Anwar et al v. Fairfield Greenwich Limited et al

Filing 787

DECLARATION of Savvas A. Foukas in Opposition re: #775 FIRST MOTION to Certify Class.. Document filed by PricewaterhouseCoopers Accountants Netherlands N.V., Pricewaterhousecoopers L.L.P.. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E, #6 Exhibit F, #7 Exhibit G, #8 Exhibit H, #9 Exhibit I, #10 Exhibit J, #11 Exhibit K, #12 Exhibit L, #13 Exhibit M, #14 Exhibit N, #15 Exhibit O, #16 Exhibit P, #17 Exhibit Q, #18 Certificate of Service)(Maguire, William)

Exhibit L

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UNITED STATES DISTRICT COURT

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SOUTHERN DISTRICT OF NEW YORK
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PASHA S. ANWAR, et al.,

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Plaintiffs,
Civil Action No.

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vs.

09-CV-0118(VM)

FAIRFIELD GREENWICH LIMITED, et al.,

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Defendants.
------------------------------------x

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VIDEOTAPED DEPOSITION OF NAJLA AL SHIRAWI

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New York, New York

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September 21, 2011

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Reported by:

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KATHY S. KLEPFER, RMR, RPR, CRR, CLR

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JOB NO. 42088
TSG Reporting - Worldwide

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N. Al Shirawi
(Shirawi Exhibit 1, a document bearing
Bates Nos. SICO 0015724 through 0015813,
marked for identification, as of this date.)
BY MR. BALDWIN:
Q. Please take some time to read through
it if you like.
(Document review.)
Q. Do you recognize this e-mail?
A. Yes.
Q. Did you receive this e-mail?
A. Yes.
Q. At the top it says to Najla Al Shirawi
and [e-mail]. Is that your e-mail
account?
A. That used to be my Natalia account.
Q. What is currently your e-mail account?
A. [e-mail],
without a dash.
Q. I see. It's dated March 24, 2004, and
it's from Annie Hudson to you, CC-ing Richard
Landesberger.
First, who is Annie Hudson?
A. Annie was sort of -- we saw her as a
coordinator for our account with -- with

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Fairfield Sentry. I know that she worked are
Richard, but I have never met her.
Q. And what kind of communications did
you have with Annie Hudson?
A. I believe we had an ongoing
communication on our investment, our subsequent
investments. She sends us sort of fact sheets.
I think she used to send the fact sheets. There
are communication about our investment and the
fund.
Q. Did you ever have any discussions with
Annie Hudson with Sentry's strategy?
A. No, not to the best of my
recollection.
Q. Did you have any subsequent
discussions with Annie Hudson?
A. No.
Q. E-mail communication?
A. Just these back-and-forth e-mails
about -- about the fund and our investments.
Q. If you turn to -- these little numbers
in the bottom right-hand corner are called Bates
numbers, begin with SICO. If you read -- you
don't have to read through the whole thing, but

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if you look at SICO 15775 through 15776?
A. Uh-huh.
Q. Do you recognize this document?
A. Yes.
Q. What is it?
A. It's the PPM.
Q. For Sentry?
A. Yes. For Sentry, yes.
Q. Do you know if this is the first time
that you received the Sentry PPM?
A. I'm not sure, no.
Q. After receiving this PPM from Annie
Hudson on March 24, 2004, do you recall reading
it?
A. Yes, I've gone through it.
Q. At that time?
A. I believe so, yes.
Q. This would have been before SICO made
the investment in 2004?
A. Yes.
Q. Do you recall if you read the whole
document?
A. Not word by word, but I've gone
through it, yes, the entire document.

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Q. On the cover page at SICO 15727?
A. Uh-huh.
Q. There's two paragraphs in all caps.
The second paragraph there says, "The shares
offered hereby are speculative and involve a
high degree of risk. They have not been
registered under the securities laws of any
jurisdiction," et cetera.
Do you recall reading this language?
A. Maybe. I'm not sure.
Q. Did you understand that there were
risks in investing in Sentry?
A. Yes, I understand that there are -there are risks in anything you invest in.
Q. Did you understand there was a high
degree of risk?
A. That was not our sort of -- or, that
was not my understanding at that time.
Q. In what sense did you not understand
that there was a high degree of risk investing
in Sentry?
A. Because this is not how this was sold
to us. It was not sold to us as high risk.
Q. Well, what did you understand to be

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the risks associated with Sentry?
A. Like any other fund. There are, you
know, there are risk factors that would have an
impact on any other funds. These are standard,
but we believe that Fairfield are taking
measures to mitigate these risks and this is how
we perceived their role.
Q. Is the statement here on the first
page of the PPM that Sentry involves a high
degree of risk inconsistent with what you were
otherwise told about the Sentry Fund from
Fairfield?
A. This is a standard disclaimer. This
would be sort of part of any document. So we
don't sort of pay our -- or, base our investment
decision on standard -- the standard disclaimers
in the document these are.
Q. Did you understand that all hedge
funds involve a high degree of risk?
A. Yes, and that's what differentiates
the managers, how they manage and control their
risks.
Q. But hedge funds are inherently very
risky?

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A. I understand that.
Q. Can you go to SICO 15749 under the
section entitled "Escrow Bank & Custodian." Do
you recall reading this portion of the PPM?
A. I'm not sure. I can't remember if I
read it or not.
Q. Were you aware in 2004 when you
received this PPM or thereafter that Madoff
served as the sub-custodian for Sentry?
A. Sort of I know that there was a
sub-custodian and a broker for the fund, but the
name Madoff, you know, did not make such a
difference for me at that time.
Q. Were you aware of whether Madoff was
implementing the investment strategy for Sentry?
A. At that time I knew that they had sort
of an underlying manager and, you know, the
manager selection is -- is made by Fairfield,
but I was -- I was not really -- I don't know at
that time whether I was sure that Madoff is, you
know, the manager executing the strategy, the
sole manager executing the strategy.
Q. Did you know the identity of the
underlying managers at this point in 2004?

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MR. GLASSER: Objection to form.
A. I can't remember really.
Q. The second paragraph under "Escrow
Banking Custodians," there's a sentence here
that says, "Currently BLM," which is defined
above to be Bernard L. Madoff Investment
Securities, "has approximately 95 percent of the
fund's assets under custody."
Were you aware that Madoff held
custody of approximately 95 percent of the
fund's assets?
A. As a sub-custodian, yes.
Q. Did you ever inquire anymore de -- did
you ever try to gather any more information
about the sub-custodian for the Sentry Fund?
A. At that time, no.
Q. Do you know if anybody else at SICO
read the private placement memorandum at around
the time you received this from Annie Hudson in
September 2004?
A. I'm not sure.
Q. Subsequently, do you know if anybody
read this later than 2004?
A. No, I'm not sure.

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Q. Did you discuss the contents of the
Sentry PPM with anybody else at SICO?
A. I'm -- I'm not sure, but you know, at
the time of making the subsequent investment,
the PPM was part of the package that was sent -to the other sort of decision-makers.
My problem, I can't remember at that
time we had an Investment Committee or it was
just circulated to Tony and maybe our risk
manager. I'm not sure.
Q. Who was the risk manager?
A. Raj, Raj Gobalan.
Q. Can you spell that name?
A. R-A-G -- J. R-A-J. G-O-B-A-L-A-N.
I'm not sure of the spelling, though.
This is his short name. He has a long
name as well.
Q. Would the PPM for the hedge fund
investment usually be circulated to the
Investment Committee in full?
A. Only upon request. I'm -- I think
it's only if requested, but, you know, parts of
the PPM will be sort of inserted in the initial
or the memorandum for initiating an investment.

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A. No.
Q. Did you contact anyone at
PricewaterhouseCoopers to discuss this document
during -A. No.
Q. -- that period of time that you're
referring to?
A. No.
Q. Do you know if anyone outside SICO
would have contacted PricewaterhouseCoopers to
discuss this document?
A. No.
Q. How did you receive a copy of the 2007
and 2006 financial statements, you personally?
A. I can't recall. I don't know if I
received a copy or it was just received by -- by
the Investment & Treasury Department and then,
you know, it was filed and then, you know, at
the time of -- of making the 2008 investment, I
asked them to bring it to my office just to
check it.
Q. So you think you probably reviewed a
hard copy of this statement?
A. Yes.

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Q. Do you think that you filed your hard
copy of this statement or do you think you would
have done something else with it?
A. No, you know, they give me a copy and
then I'll go through it. It will, you know, be
sitting there until I'm done with it. Then I'll
send it to shredding if it's only a copy.
Q. Besides these two audited financial
statements, the copy for 2002 and the copy for
2006 and 2007, do you recall reviewing any of
the other audited financial statements for
Fairfield Sentry?
A. No. I can't remember.
Q. So, comparing these two documents,
looking at Exhibit 9, there is a cover page from
Citco, correct?
A. Uh-huh. Yes.
Q. Is that because you received this
document, the 2002 audited financial statements,
is that because you received it from Citco?
A. Yes.
Q. Do you have -- did you normally
receive audited financial statements for the
funds you invested in from the administrators?

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A. Usually, yes, we do.
Q. Do you have any idea why the copy of
the December 31, 2007 and 2006 financial
statement, Exhibit 15, why that does not have a
cover sheet?
A. I don't know. It might have been
sent, you know, without a cover page, just an
e-mail with this being the attachment, just find
attached this, without really a formal e-mail
with -- on the letterhead of Citco.
Q. And did you ever receive audited
financial statements directly from
PricewaterhouseCoopers in connection with your
investment in Fairfield Sentry?
A. I don't believe so. To the best of my
recollection, I don't believe we received them
directly.
Q. Do you receive audited financial
statements for other funds that SICO's invested
in?
A. Yes, we do.
Q. Do you receive those annually?
A. We receive those annually, yes.
Q. Is it your expectation that you will

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receive an audited financial statement for a
fund that you're invested in?
A. Yes.
Q. It's just the regular course of
business?
A. No, this is our expectation.
Q. So for Exhibit 9, if you'll turn to
the last page of the exhibit, page Bates-stamped
SICO 291, this is the Auditor's Report that we
have referred to a few times?
A. Uh-huh.
Q. Is this report addressed to SICO?
A. No.
Q. Is it addressed to you?
A. No.
Q. Do you -- let's switch now to Exhibit
15. I believe if you'll turn to page SICO Bates
stamp SICO 170.
A. Uh-huh.
Q. And we're looking at the Audit Report
from PricewaterhouseCoopers for the 2006-2007
statement that you received.
A. Uh-huh.
Q. Is this report addressed to SICO?

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A. Yes, we are a shareholder.
Q. For the record, this says "To the
Directors and Shareholders of Fairfield Sentry,"
correct?
A. Yes.
Q. It does not say to Securities &
Investment Company?
A. No.
Q. It doesn't have your name on it?
A. Doesn't have our name on it.
Q. Now we can put these away, I think.
A. Okay.
Q. I would like to ask you some specific
questions about PricewaterhouseCoopers
(Netherlands).
A. Sure.
Q. Prior to this litigation, have you
ever heard of PricewaterhouseCoopers
(Netherlands)?
A. No.
Q. Is the only time that -- or was it
this litigation that you first became aware that
there was a Netherlands office of
PricewaterhouseCoopers?

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A. When you say you've never heard -- I
withdraw my first answer. I think I answered
quickly.
I've never heard of them. You know,
I've never heard of them, but I've seen their
name on the audited financial statements. But
it's not that the litigation made we aware that
we had, you know, Pricewaterhouse "Netherlands"
being an auditor for a period of time. I knew
that they -- that PricewaterhouseCoopers
(Netherlands), but from our perspective, we did
not pay attention to this or this was not, you
know, taken into consideration because for us
it's the firm that matters, it's
Pricewaterhouse.
Q. And as you said earlier, you're not
sure which PricewaterhouseCoopers audited
Fairfield Sentry for which years; is that right?
A. Yes.
Q. You were not involved in the
decision-making to initially invest in Fairfield
Sentry in 2002 on behalf of SICO; is that right?
A. No. No.
Q. So it's fair to say you had no contact

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with PricewaterhouseCoopers (Netherlands) in
connection with that 2002 investment on behalf
of SICO?
A. Yes.
Q. That's it, you had no contact?
A. No, I had no contact.
Q. Prior to SICO's decision to invest the
additional funds in Fairfield Sentry in 2004,
did you have any contact with
PricewaterhouseCoopers in connection with that
decision?
A. No.
Q. Would that be the same for
PricewaterhouseCoopers (Netherlands)?
A. Yes, we never had any contact.
Q. So you did not speak to anyone at
PricewaterhouseCoopers (Netherlands) in
connection with the 2004 investment?
A. I've never had any contact with them.
Q. No meetings?
A. No meetings.
Q. You've never sent them any written
communication?
A. I don't believe so, no.

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Q. And you've never received any written
communications directly from PwC (Netherlands)
to you or to SICO?
A. I don't believe so.
Q. The same questions for the investment
in 2005. Prior to the decision to make that
investment, did you have any contact with
PricewaterhouseCoopers (Netherlands) in
connection with the 2005 investment in Fairfield
Sentry?
A. I don't think so.
Q. Again, you didn't speak to anyone at
PricewaterhouseCoopers (Netherlands) in
connection with the 2005 investment?
A. No.
Q. You don't believe you had any meetings
with anyone from PricewaterhouseCoopers
(Netherlands)?
A. No.
Q. You don't think you sent any written
communication in connection with the 2005
investment to PricewaterhouseCoopers
(Netherlands)?
A. I don't think so.

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Q. And you don't believe that you
received anything directly from
PricewaterhouseCoopers (Netherlands) to you in
connection with that 2005 investment?
A. I don't think -Q. Would that be correct?
A. Yes, correct.
Q. So the last investment in 2008, in
connection with making that investment on behalf
of SICO, did you have any contact with
PricewaterhouseCoopers (Netherlands)?
A. No.
Q. You didn't contact -- you didn't speak
to anyone at PwC (Netherlands) about the 2008
investment?
A. No.
Q. You didn't speak to anyone at
PricewaterhouseCoopers (Netherlands) about the
2007 audited financial statement?
A. No.
Q. You had no meetings with PwC
(Netherlands) in connection with the 2008
investment?
A. No.

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Q. My last set of questions are switching
gears again. What did you understand the role
of SICO to be in relation to the Fairfield
Sentry Fund? You were an investor, but did you
consider yourself a partner?
A. We considered ourself as an investor
and a shareholder in the Sentry Fund.
Q. Do you know approximately how many
other investors there were in Fairfield Sentry?
A. No.
Q. Did you know anyone else or any other
entity that was invested in Fairfield Sentry?
A. No.
Q. Did you ever attend meetings on behalf
of SICO that -- in its capacity as an investor
in Fairfield Sentry?
A. No.
MS. PIERCE: I hope that I'm done, but
I may come back for a few more questions.
THE WITNESS: Please take your time.
MS. PIERCE: I think that's it for
now, so I'll pass the buck. Thank you.
EXAMINATION BY
MR. TRESSLER:

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Q. Good afternoon.
A. Good afternoon.
Q. Ms. Al Shirawi?
A. Al Shirawi.
Q. My name is David Tressler. I am with
the law firm Kirkland & Ellis in Chicago,
Illinois. I represent PricewaterhouseCoopers
(Canada), one of the PricewaterhouseCoopers
defendants in this case.
Counsel asked you whether you were
aware that two different PricewaterhouseCoopers
firms audited Fairfield Sentry funds, and I'm
not going to ask you the same questions, but
just to clarify, you're not aware of which years
or you don't recall which years which of the PwC
firms audited Fairfield Sentry?
A. Yes.
Q. You understood that these PwC firms
were not the auditor of Madoff or the Bernard
Madoff investment?
A. At that time, we didn't know who are
the auditors of Madoff. So it could be PwC, it
could be any other firm. We didn't know.
Q. And you didn't conduct any

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investigation into who the auditor of Madoff
was?
A. No.
Q. You testified earlier that when you
were considering the 2008 investment, you only
received and considered information in tear
sheets, strategy reviews, the semiannual update
and the NAV statements?
MR. GLASSER: Objection to form.
A. As well -Q. Is that -A. No, that's not correct. As well also
I said that a few times as well as the audited
financial statements of -- of the 2006-2007 for
the fund. So these were all the documents that
we have used to -- I have used to decide on the
investment of 2008.
Q. Okay. And when you made the
investment in 2008, you also considered the
year-to-date performance in 2008, correct?
A. Yes.
Q. And in fact -A. Among other things, though.
Q. Understood. Understood.

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If you pull from your pile Exhibit 20,
please.
A. Yes.
Q. This was a memorandum from December of
2008, but attached to it was the approval
memorandum -A. Memorandum.
Q. -- seeking new limits for SICO's
investment in Fairfield Sentry, correct?
A. Yes.
Q. And that, that memorandum starts at
SICO 50?
A. Uh-huh.
Q. And on SICO -- on page SICO 51, the
second page of the memo, it discusses the fund
performance?
A. Yes.
Q. This memorandum was the memorandum to
the SICO Investment & Credit Committee?
A. Yes.
Q. Seeking approval for SICO's additional
investment in 2008 in Fairfield Sentry, right?
A. Yes.
Q. And on SICO 51, it discusses and shows

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a chart of the year-to-date performance in 2008?
A. Yes.
Q. And the chart at the bottom, could you
explain what's being shown?
A. In the table?
Q. In the table.
A. It's just comparative analysis of the
performance of the fund, Fairfield Sentry and
S&P 100.
Q. And what period is being shown? What
period of time is being shown in that table?
A. It was the year-to-date with the
record date being July, end of July 2008.
Q. And that information is coming from
the documents in SICO 52 through SICO 55?
A. I believe so.
Q. Is that right?
A. I'm not sure, because I've not
prepared this document, so I'm not sure where
from they got this.
Q. Okay. Well, where would SICO have
been able to get this kind of information
year-to-date for 2008?
A. We would have two sources for the

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year-to-date numbers. It will be the monthly
NAV statements from Citco and the fact sheets
from Fairfield.
Q. So, in considering the year-to-date
performance in 2008, before making that
additional 2008 investment in Fairfield Sentry,
you weren't relying on any information from
PricewaterhouseCoopers as to 2008 performance
figures, correct?
A. Not correct, because this is part of
what we have considered. I'll talk about myself
when I gave my approval on this, I have reviewed
the audited statements and I relied on the
information provided by PricewaterhouseCoopers,
and the financial statements of 2007 to be
specific. So the information that was given and
the fact that the Auditor's Report gave
non-qualified opinion made me basically take the
decision to approve that.
Q. So I understand that you have
testified that you considered the 2007 financial
statements and the audit opinion -A. The most recent.
Q. Which was the most recent?

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N. Al Shirawi
A. Yes.
Q. And the audit opinion attached to
those financial statements, but my question
was -A. Uh-huh.
Q. -- and I'll -- best just to read it
back to you. My question was something
different than that.
A. Okay. Sorry.
Q. So I asked, in considering the
year-to-date performance in 2008 before making
the additional 2008 investment in Fairfield
Sentry, you didn't rely on information from
PricewaterhouseCoopers as to 2008 year-to-date
performance figures, isn't that right?
A. That's correct.
Q. You didn't receive -A. We had no -Q. -- information directly from
PricewaterhouseCoopers?
A. No.
Q. And in fact, just to clarify, you
didn't receive any audited financial statements
from PricewaterhouseCoopers, did you?

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N. Al Shirawi
A. Directly from them? I -- I'm not sure
about others, but I haven't received anything
directly from Pricewaterhouse.
Q. And are you aware that
PricewaterhouseCoopers doesn't prepare the
financial statements?
A. Specifically, in this case, I'm not
sure, but I know as a standard sort of practice
that the financial statements usually are
prepared by the client and audited by the
auditing firms.
Q. So, in the course of your
consideration of additional investments with
SICO -- I'm sorry, for SICO with Fairfield
Sentry, did you have any conversations with PwC
(Canada) in connection or concerning SICO's
investments in Fairfield Sentry?
A. No, I have not.
Q. Did you send any written
correspondence to PricewaterhouseCoopers
(Canada) in connection with SICO's investments
in Fairfield Sentry?
A. No.
Q. Did you receive any written

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N. Al Shirawi
correspondence from PricewaterhouseCoopers in
connection with SICO's investments in Fairfield
Sentry?
A. No.
Q. And did you meet with anyone from
PricewaterhouseCoopers (Canada) in connection
with any of SICO's investments in Fairfield
Sentry?
A. No.
Q. When you received and considered and
looked at the 2007 and 2006 audited financial
statements, what if any discussions did you have
with anyone else at SICO about those financial
statements?
A. I'm not certain about what discussion
I had, but since, you know, I have requested
getting a copy of these audited statements, I'm
sure I have discussed it with someone from
Investment & Treasury because, you know, usually
whenever we ask for documents, we have to
explain why we are asking for these documents.
Q. And after reviewing those financial
statements, you didn't contact PwC (Canada) to
ask for any more information?

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N. Al Shirawi
A. No.
Q. And you didn't contact
PricewaterhouseCoopers (Canada) to ask any
questions about their audit opinion?
A. No.
Q. And just to be clear, you didn't
contact PwC (Canada) in any way with regard to
SICO's investments -A. Confirmed.
Q. -- in Fairfield Sentry?
A. I've never contacted them.
Q. Earlier in connection -- you testified
in connection with the 2004 investment -A. Uh-huh.
Q. -- in Fairfield Sentry. You were
asked which independent parties did you reach
out to to get updated information on Fairfield
Sentry Fund, but you testified that you had the
Citco statements and received audited financial
statements. I just want to clarify, did you
reach out to the fund's auditor to get those
statements?
A. No, we have not reached to the fund
auditors. We have not -- we have never, at

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N. Al Shirawi
least, you know, specifically, if we go to the
2004 and if I just, you know, talk on behalf of
myself, I have not reached out to the auditors.
We used to get them through other -- we would
get the financial statements either from
Fairfield or from Citco. I can't remember
specifically the 2004 investment when we had the
file where from we got those financials. I
can't remember.
Q. Finally, you testified this morning
that part of your due diligence includes looking
at the PPM?
A. Uh-huh.
Q. And you would look to who the external
auditor was. You also mentioned that you would
look to see whether there were risk advisors or
due diligence partners, and I just wanted to
clarify because of the way you said it that you
don't understand the outside auditors of the
fund to be risk advisors, do you?
A. No.
Q. And do you understand them to be due
diligence partners?
A. No.

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N. Al Shirawi
MR. TRESSLER: Thank you, Ms. Al
Shirawi. I think I'm done.
THE WITNESS: You're welcome.
THE VIDEOGRAPHER: The time is 5:28.
This is the end of the deposition, September
21, 2011.
oOo

____________________
NAJLA AL SHIRAWI
Subscribed and sworn to
before me this day
of
2011.
_______________________

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CERTIFICATE
STATE OF NEW YORK )
: ss
COUNTY OF NEW YORK)
I, Kathy S. Klepfer, a Registered
Merit Reporter and Notary Public within and
for the State of New York, do hereby
certify:
That NAJLA AL SHIRAWI, the witness
whose deposition is herein before set forth,
was duly sworn by me and that such
deposition is a true record of the testimony
given by such witness.
I further certify that I am not
related to any of the parties to this action
by blood or marriage and that I am in no way
interested in the outcome of this matter.
In witness whereof, I have hereunto
set my hand this 27th day of September,
2011.
------------------------------KATHY S. KLEPFER, RPR, RMR, CRR, CLR

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INDEX
TESTIMONY OF N. AL SHIRAWI:
Examination by Mr. Baldwin
Examination by Ms. Izquierdo
Examination by Ms. Pierce
Examination by Mr. Tressler

2
PAGE 3
7
4
211
5
231
6
252
7
8
SHIRAWI EXHIBITS:
PAGE
9
Exhibit 1, a document bearing Bates Nos.
78
10
SICO 0015724 through 0015813
11
Exhibit 2, a document bearing Bates Nos.
90
12
SICO 0000324 through 326
13
Exhibit 3, a document bearing Bates Nos.
90
14
SICO 0000327 through 328
15
Exhibit 4, a document bearing Bates Nos.
90
16
SICO 0000329 through 333
17
Exhibit 5, a document bearing Bates Nos.
96
18
SICO 0016987 through 0016992
19
Exhibit 6, a document bearing Bates Nos.
101
20
SICO 0000566 through 572
21
Exhibit 7, a document bearing Bates Nos.
106
22
SICO 347 through 348
23
Exhibit 8, a document bearing Bates Nos.
117
24
SICO 15709 through 15712
25

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INDEX (Cont'd.)
SHIRAWI EXHIBITS:
PAGE
Exhibit 10, a document bearing Bates Nos.
133
SICO 628 through 640
Exhibit 11, a document bearing Bates Nos.
145
SICO 2265 through 2267
Exhibit 12, a document bearing Bates Nos.
148
SICO 7838 through 7844
Exhibit 13, a document bearing Bates Nos.
151
SICO 6260 through 6262
Exhibit 14, a document bearing Bates Nos.
154
SICO 5216 through 5220
Exhibit 15, a document bearing Bates Nos.
155
SICO 162 through 190
Exhibit 16, a document bearing Bates Nos.
164
SICO 17367 through 17376
Exhibit 17, a document bearing Bates Nos.
170
SICO 6616 through 6625
Exhibit 18, a document bearing Bates Nos.
175
SICO 6534 through 6538
Exhibit 19, a document bearing Bates Nos.
179
SICO 16303 through 16305
Exhibit 20, a document bearing Bates Nos.
181
SICO 46 through 55

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