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 B

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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK

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PASHA S. ANWAR, et al.,

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Plaintiffs,
vs.

Civil Action No.
09-CV-0118(VM)

FAIRFIELD GREENWICH LIMITED,
et al.

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Defendants.
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VIDEOTAPED DEPOSITION OF MARTIN BACH
VOLUME 2

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Phoenix, Arizona
June 30, 2011
10:01 a.m.

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Job Number: 39762

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Reported by:

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Janice Harrington, RPR, CRR, CLR

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AZ Certified Court

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Reporter No. 50844

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A. I know them.
Q. And we represent PricewaterhouseCoopers
Netherlands -A. Okay.
Q. -- in this litigation. I want to start
by asking you some questions about some of your
testimony yesterday. Do you recall testifying that
the reason why you decided -- or one of the reasons
why you decided to invest in Greenwich Sentry was
because they had a conservative approach and
consistent returns?
A. Yes.
Q. And did the consistent returns continue
after you made your initial investment in Greenwich
Sentry?
A. Yes.
Q. And did those consistent returns continue
during the course of your investments with Greenwich
Sentry?
A. Yes.
Q. Over that period of time, you were
pleased with those returns; is that fair to say?
A. Yes.
Q. And did you continue to invest in
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Greenwich Sentry because you were receiving those
consistent returns?
A. Yes.
MR. GLASSER: Objection to form.
BY MS. PIERCE:
Q. Did you maintain your investments in
Greenwich Sentry because you were receiving those
consistent returns?
MR. GLASSER: Objection to form.
THE WITNESS: Yes.
BY MS. PIERCE:
Q. Okay. Now I want to switch gears and
talk to you about your investments in the real estate
partnership in Santa Fe and your investment in
Greenwich Options, the fund that you invested in
prior to Greenwich Sentry.
So prior to your decision to invest in
the real estate partnership, did you review any
audited financial statements for the partnership?
MR. GLASSER: Objection to form.
THE WITNESS: I don't remember that.
That's way back all those investments. I did them
going back to 1990, '91, you know, so I don't
remember. I might have.

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BY MS. PIERCE:
Q. Do you recall if there was an auditor for
the real estate partnership in those early years?
MR. GLASSER: Objection to form.
THE WITNESS: Yes.
BY MS. PIERCE:
Q. Do you recall who that was?
A. It wasn't one of the big four, but it was
-- it was a CPA firm in New York.
Q. But you don't remember the name or do you
remember the name?
A. No, but I could find out, you know, if
it's important.
Q. Okay. Let's switch and talk about your
investment in the Greenwich option fund. Prior to
your decision to invest in that fund, do you know who
audited the Greenwich Option fund?
MR. GLASSER: Objection to form.
THE WITNESS: I think -- I'm not sure. I
think it was Ed Schechter. I'm not sure.
BY MS. PIERCE:
Q. Berkow, Schechter?
A. Yes.
Q. Did you ever receive audited financial
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statements related to the Greenwich Option fund?
MR. GLASSER: Objection to form.
THE WITNESS: I don't remember.
BY MS. PIERCE:
Q. If you had received them, do you think
you would have kept audited financial statements
related to the Greenwich option fund?
MR. GLASSER: Objection to form.
THE WITNESS: Not -- not for 30 years.
30 years ago I would have kept it.
BY MS. PIERCE:
Q. Is your answer the same for the real
estate partnership, if I ask the same question?
A. Yes. You know, I have a little house. I
can't keep all these papers, all these prospectuses.
Q. I live in New York. I understand the
space issues. Okay. Let's return to your investment
in Greenwich Sentry.
A. Uh-huh.
Q. What did you understand your role to be
with respect to the Greenwich Sentry fund?
MR. GLASSER: Objection to form.
THE WITNESS: I was a partner.
BY MS. PIERCE:

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Q. And officially would you say you were a
limited partner?
A. Yes, yeah. I had nothing to do with the
operation at all, you know.
Q. Do you know approximately how many other
limited partners were in Greenwich Sentry fund?
MR. GLASSER: Objection to form.
THE WITNESS: About 10.
BY MS. PIERCE:
Q. Beside your friend Mr. Centro, do you
know any of the other investors?
A. Say the question again. I'm sorry.
Q. Let me rephrase.
A. Did you say Greenwich?
Q. Greenwich Sentry.
A. Oh, okay. I get mixed up with Greenwich
Options at the time.
Q. Okay. For the record, let me just start
over, and right now we're just talking about the
Greenwich Sentry fund.
A. Okay.
Q. Okay. So what did you understand your
role to be in relation to the Greenwich Sentry fund?
MR. GLASSER: Objection to form.
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THE WITNESS: A limited partner.
BY MS. PIERCE:
Q. And do you know approximately how many
other limited partners there were in the Greenwich
Sentry fund?
MR. GLASSER: Objection to form.
THE WITNESS: No, no.
BY MS. PIERCE:
Q. I recall you testifying yesterday that
your friend Mr. Centro also invested in Greenwich
Sentry?
A. Yes, ma'am.
Q. Besides Mr. Centro, do you know any of
the other investors or the -- any other limited
partners in Greenwich Sentry?
MR. GLASSER: Objection to form.
THE WITNESS: No.
BY MS. PIERCE:
Q. Did you ever attend any meetings in your
capacity as a limited partner in Greenwich Sentry?
MR. GLASSER: Objection to form.
THE WITNESS: No.
BY MS. PIERCE:
Q. Okay. Prior to your decision to invest

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in Greenwich Sentry -A. Uh-huh.
Q. Strike that.
Do you recall when you first received an
audited financial statement for Greenwich Sentry?
MR. GLASSER: Objection to form.
THE WITNESS: Yes. I believe it was in
2003 or 2004. Maybe 2002 also. I'm not sure.
BY MS. PIERCE:
Q. Did you receive any audited financial
statements before your decision to invest in
Greenwich Sentry?
MR. GLASSER: Objection to form.
THE WITNESS: No.
BY MS. PIERCE:
Q. Do you know who audited Greenwich Sentry
at the time you decided to invest?
MR. GLASSER: Objection to form.
THE WITNESS: I believe it was Berkow,
Schechter
BY MS. PIERCE:
Q. How did you know that Berkow, Schechter
audited Greenwich Sentry at that time?
A. Well, I spoke to Mr. Schechter a few

Martin Bach
times when I had -- we discussed tax questions up and
back, you know, and I believe he told me he did the
audit there. He was their accountant.
Q. Do you recall in any of those
conversations if you asked to review the financial
statements for Greenwich Sentry?
MR. GLASSER: Objection to form.
BY MS. PIERCE:
Q. If you asked -- let me rephrase that. Do
you recall if you ever asked Mr. Schechter prior to
your investment in Greenwich Sentry to review
financial statements for the fund?
A. No, no.
Q. Your first decision to invest in
Greenwich Sentry was when?
A. In February 2002.
Q. And then you -- did you make subsequent
investments in 2002?
A. Yes, ma'am.
Q. How many?
A. Five more.
Q. Well, how about just in 2002?
A. I made -- I made one more in 2002.
Q. Is it possible that you made two more in

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2002?
A. It's possible. It's possible. Yeah.
Q. So it's possible that you made three
investments in 2002 in Greenwich Sentry?
A. If you say so. I don't remember. I made
six altogether, you know.
MS. PIERCE: Okay. Could I see the
addendum to interrogatories?
THE WITNESS: What am I looking for?
MR. GLASSER: I'll grab it. I think
actually it's right there.
BY MS. PIERCE:
Q. If you could take a look at Exhibit 27.
MR. GLASSER: There you go.
THE WITNESS: 27. I got it there, yeah.
BY MS. PIERCE:
Q. Okay. And right there on the front page.
A. Uh-huh.
Q. In the first answer.
A. Okay. I'm looking.
Q. Is that a list of your investments?
A. Yes, I made three in 2002.
Q. And prior to making those three
investments in 2002, is it correct that you did not

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receive an audited financial statement for Greenwich
Sentry?
MR. GLASSER: Objection to form.
THE WITNESS: That's correct.
BY MS. PIERCE:
Q. Okay. Prior to your decision to invest
in Greenwich Sentry, did you receive anything from
PricewaterhouseCoopers related to Greenwich Sentry
fund?
A. No.
Q. Is your question -- or is your answer the
same with respect to PricewaterhouseCoopers
Netherlands?
A. Yes, uh-huh.
Q. Did you know prior to your investment in
Greenwich Sentry that PricewaterhouseCoopers
Netherlands did not audit the Greenwich Sentry fund
at that time?
A. Sure.
Q. Before your decision to invest in
Greenwich Sentry, did you have any contact with
PricewaterhouseCoopers Netherlands with respect to
that investment?
A. No.
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Q. So you didn't contact anyone at
PricewaterhouseCoopers Netherlands?
A. No.
Q. You did not speak to anyone from
PricewaterhouseCoopers Netherlands?
A. No.
Q. You didn't request any materials from
PricewaterhouseCoopers Netherlands?
A. No.
Q. And you never received any materials from
PricewaterhouseCoopers Netherlands?
A. Correct.
Q. Did you know at that -- at the time prior
to your first investment in Greenwich Sentry who
audited Madoff?
MR. GLASSER: Objection to form.
THE WITNESS: No.
BY MS. PIERCE:
Q. Did you think for any reason that it was
PricewaterhouseCoopers Netherlands?
MR. GLASSER: Objection to form.
THE WITNESS: I didn't think no such
thing, but I assumed it was one of the big four
considering the size of -- of Madoff.

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BY MS. PIERCE:
Q. But you know now that it was not one of
the big four; is that correct?
A. That's correct.
Q. Did you know who audited Fairfield
Greenwich Group before you invested in Greenwich
Sentry?
MR. GLASSER: Objection to form.
THE WITNESS: I think I said that before.
I think it -- I thought it was Berkow, you know,
Berkow, Schechter.
BY MS. PIERCE:
Q. You don't have any reason to think it was
PricewaterhouseCoopers Netherlands, do you?
A. That's correct.
Q. With respect to your subsequent
investments -A. Uh-huh.
Q. -- would your answers be the same as to
PricewaterhouseCoopers Netherlands?
MR. GLASSER: Objection to form. I think
it would make sense to go through the specific
investments.
BY MS. PIERCE:

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received -- you received these audited financial
statements for the Greenwich Sentry investment in the
mail?
A. Sure.
Q. Did most of the materials -- or strike
that.
When you received materials related to
the Greenwich Sentry fund -- no, strike that.
Did you ever specifically request any of
the audited financial statements for Greenwich Sentry
fund directly from Fairfield Group?
MR. GLASSER: Objection to form.
THE WITNESS: No.
BY MS. PIERCE:
Q. Did you contact the Fairfield Group after
you learned about the Madoff fraud to discuss any of
the financial statements?
MR. GLASSER: Objection to form.
THE WITNESS: I called -- when I spoke to
Jeffrey Tucker after December 11th, one of the
questions I asked him, this is probably related to
Price Waterhouse. I said, "Jeffrey, did you ever
receive a certified statement from Madoff Investment
Trust?" And he said, "No." That's when my head
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THE WITNESS: I assume so.
BY MS. PIERCE:
Q. It was not out of the ordinary to you
that you were being sent audited financial statements
for Greenwich Sentry?
A. That's correct.
Q. Did you expect to receive one every year?
And let me rephrase. Did you expect to receive an
audited financial statement for Greenwich Sentry
every year?
A. That's correct.
Q. Did you expect Fairfield Greenwich Group
to provide those to you as a part of their services?
MR. GLASSER: Objection to form.
THE WITNESS: Yes.
MS. PIERCE: Just one second. I think
those are all the questions that I have. Thanks very
much.
THE WITNESS: Okay. Thank you, dear.
MR. DECKINGER: We can go off the record
for a second.
THE VIDEOGRAPHER: Going off the record.
The time is 12:24 p.m.
(Recessed from 12:24 p.m. to 12:31 p.m.)
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started to swim a little bit.
If -- if Greenwich who had millions of
dollars invested with Madoff never got a certified
report from anybody, or he invested the money with,
that's when my head started to spin and I started to
wonder how did Price Waterhouse certify the financial
statements of -- of Greenwich when then no -- no
certified audit was in their possession? I couldn't
figure it out. That's when I first started to get
very suspicious.
BY MS. PIERCE:
Q. Prior to that conversation with Jeffrey
Tucker during the -- the six years that you invested
in Greenwich Sentry, you never asked a similar
question of Jeffrey Tucker is what you just
described; is that correct?
A. I just assumed that he got it. Stupidly
assumed.
Q. When I was asking you earlier about your
receipt of audited finan- -- your receipt of audited
financial statements related to Greenwich Sentry, did
you receive those as a routine part of your
relationship with Greenwich Sentry fund?
MR. GLASSER: Objection, form.
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THE VIDEOGRAPHER: Going on the record,
the time is 12:31 p.m.
EXAMINATION
BY MR. TRESSLER:
Q. Good afternoon, Mr. Bach. My name is
David Tressler.
A. Hi.
Q. I'm with the law firm of Kirkland & Ellis
in Chicago, and I represent Price Waterhouse -PricewaterhouseCoopers Canada.
A. Okay.
Q. And I may refer to it as PwC Canada.
A. Okay.
Q. Or PricewaterhouseCoopers Canada, if
that's okay with you.
A. Okay.
Q. Mr. Bach, we are down to the homestretch.
I have 18 minutes so I'm going to be as quick as I
can.
A. Thank you.
Q. But the end is in sight.
MR. GLASSER: But just still give me a
chance in case I need to lodge an objection.
MR. TRESSLER: Yes, absolutely.
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THE WITNESS: Okay.
BY MR. TRESSLER:
Q. You talked with counsel, Mr. Bach,
earlier and confirmed that you didn't receive any
audited financial statements for Greenwich Sentry
prior to making your three 2002 investments in
Greenwich Sentry, correct?
MR. GLASSER: Objection to form.
THE WITNESS: Correct.
BY MR. TRESSLER:
Q. And since you didn't seek audited
financial statements for Greenwich Sentry prior to
making your investments with Greenwich Sentry, not
knowing what the audit report said about Greenwich
Sentry's financial statements didn't stop you from
making your investment with Greenwich Sentry, did it?
MR. GLASSER: Objection to form.
THE WITNESS: That's correct.
BY MR. TRESSLER:
Q. You said earlier that you didn't receive
anything from PricewaterhouseCoopers prior to
investing in Greenwich Sentry?
A. Correct.
Q. And is that also true for
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PricewaterhouseCoopers Canada?
A. Correct.
Q. And you knew that PricewaterhouseCoopers
Canada isn't -- was not the auditor of Greenwich
Sentry prior to making your investment, correct?
MR. GLASSER: Objection to the form.
THE WITNESS: Right.
BY MR. TRESSLER:
Q. And you had no contact or communication
of any kind with PricewaterhouseCoopers Canada with
respect to your investment in Greenwich Sentry before
deciding to invest?
A. Correct.
MR. GLASSER: And just to clarify, we're
talking about his first initial investment?
MR. TRESSLER: Correct. When he decided
to invest. I think I said decided to invest, but I
was referring to 2002.
THE WITNESS: Uh-huh, correct.
BY MR. TRESSLER:
Q. And so you didn't have any -- strike
that.
After you invested in Greenwich Sentry,
you didn't speak or have any communication with
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anyone from PricewaterhouseCoopers Canada -A. Correct.
Q. -- did you? You didn't meet with anyone
from PricewaterhouseCoopers Canada?
A. Correct.
Q. And you didn't call or try to contact
anyone from PricewaterhouseCoopers Canada?
A. Correct.
Q. From the time that you first invested
until today, correct?
A. That's correct.
Q. And you never requested any materials
directly from PricewaterhouseCoopers Canada with
regard to your investment in Greenwich Sentry,
correct?
MR. GLASSER: Objection, form.
THE WITNESS: Correct.
BY MR. TRESSLER:
Q. And after you learned that
PricewaterhouseCoopers became the auditor for
Greenwich Sentry, you didn't think that PwC audited
Madoff, did you?
MR. GLASSER: Objection to form.
THE REPORTER: Madoff?

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MR. TRESSLER: Madoff.
THE REPORTER: Oh, Madoff.
MR. TRESSLER: Madoff.
THE WITNESS: I didn't know who audited.
BY MR. TRESSLER:
Q. You didn't know who audited Madoff, did
you?
A. I just was told it was a large fund like
I said before. Billions of dollars. I couldn't have
done it with three people, you know, so.
Q. And you testified earlier that you found
out after the Madoff Ponzi scheme was revealed that
it was a small accounting firm?
A. Yeah, smaller than my firm actually,
yeah.
Q. You went through with the counsel for -with counsel for PricewaterhouseCoopers Netherlands
the audit reports that you had prior to making your
particular investments, and I think you referred to
Exhibit 27 which listed the six dates on which you
made an investment in Greenwich Sentry?
A. That's correct.
MR. GLASSER: Objection to form.
BY MR. TRESSLER:
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Q. The handwritten notes that we've been
talking about.
A. Yeah, go ahead.
Q. The ones that you took today.
A. Yes, ma'am.
Q. You -- you see at the top there you wrote
the word "Citco"?
A. Yes, ma'am.
Q. Why did you write that?
A. Because I couldn't remember how to say it
all the time. I wanted to remember that when you
asked -- when I talked about it, I said Citco. I
keep forgetting that name. I called it city
yesterday then somebody corrected me so I just put it
down for my memory, that's all.
Q. So would it be correct that you just
wrote that down so that you could remember how to
spell it or pronounce it?
A. Yes, yes, that's all.
Q. So is there any connection between the
word Citco at the top and these other words that
you've written here underneath the word Citco?
A. No. The rest of it had to do with the -the Price Waterhouse audit I wanted -- in case they

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ask me certain questions. Everything else here from
audit program to capital where there's a line relates
to the Price Waterhouse audit.
Q. Okay. What about the -- below the line
it says there are no certified reports from Madoff.
A. Yes.
Q. What did they relate to?
A. Because I didn't get -- when I spoke to
Mr. Tucker, he told me he never got a certified
report from Madoff. So this is a point that I wanted
to bring up in case I had a question about why I was
so angry and everything.
MS. IZQUIERDO: I have no further
questions.
THE WITNESS: That was it.
MR. DECKINGER: I think -- strike that.
MR. DIVINE: Give me one second, I
apologize.
FURTHER EXAMINATION
BY MR. DIVINE:
Q. Mr. Bach, just one or two quick
questions.
A. Sure.
Q. The sentence you wrote here, "No

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Martin Bach
certified report for Madoff," Bach Exhibit number 43.
Do you recall which point in the morning you wrote
that down?
A. What time I did it?
Q. Well, I asked a question. There were a
bunch of people in the room asking questions. Do you
recall who was asking you questions at the time?
A. I might not have had any questions at the
time. I might have just been writing these things
down in case I'm asked questions.
Q. Okay. And these are specific things that
you wanted to make sure that you brought up today; is
that correct?
A. Absolutely.
Q. You wanted everybody to know at this
point; is that correct?
A. Yes. I mean, there's a lot of other
things I would have liked to bring up today, you
know.
Q. I understand. I understand.
A. Believe me.
Q. You came here and you specifically wanted
to get that on the record; is that right?
A. Yes.
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Martin Bach
MR. DIVINE: Okay. That's all I have.
MR. DECKINGER: Anybody else? All right.
I think we're done. Thank you.
THE VIDEOGRAPHER: This concludes the
deposition of Martin Bach. We are off the record at
4:48 p.m.
(Whereupon, at 4:48 p.m. the deposition concluded.)
____________________
MARTIN BACH
Subscribed and sworn to
before me this
day
of
2011

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