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 N

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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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Plaintiff,
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vs.

Civil Action No.

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09-CV-0118 (VM)
FAIRFIELD GREENWICH LIMITED, et al,

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

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VIDEOTAPED
DEPOSITION OF ALI MARSHAD

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New York, New York

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Friday, September 23, 2011

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Reported by:
FRANCIS X. FREDERICK, CSR, RPR, RMR

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JOB NO. 42090
TSG Reporting - Worldwide

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A. MARSHAD
proprietary desk. So whoever came under him
might have done the due diligence or him
himself might have done the analysis.
Q. Did SICO make a subsequent
investment after July 1, 2002 in Fairfield
Sentry Limited?
A. Yes, they did.
Q. And what was the date of that
investment?
A. Again, I don't recollect date by
date when the investment were made but looking
at this, I mean, we've got the dates right in
front of us.
MR. MIRRER-SINGER: And let the
record reflect that the witness is
pointing to Marshad Exhibit 2.
Q. And so based on Marshad Exhibit 2,
it's your understanding that SICO made its
second investment in Fairfield Sentry Limited
on April 1, 2004?
A. Yeah.
Q. Okay. And what was the amount of
the investment?
A. Half a million dollars.

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A. MARSHAD
Q. Okay. What was the percentage of
SICO's total assets that was invested in
Fairfield Sentry Limited as of April 1, 2004?
A. I have no idea.
Q. Between July 1, 2002 and April 1,
2004 did SICO change its due diligence
procedures with respect to investments in
hedge funds?
A. No.
Q. I want to come back to the July 1,
2002 investment. Did SICO follow the due
diligence procedure with respect to
investments in hedge funds as applied to the
investment in Fairfield Sentry Limited?
A. Can you -MR. SIRES: Objection.
Q. Do you understand the question?
MR. SIRES: Just one second.
(Pause on the record.)
MR. SIRES: Withdraw the
objection.
A. Can you repeat the question?
MR. MIRRER-SINGER: Sure. Can we
have the court reporter read it back.

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A. MARSHAD
(Record read.)
A. Yeah.
Q. Okay. Do you know who was on the
due diligence team prior to the April 1, 2004
investment in Fairfield Sentry Limited?
MR. SIRES: Objection.
A. We go back to the same question
which we just answered previously. I mean, I
told you -- I told you that I don't recollect
who was sitting on the team.
Q. Okay. Was Fouad Rashid still
sitting on the due diligence team as of April
1, 2004?
A. He sits on the proprietary desk.
Q. And sitting on the proprietary
desk he is involved in the due diligence
process.
A. He's part of the proprietary desk
so anyone in the proprietary desk can do the
analysis. So it's not just him.
Q. I'm not asking whether -- whether
anyone can do the due diligence. I'm asking
who actually did the due diligence at that
time.

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A. MARSHAD
A. Again, I don't know who did it.
Q. Did SICO follow the due diligence
procedures in connection with its investment
in Fairfield Sentry Limited in April 1, 2004?
A. I just answered that question.
Yes, they did.
Q. Coming back to the July 1, 2002
investment, what due diligence did SICO do
with respect to its investment in Fairfield
Sentry Limited?
A. I've already answered that.
MR. SIRES: Please hold on one
second. You really need -- counsel
needs some leeway. And so it's not the
witness's job to tell him that you've
answered already. You should answer the
questions to the best of your ability if
you know an answer unless I advise you
not to answer the question, okay.
THE WITNESS: (Witness nods.)
MR. SIRES: Now, hold on one
second. Let me read the question.
(Pause on the record.)
MR. SIRES: Okay. Go ahead. You

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A. MARSHAD
may answer the question.
Would you read it back to him,
please.
MR. MIRRER-SINGER: Sure. Can we
have the court reporter read back the
last question.
(Record read.)
A. They basically met up -- I mean,
how the investment was done initially in
Fairfield, Anthony Mallis met up with Andres
and subsequently -- I mean, the way Anthony
came across basically the Fairfield name is
reading through a magazine and looking at the
performance numbers. And post that Anthony
came back to Bahrain and the guys on the sales
team of Fairfield came down to Bahrain and met
Najla Shirawi and we were provided with the
marketing material. We were provided with the
PPM. And based on that the analysis was done
and the memo was drafted.
Q. Okay. And prior to the April 1,
2004 investment in Fairfield Sentry Limited,
what due diligence did SICO conduct with
respect to Fairfield Sentry Limited?

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A. MARSHAD
A. We basically went through the fact
sheets, the performance updates, the PPM, the
Web site, as well as the annual report from
the auditors.
Q. Did SICO make a subsequent
investment in Fairfield Sentry Limited after
April 1, 2004?
A. Yeah.
Q. And what was the date of that
investment?
A. September 1, 2005.
Q. And how much was invested in
September 1, 2005?
A. 1.5 million.
Q. As of September 1, 2005, what
percentage of SICO's total assets were
invested in Fairfield Sentry Limited?
A. I don't know.
Q. Between April 1, 2004 and
September 1, 2005, did SICO change its due
diligence process with respect to investments
in hedge funds?
A. No.
Q. With respect to the investment in

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A. MARSHAD
Fairfield Sentry on September 1, 2005, did
SICO follow the due diligence processes that
it had in place with respect to investments in
hedge funds?
A. Can you repeat the question?
MR. MIRRER-SINGER: Sure. Can the
court reporter read it back.
(Record read.)
A. Yes, indeed, they did.
Q. Who was involved in the due
diligence of the investment in Fairfield
Sentry on September 1, 2005?
A. The -- I mean, the team in 2005
would have consisted of Abdul Rahman Saif,
Najla Shirawi. Who exactly did the due
diligence analysis, I mean, I don't exactly
know who exactly did the due diligence
analysis. But that is the team. So someone
sitting on the team would have conducted the
due diligence analysis.
Q. What due diligence was performed
in connection with the investment on September
1, 2005 in Fairfield Sentry?
A. The same due diligence that would

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A. MARSHAD
have been performed in any investment
basically which we discussed previously which
is, again, looking at the fact sheets, the
semi-annual updates received from the guys, as
well as the subsequent annual reports,
performance updates received from -- from
Fairfield. And reviewing the PPM. And
whatever marketing material was supplied.
Q. With respect to the investments
in Fairfield Sentry Limited on July 1, 2002
how do you know what due diligence was
performed on Fairfield Sentry Limited?
A. This is the standard way of -- I
mean, this is the standard way of doing due
diligence and analysis on funds in general.
Q. I understand that that's the
general way of doing it. But how do you know
that those general practices were applied to
the investment in Fairfield Sentry Limited?
MR. SIRES: In July 2002?
MR. MIRRER-SINGER: July 1, 2002.
That's correct, Counsel.
A. I mean, those people doing it I
mean, they no longer exist in the company. I

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A. MARSHAD
Q. Let's talk about oral
communications. Are you aware of any
communications during the time period I just
identified, October 2008 going forward, of any
oral communications between SICO and quote as
you put it "Citco"?
A. I don't remember.
Q. So you don't -- you can't recall
sitting here any oral communications between
SICO and "Citco" as you've described the
different Citco entities from October 2008
going forward. Is that an accurate statement?
A. Yes.
Q. I'm sorry?
A. Yes.
Q. It got caught up in the sneeze. I
couldn't hear you.
A. Yes.
(Pause on the record.)
MS. McGOVERN: Thank you so much,
Mr. Marshad. I have no further
questions.

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A. MARSHAD
EXAMINATION BY
MS. PIERCE:
Q. Mr. Marshad, my name is Betsy
Pierce. I'm an associate with the firm of
Hughes Hubbard & Reed and we represent
PriceWaterhouseCoopers Netherlands in this
litigation. I may have refer to
PriceWaterhouseCoopers or PwC but will you
understand that I'm speaking about the same
thing?
A. Yeah.
Q. Does SICO know who audited
Fairfield Sentry when SICO decided to invest
in the fund in 2002?
MR. SIRES: Hold on a second. Let
me read that.
Go ahead.
A. Obviously we knew because when we
look at investments we would review the
documents discussed and in the documents
discussed PwC was mentioned as an auditor.
Subsequent investments we received financial
statements basically from PwC, not directly
sent to us by PwC, but two of the financial

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A. MARSHAD
statements, if I recollect, were addressed to
shareholders and we were shareholders in
Fairfield Sentry.
Q. Okay. So just focusing on the
time period when SICO decided to make its 2002
investment, who did SICO believe audited the
Fairfield Sentry Fund at that point in time?
A. PwC.
Q. Does SICO know who audited the
Fairfield Sentry Fund prior to 2002?
A. I don't know.
Q. Now, you just said a moment ago in
your answer to that -- your long answer to
that question, you said that you received
financial statements, they weren't directly
sent to us by PwC. What do you mean
statement?
A. They were -- the documents were
sent by -- basically not directly by -- from
PwC representative, but it came through Citco
if I can recollect correctly. And the annual
reports were addressed to the shareholders of
the fund.
Q. So in that part of your answer,

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A. MARSHAD
that latter part of answer where you say that
the annual statements were addressed to the
shareholders of the fund, do you mean to say
that the statements did not have SICO's name
on them specifically?
A. Yes, indeed. But the statements
were addressed to shareholders of the
Fairfield Sentry Fund and SICO is a
shareholder in the Fairfield Sentry Fund.
Q. Is SICO aware that the auditor of
Fairfield Sentry changed during the course of
SICO's investment in the fund?
A. To SICO, PwC is PwC, whether it's
PwC Canada or PwC Netherlands or any other PwC
in the region. We view PwC as a single
entity. Whatever sits under basically the
trust, whether it's PwC or any of the
competing auditing firms, we see them as PwC
or as the parent company and not the
individual underlying subsidiaries or whatever
regions they're covering.
Q. I appreciate that answer. But the
question that I asked you didn't -- you didn't
respond to the question I asked you. What I

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A. MARSHAD
wanted to ask you -- I'll just repeat it
again. Is SICO aware that the auditor of
Fairfield Sentry changed during the course of
SICO's investment in the funds; yes or no?
MR. SIRES: Objection. I think he
answered. Try and go again.
A. The answer is we knew PwC has
audited the fund during our investment period.
And whether it was PwC Netherlands or PwC
Canada or whatever the region is, we see PwC
as one entity.
Q. Sitting here right now can you
tell me which years PwC Netherlands audited
Fairfield Sentry?
A. I don't recollect but I think the
change happened in 2005.
Q. Which changes are you referring
to?
A. From whatever the PwC entity was
previously to the other PwC. But, again, as a
company we see it as one PwC entity.
Q. But you don't know which PwC
entity audited Fairfield Sentry for which
years; is that a fair statement?

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A. MARSHAD
A. Me, personally, yes. But as a
company we've reviewed and went through the
documents and PwC was mentioned on the
documents.
Q. I appreciate that. I hear what
you're saying. I just want to know whether
sitting here as a representative of SICO do
you know which PwC firm audited Fairfield
Sentry for which specific years of SICO's
investment?
A. I don't know the dates. I don't
know the exact dates but I knew a change has
happened.
Q. Prior to SICO's decision to invest
in Fairfield Sentry in July 2002 did SICO have
any communications with PriceWaterhouseCoopers
Netherlands concerning that investment?
A. No.
Q. Some of these questions are very
repetitive but just pay attention. They're
necessary. Prior to SICO's decision to invest
in Fairfield in April of 2004, did SICO have
any communications with PriceWaterhouseCoopers
Netherlands concerning the 2004 investment in

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Fairfield Sentry?
A. No direct communications. But the
annual reports were reviewed and relied upon
in making the investments. And PwC being an
auditor have been relied upon to basically
trust the underlying entity auditing the fund.
Q. But no one from SICO tried to
contact PriceWaterhouseCoopers Netherlands to
discuss those audited financial statements; is
that correct?
A. No one did. That's correct.
Q. There were no meetings between PwC
and SICO -- PwC Netherlands and SICO
concerning the 2004 investment in Fairfield
Sentry that SICO made; is that correct?
A. That's correct.
Q. There were no written
communications directly exchanged between PwC
Netherlands and people from SICO concerning
the 2004 investment in Fairfield Sentry,
correct?
A. That's correct.
MR. SIRES: Objection.
A. Yeah. But to clarify again for

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A. MARSHAD
the record there was indirect communication
via the annual reports sent through Citco if I
can recollect addressed to the shareholders.
So to me that's communication. It's not
direct communication between SICO and PwC but
it is indirect communication between PwC and
SICO via the administrator. And so to me that
it a form of communication.
When I say no I mean there was no
direct oral communication with an employee of
PwC.
Q. Are you finished?
A. Yeah.
Q. Prior to SICO's decision to invest
in Fairfield Sentry in September of 2005 did
anyone from SICO contact anyone from
PriceWaterhouseCoopers Netherlands to discuss
that investment decision?
A. No.
Q. No one from SICO sent written
communications directly to
PriceWaterhouseCoopers Netherlands concerning
the 2005 investment.
A. No.

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A. MARSHAD
Q. There were no meetings that
occurred between anyone from SICO or
PriceWaterhouseCoopers Netherlands concerning
the 2005 investment in Fairfield Sentry; is
that correct?
A. Yeah.
Q. Prior to SICO's decision to invest
in Fairfield Sentry in October 2008, did
anyone from SICO directly contact
PriceWaterhouseCoopers Netherlands to discuss
the investment made in 2008 in Fairfield
Sentry?
A. No.
Q. There were no meetings between
SICO and people from PriceWaterhouseCoopers
Netherlands with respect to that 2008
investment in Fairfield Sentry; is that
correct?
A. Yep.
Q. SICO did not send any written
communications directly to
PriceWaterhouseCoopers Netherlands concerning
the 2008 investment in Fairfield Sentry?
A. No.

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A. MARSHAD
Q. SICO did not receive any
communications directly from
PriceWaterhouseCoopers Netherlands concerning
the 2008 investment; is that correct?
MR. SIRES: Objection.
A. Incorrect. Because, again, we go
back to the same point. We received the
annual reports which were addressed to
shareholders. And to me that is a form of
communication. The e-mail did not come
through from PwC but the audited annual
reports were done by PwC and addressed to the
shareholders giving a fair opinion on
Fairfield Sentry.
Q. Other than the audited financial
statement and the audit opinion that SICO
received from PriceWaterhouseCoopers
Netherlands concerning Fairfield, were there
any other forms of communication from
PriceWaterhouseCoopers Netherlands directly to
SICO concerning the investment in Fairfield?
A. Not that I'm aware of.
Q. If you could take a look for me at
Exhibit 9 which is the really thick exhibit,

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which is Plaintiffs' Responses and Objections
to Defendants' Joint First Set of
Interrogatories to Plaintiffs'?
A. Yep.
Q. Okay. So let's find SICO's answer
to number 19. This is the question that asked
you to identify any telephone conversations,
in-person meetings, or other oral
communications you had with -- SICO had with
the PriceWaterhouseCoopers Canada or
PriceWaterhouseCoopers Netherlands concerning
Madoff or BLMIS or Fairfield or SICO's
investment in the litigated Fairfield funds,
the non-litigated Fairfield funds, or the
non-Fairfield funds.
Is your answer to that question
that's written here in Exhibit 9, has that
answer changed at all from the day that you
gave it in this exhibit?
A. No. Again, direct in-person
meetings or direct oral communications do not
exist. But, for the record, there has been
communication but it wasn't an oral
communication which was direct. It was done

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A. MARSHAD
via an intermediary which is the
administrator -- which is Citco basically.
Q. And so you've already said several
times today, other than the Citco intermediary
providing you the audited financial statement
and the audit opinion, you had no other
written communications with
PriceWaterhouseCoopers, Netherlands?
A. Apart from the the annual reports,
no.
Q. And that would be the same
regardless of what PriceWaterhouseCoopers
office we're speaking about, correct?
A. Yep.
Q. Does SICO have an existing
business relationship with
PriceWaterhouseCoopers?
A. I mean, I mentioned that
previously. They are the auditors of our
funds in the asset management division.
Q. And do they also audit one of the
SICO subsidiaries?
A. I'm not sure.
Q. But it's possible; you're just not

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sure?
A. Yeah. I can't give an answer so,
I mean, I don't know whether they do or they
don't. But I know that our asset management
funds are audited by PwC.
Q. I just want to go back to some
earlier questions to make sure I've got the
record clear. In connection with SICO's
decision to invest in Fairfield Sentry in July
2002, there were no meetings that took place,
to your knowledge, between SICO and
PriceWaterhouseCoopers Netherlands; is that
correct?
A. Yeah.
Q. And there was no written
correspondence exchanged between
PriceWaterhouseCoopers Netherlands and SICO
concerning SICO's 2002 investment in Fairfield
Sentry; is that correct?
A. Yeah. But PwC were mentioned as
auditors of the fund.
MS. PIERCE: I think that those
are all the questions that I have but
I'm going to reserve some time just in

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case after my colleagues ask you some
questions. Thanks.
EXAMINATION BY
MR. TRESSLER:
Q. Good evening, Mr. Marshad. I
think we're into the evening now. I'm going
to ask you a few questions. My name is David
Tressler. I'm with the law firm of Kirkland &
Ellis in Chicago, Illinois. I represent
PriceWaterhouseCoopers Canada, one of the PwC
entities that are parties in this case.
I'm going to ask you questions
that are specific to PriceWaterhouseCoopers
Canada and they're going to sound similar in
some ways to the questions counsel just asked
you but I'm going to be referring to PwC
Canada. Is that okay?
A. Yeah.
Q. Do you understand?
A. Yeah.
Q. Prior to or in connection with
SICO's investment in 2002, its initial
investment in 2002 in Fairfield Sentry, no
representative of SICO had any contact

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directly with anyone at
PriceWaterhouseCoopers, Canada; is that
correct?
A. That's correct. As far as I'm
aware. Prior to 2008. But, again, the same
point is the fund was audited by PwC.
MR. SIRES: And object to that
last question, please.
Q. And in connection with the initial
investment -- SICO's initial investment in
2002, no one at SICO had any telephone
conversations with anyone at
PriceWaterhouseCoopers Canada; is that right?
A. No.
Q. Oh, I'm sorry. Let me just look
at the...
So I'm sorry, Mr. Marshad, could
you -- let me repeat the question because it
may be the way that I asked it and the way
that you answered. But in connection with
SICO's initial investment in 2002 did anyone
at SICO have any telephone conversation or
other oral communication with anyone at
PriceWaterhouseCoopers, Canada?

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A. To the best of my knowledge, no
one had any oral conversations.
Q. And is that the case for the
additional investment in 2004 as well?
A. Again, the same answer which was
given earlier and we received the annual
report.
Q. The question was telephone
conversations.
A. No.
Q. Or oral communications.
A. No, no.
Q. And was that the case for the
additional investment in 2005?
A. None that I'm aware of.
Q. And did anyone at SICO have any
telephone conversation or other communication
with anyone at PriceWaterhouseCoopers Canada
prior to or in connection with SICO's
additional investment in 2008 in Fairfield
Sentry?
A. No.
Q. In connection with any of those
investments that SICO made in Fairfield

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A. MARSHAD
Sentry, did anyone at SICO have any meetings
with anyone at PriceWaterhouseCoopers Canada?
A. No meetings.
Q. Did anyone at SICO in connection
with any of SICO's investments in Fairfield
Sentry from 2002 to 2008 ever contact
PriceWaterhouseCoopers Canada in connection
with any of Fairfield Sentry's financial
statements?
A. No. Nothing that I'm aware of.
Q. And did anyone at SICO ever send
any written correspondence to anyone at
PriceWaterhouseCoopers Canada in connection
with any of SICO's investments in Fairfield
Sentry?
A. None that I'm aware of.
Q. And aside from the audit opinion
letters contained in Fairfield Sentry's
financial statement, did SICO receive any
written correspondence from anyone at
PriceWaterhouseCoopers Canada or
PriceWaterhouseCoopers Canada as a firm?
A. No correspondences with the
exception of the audited financial statements

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A. MARSHAD
received by Citco which were addressed to the
shareholders basically by PwC. And those -- I
mean -- and those were looked at and reviewed.
Q. After you received Fairfield
Sentry's financial statement, did anyone at
SICO seek to contact anyone at
PriceWaterhouseCoopers to discuss the
financial statements?
A. No one did because we didn't see
the need. We didn't see the need for it
because it was a fair opinion done by a
reputable organization such as PwC so we
trusted what we received and we trusted the
opinion given by PwC.
MR. TRESSLER: Mr. Marshad, that's
all the questions I have.
THE WITNESS: Okay.
MR. MIRRER-SINGER: Let's go off
the record for just one minute.
THE VIDEOGRAPHER: The time is
5:05. We're going off the record.
(Discussion held off the record.)
THE VIDEOGRAPHER: The time is
5:06. Back on the record.

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EXAMINATION BY
MR. MIRRER-SINGER:
Q. Mr. Marshad, I want to refer to
Marshad Exhibit 9 which is the thick
interrogatory responses and to the addendum
that SICO Bahrain submitted and where we left
off with the Fairfield Greenwich defendant
questioning was we were going over the
individuals that were listed in response to
interrogatory number 4. And the last
individual that we discussed was Hanan Sater.
And now I'd like to discuss Shakeel Sarwar.
Is Shakeel Sarwar a man or a
woman?
A. A man.
Q. Is Mr. Sarwar currently employed
by SICO?
A. Yes, he is.
Q. And what is Mr. Sarwar's current
title?
A. Head of asset management.
Q. And how long has Mr. Sarwar held
that title?
A. No idea.

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Q. What was Mr. Sarwar's previous
title?
A. No idea.
Q. What is the function of an asset
management group?
A. Can you clarify?
Q. No. That's actually the question
for you. Within SICO what is the function
that the asset management group plays?
A. Okay. Within SICO. Because the
question was what is the function of head of
asset management.
Q. Thanks for that clarification.
A. So within -- the asset management
runs the funds of the -- SICO which are
basically various funds.
Q. And does the asset management
group -- withdrawn.
Did the asset management group
have a role with respect to SICO's investment
in Fairfield Sentry?
A. No.
Q. Did Mr. Sarwar have any
involvement in the decision for SICO to invest

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Q. And specifically my question goes
to paragraph 5 on SICO 1793 which reads "The
borrower of a file shall be required to
initial the movement log which shall be placed
in the relevant file slot in the filing
cabinet."
Mr. Marshad, my question for you
is are you aware of a movement log with
respect to the central investment file for
Fairfield Sentry?
A. As the point refers, the borrower
of a file. A borrower of a file takes the
whole file away and that doesn't happen. The
file stays within the investment and treasury.
What that point refers to is an actual folder
that contains information from A to Z. What
would be borrowed from the file is a paper
which is photocopied and passed on to whoever
needs that document.
Q. Okay. So this would only apply if
the entire file would be taken out.
A. Yeah.
Q. And is there a record -withdrawn.

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Is there a movement log with
respect to the entire Sentry file?
A. No one has ever moved the whole
folder or looked to move the whole folder. I
mean, if someone is looking for any piece of
information they will be specifically after
something. What they're after I would just
copy it and provide it. The file sits in this
space.
Q. Mr. Marshad, if you could direct
your attention still to Marshad Exhibit 5, the
following page, SICO 1794, and specifically I
want to take up the paragraph 16. It refers
to the following general guidelines for
culling documents.
(Document review.)
Q. First of all, Mr. Marshad, did the
guidelines with respect to culling documents
apply to both hard copy documents and
electronic documents or just with respect to
hard copy documents?
A. As I said, all electronic
documents are backed up so that information
would always exist. With regards to hard copy

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documents we save whatever we have on file.
Q. Okay. So there -- is it your
testimony documents in the hard copy Sentry
file were never culled?
A. I mean, referring to that specific
point, that question, I personally don't know.
I don't answer something I don't know.
MR. MIRRER-SINGER: Mr. Marshad, I
thank you very much for your time. The
deposition is closed.
THE WITNESS: Thanks.
(Continued on next page to include
jurat.)

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THE VIDEOGRAPHER: Any questions,
counselor?
MR. SIRES: No.
THE VIDEOGRAPHER: That's it.
We're done? Anyone else?
The time is 7:06. This is the end
of the deposition, September 23rd, 2011.
(Time Noted:
7:06 p.m.)

____________________
ALI MARSHAD
Subscribed and sworn to before me
this ___ day of __________, 2011.
_________________________________

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