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Case 1:90-mc-00919-JBS Document 45-12 Filed 10/21/91 Page 1 of 5 PageID: 1647

fJ
1

UNITED

STATES

DISTRICT

DISTRICT

OF

NEW

COURT

JERSEY

2
CIVIL

ACTION

MDL

IN

DONALD

NO.

864

RE:
J.

TRUMP

SECURITIES

LITIGATION,
ORAL

DEPOSITION

MARVIN

OF

ROFFMAN

8
*

9
WEDNESDAY,

SEPTEMBER

25,

1991

10
*

TRANSCRIPT

12
AT

13

THE

STREET,

OFFICES

OF

A.M.

IN

THE

SCHWARTZMAN

PHILADELPHIA,

10:00

ABOVE
&

MATTER

HEPPS,

PENNSYLVANIA,

2033

COMMENCING

14
15

S:

16
17

BERGER
BY:

18

MONTAGUE,
S.

ESQUIRES

COLLINS,

ESQUIRE

AND
CLAY

19

&

TODD
W.

HAMLIN,

III,

ATTORNEYS

FOR

THE

CERTIFIED

SHORTHAND

ESQUIRE

PLAINTIFFS

20
21
22
23
24
25

REPORTING

SERVICES

ARRANGED THROUGH
MASTROIANNI

104
HADDON

&

FORMAROLI,

WHITE HORSE

HEIGHTS,

( 609)

NEW

INC.

PIKE
JERSEY

546-1100

TAKEN
WALNUT

08035

AT

Case 1:90-mc-00919-JBS Document 45-12 Filed 10/21/91 Page 2 of 5 PageID: 1648


18

OCCASION TO,

AT ANY TIME,

LOOK AT THE PROSPECTUS

FOR

A.

YES.

Q.

I'M GOING TO ASK YOU TO TAKE A

DOCUMENT THAT'S BEEN PREVIOUSLY MARKED AS

THAT OFFERING?

LOOK AT A
WEBB-2.

(OFF-THE-RECORD DISCUSSION)

BY MR.

Q.

HAVE YOU SEEN THIS DOCUMENT BEFORE?

A.

YES.

10

Q.

AND THIS

11

A.

YES.

12

Q.

DID YOU

13

HERRING IN

14

NOVEMBER,

15

A.

YES.

16

Q.

IN NOVEMBER,

17

RECOMMENDATIONS

TO

ANYONE

18

WAS A GOOD IDEA

TO

BUY THESE BONDS?

19

A.

YES.

20

Q.

AND DID YOU MAKE THOSE RECOMMENDATIONS

21

NOVEMBER OF

22

A.

IN

23

Q.

AND TO

24

RECOMMENDATIONS?

25

A.

COLLINS:

IS,

IN FACT,

A PROSPECTUS?

LOOK AT THIS DOCUMENT OR

SOME

AT SOME POINT

IN

1988,

MAKE

A RED

OR PRIOR TO

1988?

19

DID YOU
AS TO

WHETHER OR NOT

'88 OR BEFORE NOVEMBER OF


--

IN NOVEMBER OF

ANY

IN

'88?

1988.

WHOM DID YOU MAKE THESE

TO THE SALES FORCE OF

JANNEY,

MONTGOMERY,

IT

Case 1:90-mc-00919-JBS Document 45-12 Filed 10/21/91 Page 3 of 5 PageID: 1649


19

SCOTT.

Q.

AND

IN

A.

THE

SPOKEN

Q.

WHAT

A.

AVOID

Q.

DID

AVOIDED?

A.

YES.

Q.

WHAT

DID

10

A.

THEY

WERE

WHAT

WERE

FORM

WERE

THOSE

WORD.

THOSE

RECOMMENDATIONS?

THEM.

YOU

EXPLAIN

YOU

WHY

THESE

BONDS

JUNK

12

A.

13

PROPERTY

TO

14

WIN

15

ANY

16

RESERVATIONS

17

Q.

WHAT

18

A.

WELL,

19

20

Q.

21

SERIOUS

RESERVATIONS,

22

BELIEVE

THAT

23

A.

THAT'S

24

Q.

DID

25

COVERED

SAID

CASINO

CASINO

WAS

THAT

BREAK
--

WIN

DO

YOU

EVEN,
WIN

THAT
IT

IN

WOULD

--

HAD

---------------

ORDER
HAVE

SUBSTANTIALLY

THAT

FOR
TO

IN

THIS

GENERATE

EXCESS

OF

SERIOUS

THAT.

MEAN

THIS

SERIOUS

PROPERTY

RESERVATIONS?

WAS

ABOUT TO OPEN,

ABOUT THE ECONOMY.

ANSWERS

BY

BE

BONDS.

FELT

EVER,

WHEN

YOU

ABOUT

WORRIED
TWO

SHOULD

SAY?

1-1---Q-.----WHAT-- ELSE-D-IO---YO-U-- SAY?-------I

RECOMMENDATIONS?

THE

AGO

WHEN
DID

YOU
YOU

CASINO WOULD

SAID

MEAN

YOU

HAD

THAT

YOU

BREAK

DIDN'T

EVEN?

CORRECT.
BELIEVE

CASH

FLOW,

THAT
BY

DEBT

SERVICE

INTERNALLY

WOULD

GENERATED

BE
CASH

Case 1:90-mc-00919-JBS Document 45-12 Filed 10/21/91 Page 4 of 5 PageID: 1650


41

A.

Q.

IN

A.

SAINT

Q.

DO YOU KNOW WHERE HE

A.

NO.

Q.

VAN

A.

DAN.

Q.

DAN,

A.

HE

10

Q.

DO YOU KNOW WHERE HE

THINK HE WAS
WHAT

WITH

LEE,

EXCUSE

WITH DREXEL

12

Q.

AND

13

1988?

14

A.

PAINE

15

Q.

DO

16

A.

WITH

17

18

Q.

IS

19

A.

TO MY KNOWLEDGE.

__ .

LEE ISKER,

SMALL

VOGEL

AT

HAVE

Q.

25

WEXLER?

--- ---

NOW?

--------- -

YOU KNOW

---

--

__

___

___

__

WHERE HE WAS

IS

IN

BOUTIQUE

THE

NOW?

IN

SAN

FRANCISCO,

WITH

MERRILL-LYNCH?

COLLINS:

I HAVE

NO FURTHER

MR.

JUST HAVE A FEW.

BRADY:
MR.

YOU EVER

BUT

NAME.

THIS TIME AND

(EXAMINATION OF

24

DO

STILL

MR.

22
23

IS

WEBBER.

REMEMBER

QUESTIONS

NOW?

BURNHAM.

YOU KNOW WHERE HE

20

IS

ME.

F_IRS T_ BOSTON.._

21

FLORIDA.

WHERE WAS HE?

lL ___ A

CAN'T

JAMES.

CITY?

PETERSBURG,

WAS

RAYMOND

THANK YOU.

ROFFMAN BY
MET

MR.

LAWYER

BRADY:)

NAMED

STEWART

Case 1:90-mc-00919-JBS Document 45-12 Filed 10/21/91 Page 5 of 5 PageID: 1651


ROFFMAN

A.

I'VE

Q.

DO

A.

NO.

Q.

DO

A.

DURING

Q.

COULD

THE

TALKED

42

BRADY

HIM.

YOU

RECALL

HOW

YOU

RECALL

WHEN?

MANY

TIMES?

1990.
YOU

TELL

ME

WHAT

YOU

REMEMBER

ABOUT

CONVERSATION?

( OBJECTION )

9
10

TO

READ

THE

MR.

COLLINS:

THE

WITNESS:

HE

TRUMP

TAJ

MAHAL

OBJECT.

GO

WANTED

PROSPECTUS

TO
TO

AHEAD.

HAVE

SEE

ME

IF

l L_ CQ_UL_D_ ITND__S QME__THINCL IR-THERE--T HAT-- MIG H-'I'-- BE---ABLE12

TO

13

BY MR.

14

Q.

DID

15

A.

NO.

16

Q.

DID

17

KIND OF

18

A.

19

Q.

DO

20

YOU

WERE

21

HIM

BECAUSE

22

TRUMP?

23

A.

NO.

24

Q.

NO

25

SAY

GET

THE

PEOPLE

WHO WROTE

IT

IN

TROUBLE.

BRADY:
YOU

AGREE

YOU

EVER

TO

THAT?

YOU

YOU

WITH
HAD

MR.

WITH

WEXLER
DONALD

ANY
TRUMP?

REMEMBER.

RECALL IF

BARRED
OF

YOU

THAT?

DISCUSS

CONVERSATIONS
DON'T

DO

FROM

YOU

EVER

EXPRESSING

AN AGREEMENT

DON'T RECALL

YOU

THAT

TOLD

MR.

WEXLER

ANY

OPINIONS

HAD

WITH

DONALD

YOU

DIDN'T

OR

NO

TO

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