understand 18 and that that must Okay. 20 Q Are State of Q a t a r 22 testify you are aware truthfully Say that 24 Q The State outset you address? businesses by s a y i n g that oath today truthfully? of a n y would or you under testify A at t h e did address? sure 23 25 address? of t h e start you A the that 550 Grill. 19 21 use businesses some to m a k e you point business 11 13 use? as a b u s i n e s s for ONLY a business currently you Avenue EYES reason why not want you to of Q a t a r made remarks today? again. of t h i s deposition. Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 14 of 386 Page ID #:5184 Page 13 1 Allaham 2 - ATTORNEYS' Are 3 the State 4 testify you aware of Q a t a r MR. of a n y would GIMBEL: 6 object. There 7 for question 8 argumentative. BY M R . ONLY not reason want why you to today? 5 9 EYES that I'm going is no g o o d and to faith basis it's WOLOSKY: 10 Q You can answer 11 A I'm not aware. 12 Q Are you aware 13 Stonington Strategies 14 to t e s t i f y today? A I'm not aware, 16 Q Are you aware Global Risk 18 testify Advisors question. of a n y would 15 17 the reason not want why you no. of a n y would reasons not want you why to today? 19 A No. 20 Q Okay. 21 During 22 deposition, 23 can 24 clear 25 down. answer I'll the course ask you them. so t h e court Please of t h i s questions and make answers reporter your can take you them Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 15 of 386 Page ID #:5185 Page 14 1 Allaham 2 - ATTORNEYS' If I a s k you EYES a question 3 believe is u n c l e a r , please 4 clarify it a n d try 5 please 6 that 7 answer. wait the 8 9 10 I'll until court just let pending need us k n o w , question but and 11 A Sure. 12 Q Have you now, 13 you me to to do s o ; and my q u e s t i o n can take a break please we c a n ever that at a n y answer take met down so your time the a break. Elliott Broidy? 14 A Just 15 Q In 2 0 1 7 16 you to h a v e 17 Mr. Broidy? 18 felt MS. 20 Q You 21 A I don't 23 is i l l by i l l Q you to h a v e 25 Mr. Broidy? will ago. any reason for towards Object to t h e form. will? can answer the understand. question. What do y o u will? 2017, 24 is t h e r e YUSUF: What mean a second ill 19 22 ask I finish reporter If y o u ONLY had is t h e r e any reason a grudge towards for Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 16 of 386 Page ID #:5186 Page 15 1 Allaham - ATTORNEYS' 2 A No. 3 Q Where 4 Mr. were you A In D a m a s c u s . 6 Q Damascus Syria, A Syria. 9 Q When is t h e did you of to t h e United States? A Around 12 Q And 13 currently 14 A United States. 15 Q Do y o u maintain at t h i s A No. 18 Q Did 19 A No. 20 Q Do y o u you hospitality '90s. countries a citizen citizenship the early what 17 21 capital move 11 16 born, correct? 8 10 ONLY Allaham? 5 7 EYES are you of? point attend have Syrian in t i m e ? any formal university? training business? 22 A No. 23 Q How 24 A No. 25 Q In a c c o u n t i n g ? about in r e a l estate? in Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 17 of 386 Page ID #:5187 Page 16 1 Allaham - ATTORNEYS' EYES ONLY 2 A No. 3 Q In i n t e r n a t i o n a l affairs? 4 A Say Meaning 5 terms 6 Q 7 that again. of -Do y o u international have formal A How 9 Q At a u n i v e r s i t y . 10 A No. 11 Q What 12 fluently? 13 A that 17 for I'd define languages training? do y o u English like -- a d o c u m e n t identification 18 and to s h o w that speak managing Politico on J u n e Politico, 22 Exhibit 23 this BY M R . Q an e x h i b i t been as A l l a h a m marked Exhibit published was 3 for Article by marked published as A l l a h a m identification, as of date.) WOLOSKY: Have 3. 7, 2 0 1 8 . (Whereupon, 21 you has It is an a r t i c l e 20 25 do y o u Arabic, Q 16 24 in Hebrew. 15 19 training affairs? 8 14 in you seen that article in Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 18 of 386 Page ID #:5188 Page 17 1 2 Allaham - ATTORNEYS' A Yes. 4 Q You 5 the article 6 cut ties 7 reference see the 9 A Yes. 10 Q Then saying, 12 themselves 13 region, 14 the you country," see the "Qatar that, this "Recently which is a Allaham? quotes you as portraying purveyor could of p e a c e not in t h e be f u r t h e r from truth." Do y o u 16 A Yes. 17 Q Did 18 A I did statement, Q agreed see you that? make not that make that no. But would is t h a t a statement be a t t r i b u t e d A I think it w a s 23 assistant of m i n e and 24 Q statement? statement? personally 22 25 paragraph had Mr. article enjoys as t h e but 15 21 that second to Q a t a r . Do y o u 11 in t h e states with 8 20 ONLY before? 3 19 EYES And do y o u to y o u ? prepared she agree that by an submitted with that it. you Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 19 of 386 Page ID #:5189 Page 18 1 Allaham 2 3 A I mean, agreeing 4 with Q article 6 agree 7 A with 9 statement that so I h a p p e n 11 statement 12 Q that 14 A No. 15 Q You call Politico that 18 Q So w h a t 21 Mr. 22 him, 23 24 25 could MS. it w a s the Either you WOLOSKY: agree moment with it. I was the full on my b e h a l f , -- it w a s a disassociate or h a v e I never said someone that? you mean by s a y i n g , be f u r t h e r from the just his truth?" Objection. said that it w a s n ' t assistant. GIMBEL: objection. BY M R . did YUSUF: Allaham MR. that on my b e h a l f . call to s a y , No. 20 by statement? didn't A "Nothing made wouldn't 17 19 done I have was So y o u ONLY mean -- r e a d i n g it w a s to s a y from do n o t at t h a t do I s a y 10 yourself to y o u . it or y o u -- h o w do y o u is a s t a t e m e n t I think not EYES statement? attributes 8 16 what that This 5 13 - ATTORNEYS' I join in t h a t Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 20 of 386 Page ID #:5190 Page 19 1 Allaham 2 3 Q 5 Do y o u purveyor 4 Qatar. think It is n o t Q I'm a statement 8 your 9 objection behalf, I can was to w h i c h you your 12 Q Do y o u believe of p e a c e A for 16 that 17 happened 18 translated 19 event. 20 me to a n s w e r day Q 21 you 22 article? 23 or t h e that to P o l i t i c o on not make any it w a s that Qatar that day I was And question. before 24 al-Qaradawi was the around the time 25 against. was is a It's about, with event -- and that was that that of t h i s of E m i r something hard an e v e n t unhappy meeting Qatar is -- i t ' s what The again. region? my d i s s a t i s f a c t i o n unhappy A for to question in t h e I think 15 speak to y o u . So s a y 14 is a to s p e a k did after A purveyor you given 11 13 Qatar region? asking to P o l i t i c o attributed ONLY my p o s i t i o n . only that EYES that in t h e I don't 7 10 believe of p e a c e A 6 - ATTORNEYS' with we w e r e made Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 21 of 386 Page ID #:5191 Page 20 1 Allaham - ATTORNEYS' 2 Q Can you 3 A The -- h o w 4 explain it; in w h a t 5 Q Could 6 A I mean, 7 leaders 8 issue 9 make who with sure associated 11 I brought 12 13 14 in a r e article, 16 reasons A And June that not you like me to who Qaradawi Jewish to Q a t a r that's -- I ' m person raised -- a n d that to not and associated really is? the people with. the of t h a t . as of t h e 7th, to be a n g r y No. further? of t h e that's dissatisfaction 15 17 all So t h a t ' s Q say person with that terms? you that ONLY would I brought that 10 explain EYES did date you of t h a t have at Q a t a r ? any other Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 22 of 386 Page ID #:5192 Page 21 16 Q I'd 17 that has 18 Allaham been 5. 19 like to s h o w marked Exhibit stamped 21 marked 22 identification, 24 25 BY M R . a document identification as 5. (Whereupon, 20 23 for you Document PROOD00000024 as A l l a h a m Bates through Exhibit as of t h i s 60, was 5 for date.) WOLOSKY: Q WhatsApp These documents messages are involving series you. of They are Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 23 of 386 Page ID #:5193 Page 22 1 Allaham 2 Bates 3 obtained 4 counsel. - ATTORNEYS' stamped documents Now, 6 WhatsApp 7 917-570-6132. you'll messages 8 9 PROD00000024 these 5 That see is y o u r ONLY to 6 0 , from we these phone phone and your that involve number number, correct? 10 A Correct. 11 Q Now, 12 EYES messages you involve 13 Would 14 MS. 15 point 16 when 17 Q that 18 2018 at 5 : 0 1 19 second message, 20 refers to J a m a l . 21 MR. 22 on t h e 23 30 p a g e s 24 not 25 content refers this familiar of t h e m , to but January 7, 2 0 1 8 , or so of t e x t intimately you to J a m a l . I'm that can messages? February record Benomar? referring message, GIMBEL: these Jamal. Counsel, these a.m. named you're second that be J a m a l YUSUF: say The see someone to w h e r e you also going 19, The 6 a.m. to s t a t e is o b v i o u s l y messages. with to t h e the extent I'm Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 24 of 386 Page ID #:5194 Page 23 1 Allaham - ATTORNEYS' 2 that 3 communication 4 the Vienna 5 the use 6 BY M R . 7 8 they contain any that of t h i s see, Mr. 10 Q Is t h a t 11 A Yes. 12 Q And 13 A He is an a l l y . 17 trusted Q you're we o b j e c t to to Allaham, the to J a m a l ? Yes. 16 be s u b j e c t document. A say. of would 9 15 kind Conventions, Do y o u references of t h e ONLY WOLOSKY: Q 14 EYES Who Jamal who is J a m a l man for is t h e referring Benomar? 19 Q He is a t r u s t e d 21 referring to? 22 A Yes. 23 Q And 24 A I've 25 Q Did You Qatar how just that asked. friend leadership do y o u known you man I would to? Jamal. The Qatar, trusted A Qataris? He is a f r i e n d the 18 20 Benomar? him know know for him to w h i c h you're him, many when Jamal? years. he w a s an Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 25 of 386 Page ID #:5195 Page 24 1 2 Allaham official - ATTORNEYS' at t h e United A Yes. 4 Q Is he c u r r e n t l y the 6 7 8 9 United A ask ONLY Nations? 3 5 EYES an o f f i c i a l at Nations? I don't know. You would have to him. Q Do y o u official at t h e know if he w a s United Nations 10 A I don't 11 Q Please 12 these 13 WhatsApp 14 a dispute e-mail take that MS. 16 handed 17 messages 18 him 19 there 20 to l o o k you a moment which were YUSUF: him me, specific these having to r e f l e c t with whole messages Jamal. Counsel, or s o . specifically? the to r e v i e w appear Again, 30 p a g e s to r e v i e w in 2 0 1 7 ? no. -- or e x c u s e messages, 15 21 know, an you Which Do y o u want packet or a r e you want him I would like for at? MR. WOLOSKY: 22 him to t a k e a look 23 PROD00000024, and 24 indicated messages 25 that the contain the at t h e I have name first page, already on t h e Jamal. record Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 26 of 386 Page ID #:5196 Page 25 1 2 Allaham BY M R . - ATTORNEYS' WOLOSKY: EYES ONLY Case Document 238-20 Filed 10/17/18 Page 27 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 28 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 29 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 30 of 386 Page ID I MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 31 of 386 Page ID I MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 32 of 386 Page ID I MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 33 of 386 Page ID I MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 34 of 386 Page ID I MAG NAQ LEGAL SERVICES Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 35 of 386 Page ID #:5205 Page 34 9 Do y o u 10 message, 11 2018. 12 litigator 13 ago and still 14 the run around, 15 Huckabee 17 Huckabee A business 20 21 Q you A 23 I was 24 Q you you sent message "My can't and a text on M a r c h lawyers he m e t contracts with me f i v e I have 26, is n o t resolve it, a month getting Dershowitz and ongoing." are the Dershowitz contracts that I mean, I work you had with and ongoing? them. I'm doing No, that in r e l a t i o n with not to t h e work Qatar? Qatar. Abroad. I mean, -- were a person. Was were 22 25 who What 18 19 WhatsApp It s a y s , 16 see What doing was with the nature Dershowitz of t h e and work Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 36 of 386 Page ID #:5206 Page 35 1 2 Allaham - ATTORNEYS' EYES Huckabee? 3 MS. 4 question. 5 Q You can answer it. 6 A I mean, I work with 7 matters 8 especially 9 and 10 11 that YUSUF: Israel. And written Yes. 13 Q And 14 contract? 15 A 18 Many these with what are I cannot top Do y o u in m a n y East, places. Advisory -- do y o u Alan a Dershowitz? the recall have terms of t h a t that right much you off know how paid Dershowitz? 19 MS. YUSUF: Objection. in e v i d e n c e . 20 facts not 21 A I mean, 22 question. He is my l a w y e r 23 something -- it is c l i e n t . 24 Q 25 them of my h e a d . Q Alan are contract A 17 Middle Compound consulting. Q the Objection. involved 12 16 ONLY Dershowitz So y o u r is o n e I will not contract for legal Assumes answer and with that it is Alan services that Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 37 of 386 Page ID #:5207 Page 36 1 2 3 4 Allaham he p r o v i d e s A - ATTORNEYS' ONLY to y o u ? Legal consulting. EYES services, advisory and Case Document 238-20 Filed 10/17/18 Page 38 of 386 Page ID I MAG NAQ LEGAL SERVICES Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 39 of 386 Page ID #:5209 Page 38 16 MS. YUSUF: 17 attorney-client 18 Don't 19 MR. 20 your 21 answer 22 23 24 25 fire BY M R . Q privilege answer DWYER: counsel's that THE Attorney. Calls information. it. Are you instruction following not to question? WITNESS: Yes. She would me. WOLOSKY: Can you go to t h e for next page. Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 40 of 386 Page ID #:5210 Page 39 1 Allaham 2 I'm 3 just going say - ATTORNEYS' to s h o r t e n Bates 4 message 6 that 7 to U A E . to M r . concerns 8 Yes. 10 Q Now, 11 page, 12 you 13 March you'll sent see to M r . Now, 15 messages 16 notice sent a text on M a r c h Focus turn 4, 2 0 1 8 on A d v i s e r to t h e additional Benomar why to M r . next messages on M a r c h that 4th, were Benomar you sending after you gave him in F e b r u a r y ? A I mean, 18 recall, 19 our 20 conversation. since dispute Q WhatsApp what we w e r e between Did Mr. happened, trying us w a s Benomar A I don't 24 Q In t h e an o n g o i n g respond MS. -normal YUSUF: if I to r e s o l v e messages? 23 25 25. that? if y o u see and 5th. 14 17 you Benomar Do y o u A 22 see ONLY reference page Mueller's 9 21 marked Do y o u 5 the EYES course? Objection. to y o u r Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 41 of 386 Page ID #:5211 Page 40 1 Allaham 2 - ATTORNEYS' Are 3 specific 4 you referring messages MR. EYES to t h e s e or j u s t WOLOSKY: I'm these specific messages, 6 March 5th are 7 documents 8 A 9 11 I see I don't 10 Bates see Q any I see stamped A Yes. 13 Q I see 14 Mr. 15 it s a y s , Benomar stamped I'm response from skip 4th and on t h e 25 a n d whatever one 26. looking at. him. to p a g e response on M a r c h "just Bates 5, 2 0 1 8 from at 6 : 5 1 p.m. now." Do y o u 17 MS. see that? YUSUF: 18 characterization 19 response from 20 document speaks 21 "Joey" 22 to be a m e s s a g e 23 MR. next Objection that Mr. to i t , WOLOSKY: to t h e this is a Benomar. The for itself and sent GIMBEL: objection. BY M R . reflected if y o u 16 25 March to 27. 12 24 in l i f e ? referring 5 that ONLY it s a y s so it a p p e a r s by M r . Join and Allaham. in t h a t Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 42 of 386 Page ID #:5212 Page 41 1 Allaham 2 Q 3 Bates Please stamped 4 the second, 6 excuse 7 messages me, Can your fourth third page, you take attention messages fifth dated March a moment to -- 13th. to r e a d those? A Yes, go a h e a d . 11 Q Now, this 12 messages 13 regarding 14 e-mails? 15 that you is a s e r i e s and the theft MS. YUSUF: Muzin 17 for The of exchanged Broidy's Objection characterization. to t h e messages speak themselves. 18 MR. 19 Mr. of M r . 16 GIMBEL: Join in t h a t objection. BY M R . 21 WOLOSKY: Q 22 e-mails. 23 there. 24 MBS 25 document and 10 20 ONLY 38. and second, EYES to t h e direct third on t h a t 8 skip number Please 5 9 - ATTORNEYS' You wrote, That what Reviewing. comes." MS. Then "Tried to g e t the I think he w a s doing He h a d it r i g h t before -- YUSUF: Objection. It s a y s , Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 43 of 386 Page ID #:5213 Page 42 1 Allaham 2 3 "he BY M R . 4 did it" Q Now, "Why would 6 e-mails?" 7 not "he had then Mr. Muzin they need Do y o u 8 sorry, 9 "he" 10 first, A 12 with Q Jamal know who referring know to J a m a l it." responds, to r e v i e w the they "he"? -- I ' m Is t h e Benomar? I'm not sure. who the conversation To y o u r I mean, knowledge, Mr. Benomar -- d i d 15 Mr. Benomar was 16 Mr. Broidy's 17 seem I don't was going. you believe in Q a t a r e-mails was that reviewing as t h e s e messages to s u g g e s t ? 18 MS. YUSUF: Objection 19 characterization. 20 believe 21 Mr. 22 that. 25 who is t h e 14 24 ONLY Okay. 13 23 EYES WOLOSKY: 5 11 - ATTORNEYS' they Allaham MR. That's suggest. has said GIMBEL: to t h e what I don't you think they suggest I join in t h a t objection. MR. WOLOSKY: Can you re-read Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 44 of 386 Page ID #:5214 Page 43 1 Allaham 2 the question, 3 4 A 5 remember 6 on t h e 7 out 8 those 9 Q I think -- I d o n ' t if he w a s time. But publicly, there the really or n o t , e-mails but were based coming so e v e r y o n e was reading you it is p l a u s i b l e e-mails. But 11 that's 12 "reviewing" that's 13 what what Mr. for believe he w a s Benomar doing was in M r . doing -- in Q a t a r them? MS. 15 YUSUF: Objection. Calls speculation. MR. 16 objection. 17 A 19 ONLY please. read) that 18 EYES (Record 10 14 - ATTORNEYS' GIMBEL: Join Misstates I can't speak in t h a t his for testimony. what he w a s doing. Q 20 You think MS. YUSUF: 21 for 22 possible. 23 MR. it is p o s s i b l e ? speculation. 24 objection. 25 A GIMBEL: Everyone was Objection. Anything I join reading Calls is in t h a t those Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 45 of 386 Page ID #:5215 Page 44 1 2 Allaham e-mails. 3 They Q Why 4 that Mr. 5 reviewing - ATTORNEYS' were do y o u Benomar EYES hot. think would it's Broidy's 6 MS. YUSUF: 7 Misstates his testimony. 13 Q Did you read 14 A Some. 15 whatever 16 17 was Q not in t h e Did you Never. 19 Q Did 21 the Objection. the ones e-mails? I was able to -- read e-mails that were articles? A knowledge, e-mails? in a r t i c l e s . 18 20 possible be in Q a t a r Mr. The ONLY Mr. read Muzin, e-mails to y o u r that were not in articles? 22 A I can't speak 23 Q Did you ever his review 24 Mr. Muzin 25 not in a r t i c l e s ? for Nick. discuss of e - m a i l s with that were Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 46 of 386 Page ID #:5216 Page 45 1 Allaham 2 - ATTORNEYS' MR. GIMBEL: in e v i d e n c e . 3 facts not 4 A I think 5 which 6 not 7 that 8 these 9 e-mails, 10 16 is I w i l l -- he w a s wanted Nick to s p e a k and 18 you 13th 19 A Yes. 20 Q It s a y s , 21 e-m ails Broidy 22 I'm 23 assuming 24 the 25 Royce? House of N i c k , state that my o p i n i o n from with claimed wanted on t h e that "It's assuming is a r e f e r e n c e all of had leaked with e-mails. your attention Muzin sent to p.m.? cool references And to s p e a k Mr. at 5 : 3 1 of F o r e i g n reporters him. I direct message on M a r c h credit all can Assumes the all comment Now, to W h a t s A p p had they to j u s t 17 for only ONLY Objection. bombarded reporters Q EYES that in Royce." -- w h i c h to t h e Affairs I'm Chairman of Committee, Ed Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 47 of 386 Page ID #:5217 Page 46 1 Allaham - ATTORNEYS' 2 A Yes. 3 Q Do y o u 4 what was in t h o s e 5 MS. 6 restate 7 the 10 A 11 reporters 12 Q 14 were I'm 16 referencing above 19 that 20 Jamal here that some "I'm read back whatever reporters Mr. But of t h e sent Royce? I mean, it e-mails message sure the credit I have 24 Q Did from he" you to M u z i n -- r e f e r r i n g you believe to Jamal for? to -- Jamal of M r . immediately credit." is t h a t A hack that sure. the What the you Royce. -- " t o o k the know not 23 25 Can him. is a m e s s a g e reads, took you I stated, concerning Now, 21 22 Can sending e-mails states 18 knew read) what Do y o u 15 Q Objection. WOLOSKY: Again, A 17 Muzin question? (Record to h i m Mr. question. 9 13 how ONLY e-mails? YUSUF: your MR. 8 know EYES take Broidy's the credit e-mails? for Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 48 of 386 Page ID #:5218 Page 47 1 Allaham - ATTORNEYS' 2 A No. 3 Q Did 4 the hack you of M r . A Never. 6 Q Can you This 8 Bates stamped 9 message that 10 March 18, 11 thinking number you Yes. 14 Q Why that Jamal 16 was criminal this says MR. in t h a t Muzin for on on Jamal." that? it t h a t you a criminal believed lawyer? Objection. that GIMBEL: Assumes I don't Jamal needs think a I'm going to j o i n objection. WOLOSKY: Q You 24 A I think bit is a t e x t lawyer. 23 25 Brafman page. that's "I k e e p in e v i d e n c e . 19 BY M R . to N i c k not that next There YUSUF: 18 21 to t h e 39. see Jamal e-mails? MS. facts 22 Ben needed 17 20 with document send Do y o u A discuss It s a y s , to u s e 13 15 flip is t h e 2018. 12 ONLY Broidy's 5 7 ever EYES -- I ' m not can answer the my E n g l i s h so g o o d question. is a l i t t l e in -- I w a s saying Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 49 of 386 Page ID #:5219 Page 48 1 Allaham 2 for 3 Meaning 4 dispute. 5 use - ATTORNEYS' me to u s e Ben I need Ben Brafman a lawyer So I w a s Brafman. EYES ONLY against to f i g u r e referring Jamal. out to m y s e l f our to Case Document 238-20 Filed 10/17/18 Page 50 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 51 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 52 of 386 Page ID Page 51 MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 53 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 54 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 55 of 386 Page ID MAG NAQ LEGAL SERVICES Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 56 of 386 Page ID #:5226 Page 55 18 19 MS. quick YUSUF: Can I just MR. WOLOSKY: 21 THE VIDEOGRAPHER: 22 10:03 23 record. 25 a.m., and time is then the Sure. we're (Thereupon, and a break? 20 24 take The going a recess proceedings off was the taken, continued as Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 57 of 386 Page ID #:5227 Page 56 1 Allaham 2 follows:) 3 THE 4 start 5 time 6 on t h e 7 8 9 BY M R . - ATTORNEYS' VIDEOGRAPHER: of m e d i a now EYES labeled is 1 0 : 1 7 ONLY This is t h e number 2. a.m., and we're have you ever The back record. WOLOSKY: Q Mr. associated Allaham, with a business 10 Prime Hospitality 11 A Yes. 12 Q What 13 business? 14 A Restaurant. 15 Q And operated out 17 York, was 18 building, 19 A Yes. 20 Q Did 21 perform 22 directly the of 5 5 0 otherwise the Group? Prime 16 called been nature of t h a t Hospitality. Hospitality Madison known Group Avenue as t h e in N e w Sony correct? work Prime for the Hospitality State Group of Q a t a r or i n d i r e c t l y ? 23 A No. 24 Q Does 25 still operate? Prime Hospitality Group ever Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 58 of 386 Page ID #:5228 Page 57 1 Allaham - ATTORNEYS' 2 A No. 3 Q When 4 A Around 5 Q Have 6 with 7 LLC? did a business 8 A Yes. 9 Q And 10 business? 11 A It w a s 12 Q And 13 A At t h e 14 Q Did 15 business? 16 A 17 Prime 18 Q 19 performed 20 either what AFH Associates, the nature did it h o l d ? in a n y directly the other operating Associates for of t h a t holder. of -- so t h a t ' s State the -- ever of Q a t a r or i n d i r e c t l y ? A No. 22 Q Is A F H 23 A Rephrase 25 associated building. I was AHF work of 2 0 1 7 . been lease Sony 21 24 was it e n g a g e out Has ever a lease I mean, Grill fall called what ONLY it c l o s e ? the you EYES still that in o p e r a t i o n ? again, the corporation? Q Does it s t i l l conduct business? Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 59 of 386 Page ID #:5229 Page 58 1 Allaham - ATTORNEYS' 2 A No. 3 Q Does 4 accounts? 5 A No. 6 Q Did 7 accounts? 8 A I believe 9 Q And 10 do y o u those recall recall. 12 Q Did have 13 accounts? 14 A No. 15 Q Did AFH Prime bank 17 A No. 18 Q Does 19 maintain 20 open? 21 A No. 22 Q Have 23 business 24 Allaham 25 A any called bank banks any offshore bank Group have accounts? Hospitality accounts you been Allaham Consulting? Yes. at w h a t Hospitality Prime bank maintain accounts? I don't offshore bank so. A any any time 11 16 ONLY it m a i n t a i n it at a n y it m a i n t a i n e d EYES that Group are associated Consultancy still with or a Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 60 of 386 Page ID #:5230 Page 59 1 Allaham 2 3 Q - ATTORNEYS' Do y o u interest in t h a t 4 A Yes. 5 Q Do a n y 6 ownership 7 A No. 8 Q What 9 A Real 11 Q Has 12 Allaham 13 the 14 indirectly? Consultancy 16 Q Can 17 which Allaham 18 estate 21 22 you consulting conduct? or performed either work directly describe Consultancy the or manner provides for in real services? consulting services for estate. Q And services who A Whoever 24 Q And estate does it p r o v i d e those to? 23 25 Allaham Allaham of Q a t a r It's does Consulting ever an business? consulting. Never. real in t h a t have estate A A persons business 15 20 other Consulting State an o w n e r s h i p or A l l a h a m 10 ONLY business? interest Consultancy 19 have EYES seeks is t h a t or r e s i d e n t i a l to be a c l i e n t . commercial real real estate? Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 61 of 386 Page ID #:5231 Page 60 1 Allaham - ATTORNEYS' 2 A Both. 3 Q And is it -- w h a t 4 country or w o r l d 5 provide real does estate MS. YUSUF: 7 Are you operates 9 the 10 BY M R . 11 12 Allaham Consultancy services? Objection. you come to w h e r e referring What are it p r o v i d e s the consultancy markets services United 14 Q New York City? 15 A New York City. 16 Q Any places 17 City? 18 A United 19 Q Is it a b i g company? 20 MS. Objection. 21 What 23 to w h e r e geographic A BY M R . it from? 13 22 of t h e WOLOSKY: Q that regions referring or a r e clients ONLY consulting 6 8 EYES for? States. outside of N e w York States. YUSUF: do y o u mean by b i g ? WOLOSKY: Q What 24 revenues 25 Consulting would of A l l a h a m are? you say the Consultancy annual or A l l a h a m Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 62 of 386 Page ID #:5232 Page 61 1 Allaham - ATTORNEYS' 2 A It j u s t 3 Q When 4 A I'm 5 Less than not How 7 A Whoever Does 10 A At t h i s 11 Q Does maintain bank 13 A No. 14 Q How paid 16 by i t s A depends 18 mean 20 sure, but clients comes. it h a v e not does long. it h a v e ? I mean, how any time, Allaham it is clients? no. Consultancy accounts? does Allaham Consultancy get clients? If t h e r e 17 19 ago. -Q 15 long it s t a r t ? many 9 12 not ONLY a year. Q not started did 6 8 EYES the is a c l i e n t , deal usually is s t r u c t u r e d . I -Q time I'm sorry. I'm having a hard understanding. 21 If it d o e s n ' t 22 accounts, 23 A 24 there 25 Q how does I mean, is a d e a l , have it g e t when Participation paid? the I don't bank deal have -- w h e n to g e t in a d e a l , paid. is t h a t Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 63 of 386 Page ID #:5233 Page 62 1 Allaham 2 how Allaham 3 compensation - ATTORNEYS' Consultancy for 4 A That 5 Q But 6 Allaham 7 deals 8 receive at t h i s 11 12 it is f a i r to s a y point has not for which that conducted any it w o u l d MS. YUSUF: Objection. not in e v i d e n c e . Assumes WOLOSKY: Q Has Allaham participated in a n y 14 transactions for 15 receive Consultancy real which estate it h a s or w i l l compensation? 16 A Not 17 Q Does any work? to b e . 13 18 receives compensation? facts BY M R . ONLY is my a i m Consultancy 9 10 its EYES offshore A No. 20 Q Are consultancy 22 associated 23 Consultancy? Allaham bank 19 21 yet. with any that other 24 MS. 25 Is t h e r e have accounts? there firms Consultancy YUSUF: other you than real have estate been Allaham Objection. a time period here or Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 64 of 386 Page ID #:5234 Page 63 1 Allaham 2 do y o u 3 - ATTORNEYS' mean MR. WOLOSKY: A Yes. 5 Q What are 6 which you have been 7 conducted real estate 8 A I don't around 2010 10 Q 11 deals 12 A 13 a few 14 is v a g u e 15 for 16 is y e s . 17 18 when deals, about a deal Q have done 19 A 20 mean? 21 small more. -- c o u l d in r e a l the estate company? real be -- y e s , deals would we d i d estate money the answer you say you estate? I had Q Yes. And 22 A I would say 23 Q So l e s s than A I don't remember. 25 company. be r a i s i n g When 24 It w a s Definitely again, many real have work? name. a small do a n y that or c o u l d How the with that consultancy you but, firms associated we h a d had It w a s other recall did you In l i f e . the or ' 1 1 And ONLY in l i f e ? 4 9 EYES the company, throughout you your life. we d i d a few deals. five, would you say? It w a s years Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 65 of 386 Page ID #:5235 Page 64 1 2 Allaham - ATTORNEYS' EYES ago. 3 Q Was 4 A No. 5 Q So it is s o m e w h e r e 6 7 that. 8 Q 9 did time? 11 A 14 residential A 16 actually. 17 Q 18 there 19 can 20 22 A were estate any between Sorry. any during that sell -- Strike deals I helped that that you period of something a commercial project or project? I'm than the other real estate that you Again, sure I don't were than I don't Miami deal, deals are that you did? I don't There not be b o t h . Other Less A 100? Miami. Could a few. Q name Commercial. name 23 24 you Was 15 21 Can I mean, Q than WOLOSKY: in d o w n t o w n 13 it m o r e MR. in r e a l 10 12 ONLY recall but there recall. a few. ten, recall. would you say? Case Document 238-20 Filed 10/17/18 Page 66 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 67 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 68 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 69 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 70 of 386 Page ID MAG NAQ LEGAL SERVICES Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 71 of 386 Page ID #:5241 Page 70 13 Q 14 with 15 LLC? Have the you business ever called 16 A Coin Funding? 17 Q Coin Funding, 18 A Is t h a t 19 Rodman's 20 21 Q been associated Coin Funding, LLC. Rodman's, Dennis -You've not heard of t h i s company? 22 A No. 23 Q I'd 24 that has 25 Allaham been 30. like to s h o w marked for you an e x h i b i t identification as Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 72 of 386 Page ID #:5242 Page 71 1 Allaham 2 (Whereupon, 3 and 4 website, 5 30 f o r 6 date.) 7 BY M R . 8 9 - ATTORNEYS' Conditions was Q Printout of A l l a h a m marked Consulting I'd like to t h e under terms and 13 about us". It s a y s , 14 "www.AllahamConsulting.com 15 operated 16 A Yes. 18 Q Can Funding, LLC A see your where it s a y s "Information is o w n e d and LLC". that? explain what Coin is? guy. Q Funding, you I have website page conditions, Do y o u 17 Have no i d e a . I have you Probably the no c l u e . ever seen this document before? 24 25 first by C o i n of t h e to d i r e c t 12 23 Exhibit website. attention 22 Consulting as of t h i s is a p r i n t o u t 11 21 of T e r m s as A l l a h a m identification, This Allaham 20 ONLY WOLOSKY: 10 19 EYES A life I have read the to a d m i t , terms and I never conditions in my on Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 73 of 386 Page ID #:5243 Page 72 1 Allaham 2 anything, 3 have 4 5 so n o . never Q the - ATTORNEYS' read Who I have was involved A web 7 Q I'm 8 A A website 9 Q Do y o u master I web up page? person. sorry? person. know the name of t h a t person? 11 A Baskhar. 12 Q Were 13 or o w n e r s 14 in s e t t i n g there up t h e A No. 16 Q Other 17 Consultancy, 18 with any other No. 20 Q Other 21 Consultancy, 22 associated 23 entities web involved page? Lexington and you presently associated than were with employees Consulting business A other than are 19 A any of A l l a h a m 15 25 it b u t in s e t t i n g www.AllahamConsulting.com A 24 seen ONLY it. 6 10 EYES any entities? Lexington you Allaham involved other and Allaham or business in 2 0 1 7 ? No. Can I add something to t h a t ? Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 74 of 386 Page ID #:5244 Page 73 1 Allaham - ATTORNEYS' 2 Q Please. 3 A There 4 that I'm 5 personally. Q Okay. 7 A Okay? 8 Q Why 9 establishing 10 question 12 and 13 WhatsApp 14 answered. 15 MR. 17 18 the you YUSUF: message Q 19 that's 20 Exhibit 21 in 2 0 1 7 ? The accounts, referring that was I think the asked to t h e and it a l s o record. WOLOSKY: I'd been like marked Allaham to s h o w for phone 23 as A l l a h a m Exhibit 24 identification, WOLOSKY: an e x h i b i t as 7. Two containing you identification Exhibit (Whereupon, BY M R . into account offshore 22 25 looking GIMBEL: or record. you're mischaracterizes BY M R . company Objection. is a b o u t I believe account in a n y an o f f s h o r e 11 16 with For were MS. ONLY is no o f f s h o r e affiliated 6 EYES Binders records, were marked 7 for as of t h i s date.) Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 75 of 386 Page ID #:5245 Page 74 1 Allaham 2 Q - ATTORNEYS' These 3 Sprint that 4 in r e s p o n s e 5 on S p r i n t are 7 us in an E x c e l 8 printed received 11 except 12 numbers 13 with 14 indicate 15 was for this some the the and 16 Excel it is a r e c o r d 18 the phone 19 May 1, 2 0 1 7 this this notations of t h e and document 20 Now -- 21 MR. GIMBEL: 22 the record, you 23 are handwritten 24 those 25 by t h e business that who reflects placed beginning 1, 2 0 1 8 . Can I just said notations ask that here. notations record that to or f r o m May have handwritten along person 917-570-6132, ending page called. of c a l l s number is spreadsheet of p r i n t i n g , you to was exhibit date or w h o 17 which containing identity And served exhibit. that handwritten called 18th produced header the the were spreadsheet, from on M a y plaintiff materials I represent unchanged from 1st. to c r e a t e 10 ONLY records to a s u b p o e n a These 9 phone plaintiff on M a y 6 EYES for there Are supplied holder, Sprint, Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 76 of 386 Page ID #:5246 Page 75 1 Allaham 2 or h a v e 3 your - ATTORNEYS' they MR. added WOLOSKY: by o u r 6 MR. 7 notations 8 not 9 on t h e MS. 11 the first 12 Mr. Allaham 13 almost for 16 just 17 a document 18 received want 21 917-570-6132 22 that you A they are is s e e i n g what pages I expect to s p e c i f i c that that this is for looks like of p a p e r . that we w i l l pages, that we h a v e want but this reviewed I is n o t or previously. is it c o r r e c t is y o u r -- t h e that phone number use? MS. 25 that counsel to be c l e a r Now, and to t h e WOLOSKY: Q 24 been I similarly record a thousand be d i r e c t e d 23 And that Certainly 20 on record. the time 15 have We o b j e c t ground YUSUF: to s t a t e BY M R . They GIMBEL: 10 19 by s o m e b o d y team. a business 14 added ONLY team? 4 5 been EYES YUSUF: answered. Yes. Objection. Asked Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 77 of 386 Page ID #:5247 Page 76 1 Allaham 2 Q - ATTORNEYS' And 3 Sprint 4 that is it c o r r e c t as y o u r phone mobile ONLY that service you A Yes. 6 Q Now, 7 and 8 pages in t h i s 9 pages 851, provider happy I will represent to f l a g them document, 855, 859, for they 860, you 862, 863, 867, 873, 874, 878, 839, 880, 11 884, 887, 890, 908, 909, 919, 921 12 that's on 864, 883, and -- it. 13 There are 42 p h o n e the phone number 14 to or f r o m 15 which is t h e 16 Nevis International 17 phone Did you number calls placed 869-469-0080, for in t h e make Bank of Caribbean. those calls, Allaham? 19 MS. 20 I believe 21 were 22 which 23 on t h e appear 866, Mr. for to y o u , 10 18 use number? 5 I'm EYES BY M R . 24 Q 25 phone YUSUF: received calls Objection. counsel and are some you just were said sent. referring to? WOLOSKY: Did calls you with participate Bank of N e v i s in t h o s e some So Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 78 of 386 Page ID #:5248 Page 77 1 2 Allaham - ATTORNEYS' EYES International? 3 MR. 4 objection 5 because 6 A Yes. 7 Q What 8 those GIMBEL: to t h e I think was I want form of t h e counsel the MS. YUSUF: Which specifically? 11 44 d i f f e r e n t ones, and 12 doesn't which page 13 referring to. 14 questions about 15 MR. know 16 Objections 17 really 18 21 from Q matter of are you, calls just So h o w said Mr. are Allaham you're can he a n s w e r Are you testifying? as to f o r m . to c o a c h YUSUF: Bob, there calls? DWYER: Sir, the That's but You're witness. a lot coming okay. it is a s i m p l e Do y o u 23 42 p h o n e 24 International? A question WOLOSKY: 22 25 You trying MS. BY M R . an is t e s t i f y i n g . subject 10 20 to s t a t e calls? 9 19 ONLY calls No. deny from making Bank question. or r e c e i v i n g of N e v i s Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 79 of 386 Page ID #:5249 Page 78 1 Allaham 2 3 Q So w h a t 42 p h o n e A 5 in N e v i s . 6 Q account 8 9 10 A have was the EYES subject I was trying Isn't it t r u e at B a n k No, to o p e n that of N e v i s it is n o t an a c c o u n t Q And 12 calling 13 calls 14 to y o u r an a c c o u n t you have an International? true, at N e v i s and or a n y isn't on t h o s e on t h o s e it t r u e dates I do n o t offshore dates concerning I do n o t have 16 Q And testimony were 18 me. trying 19 21 A and account 23 less, 24 need were phone deposits were you and trying needed to o p e n And the and is t h a t calls to c a l l then a bank 42 t i m e s ? to o p e n research, you -- e x c u s e to o p e n trying it is t h e paperwork, an a c c o u n t . phone We -- I w a s 22 Q your to o p e n You account you account? A 17 that or r e c e i v i n g 15 25 of t h o s e period. 11 20 ONLY calls? 4 7 - ATTORNEYS' more I decided an or no account. have you traveled to N e v i s ? Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 80 of 386 Page ID #:5250 Page 79 1 Allaham - ATTORNEYS' 2 A Never. 3 Q And 4 Bank 5 opening 6 of N e v i s why Because 7 accountant 8 the is it t h a t as a l o c a t i o n up a b a n k A that's suggested to do i t . 9 Q Who 10 A Allen 11 Q Did 12 Nevis concerning 14 Which 16 referring BY M R . 17 that that is this an a c c o u n t a n t bank in account? Objection. bank account are you WOLOSKY: Q Did you 19 Nevis 20 up a b a n k 21 A No, 22 Q Do y o u 25 my to? any 24 what accountant? retain YUSUF: 18 23 selected Dorkin. you MS. you to p u r s u e to m e , is y o u r 13 ONLY account? place 15 EYES professional concerning account retain service your an a c c o u n t a n t providers interest at B a n k I did or in in o p e n i n g of N e v i s ? not. know someone named Midge Morton? A That's I think why I said the name earlier, is f a m i l i a r . I have to l o o k Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 81 of 386 Page ID #:5251 Page 80 1 2 Allaham - ATTORNEYS' EYES ONLY it u p . 3 Q Okay. 4 Well, I will multiple 5 that there are 6 form Midge Morton 7 during 8 calls the same 9 I'll 10 those 11 852, 12 time, 13 from phone 853, calls 14 as t h e have no r e c o l l e c t i o n 16 with Midge 17 year? Morton MS. MR. 21 A phone that on p a g e s 860 at t h e phone calls testimony 851, same to or during YUSUF: the GIMBEL: of t h i s testimony. Objection. I was trying open an a c c o u n t through 23 then we d e c i d e d it is a h a s s l e , 24 Qataris 25 in t h e United calls February 22 to p a y you Objection As I s t a t e d , want that of 11 p h o n e mischaracterizes 20 as y o u r of N e v i s . 15 19 of N e v i s represent and Is it y o u r 18 to or of N e v i s . appear 858 roughly, Bank Bank to y o u calls Island period further 855, phone on t h e time to or f r o m represent me, States. Form. to my a c c o u n t a n t s they and should and if t h e pay me Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 82 of 386 Page ID #:5252 Page 81 1 Allaham 2 - ATTORNEYS' The went account through, was never 4 there. 5 for 6 complicated, above 7 I'm sophisticated, 8 never what not phone paperwork that opened. calls ONLY never 3 The and EYES there were opened was just nothing research is n e e d e d . It w a s my p a y to o p e n rate and so it w a s too it. Case Document 238-20 Filed 10/17/18 Page 83 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 84 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 85 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 86 of 386 Page ID MAG NAQ LEGAL SERVICES Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 87 of 386 Page ID #:5257 Page 86 23 Q 24 you 25 marked Well, review for the then, why document don't that identification we h a v e we h a v e as E x h i b i t Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 88 of 386 Page ID #:5258 Page 87 1 2 Allaham number - ATTORNEYS' (Whereupon, 4 Registration 5 Foreign 6 1938, 7 for 8 A Agents was Short Statement marked sorry 9 MS. YUSUF: 10 question. 11 A back record, 15 deal that 16 of 2 0 1 7 . 17 person There which for I had done years I was owed the Q Who the 19 A It is a N e w 20 unrelated 21 just 22 the to Q a t a r to s h o w you estate 23 Q Sure. 24 A Not to a 2 0 0 7 a real ago money estate at t h e and end the money. 18 real was it is i m p o r t a n t . paid me t h e date.) is no like I got paid 1 -- to p u t 13 14 as of t h i s I would and of Exhibit I just remembered, to t h e Act is s o m e t h i n g 12 on t h e Pursuant as A l l a h a m identification, There Form Registration I'm back ONLY 1. 3 25 EYES person? York or a n y that company -- it is a -- I was involved in business. related or 2 0 0 8 at a l l . deal It g o e s that I had Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 89 of 386 Page ID #:5259 Page 88 1 Allaham 2 done. 3 Q Let's 5 which 6 statement, 7 Registration is y o u r 8 10 short Act Security Justice ONLY Yes. 13 Q Okay. 14 Did before it w a s 16 A Yes. 17 Q And signed are A What 20 Q I mean, thirds 22 above 23 undersigned 24 penalty 25 read your the with the National Department of that? review you this aware penalty 19 two Agents document filed? it u n d e r 21 Foreign 2018. see you document, as a m e n d e d . of t h e 15, Do y o u A to t h e filed this registration of 1 9 3 8 Division on J u n e with form pursuant 12 18 start It w a s 11 15 EYES Okay. 4 9 - ATTORNEYS' does of t h e that if y o u way signature swears that you of p e r j u r y ? mean? look down, at p a g e the page it s a y s , "The or a f f i r m s that of p e r j u r y , information that set he or s h e forth 2, right under has in t h i s Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 90 of 386 Page ID #:5260 Page 89 1 Allaham 2 registration 3 familiar 4 that such 5 true and 6 her statement, with accurate knowledge MR. the A Yes. 11 Q Did signed contents are ONLY that thereof, in t h e i r to t h e he/she best is and entirety of h i s or belief." Can you re-read question. you read) review it b e f o r e you it? 13 A Yes. 14 Q And believe EYES and WOLOSKY: (Record 10 15 and pending 9 12 the contents 7 8 - ATTORNEYS' when you signed it, did you it to be t r u e ? 16 A Yes. 17 Q And 18 Lexington will 19 documents pursuant do y o u file anticipate any additional to t h i s 20 MS. YUSUF: 21 MR. GIMBEL: statement? Objection. Objection 22 Q You can answer. 23 A I'm not going 24 anything. 25 Q Okay. that to f o r m . to a n t i c i p a t e Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 91 of 386 Page ID #:5261 Page 90 1 Allaham 2 - ATTORNEYS' Now, on t h e document, 4 number 5 whom 6 of t h e 7 State of Q a t a r , Emir, 8 Thani and Supreme 9 Delivery 10, you Hamad page front 3 10 first list will every and Legacy of t h i s document, foreign services registrant. Qatar ONLY page of t h e render primary EYES Tamim principal to in s u p p o r t And it s a y s , bin Hamad Committee Sheikh item Al for Mohammed bin Al T h a n i . " 11 Do y o u 12 A Yes. 13 Q And 14 number 15 working 16 Qatar, 17 include 18 relations 19 leadership 20 United 21 11, see then beneath it s a y s , to p r o m o t e and then that? "The the within better the in t h e see A Yes. 23 Q So my q u e s t i o n 25 Qatar, Cup in activities to international region with community the in t h e that? 22 whether began States." Do y o u 24 World its Gulf Jewish in b o x registrant 2022 expanded fostering that the that additional you have to y o u payments declined was from to i d e n t i f y , Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 92 of 386 Page ID #:5262 Page 91 1 Allaham 2 relate 3 this - ATTORNEYS' to a c t i v i t y that MS. YUSUF: 5 Counsel, I think 6 else -- 7 9 ONLY is d i s c l o s e d in statement? 4 8 EYES but MR. GIMBEL: objection. BY M R . WOLOSKY: Objection you meant I join to f o r m . something in t h a t Case Document 238-20 Filed 10/17/18 Page 93 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 94 of 386 Page ID MAG NAQ LEGAL SERVICES Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 95 of 386 Page ID #:5265 Page 94 15 Now, 16 references 17 Thani. 18 19 the in B o x Emir Is he y o u r A I mean, 10 it s a y s , Tamim bin it Hamad Al client? he is t h e Emir of Q a t a r . Case Document 238-20 Filed 10/17/18 Page 96 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 97 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 98 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 99 of 386 Page ID MAG NAQ LEGAL SERVICES Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 100 of 386 Page ID #:5270 Page 99 1 Allaham 2 Q EYES ONLY name in B o x Okay. 3 Now, 4 other 5 bin 6 reference 7 for than Hamad the the to t h e and What Committee for 10 A 11 takes the 12 takes place. second Emir, Al T h a n i , Delivery 8 9 - ATTORNEYS' is S h e i k h and Qatar there Mohammed is a Supreme Committee Legacy. is t h e Qatar Delivery and It is t h e whole 10 Supreme Legacy? building preparation Planning. where for the it workup Case Document 238-20 Filed 10/17/18 Page 101 of 386 Page ID MAG NAQ LEGAL SERVICES Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 102 of 386 Page ID #:5272 Page 101 9 10 Q Now, registration in y o u r statement, short you form refer FARA to M B H . Case Document 238-20 Filed 10/17/18 Page 103 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 104 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 105 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 106 of 386 Page ID MAG NAQ LEGAL SERVICES Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 107 of 386 Page ID #:5277 Page 106 25 MR. WOLOSKY: Can we j u s t take a Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 108 of 386 Page ID #:5278 Page 107 1 Allaham 2 five-minute 3 THE 4 11:16 5 record. 6 VIDEOGRAPHER: and we're (Thereupon, and then 8 follows:) 9 THE 10 start 11 The 12 back BY M R . the VIDEOGRAPHER: now on t h e labeled is 1 1 : 2 4 attention back 16 form registration I'd FARA 17 14. was the taken, continued There number a.m., as is t h e three. and to d i r e c t we're to E x h i b i t see your 1, t h e short statement. that? A Yes. Can you t u r n to page two, The question reads: What 21 22 compensation 23 received 24 the 25 like Do y o u 20 off is WOLOSKY: 15 Q time record. Q 19 going a recess 14 18 ONLY The proceedings of m e d i a time EYES break? a.m., 7 13 - ATTORNEYS' above or t h i n g s to d a t e of v a l u e or w i l l you box have you receive for services? What additional compensation Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 109 of 386 Page ID #:5279 Page 108 1 2 Allaham will you - ATTORNEYS' receive for the A I don't 4 Q Why 5 A Because we n e v e r 6 contract. 7 Q But do e x p e c t additional 9 services? do y o u you A Yes. 11 Q Do y o u 12 additional FARA 13 A That 14 Q I'd has that 16 identification been Statement 19 Agents 20 Amended, 21 2 for 22 date.) BY M R . 24 Q 25 filed know? had a written to r e c e i v e for the to m a k e in t h e above an future? be up to my l a w y e r s . to s h o w marked you Exhibit an e x h i b i t Number 2 for purposes. (Whereupon, 18 23 filing like 15 17 not expect will services? yet. compensation 10 ONLY above 3 8 know EYES Registration Pursuant to t h e Registration was marked Act Foreign of 1 9 3 8 , as A l l a h a m identification, as Exhibit as of t h i s WOLOSKY: It is a r e g i s t r a t i o n pursuant to t h e Foreign statement Agents Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 110 of 386 Page ID #:5280 Page 109 1 Allaham 2 Registration 3 with 4 by y o u 5 various the - ATTORNEYS' Act 15, Do y o u 7 A Yes. 8 Q Did before It w a s of J u s t i c e , 2018, you see you and A Yes. 11 Q And 12 agree 13 A 14 disagree. 15 told with filed and signed it c o n t a i n s you agree know document that 18 inaccurate? anything you believe 19 A I'm not sure. 20 Q Are you aware 21 under penalty 22 A Yes. 23 Q On p a g e 24 asks the 25 registrant. -- do y o u or my l a w y e r s so -- Is t h e r e 17 document if I a g r e e It is a d o c u m e n t me to r e a d , for this contents? I don't Q document? it? did its that review signed 10 16 ONLY exhibits. 6 9 of 1 9 3 8 . Department on J u n e EYES in t h e is f a c t u a l l y that you signed of p e r j u r y ? type one in b o x five, of o r g a n i z a t i o n 5A, of t h e it Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 111 of 386 Page ID #:5281 Page 110 1 Allaham 2 - ATTORNEYS' Do y o u see 3 A Yes. 4 Q And there Why has 5 6 A 7 idea. 8 Q 9 Lexington 10 EYES that? are no b o x e s it b e e n I'll ask What kind left Strategies, LLC, what no is type of entity? It s a y s 12 Q So it is an L L C ? 13 A It s a y s 14 Q Do y o u LLC. that, know number its one. date and place that field, of o r g a n i z a t i o n ? 16 A I'm 17 Q Do y o u was left not sure. know why 5B, blank? 19 A No, I don't. 20 Q Can you turn The top of t h e 21 I have of o r g a n i z a t i o n A 18 checked. blank? my l a w y e r . 11 15 ONLY to p a g e two, please. 22 23 "List all 24 of p e r s o n s 25 officer partners, officers, performing or d i r e c t o r page the of t h e 5G s a y s , or d i r e c t o r s functions of an registrant." Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 112 of 386 Page ID #:5282 Page 111 1 Allaham 2 - ATTORNEYS' Do y o u 3 A Yes. 4 Q Listed 5 who I believe 6 you A Yes. 8 Q And perform for It s a y s 11 Q Well, 12 what functions Support 14 Q Does 15 communications 16 of Q a t a r ? 17 A Not 18 Q Does 19 communications 20 A No. 21 terms of w h a t 22 Q 23 LLC? position, but perform? officials directly, she in Nick I mean State no. engage with of t h e in Muzin? communications in of c o m m u n i c a t i o n ? text messages, phone calls? 24 25 she she director. her engage with E-mails, wife. me. she sort does Strategies, managing does A is y o u r functions that's 13 Allaham correct? Lexington A is L a u r e n testified what 10 ONLY that? here Is t h a t 7 9 see EYES A baby I mean, he w i s h e d her I'm sure "mazel when tov." she had a Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 113 of 386 Page ID #:5283 Page 112 1 Allaham 2 Q - ATTORNEYS' Any 3 the work 4 State 5 A No. 6 Q Were EYES communications performed ONLY relating by L e x i n g t o n for the of Q a t a r ? 7 electronically 8 in r e s p o n d i n g 9 you? 10 MS. her documents stored to t h e and information subpoenas YUSUF: searched served A No. 12 Q They 13 A No. 14 Q Does Lexington Strategies, other employees or o f f i c i a l s any were not 15 have 16 other 17 A No. 18 Q Who is E m m a 19 A She is t h e 20 would 21 Q than you and on Objection. 11 22 to searched? Lauren LLC, Allaham? Hitchcock? house assistant, I say. Does businesses 23 A 24 helps 25 something she or j u s t I mean, me w r i t e , do w o r k for personal for the if I n e e d in E n g l i s h . your work? family, usually to w r i t e My E n g l i s h is n o t Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 114 of 386 Page ID #:5284 Page 113 1 Allaham 2 perfectly 3 Q 4 good professional 6 Q 7 services 8 of y o u r 9 will MR. WOLOSKY: She will for you business Strike perform that. occasionally that are perform in f u r t h e r a n c e interests? A Personal Q And furtherance or b u s i n e s s , did she of y o u r A I'm 14 Q Were not if I a s k her electronically 16 in r e s p o n s e to t h e 17 served you? upon 18 A I'm 19 Q Does 20 issue 21 A have not But 24 A I don't first time work in Qatar? and information subpoenas Hitchcock on y o u r issued Q The documents Emma 23 for any that searched were sure. I mean, never work stored statements perform sure. 15 25 occasionally or -- 13 22 ONLY her. 11 12 EYES in w r i t i n g . So s h e 5 10 - ATTORNEYS' she occasionally behalf? -- n o t often, no. I -- occasionally? was know the about one occasionally. that you named. Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 115 of 386 Page ID #:5285 Page 114 1 2 Allaham The 3 4 - ATTORNEYS' Q from You're Politico referring Yes. 6 Q -- t h a t 7 A Yes. 8 Q Did Tablet No, 11 was in t h e 12 getting 13 ever this 15 and article that issue day, hospital a lot about earlier? statements to behalf? I have with of p h o n e So I w o u l d 14 is -- my l a w y e r to s a y , my w i f e I and I was is. And calls. not say she is i n v o l v e d in i t , my l a w y e r . 16 MS. 17 Don't 18 privileged. 19 question, 20 anything 21 A YUSUF: She not testify You but 23 instructions. 24 MR. does do it w i t h o u t pending Objection. to a n y t h i n g can don't answer testify that's his to privileged. 22 25 we t a l k e d she on y o u r A to t h e -- A 10 ONLY statement. 5 9 EYES not do it -- s h e did my l a w y e r s ' s WOLOSKY: question? Can you read the Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 116 of 386 Page ID #:5286 Page 115 1 Allaham 2 - ATTORNEYS' (Record A Yes. 4 Q On t h e 5 "Give a complete 6 ownership 7 And 8 meaning Miss Allaham, 9 meaning you, "co-owned 10 it s a y s , Strategies, 11 page statement control two, of t h e of t h e managing "and Do y o u A Yes. 13 Q What the member," Lexington of L e x i n g t o n see that? percentages Strategies, I don't know do y o u 16 head. 17 Q Who 18 A I will 20 Q Would 21 A Yes. 22 Q Would 23 A No, the accountant 24 Q Can you turn would each own LLC? A 25 registrant." director," 15 19 5J r e a d s , LLC." 12 14 same "The ONLY read) 3 and EYES off the top of my know? find out and get back to you. Now, your accountant Miss Allaham we've know that? that? probably. to p a g e already know three. discussed the Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 117 of 386 Page ID #:5287 Page 116 1 Allaham - ATTORNEYS' and 2 Emir and MBH 3 work performed 4 matter 5 registration by y o u of w h a t ' s 6 which work -- t h e i r 8 that was 9 was the same 10 subject 11 concerning 12 statement? 14 A 15 question. 16 Q very the to s a y the work previous short form MR. GIMBEL: I'm not That's the to t h e work Strategies was the testimony registration Objection understanding because form 1. that that to t h e subject short by L e x i n g t o n as t h e FARA to f o r m . the forms are complicated. 18 I'll 19 Do y o u 20 is t h e relationship of y o u r 13 that is E x h i b i t performed ONLY relationship called Is it f a i r 7 17 their EYES come see back to i t . in b o x eight it s a y s activities? 21 A Yes. 22 Q The 23 to t h e 24 B to t h i s 25 are you question activities described statement, engaging reads, now will "In addition in a n y you Exhibit engage in a c t i v i t y or on y o u r Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 118 of 386 Page ID #:5288 Page 117 1 Allaham 2 own 3 your behalf - ATTORNEYS' which foreign 4 A Yes. 6 Q And 7 there see then is no b o x Do y o u A Yes. 10 Q Do y o u it s a y s 13 Q Can 14 A I don't why you answer have but no b o x is the any question? further engagement. 16 Q 17 then? 18 A Yes. you? I'll check Q Now, Exhibit for Exhibit 22 A 23 is B? 24 25 or n o , checked? No. 21 yes that? know A 20 of that? see 12 19 or a l l checked. 9 15 any ONLY principals." 5 11 benefits Do y o u 8 EYES So t h e Do y o u is e f f e c t i v e l y want no, me to c h e c k it it. B, c a n you flip to B. Where They are MS. Q answer is E x h i b i t not YUSUF: Do y o u see B? Which marked. Keep flipping. Exhibit B? one Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 119 of 386 Page ID #:5289 Page 118 1 Allaham 2 - ATTORNEYS' I'm 3 end. 4 complicated. sorry. As I s a i d , 5 MS. A Yes, 7 Q Okay. 8 9 10 way down appropriate FARA I see Do y o u the the see A Yes. 12 Q And 13 four, 14 substance, 15 pursuant 16 You five, then with 19 not 20 Qatar whether check 21 answer 22 I'm not the are Go b a c k . B. about two-thirds it s a y s , your of "Check and an e x p e r t asks choices, you, agreement in is contract. box. because your in t h i s to a f o r m a l why you written that My l a w y e r s you far. Four described pursuant A Too it g i v e s or s i x . Is t h a t 18 towards statements page to a f o r m a l 17 ONLY box"? 11 didn't It's YUSUF: 6 EYES did why agreement statement written this not. on f i l i n g . is contract? so I c a n n o t It is n o t -- Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 120 of 386 Page ID #:5290 Page 119 3 Q Box number 4 no f o r m a l 5 has 6 correspondence." 7 Do y o u written resulted A Yes. 9 Q Was 10 an e x c h a n g e 11 A 12 to a n s w e r 13 more 14 15 17 check 18 Q it. 21 engagement? more it. was that not result of my l a w y e r he k n o w s this GIMBEL: question. I should I checked an e x c h a n g e you and led to y o u r meeting I'm it. of your correspondence, of an o r a l MR. you to me t h a t between It w a s to t h e like because asking check principal 24 the -- So t h e r e foreign 25 I'm I'll 20 it w a s agreement I would It l o o k s correspondence 23 of that? question because A agreement it. 19 22 is of c o r r e s p o n d e n c e ? Well, question A your that Q 16 see "There The an e x c h a n g e I think about says, contract. from 8 five no, agreement. going to o b j e c t It m i s s t a t e d his Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 121 of 386 Page ID #:5291 Page 120 1 Allaham - ATTORNEYS' 2 testimony. 3 Q 4 agreement 5 foreign 6 a formal 7 of c o r r e s p o n d e n c e . Box six asks between the written contract 9 A I see 10 Q Now, 11 situation 12 of Q a t a r ? 13 A and see your of n e i t h e r an e x c h a n g e accurate engagement I should 14 lawyer 15 have they 16 I have been in t h i s . 17 better than me. 18 to c h e c k involved boxes nor the that. Again, been result and that? is t h a t because the registrant is t h e Do y o u ONLY whether principal 8 EYES a lot So t h e y or u n c h e c k this answer in t h i s not by t h e refer would I'm as to y o u r going can State to my -- t h e y more than answer to be a b l e boxes. Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 122 of 386 Page ID #:5292 Page 121 1 Allaham 2 Q 3 then? 4 A 5 that. 6 Q - ATTORNEYS' Why wasn't I think For 7 form 8 description 9 the oral you of t h e agreement 10 duration, the 11 to be r e c e i v e d . fees to g i v e terms and didn't 13 MS. YUSUF: What 15 Q Box are situations where 17 written 18 correspondence. 19 Do y o u 20 A I see 21 Q The 22 this 23 complete 24 conditions 25 situation answer the FARA a complete and conditions of its if a n y , do t h a t ? Objection to f o r m . reading? six, there contract should expenses, you number 16 checked or u n d e r s t a n d i n g , You A box ONLY situations, 12 14 this my l a w y e r these instructs EYES which applies is n e i t h e r nor exchange see that? in a formal of that. FARA form you're description of t h e Do y o u supposed of t h e oral see indicates to g i v e terms agreement. that? that and in a Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 123 of 386 Page ID #:5293 Page 122 1 Allaham 2 - ATTORNEYS' MS. YUSUF: 3 leaving a word 4 "complete 5 A Yes. 6 Q Okay. out. MS. YUSUF: 8 be on t h e 9 below. So I j u s t 10 because the 11 Q is d i r e c t i n g 13 A I don't 15 Q I'm 16 "Describe 17 performance 18 agreement 19 fully the of t h e A Yes. 21 Q And 23 World work 24 and 25 to i n c l u d e Cup Qatar. to reflect. So c o u n s e l seven. seven? a box. It's nature question and seven. method of above-indicated or u n d e r s t a n d i n g . " 20 of t h e see appears to be c l e a r won't box sorry. Do y o u 22 want us to b o x 14 there is c o r r e c t . see -- a description record Do y o u below below." And document you're It s a y s description Counsel ONLY Counsel, 7 12 EYES see now began you wrote, to p r o m o t e in Q a t a r , The that? in t h e the United understanding relationship "The was building nature 2022 States expanded with the Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 124 of 386 Page ID #:5294 Page 123 1 Allaham 2 leadership 3 United 4 relations. 5 included 6 engagement, 7 arranging 8 and 9 1.45 10 - ATTORNEYS' in t h e States to b e t t e r Methods peaceful charitable The million disbursements, 12 A Yes. 13 Q Now, 14 the 15 Cup, 16 work began in t h e international of c o m m u n i t y contributions, United grant States was for operating This USD see this expenses." that? answer to p r o m o t e reflects the 2022 that World correct? A and compensation, and Do y o u community in t h e initial for ONLY of p e r f o r m a n c e means meetings Qatar. 11 Jewish EYES is w h a t it r e a d s , yes. Case Document 238-20 Filed 10/17/18 Page 125 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 126 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 127 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 128 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 129 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 130 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 131 of 386 Page ID MAG NAQ LEGAL SERVICES Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 132 of 386 Page ID #:5302 Page 131 24 25 Q Can you Question turn nine to t h e reads: next page. "Will the Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 133 of 386 Page ID #:5303 Page 132 1 Allaham - ATTORNEYS' EYES 2 activities on b e h a l f of t h e 3 principal" -- t h a t ' s the 4 "include 5 in S e c t i o n 6 the political footnote 7 8 A Yes. 9 Q And or 1 - 0 see there whether political 11 engaged in on b e h a l f 12 principal. Why A in c o n t a c t 16 my -- t h r o u g h o u t 17 with 18 officials 19 Q the answer as d e f i n e d act in that? of t h e with I never any checked will for be foreign -- s i n c e I never your to t h i s was throughout I started interacted -- A m e r i c a n So t h e n -- I n e v e r official work with any officials. testimony question 21 A Yes, 22 Q Do y o u know to c h e c k 23 -- is t h a t ? 15 20 MBH of t h e activities Because Qatar, and is no b o x 10 14 Emir foreign below." Do y o u 13 above activities one-zero ONLY we s h o u l d why is t h a t should do a " n o " no w a s be n o ? here. not checked? 24 A I have 25 Q And who are the with my l a w y e r s . lawyers that Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 134 of 386 Page ID #:5304 Page 133 1 2 Allaham filled 3 out A these I'm 4 who 5 that day, 6 know who 7 definitely, 8 need 9 boxes. 10 - ATTORNEYS' was was my l a w y e r with 12 form? 13 A No. 14 Q Was Alan preparation 15 preparation 16 registration No. 18 Q Was preparation 20 registration Engle. did 21 A No. 22 Q Was the 24 registration it, raise traveling So I d o n ' t but I will it w i t h We h a v e FARA Brafman him. We unchecked Dershowitz filing Abbe and 23 was involved in registration involved of t h i s in t h e FARA form? A 19 this of t h i s Ben and 17 A because boxes. Was the 25 sure please, 11 filing behalf? and to c h e c k Q on y o u r Craig took ONLY forms not dealing EYES filing involved of t h i s in t h e FARA form? Michael and No. Lowell Bhargava preparation form? involved of t h i s FARA in Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 135 of 386 Page ID #:5305 Page 134 1 Allaham 2 Q 3 three - ATTORNEYS' Can you of E x h i b i t 4 MS. please turn YUSUF: Which Q Same exhibit, 6 A More boxes? 7 Q More questions. 9 So q u e s t i o n response to q u e s t i o n 10 registrant began 11 2022 Cup 12 its 13 relations World Does 15 MS. the that YUSUF: word, 17 reflect 18 relations." 19 Q within so I j u s t it s a y s "Better the eight, and Gulf Gulf mean You then in the expanded fostering better region." -- the "better skipped record a to international international region." write "The Counsel want 2. to p r o m o t e to i n c l u d e 16 20 Exhibit working within 14 to p a g e exhibit? eight. in Q a t a r activities ONLY 2. 5 8 EYES relations Case Document 238-20 Filed 10/17/18 Page 136 of 386 Page ID MAG NAQ LEGAL SERVICES Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 137 of 386 Page ID #:5307 Page 136 5 6 Q you 7 8 used the A put 9 10 What so I ' m Q 11 term that A is y o u r term means? you 13 have have 14 politicians. 15 touch with 16 chose to do it n o t 17 was 18 since 19 or w a s 20 politician. -- if y o u ' r e never that 23 other of about FARA. to r e g i s t e r in t o u c h In my c a s e , politicians, with I was but never to v i o l a t e any law. shook a politician And same sidewalk then it g o e s sentence, consultants Yes. "And time that? hand on to s a y working I given, of a to Q a t a r . " see in my l a w y e r s I started, on t h e To if y o u at a n y Do y o u A understanding time, same 24 to at a n y Q 22 decided no i d e a me, 25 was as sure. What 12 21 FARA my l a w y e r s not I have activity," there? I think it, what is " n o n - F A R A with in Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 138 of 386 Page ID #:5308 Page 137 1 Allaham 20 21 22 23 24 25 Q with But - ATTORNEYS' EYES it is f a i r to s a y ONLY you worked him? A we b o t h Q messages I mean, our interests But exchanged align. -- with you him? WhatsApp So Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 139 of 386 Page ID #:5309 Page 138 1 Allaham - ATTORNEYS' 2 A Yes. 3 Q You 4 exchanged e-mails 5 documents with 6 A spoke 7 to h i m and him, Yeah, make, MR. GIMBEL: can you 9 A I mean, yes. 10 Q Why you A 13 don't 14 volunteered 15 use know -to f o r m . answer. did Because have have an e - m a i l it w a s an e n c r y p t e d for encrypted account. me to h a v e and I So N i c k one. I rarely it. Q Were you ever a subagent of Stonington? 18 A No. 19 MR. 20 for 21 Q GIMBEL: a legal Objection. Calls conclusion. Okay. 22 Now, 23 that 24 financial 25 of at S t o n i n g t o n . c o m ? 12 17 drafts Objection You 16 phone, correct? Q address ONLY on t h e working 8 11 EYES page, if y o u there go to t h e is a s e c t i o n information. Do y o u see that? bottom called of Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 140 of 386 Page ID #:5310 Page 139 1 Allaham - ATTORNEYS' 2 A Yes. 3 Q And 4 incoming 5 dollars. this, initial 6 Do y o u 7 was r e ce i ve d 2017. 10 A Yes. 11 Q Under plan to p r o m o t e 13 Do y o u 14 MS. 15 2022. 16 Q promote 18 19 see It 9 17 grant Yes. Q 12 again, A 8 A Yes. it s a y s , World Cup a copy I think "Developed World Cup see the million in O c t o b e r have Sorry. Do y o u describes of 1 . 4 5 purpose, 2002 ONLY that? YUSUF: 2022 EYES "Develop in D o h a . " of t h a t you plan in D o h a . " that? of plan? mean to Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 141 of 386 Page ID #:5311 Page 140 24 Q 25 says, The "Work last sentence entailed making under FARA purpose and Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 142 of 386 Page ID #:5312 Page 141 1 Allaham - ATTORNEYS' 2 non-FARA-related 3 Do y o u 4 A Yes. 5 Q What 6 A I'm 9 non-FARA. not 10 was 11 on t h e sure see that? non-FARA-related dealing 14 where 15 consultants it s a y s A No. 18 Q And to i t . Yes. that in. consider FARA or my u n d e r s t a n d i n g politicians I never I leave "working to Q a t a r , " 17 put to m e , to q u e s t i o n Do y o u A they which Before to go b a c k 16 with hill, Q my l a w y e r s what FARA, 13 20 expenditures." are Again, 8 19 ONLY expenditures? 7 12 EYES see Yes, and lobbying did. this eight with page, I want briefly, other at t h e end. that? on e i g h t , I apologize for yes. coming back Case Document 238-20 Filed 10/17/18 Page 143 of 386 Page ID MAG NAQ LEGAL SERVICES Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 144 of 386 Page ID #:5314 Page 143 20 A No. 21 Q Can 22 same exhibit, 23 you Exhibit At t h e 24 9B, Receipts, 25 "During the turn top Things period to p a g e four of t h e 2. of t h e page, of V a l u e beginning question reads, 60 d a y s prior Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 145 of 386 Page ID #:5315 Page 144 1 Allaham - ATTORNEYS' 2 to t h e date of y o u r 3 to t h e time of f i l i n g 4 you 5 named in i t e m 6 other than 7 for receive from seven 8 Do y o u 9 A Yes. 10 Q You'll 11 "yes" 12 the box form 13 nor foreign did principal anything see of v a l u e as c o m p e n s a t i o n , that? note Do y o u A Yes. 15 Q Do y o u that "no" neither box the is c h e c k e d on see that? know why neither box was checked? 17 A No, 18 Q Do y o u 19 statement, is f i l e d . 14 16 to r e g i s t e r or o t h e r w i s e . " the that this either disbursement, ONLY obligation any money EYES the question 20 A No. 21 Q Did any I don't. know that you, 22 from foreign 23 seven 24 A Where 25 Q Item anything what the 9B p o s e s is? Mr. Allaham, principal of v a l u e is i t e m seven answer named other receive in i t e m than money? seven? is t h e box to that Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 146 of 386 Page ID #:5316 Page 145 1 2 Allaham includes - ATTORNEYS' the Emir 3 A No. 4 Q And 5 Supreme the The whether 8 value 9 entities you from for any of t h o s e than MS. YUSUF: 11 question says. 12 period beginning 13 So t h e question and the & Legacy. is a s k i n g received other 10 of Q a t a r Delivery question have ONLY MBH. State Committee 6 7 and EYES you anything persons of or money? That's It s a y s , 60 d a y s does have not what "During prior the the to." a qualifier. Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 147 of 386 Page ID #:5317 Page 146 17 A The Sheraton, usually, I like, I get my p o i n t s on S P G . I like 18 because 19 SPG points, 20 and SPG, 21 vacation. 22 Q and usually that's Question 23 period 60 d a y s " 24 period beginning 25 of y o u r gets how 10A me to M a r r i o t t we t a k e reads, -- s o r r y . 60 d a y s obligation our "During "During the the prior to t h e date to r e g i s t e r to t h e time Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 148 of 386 Page ID #:5318 Page 147 1 Allaham 2 of f i l i n g 3 disburse 4 connection 5 of a n y 6 seven." - ATTORNEYS' the any statement, money with foreign 7 8 A Yes. 9 Q And 10 it d o e s 11 bottom. say 12 "see Do y o u see see Yes. 14 Q So l e t ' s 15 A Attachment. 16 Q If y o u 18 says, 19 A Yes. 20 Q Do y o u 21 A Yes. 22 Q This 23 there named box go to t h e ahead is a s h e e t in i t e m but at t h e attachment. about of p a p e r question see on b e h a l f that? flip "Attachment, or of or in is c h e c k e d , attachment" A pages, spend that? "no" 13 17 you activities principal the did ONLY in f u r t h e r a n c e your Do y o u EYES four that 10A." that? is a l i s t of d i s b u r s e m e n t of m o n i e s . 24 A Yes. 25 Q Now, is t h i s a complete list of Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 149 of 386 Page ID #:5319 Page 148 1 2 Allaham that 3 A Yes. 4 Q -- in f u r t h e r a n c e that you was EYES money 5 the - ATTORNEYS' disbursed performed 6 A Yes. 7 Q Did you by t h e by y o u of t h e State disburse Dershowitz 9 performed by t h e State A Again, it is c l i e n t 11 does not only 12 work on m a n y 13 on m a n y 14 of t h e 15 Africa. work Arab with subject some 17 countries that are the 18 work Alan Dershowitz? 20 for 21 you're 22 business. Q 23 24 25 You on c o u n t r i e s A have them mentioned work relating I mean, in t h e regions East subject to s e n d Do y o u consult of t h e is s e a l e d If y o u welcome and or M i d d l e are Nothing you we What A work me on Q a t a r , Q 19 the he 16 with to A l a n -- a n d countries regions work of Q a t a r ? different different with -- of Q a t a r ? money 8 10 in c o n n e c t i o n ONLY other of y o u r yet. any or I'm open clients, over. Africa. with Alan Dershowitz to or in A f r i c a ? Morocco, I assume, is in Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 150 of 386 Page ID #:5320 Page 149 1 2 Allaham Q Do y o u Dershowitz 5 A No, I did job, but it w a s 7 account. I did 8 10 Q from A not you Mr. Not end get up g e t t i n g trying to g e t the the it. trying from Q Was Mr. to g e t the relating him, from Benomar were that you 15 work from Morocco? 16 A I mean, 17 "involved" 18 minister 19 interested, 20 the to officials hire You have I'm Dershowitz know I met with to g e t what the he w a s Did knowledge, to do w o r k not to a s k Q I don't in t h a t foreign not so -- Benomar A to t r y apparently To y o u r Mr. involved doing means. and Q 22 25 not Benomar work 24 Professor issues? -- I w a s 14 23 with of M o r o c c o . 13 21 ONLY Morocco? 11 12 Were account work on M o r o c c o 6 9 EYES Africa. 3 4 - ATTORNEYS' sure. him to do w o r k hire for for I don't that. Morocco did Morocco it? know. I do n o t know. Professor it, to y o u r Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 151 of 386 Page ID #:5321 Page 150 1 2 Allaham A No, 4 because 5 not 6 I recall 7 didn't 8 10 through king really And Dershowitz ONLY was how paid Again, with Japan, 15 not 16 me as a c o n s u l t a n t . just A but it w i l l But for open. -- w h a t e v e r Q 20 me. And so it the did work Professor for the the Objection. it's 14 other there, money for YUSUF: me is w i d e 19 through not much with did So it w a s effect. 13 18 it. me, of M o r o c c o ? A 17 through it w a s take get MS. 12 done I arranged Jamal, the Q State it w a s of m e , 11 21 EYES knowledge? 3 9 - ATTORNEYS' that State not -- h i s If I h a v e contract to w o r k be w i t h Japan. It's I do, he w o r k s with So -includes of Q a t a r , work that among you many countries? Israel Not many is o n e other countries of t h e m , for yet, example. Case Document 238-20 Filed 10/17/18 Page 152 of 386 Page ID MAG NAQ LEGAL SERVICES Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 153 of 386 Page ID #:5323 Page 152 21 Q 22 MS. 23 the 24 Q 25 So t u r n i n g question YUSUF: attachment, Yes, 10A. thank to t h i s Are you exhibit. referring Counsel? you. Attachment to to Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 154 of 386 Page ID #:5324 Page 153 1 Allaham 2 What 3 4 A that 5 helps Q soldiers And purpose 7 connection 8 doing 9 A for with the IDF and 11 something 12 Q State that Soldiers Speak? organization their families. it -- w h a t grant work was the to it in that you were of Q a t a r ? my c h o i c e . Israeli Who and was the ONLY Soldiers $100,000 It w a s the And soldiers, is v e r y is t h e dear I support and it is to m e . leadership of O u r Speak? 14 Who are the people you deal with there? 16 A 17 specific. 18 organization 19 organization. 20 how of t h e 10 15 is O u r EYES It is an I s r a e l i 6 13 - ATTORNEYS' I don't Q Same before 22 contribute thing or A P E C But 21 deal October who with with -- n o t IDF or -- it is a g e n e r a l did you call up on or 30th to s a y , "I w a n t $100,000 to y o u r organization"? 23 A It is o n e 24 Q What 25 honorary? of t h e is t h e name to honoraries. of t h e Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 155 of 386 Page ID #:5325 Page 154 1 Allaham - ATTORNEYS' 2 A Joe Cayre. 3 Q Can you 4 A Joe, 5 Q And 6 A American. 7 spell J-O-E; And or I s r a e l i ? he w a s being honored. And 9 A At t h a t 10 Q Where 11 A At a d o w n t o w n 12 I forgot. 13 Q 14 table 15 dinner? where was It w i l l And or s o m e t h i n g Yes. 17 Q Honoring 18 A Mostly the Q anything 22 Qatar? the further 23 A No. 24 Q To y o u r Qatari event. dinner to t h a t the hall or -- to m e . basically Mr. held? banquet come honored? bought effect, a at t h i s Cayre? organization because organization. Did 21 he b e i n g the so y o u A I like was dinner 16 25 C-A-Y-R-E. is he A m e r i c a n Q 20 ONLY that? Cayre, 8 19 EYES nationals organization to do w i t h knowledge, attend that have your did work any dinner? for Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 156 of 386 Page ID #:5326 Page 155 1 Allaham - ATTORNEYS' 2 A No. 3 Q When 4 to O u r 5 Soldiers 6 Qatar? you Soldiers Speak Speak, that 7 A They 8 Q Did 9 A I didn't 10 Q And 11 made you did ONLY contribution you money ask tell you the the didn't EYES me, tell came Our from so -- them? -- I w a s didn't not asked. volunteer the information? 12 A I was 13 Q So w h a t ' s 14 in y o u r 15 to p r o m o t e goodwill 16 recipients knowing 17 from 18 mind, not asked. the $100,000 purpose of g i v i n g , to an o r g a n i z a t i o n for Qatar that the without money the came Qatar? A I think 19 me, and 20 soldiers 21 with I know that because about are the held it is d e a r capture by H a m a s , many people involved, non-FARA, if y o u want. that to of and they I met want 22 23 24 25 So w e ' r e trying to Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 157 of 386 Page ID #:5327 Page 156 1 Allaham - ATTORNEYS' 2 recapture the alive 3 holding. And I wanted 4 that 5 something that 6 get bodies 7 many 8 the 9 topic it is v e r y those people main came percent of e v e r y 11 was top 12 captured 13 returned. me to s e n d 16 want this 17 that I asked 18 for And 19 an i m p o r t a n t 20 time 21 Qatar's 22 furthers that A paying 25 spend was how that for to be better for that we it is s o m e t h i n g to g e t it d o n e . agree I'm that having giving it is a hard $100,000 Soldiers of Speak goal. I have 1.6 But to O u r in, to my b o s s e s , day goal. 99 parents, and was leaders came nothing to and that say, to a s k , I certainly understanding money Jewish the a message every with, that list we w a n t parents I would to be d o n e , Q 24 the person So t h e r e 15 The to k n o w it is that I met even of t h e bodies, 14 23 who was Qataris to me a n d back. probably, ONLY Hamas the I support, 10 the bodies dear topic, was EYES a hard to a P l a y b o y my 1 0 0 , 0 0 0 time with model, a client so I t r y on an o r g a n i z a t i o n to rather Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 158 of 386 Page ID #:5328 Page 157 1 Allaham - ATTORNEYS' 2 than a Playmate. 3 with that, 17 18 Q And A how this 21 soldiers 22 Qataris 23 that 24 soldiers, 25 because So I h a v e a hard does goodwill further Because 20 ONLY time so -- contribution 19 EYES money this that goal? me -- my p o i n t , to an o r g a n i z a t i o n , -- a n d knew, I will coming that always and is t h a t me, which it is a b o l d support we w a n t I arranged from those many the giving the the statement IDF bodies meetings and the back with the Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 159 of 386 Page ID #:5329 Page 158 1 Allaham 2 ambassador 3 general 4 and 5 So w a s 6 other 7 Q - ATTORNEYS' of G a z a of t h e I hope Israel those just for EYES the Qatari IDF. bodies a statement ONLY with We d i d will and a lot, be r e t u r n e d . support for soldiers. Did you discuss the the return of Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 160 of 386 Page ID #:5330 Page 159 17 Q And 18 November 19 Organization 20 the 2, 2 0 1 7 , was contribution, to Z i o n i s t of A m e r i c a , What was 21 A For 22 Q Is t h a t 23 next that a table $50,000. contribution for that dinner. Morton Klein's attend that organization? 24 A Yes. 25 Q Did you for? dinner? Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 161 of 386 Page ID #:5331 Page 160 1 Allaham - ATTORNEYS' 2 A No. 3 Q Did 4 A Yes. 6 Q And your A Yes. 9 Q Why 10 attend 11 dinner? the 12 for 14 Q A 17 I was 18 have 19 would 20 Q 23 24 25 that that dinner at that out al-Rumaihi Organization GIMBEL: want to of A m e r i c a Objection. Calls you discuss -- y o u can question. know that of t o w n when he -- I d i d table, and I invited he s a i d him. not yes, he come. Zionist A people, United Mr. I don't a full Q did speculation. Did answer 16 22 he a t t e n d e d Zionist MR. 13 21 attend invitation? 8 15 al-Rumaihi ONLY dinner? 5 7 Mr. EYES Why did you Organization I just bodies Does States did invite of A m e r i c a not to f i l l Mr. have to t h e dinner? enough my t a b l e . Rumaihi to y o u r him live knowledge? in t h e Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 162 of 386 Page ID #:5332 Page 161 1 Allaham 2 A I'm 3 lives between 4 I don't 5 the ZOA 7 States? dinner, A the sure. Doha At t h e 6 9 not and That United time you he w a s dinner, States not Doha, Q Do y o u know 12 residence in t h e United 13 A I do n o t him to United was if I ' m if he h a s in not a States? know. A residence, a home? 15 Q Yes. 16 A From 17 nothing 18 an i n t e r e s t i n g 20 He States. invited I assume, 11 19 know. United in t h e mistaken. meaning ONLY I don't the 10 14 EYES know. Q 8 - ATTORNEYS' that Q what I read, I -- y o u figure In w h a t way know, in L A , the but Ahmed so I w a s n ' t is -- is he an i n t e r e s t i n g figure? 21 A He is j u s t an i n t e r e s t i n g 22 so I n e v e r -- he is t h e r e , 23 is t h e r e . So I d o n ' t 24 what his 25 have no c l u e . residence, know. figure he is h e r e , I don't if he o w n s , he know rents, I Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 163 of 386 Page ID #:5333 Page 162 1 2 3 4 Allaham Q United A - ATTORNEYS' Do y o u States know ONLY if he is in t h e currently? I do n o t EYES know. Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 164 of 386 Page ID #:5334 Page 163 9 10 Q Did during this you time speak to M r . period? 11 A No -- is he a l a w y e r ? 12 Q Mark 13 A Is he a l a w y e r ? 14 Q Yes. 15 A I did 16 name from Jeff. Geragos Geragos. not, but I have heard the Case Document 238-20 Filed 10/17/18 Page 165 of 386 Page ID MAG NAQ LEGAL SERVICES Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 166 of 386 Page ID #:5336 Page 165 12 Q The 13 form 14 Zionist 15 $50,000. is J a n u a r y 16 17 last disbursement 23, Organization What was I believe 19 Q Say 20 A I believe 23 purpose the for of t h a t contribution? A 22 again, of A m e r i c a the 18 21 2018, on t h i s 2018 for the ZOA dinner. it a g a i n ? it w a s for the ZOA dinner. Q funded That's with the 24 MS. 25 Misstates the same initial YUSUF: the dinner that grant? Objection. witness' testimony. was Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 167 of 386 Page ID #:5337 Page 166 1 Allaham 2 3 Q ZOA - ATTORNEYS' The dinner, 4 record grant 6 the 7 dinner? to Z O A was subsequent for the 2017 grant was for A I think 9 Q It d o e s n ' t that's 11 what 12 January 13 America. 14 15 what you're 23, A this is w h a t I'm Okay. 17 A I'll the 2018 but if that's says Organization really ZOA it s a y s . then It j u s t and recall 50,000, of the -- b u t assuming. invite you to t h e dinner of A h m e d . Q 20 I'd love MR. WOLOSKY: 21 natural 22 would 23 lunch. 24 25 the initial dinner that, saying, Zionist I don't instead for the what say saying. Q 19 that's you're 16 18 it w a s to c l a r i f y , 8 10 shows ONLY Z-O-A. So j u s t 5 EYES breaking propose THE lunch? that. I think point that WITNESS: we're here. we a d j o u r n Okay. How at a So I for long is Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 168 of 386 Page ID #:5338 Page 167 1 Allaham 2 - ATTORNEYS' MR. 3 that WOLOSKY: work for EYES An h o u r . THE WITNESS: 5 THE VIDEOGRAPHER: 12:29 p.m., 7 record. 8 and then the 10 follows:) 11 THE start 13 now is 1 : 3 5 14 the record. BY M R . 16 Yes. we're The going a recess proceedings of m e d i a labeled p.m., and time off was is the taken, continued VIDEOGRAPHER: 12 15 and (Thereupon, 9 Does you? 4 6 ONLY This number we're as is t h e 4. Time back on WOLOSKY: Q Good 17 afternoon, Mr. Allaham. Joey? 18 A Exactly. 19 Q I'd 20 attention 21 Politico 22 the 23 saying, 24 themselves 25 region, back like but to d i r e c t dated in w h i c h quote, afternoon. to E x h i b i t article article Good "'Qatar as t h e this 3. June you It's enjoys not the 7, 2 0 1 8 . were purveyor could your It's quoted as portraying of p e a c e in t h e be f u r t h e r from Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 169 of 386 Page ID #:5339 Page 168 1 Allaham 2 the truth,'" 3 in a s h a r p 4 position." - ATTORNEYS' closed reversal EYES quote, from ONLY "Allaham his past said Case Document 238-20 Filed 10/17/18 Page 170 of 386 Page ID MAG NAQ LEGAL SERVICES Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 171 of 386 Page ID #:5341 Page 170 12 Q 13 phone I'm records. 14 15 going to s h o w This You have MS. YUSUF: you again is E x h i b i t that binder your 7. in f r o n t of you. 16 17 Counsel? 18 19 Q 20 you're 21 the 22 that There I'll 23 WOLOSKY: And what numbers that took 25 of 2 0 1 7 . binder, two. It is b i n d e r I will tell you free to go f i n d that are 1. -- a n d these identified on -- identify. But 24 are MR. obviously page Which there place They were with are Mr. 11 p h o n e Benomar reflected calls in J u n e on p a g e s -- Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 172 of 386 Page ID #:5342 Page 171 1 Allaham 2 volume 3 336, 1 of E x h i b i t 338, 4 5 - ATTORNEYS' and 7 -- 3 1 5 , with Mr. MS. YUSUF: 7 MR. GIMBEL: 8 it a s s u m e s 9 record. 11 BY M R . Q Your in J u n e 13 is on p a g e began 329, that your in J u n e ? Objection. I would facts that are first call with of 2 0 1 7 14 315 MR. 15 counsel 16 Q to p a g e object not to on t h e GIMBEL: of V o l u m e Okay. 19 Q Okay. Now, 21 left-hand 22 number." 16th, Benomar and it 1. Objection Allaham, A 20 on J u n e Mr. to testifying. Mr. 315 was of V o l u m e 18 23 321, WOLOSKY: 12 17 to s a y Benomar 6 10 ONLY 345. So is it f a i r contact EYES if y o u column, Do y o u 24 A Yes. 25 Q And can please turn 1. look it s a y s see you in t h e "Calling that? 917-570-6132 is y o u r number, Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 173 of 386 Page ID #:5343 Page 172 1 2 Allaham - ATTORNEYS' A Correct. 4 Q And is M r . do y o u Benomar's A I assume 7 Q Okay. 8 10 I'm recollection messages are A 12 first 13 Q And 14 A Yeah. 15 Q Okay. No. So, 18 Mr. 19 begin between Benomar's on J u n e 20 that's if y o u your is t h e Benomar, right? Yes. 22 Q Okay. 23 And those see then calls But see, for there are phone and 917-442-7695, 16 at 2 0 : 5 5 A 25 WhatsApp 442 number number, Do y o u that the -- I remember 21 24 you your -- 16 calls to r e f r e s h by s h o w i n g that if 9 1 7 - 4 4 2 - 7 6 9 5 it i s . happy 11 17 know number? 6 9 ONLY correct? 3 5 EYES and that 55 s e c o n d s . that? I will represent to y o u continue. purposes of e s t a b l i s h i n g Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 174 of 386 Page ID #:5344 Page 173 1 Allaham 2 when you 3 Mr. 4 began facts BY M R . 9 began MS. YUSUF: not in e v i d e n c e . MR. GIMBEL: you 10 telephone calls with 11 16, 14 with that contact Objection. Objection Assumes to f o r m . WOLOSKY: Would 13 that ONLY of 2 0 1 7 . Q 12 EYES contact it a p p e a r s in m i d - J u n e 7 8 first Benomar, 5 6 - ATTORNEYS' agree Mr. that you Benomar had on J u n e 2017? A It s t a t e s of m e . Q Okay. it. I see it in f r o n t Case Document 238-20 Filed 10/17/18 Page 175 of 386 Page ID MAG NAQ LEGAL SERVICES Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 176 of 386 Page ID #:5346 Page 175 9 Q And 10 A I was him did I've for 12 probably, 13 So I a l w a y s 14 I had 15 his 16 discussion with him 17 make back then 18 the 19 whatever I've some point known liked 21 him 22 event; And around 23 what took you that, to a s k him something So I ' v e about and the how mentioned event? YUSUF: I don't and how to r e s o l v e the place. that A -- h a d uprising, was 25 if or -- f o r known Syria period, Misstates. years. affairs time 24 so, ten this MS. in 2 0 1 0 . for -- if I r e c a l l , that Jamal? him international peace meet in S y r i a before of v i e w . Q you working 11 20 known how that you 2017, met at an Objection. remember. It w a s some a to Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 177 of 386 Page ID #:5347 Page 176 1 Allaham 2 bar mitzvah 3 There's - ATTORNEYS' or w e d d i n g . a lot 4 Q Was 5 A Yes. 6 Q Was 7 it h e r e York? at y o u r A He w o u l d come often, Q So g o i n g back to y o u r I would trips to Qatar. Can I put 13 Q Oh, yes. 14 A I'm not can keep MR. it f o r BY M R . this taking away? this with me; you it. 16 18 in N e w he a p a t r o n A 17 sure. of t h o s e . 12 15 not say. 10 11 I'm ONLY restaurant? 8 9 EYES WOLOSKY: me? WOLOSKY: You can. You want to g r a b Case Document 238-20 Filed 10/17/18 Page 178 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 179 of 386 Page ID MAG NAQ LEGAL SERVICES Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 180 of 386 Page ID #:5350 Page 179 20 21 22 23 Q you When travel A travel you on y o u r What traveled U.S. other to Q a t a r , did passport? passport would I on? 24 Q Do y o u have 25 A I don't. any other passports? Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 181 of 386 Page ID #:5351 Page 180 1 Allaham 2 3 Q use - ATTORNEYS' You of t h e 4 testified Do y o u recall that? my p h o n e 6 Q And for you that 8 A Yes. 9 Q Who 10 phone that 11 phone number? 12 A Apple. 13 Q What 14 A Now? the you phone is t h e use what 17 A The one 20 21 22 the is S p r i n t . to c o m m u n i c a t e is t h e of t h e on t h a t phone? The latest one, 10. And 19 number Today? Q was that manufacturer model your number. testified 16 18 about 917-570-6132. That's 15 earlier number A carrier ONLY phone 5 7 EYES was it in 2 0 1 7 ? before it; whatever before. Q system A Do y o u is u s e d What know what on y o u r does operating current that phone? mean, "operating"? 23 Q IOS? 24 A I have 25 Q And you no i d e a . don't know what it Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 182 of 386 Page ID #:5352 Page 181 1 Allaham 2 operating 3 phone, system the one 4 A No. 5 Q And 6 mobile 7 documents 8 served - ATTORNEYS' phone was you you used available ONLY on y o u r previous in 2 0 1 7 ? -- d i d responsive you make your to be s e a r c h e d to t h e for subpoena on y o u ? 9 MS. YUSUF: 10 state 11 answer 12 anything 13 attorney-client 14 MR. 15 asked 16 with I'm an o b j e c t i o n . his that has going but to -- y o u don't can discuss to do w i t h privilege. WOLOSKY: anything just Don't question, I don't about think I communications attorneys. 17 Can 18 (Record you 19 A Yes. 20 Q Do y o u 21 used EYES re-read the question. read) have any other mobile phones? 22 A In t e r m s ? 23 Q How 24 have? 25 A many I only Meaning? mobile carry phones one. do y o u Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 183 of 386 Page ID #:5353 Page 182 1 Allaham 2 3 Q that 4 5 7 Okay. you don't A carry the phone number for phone? Do y o u 10 A Could 11 sure. 12 Q And know know manufacturer? it by h e a r t . the carrier? be S p r i n t , do y o u know maybe. I'm not the Is it A p p l e ? 14 A Yes. 15 Q And A It's do y o u know what model it is? so I ' m not 19 Q 20 available 21 responsive Did you to t h e No, 23 Q Have A since but you March Rephrase an o l d e r We d o n ' t make subpoena had phone for I don't documents served on y o u ? usually any other use it. mobile 1, 2 0 1 7 ? that. phone, know. that to be s e a r c h e d A phones definitely sure. 22 25 for the Q 24 one you? what's 9 18 we h a v e with others And I don't 17 around any as an e m e r g e n c y . A 16 have ONLY family 8 13 EYES entire Q that Do y o u I mean, whole, 6 - ATTORNEYS' Meaning? Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 184 of 386 Page ID #:5354 Page 183 1 Allaham 2 3 Q - ATTORNEYS' Have phones since 4 March MS. 5 just 6 You're 7 ones you had to u n d e r s t a n d referring he h a s already WOLOSKY: 9 MS. YUSUF: MR. WOLOSKY: BY M R . 13 Q that So y o u you Yes. 16 Q Last question. than the Yes. The 10 a n d the prior Yes. have year, I believe, a 10? you had the prior model? 18 A Yes. 19 Q Other 20 have 21 March 22 A No. 23 Q And 25 -- I identified? testified, currently A 24 your WOLOSKY: 15 17 mobile one. 11 14 your to o t h e r MR. 12 other Counselor, 8 10 any ONLY 1, 2 0 1 7 ? YUSUF: want EYES you you had any than those other two mobile phones, phones since 1, 2 0 1 7 ? other than testified about. A I don't. No, the family phone Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 185 of 386 Page ID #:5355 Page 184 1 Allaham 2 3 Q - ATTORNEYS' Do y o u landline telephones, 4 A Yes. 5 Q What's 6 have landline any the phone I have no i d e a . 8 Q Do y o u know 9 A I assume probably. 11 Q Spectrum? 12 A Probably. 13 Q Is t h a t 14 A It's Q I have sophisticated. Q number 22 25 like the the your provider is? company? cable and So is it an I P - b a s e d A 20 24 for Spectrum, a cable is it a t r a d i t i o n a l 18 23 number everything. 16 21 who it's 10 19 home? phone? A 17 ONLY landlines, at y o u r 7 15 EYES no i d e a . I don't Do y o u for landline ever A I could Q Do y o u or phone? I'm not that know. use work-related phone, that home phone calls? -- 99 p e r c e n t point 9, no. at y o u r business? have landline telephones Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 186 of 386 Page ID #:5356 Page 185 1 Allaham 2 - ATTORNEYS' MS. YUSUF: EYES ONLY Objection. 3 A No. 4 Q Do y o u ever use burner 5 A What's a burner phone? 6 Q Do y o u ever temporary 7 that you use only 8 time for a specific 9 A No, 10 Q When 11 use 12 iPhone 13 14 that A you're A 18 my p h o n e s 19 usually phone you 22 iPhone 23 your you 25 would travel or y o u r testified to Q a t a r , phone do y o u -- y o u r about? my p h o n e . ever use My p h o n e is have other phones on b u s i n e s s ? Sometimes, don't used 10 t h a t previous A purpose? in Q a t a r When that of the driver's, connections if or -- b u t my p h o n e s . Q 24 you No. 21 period never. Do y o u 17 20 a short phones in Q a t a r . Q when for Usually, working 15 16 another use phones? you in 2 0 1 7 you for use, your the did phone current you destroy phone? I don't usually replaced think exchange I destroyed it, yes, it. swipe it. I Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 187 of 386 Page ID #:5357 Page 186 1 Allaham 2 3 Q - ATTORNEYS' Do y o u have A I don't 5 Q To t h e what 7 possession happened A believe best to t h a t it g e t s mailed I believe. Every 9 comes 10 Q 11 contacts? 12 A On my p h o n e . 13 Q On t h e 14 A Yeah. 15 Q -- a p p l i c a t i o n ? 16 A Not out, I just How knowledge, phone? I'm trade do y o u Apple. new phone in. maintain Apple back. your contacts Whatever -- is on t h e phone. 18 Q 19 other 20 A Do y o u format maintain contacts in a n y or l o c a t i o n ? No. 21 MS. YUSUF: 22 You can answer. you provide 23 A No. 24 Q Did 25 of it no. old I think on a p l a n , so, of y o u r 8 17 ONLY today? 4 6 EYES be s e a r c h e d for Objection documents your to f o r m . contacts responsive to to Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 188 of 386 Page ID #:5358 Page 187 1 2 Allaham the - ATTORNEYS' subpoena 3 served MS. A I gave 5 Q And 6 A Yes. 7 Q What 8 communicate devices text A My c e l l 10 Q Is it t h e phones that A Yes. 13 Q And 14 communicate 15 You 16 A 17 WhatsApp. 18 Q 19 additional 20 A use that usually -- I d o n ' t 25 A other are you Mostly and use to correct? apps I use is of t h e use? That's apps, use but usually what I don't them. some occasionally phone do y o u some text. 22 you to message? are what I have that services And What use discussing? WhatsApp, I use. 24 cell of t h e I use Q same I -- o n e apps contacts? message? text 21 23 do y o u been what via your phone. we've 12 to f o r m . my p h o n e . 9 11 Objection it i n c l u d e d via ONLY on y o u ? YUSUF: 4 EYES of t h e use? WhatsApp. other apps Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 189 of 386 Page ID #:5359 Page 188 1 Allaham - ATTORNEYS' 2 Q Do y o u 3 A Very 4 Q Do y o u 5 to Q a t a r . 6 use ONLY Signal? rarely. use it f o r work relating Possibly? 7 A No. 8 don't usually 9 Q Do y o u use 10 A What's Telegram? 11 Q It's 12 A I don't 13 Q Do y o u 14 A I don't 15 Q Do y o u 16 A No. 17 Q Do y o u 18 A Yes. 19 Q Do y o u 20 communications 21 Qatar? They have -- t h e y on S i g n a l . Telegram? an a p p . believe use No. 23 Q Do y o u 24 A I don't I have believe so. use Skype? use FaceTime? use FaceTime use it. Wickr? relating A my F a c e b o o k . don't communicate 22 25 EYES to y o u r Facebook even for know work for Messenger? how to go on Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 190 of 386 Page ID #:5360 Page 189 1 Allaham 2 3 Q - ATTORNEYS' Do y o u A 5 LinkedIn. 6 Q Do y o u 7 A No. 8 Q Did 10 I don't messages A have 13 you to t h e no i d e a Did what you 14 searched for 15 subpoena served 16 use I mean, Q A day, and 18 manage. know to that's how to go on GroupMe? provide your for subpoena I gave they Signal documents served on y o u ? my p h o n e , were provide documents so I looking your for. texts responsive to be to t h e on y o u ? Again, 17 even to be s e a r c h e d responsive 11 12 LinkedIn ONLY communicate? 4 9 use EYES I gave very Do y o u my p h o n e hard 19 Q backup 20 regularly 21 A I have no i d e a . 22 Q Do y o u know 23 automatic 24 25 for your for the me to device to i C l o u d ? if y o u backups on i C l o u d ? A I'm aware Q Do y o u not have disabled of i t . any computers at Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 191 of 386 Page ID #:5361 Page 190 1 2 Allaham your - ATTORNEYS' A 4 kids. 5 Q You 7 A Never, no. 8 Q Do y o u use 9 A Mostly, 10 Q So y o u 11 Not mine. I never use that you A use. For the it. don't use any computers at use have not don't at y o u r 14 years. had your have use any Q Do y o u 16 A Meaning 17 Q Yes. 18 A When 19 Q Do y o u use computers computer. probably my b r a i n , 15 any office? a computer I have iPhone? yes. I don't 13 any A No. 22 Q What communicate I in t e n so -tablets? iPad? I watch use shows, them usually. for communications? 21 23 I never all? 12 20 ONLY home? 3 6 EYES devices do y o u by e - m a i l ? 24 A My p h o n e . 25 Q Not your computer? use to Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 192 of 386 Page ID #:5362 Page 191 1 Allaham 2 - ATTORNEYS' MS. 3 A No. 4 Q Not 5 A No. 6 to t e l l you 7 I don't like 8 use 9 10 Q with 13 14 it's have all a tablet, greasy to t o u c h it. We're glad you use A software I have broken, so my k i d s bring to c o m p o s e , Whatever applications read, and send is on -- I h a v e it do e-mail? in my phone. Do y o u know 16 A I have no i d e a . 17 Q Do a l l of y o u r accounts go i n t o the Correct, if i t ' s A 20 which I don't 21 Q But 22 A I have the 23 Q That's right. Have application use, you except called e-mail display? the Proton, usually. have you Outlook? various same 19 25 I see but you. Q 24 and didn't 15 18 a computer. tablet? I have What you Objection. I do n o t your ONLY it as a -- 11 12 YUSUF: EYES a Proton Stonington. ever used an Thunderbird? account? Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 193 of 386 Page ID #:5363 Page 192 1 Allaham - ATTORNEYS' 2 A No. 3 Q Can 4 addresses 5 or b u s i n e s s 6 A that you tell you use me t h e for Mostly, 8 Joey@alexisstrategies, 9 joey@Stonington. 11 e-mail either personal my josephallaham@gmail.com. Q ONLY activities. 7 10 EYES I believe and your icloud.com, iCloud e-mail and is joeyallaham@icloud.com. 12 Does that 13 A Probably, 14 Q Do y o u sound right? yes. still have access 15 e-mail 16 joey@stoningtonstrategies.com? to y o u r address 17 A Yes. 18 Q Do y o u 19 A Not 20 Q What is A l e x i s 21 A It's just 22 I wanted 23 Alexis, 24 never 25 many use set ended up t h e e-mail regularly? at a l l . to -- I w a s and that Strategies? a website. debating up w i t h e-mail addresses, You Lexington Lexington, because and know, that but I have was or the I too Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 194 of 386 Page ID #:5364 Page 193 1 2 Allaham e-mail 3 4 - ATTORNEYS' I landed Q with. is y o u r Alexis e-mail address for 5 A I think 6 Q Joey@. 8 And does anyone alexisstrategies.com A No. 10 Q Is A l e x i s 11 A No. 12 Q It's 13 A A domain. 14 Q A domain. 15 A I own 16 just every 17 like to b u y 18 have that 20 21 22 23 24 25 Q already, just time it. an e - m a i l 100 I come but A Q It's a name, I used confirmed The that hosts the e-mail address Sorry. entity to this correct? Again? I I stopped. stoningtonstrategies.com ProtonMail, a company? domains. $12. you entity an address? up w i t h I spent have address? Strategies So I t h i n k the else e-mail maybe sickness, but -- joey@alexisstrategies. 9 19 ONLY So w h a t Strategies 7 EYES that stoningtonstrategies.com h o s t s the e - m a i l address is Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 195 of 386 Page ID #:5365 Page 194 1 2 Allaham that you - ATTORNEYS' have EYES -- 3 A Yes. 4 Q -- is P r o t o n M a i l ? 5 A Yes. 6 Q Why 7 necessary 8 e-mail 11 did to h a v e MS. A Told 13 A I mean, 15 it, 16 e-mail 17 Nick 19 the 20 read a lot address Muzin's a safer that recall, but it -- a l o t Proton is t h e about safest to h a v e . it y o u r idea to h a v e idea, or w a s ProtonMail stoningtonstrategies.com e-mails? A the No, person; 22 efficient 23 Q 25 it's I don't I read So w a s 21 24 that by w h o m ? -- I m e a n , Q 18 Objection. address. Q it's it w a s a ProtonMail-linked told 12 14 feel YUSUF: I was e-mail you address? 9 10 ONLY I think he s u g g e s t e d it w a s that's the it host tech best, most way. The tech The guy person at w h i c h company? A who I told you I use. Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 196 of 386 Page ID #:5366 Page 195 1 Allaham 2 Q 3 Nick? 4 A 5 Nick - ATTORNEYS' So, then, No. Well, to do h i s 6 And real did estate. 8 another website 9 concept to do p o p - u p s . it's 11 part of t h e 12 13 websites, 14 and 15 Proton, 16 government 17 18 that's and Q the you you and And, stuff, I'm can check that Baskhar him it does to N i c k , -- he s a i d , dealing it's sorry, the his with safest name way. is Baskhar? A Yes. 20 Q B-A-S-C-A-R? 21 A B-A-S-K-H-A-R. 22 Q Is t h a t last his first name or h i s name? 24 A First 25 Q Do y o u name. know, my It w a s I did. are 19 23 to I had that Proton guys to my g u y . running. I introduced how since that You estate So I t o l d him popupgenius.com, up a n d real it to to go b a c k I forgot called still suggest So i t ' s I have the out; ONLY I introduced 7 10 you website. even EYES what's his last Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 197 of 386 Page ID #:5367 Page 196 1 Allaham - ATTORNEYS' 2 name? 3 A I have 4 Q Does 5 A No. 6 Q Washington? 7 A No. 8 Q Qatar? 9 A No. 10 Q Where 11 A India. 12 Q India? 13 A He's 14 site. 15 Q He's does York? he l i v e ? from account, 17 account, and 18 account, have 19 addresses 20 A No. 21 Q Do y o u the Nobody the the used March use Gmail Alexis Stonington you since you in N e w uses the in I n d i a . the service here in I n d i a . 16 22 ONLY no i d e a . he l i v e Aside iCloud EYES know account, Strategies Strategies other e-mail 1, 2 0 1 7 ? what internet at h o m e ? 23 A I said probably 24 Q Spectrum? 25 A Used Spectrum. to be V e r i z o n , and now it's Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 198 of 386 Page ID #:5368 Page 197 1 2 Allaham - ATTORNEYS' Q 4 plans 5 when And that do y o u you you're 6 use YUSUF: A "Special 8 Q What while traveling? 10 A Sprint. 11 Q Do y o u time overseas 13 A 14 think 15 Q 16 plan? 17 A 18 abuse 19 Q 21 the ever to f o r m . meaning? services purchase you're I think do y o u internet traveling? I have the plan; I international. So t h a t ' s an i n t e r n a t i o n a l I believe so. did litigation I try of Q a t a r A I think 23 recall 24 told whether me. I'm you and not data to Do y o u become Broidy aware against others? -- I ' m I read not first by M r . State Q Objection plan" when for When of t h e 25 service it. 20 22 special internet internet No. 19.99 any traveling? MS. use have for 7 12 ONLY Spectrum's. 3 9 EYES not about -- I d o n ' t it or N i c k sure. recall whether you Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 199 of 386 Page ID #:5369 Page 198 1 Allaham - ATTORNEYS' 2 learned 3 complaint was filed, 4 A I'm not 5 recall 6 about it on t h e exactly Q And document 8 identification 9 you 11 that already like sorry, to s h o w marked 2018? I don't you a for 19. it is E x h i b i t it. Bates-stamped 14 A Yes. 15 Q You You document you page 41. already 5, a n d have Yes. 18 Q Okay. Do y o u 20 2018 at 3 : 3 3 21 you 22 Complaint.pdf"? see p.m., a document that Nicolas called I see 24 Q Is it c o r r e c t that on M a r c h Muzin "Elliott A date of y o u to p a g e a PROOD00000041. 23 is t h e to f l i p in f r o n t Bates-stamped A 19 ask have 17 25 26, -- as E x h i b i t If I c a n 41, but a exhibit. 12 16 how, have that on M a r c h we h a v e I'm 10 13 that day ONLY -- p r o b a b l y . I'd 7 EYES 26, texts to Broidy it. you to s a y learned that about that the Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 200 of 386 Page ID #:5370 Page 199 1 Allaham - ATTORNEYS' 2 complaint filed 3 A Yes. 4 Q And by M r . you at 3 -- at -- s o r r y , 6 day, 7 me, Do y o u see A Yes. 9 Q Why 10 A I don't an h o u r 12 2018, 15 identified mean, 18 Q so I d o n ' t 26, e-mails of t h e a moment ago? a lot And deleted e-mails 20 for State 21 MS. YUSUF: I don't 23 Q Since 26, 25 messages This 2018, you? is of t h i s have you deleted accounts every you day. fair to s a y relate that to y o u r I Objection. believe that have on s e r v i c e s so. date, April 26 -- you deleted any such you work of Q a t a r ? A March, to c a l l of j u n k . that 22 24 same -- e-mails so i t ' s 19 the that why. date on a n y I delete I get him remember March any 17 ask the 14 A you since message, p.m. Muzin that? And 13 16 did later, Q 4:14 to M r . please." 8 11 ONLY Broidy? responded 5 "Call EYES as W h a t s A p p ? Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 201 of 386 Page ID #:5371 Page 200 1 Allaham - ATTORNEYS' know if -- I A 3 don't 4 but, 5 if s o m e t h i n g 6 I don't, 7 unrelated to my -- my f r i e n d 8 important videos 9 keep know. I don't ONLY 2 10 I mean, EYES I don't usually, believe I know is n o t usually I deleted, my m e m o r y . a video delete all or s o m e t h i n g , stuff the I -- so that's sends time. me I don't them. Q Did 11 WhatsApp 12 Muzin 13 filing you messages delete that or S t o n i n g t o n of t h i s A I do n o t 15 Q Did messages 17 Global since Risk you since date on M a r c h delete or to N i c k the believe March texts relate complaint 14 16 any of t h e 26? so. any 26 t h a t WhatsApp relate to Advisors? 18 A I never heard 19 Q Did delete you 20 WhatsApp since March 21 to A h m e d Al-Rumaihi? of t h e m . 26, 22 A I don't believe 23 Q Did delete you 24 WhatsApp since March 25 to J a m a l Benomar? 26, any 2018 messages that on relate so. any 2018 messages that on relate Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 202 of 386 Page ID #:5372 Page 201 1 Allaham 2 A - ATTORNEYS' I don't 3 But, up my W h a t s A p p . 5 when 6 think 7 Q 8 you believe so y o u 4 I changed phones When I do n o t backed in 2 0 0 0 , anything, back it u p . So I don't so -- did you change the new phones; do recall? 9 A Whenever 10 Q And 11 you 12 or W h a t s A p p 13 work deleted for since any March texts messages the State phone 26, that that intentionally, 15 Q And going 17 week, 18 practice 19 e-mails? once A 21 lot 22 every 23 Q a day? you I mean, of -- a g o o d day, back e-mails, that out. have -- t e x t s to y o u r of Q a t a r ? Not of d e l e t i n g 2018, relate A 16 came relate 14 20 ONLY so. know, I never I deleted EYES to y o u r do y o u Is t h e r e follow not no. do t h a t once in d e l e t i n g no. of j u n k your I get e-mails so -So y o u r 24 delete only 25 delete whole the practice junk blocks a a regular really, amount practice would e-mails, of e - m a i l s be to or do y o u that may a Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 203 of 386 Page ID #:5373 Page 202 1 2 come Allaham - ATTORNEYS' in o v e r a certain EYES time period? e-mails. 3 A Usually, the junk 4 Q When you first did 5 of t h e 6 case? 7 A When Joel 8 Q What did 10 A He b a s i c a l l y 11 Q How 12 A On my p h o n e , 13 Q What did 14 A That if I d o n ' t 9 subpoena for ONLY your documents Mowbray Joel become called Mulberry aware in t h i s me. say to you? 15 I'll 16 think, 17 cooperate 18 stuff 19 threats 20 will did -- t h e y ' l l or s o m e with with all that's add threatened he t h r e a t e n -- I h a v e you or, guys those -- a l l if I d o n ' t defendant in t h i s case? 23 A I know, but 25 saying: you I to know, different do t h i s , they me as a d e f e n d a n t . 22 the to y o u ? cooperate, language Q all or w r i t e me as a d e f e n d a n t , 21 24 you? text. he s a y have me. You understand time. And I'm keeping that that that's you was how you're his not a threats he w a s because of t h e -- Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 204 of 386 Page ID #:5374 Page 203 1 Allaham 2 you 3 I hosted 4 whatever. 5 I found 6 7 know, because him for But that Q Mr. - ATTORNEYS' 9 Q And 11 lawsuit? 12 A came to s e e 14 lawyers Q 16 other 17 lawsuit? the filing yeah. me t w o times, 19 Q Were or h i s 22 Q Did 25 time. his you Then with met filing him him. at of t h i s to s e e meetings my with with he me. at y o u r request. have any interest in him? I mean, That's me. request? Always A the those A 24 was of t h i s ago meet He c a m e 21 with weeks you since Yes. speaking to d o . with He m e t My l a w y e r did A 23 is -- no i d e a . since And request which of c o o p e r a t i o n meet 18 20 kind you in D C . 15 past threats, did Oh, 13 -- b e c a u s e seeking? I have Mowbray kids disturbing what A Mr. ONLY in t h i s it w a s 8 10 free very And Mowbray of y o u r EYES his he t h r e a t e n e d way of c a l l i n g me a l l the me to a Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 205 of 386 Page ID #:5375 Page 204 1 Allaham 2 meeting, 3 the 4 occurring. 5 approach FBI - ATTORNEYS' that something is c o m i n g , So he a l w a y s of c a l l i n g for Q And has the 7 A No, not yet. 8 Q They 10 A No. 11 Q Have cooperation 13 Government 14 Mr. you urgent was a bad a meeting. come? come entered agreement Broidy's to t a l k to Say 16 Q Have that you entered cooperation agreement 18 arrangement with 19 concerning 20 e-mails? the 23 with the hack a U.S. of again. 17 22 the into e-mails? A 21 with concerning 15 25 is h a p p e n i n g ; had FBI haven't ONLY you? 12 24 bad something 6 9 EYES the the hack A I don't hack, and into a or i m m u n i t y U.S. Government of M r . Broidy's have I don't anything have any to do w i t h agreement anybody. Q I just So is t h e asked, "No"? answer to t h e question Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 206 of 386 Page ID #:5376 Page 205 1 Allaham 2 MR. 3 question. 4 - ATTORNEYS' (Record 5 A No. 6 Q Have 7 A No. 8 Q Have 9 Bhargava? 10 A No. 11 Q Have 12 Mr. 13 14 WOLOSKY: Lowell A Have Q 16 words 17 A re-read the read) you retained Abbe you retained Michael you spoken or M r . Define Lowell? to e i t h e r Bhargava? that. Spoken: come 18 restaurant 19 the What You do y o u mean? move your mouth and out. I mean, and did I meet him spoken to h i m or p i c k e d phone and 20 Q Either 21 A None, 22 Q Has Mr. call MS. YUSUF: in t h e up him? one. no. Muzin retained Abbe Lowell? 24 25 Please ONLY I -- 15 23 EYES A I can't Objection. answer for someone else. Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 207 of 386 Page ID #:5377 Page 206 1 Allaham 2 3 Q has - ATTORNEYS' To t h e Mr. Muzin best of y o u r retained Abbe 4 A I don't know. 5 Q Has Mr. Muzin 6 Bhargava? MS. YUSUF: 7 8 A I don't 9 Q I'd 10 that we've 11 Allaham 12 marked This 13 produced 14 Bates-stamped 15 And 16 between it's 17 an e x h i b i t identification that and PRODOOD00000046 Mr. Muzin 19 or do y o u have 20 referring to? 21 MR. and been something 23 MR. GIMBEL: 24 MR. WOLOSKY: 25 So t h e n can we j u s t of E x h i b i t else There it e n d e d -- t h a t up, It i s ? correct 5, you're may It is n o w , I will 51. others. is a s u b s e t how it's messages Counsel, WOLOSKY: was through of W h a t s A p p YUSUF: this have you attorneys, confirm may Michael Objection. is a d o c u m e n t 18 22 Lowell? retained to s h o w for a series MS. knowledge, 19. by y o u r you, ONLY know. like Exhibit EYES so -so -- Okay. the Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 208 of 386 Page ID #:5378 Page 207 1 Allaham - ATTORNEYS' 2 record and 3 that's been 4 ask 5 that 6 BY M R . that refer marked you ends Do y o u 8 A Yes. 9 Q The 11 Muzin 5, a n d to p a g e see first that -- text page? message on A p r i l 5, 2 0 1 8 at 1 2 : 2 8 Do y o u Yes. 14 Q Now, a cut-and-paste 16 Lowell. 17 see that 15 Do y o u A Yes. 19 Q So w h y 20 cutting 21 Lowell and A see Abbe on t h a t to N i c k p.m. that? is w h a t appears from to be Abbe that? is it t h a t pasting to M r . you of an e - m a i l 18 25 turn from A 24 please message 13 23 document as E x h i b i t is a t e x t 12 22 to t h e WOLOSKY: Q page ONLY in 4 6 . 7 10 you EYES you an e - m a i l were from Abbe Muzin? was asking if we h a v e insurance. Q insurance? Why was Abbe asking if y o u have Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 209 of 386 Page ID #:5379 Page 208 1 Allaham 2 - ATTORNEYS' MS. 3 for YUSUF: MR. A I think 6 Q Well, 8 12:20 9 Quote, that "That A Yeah. 12 Q Okay. write that? A It's 15 and 17 MS. BY M R . 18 that 20 says, 21 A I'm Mr. Allaham "That what "That 12:30. Q see that? And why 12:30 day at p.m. is it -- w h y Are referring 23 25 me, same I said." YUSUF: MS. BY M R . on t h a t to a t e x t did between me Matthew. 22 24 you Abbe. you referring -- WOLOSKY: Q 19 to a s k a communication my l a w y e r , 16 refer wrote what 11 14 need -- e x c u s e Do y o u you Calls Join. you I'll you -- s o r r y 10 13 Objection. GIMBEL: 5 message ONLY speculation. 4 7 EYES sent to N i c k message Muzin that I said." what YUSUF: WOLOSKY: 12:30 to a t e x t p.m. I said." He's talking about Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 210 of 386 Page ID #:5380 Page 209 1 Allaham 2 A - ATTORNEYS' "That what 4 Q Yes. 5 A Because 6 I don't 7 to h i m . " know 8 Q So w h y 11 that 12 difference? the issue 13 MR. 14 form. 15 A of -- m e a n i n g 17 with insurance Q were concerned 20 insurance? A 22 case. 23 Q that "Interesting. a difference what I said." is it t h a t you believed of i n s u r a n c e did not GIMBEL: this Objection know what's case had or w i t h o u t In w h i c h 19 21 makes "That's I don't 16 25 that says, Yes. 10 24 how I said." Nick I said, 18 ONLY Okay. 3 9 EYES case about Meaning the And what MS. YUSUF: the sequence to be d e f e n d e d insurance. you being -- y o u r is M r . a to t h e is it t h a t there make client's Lowell's case? Objection. role in Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 211 of 386 Page ID #:5381 Page 210 Allaham 1 2 3 A I think Q And 5 are c o p y i n g 6 Mr. Muzin. 7 A this and to a s k is an e - m a i l pasting It w a s Q This 10 copying 11 Mr. and not and sent that sending to m e , you to that is an e - m a i l pasting and that sending you were to Muzin. 12 So w h a t this is y o u r relationship to e-mail? 14 A My l a w y e r , 15 Q And 16 need ONLY e-mail. 9 13 you EYES Mr. Lowell. 4 8 - ATTORNEYS' relationship 17 MS. what Matthew. is M a t t h e w ' s to t h i s e-mail? YUSUF: 18 for 19 information. Objection. Calls attorney-client-privileged 20 MR. WOLOSKY: his communications 21 about 22 counsel. 23 Can 24 question. 25 MS. you I'm please YUSUF: not with re-read You're asking him his the asking about Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 212 of 386 Page ID #:5382 Page 211 1 Allaham 2 counsel's 3 which 4 attorney-client-privileged 5 information. 6 BY M R . 7 8 - ATTORNEYS' calls Q What answer that to t h e No. 10 Q Why Abbe 12 for is -- n o w , are you is y o u r lawyer YUSUF: 14 attorney-client-privileged 15 information. 18 19 20 speculation Objection. for 17 in t o u c h A calls for Do y o u with know Abbe Again, why your lawyer is Lowell? it's client-privileged information. Q 22 make. 23 25 and Calls WOLOSKY: Q 21 24 to Lowell? MS. BY M R . going in c o n t a c t 13 16 e-mail, question? A with ONLY WOLOSKY: 9 11 relationship EYES That's MS. just not your YUSUF: It's objection the to objection made: "Why is y o u r client in c o n t a c t I Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 213 of 386 Page ID #:5383 Page 212 1 Allaham 2 with - ATTORNEYS' Abbe 3 EYES ONLY Lowell? "Objection. Calls for 4 speculation 5 attorney-client-priveledged 6 information." 7 MR. WOLOSKY: 8 instructing 9 question? 10 MS. 11 BY M R . Q 13 question? 14 A And Q 17 18 the are to a n s w e r you that Yes. you not I think I would And I'm asking MR. WOLOSKY: answering refer A 21 to a n s w e r 22 Q that Again, that that it to my A phone, Can so -- you go b a c k to please. read) I defer it to my l a w y e r s question. So y o u ' r e question you, question, (Record 20 25 YUSUF: pending 19 24 not are lawyers. 16 23 him Well, WOLOSKY: 12 15 and not going to a n s w e r today? No. whatever I think you can pick method you can -- my up t h e Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 214 of 386 Page ID #:5384 Page 213 1 Allaham 2 lawyers 3 speak 4 Q 5 can - ATTORNEYS' do t h e on b e h a l f And Bhargava MS. I'm what is t h e e-mail YUSUF: I have no i d e a . 8 Q Do y o u know to role of M i c h a e l who Michael Bhargava is? 10 MS. YUSUF: 11 and 12 Q You 13 A I don't. 14 Q Have Objection. Asked answered. can answer you ever it. met with Abbe Lowell? 16 A I met 17 Q In w h a t 19 A In t h e 20 every 21 Q 22 time. 23 A 18 going Objection. A 15 not chain? 7 9 ONLY of my l a w y e r s . in t h i s 6 same. EYES him many context times. did you meet him? 24 goes 25 pay. Jew restaurant. on t h i s planet. We j u s t met You to o n e know, today I was of my e v e n t s He o w e s me. So -- I've for told and the met first Elliott he d i d n ' t Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 215 of 386 Page ID #:5385 Page 214 1 2 Allaham Q - ATTORNEYS' Have 3 a professional 4 sought his 5 YUSUF: that Say 7 Q Have 8 a professional 9 sought A 11 13 assertions 14 Will Lowell you in have Objection. again, ever context please. met where Abbe Lowell you in have services? to t h e So I ' d attorney-client given you that allow like to go privilege answer. him to a n s w e r questions? 16 MS. YUSUF: 17 MR. WOLOSKY: 18 MS. YUSUF: No. On w h a t basis? Attorney-client privilege. 20 MR. WOLOSKY: 21 that he n e v e r 22 Abbe Lowell 23 relationship. 24 25 in w h i c h WOLOSKY: back 19 Abbe No. MR. those you legal 12 15 met ONLY services? MS. A 10 ever context legal 6 his you EYES MS. ever met had He j u s t any testified contact with in an a t t o r n e y - c l i e n t YUSUF: Abbe You Lowell asked him if he in a p r o f e s s i o n a l Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 216 of 386 Page ID #:5386 Page 215 1 Allaham - ATTORNEYS' 2 context 3 services. 4 MR. WOLOSKY: 6 MS. YUSUF: 7 MR. WOLOSKY: 5 8 where ONLY sought And his legal he a n s w e r e d no. have MS. 10 to -- I ' m 11 client's 12 him 14 than not my o b j e c t i o n , 17 can which I'm you an o b j e c t i o n , 19 be n o t e d 20 answer for the MR. my on t h a t . instructing is d i f f e r e n t that. If y o u ' r e then the sorry, restate WOLOSKY: 18 based and an o b j e c t i o n . YUSUF: MR. testifying You're to a n s w e r , Counselor, not answering he relationship? stating WOLOSKY: MS. does I'm stating 15 21 So h o w YUSUF: not MR. 13 Right. an a t t o r n e y - c l i e n t 9 16 he h a s EYES your record stating objection and can he c a n question. GIMBEL: 22 long since lost 23 this question 24 it e i t h e r 25 MR. I, f o r the is, have of w h a t so I w o u l d be r e - r e a d WOLOSKY: thread one, ask that or r e s t a t e d . The question is: Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 217 of 386 Page ID #:5387 Page 216 1 Allaham - ATTORNEYS' 2 Have you ever 3 professional 4 sought his met 5 The 6 So g i v e n 7 have 8 Lowell, 9 context, aside I've 10 will 11 answer 12 communications 13 Lowell 14 asserted 15 not 16 Lowell from her questions there with concerning with counsel Abbe if s h e instruction not or c o n c e r n i n g which to Abbe she instructed YUSUF: it. No, reconsider 18 information 19 an o f f - t h e - r e c o r d 20 helpful. her you I will I think client don't not there's have. Perhaps discussion 21 MR. WOLOSKY: 22 Can we h a v e it r i g h t 23 MS. YUSUF: Yes. 25 to to a n s w e r . MS. step appears concerning 17 24 have in a s o c i a l asked -- s h e you "no." contact reconsider in a in w h i c h was that been ONLY advice. answer never Abbe context legal EYES would be Okay. now? Let's just outside. We're going to go o f f the record Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 218 of 386 Page ID #:5388 Page 217 1 Allaham 2 for THE 4 2:31 5 record. VIDEOGRAPHER: p.m., 6 and 7 and 8 follows:) 9 THE then 10 start 11 The 12 back 14 show 16 for the now on t h e you the a recess was taken, labeled continued This number p.m., as is t h e five. and we're record. Allaham, a document York 19 was 20 identification, I would that has like been as A l l a h a m (Whereupon, 18 23 off is 2 : 4 2 identification Q is WOLOSKY: 17 22 time going VIDEOGRAPHER: Mr. BY M R . ONLY The proceedings of m e d i a time Q 15 21 we're (Thereupon, BY M R . EYES a minute. 3 13 - ATTORNEYS' to marked 36. Document from New State Department of C o r p o r a t i o n s , marked as A l l a h a m Exhibit as of t h i s 36 f o r date.) WOLOSKY: Have you seen that document before? 24 A No. 25 Q This is a d o c u m e n t from the New Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 219 of 386 Page ID #:5389 Page 218 1 Allaham 2 York State 3 Corporations 4 2017, 5 called for - ATTORNEYS' Department that Alexis A I see 7 Q Did 8 cause 9 A this you see used 11 and 12 I never even 13 up t h i s -- t h e 14 this. 15 Q 16 discussed 17 called 18 alexisstrategies.com, 19 I liked LLC. a little the believe I don't name, you And recall recollection? recall did this bit but seeing we called I believe I believe Strategies Does have I I picked address Q 25 for an e - m a i l -- t h a t or now. earlier 21 entity. address recall Yes. 23 document -- do y o u A Alexis company you 20 24 said Do y o u 22 the -- I d o n ' t Did 9, LLC. this accounting have on N o v e m b e r to be f i l e d ? 10 might of liability file document for Division that. I think them filed Strategies, 6 ONLY of S t a t e was a limited EYES that you not discussion? testified exist document it w a s . that as a l e g a l refresh your Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 220 of 386 Page ID #:5390 Page 219 1 Allaham 2 A I have 3 probably 4 it. 5 picked 6 I never So y o u accountant 8 your A the 11 it. Which 12 happened, 13 picked picked name but picked it u p . 19 it w a s done. as f a r A yes. 25 pick Q 24 never your document have have I believe, without called them probably done that's what I never used it or I n e v e r do y o u mean by y o u up t h e when as y o u Yes, you paperwork And this So is t h i s related Q they Meaning, 18 not It w a s used "never it u p " ? you 23 this and What A 22 So I never that I probably is, 17 21 it. it u p . Q 20 it u p . believe filed No, with 16 it, ONLY knowledge? 10 15 seen done picked EYES up. 7 14 never if he h a s Q 9 - ATTORNEYS' do a n a l y s e s , for it. is n e w s an i n a c t i v e I never to me t h a t company know? but to m e , not -- c o r r e c t , absolutely So is it i n a c t i v e it is inactive, and not Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 221 of 386 Page ID #:5391 Page 220 1 Allaham 2 related 3 you? 4 is n o t 6 ask 7 there 8 Q 9 to y o u A 5 related for it, EYES or i n a c t i v e Both. but It is n o t to m e . Q I'll active I believe take And if t h i s MR. WOLOSKY: If t h i s 12 to y o u , 13 inactive? 14 A how assume 16 liked 17 was do y o u he h a s company 18 assuming the name. that I never it f o r related it is used it. I me b e c a u s e So I d o n ' t believe that. is n o t think I it it is a c t i v e . I'm it is n o t . Q 20 accounts? 21 A Not to my k n o w l e d g e , 22 Q Who would Do y o u accountant a bank -- I w i l l is n o t 19 25 it -- if it is Strike know done -- I d o n ' t A and to it. company Because 15 24 related -- 10 23 ONLY if it is a v a i l a b l e still, active 11 - ATTORNEYS' know if it h a s know, would any bank no. your know? I mean, account, I don't no. believe there is Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 222 of 386 Page ID #:5392 Page 221 1 Allaham 2 3 Q - ATTORNEYS' Do y o u Strategies, A No, 5 Q Now, went 7 you 8 becoming 9 documents 10 off some a long questions aware that And WhatsApp 13 that 14 subpoena while of t h e was ago, topics, about before I was your we asking first subpoena served I referred messages, Joel Mowbray and 15 for on y o u A I mean, 17 phone 18 my l a w y e r , call 19 for in t h i s 21 22 you 23 this to s o m e you also told you about recall you. testified the you. that? I recall he a r r a n g e d He a s k e d you ongoing. talking I don't Q But did about the subpoena subpoena to c a l l to me a b o u t remember. he s p e c i f i c a l l y served I believe was coming, he t o l d yes. inform on y o u case? A a correct? So he w a s this you but threatened Do y o u 16 25 Alexis case. 12 24 owns I don't. on d i f f e r e n t 11 20 who ONLY LLC? 4 6 know EYES me t h e in Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 223 of 386 Page ID #:5393 Page 222 1 Allaham 2 Q - ATTORNEYS' Now, 3 5, i t ' s 4 page 49. 5 Nick Muzin 6 called Exhibit Yes. 9 Q And 10 from you 11 in N e w 12 then 14 Q 24, from 2018, that? Muzin is a r e s p o n s e that aware WOLOSKY: Muzin 16 on A p r i l 24 c a l l e d 17 you become 18 subpoena had says, "It is of t h e A I'm 20 Q Also, 21 being 22 A served not that. to y o u Allaham of t h e fact on y o u ? sure. I don't you remember the never served Q Served 25 A Yes. on y o u r did a know. subpoena on me lawyer? text that correct? personally. 24 the subpoena, served on y o u , It w a s Strike sent aware been 19 23 April there you When then message -MR. 15 5 on Times." Were subpoena see to N i c k York Exhibit subpoena. Do y o u A dated ONLY to E x h i b i t is a W h a t s A p p to y o u 8 go b a c k 5, r i g h t ? There Allaham 7 13 if y o u EYES Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 224 of 386 Page ID #:5394 Page 223 1 Allaham 2 3 Q - ATTORNEYS' You subpoena had were been 4 A I don't 5 Q Do y o u 6 any e-mails 7 since 8 you? the know A E-mails, 10 Q E-mails 12 your Gmail 13 your Alexis 14 Stonington 16 Q You any 18 April 19 A I don't 20 Q Have 21 22 WhatsApp A messages 24 to s e e Q deleted accounts served on iCloud e-mail earlier, account, account, and your account? so, believe those no. you deleted accounts since 2018? since believe you that Again, 23 25 from was various believe don't 17 e-mail testified your strategies I don't 24, you Strategies A correct? have subpoena to y o u r what 15 a meaning? account, e-mails if y o u of y o u r this about on y o u , that recall. 9 accounts ONLY in A p r i l served on a n y time 11 aware EYES that's so, no. deleted any date, April I told you messages 24, inappropriate recall 2018? I delete for my w i f e or my k i d s . Do y o u on deleting any Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 225 of 386 Page ID #:5395 Page 224 1 Allaham 2 messages 3 related 4 Qatar? - ATTORNEYS' on W h a t s A p p to y o u r work 5 A I don't 6 Q I'd document that 8 identification 9 document attorneys 11 PROD00000062 12 letter 13 dated May 14 to a s k you marked through Mr. 17, 16 2018, marked 17 for 20 is a by y o u r it is a of W i l e y Letter of W i l e y 19 This Rein 2018. Obermeier BY M R . for And Obermeier 15 18 at a stamped 65. (Whereupon, was of to l o o k 21. produced date State so. is B a t e s ONLY that the as E x h i b i t was and from for we h a v e that 10 since believe like 7 EYES Rein, from dated as A l l a h a m identification, Stephen May 17, Exhibit as of t h i s date.) WOLOSKY: Q Have you seen this letter before? 21 A Yes. 22 Q Did you receive 23 or a r o u n d May 17, 2018? 24 A Yes, 25 Q And that's are you this what aware letter it s a y s . that 21 this on Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 226 of 386 Page ID #:5396 Page 225 1 Allaham 2 document 3 your 4 matters? - ATTORNEYS' instructs documents 5 A This 6 Q Did 7 documents 8 A Yes. 9 Q When 10 you 11 delete 12 trash 13 A 14 relevant is w h a t you, them or d i d preserve with did they you just this letter? earlier that permanently go i n t o your folder? I don't Q think everything So w h e n 16 your e-mails 17 they are 18 of y o u r I have comes you as y o u delete deleted, I have 20 Q Did you stop after you received e-mails 22 Mr. on to e a r l i e r , to t h e best knowledge? A 21 documents testified permanently a trash up. 19 23 of it s a y s . testified e-mails, all to c e r t a i n in f a c t , you ONLY to p r e s e r v e in a c c o r d a n c e deleted folder, 15 you EYES no i d e a . I don't deleting know. your a letter from Obermeier? A 24 I never 25 e-mails. In t h e -- I t o l d relation you to t h i s I delete lawsuit, junk Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 227 of 386 Page ID #:5397 Page 226 1 Allaham 2 Q 3 did 4 after 5 Mr. 6 7 9 And you stop how about deleting receiving the delete stuff Q like did 12 A I don't 13 Q It w a s 14 A Probably. 15 Q I'd Allaham, 17 Muzin on prior see messages back to 21 A Yes. 22 Q Now, messages between 24 had produced 25 2017, which using you, 27 of t h i s on t h i s 7 and t h e r e are 23 start to 2 0 1 7 ? between September 2017? first to r e f e r to p a g e 20 been you remember. like Do y o u four usually inappropriate. you WhatsApp? 19 messages from to r e f e r 11 are messages, 5. When 18 WhatsApp -- I d o n ' t unless I'd Exhibit Mr. ONLY WhatsApp letter I believe 10 16 EYES Obermeier? A 8 - ATTORNEYS' y o u and you page and September there Mr. 8, no a d d i t i o n a l Mr. to us u n t i l appears exhibit. on t h e Muzin that December next page, 7, on Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 228 of 386 Page ID #:5398 Page 227 1 Allaham 2 pages 28, 3 exchanged 4 - ATTORNEYS' 29, when you and Mr. Muzin any WhatsApp Did you exchange with Mr. Muzin messages 6 8 and 7 A 8 my p h o n e . 9 Q 10 phone 11 A Do I? 12 Q Go a h e a d . December September 7, 2 0 1 7 ? I don't Would right between know. you I have like to c h e c k to c h e c k your now? MS. YUSUF: phone You're 14 your 15 Q 16 Muzin communicated at a l l 17 dates of S e p t e m b e r 8 and 18 A 19 know. 20 Q 21 offer 22 messages 23 between you 24 through December 25 ONLY 15 m e s s a g e s . 5 13 EYES while Do y o u recall I don't Do y o u as to w h y that MS. touching on t h e if y o u know. and between record. Mr. the December 7, 2 0 1 7 ? I really do n o t have any explanation there are no W h a t s A p p have and you're not been Mr. produced Muzin from to by y o u September 7, 2 0 1 7 ? YUSUF: I'm going to o b j e c t 8 Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 229 of 386 Page ID #:5399 Page 228 1 Allaham 2 to f o r m . 3 response 4 asking 5 communications 6 produced as o p p o s e d 7 specific to t h e 8 This Muzin 11 7, 2 0 1 7 . 13 don't BY M R . 15 Q 16 Muzin 17 for why in is about none have been to s o m e t h i n g subpoena. I'm September YUSUF: know. made So C o u n s e l asking communications between MS. and ONLY was question WOLOSKY: any 10 12 production a general he h a d EYES to a s u b p o e n a . MR. 9 14 - ATTORNEYS' And I really him with 8 and if Mr. December he a n s w e r e d , do n o t "I know." WOLOSKY: Did about the you things State communicate other than with Mr. your work of Q a t a r ? 18 A I mean, 19 Q From the period 20 which was when you were working 21 Muzin on d o c u m e n t s that relate 22 representation 23 2017, did 24 about subjects 25 Qatar? you general of Q a t a r , communicate other than stuff. September and 8, with Mr. to t h e December with Mr. your work 7, Muzin for Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 230 of 386 Page ID #:5400 Page 229 1 Allaham 2 3 A I'm friends, 4 - ATTORNEYS' sure I would Q And subjects that 6 with about 7 you 8 9 him did for A His 10 Q 11 31, you'll 12 exchanged 13 27, have communicated than State that life, social flip you 12 m e s s a g e s the work that of Q a t a r ? his if y o u A see his stuff. to p a g e s and Mr. 30 to Muzin on J a n u a r y 26 a n d MS. YUSUF: That's not how 18 on J a n u a r y 26. 19 Q 20 27, MS. YUSUF: messages 22 Q of t h a t from I'm many And 21 23 that? Yes. 17 25 would other Do y o u 16 24 of t h e 2018. 14 15 some Personal, see we're were kids, Now, ONLY say. you the girlfriend. -- I m e a n , what 5 EYES to o b j e c t . messages I said. the going 26 a n d I don't 27. Let me r e p h r a s e I'm sorry. see were 27. any So w h i c h the Please ones? question. go to p a g e exhibit. Do y o u see a series sent of t e x t 29 Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 231 of 386 Page ID #:5401 Page 230 1 Allaham - ATTORNEYS' 2 messages between 3 December 7, 2 0 1 7 ? 4 Do y o u EYES you and Mr. see that? 5 A Yes. 6 Q And then do y o u messages pick up a g a i n 7 text 8 2018? 9 Do y o u 10 A Yes. 11 Q There 12 record between 13 December 14 see are you 7, 2 0 1 7 , Do y o u and and see Mr. Q Do y o u 17 case? 18 A No, I don't. 19 Q Did you exchange with Mr. Muzin know why 22 A I don't know. 23 Q Did and 24 25 communicate A you at a l l the 25, Muzin between 25, that 2018. any is t h e WhatsApp between Mr. between We p r o b a b l y in t h i s that? 16 dates? that on on J a n u a r y January Yes. 21 see no m e s s a g e s A messages Muzin that? 15 20 ONLY did. those Muzin those dates? I have to Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 232 of 386 Page ID #:5402 Page 231 1 2 Allaham - ATTORNEYS' Q 4 think 5 communicating 6 period? Is t h e r e of w h y you A No, 8 Q Now, January 25, 10 that gap 11 message from 12 begins, "It reason would there not the which first can been during message weeks, Muzin is v e r y Do y o u have is on p a g e Nick you that time is no r e a s o n . of s e v e r a l 13 29, on after is a t e x t to y o u and it good." know w h a t he is r e f e r r i n g to? 15 A No. 16 Q Was 17 communication 18 was 19 20 any by W h a t s A p p 7 14 ONLY check. 3 9 EYES very with any Mr. prior Muzin about what good? A see. there Again, I have Q Now, 22 there 23 communication 24 record, 25 other I'll similar that times looking at w h a t you to c h e c k . 21 are I'm gaps with has such represent Mr. been in y o u r Muzin, produced as A p r i l to y o u that WhatsApp on t h e to us at 24 a n d May 4, Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 233 of 386 Page ID #:5403 Page 232 1 2 Allaham and April - ATTORNEYS' 13 a n d 3 Are 4 there should 5 communication 6 dates? you with MS. 8 When communication, 10 11 you to t h e BY M R . You 13 A Again, 14 based 15 Q on t h e 19 gaps you're can those in h i s just referring or s o m e t h i n g WhatsApp the I think subpoena. messages MR. Q answer else? this that that I don't 21 Q I'd like 22 document that 23 identification Statement Pursuant deleted marked have you deleted dates? so. look for as E x h i b i t 33. Supplemental to t h e -- that. to p l e a s e purposes (Whereupon, you those believe you we h a v e produced would that between No, was Strike Is it p o s s i b l e messages question. So -- WOLOSKY: A 25 between Objection. say 20 24 why WhatsApp Muzin Is it p o s s i b l e WhatsApp 17 18 reason WOLOSKY: Q the Mr. production 12 16 of a n y in y o u r YUSUF: ONLY 19. aware be g a p s 7 9 April EYES Foreign at a Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 234 of 386 Page ID #:5404 Page 233 1 Allaham 2 Agents 3 amended, 4 33 f o r 5 date.) 6 BY M R . - ATTORNEYS' Registration was EYES Act marked of 1 9 3 8 , as A l l a h a m identification, Q 8 filed 9 pursuant It is a s u p p l e m e n t a l by M u z i n Capital to t h e Foreign of 1 9 3 8 , 11 it w a s filed for the six-month 12 ending September 30, 2017. Have before, Mr. you seen I probably 16 Q And 17 which 18 A Meaning -- s a y 19 Q Why you 20 A Because were doing 22 were working 25 A period document did did. was seen the And for what have 21 acting and Allaham? A Q as a m e n d e d , this 15 you LLC, Agents Act 13 statement Partners, Registration 24 Exhibit as of t h i s 10 23 as WOLOSKY: 7 14 ONLY the context it p r e v i o u s l y ? see that I remember who Nick's were you? Arent Fox. again. it p r e v i o u s l y ? registration with in my l a w y e r s for it. lawyers. those lawyers They Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 235 of 386 Page ID #:5405 Page 234 1 Allaham 2 3 Q this - ATTORNEYS' And if y o u skip EYES ONLY to p a g e 10 of document. 4 A Yes. 5 Q Question 6 six-month 7 registrant 8 capacity 9 render 5B r e a d s , reporting hired any period, who to t h e or in f u r t h e r a n c e 11 principals 12 secretarial 13 capacity," 14 And your 15 who was 16 LLC, 17 retained as a c o n s u l t a n t 18 with representation 19 party other hired the than the box or s i m i l a r as s u c h Capital forth directly or is c h e c k e d by M u z i n or w i l l foreign a clerical is l i s t e d it s e t s or a n y rendered or in a r e l a t e d name and of a n y the a registrant 10 and has as e m p l o y e e s persons services "During that "yes." a person Partners, you were in c o n n e c t i o n of t h e democratic of A l b a n i a . 20 Is t h a t accurate? 21 A This 22 Q Is it an a c c u r a t e 23 you were 24 or by h i s 25 representation is w h a t retained entity it r e a d s . to do w o r k statement by M r . in c o n n e c t i o n of t h e with democratic that Muzin the party of Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 236 of 386 Page ID #:5406 Page 235 1 2 Allaham - ATTORNEYS' A So w h a t ' s 4 MR. 5 re-read 6 the A It i s . 8 Q And same Yes. 11 Q There disbursements, 14 A Yes. 15 Q Okay. And 17 payment 18 Associates? to y o u 19 A Yes. 20 Q For 21 A Yes. 23 Q Was 25 to y o u A please to p a g e 13 of $52,000 see that at t h e bottom monies. that? see that or an e n t i t y or to y o u r Yes. see do y o u Do y o u 22 24 turn is a s e c t i o n Do y o u 16 you document. A 13 Can read) if y o u 10 called question? question. (Record that the WOLOSKY: 7 12 ONLY Albania? 3 9 EYES it r e c o r d s called on A p r i l AFH 5, 2 0 1 7 . that? payment, entity, in f a c t , AFH made Associates? a Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 237 of 386 Page ID #:5407 Page 236 1 Allaham - ATTORNEYS' EYES 2 Q And what was 3 A For what it s t a t e s 4 Q To do w o r k 5 party 6 A Not says 8 services 10 on p a g e for 10, Q And on p a g e the Albania. 10. democratic Whatever it d e s c r i b e s what in f u r t h e r a n c e what MS. specifically of t h i s YUSUF: 12 to r e l e v a n c e . 13 A it the did you do representation? I'm going to o b j e c t Consultant. 14 MR. sea GIMBEL: 15 deep 16 Q Consulting 17 A It s a y s 18 would 19 read 21 for? are. 11 20 for payment of A l b a n i a ? 7 9 that ONLY like fishing It s e e m s like we're now. to w h o m , it on p a g e me to r e a d Mr. Muzin? 10. If y o u it to y o u , or y o u it a l r e a d y . Q What democratic work party did A Consultant. 23 Q And perform 25 work? do f o r the of A l b a n i a ? 22 24 you what specific in c o n n e c t i o n with facts your did you consulting Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 238 of 386 Page ID #:5408 Page 237 1 Allaham - ATTORNEYS' 2 A I don't 3 Q What 4 provided 5 to t h e was the advice to y o u r democratic party YUSUF: Objection. in e v i d e n c e . facts not 8 A I don't remember. 9 Q Did do a n y $52,000 11 entity? that you work received A Consultant. 13 Q And 14 A No. 15 Q Did 16 A Albanians -- I h a d 17 employees that Albanians 18 with 19 you you meet were Albanians, Q Now, 20 a document 21 identification 22 work I was Assumes for from 12 did you of A l b a n i a ? MS. you that consulting 7 10 ONLY remember. pursuant 6 EYES the Mr. Muzin's consulted. go to A l b a n i a ? with any Albanians? a lot of so I m e t yes. I'd that like we h a v e for marked as A l l a h a m (Whereupon, 23 Registration 24 Foreign 25 1938, to l o o k was 34. Form Pursuant Registration as a m e n d e d , at for Exhibit Short Statement Agents you marked Act as to t h e of Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 239 of 386 Page ID #:5409 Page 238 1 Allaham - ATTORNEYS' 2 Allaham 3 as of t h i s 4 BY M R . 5 Exhibit identification, WOLOSKY: Q This is y o u r short form statement filed pursuant registration 7 the 8 connection with 9 by y o u Mr. Foreign party 34 f o r ONLY date.) 6 10 EYES and Agents Registration this same Muzin for work the Act performed democratic MS. YUSUF: I'm 13 thought 14 action 15 District of C a l i f o r n i a , but 16 I'll the soon. we w e r e that see here I really relating filed in t h e connection to t h e Central hopefully WOLOSKY: Q Do y o u 19 11 a s k s 20 detail all 21 to t h e foreign you 22 services on p a g e A Yes. 24 Q And with 1, q u e s t i o n separately which you will and in render principal? Do y o u assisted see to d e s c r i b e 23 25 was because to o b j e c t again BY M R . on r e l e v a n c e going 12 18 in of A l b a n i a . 11 17 to you see that reply, promoting box? "The the registrant visions and Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 240 of 386 Page ID #:5410 Page 239 1 Allaham 2 goals 3 to b u s i n e s s 4 United - ATTORNEYS' of t h e democratic and 6 A Yes. 7 Q How 9 party 10 political Do y o u the visions did and in t h e A been 13 you 14 invest know, signed get of t h i s in p r o m o t i n g goals of t h e democratic to b u s i n e s s investors if y o u the they and 19 A I see 20 Q Do y o u 21 A Yes. 22 Q And 23 on w h i c h 24 Qatar, you turn document, Do y o u A and political States? remember on N o v e m b e r 18 25 assist So -- b u t Now, 17 in t h e -- i t ' s wanted get to, people to in A l b a n i a . Q page leaders that? United a while. 16 of A l b a n i a you I don't 12 15 see of A l b a n i a leaders 11 party ONLY States." 5 8 EYES see were Yes. it s a y s 2017, see second that it w a s by y o u . that? my n a m e , this correct? 14, to t h e the date yes. date? is a f t e r retained by t h e the date State of Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 241 of 386 Page ID #:5411 Page 240 1 Allaham 2 Q 3 political 4 that 5 visions 6 of A l b a n i a ? 7 8 you leaders worked and Q you're tell me a n y in t h e with ONLY business United to p r o m o t e or States the goals of t h e democratic I never worked with So w h a t receiving, A Business 13 party any And 33, on t h e 15 previously, 16 the 17 monies. 18 same called A Page 20 Q Top 21 A Yes. 22 Q And 24 support and that -- c o n s u l t a n t . go b a c k page page 19 Biniatta for $52,000? if y o u that 13, there receipt Do y o u 23 money consulting. Q top is t h i s Consulting 14 25 you EYES politicians. 11 12 Can A 9 10 - ATTORNEYS' see to E x h i b i t we w e r e on is a s e c t i o n -- r e c e i p t s , that? what? of p a g e there Trade 13. is a c o m p a n y LP w h i c h of t h i s Do y o u paid project. see that? called $150,000 in at Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 242 of 386 Page ID #:5412 Page 241 1 Allaham - ATTORNEYS' 2 A Yes. 3 Q And what MS. YUSUF: 4 5 A I don't 6 Q Were 7 at a n y 8 point 9 A point with to s a y 11 Q Can you 12 5, p a g e 35. engaged Muzin Not no. about that please Biniatta turn Exhibit 5? 14 Q Exhibit 5, on p a g e 15 A Yes. 16 Q Okay. 18 message 19 2018, 20 and 21 framed from it is t h e it s a y s , 22 Mr. third "Broidy I don't to E x h i b i t 35. is a t e x t to y o u one from is s a y i n g on M a r c h the Do y o u A Yes. 24 Q And you Do y o u see Biniatta that? respond, see that? "Holy 8, bottom, him." 23 25 there Muzin Trade? remember. A see at a n y I recall. I don't Do y o u LP? in d i s c u s s i o n s 13 17 Trade Objection. or c o m m u n i c a t i o n s No. want is B i n i a t t a ONLY know. you Mr. 10 EYES shit." Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 243 of 386 Page ID #:5413 Page 242 1 Allaham - ATTORNEYS' 2 A Yes. 3 Q Does 4 recollection 5 A remember 7 conversation. 9 the Q refresh of w h a t I don't 6 8 that I don't it r e f r e s h had Muzin 11 Trade? concerning A No, 13 Q Is B i n i a t t a 14 entity to t h e best A I have 16 Q Does work that 19 Q Does 20 relation 21 for it b e a r sorry? I'm that you Biniatta done Biniatta to t h e a Russian knowledge? no c l u e . have A Trade of y o u r you 18 the I don't. 15 17 really your 10 12 is? remember of c o m m u n i c a t i o n s Mr. Trade I don't recollection with ONLY your Biniatta -- n o , -- n o , Does EYES work any relation for Qatar? Trade that to t h e you bear any have done Qatar? 22 A Not 23 Q Does 24 relation 25 wish to my k n o w l e d g e to t h e to do f o r Biniatta work Trade that Morocco? you at a l l . bear any have done or Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 244 of 386 Page ID #:5414 Page 243 1 Allaham - ATTORNEYS' 2 A No, not 3 Q Did Biniatta 4 relation to t h e 5 democratic 6 A 7 that. 8 subcontractor 9 10 Again, I don't Q bear any did for you the of A l b a n i a ? I was not involved I was so I d o n ' t want in a know. to t a k e a short break? 11 A Sure. 12 THE 13 3:16 14 record. VIDEOGRAPHER: p.m., 15 and we're (Thereupon, 16 and 17 follows:) 18 THE then 19 start 20 is n o w 21 the 22 Trade that know. Do y o u ONLY to my k n o w l e d g e . work party EYES BY M R . 23 Q the the a recess was taken, labeled p.m., is off proceedings of m e d i a time going VIDEOGRAPHER: 3:31 The and continued This number we're as is t h e 6. back It on record. WOLOSKY: Mr. 24 some questions 25 Strategies, Allaham, about LLC. I'd like Stonington to a s k you Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 245 of 386 Page ID #:5415 Page 244 1 Allaham 2 3 Do y o u Strategies, 4 5 A LLC What Stonington 6 7 - ATTORNEYS' Q interest do y o u It's in t h a t No. 9 Q Do y o u 10 A I assume 12 if t h e r e ' s Q And 13 associated 14 LLC? 15 16 A Q Have Stonington does? Nick. I'm not others. you ever Stonington term you been Strategies, mean, you I mean, 20 Nick, so i t ' s 21 Q I'd 22 that 23 Exhibit ever done work with parallel with Strategies? A 25 what an o w n e r s h i p who it's any with 19 24 if I k n o w "associated"? 17 18 mean have know have What Stonington business? A sure what an L L C . do y o u 8 11 ONLY is? is? And know EYES we h a v e I work a very like marked -- A l l a h a m broad to s h o w for registration you an e x h i b i t identification Exhibit (Whereupon, question. 25. Exhibit statement A to t h e filed by as Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 246 of 386 Page ID #:5416 Page 245 1 Allaham - ATTORNEYS' EYES 2 Stonington Strategies, 3 as A l l a h a m Exhibit 4 identification, 5 BY M R . 6 Q 8 the 9 1938, Foreign filed Agent's 11 of f i l i n g 12 before, you A I'm 15 Q If y o u 16 "Name not 18 A Yes. 19 Q Do y o u provided 21 A Yes. 22 Q That used in 2 0 1 7 24 correct? pursuant Act to of Strategies, dated -- t h e LLC date 3, 2 0 1 7 . ever seen this document 1, it s a y s , of r e g i s t r a n t . " see that? see that is 5 5 0 is t h e for Yes. sure. go to b o x address Do y o u 23 A to t h e Allaham? 14 17 it's is S e p t e m b e r Mr. and filed Registration And Have A marked date.) Exhibit by S t o n i n g t o n as r e g i s t r a n t . 25 as of t h i s statement 10 that's was 25 f o r It is a -- i t ' s registration 20 LLC, WOLOSKY: 7 13 ONLY your the Madison address business address Avenue? that you interests, Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 247 of 386 Page ID #:5417 Page 246 1 Allaham 2 Q - ATTORNEYS' Do y o u 3 Stonington 4 its FARA have any Strategies Exhibit No, I don't. 6 Q Did Stonington 8 in 2 0 1 7 ? idea why that an o f f i c e I have at 5 5 0 Not to my k n o w l e d g e , 10 Q Did Stonington offices 12 2017? 13 A I don't 14 needed 15 no a d d r e s s 16 and 17 recall 18 relationship; 19 New 20 address. 21 his -- it w a s my r e c o l l e c t i o n . York. He s a i d Do y o u 22 York address for 23 form? 24 A I have 25 Q Did his use in why FARA and he he h a d or s o m e t h i n g , with me, That's used it w a s know Avenue York, FARA okay he j u s t no. -- I b e l i e v e in N e w to f i l e Avenue Strategies Madison think an a d d r e s s I was Q at 5 5 0 no i d e a . Madison A your on Strategies 9 11 address A form? A maintain ONLY used 5 7 EYES if I the only my a d d r e s s a New for York he n e e d e d a New registration no i d e a . he u s e this address, to y o u r Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 248 of 386 Page ID #:5418 Page 247 1 Allaham 2 knowledge, 3 that 4 together? you 5 6 A 7 agreement 8 Q 9 of t h i s 10 - ATTORNEYS' for your and could work on Q a t a r MS. YUSUF: We h a d with Did 13 you rent MS. date was this YUSUF: 15 3, 2 0 1 7 . 16 Q Sorry. September 17 A I don't think 19 20 Q This the use says of That's it w a s September 2017. I was in b u s i n e s s Do y o u know where Mr. Muzin lives? A Somewhere 22 Q Have 23 A Yes. 24 Q Do y o u Maryland no filed? time. 21 25 for Objection. misstated. at t h a t form. I have in N o v e m b e r 14 18 to t h e address? was filed 2017. so matters Object he p a y It 12 convenience Stonington. What Q his ONLY no a g r e e m e n t . A 11 EYES or D C ? you in D C . been know to h i s house? if he l i v e s in Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 249 of 386 Page ID #:5419 Page 248 1 Allaham 2 3 A familiar 4 - ATTORNEYS' I'm not with it. Q Have 5 same manner 6 addresses? sure. you 7 A No. 8 Q Do y o u 9 maintains any I don't know. 11 Q But did, 13 Stonington in f i n a n c i a l 14 or M r . MS. 15 A No. 16 Q You 17 in f i n a n c i a l 18 controlled 19 A Yes. 20 Q And 21 used for those No, 23 Q Do y o u 25 phone A business time to t i m e , with correct? Objection. at v a r i o u s Muzin, times with engage entities correct? recall what banks I don't. number No. your in t h e transactions? A main Muzin, do y o u 22 24 offices from transactions by M r . very transactions YUSUF: did not accounts? A engage ONLY if S t o n i n g t o n 10 12 his used know bank you I'm used as he h a s EYES know is? what Stonington's he Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 250 of 386 Page ID #:5420 Page 249 1 Allaham 2 Q - ATTORNEYS' When 3 Nick Muzin, 4 number 5 numbers, such 6 you for you did needed you use exclusively, used as an o f f i c e cell 8 Q Has Stonington 9 State 10 A That that 14 except Stonington for A 16 A its not other number, that only. done I'm work saying; did aware for public I'm not MR. GIMBEL: I'm not 18 Stonington. 19 with for the I of a n y the State work of Q a t a r filings? -Objection answering I have to f o r m . for no -- n o t h i n g to do Stonington. Q You 21 that 22 knowledge. 24 phone is w h a t You're 13 23 there it d i d n ' t . Q 20 phone of Q a t a r ? believe 17 with Stonington? His 15 cell or w e r e A 12 ONLY to s p e a k his 7 11 EYES are A please. posed have to a n s w e r to y o u So t h e n can to t h e you the best re-ask questions of y o u r it, Case Document 238-20 Filed 10/17/18 Page 251 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 252 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 253 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 254 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 255 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 256 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 257 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 258 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 259 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 260 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 261 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 262 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 263 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 264 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 265 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 266 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 267 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 268 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 269 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 270 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 271 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 272 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 273 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 274 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 275 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 276 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 277 of 386 Page ID MAG NAQ LEGAL SERVICES Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 278 of 386 Page ID #:5448 Page 277 13 Now, 14 look 15 identification I'm at an e x h i b i t going that to a s k we h a v e as A l l a h a m you to marked Exhibit 9. for Case Document 238-20 Filed 10/17/18 Page 279 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 280 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 281 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 282 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 283 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 284 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 285 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 286 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 287 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 288 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 289 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 290 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 291 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 292 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 293 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 294 of 386 Page ID MAG NAQ LEGAL SERVICES Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 295 of 386 Page ID #:5465 Page 294 12 13 break 14 MR. GIMBEL: you requested. THE VIDEOGRAPHER: 15 4:22 p.m., 16 record. 17 and 19 follows:) 20 THE then 21 start 22 The 23 on t h e 25 we're (Thereupon, 18 24 and BY M R . Q the the time is going off the a recess was taken, VIDEOGRAPHER: labeled is 4 : 3 0 take The proceedings of m e d i a time Let's continued This is t h e number seven. p.m., and we're going to a s k back record. WOLOSKY: Okay. I'm as you, Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 296 of 386 Page ID #:5466 Page 295 1 Allaham Allaham, - ATTORNEYS' 2 Mr. 3 we h a v e marked 4 Exhibit 27. 5 to l o o k at t h e attachment, 7 Exhibit 8 this BY M R . was 27 f o r date.) WOLOSKY: ONLY document identification (Whereupon, 6 9 for EYES E-mail marked that as with as A l l a h a m identification, as of Case Document 238-20 Filed 10/17/18 Page 297 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 298 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 299 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 300 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 301 of 386 Page ID MAG NAQ LEGAL SERVICES Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 302 of 386 Page ID #:5472 Page 301 5 Q Did 6 Elliott 7 levels 8 against 9 you Broidy of t h e have had concerns access White that to t h e House and was A I had no i d e a 11 who the 12 have read 13 it. It w a s 14 lobbyist 15 -- y o u know, to be h o n e s t here, 16 writes a lot and a lot, 17 never 18 pitching 19 good 20 serious the name, always and 23 levels 24 against Broidy no c l u e January. but I never connected Joel Mowbray was Qatar. To m e , all took Nick so I he w a s a salesman. So t h a t ' s I the So I n e v e r he t a l k s being I had probably it s e r i o u s . writer. Elliott until against took 22 25 was you. Elliott to be h o n e s t man with who was Q lobbying Qatar? 10 21 top He is a I took it a s , as t h a t . Did Broidy of t h e Nick had have concerns access White House to t h e and was Qatar? MS. YUSUF: Objection. that top lobbying Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 303 of 386 Page ID #:5473 Page 302 1 Allaham 2 A Again, 3 but one 4 and Joel 5 hated 6 each thing I can't I would Mowbray each are other. other's 7 really throat truth, 9 personal. 10 more 11 of be m o r e 12 They 13 friends not and 14 thought 16 close they of i t . 17 several 18 to l u n c h 19 that to R o y c e times 20 don't, 22 it. 23 and 24 throat. how Q who enemies. were than and they at can. if t h i s was because then, the it w a s to s o r t other one. were best much I they enemies. I never with They going is g o i n g how -- I k n e w I hosted together, him so I w a s them. he w a s invited So I k n e w is t r u e . I never And him is r e a l l y So to t h e 21 sure, or it is t h e i r became together part for sure rivalry, So t h i s 15 Nick, I do b e l i e v e , successful true for anytime of a p e r s o n a l , had two ONLY speak say reality, And EYES So t h e y So I w a s 8 25 - ATTORNEYS' Nick they I'm extent really was can honestly more obsessed go at e a c h sorry, of E l l i o t t , you bought with I into Joel other's mentioned a lunch Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 304 of 386 Page ID #:5474 Page 303 1 2 Allaham with - ATTORNEYS' Who 4 A 5 likes 6 in my o w n 7 meal. 8 did attended I was free not meals. place, attend Q And Nick 12 Broidy meaning invited 13 did me. they Joel invited he w a n t s me a free to a l u n c h , I hosted concerns you that had access White House that 14 plans to w o r k 15 A Say that 16 Q Can you but I them. ever he h a d to t h e would for discuss that top with Elliott levels interfere of t h e with his Qatar? again, I'm sorry. re-read the question, please? 18 (Record read) 19 A No, I don't 20 Q Did you 21 with Jamal 22 that Elliott 23 of t h e 25 invited So w h e n it, lunch? I see. 11 24 that -- J o e l So I w a s 10 17 ONLY Ed R o y c e . 3 9 EYES A so I w o u l d ever Benomar White House not have about Broidy I don't recall. had the have influence at t h e lobbying think discussions top levels against I knew about a discussion Qatar? it, about Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 305 of 386 Page ID #:5475 Page 304 1 Allaham - ATTORNEYS' EYES ONLY Case Document 238-20 Filed 10/17/18 Page 306 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 307 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 308 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 309 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 310 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 311 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 312 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 313 of 386 Page ID MAG NAQ LEGAL SERVICES Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 314 of 386 Page ID #:5484 Page 313 10 Q Who 11 A A friend 12 Q What 13 Jack is J a c k kind of w o r k MS. YUSUF: in e v i d e n c e . 15 facts not 16 Q Do y o u Mr. of m i n e . do y o u do w i t h Abernathy? 14 17 Abernathy? Objection. do w o r k Assumes with Abernathy? 18 A No, 19 Q Is y o u r relationship 20 personal? 21 A I would say personal. company, whatever, a crypto I don't. 22 had 23 bitcoin-type-of-thing 24 I mean 25 me to i n v e s t it is m o r e and a month personal, I did not strictly I mean or t w o but ago. he a s k e d invest. he Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 315 of 386 Page ID #:5485 Page 314 1 2 Allaham Nothing 3 4 more Q your - ATTORNEYS' than Did work A Never. 6 Q Do y o u 7 WhatsApp message 8 and Muzin? Nick 9 10 facts 11 12 A 15 5. I 16 A Sure. 17 Q The Do y o u name that on t h e Yes. 23 Q Do y o u Abernathy's A name with you that Benomar Assumes Jamal back in a to E x h i b i t is B a t e s stamped exhibit. see a series left-hand A Jamal Objection. include 22 on Objection. refer page he w a s with never 50 in t h a t 21 25 chats GIMBEL: Can messages why MR. Q 24 know him of Q a t a r ? in e v i d e n c e . 14 20 State not conversation. 19 with YUSUF: He w a s number discuss MS. 13 18 ever the 5 ONLY that. you with EYES have Jack of t e x t Abernathy's side? any idea why is t h e r e ? I looked and this is -- I Jack Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 316 of 386 Page ID #:5486 Page 315 1 Allaham - ATTORNEYS' 2 brought this 3 deleted before 4 text. Jack 5 He w a s never 6 Q 7 messages, 8 Nick 9 was that Muzin That taken out was 11 or t w o , when Q message 14 group 15 A part was of t h e text with us. deleted chat from that the text included Jamal? me, Nick, and when Jamal -- I t h i n k , Jamal Do y o u 13 in t h e This of i t . group and A became never part ONLY my c o u n s e l . Jamal So he w a s 10 12 up w i t h EYES is t h a t came know Jack. Jack a day in. where includes that Jamal text in t h a t chat? I don't this reads, believe 16 way 17 shows 18 it w a s ever -- I d o n ' t 19 a time that they on t h e 20 Q 21 group 22 then 23 Abernathy when different, phone. Mr. chat it's But were Jamal any. the I don't believe The way it w a s ever was part and Mr. Muzin, but Benomar was added, Jack you was deleted; 24 MS. YUSUF: 25 Misstates the is t h a t of a correct? Objection. testimony. it believe together. Abernathy with it w a s I think he Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 317 of 386 Page ID #:5487 Page 316 1 Allaham 2 said 3 Q 4 question? - ATTORNEYS' it w a s the other Can you 5 MR. WOLOSKY: 6 (Record read) I think it w a s 7 A 8 time before 9 conversation answer that. of u s , between 11 Probably, 12 no c o n v e r s a t i o n , 13 created a month for For 15 A Yeah, know, a smart -- period of no and the three Jack. before a group you, Nick just that that when, 18 that 19 joined, 20 no c o n v e r s a t i o n between 21 which Nick 22 days or m o n t h s 23 with Jack. I believe guy and -- a n d was was was is me a n d What which you out, and before Jack the is s o m e t h i n g the and Jamal but there three Jack, Jamal is, to -- b u t -- w h e n taken were Jack? just this on my p h o n e Jack and to c h a t . 17 concerning you was or t w o you 25 pending between 16 Q around. that. Q 24 ONLY a much me, just 14 I saw the There Nick, way Can initiated 10 EYES of u s , probably was subject Nick was added, matters and Jack Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 318 of 386 Page ID #:5488 Page 317 1 2 Allaham - ATTORNEYS' MS. YUSUF: 4 Relevance. 5 A So it is n o t What 8 A I don't recall, but unrelated something Q was anyone on t h i s 11 is an e x p e r i e n c e d 12 nothing 13 I can 14 Q 15 lobbyist, 16 with 17 in? that that the don't Qatar It is r e a l l y lobbyist really matter? I really to do w i t h list. to t h i s . is r e l e v a n t . subject know. nothing 10 18 Objection. It is r e a l l y 7 9 ONLY chatted? 3 6 EYES has and any just or just he -- relevance that recall. him Because he w a s an e x p e r i e n c e d did or M r . Muzin you about A activities I don't 19 anything 20 It w a s 21 to N i c k . 22 so N i c k 23 since 24 business. 25 that recall to do w i t h just I knew Jack. he w a s Jack So it w a s is l o o k i n g I introduced could for get in t h e just to h e l p engaged relationship. looking no l o n g e r were us c o n s u l t i n g -- a n y So we w e r e thought you consult pure us g e t him clients, the clients lobbying friendship, clients. Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 319 of 386 Page ID #:5489 Page 318 1 Allaham 2 3 4 Q Nick And to g e t A - ATTORNEYS' do y o u know EYES ONLY if J a c k helped clients? I don't recall that he d i d , no. Case Document 238-20 Filed 10/17/18 Page 320 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 321 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 322 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 323 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 324 of 386 Page ID MAG NAQ LEGAL SERVICES Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 325 of 386 Page ID #:5495 Page 324 13 Q Do y o u 14 A I do n o t 15 16 him Michael know him. Avenatti? I have seen on T V . Q To t h e 17 recollection, 18 phone 19 Benomar? 20 know A calls best did using Yes. you of y o u r place or r e c e i v e WhatsApp with I probably did. Jamal Case Document 238-20 Filed 10/17/18 Page 326 of 386 Page ID MAG NAQ LEGAL SERVICES Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 327 of 386 Page ID #:5497 Page 326 10 Q 11 regularly 12 A Yes. 13 Q What 14 your 15 Did you speak to M r . Klein by t e l e p h o n e ? were the subject matters of discussions? A it's Mort always likes to c a l l anything every hour, 16 and 17 honestly, Israel-related-type-of-thing. 18 It is a l l about 19 his -- m o s t l y organization. to do w i t h , about Israel and Case Document 238-20 Filed 10/17/18 Page 328 of 386 Page ID MAG NAQ LEGAL SERVICES Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 329 of 386 Page ID #:5499 Page 328 11 Q 12 Klein 13 release a negative 14 on J u n e 6, 2 0 1 8 , 15 Mr. 16 ties 17 And about Klein with A his that probably 19 that was And part of t h e 22 your ties did you would Mort to r e a c h -- about also Qatar tell be c u t t i n g was payments that 24 entitled to? That my t i e s the same part did reason 23 A with statement you around 21 25 spoke your Qatar? reason Q you decision Cutting 18 20 when you why was Qatar time. of t h e because you with tell you I mean break Mr. up. Klein were did not thought you were -- a g a i n , that cutting you not was receive that was Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 330 of 386 Page ID #:5500 Page 329 1 Allaham 2 not 3 done. 4 Q 5 Mr. the - ATTORNEYS' reason really. I wanted EYES Just to be o u t Did you my j o b way discuss that No, I don't 7 Q Did you discuss that I don't -- i t ' s not A 10 my d e c i s i o n . 11 February, 12 notice. 13 Q You I was that. with Mr. the and Mr. 15 Mr. Muzin did 16 A I believe 17 Q Did his 19 decision A he w a s your the same, I mean also going Did he s a y 22 A I'm not involved 24 embassy. Q Qatar, it. with ties Mr. with Muzin Qatar? to me t h a t why? sure. in h i s It w a s you to do i t . Q not as b o t h with he e x p r e s s e d 21 23 he d i d his my correct? discuss to c u t time ties was from to -- I g a v e same cut you -- t h a t my t e x t asking Around Klein saw 14 25 recall Muzin? 9 20 with Klein? A 18 was before. 6 8 ONLY I mean discussions a good contract -- I w a s with for the him, Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 331 of 386 Page ID #:5501 Page 330 1 2 Allaham wasn't MS. 7 I'm 9 EYES YUSUF: A Again, going to a n s w e r Q Did 10 reasons 11 Qatar? for Objection. this you is n o t for Nick. discuss terminating a question with his A No, I'm not. 13 Q Are you aware he t e r m i n a t e d his relationship 15 A 16 don't want 17 never -- I w a s 18 the 19 I can't embassy Q 20 decision 21 Qatar? not and to s e v e r know 22 A Or? 23 Q Or Q a t a r ' s 24 25 relationship A with I think with with why Qatar? on it b e c a u s e in t h e and He loop of his relationship decision I stuff. if it w a s his his reasons on w h y . really meetings Do y o u of t h e comment to s p e c u l a t e him contract 12 14 ONLY it? 3 8 - ATTORNEYS' with to s e v e r its him? it is c l e a r that he p u t Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 332 of 386 Page ID #:5502 Page 331 1 Allaham 2 out, 3 Qatar 4 for 5 6 7 that's - ATTORNEYS' not should for answer EYES ONLY me to a n s w e r . I think or N i c k answer should that. Q But are you No, I'm not. reasons? A aware of t h e Case Document 238-20 Filed 10/17/18 Page 333 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 334 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 335 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 336 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 337 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 338 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 339 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 340 of 386 Page ID MAG NAQ LEGAL SERVICES Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 341 of 386 Page ID #:5511 Page 340 25 Q Are you paying for your Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 342 of 386 Page ID #:5512 Page 341 1 2 Allaham - ATTORNEYS' A Yes. 4 Q Do y o u party to r e i m b u r s e 5 any 6 legal 7 A No. 8 Q I'm some of t h e 11 with 12 through a lot 13 Exhibit 19. with or i n d e m n i f y messages your already. You 16 Q I do. 17 well. Exhibit need this. A Page 24, 22 Q Page 24. Do y o u A Yes. 25 Q And exchanged been This is at 5, y e s . different quickly document tabs and that's yes. see that? we t a l k e d about this as we'll 24. 21 24 start The you coffee. I need So l e t ' s Bates s t a m p e d the through you of t h e m A go t h r o u g h that We h a v e 15 18 messages you parties. Sorry, 23 an a g r e e m e n t to t a k e WhatsApp various 14 going text exchanged, 20 have fees? 10 19 ONLY attorneys? 3 9 EYES page Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 343 of 386 Page ID #:5513 Page 342 1 2 3 Allaham - ATTORNEYS' already. A Yes. EYES ONLY Case Document 238-20 Filed 10/17/18 Page 344 of 386 Page ID MAG NAQ LEGAL SERVICES Case Document 238-20 Filed 10/17/18 Page 345 of 386 Page ID MAG NAQ LEGAL SERVICES Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 346 of 386 Page ID #:5516 Page 345 19 20 Q Now, Bates s t a m p e d on t h e page which is 28. 21 A Yes. 22 Q Do y o u 23 excuse me, 24 Broidy Capital. 25 Muzin see WhatsApp to y o u , next there are messages e-mails that It is a m e s s a g e December 7, 2 0 1 7 , -- refer from to Nick at 9 : 4 2 Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 347 of 386 Page ID #:5517 Page 346 1 2 Allaham a.m. - ATTORNEYS' It is t h e third from 3 Do y o u see 4 Broidy Capital 5 A Yes. 6 Q And 7 one." 8 then Do y o u A Yes. 10 Q What you 11 A Meaning, does time 13 disinvited to t h e Vegas 15 A I think 16 National 17 Why Vegas event? 19 A I have 20 Q Did 21 the him uninvited did I have 23 Q Can 25 A Nick -- he g o t Vegas event? Republican Bates Yes. he g e t you disinvited from no i d e a . to t h e A please, is, event. is t h e the that getting he b e l i e v e 22 24 "He -- R N C . Q 18 company. mean? I remember a hard what is h i s that having And bottom. that? was Q the respond, 12 14 ONLY that? see 9 EYES that Vegas Broidy got event? no i d e a . turn stamped to t h e 29. next page, he Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 348 of 386 Page ID #:5518 Page 347 1 2 3 4 Allaham Q e-mail. The - ATTORNEYS' third -- I ' m EYES ONLY sorry, the Sorry. MR. WOLOSKY: Strike that. top Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 349 of 386 Page ID #:5519 Page 348 10 Q 11 spoke And then Do y o u see 13 A Yes. 14 Q And 15 A Because Broidy spoke why Q About 18 A No, 19 he s p o k e . 20 it. Q message 23 from 24 2018, Malcolm That's he w a s all. the Muzin at 5 : 4 2 you write that? told me t h a t nice to h i m what? on t h a t Nick that? did just Now, 22 25 "Broidy to h i m . 17 21 write, to M a l c o l m . " 12 16 you very page The last to y o u see he s a y s WhatsApp is a W h a t s A p p on J a n u a r y p.m. Do y o u way that? and message 25, Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 350 of 386 Page ID #:5520 Page 349 1 Allaham - ATTORNEYS' 2 A Yes. 3 Q Okay. 4 5 It s a y s , after Do y o u see 7 A Yes. 8 Q Do y o u A I think 11 lot 12 reporters are 13 that, know, 14 Broidy. 15 the you calling calling they He s e e m s press going going he is r e f e r r i n g referring him. him is t h e MS. YUSUF: of him information to be s a y i n g , Who to a A lot telling have after "We on got Broidy." "we" in t h a t sentence? 20 A I don't 21 Q Were 22 press 23 A 25 what he w a s Q 19 24 press that? know of r e p o r t e r s 17 18 the to? 10 16 got ONLY Broidy." 6 9 "We EYES reporter Q Never, until Who know you to go a f t e r who the involved "we" is. in g e t t i n g the Broidy? I never last was Objection. week Nick spoke to a probably. Muzin working with Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 351 of 386 Page ID #:5521 Page 350 1 2 Allaham to g e t 3 the A - ATTORNEYS' press I have 4 not in t h e 6 foundation. BY M R . 8 Now, 9 10 A Yes. 11 Q I'd 13 marked. 14 Exhibit a look see like Assumes Lacks "I e - m a i l e d you." that? to -- I ' d like that we h a v e you to we h a v e marked it 23. This 16 by y o u r 17 PROD000000075. is an e - m a i l lawyers. 18 It's (Whereupon, 19 Muzin 20 25, 21 Exhibit 22 this BY M R . record. at an e x h i b i t I believe 15 23 Objection. he s a y s , Do y o u take Broidy? WOLOSKY: Q 12 ONLY no i d e a . GIMBEL: facts 7 to go a f t e r MR. 5 EYES to J o e y 2018, Bates E-mail Allaham, was marked 23 f o r produced to us stamped from Dated Nick January as A l l a h a m identification, as of date.) WOLOSKY: 24 Q 25 forwarded It is an e - m a i l to y o u from Nick that has Muzin on been Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 352 of 386 Page ID #:5522 Page 351 1 Allaham 2 January 3 forwarded 4 Wieder 5 2018, 6 A Okay. 7 Q And 8 the 25, - ATTORNEYS' 2018, e-mail to N i c k at 1 : 0 9 forwarding 9 A Yes. 11 Q What 12 ONLY p.m. And is an e - m a i l Muzin dated the from Ben January 26, a.m. Nick Muzin e-mail, Do y o u 10 at 5 : 2 5 EYES see does writes "Time to y o u in to r o c k . " that? he m e a n by, "Time to rock"? 13 MR. 14 for 15 A GIMBEL: Objection. Calls speculation. I mean, nearer 16 e-mail, "Hope you 17 Sending along my c o n t a c t 18 mentioned, we s p o k e 19 on a s t o r y about 20 to t a l k . 21 you." 22 Let meant, but 24 was 25 excited. working a good info. Elliott when I am w o r k i n g and is b e s t know states on a s t o r y , As I Broidy I don't it c l e a r l y bottom flight. briefly. me k n o w I mean, 23 had to t h e and hoping for what that Nick he somebody was Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 353 of 386 Page ID #:5523 Page 352 1 Allaham 2 3 Q - ATTORNEYS' And to y o u , he c o n v e y s A He w r o t e 5 Q And it, you share his he e x c i t e d ? excitement? A No. 8 Q Why was MS. YUSUF: 9 Objection. 10 A I don't know. 11 Q Did ever 12 Muzin 13 was 14 why you he w a s going after A I mean 15 were 16 me, 17 Elliott. 18 cannot not that Elliott Q Why excited and 21 he d i s l i k e A would that It is c o m p e t i t i o n . 24 perceive 25 different it. way. I should coming something media we say for down that's on -- I about. you think he w o u l d to r o c k ? be Did Broidy? I think 23 the Nick -- a g a i n , it is t i m e Elliott Again, not, Nick with Broidy? of w h a t ' s So it w a s for that it is n o t -- a w a r e speak discuss excited -- or I w a s 20 22 excitement yes. did 7 19 that ONLY correct? 4 6 EYES it is a r i v a l r y . So t h i s I cannot I mean look is h o w I at it a n y he h a s to a n s w e r it Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 354 of 386 Page ID #:5524 Page 353 1 2 Allaham for Q 4 Muzin 5 the 6 work how for you extent 9 to s p e a k Mr. Broidy anyone 11 You 12 lobbying 13 Broidy knew to u s , for 16 U.S. Joel was Nick having officials A of h i s did. But of lobbying to w h a t I don't want I don't think Elliott is t h e I never Q but about had, so. who was guy believed for the exhibit 23 moment 24 WhatsApp ago, Yes. you I never please we w e r e messages. with I cannot myself, Exhibit Elliott senior Objection. know. can that that Qatar? YUSUF: Now, 22 believe discussions I don't him, A an i m p e d i m e n t I knew extent Qatar. MS. 21 Nick was. 17 it. think behalf. what Did Broidy 20 with was or N i c k on h i s know, 15 for discuss Qatar? Q 19 ONLY completion it w a s , 10 18 ever I don't 8 25 Did successful A 14 EYES himself. 3 7 - ATTORNEYS' believed go b a c k looking 5, t h e speak at a exhibit of to Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 355 of 386 Page ID #:5525 Page 354 1 Allaham 2 3 Q - ATTORNEYS' Now, We d i s c u s s e d the 4 A Yes. 5 Q I'm 6 you know we w e r e who sorry. Ben Ben 8 Q Yes, 9 A Exhibit 10 Q Have 11 A Never. 13 until 14 Q 15 the 16 turn And talked I'll spoke to a n y stamp You 19 Mr. 20 press going 21 "Just be v e r y reply e-mail, after Why A reporters to E x h i b i t 30, can 5, you within that 60 s e c o n d s said, Broidy." You "We to got the reply, careful." were you advising Mr. Muzin careful? Because all on t h e page. Q to be v e r y to h i m ? state Bates 18 that ever I don't. page, Yes. 25 you No, back A 24 23? going 22 do 23. Now, 17 23 on E x h i b i t article. Muzin's we go o n , Wieder? I never to t h a t 29. is? my l a s t - w e e k next on p a g e Before Wieder A record, just ONLY e-mail. 7 12 EYES of t h i s I did stuff not was really not believe relevant to Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 356 of 386 Page ID #:5526 Page 355 1 Allaham 2 me. 3 Elliott, - ATTORNEYS' I sympathized with to be h o n e s t . EYES what ONLY happened with Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 357 of 386 Page ID #:5527 Page 356 11 Q Is t h e r e 12 WhatsApp 13 that messages refers to t h e A I don't 15 Q Do y o u 16 A Usually, 17 also, when 18 liked to s h a r e 19 don't want 20 I knew 21 want 22 it is d o n e . I was Q message to w h i c h 25 got press point to it. I'm going doing anybody that's you're press. press So until immediate replying after I -- I d o n ' t in t h e the I never because up in t h e But going to s t a t e things, up b e i n g Right. can -- with 24 the see something it to e n d you in t h e s e documentary? it to e n d that place that 14 23 any says, Broidy." "We So y o u Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 358 of 386 Page ID #:5528 Page 357 1 Allaham 2 reply, 3 himself." "Alan 4 is d o i n g Is y o u r 5 nothing 6 Broidy? 7 8 - ATTORNEYS' absolutely 9 the Absolutely Q would 10 in r e s p o n s e to M r . 11 going Broidy? 12 A after 14 only 15 always 16 And that text 18 hill one 19 21 things -- I ' m 17 which The write had after -- message the press. It So I j u s t from the then last sentence the is, "He I think does press. helped in so t h e is g r e a t . " that article press I never to t h e up. that about again, mean? in T h e Hill that he wrote. 22 Q That 23 A Mr. Dershowitz. 24 Q And then write to M r . 25 going paranoid message What A that We h a v e Muzin's in s p e a k i n g screws Q 20 you I stated, believed that press not. tomorrow not. Why 13 ONLY something testimony to do w i t h A EYES you who wrote? two Muzin, text messages "This Vegas down thing Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 359 of 386 Page ID #:5529 Page 358 1 Allaham 2 is b o t h e r i n g 3 - ATTORNEYS' A Him is t h a t being 5 really recall, 6 kicked -- I d o n ' t 7 out 8 about, 9 but or s o m e t h i n g he w a s Q on t h i s page 11 Muzin. It r e a d s , 13 A Yes. 14 Q Who 15 A Just individual. 17 Vegas, 18 19 did Q Bob a wealthy me message you Book to N i c k go?" Republican asking if he w a s in he g o . Mr. is he i n v o l v e d If y o u 22 which is B a t e s And in r u n n i n g Book? Q Muzin? from Book? 21 25 WhatsApp is B o b No. on M a r c h last that? A 24 kicked out. see 20 23 he w a s -- he t o l d "Does I was And Miramax, he w a s to? -- I d o n ' t if he w a s is a m e s s a g e Do y o u 16 I think know the 10 in r e f e r e n c e -- I t h i n k kicked Now, 12 ONLY me." What 4 EYES can turn stamped do y o u 1, 2 0 1 8 , to t h e next page 31. see between texts you that and begin Mr. Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 360 of 386 Page ID #:5530 Page 359 1 Allaham - ATTORNEYS' 2 A What 3 Q Bates 4 A Yes. 5 Q There 6 messages 7 these 8 Mr. 9 something that are Broidy 12 A The 13 14 Real Q Do y o u see Yes. 16 Q And p.m., 18 "He 19 A Yes. 20 Q Did 21 finished 22 articles? 23 A his 25 about concerning with that? is i t ? Yes, I see it. line? The Mr. Real Deal and the Wall Muzin you see I have -- t h i s , to y o u at that? think as a r e s u l t -- I d o n ' t writes is f i n i s h e d . " Do y o u 24 and Journal. A 1:04 date Yes, Street 1, 2 0 1 8 , relationship 1MDB. Deal of t e x t on M a r c h called 15 17 his What 31. is a s e r i e s articles and ONLY 31? stamped begin news 10 11 page, EYES that of t h e s e no i d e a . -- I w a s to m e , Broidy was news I don't not was know concerned pure trash and Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 361 of 386 Page ID #:5531 Page 360 1 2 Allaham EYES ONLY gossip. 3 4 - ATTORNEYS' Q But Nick is c o n c e r n e d MS. YUSUF: about it, correct? 5 6 A I can't 7 Q What 8 believe 9 "he Nick Objection. speak does means for he m e a n when Nick. -- w h a t he w r i t e s do y o u to y o u is f i n i s h e d " ? 10 A 11 speak 12 Q I don't for know. believe 13 role in t h e 14 that he is s e n d i n g 15 sending A publication I don't 17 reporters 18 knew 19 likes 20 Q did he w a s Nick of t h e to had a articles and you believe so, no. Broidy A 24 speak were 25 knowledge press, would and Nick, of a n y And Nick so -- lobbying for Qatar concerning Malaysia? I don't but I think everyone Qatar. articles Again, for because for to t h e to do w i t h 23 him lobbying So w h a t Elliott that to y o u call to s p e a k 22 going to h i m ? 16 have not Nick. Do y o u 21 I'm I was of t h e s e know, not I can't -- a n y besides what you Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 362 of 386 Page ID #:5532 Page 361 1 2 Allaham saw, - ATTORNEYS' so I d o n ' t 3 Q Did 4 reporters 5 Elliott ever calling Broidy's A No. 7 Q Did you 8 A You know, 9 being 10 and 11 told, 12 Q 13 they were that for A were I think -- s i n c e to t a l k ask are -- t h a t ' s think -- I g e t 17 typical 18 you want someone to go on t h e 19 whatever to h e l p put 20 add 21 opinions, not for Nick. 22 Q Can you turn reporters. -- w h e n e v e r to it or -- b u t message 25 you Bates on t h a t reads, "We input. were calls. calls 24 I was input? I registered, It's his they was e-mails what for 16 please. Nick hacked got 23 about him? 15 from why e-mails? asking do y o u Nick's to y o u he -- a g a i n , there they him ever calling Why asking 14 that explain hacked 6 told ONLY know. Nick were EYES page have I got I think you have a scandal, record out. I speak to t h e next stamped 32. which Muzin reason 40 p h o n e it is a something again, I or do Or for my page, The first sends to b e l i e v e to this Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 363 of 386 Page ID #:5533 Page 362 1 Allaham 2 hack was 3 registered 4 Qatar 5 strong 6 terrorism," - ATTORNEYS' sponsored and seeking to p u n i s h opposition said You 8 Do y o u A Yes. 10 Q And "That's 12 registered 14 ridiculous. Q agents of Broidy for his spokesman. see "That's F crazy." that? do y o u mean by t h a t , that agents or n o n - r e g i s t e r e d , I mean Why -- to s e e do y o u think it is ridiculous? 17 A Because 18 is my o p i n i o n , 19 Americans, 20 don't 21 was 22 you're 23 the what That 13 16 by F crazy"? A 15 Mr. out to s t a t e - s p o n s o r e d respond, 9 ONLY carried unregistered 7 11 and EYES I don't lobbyists know. Just shocking, same excited defeated. I don't believe were times. your So it is n o t go o u t 25 is -- y o u k n o w , at t h e any that's You end I -- it know, opponent something of c o n t e x t . should -- t h i s involved. something to s e e 24 believe You that know, of t h e being it day, Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 364 of 386 Page ID #:5534 Page 363 1 Allaham 2 Elliott 3 the 4 5 - ATTORNEYS' lost this Did you that's really consider No, I don't Elliott your enemy? A 7 enemy. I don't. 8 trying to -- J o e l 9 trying to m a k e 10 chaos 11 Q because day, Elliott 13 mean by t h a t ? 14 A you lost Nick right 16 Elliott became 17 e-mails that 18 everything, 19 registered Q this countries. 25 other "At I was have the this end of t h e what do y o u of t h e day, fight," end proposal apparent, from that that the hacked he w a s without I don't doing being understand. fight, who was he f i g h t i n g mind? Again, 24 I was as an a g e n t . in y o u r A not at t h e lobbying that my beneficial. say, in h i s Which with and Elliott opposite, vouch we r e a d , And 21 the it is n o t 15 20 can Meaning, was consider Even peace When 12 23 and ONLY conversation. Q 6 22 fight, EYES you We h a v e countries. know, Qatar We a r e there and is t w o we h a v e on t h e other the Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 365 of 386 Page ID #:5535 Page 364 1 2 Allaham These 4 Elliott, 5 a way, 6 on y o u r 7 again, 8 goal 9 looked 10 scored for at i t . the other do y o u think So in other -- working team so t h i s is h o w exposed country. on t h e you, This I don't they end do y o u to s c o r e A know the I don't who, but 18 me a n d 19 capacity. 20 Q was a is h o w I looked -- we at i t . scored the goal scored the goal I know I'm Nick, not Do y o u to t h e think would have a goal? to s p e c u l a t e I could it's believe State A No, I don't. 23 Q Why is t h a t ? 24 A And I think 25 damaging. on it is n o t in N i c k ' s for that him, the so -- hack of Q a t a r ? Not it w a s opposite. say not speaking 22 The press. want definitely beneficial who up in t h e Who reason other out, Elliott? 17 21 ONLY So if y o u ' r e against Who came something working Q 16 had the opponent. A 14 15 you against and e-mails exposed Q 12 13 EYES side. 3 11 - ATTORNEYS' at a l l . very much was Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 366 of 386 Page ID #:5536 Page 365 1 Allaham - ATTORNEYS' 2 Q Why 3 A Because 4 this 5 not 6 believe 7 not. 9 Qatar 10 A 12 But 13 against 15 had if s o m e o n e any period. for the the it w a s State of hacking? them, to s p e a k for a nation. me, was I don't I think that I would and it advise of t h a t . MS. think the to h a c k YUSUF: State Mr. of Q a t a r Broidy? Objection. 17 A I don't 18 Q Do y o u believe 19 Qatar has hacked other 20 State of Q a t a r ? 21 A 22 whatever, for asked ability 16 without speak Do y o u the Qatar, responsible my p l a c e Q hacking, think I cannot is n o t winning beneficial. Do y o u 11 14 for it w a s was we w e r e This beneficial Q ONLY is t h a t ? hacking. 8 EYES know. I don't know. that the enemies Not State of t h e to my knowledge. 23 Q Have 24 about hacking 25 State of Q a t a r you read taking and public place the reports between United Arab the of Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 367 of 386 Page ID #:5537 Page 366 1 Allaham - ATTORNEYS' EYES 2 Emirates? 3 A I have read reports 4 Q Do y o u know anything 5 A I do n o t 6 read. 7 Q Do y o u 8 A I don't 9 know that. about what that? I it to be t r u e ? know. I cannot speculate. Q 11 document, 12 are 13 32. We j u s t talked 14 text message that 15 "That's Okay. on t h e 17 Q Yes. 18 Can that's A The that you to t h i s document is B a t e s about Page I ask Bates I like 21 you 22 explanation. -- we stamped an e - m a i l wrote should read 32, you that or a said, 32. to t u r n so it w i l l What part 24 A "Now it m a k e s have to t h e 34? There Q Mowbray right? stamped 23 and go b a c k F crazy." Yes. 20 5. document A page So l e t ' s Exhibit 16 25 about besides believe 10 19 ONLY is o n e give part an is t h a t ? been sense going why Broidy after me f o r Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 368 of 386 Page ID #:5538 Page 367 1 2 Allaham months." 3 4 but 5 they are 6 just found 7 after Meaning he j u s t I'm seek reading not it, going now why Because Nick, and that's Joel, and I was 12 There was no r e a s o n 13 stuff. Q He p u s h e d And Mowbray have 16 months, you're 17 just been 18 for hack been Nick, why they going rivalry for going after that kind of Broidy after Nick is b e c a u s e was me, it. why Qatar I kept against about this reason that going and for they responsible e-mails? No. MR. completely 22 testimony 23 A 25 have upset of t h e i r 21 24 for sense articles saying, discovered the very the 15 20 it o u t . Meaning was their 11 A him. Joel on s a y i n g . 19 speaking they 10 14 ONLY figured it m a k e s after out EYES Nick. 8 9 - ATTORNEYS' GIMBEL: Objection. mischaracterizes in t h e most his ridiculous No. MS. objection. YUSUF: I join in t h a t way. Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 369 of 386 Page ID #:5539 Page 368 1 Allaham 2 Q 3 again 4 A - ATTORNEYS' So, what I'm your Mowbray 6 read were the Can 8 Bates stamped 9 A Yes. 10 Q There 11 March you turn number 6, 2 0 1 8 , are why Nick, to t h e explain Broidy after and he page that's 34. e-mails between Do y o u see you that beginning and Nick in t h e Muzin. middle page? 14 A Yes. 15 Q You 16 articles 17 Bloomberg 18 send and one Do y o u A Yes. 20 Q And 21 "Saw it, 22 coming 23 Joel." 24 means out. see More York Muzin Broidy people know It m e a n s one two news is Times. that? Mr. more Muzin Broidy, is N e w then Do y o u A to M r . concerning 19 25 you is? out after ONLY e-mails. Q the found going 7 12 can testimony He j u s t 5 13 sorry, EYES stuff talking what what responds, that it s a y s , will be about means? meaning of Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 370 of 386 Page ID #:5540 Page 369 1 2 Allaham more stuff 3 Q 4 that? 5 A 6 reporters 7 Q 8 - ATTORNEYS' is c o m i n g And how were Can please. This 9 A Yes. 10 Q The 11 A Yes. 12 Q The 13 discussed. 14 Biniatta A Yes. 17 Q Has 18 money 19 A Never. 20 Q Has 21 money stamped 35. page. that we h a v e "Broidy page, already is s a y i n g see that? Biniatta ever paid you any Biniatta ever paid you any indirectly? MS. YUSUF: 23 A I don't 24 Q You paid next directly? 22 25 to t h e him." Do y o u 16 to my k n o w l e d g e , of t h e message It s a y s , know him. turn bottom Muzin calling is B a t e s framed 15 Mr. again, always you ONLY out. does Because, EYES money know. don't to y o u Objection. know if B i n i a t t a indirectly? ever Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 371 of 386 Page ID #:5541 Page 370 1 Allaham - ATTORNEYS' 2 A No. 3 Q Have 4 from A No. 6 Q The 7 Biniatta, 8 Mr. 9 stupid," "Call And to M r . These space of t e n with anyone Why call shit," then continue you're you Muzin. saying say, And about "This then to is you say, are 3 messages in t h e minutes. did you want Mr. Muzin to you? 15 A 16 remember. 17 Q Was 18 A I had 19 attention 20 Q 21 met me." 13 14 messages "Holy Muzin. 11 12 ever ONLY Biniatta? 5 10 you EYES I don't it a b o u t you It's A Yes. 23 Q The 24 sends 25 leaked to y o u Biniatta? top turn to t h e stamped of t h e a Huffington e-mails paid much next page, stories. Bates 22 I don't no -- I n e v e r to t h e s e Can please. remember. of E l l i o t t 37. page, Post Mr. Muzin story Broidy. about Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 372 of 386 Page ID #:5542 Page 371 1 Allaham 2 - ATTORNEYS' Do y o u 3 A Yes. 4 Q And 5 you Do y o u 6 A I do. 7 Q Do y o u 8 see EYES ONLY that? respond, see "Crazy." that? know why you responded "crazy"? 9 A Just 10 not 11 enthusiastic 12 -- I ' m Q my r e a c t i o n , not saying about And 13 another article 14 is f r o m The 15 again, it is a b o u t 16 write, "This 17 mentions 18 Uh-huh. 20 Q Why that Mr. 22 about 23 A 24 don't 25 articles. 12, you Muzin Elliott and probe. one send this one And And you in a w a y is g o o d , I think." that? you was Muzin Reporter. the see did not on M a r c h which A I'm excited. is a l o n g 19 it. not Hollywood you, it is I'm to N i c k Do y o u 21 I love it. then that think it w a s mentioned good in an a r t i c l e Broidy? I have remember. I was to r e a d There trying the are article. I so m a n y to m a k e him feel Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 373 of 386 Page ID #:5543 Page 372 1 Allaham - ATTORNEYS' 2 good. I don't 3 Q Now, 4 you read 7 A 8 idea. 9 Q You Now, is f r o m 11 anything 12 stick." you 13 they A Yes. 15 Q Who 16 sentence? 17 A You 19 don't 20 not "Call recall have me," whether get I was that believe Q please. next after Mr. Muzin put see is t h e all in a l l Can It's you 23 A Yes. 24 Q Again, 25 referring "I d o n ' t "they" turn to " t h e y " -- it think will in t h a t of t h e s e your articles. client. records. of t h i s Mr. no that? the Bates says on B r o i d y defending from I have message Muzin, will I mean see, my r e c o r d s , the Do y o u 18 say, to M r . 14 22 you you? 10 21 know. Do y o u called ONLY it. 5 6 EYES Muzin, I did nonsense. to t h e stamped You next page, 38. here, in a m e s s a g e is he s e n d s Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 374 of 386 Page ID #:5544 Page 373 1 Allaham 2 you 3 reviewing - ATTORNEYS' on M a r c h 13, the 4 2018, see 5 A Yes. 6 Q Who is t h e 7 A I'm not of " t h e y , " 9 reading 10 would 11 e-mails. 12 13 14 A 15 them. 16 Q 17 A 19 know. 20 Q 22 23 that the "they"? sure what -- I m e a n e-mails does not Jamal was sure the everyone the reflect point that was Qataris reading is t h e was was assumed this "they" I'm Qataris, 18 21 And Jamal that? be -- e v e r y b o d y Q belief but those about ONLY e-mails. Do y o u 8 EYES those your Qataris? what I refer working for to the right? I don't Jamal know. had I still don't a relationship with Qataris? A nation 24 Q 25 taken He h a d a relationship in t h e world, I would Why do y o u think credit for the Broidy with every say. he w o u l d e-mails? have Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 375 of 386 Page ID #:5545 Page 374 1 Allaham 2 A - ATTORNEYS' I don't 3 Broidy e-mails. 4 for 5 together 6 team the I'm proposals that's look 11 that. 12 Qatari, you 13 around, Elliott's 14 see stuff. 15 context 16 in. 18 "I'm 19 the 20 team? 21 A 22 23 24 25 No, credit that Nick Q for about put the just in know, I would make not say it is l i k e the if it w a s team the would So t h i s would put is r e a l l y it i n , our texted he t o o k the credit," a victory No, it's was right This Yes. not, all for Mr. the is a r e f e r e n c e to it Muzin, you meaning along way the phrase you for other be h a p p y So w h e n Benomar? A Nick again, know, that sure credit -- y o u I mean, Meaning, Q that ONLY good. A the the thinking make 10 17 mean EYES mean Qatari the about credit -- to J a m a l Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 376 of 386 Page ID #:5546 Page 375 1 Allaham 2 Q 3 what 4 would - ATTORNEYS' So I ' m you are take not saying the sure that credit 14 MS. YUSUF: 15 MR. GIMBEL: 16 A 17 at it a s . 18 Q 19 "Any I mean ONLY I understand you believe he for? Objection. Objection that's On M a r c h EYES 14, what you to f o r m . I would ask Mr. look Muzin, news?" 20 Do y o u see that? 21 A Yes. 22 Q What is t h a t 23 A It's more 24 is h o w 25 wife you phrase -- I m e a n of an A r a b i c this this referring to? way, conversation. is h o w this My I communicate. Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 377 of 386 Page ID #:5547 Page 376 1 Allaham 2 Like, 3 "any 4 - ATTORNEYS' what's going Q And a minute 6 intel Mr. later, about 7 the see A Yes. 9 Q Does 10 A No. 11 Q So w h a t Broidy event 13 A Broidy Mr. that fundraiser that? 18 A I think whole world 21 Q What 22 referring 23 A TV. 24 fundraiser 25 was every I'll event less get than some soon." that? is t h e intel about he is r e f e r r i n g not Were responds Arabic? I'm 17 20 say speak YUSUF: Q The you Muzin MS. 16 19 Muzin Broidy 8 15 on in A r a b i c , "Nothing. Do y o u 14 ONLY news." 5 12 EYES the to? Objection. sure. I think the probably. you very curious everybody was was curious, the was about curious. if y o u fundraiser watch you were to? That they to t h e night were throwing president. on T V . a I mean that Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 378 of 386 Page ID #:5548 Page 377 1 Allaham 2 Q 3 March 4 39. - ATTORNEYS' Now, -- t h e next 5 A Yes. 6 Q And 7 article 8 an a r t i c l e 9 have, on t h e and I'll someone named 11 Broidy. You 12 A I have 14 Q Why you stamped send Muzin to y o u and "That's an sends which it's we about Elliott not good." Vanetik? no c l u e . did you respond, "That's not good"? 16 A 17 articles. I'm 18 Q There Because, 19 were 20 response sent 21 22 on McClatchy, Vanetik is Y u r i page Mr. represent 13 15 from respond, Who 15, sorry, Yuri ONLY is B a t e s on M a r c h to y o u 10 next page to -- I ' m EYES not 23 to y o u I don't of b a d many you didn't know why you was not good? like articles. articles that that have any to. in p a r t i c u l a r A a fan are Do y o u one again, No, 24 But I think 25 the same I don't recall I responded response. It's thought this this one. many times, that's not -- I ' m not -- Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 379 of 386 Page ID #:5549 Page 378 1 Allaham 2 I don't 3 shots. 4 5 cheer Q Yuri 6 - ATTORNEYS' for And Vanetik 8 Q And 9 write Ben Brafman And Ben Brafman know is c h e a p who your Never met the down, on t h i n k i n g you to u s e what is it t h a t do f o r YUSUF: you thought Jamal? Objection. Asked answered. MR. 16 Misstates BY M R . messages Jamal." could MS. and text "I k e e p for 15 17 no c l u e . two to M u z i n , 13 14 this guy. 11 12 don't ONLY is? I have 10 -- to m e , so y o u A 7 EYES GIMBEL: his Objection. prior testimony. WOLOSKY: 18 Q What 19 sentence, 20 Brafman is t h e "I k e e p for meaning on t h i n k i n g of t h i s to u s e Jamal"? 21 A To s u e 22 Q That 23 A Yes. 24 Q Why 25 A Because him. you would would you I was sue sue Jamal? Jamal? getting the Ben Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 380 of 386 Page ID #:5550 Page 379 1 2 Allaham - ATTORNEYS' Q About what? 4 A About my m o n e y . 5 Q That 6 A I mean, State of Q a t a r . 7 the 8 couldn't 9 in t h a t . Jamal Q And 11 A No. 12 Q Why 14 A 15 don't I couldn't Everyone Nobody sue -- I was interested Mr. Benomar? did you sue did you decide Because the lawyers have an a g r e e m e n t MS. YUSUF: 17 anything 18 A Okay, 19 Q So t r y 20 without 21 privilege 22 A 25 to y o u ? not to s u e him? 16 24 owed Jamal, do t h a t . 10 23 ONLY runaround. 3 13 EYES that's it's revealing told and it w i l l be -- Don't testify to privileged. privileged. to a n s w e r the question attorney-client information. That I did not want to w a s t e money. Q Benomar? me I On l a w y e r s to c h a s e Jamal any Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 381 of 386 Page ID #:5551 Page 380 1 Allaham - ATTORNEYS' 2 A Yes. 3 Q How 4 owed 5 money ONLY do y o u think he you? A 6 it's 7 share 8 Q 9 much EYES It's not only -- i t ' s something yet. It's Well, that deposition. relevant 11 subpoena. So I w o u l d 12 answer question. 13 Can 14 question? 15 A I know 16 understand 17 parties 18 something 19 owed 20 pinpoint, 21 from 22 million. the that, and something but a number, you back to p l e a s e the Again, know, I think the other party be f r o m I would five Q And you were seeking 24 Jamal Benomar for that money 25 the was really I'm thinks 23 money it is t w o So it is h a r d my p o i n t could pending I you else. eyes of y o u r question. question. from to I think. matter ask read the want is d i r e c t l y subject you So is an a t t o r n e y s ' This 10 the I would confidential, this to t h e complicated. owed owed I'm to say to t e n to p u r s u e even to y o u though by t h e Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 382 of 386 Page ID #:5552 Page 381 1 Allaham - ATTORNEYS' 2 State 3 A Yes. 4 Q And 5 6 of Q a t a r , Benomar was A answer 8 part, 9 sometimes 10 I was 11 It w a s is t h a t holding so I d i d you know than 13 to g e t 14 to d o . my m o n e y , I was 15 MS. 16 we h a v e 17 but 18 confirm. reached ask all the 20 MR. WOLOSKY: 24 25 trying collector. I believed mark, videographer VIDEOGRAPHER: 23 to p i n p o i n t seven-hour THE 22 up on t h a t . I was Counsel, 19 21 an o f f s h o r e , trying the is a baby. a debt YUSUF: -- t h i s I gave that's you? know, have was being I will what having So I j u s t for a straight -- y o u if y o u Jamal money get to do i t . harder 12 not your excuse because that not know, trying ONLY correct? I could 7 EYES Two We g e t to minutes. eight hours. BY M R . Q please, WOLOSKY: Can Bates "You you turn stamped see to t h e next page, 40. juice in i t ? " Do y o u Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 383 of 386 Page ID #:5553 Page 382 1 2 Allaham see - ATTORNEYS' an e - m a i l 3 that you EYES wrote? MR. WOLOSKY: the federal rules. 5 MS. YUSUF: Which 6 referring 7 MR. GIMBEL: 8 MR. WOLOSKY: 9 MR. GIMBEL: 10 MS. YUSUF: 4 11 12 13 under BY M R . eight rule are hours you to? Can Bates you Seven. Seven hours? Yes. Rule A Yes. 15 Q No, 16 preceding it. 17 a series 18 be e x p e d i t e d 19 Fantastic. 20 turn stamped 14 21 We g e t 30. WOLOSKY: Q that's ONLY to t h e 44. actually, Mr. of t e x t sorry, Muzin and messages, about document this turn you to 4 3 , engage "Nothing will lawsuit. Good." And then you write, "Will give us t i m e . " 22 Give 23 A 24 owed. 25 Q you Probably Can you time for what? to c o l l e c t turn to t h e what I'm document in Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 384 of 386 Page ID #:5554 Page 383 1 2 3 Allaham that's Bates A MR. five 8 9 seven ONLY -- 44. I'll finish in YUSUF: You'll finish in seconds. WOLOSKY: Q Bates 10 MS. seven-hour 12 going 13 that's 14 under all rules MR. WOLOSKY: 17 18 off 19 seven-hour 20 stay 22 if y o u of t h e 25 hours. procedure. I'm going to a s k We're going to go because we're past the WOLOSKY: We're record, but going you to can leave need leave beyond seven wish. MS. 24 to mark. on t h e 23 entitled of f e d e r a l YUSUF: record MR. 21 because question. MS. the you're the so w e ' r e deposition time the more reached Counselor, the the 52. We've mark, to s t o p 15 one stamped YUSUF: 11 16 number WOLOSKY: MS. BY M R . EYES minutes. 6 7 stamped Page 4 5 - ATTORNEYS' YUSUF: Court You to k e e p So u n l e s s you will him have that, you Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 385 of 386 Page ID #:5555 Page 384 1 Allaham - ATTORNEYS' EYES ONLY 2 cannot keep him beyond 3 hours. And the videographer 4 indicated to me t h a t 5 the hours. seven 6 MR. WOLOSKY: 7 more minutes, 8 seek leave 9 witness' 10 Will MS. to g i v e 15 during 15 we w i l l as a r e s u l t you give of t h e this us 15 m o r e YUSUF: you MR. I am n o t beyond what WOLOSKY: You authorized. You 17 for minutes. ten 18 more MS. can YUSUF: reached an a g r e e m e n t 20 outside of w h a t 21 Court authorized is r e q u i r e d . are allow The 19 him last with we w e r e time your ordered to s i t that I firm by t h e -MR. WOLOSKY: 23 ordered by t h e 24 Federal Rules 25 requesting which 16 22 reached minutes? 13 14 has deposition. 11 12 I'm of C o u r t seven we h a v e absent evasion the MS. This Court. of C i v i l YUSUF: I'm wasn't This is t h e Procedure. going to go w i t h Case 2:18-cv-02421-JFW-E Document 238-20 Filed 10/17/18 Page 386 of 386 Page ID #:5556 Page 385 Allaham 1 2 the 3 record. - ATTORNEYS' rules, 4 Mr. 5 not 6 have 7 counsel 8 for 9 do to so we Allaham, answer reached any the wants more are time, to EYES going I'm more ONLY off the instructing you questions. We seven-hour mark. seek leave of has every right he If Court to so. 10 MR. WOLOSKY: 11 THE VIDEOGRAPHER: 12 6:11 13 record. p.m., and we're We will do The going so. time off is the 14 15 16 _________________________ 17 JOSEPH 18 19 Subscribed 20 before 21 of 22 ______________________ 23 24 25 me and this sworn to day , 2018. ALLAHAM