Case Document 111-3 Filed 08/14/19 Page 1 of 17

Exhibit 

Case 1:18-cr-00693-RMB Document 111-3 Filed 08/14/19 Page 2 of 17
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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
MIAMI DIVISION
Case No. 1:16-cv-20194-GAYLES

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For Harald Joachim von der Goltz:
MARCUS, NEIMAN & RASHBAUM, LLP
100 Southeast Third Ave, Suite 805
Fort Lauderdale, Florida 33394
By MATTHEW CHAVES, ESQUIRE
By JEFFREY NEIMAN, ESQUIRE
ALSO PRESENT:
Marcio Martinez, Videographer
Above and Beyond Reprographics

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LYNN McCULLOUGH and WILLIAM
McCULLOUGH,

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Plaintiffs,
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vs.
ROYAL CARIBBEAN CRUISES, LTD.;
RAINFOREST ADVENTURES
(HOLDINGS), LTD.; ELITE SHORE
EXCURSIONS FOUNDATION;
RAINFOREST SKY RIDES, LTD.;
RAINFOREST TRAM, LTD.; et al.,

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Defendants.
_________________________________/

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VOLUME II

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VIDEOTAPED DEPOSITION
OF
HARALD JOACHIM VON DER GOLTZ

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Taken on Behalf of Plaintiffs

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Monday, March 6th, 2017
1:31 p.m. - 2:28 p.m.
2 Biscayne Boulevard, Suite 1750
Miami, FL 33131

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Examination of the witness taken before
Sonja D. Hall
Palm Beach Reporting Service, Inc.
1665 Palm Beach Lakes Boulevard, Suite 1001
West Palm Beach, FL 33401
(561) 471-2995

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Videotaped Deposition of Harald J. von der Goltz

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Direct Examination by Mr. Scarola

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Certificate of Oath

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Certificate of Reporter

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Read & Sign Letter to Witness

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I N D E X

Page No.
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APPEARANCES:
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For Plaintiffs:

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SEARCY, DENNEY, SCAROLA, BARNHART &
SHIPLEY, P.A.
2139 Palm Beach Lakes Boulevard
West Palm Beach, FL 33409
By JOHN JACK SCAROLA, ESQUIRE
By BERNARD O'DONNELL, ESQUIRE
For Defendants Rainforest Adventures (Holdings),
Ltd.; Elite Shore Excursions Foundation;
Rainforest Sky Rides, Ltd.; Rainforest Tram, Ltd.:
COLE, SCOTT & KISSANE, P.A.
9150 South Dadeland Boulevard, Suite 1400
Miami, FL 33156
By STEVEN SAFRA, ESQUIRE
By WARREN CHIN, ESQUIRE (Telephonically)

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PLAINTIFFS' EXHIBIT INDEX

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No.

Description

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118

New York Times Article - Panama Papers

Page No.

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* * * *

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DEFENDANTS' EXHIBIT INDEX

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(No exhibits were marked.)

For Defendant Royal Caribbean Cruises, Ltd.:
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MASE TINELLI
2601 S. Bayshore Drive, Suite 800
Miami, FL 33133
By WILLIAM R. SEITZ, ESQUIRE (Telephonically)
For Defendant Andrew Pierce and AP Electrical:
LITCHFIELD CAVO LLP
600 Corporate Drive, Suite 600
Fort Lauderdale, FL 33334
By MARCI STRAUSS, ESQUIRE

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Palm Beach Reporting Service, Inc.

561-471-2995

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 Case 1:18-cr-00693-RMB Document 111-3 Filed 08/14/19 Page 3 of 17
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THE VIDEOGRAPHER:

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video record.

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2017.

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We are now on the

Today's date is March 6th of

The time is approximately 1:31 p.m.

MR. SCAROLA:

My name is Jack Scarola

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along with Bernie O'Donnell.

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this action sags.

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No, but I did read, for

example, these documents.
BY MR. SCAROLA:
Q

And those documents are which documents,

A

They are the documents -- I don't really know

sir?

We represent

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very well how to describe them legally.

Mr. and Mrs. McCullough, the plaintiffs in

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certificate of service.

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MR. SAFRA:

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Harald von der Goltz.

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THE WITNESS:

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This is the videotaped deposition of

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Steven Safra and Warren

Q

I guess

There is title in bold near the bottom

third of that document.

Chin on behalf of the witness,

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Mr. von der Goltz, as well as what's

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and Objections to Plaintiff's Jurisdictional

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referred to in the complaint as the

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Interrogatories.

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collectively as the Rainforest defendants,

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Q

All right, sir.

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and John Dalton.

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A

And the other one is this.

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MR. NEIMAN:

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Q

I'm sorry.

Chaves on before of Mr. von der Goltz,

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A

This is also objections to request to produce

individually.

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Jeffrey Neiman and Matt

MS. STRAUSS:

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Marci Strauss on behalf

of AP Electrical and Andrew Pierce.

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MR. SEITZ:

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What else did you review?
And --

I don't know what this is.

documents, I guess.
Q

And did you review any other documents.

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A

Yes.

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Royal Caribbean.

Defendant Harald von der Goltz's Responses

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Bill Seitz on behalf of

A

I also read the -- I reviewed the

Panama Papers.
Q

When you say you reviewed the Panama

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Papers, did you review the papers themselves, or did

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you review news accounts of the contents of those

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papers?

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THEREUPON,

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HARALD JOACHIM VON DER GOLTZ,

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being a witness in the notice heretofore

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A

I just read the news account of the Papers.

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Q

Are you referring particularly to what I

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have marked as Exhibit Number 118 and handed to you
just a moment ago?

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filed, and being first duly sworn in the above cause,

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testified on his oath as follows:

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THE WITNESS:

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Yes, ma'am.

DIRECT EXAMINATION

Q

Mr. von der Goltz, you understand that we

Yes, sir.
(Plaintiffs's Exhibit Number 118 was

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marked for identification.)

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BY MR. SCAROLA:

A

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BY MR. SCAROLA:
Q

Is that the first time that you had

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are here for purposes of spending an additional 45

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reviewed that New York Times article, that is, the

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minutes, pursuant to court order, to complete your

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first time in preparation for this deposition, or had

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deposition, which was begun earlier with regard to

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you seen it earlier?

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matters of jurisdiction, correct, sir?

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A

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York Times.

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Q

How many times have you read that document?

All right, sir.

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A

One more time.

Have you done anything to prepare for this

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Q

You saw it when it was published; you read

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A

Q

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Yes.

I understand that's what the reason is

for these 45 minutes.

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it one more time in preparation for today's

Yes.

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deposition?

session?
A

I saw it after it was published in the New

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Q

What have you done?

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A

Correct.

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A

I basically --

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Q

Is that correct?

MR. SAFRA:

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A

Uh-huh.

Q

In reading through that document, to the

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Don't get into

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conversations with your attorney, but you

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can otherwise say.

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extent that the document makes any reference to you

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we talked about.

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whatsoever, did you note any inaccuracies in the New

Don't get into anything

Palm Beach Reporting Service, Inc.

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York Times' account?

observing those rules, okay?

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A

Yes, sir.

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Q

So there is -- I'm sorry.

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A

Yes, sir.

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A

It's inaccurate.

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Q

Thank you.

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Q

And you said specifically that it is all

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inaccurate, is that correct, as it relates to you?

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inaccurate about the references in this article to

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you, and your response was that it is all

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A

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I think it's all inaccurate.

I want to just state that, as a -- in my

Yes?

Is that all right?

I asked you whether there was anything

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capacity as an advisor to EMJO, there are -- the

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inaccurate.

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document that I have been presented with and I have

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A

No, it is not.

Q

So there are portions of this that are

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read is not accurate.

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all cases, but it is not accurate.

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I can't say it's not accurate in

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Since this was based on a document that I

Is that still your response?

accurate; is that correct?

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A

Yes, sir.

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Q

For example, where it says that, For more

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had never seen, I had nothing to do with it.

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never read it.

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by the New York Times.

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that I had never seen.

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and I don't know really what -- where they got these

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contents from.

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A

Yes.

Turn, if you would, please, to --

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Q

You also sought and received help from the

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unfortunately the pages are not numbered -- but about

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a little more than halfway through the document a

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MR. SAFRA:

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heading that reads, "Live This Potential Risk" that

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THE WITNESS:

is in enlarged type?

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and -- as a capacity of a Boston Capital

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19

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Q

I

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than 30 years as the founder of Boston Capital

Obviously, got information

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Ventures, Harald Joachim von der Goltz has built a

It's totally foreign to me

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reputation as a savvy investor in emerging companies.

I saw the article that was written

That's an accurate statement, is it not?

law firm Mossack Fonseca, did you not?
Objection, form.
I did not receive help

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A

Yes, I see it.

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Ventures partner, I never received any help

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Q

Do you see that section?

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or assistance from Mossack Fonseca.

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A

Yes, sir.

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Q

We can agree that that's the section that

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relates specifically to you, correct?
A

I presume that it goes -- I haven't seen the

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BY MR. SCAROLA:
Q

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No, sir.

That was not my question.

My question was did you seek the legal
assistance of Mossack Fonseca?

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end of it, but -- there is the no other heading after

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A

No, I did not, sir.

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that, so I don't know if it involves just me and my

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Q

You have never had them as your lawyers; is

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family or not.

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Q

Well, you do agree that you are referenced

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in the section --

that accurate?
A

I have had them as the lawyers, but I did not

seek any support from them in this context.

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A

Yes, sir.

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Q

-- that reads "Live This Potential Risk,"

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My only question to you was, was the law firm Mossack

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Fonseca a law firm that provided legal help to you?

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correct?
A
Q

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It is your testimony that there's nothing

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is in the document that is being shown and

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asked about.

in that section that is accurate?
A

No.

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Q

Oh, I am sorry.

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Is that true?

I didn't say that.
I thought that is what you

said.

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I asked you if there was anything

Excuse me, sir.

I'm sorry, but if you

MR. SAFRA:

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Objection, form.

THE WITNESS:

Context

In what respect would you

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want to spec -- specifically say that they

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would -- that you want to know in what sense

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they gave me some legal advice?

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inaccurate about --

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Well, I am not sure what context you mean.

Yes, I agree that it references me.

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Q

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BY MR. SCAROLA:
Q

All I want to know is whether they were or

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remember -- and we talked about these rules a little

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bit earlier -- you need to wait until I finish my

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A

In general or specifically?

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question, and I need to wait until you finish your

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Q

With regard to anything.

answer.

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A

They were never my personal lawyers, no.

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So we will do the best we can to go back to

were not your lawyers.

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Q

Did they represent any business entity with

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making a decision.

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which you were associated?

Q

I don't understand that answer.

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A

Yes, they did.

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Q

Which business entities did they represent?

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mother lacked the capacity to be able to make

A

They represented Rain Forest Adventures and

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business decisions on her own?

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MR. SAFRA:

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they also represented EMJO Investments.
Q

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Have they represented any other business

entities with which you have had any connection?
A

Did there come a point in time when your

Right now, except for Revack Holdings, which

Objection, form.

THE WITNESS:

I think my mother was

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never a businesswoman, so clearly she was

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not a person -- she trusted her advisors.

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is a company that -- the entity that owns EMJO, I can't

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And based on the advice she got, she would

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think of -- oh -- no, I don't think that they

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then support those decisions, but she was --

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represented anybody else.

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Q

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Maybe Coral Reef Adventures, but I am not 100 percent

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sure about that.

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Q

I'm not 100 percent sure.

Those that you are sure of are Rain Forest

Adventures (Holdings), EMJO and Revack; is that

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correct?

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A

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Q

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MR. SAFRA:

You can finish your answer.

BY MR. SCAROLA:

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Did --

Q
you.

You can finish.

I didn't mean to interrupt

I thought you had finished.
A

So, she did not, let's say, make decisions on

Yes.

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her own, but relied on the advice she got from her

What was the nature of the services that

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counsel or advisors that she employed when these

that law firm provided for Rain Forest Adventures?

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decisions were made.

They

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were corporate services regarding the -- the different

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authority to make decisions on behalf of your mother

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companies that were established, I believe, in the

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with regard to investments?

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British Virgin Islands.

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A

I don't know that.

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company from the legal perspective.

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Q

Were you ever given the authority to make

A

They were the lawyers for the company.

And they represented the

Q

Was Mossack Fonseca ever given the

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Q

What was the nature of services they

provided to EMJO?
A

They were -- Mossack Fonseca was a legal

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decisions on behalf of your mother with regard to

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investments?

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A

No.

Q

Did you ever communicate to Mossack Fonseca

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representative to EMJO, and they were the ones who were

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deciding on the investments that EMJO would make for my

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decisions as to how investments were to be made on

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mother.

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behalf of EMJO?

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Q

So they had final decision-making authority

with regard to where EMJO's money was invested?
A

After discussions with my mother, yes.

Q

When your mother reached the point,

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A

My only capacity was as an advisor.

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Obviously, I gave some advice to Mossack Fonseca.

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this case, usually through my financial advisor, Dick

In

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Gaffey, who then communicated with Mossack Fonseca.

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whereas, you told us earlier, she was incapable of

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And that advice was either taken or not.

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making business decisions herself, was the

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Mossack Fonseca made, basically, the final decision on

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the investment.

responsibility for making those decisions

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entrusted to EM -- excuse me -- entrusted to Mossack

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Fonseca?

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MR. SAFRA:

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Objection.

Mischaracterization of the testimony.
THE WITNESS:

I don't think I said that

my mother was -- what's the word you used?
BY MR. SCAROLA:
Q

Incapable of making her own business

decisions.
A

Well, I don't think my mother ever was a

Q

Who gave Mossack Fonseca the final

decision-making authority?

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A

My mother.

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Q

How did she communicate that?

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A

I don't know.

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don't know.

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And then

Q

I think verbally or -- I just

But I think probably verbally.

When did you first learn that Mossack

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Fonseca had been given final decision-making

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authority with regard to investments to be made on

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behalf of EMJO?

businesswoman, so it was related more to business-type

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A

I don't remember the time.

decisions, rather than incompetent or incapable of

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Q

How old was your mother when she gave

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Mossack Fonseca final decision-making authority?
A

Oh, she must have been 80 or something like

that.
Q

So they have had that authority for more

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Guatemala?

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MR. SAFRA:

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THE WITNESS:

Object to form.
I didn't think it was

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going to be -- I didn't even know who I

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would be able to contact at the firm

Yes, sir.

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regarding these issues.

Well, not Mossack Fonseca, but -- 20 years

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than 20 years; is that correct?
A

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BY MR. SCAROLA:

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ago it was Mossack Fonseca, and then afterwards it

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Q

Did you ever try?

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was relayed to Mr. Ramses Owens.

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A

No, I did not.

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Q

You never were a resident of Guatemala

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Q

When was the final decision-making

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authority transferred from Mossack Fonseca to Ramses

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Owens?

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MR. SAFRA:

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A

It was, I believe, 2010 or so.

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What period?

Q

To your knowledge, did Mossack Fonseca ever

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2009/2010.

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register you as a resident of Guatemala?

during this period of time, were you?
Objection, form.

THE WITNESS:

No, I was not.

BY MR. SCAROLA:

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A

I don't know about that.

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Q

Have you ever been a resident of Guatemala?

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Q

Did you ever make any effort to determine

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A

Yes.

Q

When?

A

Well, all my life, until I came -- moved to

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whether Mossack Fonseca had registered you as a

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citizen of -- as a resident of Guatemala?

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A

No.

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Q

When you read this account in the New York

the United States.

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Q

And when was that, sir?

Times that says that Mossack Fonseca registered you

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A

That was in the late -- mid- to late '80s.

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as a resident of Guatemala, did you do anything about

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Q

And you have not been a resident of

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that?

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Did you respond to that in any way?

A

No, I have not responded.

I was very upset

Guatemala since the mid- to late '80s, correct?

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A

Correct.

Q

Have you ever signed any documents

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about all the things I read there because they were not

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true.

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representing that you were a resident of Guatemala
after the mid- to late '80s when you moved to the
United States?

And after this article appeared, I basically

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have had very little -- I have had no contact with

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Mossack Fonseca anymore.

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5

Q

Well, this is a statement which you have

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A

I don't recall.

Q

Did Mossack Fonseca attorneys ever talk to

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told us you don't know whether it is true or not,

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correct?

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you about risks involved in claiming that you were a

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registered me as a resident of Guatemala.

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Guatemalan resident when you no longer were one?

You just said, I don't know if whether they

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A

That's right.

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Q

So when you read this in the New York

I didn't know that.

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A

No, they didn't talk to me about that.

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Q

Did Ramses Owens ever talk to you about

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Times, not knowing whether it was true or not, didn't

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registering you as a resident of Guatemala when you

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you want to find out whether these lawyers had

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were no longer a resident of Guatemala?

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improperly registered you as a resident of Guatemala?

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MR. SAFRA:

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THE WITNESS:

Objection, form.
Well, there was so many

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A

No -- not that I can recall -- he didn't.

Q

Did you, in fact, frequently transfer money

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from offshore accounts to accounts in the United
States in order to fund investments for EMJO?

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points in here that were obviously not true

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that I -- after what happened and those

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A

Never.

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publications, there was a big turmoil, from

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Q

Did you direct the transfer of funds from

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what I understand, in the firm.

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offshore accounts to the United States to fund any

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even know who I would have called to talk

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investments recommended by you?

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about that.

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A

No.

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Q

Do you maintain offshore accounts, either

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So I don't

BY MR. SCAROLA:

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in your own name or in the name of any entity, in

law firm prevented you from making an inquiry as to

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which you have an ownership interest, either

whether they had registered you as a resident of

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registered or beneficial?

Q

So it's your testimony that turmoil in the

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MR. SAFRA:

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Outside the scope.

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Objection, form.
It's dealing with

advisor to EMJO, you know, I recommended some

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investments to be made.

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offshore accounts, other assets outside.

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It's been brought up before the Court.

But that to me is not a transfer of

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assets.

Transfer of assets would be, like,

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I will allow a little leeway to the

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transferring an investment from one place to

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follow-up question.

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another.

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Do you need to hear the question again?
I spoke for a minute.

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THE WITNESS:

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The only account that I

have is a personal account offshore, which I

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have in Germany.

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Have you directed the movement of money
from accounts belonging to your mother for any
purpose?
MR. SAFRA:

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BY MR. SCAROLA:
Q

I am talking about moving money.

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That's why.

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Is that what you're referring to or --

Q

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Do you maintain any bank accounts outside

Objection, form.

THE WITNESS:

No, I have not.

BY MR. SCAROLA:

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the United States on behalf of any business entity

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with which you have any connection?

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Mr. von der Goltz's Boston-based accountant asked

Q

This article states, "In a 2008 email,

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A

No.

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executives at Mossack Fonseca to wire money from

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Q

Where is the German account maintained?

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Mr. von der Goltz's mother, Erika."

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A

At Warburg Bank in Hamburg.

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A

Uh-huh.

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Q

Have you ever directed the transfer of any

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Q

Are you aware of that happening?

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money from the Warburg Bank in Hamburg to the United

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A

Is that the reference to the gift that my

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States?

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A
Q

No.

I don't think so.

Have you ever discussed with any Mossack --

mother gave me.

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Q

Yes, sir, the $100,000 gift.

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A

Yes.

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with any Mossack Fonseca attorneys efforts to avoid

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Q

You are aware of that happening?

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the payment of United States taxes?

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A

Yes.

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MR. SAFRA:

Objection, form with regard

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to privilege.

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THE WITNESS:

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MR. SAFRA:

Never.
Without waiver of privilege

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I let him answer that question.

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okay, Jack?

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MR. SCAROLA:

Is that

I don't agree it's

Q

So that part of the article is accurate; is

that correct?

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A

Yes, sir.

4

Q

Yes?

5

A

Yes, sir, it is.

6

Q

One of the names by which you are known is

7

Tica, T-I-C-A?

8

privileged, pursuant to the crime fraud

8

A

Correct.

9

exception.

9

Q

Have you ever discussed any effort to

10

But I understand that you have allowed

10

shield your assets from liability with any Mossack
Fonseca agent?

11

him to answer the question and reserve any

11

12

right you have to claim privilege.

12

MR. SAFRA:

13

THE WITNESS:

13
14
15

MR. SAFRA:

Exactly.

Thank you.

BY MR. SCAROLA:
Q

Have you ever directed the transfer of any

14

that.

15

BY MR. SCAROLA:

Objection, privileged.
No, I have never done

16

assets belonging to your mother through Mossack

16

17

Fonseca?

17

that deal with you are on approximately three pages

18

that begin under the title "Live This Potential

19

Risk."

times before.

18
19

A
Q

No.

Never.

Have you ever directed your accountant to

Q

The portions of this New York Times article

And you said you have read this at least two

20

direct the transfer of assets belonging to your

20

21

mother for any purpose?

21

it was accurate.

22

inaccurate portion in those three portions?

22
23
24
25

A

Can you explain to me transfer of assets,

because obviously I don't understand that concept?
One thing is, let's say, to make an
investment, which obviously in my capacity as an

And you told us initially that none of
Can you identify for us any

23

MR. SAFRA:

24

THE WITNESS:

25

Objection, form.
The second paragraph is

totally wrong.

Palm Beach Reporting Service, Inc.

561-471-2995

 Case 1:18-cr-00693-RMB Document 111-3 Filed 08/14/19 Page 8 of 17
25
1
2
3

BY MR. SCAROLA:
Q

Boston Capital Ventures" ...

4

A

5

Sorry.

6
7

No, no, that's correct.

The third paragraph.

that very clearly that I do -- I have given advice to

2

EMJO, and, obviously, to my mother in my capacity as an

3

advisor to EMJO.

4
5

"What few know, however, is that over
roughly that same span of time" ...

8
9

"For more than 30 years the founder of

27
1

MR. SAFRA:

Take your time.

BY MR. SCAROLA:

Q

I mean, that I have done.

You have told us that the third paragraph

of this article, the one that you just read to us --

6

A

Exactly.

7

Q

-- is not accurate.

8

A

Correct.

9

Q

And I am trying to determine what is not

10

Q

I think you have identified the paragraph.

10

11

A

"What few know, however, is that over roughly

11

accurate about the statements in that paragraph.
I understand that you challenge the

12

that same span of time and with the help of Mossack

12

13

Fonseca, Mr. von der Goltz has also come to command a

13

A

Yes, sir.

14

vast offshore empire: interconnected corporations,

14

Q

The rest of what is said there is accurate,

15

foundations and bank accounts with about $70 million in

15

16

assets, according to internal emails."

16

MR. SAFRA:

17

THE WITNESS:

17

That is totally wrong.

I was -- first of

18

all, my only role was as an advisor to EMJO.

19
20

23
24
25

is it not?
Object to the form.
I don't think so.

It

18

says here, "Has come to command a vast

never was a beneficiary of any of these entities.

19

offshore empire."

It was always my mother.

20

21
22

accuracy of the $70 million number, correct?

And I

21

And the number of -- that they mention
there is also invented.

I don't know where they got

it from.
Q

Well, do you know whether those statements

22

Interconnected corporations.

23

know what they are talking about.

24
25

are an accurate reflection of internal Mossack

I have never commanded an offshore
empire.
I don't

Foundations and bank accounts.

It's

just totally false.

26
1
2
3
4
5

A

That I don't know.

I have no way of knowing

2
3

that.
Q

28
1

Fonseca emails?

Well, one way of knowing it would be to ask

Mossack Fonseca, correct?

BY MR. SCAROLA:
Q

Do you have a relationship with

interconnected corporations?

4

MR. SAFRA:

5

THE WITNESS:

6

A

Correct.

6

7

Q

But you have never done that?

7

8

A

No.

8

9

Q

You do, in fact, have relationships with

9

Objection, form.
As an advisor or what?

BY MR. SCAROLA:
Q

In any capacity, sir.

A

Well, I am on the board of the foundation

that -- that helps to prevent blindness in Guatemala.

10

interconnected corporations, foundations and bank

10

And my mother asked me to serve on that foundation,

11

accounts, correct?

11

so there I have a relationship.

12

MR. SAFRA:

13

THE WITNESS:

14
15
16

Objection, form.
I didn't understand, sir

what that question was referring to.
BY MR. SCAROLA:

12

I don't know any relationship to any bank

13

accounts or -- I don't know what the interconnected

14

corporations are.

I just don't know.

15

Q

Did EMJO pay for your daughter's education?

16

A

It was my mother who paid for it.

17

interconnected corporations, foundations and bank

17

Q

With funds from EMJO?

18

accounts?

18

A

Yes, sir.

19

Q

Did EMJO pay for your granddaughter's high

Q

19

Do you, in fact, have relationships with

MR. SAFRA:

20

Same objection.

THE WITNESS:

I have relationships with

20

school tuition?

21

many things, but not related to this

21

A

Yes, it did.

22

particular -- to this particular article.

22

Q

Did you direct the transfer of funds from

23
24
25

BY MR. SCAROLA:
Q
A

23

EMJO to pay for your daughter's education?

Well, my question to you is --

24

MR. SAFRA:

I mean, I mentioned to you -- I want to state

25

THE WITNESS:

Palm Beach Reporting Service, Inc.

Objection form.
No, I did not.

561-471-2995

 Case 1:18-cr-00693-RMB Document 111-3 Filed 08/14/19 Page 9 of 17
29
1
2

BY MR. SCAROLA:
Q

Were you involved in any way whatsoever in

31
1

A

No, I have not.

2

Q

From the time that the Rain Forest

3

communicating instructions that resulted in the

3

subsidiaries began operating until July of 2015, when

4

payment of your daughter's education by EMJO?

4

Mrs. McCullough suffered her catastrophic fall, did

5

your involvement with the subsidiaries change in any

6

significant way?

5
6
7
8
9

A

Well, my mother, obviously, told me -- or I

discussed it with her.

And one of the purposes or

goals of my mother is that both her grandchildren and

7

A

In what sense?

great grandchildren get a good education.

8

Q

From the time they began --

9

A

I understand.

Q

-- until Mrs. McCullough's catastrophe, did

Q

Were you involved in any way in

10

communicating instructions to transfer EMJO funds to

10

11

pay for your daughter's education?

11

your involvement with the subsidiaries change in any

12

significant way?

12
13
14

A

I communicated this -- what I discussed with

my mother to Mr. Gaffey.
Q

Did you communicate instructions that EMJO

13

A

14

about?

Which subsidiaries would you be talking

15

wire-transfer money to pay for your granddaughter's

15

Q

The Rain Forest subsidiaries.

16

high school tuition?

16

A

I was the director of Rain Forest Adventures,

17
18
19
20

A

I communicated that to -- after discussing

with my mother, I communicated it to Mr. Gaffey.
Q

When was it that you gave the instructions

regarding your daughter's education?

21

MR. SAFRA:

22

THE WITNESS:

What year?

Objection to form.
I don't remember.

23

can't remember when that was.

24

some time ago.

I

Obviously,

25

17

and that's the role that I had -- basically, I had for

18

many years.

19

Q

Yes, sir.

You have in your earlier

20

testimony talked about the relationships that you

21

had, the functions that you performed, the people

22

with whom you interacted.

23

is, from the time the subsidiaries began until July

24

of 2015, was there any significant change in your

25

involvement in and relationship to those

And what I want to know

30
1
2

32
1

BY MR. SCAROLA:
Can you give us any idea as to when it was?

2

A

I think it was in the 2000s probably.

3

Q

When did you communicate the instructions

4

5

for the payment of your granddaughter's high school

5

6

tuition?

6

3
4

Q

7

A

I don't know the date.

8

Q

9
10
11

Objection to form.

THE WITNESS:

I don't think so, but I

can't guarantee that.
BY MR. SCAROLA:
Q

Would you agree that, at least as best you

are able to recall today, what you did, with respect

How old is your granddaughter now?

8

to the subsidiaries, remain substantially the same,

A

Fifteen.

9

correct?

Q

So she is only recently begun high school,

correct?

10

MR. SAFRA:

11

THE WITNESS:

A

Correct.

12

13

Q

So it had to have been sometime within the

13

14

fairly recent past that you communicated those

14

15

instructions to make tuition payments for her,

15

16

correct?

16

18

MR. SAFRA:

7

I wouldn't know.

12

17

subsidiaries?

A

Yes.

It was certainly not in the year 2000.

Q

During the last session of your deposition,

17
18

Object to the form.
I think I explained at my

last discussion with you -BY MR. SCAROLA:
Q

Yes, sir.

And I am just trying to make

MR. SAFRA:

Let him finish his answer.

sure --

BY MR. SCAROLA:
Q

I am just trying to make sure that there

19

you described your relationship to various business

19

weren't any significant changes during the period of

20

entities and the extent of your involvement with

20

time from the time the subsidiaries began until July

21

those businesses.

21

of 2015.

22

correct?

You recall that testimony,

23

A

Yes.

24

Q

Have you read the transcript of your

25

deposition?

Like Canopy and things like that, yeah.

22

A

Not that I am aware of.

23

Q

And the way you did what you did remained

24
25

the same during that period of time as well, correct?
MR. SAFRA:

Palm Beach Reporting Service, Inc.

Objection to form.

561-471-2995

 Case 1:18-cr-00693-RMB Document 111-3 Filed 08/14/19 Page 10 of 17
33
1

THE WITNESS:

Yes.

35
1

I was a director.

2

I tried to, obviously, do the duty I had to

2

3

do for the shareholders.

3

4
5
6

4

BY MR. SCAROLA:
Q

Your relationship with Canopy did not

change, did it?

the formation of the subsidiaries, at least up until
July of 2015, correct?

No.

Q

Your relationship with Rain Forest

8
9

11

THE WITNESS:

MR. SAFRA:

10

Objection to form.
I was -- my capacity was

EMJO's relationship with Canopy and Rain

that period of time from EMJO's foundation through

A

MR. SAFRA:

Q

6

8

Adventures (Holdings) did not change, did it?

I was a general partner in all the funds,

Forest Adventures (Holdings) was unchanged during

7

10

A
correct.

5

7

9

the funds remained the same, correct?

Objection, form.

THE WITNESS:

EMJO never had any

11

relationship or any connection at all with

12

director of Rain Forest Adventures

12

Canopy Enterprises.

13

(Holdings), and that's been my role for many

13

correct.

14

years now.

14

15

BY MR. SCAROLA:

15

16
17
18
19
20

Q

16

So your relationship with Rain Forest

Adventures (Holdings) did not change from the time it

17

was formed through at least July of 2015, correct?

18

A

Yes, sir.

19

Q

In fact -- well, Canopy's relationship with

20

21

Rain Forest Adventures (Holdings) did not change

21

22

during that period of time, did it?

22

23

A

23

Well, Canopy Enterprises did not -- was

Zero.

So that's not

BY MR. SCAROLA:
Q

Well, if it never had any relationship,

then the relationship never changed, right?
MR. SAFRA:

Objection, form.

THE WITNESS:

It was zero.

BY MR. SCAROLA:
Q

Remained zero throughout the entire period

of time?
A

Correct.

Q

So there were no changes in the

24

formed much later than, let's say, the subsidiaries of

24

relationship between EMJO and Canopy because there

25

Rain Forest, so it was much later.

25

never was any.

And the relationship between EMJO and

34
1
2

Q

Yes, sir.

From the time of its formation,

36
1

Rain Forest Adventures (Holdings) remained unchanged
up to July of 2015, correct?

its relationship with Rain Forest Adventures

2

3

(Holdings) remained substantially the same throughout

3

4

that period of time, correct?

4

investor in Rain Forest Adventures (Holdings).

5

did not change.

5

A

Well, let's say when it started, which I

A

They were -- as you know, EMJO was a passive
That

6

don't know if it was started -- that relationship --

6

7

when it was founded or a little bit later.

7

what you did or the way you did it with respect to

8

obviously I provided, as I told you, advice.

8

the Rain Forest subsidiaries until June of 2016 when

9

I am the sole owner of Canopy Enterprises, that was my

9

you resigned from the board and your son took over,

But
And since

Q

In fact, there was no significant change in

10

role and --

10

11

Q

Sole owner --

11

A

That's correct.

12

A

Of Canopy.

12

Q

Who is Victor Gallo?

13

Q

Sole owner and sole employee?

13

A

Victor Gallo?

correct?

I don't know.

14

A

Correct.

14

Q

Name doesn't mean anything to you?

15

Q

And your relationship with Boston Capital

15

A

No.

Q

In the earlier session of your deposition,

16

Ventures did not materially change at all from the

16

17

time of its foundation through at least July of 2015,

17

you described yourself as an advisor to EMJO and said

18

correct?

18

you followed up on investments on behalf of EMJO

19

after those investments were made.
testimony?

19

A

No, it did change in the sense that each

20

partnership had different partners.

So every time a

20

21

new fund was started it was not necessarily with the

21

MR. SAFRA:

22

same partners.

22

THE WITNESS:

23

partners.

24
25

Q

So in other words, we had different

Yes, sir.

But I'm talking about your

relationship with the funds.

Your relationship with

You remember that

Objection, form.
I didn't follow up on --

23

after the investments were made, with the

24

exception of when I was -- for example, in

25

the case of Rain Forest Adventures

Palm Beach Reporting Service, Inc.

561-471-2995

 Case 1:18-cr-00693-RMB Document 111-3 Filed 08/14/19 Page 11 of 17
37

39

1

(Holdings), EMJO was an investor, like

1

2

everybody else.

2

3

reports, which the board issued every

3

4

quarter for Rain Forest Adventures

4

5

(Holdings).

5

6

shareholders, including EMJO.

7

So obviously I had to file

And it was sent to all the

6

The same thing applied, for example, in

7

BY MR. SCAROLA:
Q

Do you know any of the following people:

Dr. Donald Perry, Russell Barnaby or Victor Gallo?
A

I know the first two.

I don't know the

third -- I can't -- I don't remember.
Q

You know Dr. Perry and Russell Barnaby; is

that correct.

8

my capacity as general partner of Boston

8

A

Yes.

9

Capital Ventures.

They also sent to all the

9

Q

Did you ever talk to them about your

10

investors for the limited partners, and they

10

11

sent quarterly reports.

11

involvement with the Rain Forest subsidiaries?
A

No.

They knew I was working for the Rain

12

Forest Trams, and then I think the Rain Forest

I am going to hand you a page from what is

13

Adventures (Holdings) came after they had -- they had

14

a rough transcript of your deposition -- the earlier

14

no more involvement in the company.

15

session of your deposition.

15

16

81, lines 5 through 12, which is a question and

16

17

answer that I just made reference to.

17

12
13

BY MR. SCAROLA:
Q

18

MR. SAFRA:

While he's reading, Jack,

19

it is almost 47 minutes.

20

finish this line.

21

interrupting that.

22

24

I will let you

THE WITNESS:

I think when they were involved it was
call Rainforest Aerial Trams.
Q

Did you ever misrepresent anything with

18

regard to your involvement in the Rain Forest

19

subsidiaries --

20

Obviously I wasn't

MR. SCAROLA:

23

I want you to read page

21

MR. SAFRA:

Objection.

BY MR. SCAROLA:

Thank you.

22

You said just review the

23

MR. SAFRA:

24

THE WITNESS:

I don't think so.

25

MR. SCAROLA:

All right.

1

MR. SAFRA:

page?

25

Q

-- to either Dr. Perry or Russell Barnaby?
Objection, form.

Thank you.

38
1
2
3
4
5
6
7
8
9
10
11
12

BY MR. SCAROLA:
Q

No, sir, the lines, which I think are lines

40
2

A

Oh.

4

Q

That's a question -- one question and one

5
6

answer.
A
Q

Uh-huh.

7

Do you see where you have testified under

8

oath that you followed up on investments on behalf of
EMJO after those investments were made?
MR. SAFRA:

Objection, form.

9

THE VIDEOGRAPHER:
record.

Going off the

The time is 2:21 p.m.

MR. SAFRA:

For the written record,

it's 50 minutes.
(A recess was had.)
THE VIDEOGRAPHER:
record.

10
11

I want

to see if I have anything.

3

5 through 12.

Let's take a break.

Going back on the

The time is 2:27 p.m.

MR. SAFRA:

Counsel for Royal Caribbean

on the telephone, do you have any questions?

12

MR. SEITZ:

No.

investments as -- for example, in the case

13

MR. SAFRA:

Counsel for Mr. Pierce and

14

of Boston Capital Ventures, I do it for

14

15

everybody.

15

MS. STRAUSS:

16

as I would do for all the other investors.

16

MR. SAFRA:

17

I follow up on the investments after they

17

18

are made.

18

MR. SCAROLA:

19

MR. SAFRA:

20

THE VIDEOGRAPHER:

13

19

THE WITNESS:

And the same thing I do for EMJO

So I do it for everyone, not just for

20

EMJO.

21

reviews for EMJO.

22

for EMJO.

23
24
25

I follow up on those

I mean, I don't sit there and do
I have never done reviews

21

AP Electrical?

questions.

record.

We have no questions.
We have no further

We will read.
Thank you very much.
Thank you.

22

MR. SCAROLA:

I have one more question

I would like to ask.

23
24

Going off the

The time is 2:28 p.m.
- - -

(The deposition was concluded
at 2:28 p.m.)

25

Palm Beach Reporting Service, Inc.

561-471-2995

 Case 1:18-cr-00693-RMB Document 111-3 Filed 08/14/19 Page 12 of 17
41
1

43
1

CERTIFICATE OF OATH

TO:

2
2

STATE OF FLORIDA
3

)
3

: SS

4

COUNTY OF PALM BEACH )
5

4
5

I, the undersigned authority, certify that

6

Harald Joachim von der Goltz personally appeared

7

before me and was duly sworn.

8
9

Harald Joachim von der Goltz
c/o SCOTT COLE, ESQUIRE
COLE, SCOTT & KISSANE, P.A.
9150 South Dadeland Boulevard, Suite 1400
Miami, FL 33156

6

RE: LYNN MCCULLOUGH AND WILLIAM MCCULLOUGH
vs. ROYAL CARIBBEAN CRUISES, LTD.; RAIN FOREST
ADVENTURES (HOLDINGS) LTD.; ELITE SHORE EXCURSIONS
FOUNDATION; RAIN FOREST SKY RIDES, LTD.; RAIN FOREST
TRAM, LTD.; ET. AL.

7
8

WITNESS my hand and official seal this 13th
day of March, 2017.

9
10

10
11
11
12

__________________________________

13

Sonja D. Hall

14

Commission No.: FF 082994

15

Notary Public - State of Florida

16

My Commission Expires: 2-01-18

12
13
14
15
16

17

17

18
18
19

19

20

20

21

21

22
22
23

At the conclusion of your deposition given
in the above-styled cause you indicated you wished to
read and sign the transcript.
This letter is to advise you that your
deposition is ready, and we ask that you call our
office at (561) 471-2995 at your earliest convenience
for an appointment to come in.
If you are a party in this action and your
attorney has ordered a copy of this transcript, you
may wish to read his copy and forward to us a
photostatic copy of your signed correction sheet.
It is necessary that you do this as soon as
possible, since the transcript cannot be held beyond
two weeks from the date of this letter.
If you have any reason which you would like
for me to place on your deposition as to your failure
to sign the same, please advise.
Thank you for your prompt attention.
Very truly yours,
PALM BEACH REPORTING SERVICE, INC.
1665 Palm Beach Lakes Blvd.,
Suite 1001
West Palm Beach, Florida 33401

23

BY:

24

SONJA D. HALL

24
25

25

Date:

March 13th, 2017

42
1

REPORTER'S DEPOSITION CERTIFICATE

2
3

STATE

OF

FLORIDA

44
1

CORRECTION SHEET:

2

NAME:

3

vs. ROYAL CARIBBEAN CRUISES, LTD.; RAIN FOREST

RE:

: SS
4
5

4

I, SONJA D. HALL, certify that I was
authorized to and did stenographically report the

7

deposition of Harald Joachim von der Goltz; that a

FOUNDATION; RAIN FOREST SKY RIDES, LTD.; RAIN FOREST
TRAM, LTD.; ET. AL.

5
6

The following corrections, additions or
deletions were noted on the transcript of the

8

review of the transcript was requested; and that the

9

transcript is a true and complete record of my

7

11

LYNN MCCULLOUGH AND WILLIAM MCCULLOUGH

ADVENTURES (HOLDINGS), LTD.; ELITE SHORE EXCURSIONS

COUNTY OF PALM BEACH )

6

10

Harald Joachim von der Goltz

)

stenographic notes.

testimony which I gave in the above-captioned matter
held on March 6th, 2017:

8

PAGE(S)

I further certify that on the 13th day of

12

March, 2017, I notified SCOTT COLE, ESQUIRE that the

13

deposition of Harald Joachim von der Goltz was ready

14

for reading and signing by the witness.

LINE(S)

SHOULD READ

9
10
11
12

15

I further certify that I am not a relative,

13

16

employee, attorney, or counsel of any of the parties,

14

17

nor am I a relative or employee of any of the parties'

15

18

attorney or counsel connected with the action, nor am

19

I financially interested in the action.

16
17

20

Dated this 13th day of March, 2017.

21

18
19
20

22

______________________

23

SONJA D. HALL

21
22
23

24
25

24

SIGNATURE:

____________________

25

DATE:

____________________

Palm Beach Reporting Service, Inc.

561-471-2995

 Case 1:18-cr-00693-RMB Document 111-3 Filed 08/14/19 Page 13 of 17
45
A
able 15:4 19:5 32:7
above-captioned
44:7
above-styled 43:8
account 8:1 9:1
17:21 21:9,10,17
accountant 22:19
23:15
accounts 7:24 20:15
20:15,19,22 21:3
21:13 23:9 25:15
26:11,18 27:24
28:13
accuracy 27:12
accurate 9:10,10,11
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Adventures 1:9
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advisors 15:9,19
Aerial 39:16
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agree 10:2,8,13 22:7
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allow 21:5
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anybody 13:12
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APPEARANCES
2:7
appeared 18:2 41:6
applied 37:7
appointment 43:11

approximately 5:3
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asked 10:19 11:5
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assets 21:3 22:16,20
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Bill 5:21
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belonging 22:16,20
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beneficiary 25:19
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call 39:16 43:10
called 18:20
Canopy 30:23 33:5
33:23 34:9,12
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Canopy's 33:20
capacity 9:8 11:23
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Capital 11:14,23
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certificate 4:5,6 7:8
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certify 41:5 42:5,11
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challenge 27:11
change 31:5,11,24

33:6,9,17,21
34:16,19 36:5,6
changed 35:16
changes 32:19
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Chaves 3:4 5:17
Chin 2:17 5:11
citizen 17:19
claim 22:12
claiming 20:7
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Commission 41:14
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contents 7:24 9:18
context 12:9,10,13
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copy 43:13,13,14
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corporate 2:23
13:22
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26:10,17 27:22
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correct 6:13 8:20,21
9:6 10:3,12 11:11
13:17 17:5 18:7
19:24,25 24:2,8
25:4 26:5,6,11
27:8,12 30:11,12
30:16,22 32:9,24

Palm Beach Reporting Service, Inc.

33:18 34:4,14,18
35:1,3,8,13,22
36:2,10,11 39:7
correction 43:14
44:1
corrections 44:6
counsel 15:19 40:10
40:13 42:16,18
COUNTY 41:3 42:4
court 1:1 6:11 21:4
crime 22:8
Cruises 1:9 2:18
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Dated 42:20
daughter's 28:15,23
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day 41:9 42:11,20
deal 24:17
dealing 21:2
deciding 14:5
decision 15:1 16:12
decision-making
14:7 16:15,21
17:1,10
decisions 14:12,13
14:22,25 15:5,11
15:17,20,22 16:1
16:5
Defendant 2:18,22
7:11
defendants 1:12
2:13 5:14
DEFENDANTS'
4:18
deletions 44:6
DENNEY 2:9
deposition 1:17 4:3
5:4 6:12 8:11,19
30:18,25 36:16
37:14,15 40:23
42:1,7,13 43:8,10
43:17
der 1:19 3:2 4:3 5:5
5:12,17 6:2,9 7:11
11:15 23:15,17
25:13 41:6 42:7
42:13 43:1 44:2
describe 7:7
described 30:19
36:17
Description 4:11

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27:9
Dick 16:9
different 13:22
34:20,22
direct 4:4 6:7 20:18
22:20 28:22
directed 21:19
22:15,19 23:8
director 31:16 33:1
33:12
discussed 21:23
24:9 29:6,12
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discussion 32:12
discussions 14:9
DISTRICT 1:1,1
DIVISION 1:2
document 7:10 8:15
8:23,24 9:9,12,21
12:14
documents 7:2,4,4,6
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Donald 39:3
Dr 39:3,6,22
Drive 2:20,23
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E 4:1
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29:4,10,14 35:10
35:24,25 36:3,17
36:18 37:1,6
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EMJO's 14:8 35:4,6

empire 25:14 27:19
27:21
employed 15:19
employee 34:13
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enlarged 9:23
Enterprises 33:23
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entire 35:20
entities 13:4,8 25:19
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entity 13:1,10 20:23
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entrusted 14:14,14
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ESQUIRE 2:11,12
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established 13:23
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everybody 37:2
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Exactly 22:13 27:6
Examination 2:2
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Excursions 1:10
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excuse 10:21 14:14
executives 23:16
Exhibit 4:9,18 8:3,6
exhibits 4:19
Expires 41:16
explain 22:22
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extent 8:24 30:20
F
fact 20:14 26:9,16
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fall 31:4
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Fifteen 30:9
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filed 6:4
final 14:7 16:12,14
16:21 17:1,10
financial 16:9
financially 42:19
find 18:12
finish 10:23,24
15:13,15 32:16

37:20
finished 15:16
firm 11:20 12:11,12
13:20 18:19,24
19:5
first 6:4 8:9,11
16:20 25:17 39:4
FL 1:24 2:4,11,16
2:20,24 43:3
Florida 1:1 3:4 41:2
41:15 42:3 43:22
follow 36:22 38:12
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Fonseca 11:20,25
12:4,12 14:3,15
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16:12,14,21 17:1
17:7,8,11,14,18
17:22 18:4 20:6
21:24 22:17 23:16
24:11 25:13 26:1
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Forest 13:5,15,20
31:2,15,16 33:8
33:12,16,21,25
34:2 35:5 36:1,4,8
36:25 37:4 39:10
39:12,12,18 43:5
43:6,6 44:3,4,4
form 11:21 12:13
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19:12 21:1 22:1
23:11 24:23 26:12
27:16 28:4,24
29:21 32:2,10,25
33:10 35:9,17
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formation 34:1 35:7
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Fort 2:24 3:4
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functions 31:21
fund 20:16,19 34:21
funds 20:18 28:17

28:22 29:10 34:25
35:1,2
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Gaffey 16:10 29:13
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give 30:2
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Goltz 1:19 3:2 4:3
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42:7,13 43:1 44:2
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grandchildren 29:7
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30:8
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28:19 29:15 30:5
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20:2,11,12 28:9
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halfway 9:21
Hall 2:3 41:13 42:5
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Harald 1:19 3:2 4:3
5:5 6:2 7:11 11:15
41:6 42:7,13 43:1
44:2
heading 9:22 10:5
hear 21:7

Palm Beach Reporting Service, Inc.

held 43:15 44:7
help 11:19,22,24
12:12 25:12
helps 28:9
heretofore 6:3
high 28:19 29:16
30:5,10
Holdings 1:10 2:13
13:9,16 33:9,13
33:17,21 34:3
35:5 36:1,4 37:1,5
39:13 43:5 44:3
I
idea 30:2
identification 8:7
identified 25:10
identify 24:21
II 1:15
improperly 18:13
inaccuracies 8:25
inaccurate 9:2,4,6
10:20 11:6,8
24:22
incapable 14:11,21
14:25
including 37:6
incompetent 14:25
INDEX 4:9,18
indicated 43:8
individually 5:18
information 9:15
initially 24:20
inquiry 18:24
instructions 29:3,10
29:14,19 30:4,15
interacted 31:22
interconnected
25:14 26:10,17
27:22 28:3,13
interest 20:24
interested 42:19
internal 25:16,25
Interrogatories
7:13
interrupt 15:15
interrupting 37:21
invented 25:22
invested 14:8
investment 16:13
22:25 23:5
investments 13:6
14:5 15:23 16:2,5
16:22 20:16,20
23:2 36:18,19,23
38:9,10,13,17
investor 11:16 36:4
37:1
investors 37:10

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involved 20:7 29:2,9
39:15
involvement 30:20
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K
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lacked 15:4
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line 37:20
LINE(S) 44:8
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LITCHFIELD 2:23
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Live 9:22 10:11
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44:2
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ma'am 6:6
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MARCUS 3:3
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Martinez 3:7
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materially 34:16
Matt 5:16
matter 44:7
matters 6:13
MATTHEW 3:4
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mid- 19:22,24 20:3
million 25:15 27:12
minute 21:8
minutes 6:11,15
37:19 40:6

Mischaracterizati...
14:17
misrepresent 39:17
moment 8:4
Monday 1:23
money 14:8 20:14
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29:15
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12:4,11 14:3,14
15:21 16:4,8,10
16:12,14,20 17:1
17:7,8,11,14,18
17:22 18:4 20:6
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23:16 24:10 25:12
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numbered 9:20
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24:23 26:12,19
28:4,24 29:21
32:2,25 33:10
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38:11 39:20,23
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observing 11:1
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official 41:8
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page 4:3,11 37:13
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PAGE(S) 44:8
pages 9:20 24:17
paid 28:16
Palm 2:3,4,4,10,11
41:3 42:4 43:20
43:21,22
Panama 4:12 7:21
7:22
papers 4:12 7:21,23
7:23,25 8:1

Palm Beach Reporting Service, Inc.

paragraph 24:24
25:4,10 27:4,10
part 24:1
particular 26:22,22
particularly 8:2
parties 42:16
parties' 42:17
partner 11:24 35:2
37:8
partners 34:20,22
34:23 37:10
partnership 34:20
party 43:12
passive 36:3
pay 28:15,19,23
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payment 21:25 29:4
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payments 30:15
people 31:21 39:2
percent 13:12,13
performed 31:21
period 19:11,13
32:19,24 33:22
34:4 35:6,20
Perry 39:3,6,22
person 15:9
personal 12:25
21:10
personally 41:6
perspective 13:25
photostatic 43:14
Pierce 2:22 5:20
40:13
place 23:5 43:17
Plaintiff's 7:12
plaintiffs 1:6,21 2:8
5:8
PLAINTIFFS' 4:9
Plaintiffs's 8:6
please 9:19 43:18
point 14:10 15:3
points 18:16
portion 24:22
portions 11:10
24:16,22
possible 43:15
Potential 9:22 10:11
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preparation 8:11,18
prepare 6:17
PRESENT 3:6
presented 9:9
presume 10:4
prevent 28:9
prevented 18:24
privilege 22:2,4,12
privileged 22:8
24:12

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30:3
produce 7:17
prompt 43:19
provided 12:12
13:20 14:2 34:8
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publications 18:18
published 8:13,17
purpose 22:21
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pursuant 6:11 22:8
Q
quarter 37:4
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question 10:24 12:2
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recommended
20:20 23:1

record 5:2 40:4,5,9
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reference 8:24
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referenced 10:8
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register 17:15
registered 17:18,22
18:8,13,25 20:25
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33:5,8,16,20 34:2
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relationships 26:9
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relative 42:15,17
relayed 17:9
relied 15:18
remain 32:8
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remember 10:22
16:24 29:22,23
36:19 39:5
report 42:6
Reporter 4:6
REPORTER'S 42:1
Reporting 2:3 43:20
reports 37:3,11
represent 5:7 13:1,4
representative 14:4
represented 13:5,6
13:7,12,24
representing 20:2
Reprographics 3:7
reputation 11:16
request 7:17
requested 42:8
reserve 22:11
resident 17:15,19
17:23 18:8,13,25
19:10,16,23 20:2
20:8,11,12

resigned 36:9
respect 12:16 32:7
36:7
respond 17:24
responded 17:25
response 11:7,8
Responses 7:11
responsibility 14:13
rest 27:14
resulted 29:3
Revack 13:9,16
review 7:14,19,23
7:24 37:23 42:8
reviewed 7:20,22
8:10
reviews 38:21,21
Rides 1:11 2:14
43:6 44:4
right 6:16 7:14 11:2
13:9 18:9 22:12
35:16 39:25
Risk 9:22 10:11
24:19
risks 20:7
role 25:18 31:17
33:13 34:10
rough 37:14
roughly 25:7,11
Royal 1:9 2:18 5:22
40:10 43:5 44:3
rules 10:22 11:1
Russell 39:3,6,22
S
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6:22 11:21 12:13
14:16 15:6,13
18:14 19:2,12
21:1 22:1,4,13
23:11 24:12,23
25:8 26:12,19
27:16 28:4,24
29:21 32:2,10,16
32:25 33:10 35:9
35:17 36:21 37:18
38:11 39:20,23
40:1,5,10,13,16
40:19
sags 5:9
savvy 11:16
saw 8:13,17 9:14
says 11:13 17:22
27:18
Scarola 2:9,11 4:4
5:6,6 6:8 7:3 8:8
12:1,20 14:20
15:14 18:22 19:7
19:15 21:12 22:7

22:14 23:13 24:15
25:1,9 26:15,23
28:1,6 29:1 30:1
32:5,13,17 33:4
33:15 35:14,19
37:12,22 38:1,23
39:1,21,25 40:18
school 28:20 29:16
30:5,10
scope 21:2
SCOTT 2:15 42:12
43:1,2
seal 41:8
SEARCY 2:9
second 24:24
section 9:25 10:2,9
10:15
see 9:24,25 38:8
40:2
seek 12:3,9
seen 8:12 9:13,16
10:4
Seitz 2:21 5:21,21
40:12
sense 12:18 31:7
34:19
sent 37:5,9,11
serve 28:10
service 2:3 7:8
43:20
services 13:19,22
14:1
session 6:18 30:18
36:16 37:15
shareholders 33:3
37:6
sheet 43:14 44:1
shield 24:10
SHIPLEY 2:10
Shore 1:10 2:13
43:5 44:3
shown 12:14
sign 4:7 43:9,18
SIGNATURE
44:24
signed 20:1 43:14
significant 31:6,12
31:24 32:19 36:6
signing 42:14
sir 6:13,16 7:5,14
8:5 9:2 10:1,10,21
11:3,12 12:2,5
17:6 19:21 23:22
24:3,5 26:13
27:13 28:7,18
31:19 32:14 33:19
34:1,24 38:2
sit 38:20
Sky 1:11 2:14 43:6

Palm Beach Reporting Service, Inc.

44:4
sole 34:9,11,13,13
son 36:9
Sonja 2:3 41:13
42:5,23 43:23
soon 43:15
sorry 7:16 9:3 10:17
10:21 25:5
sought 11:19
South 2:15 43:2
Southeast 3:3
SOUTHERN 1:1
span 25:7,12
spec 12:17
specifically 9:5 10:3
12:17,23
spending 6:10
spoke 21:8
SS 41:3 42:3
started 34:5,6,21
state 9:7 26:25 41:2
41:15 42:3
statement 11:17
18:5
statements 25:24
27:10
states 1:1 19:20
20:4,16,19 21:14
21:21,25 23:14
stenographic 42:10
stenographically
42:6
Steven 2:16 5:10
Strauss 2:24 5:19
5:19 40:15
subsidiaries 31:3,5
31:11,13,15,23
32:1,8,20 33:24
35:7 36:8 39:10
39:19
substantially 32:8
34:3
suffered 31:4
Suite 1:24 2:4,15,20
2:23 3:3 43:2,21
support 12:9 15:11
sure 12:10 13:12,14
13:15 32:15,18
sworn 6:4 41:7
T
T-I-C-A 24:7
take 25:8 40:1
taken 1:21 2:2
16:11
talk 18:20 20:6,9,10
39:9
talked 6:25 10:22
31:20

561-471-2995

 Case 1:18-cr-00693-RMB Document 111-3 Filed 08/14/19 Page 17 of 17
49
talking 23:7 27:23
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taxes 21:25
telephone 40:11
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third 3:3 7:10 25:4
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thought 10:17
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three 24:17,22
Tica 24:7
time 5:3 8:9,11,16
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29:24 31:2,8,23
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33:22 34:1,4,17
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title 7:9 24:18
today 32:7
today's 5:2 8:18
told 14:11 18:6
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43:6 44:4
Trams 39:12,16
transcript 30:24
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43:13,15 44:6
transfer 20:14,18
21:19 22:15,20,22
23:3,4 28:22

29:10
transferred 17:11
transferring 23:5
tried 33:2
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truly 43:20
trusted 15:9
try 19:8
trying 27:9 32:14
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VOLUME 1:15
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42:13 43:1 44:2
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wait 10:23,24
waiver 22:4
want 9:7 12:17,18
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Warburg 21:18,20
Warren 2:17 5:10
wasn't 37:20
way 17:24 26:2,4
29:2,9 31:6,12
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weeks 43:16
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West 2:4,11 43:22
whatsoever 8:25
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WILLIAM 1:5 2:21
43:4 44:2
wire 23:16
wire-transfer 29:15
wish 43:13
wished 43:8
witness 2:2 4:7 5:11
6:3,6 7:1 11:22
12:16 14:18 15:7
18:15 19:3,14
21:9 22:3 23:12
24:13,24 26:13,20
27:17 28:5,25
29:22 32:3,11
33:1,11 35:10,18
36:22 37:23 38:12
39:24 41:8 42:14
word 14:19
words 34:22
working 39:11
wouldn't 30:7
written 9:14 40:5
wrong 24:25 25:17
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yeah 30:23
year 29:20 30:17
years 11:14 17:5,7
25:2 31:18 33:14
York 4:12 8:10,14
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Z
zero 35:12,18,20

1
1:16-cv-20194-G...
1:3
1:31 1:23 5:3
100 3:3 13:12,13
100,000 23:22
1001 2:4 43:21
118 4:12 8:3,6
12 37:16 38:3
13th 41:8 42:11,20
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1400 2:15 43:2
1665 2:4 43:21
1750 1:24
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2 1:24
2-01-18 41:16
2:21 40:4
2:27 40:9
2:28 1:23 40:21,24
20 17:5,7
2000 30:17
2000s 30:3
2008 23:14
2009/2010 17:13
2010 17:13
2015 31:3,24 32:21
33:18 34:17 35:8
36:2
2016 36:8
2017 1:23 5:3 41:9
42:12,20 43:25
44:7
2139 2:10
2601 2:20

6 4:4
600 2:23,23
6th 1:23 5:2 44:7
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800 2:20
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3
30 11:14 25:2
33131 1:24
33133 2:20
33156 2:16 43:3
33334 2:24
33394 3:4
33401 2:4 43:22
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45 6:10,15
47 37:19
471-2995 2:5 43:11
5
5 37:16 38:3
50 40:6
561 2:5 43:11

0
082994 41:14

Palm Beach Reporting Service, Inc.

6

561-471-2995