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 E

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NATALIA HATGIS

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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.
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VIDEOTAPED DEPOSITION OF NATALIA HATGIS

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New York, New York

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June 24, 2011

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Reported by:

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

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JOB NO. 39620
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"The partnership commenced operations on May 1,
2006." Do you see that?
A. Yes.
Q. This indicates that the Greenwich
Sentry Partners Limited Partnership began on May
1, 2006, right?
A. Uh-huh. Go ahead.
Q. Do you have a question?
A. No. No. You go.
Q. Okay. So there were no year-end
financial statements for Greenwich Sentry
Partners, the fund that you invested in, by the
time that you decided to invest in September or
October of 2006, right?
A. Well, not -- I don't know. Not for
that year, no.
MR. VICKERY: You're representing
that, right?
THE WITNESS: Not for 2006.
BY MS. CRAWFORD:
Q. Right, because the fund just commenced
in May, right?
A. Right.
Q. So the fund had only been in existence
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FGG's auditors and the manager, Bernard Madoff,
was also audited." Do you see that?
A. No. Which one?
Q. The last sentence of -A. Paragraph which one?
Q. -- the first full paragraph on the
second page.
A. Yes. Okay. He told me that the
Sentry Fund was audited by -- yes.
Q. So that doesn't indicate that
PricewaterhouseCoopers was Sentry's auditors,
right?
A. No, not here.
Q. And nothing that your husband said
indicated that PricewaterhouseCoopers was the
auditor, right?
A. I can't remember what everything my
husband said, but it's certainly not in here.
Q. In any event, you only know that
PricewaterhouseCoopers was an auditor for one or
more Fairfield funds?
A. Yes.
Q. And you only knew that at the time
that you made your decision to invest because
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for four or five, six months when you decided to
invest, correct?
A. I don't know. I guess so.
Q. Now, you talked about how your
husband's notes of his meeting with Philip Toub
formed, I think you said, part of the big bowl
of memories about the facts of your investment,
right?
A. Yes.
Q. But those notes don't mention
PricewaterhouseCoopers' name in them, do they?
A. The big bowl?
MR. VICKERY: You better take a look
at it.
Q. The notes. Why don't you take a look
at Exhibit 3.
A. Exhibit 3?
Q. Yes.
A. Okay. What does he say here?
Q. On page 2.
A. On page 2.
Q. At the end of the first full
paragraph, it says, "He," meaning Philip Toub,
"Told me that the Sentry Fund was audited by
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there was the name PricewaterhouseCoopers in the
Fairfield Greenwich marketing materials, right?
A. There was the name somewhere.
Q. You didn't rely on anything that
PricewaterhouseCoopers (Canada) did in making
the decision to invest, did you?
A. No, not that I recall.
Q. You didn't have any contact with
anyone at PwC (Canada) before you invested?
A. No.
Q. And you didn't receive any materials
from PwC (Canada) before you invested?
A. No, I did not.
Q. As you sit here today you don't recall
receiving any audit reports for any of the
Fairfield funds, right?
A. No.
Q. That's correct?
A. That's correct.
Q. Thanks. I think it's me, not you.
A. No, that's okay.
Q. Okay. Can you look at Exhibit 22,
your declaration.
A. 22, yes.
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Q. If you look at paragraph 4, you
stated, "In deciding to make and hold my
investment in the fund, my husband and I
reviewed and relied upon a variety of documents
provided by the Defendants, including a
prospectus. We also reviewed annual reports on
the Fund's performance and documents regarding
FGG's extensive due diligence and depth of
monitoring practices." Do you see that?
A. Uh-huh.
Q. Yes?
A. Yes, I do. I'm sorry.
Q. That's okay.
So, consistent with your answer to my
prior questions, you're not referring in
paragraph 4 to anything that
PricewaterhouseCoopers did in this paragraph,
right?
A. I'm not referring specifically to
that, no -Q. Are you referring -A. -- to anything that
PricewaterhouseCoopers did. But you'd have to
ask my husband as well, because this is a "we."
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Q. Did he tell you anything about what
price -- about what PricewaterhouseCoopers did
before you made the decision to invest?
A. I can't remember.
Q. As you sit here today, you don't
recall?
A. No.
Q. Can you please look at paragraph 9?
A. 9?
Q. Yes.
A. Okay.
Q. It says, "At all relevant times, I
relied upon Defendants' representation that the
fund was going to invest, and actually was
investing, my money in securities. The
Defendants had verified the existence of these
holdings and that the various financial
statements reflecting the value of these
holdings and the value of the Partnership were
accurate." Do you see that?
A. Yes.
Q. Are you referring there to anything
that PricewaterhouseCoopers (Canada) did?
A. Not specifically that I can remember.
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Q. When you say "not specifically," what
do you mean?
A. I mean I can't remember specifically
Pricewaterhouse providing me or Pricewaterhouse
(Canada) -Q. Or PricewaterhouseCoopers at all?
A. Yes, giving me anything.
Q. You don't remember them giving you
anything, right?
A. No.
Q. And you believe that the
representation -- representations regarding the
existence of the holdings in the Greenwich
Sentry Partners Fund I believe you testified
earlier came from Fairfield, right?
A. That's right.
Q. And you said -- I think you testified
earlier, "and the Greenwich people had the
Pricewaterhouse audits," do you remember saying
that?
A. Yes.
Q. But you didn't have the
Pricewaterhouse audits?
A. No. No, I did not.
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Q. And you actually said -- you said,
"I'm not quite sure what they were auditing,"
right?
A. Yes.
Q. Do you actually know what
PricewaterhouseCoopers was auditing?
A. I thought they were auditing the
actual securities, but I didn't quite -- no. I
mean, specifically, no.
Q. You don't know?
A. At that time, no.
Q. Okay. And do you understand that -you understand that PricewaterhouseCoopers
(Canada) did not audit Bernard Madoff, right?
A. Yes.
Q. I believe you said you looked at the
Pricewaterhouse review in making your
investment. Again, are you just referring to
the PricewaterhouseCoopers name generally?
A. Yes.
Q. You're not referring to any actual
documents, right?
A. On Pricewaterhouse letterheads? No.
Q. Could you look at Exhibit No. 21.
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21. Hold on.
Yes. Yes.
Q. These are the materials that you
requested and obtained from Lina Pava in April
of 2009, correct?
A. Apparently, yes.
Q. Now, if you look at the bottom of
page -- of Hatgis 510?
A. Yes.
Q. That begins the list of the materials
you requested, right?
A. Yes.
Q. Okay. If you flip to the next page?
A. Yes.
Q. You see that letter C asks for the
audited financial statements, auditors reports
and management letters, do you see that?
A. Yes.
Q. Why did you ask for those?
A. I may have been advised by my lawyers
to do so or I may not have. I'm not sure.
Q. Well, why -A. Well, let's look at the timeline here
because -- April '09. I was asked by my counsel
A.

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to compile information. This may have been on
their list, but I don't completely remember.
MR. VICKERY: Let me instruct you
don't go any further with respect to advice
of counsel.
THE WITNESS: Okay.
BY MS. CRAWFORD:
Q. You didn't have a copy of the audited
financial statements before you asked for them
in April of 2009, right?
MR. VICKERY: Objection to form.
A. I could not find that.
Q. You didn't have a copy of the
auditor's reports or the management letters
either, right?
A. I could not find any.
Q. Could you turn, same exhibit, but turn
back to the last -- no, excuse me, to Hatgis
611.
A. 611?
Q. Yes.
A. Yes.
Q. These are -- the first page here, 611,
says that these are the Greenwich Sentry
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Partners, L.P. financial statements for the year
ended December 31, 2007 and the period ended
December 31, 2006. Do you see that?
A. Yes.
Q. Before you got this from Lina Pava,
you didn't have a copy of this document,
correct?
A. I don't remember. I really -- I
cannot remember this far back.
Q. Does this document look familiar to
you?
A. I cannot tell you whether it looks
familiar. It just -- I don't remember.
Q. Why can't you tell me if it looks
familiar?
A. Because nothing looks familiar to me
at this point. I'm overwhelmed with papers. So
I cannot tell you -- it does and it doesn't. I
mean, all these documents look the same after a
while.
Your logo's on the first page, and I
can't tell you whether that -- I can't -- I
can't tell you with certainty whether I have
seen this or not. I really can't. I can tell
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you that -Q. If it doesn't, it doesn't. Is it fair
to say it doesn't really look familiar to you,
right?
A. Well, it's hard because I know your
logo really well. Now, whether I know it from
something I owned or something I saw on a
billboard, I can't tell you.
Q. You don't remember reading this
before?
A. No, I don't remember reading this.
Q. And if you look at Hatgis 613?
A. Yes.
Q. This isn't addressed to you, right?
A. No. It's to the -Q. It doesn't have your name on it?
A. It doesn't have my personal name.
Q. It doesn't have your address on it?
A. No.
Q. As far as you know, PwC (Canada) never
actually sent you any materials, correct?
A. All I can say with certainty is if I
asked Lina for it, I didn't have it. That's
what I can tell you.
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Q. Do you recall getting any materials in
the mail from PricewaterhouseCoopers (Canada)?
A. I don't recall, but I don't -- I don't
recall, basically.
Q. And you never had any contact with
anyone from PwC (Canada).
A. No. No.
Q. You understand that you're suing PwC
(Canada) in this lawsuit?
A. I believe you're involved, yes, I
understand that.
Q. What do you contend that PwC (Canada)
failed to do?
A. I am contending that the audits that
you were giving Fairfield Greenwich and that
they were giving us seemed to be inaccurate, and
yet you were hired to give -Q. And what's your -A. -- legitimate audits.
Q. And what's your basis for that
contention?
A. That there was -- there was no -there was no money. You know, as a layperson,
that's the only way I can explain it. So we're
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Q. What's the basis for your contention
that PwC (Canada) should have discovered the
Madoff Ponzi scheme?
A. If you were the auditing firm hired by
these guys that I invested with to audit their
books and their performance, I would have
assumed that, as an auditor -- as auditors, you
would have applied your skills to see if there
was actually any money there. I mean, again, I
can't get into a technical...
Q. You certainly have no auditing
expertise, correct?
A. Oh, good Lord, no. I'm sorry.
Q. And you don't have any information
that would support the notion that PwC (Canada)
conducted its audits negligently or improperly,
right?
A. No.
MR. VICKERY: We'll have lots of
expert testimony on that.
THE WITNESS: Oh, I'd love to see
this.
MS. CRAWFORD: Me, too.
I have no further questions.
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quoting money that actually didn't exist.
Q. And are you aware of any other
auditors that discovered Madoff's Ponzi scheme
before December 11, 2008?
A. I don't -- no. I mean, I'm not
relating this to Madoff. I'm relating this to
Greenwich.
Q. Tell me what you mean by that.
A. In other words, you're asking me
whether, you know, why am I suing Greenwich
Capital. I mean, I'm not quite sure what this
has to do with Madoff. Do I know that other
people were auditing Madoff? I guess so.
MR. VICKERY: I think all the
allegations with respect to PWC are set
forth in the Second Amended Complaint, and
that's her -- she's part of the class.
MS. CRAWFORD: I'm entitled to ask my
questions.
MR. VICKERY: You can ask the
questions. I'm just telling you if you want
the facts, the allegations are in the Second
Amended Complaint.
BY MS. CRAWFORD:
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THE WITNESS: Thank you.
EXAMINATION BY
MS. PIERCE:
Q. Last but not least.
A. Another one?
Q. Yes.
A. Aren't you patient.
Q. Ms. Hatgis, my name is Betsy Pierce
and I'm associated with the firm of Hughes
Hubbard & Reed. We represent
PricewaterhouseCoopers (Netherlands) in this
litigation, and I guess my first question for
you is have you ever heard of
PricewaterhouseCoopers (Netherlands)?
A. No.
Q. And you just answered questions from
counsel for PricewaterhouseCoopers (Canada). Do
you understand that there's a difference between
the firm PricewaterhouseCoopers (Canada) and the
firm PricewaterhouseCoopers (Netherlands)?
A. No, I do not.
Q. Do you just -- just in hearing that
those two firms have two different countries
attached to their names, what would that make
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you think about those firms in terms of the
difference between the two?
MR. VICKERY: Objection to form.
MS. PIERCE: Fair.
BY MS. PIERCE:
Q. Would you like me to try to rephrase
that?
A. Yes.
Q. So if one country -- or, if one firm
is called PricewaterhouseCoopers (Canada) and
the other firm is called PricewaterhouseCoopers
(Netherlands), just based on that, what do you
think the difference is?
A. I would think that the Netherlands
branch looked after the companies in the
Netherlands and the Canada was handling
companies based out of Canada.
Q. Okay. Prior to your decision to
invest in Greenwich Sentry Partners, L.P., did
you speak to anyone at PricewaterhouseCoopers
(Netherlands) about your investment?
A. No, I did not.
Q. Okay. Prior to your decision to
invest in Greenwich Sentry Partners, L.P., did
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that may have come from PricewaterhouseCoopers
(Netherlands) after making your investment?
A. No, I don't recall.
Q. Based on the answer you just gave
regarding PricewaterhouseCoopers (Netherlands),
would you agree with me that it's fair to say
that you didn't rely on anything from
PricewaterhouseCoopers (Netherlands) -MR. VICKERY: Objection to form.
Q. -- in making your decision to invest
in Greenwich Sentry Partners?
MR. VICKERY: If you understand the
question, you can answer it.
THE WITNESS: Can you please rephrase
that or just repeat it?
BY MS. PIERCE:
Q. Sure. Based on the things we were
just talking about, the questions I was asking
and the answers you were giving?
A. Yes.
Q. Would you agree with me that it would
be fair to say that you would not have relied on
anything from PricewaterhouseCoopers (Canada) -or, excuse me, PricewaterhouseCoopers
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you receive any materials -A. No.
Q. -- from PricewaterhouseCoopers
(Netherlands)?
A. No, I did not.
Q. And prior to your decision to invest
in Greenwich Sentry Partners, did you review any
materials that may have come from
PricewaterhouseCoopers (Netherlands)?
A. Not that I can recall right now.
Q. Now I'm going to switch to after you
made your investment.
A. Okay.
Q. After making your investment in
Greenwich Sentry Partners, L.P., did you speak
to anyone with PricewaterhouseCoopers
(Netherlands)?
A. No, I did not.
Q. And after making your investment in
Greenwich Sentry Partners, L.P., did you receive
any materials from PricewaterhouseCoopers
(Netherlands)?
A. Not that I can recall.
Q. Do you recall reviewing any materials
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(Netherlands) in making the decision to invest
in Greenwich Sentry Partners, L.P.?
MR. VICKERY: Do you understand the
question?
THE WITNESS: No. I'm sorry.
BY MS. PIERCE:
Q. Just to -- my understanding of the
testimony you just gave is that you have had no
contact prior to or after making your investment
with PricewaterhouseCoopers (Netherlands)?
A. Right.
Q. So would you agree with me then that
you didn't rely on anything that
PricewaterhouseCoopers (Netherlands) did -A. As far as I can remember right now.
Q. -- in making your investment?
A. I agree.
Q. Do you understand that you have sued
PricewaterhouseCoopers (Netherlands) in this
litigation?
A. I understand that.
Q. Are you aware, though, that
PricewaterhouseCoopers (Netherlands) was not the
auditor of Fairfield Greenwich Group?
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A. Am I aware that it was not the
auditor? I am aware right now.
Q. Are you also aware that
PricewaterhouseCoopers (Netherlands) never
performed an audit of Greenwich Sentry Partners,
L.P., the fund in which you invested?
A. I have no knowledge at all of whether
you are or not or did or not.
Q. Can I turn your attention to Exhibit
5?
A. Yes. Exhibit 5, yes.
Q. And if you could turn to the page that
has the -- it's Bates-stamped Hatgis 0000758.
A. Yes.
Q. And is that the page you're looking at
at the top, does it have a black bar that says
"Value Added" -A. Yes.
Q. -- "By FGG"?
A. Yes.
Q. So, just based on that heading, do you
recognize as this being a Fairfield Greenwich
Group document?
A. I consider it as being a PowerPoint
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presentation that I probably saw.
Q. And do you think that it was prepared
by Fairfield Greenwich Group?
A. I think so, yes. It has its
letterhead.
Q. Now, the second line in the text below
that, that heading, says "Independent
Verification of Prices and Account Values"?
A. Yes.
Q. Do you remember your testimony about
that statement earlier today?
A. No, I don't.
Q. You, what I understood you to say
earlier -A. Okay.
Q. -- and we can go back and find the
testimony -A. Sure.
Q. -- if you would like, but what I
recall understanding you saying was that you
would have relied on the fact that, when you
read this, you would have understood and relied
on the fact that Fairfield Greenwich Group was
being audited by a legitimate accounting firm?
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NATALIA HATGIS
A. Yes.
Q. And that that firm -Excuse me. I'm trying to read some
notes. Just a sec.
A. That's okay.
Q. So when you were discussing that
statement, you connected it to auditors; do you
recall that in your testimony earlier today?
MR. VICKERY: Objection to form. I
don't know exactly what was said earlier,
but -THE WITNESS: Yeah, I don't, I mean -BY MS. PIERCE:
Q. We can go back and find it then.
Okay. Then let's -- let me start
over. Let me try again.
So we just agreed that this was a
Fairfield Greenwich Group document?
A. Yes.
Q. As far as you understand it?
A. Yes.
Q. And at the top it says "Value Added By
Fairfield Greenwich Group"?
A. Yes.
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NATALIA HATGIS
Q. So what do you understand that to
mean, "Value Added by Fairfield Greenwich
Group"?
A. That meant what were the advantages to
me, what were the advantages of going with the
Greenwich Group as opposed to another group. So
what were their value added by their different
services that set them apart and explained their
management fees.
Q. And nothing in this, in this page
right here, independent of your understanding
that we talked about today, nothing actually
says that this is value added by an auditor?
A. No, it does not, and it does not list
your name.
Q. It does not list
PricewaterhouseCoopers at all?
(Continued on the next page to include
the jurat.)

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NATALIA HATGIS
A. On this page, no.
Q. Okay.
MS. PIERCE: Thank you. I think those
are all -- I think those are all the
questions I have.
THE WITNESS: Thank you.
THE VIDEOGRAPHER: The time is 7:11
P.M. We're going off the record.
oOo

____________________
NATALIA HATGIS
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 NATALIA HATGIS, 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 30th day of June, 2011.
------------------------------KATHY S. KLEPFER, RPR, RMR, CRR, CLR

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NATALIA HATGIS

NATALIA HATGIS
INDEX
TESTIMONY OF N. HATGIS:
Examination by Ms. Ricciardi
Examination by Ms. McGovern
Examination by Ms. Crawford
Examination by Ms. Pierce

1
2
3
PAGE
4
7
5
317
6
350
7
373
8
9
NATALIA HATGIS EXHIBITS:
PAGE
10
Exhibit 1, a document bearing Bates Nos. Hatgis 54
11
002044
12
Exhibit 2, a document bearing Bates Nos. Hatgis 57
13
002057 through 002061
14
Exhibit 3, a document bearing Bates Nos. Hatgis 74
15
000248 to 000249
16
Exhibit 4, Addendum to Plaintiffs' Responses
85
17
and Objections to Defendants' Joint First Set
18
of Interrogatories to Plaintiffs for Plaintiff
19
Natalia Hatgis
20
Exhibit 5, a document bearing Bates Nos.
126
21
Hatgis 000739 through 000820
22
Exhibit 6, a document bearing Bates Nos.
156
23
Hatgis 0001910 through 0002034
24
Exhibit 7, a document bearing Bates Nos.
168
25
Hatgis 000290 through 000292
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NATALIA HATGIS
INDEX (Cont'd.)
NATALIA HATGIS EXHIBITS:
PAGE
Exhibit 8, a document bearing Bates Nos.
175
Hatgis 000829 through 000830
Exhibit 9, a document bearing Bates Nos.
178
Hatgis 000307
Exhibit 10, a document bearing Bates Nos.
184
Hatgis 0002149
Exhibit 11, a document bearing Bates
187
Nos. ANWAR-CCI-000095 through 0000104
Exhibit 12, a document bearing Bates
187
Nos. ANWAR-CCI-0000115 through 0000124
Exhibit 13, a document bearing Bates Nos.
205
FGANW002895361 to 2895362
Exhibit 14, a document bearing Bates Nos.
208
Hatgis 000281 through 000286
Exhibit 15, a document bearing Bates Nos.
211
Hatgis 0001828 through 1829
Exhibit 16, Addendum Number 2 to Plaintiffs' 216
Responses and Objections to Defendants' Joint
First Set of Interrogatories to Plaintiffs for
Natalia Hatgis
Exhibit 17, a document bearing Bates Nos.
224
Hatgis 0003019 to 3020
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