1

1 IN THE CIRCUIT COURT OF THE 11TH

 JUDICIAL CIRCUIT IN AND FOR

2 MIAMI-DADE COUNTY, FLORIDA

3 CASE NO: 08-16913 CA 03

4 EMBRAER FINANCE LTD.,

5 Plaintiff,

6 vs.

7 SERVICIOS AEREOS

PROFESIONALES, S.A.,

8

 Defendant.

9 ________________________________________/

10 VERITEXT REPORTING

 19 West Flagler, Suite 1020

11 Miami, Florida 33130

 January 18th, 2010

12 10:00 a.m.

13

14

15 DEPOSITION OF JOSE M. PATIN,

16

17 Taken on behalf of the Plaintiff, before Jaime

18 Koganovsky, Court Reporter, Notary Public in and for

19 the State of Florida at Large, pursuant to Notice of

20 Taking Deposition in the above cause.

21

22

23

24

25
2

1 APPEARANCES:

2 ROBERT C. OWENS, ESQUIRE, OF THE FIRM OF

ROBERT C. OWENS, P.A.

3 18890 Southwest 264 Street

Miami, Florida 33031

4 On Behalf of the Plaintiff.

5 JOSE CERVERA, ESQUIRE

7950 West Flagler Street, Suite 108

6 Miami, Florida 33144

On Behalf of the Defendant.

7

ALSO PRESENT:

8 CHRISTINA VELARDE

(SPANISH INTERPRETER)

9

10 I N D E X

11 WITNESS DIRECT CROSS

12 JOSE PATIN 3 0

13 PLAINTIFF'S EXHIBITS

14 NUMBER PAGE

15 1 13

2 15

16 3 16

4 16

17 5 28

6 28

18 7 36

8 44

19 9 45

10 45

20 11 47

12 47

21 13 49

14 56

22 15 60

16 63

23 17 71

18 72

24 19 73

20 77

25 21 78
3

1 THEREUPON,

2 CHRISTINA VELARDE,

3 was called to translate from Spanish to English and English

4 to Spanish to the best of her ability the following:

5 THEREUPON,

6 JOSE M. PATIN,

7 was called as a witness by the Plaintiff and, having been

8 first duly sworn, testified as follows:

9 DIRECT EXAMINATION

10 BY MR. OWENS:

11 Q Would you state your full name please.

12 A Jose Miguel Patin Eusebio, E-U-S-E-B-I-O.

13 Q Good morning, I'm Robert Owens the

14 attorney for Embraer Finance Limited.

15 A It's a pleasure to meet you.

16 Q Thank you.

17 A A pleasure to meet you.

18 Q I would like to make sure you understand

19 your answers will be under oath just as if you were

20 testifying in court.

21 A I understand.

22 Q I'd like to ask you to respond to each of

23 my questions with a verbal response because the

24 court reporter cannot take down a nod.

25 A I understand.
4

1 Q If you need a break, let me know and we'll

2 take a break.

3 A Fine.

4 Q If you don't understand the question, tell

5 me so and I'll rephrase it.

6 A Fine.

7 Q Please let me finish my full questions

8 before you respond.

9 A Fine. Could I borrow one of those

10 notebooks, please?

11 Q Yes.

12 If you do not know or cannot remember the answer

13 to a question, you can just say so.

14 A Fine.

15 Q What is your address?

16 A 520 Brickell Key, Apartment 914. Zip code

17 33131, Florida.

18 Q How long have you lived there?

19 A I've been living there for approximately

20 five years.

21 Q Where did you live before that?

22 A I lived in a leased apartment in the

23 southwest area, but I don't recall the exact address

24 now.

25 Q Is the United States your full -- your
5

1 domicile?

2 A Yes, the United States is where I live.

3 Q And how long have you had your domicile in

4 the U.S.?

5 A Eight or nine years.

6 Q Is that when you became a U.S. citizen?

7 A During that period. During that period my

8 family and us.

9 Q Your family and us did what?

10 A My children.

11 Q Became citizens?

12 A Yes.

13 Q What is your business address?

14 A At this time here?

15 Q What is the exact address?

16 A I'm asking you if you want the current

17 one, the one now?

18 Q Yes.

19 A We don't have one here at this time.

20 Q Well, where is your business address?

21 A In Santa Domingo.

22 Q Could you give me the exact address,

23 please?

24 A Aeropuerto del Higuero, Santo Domingo,

25 Dominican Republic.
6

1 Q What is the name of your business?

2 A Servicios Aereos Profesionales, S.A.

3 Q Do you hold any titles or positions in

4 that company?

5 A No, not at this time.

6 Q Have you ever held any positions or titles

7 in that company?

8 A Yes, until December of last year.

9 Q When did you first hold a position with

10 that company?

11 A After my father passed away, about four

12 years ago. Can't you speak? Okay. Well, then, I

13 don't recall exactly how many years exactly.

14 Q When did -- may I call it SAPSA?

15 A Servicios Aereos Profesionales.

16 Q In order to be able to speak quickly, may

17 I refer to it as SAPSA?

18 A I prefer Servicios Aereos Profesionales in

19 order not to --

20 Q Okay. When did Servicios Aereos

21 Profesionales, S.A. begin operation?

22 A Servicios Aereos Profesionales began its

23 operation 30 years ago.

24 Q And was that a family business?

25 A It's a company that my father initiated --
7

1 started.

2 Q What was your father's name?

3 A Jose Miguel Patin Hernandez.

4 Q Did his father have any association with

5 the company?

6 A His father.

7 Q Yes.

8 A No, my grandfather passed away many years

9 ago, more than 25 years ago.

10 Q Mr. Patin, when your --

11 A And his name was not Jose Miguel either,

12 it was Conrado Patin.

13 Q Prior to your father passing away, did you

14 hold any position or employment or do any work for

15 Servicios Aereos Profesionales, S.A.?

16 A Okay. Yes, I would fly as an advisor and

17 I would fly as a pilot and as an instructor, but at

18 the time I was a pilot for an airline, Dominican

19 Airlines.

20 Q Prior to your father passing away, did you

21 have any officership with the company?

22 A Could you repeat the question?

23 Q Prior to your father passing away, did you

24 have any position or employment with the company

25 other than as a pilot?
8

1 A I was an advisor to the company with my

2 father.

3 Q Do you now or have you ever owned any

4 stock in the company?

5 A Yes, we still own stock in the company,

6 and those stock we were asked to -- we still own

7 stock.

8 Q How many shares do you own?

9 A If she can't speak, I can't recall

10 exactly. We have some stock.

11 Q Do you recall how many shares the company

12 has outstanding?

13 A I don't recall.

14 Q Do you recall what percentage of the

15 company you own?

16 A I don't recall right now.

17 Q Do you recall approximately?

18 A No.

19 Q Who are the other shareholders in the

20 company?

21 A Shareholders in Santo Domingo, some of

22 them are my children, and then there are other

23 shareholders, also, in Santo Domingo, but I don't

24 recall their names exactly. I don't recall their

25 names.
9

1 Q Any of them?

2 A Yes, I could recall some, my children.

3 Q Please name them.

4 A Joan, Isabel Maria, Marisol Azar, that I

5 recall.

6 Q These are all children of yours?

7 A Some are, some are not. Some are just

8 businessmen that are involved in the company.

9 Q Well, is Joan your child?

10 A Yep.

11 Q How old is she?

12 A He is 24 or 25.

13 Q Would you please spell his name?

14 A Joan, J-O-A-N, Miguel, Patin, P-A-T-I-N.

15 Q Where does he live?

16 A Santa Domingo.

17 Q Does he have any residence here in the

18 U.S.?

19 A No.

20 Q What is his address in Santa Domingo?

21 A I don't know his address. I know where he

22 lives, I just don't know exactly what the physical

23 address is.

24 Q Is Isabel Maria one of your children?

25 A Yep.
10

1 Q And her last name is Patin?

2 A Patin Hernandez.

3 Q And how old is she?

4 A She is about 32.

5 Q Okay. And Marisol Azar?

6 A She is one of the shareholders of the

7 company.

8 Q She is not one of your children?

9 A No.

10 Q How many shares does Joan own?

11 A I don't recall mine correctly, I can't

12 recall anybody else's. I don't recall anybody's

13 shares or anybody's number of stock.

14 Q Is there anyone that you know of that owns

15 a majority of the shares?

16 A I don't recall.

17 Q Are there any other shareholders that you

18 can recall besides Joan, Isabel and Marisol?

19 A My other son, Jose Miguel. I would like

20 to ask my wife something, but if I can't ask her

21 then I don't recall who the others are.

22 Q You're fine to ask her if you want.

23 A My mother.

24 Q What is her name?

25 A Pura Eusebio.
11

1 Q Where does she live?

2 A Santa Domingo.

3 Q And Jose Miguel Patin, where does he live?

4 A Lives in Santa Domingo.

5 Q And Isabel Patin?

6 A Santa Domingo.

7 Q And Marisol Azar?

8 A Santa Domingo.

9 Q Do you recall the addresses of any of

10 these people?

11 A No. I know where they live, I just don't

12 have the physical address to be able to give it to

13 you, the numbers.

14 Q Do you own shares in the company jointly

15 with your wife?

16 A My shares are mine.

17 Q And your wife has separate shares?

18 A I think so.

19 Q Why do you say you think so?

20 A Because I think so because I'm not sure.

21 Q Would you please describe your education.

22 A I have a secondary school degree,

23 bachelor, then I came to study in the U.S., I became

24 a pilot. I attended several different pilot schools

25 here in the U.S., and then I went back to the
12

1 Dominican Republic and started flying. After that I

2 was captain for the 727 and many other planes. I

3 was also an instructor in the Dominican Republic.

4 Q Were you a citizen of the Dominican

5 Republic prior to being a citizen of the United

6 States?

7 A Yes.

8 Q Do you still hold citizenship with the

9 Dominican Republic?

10 A Yes.

11 Q What titles or positions did you hold with

12 the company after your father passed away?

13 A When my father passed away I became the

14 president of the company.

15 Q And as the president of the company, did

16 you know who the shareholders were?

17 A Yes, I know more or less who the

18 shareholders are, I believe there is seven and I've

19 given you about five, the ones I recall.

20 Q Actually, you've given me seven.

21 A Well, then, those are it.

22 Q Okay.

23 A I don't know if there is more. The

24 Dominican Republic requests or asks that I have a

25 minimum of seven so there could be more, there could
13

1 be ten, but those are the ones I recall.

2 Q Is there a roster or a document in the

3 company that shows who the shareholders are and how

4 many shares they own?

5 A Those documents should be in the Dominican

6 Republic.

7 Q In the company's records?

8 A In the record of the company in the

9 Dominican Republic.

10 Q Is that information also on file with the

11 government or Santa Domingo -- the Dominican

12 Republic, I'm sorry?

13 A Yes, I imagine so.

14 Q Do you and your wife own a majority of the

15 stock of the company?

16 A I don't recall that right now. I don't

17 know how the company is split, the stocks. I know I

18 used to be the president of the company.

19 Q And do you recall -- strike that.

20 MR. OWENS: Let me mark this as Exhibit 1

21 to this deposition.

22 (Whereupon, the referred-to documents were

23 marked as Plaintiff's Exhibit Number 1 for

24 Identification.)

25
14

1 BY MR. OWENS:

2 Q Do you recognize this document?

3 A I would like for the interpreter to

4 translate this document.

5 Q Have you ever seen that document before?

6 A Something like that -- something similar,

7 but I don't know if this is exactly it. And I

8 prefer if it's interpreted to me because then I

9 could be able to remember some things that are here.

10 Q Have you brought any documents with you

11 today?

12 A Yes, we have brought some documents.

13 Q May I see them, please.

14 You recall being served with a subpoena?

15 A Yes.

16 Q Did you have an opportunity to have that

17 document reviewed and/or translated so that you

18 understand what was in it?

19 A We went to our attorneys with the

20 document.

21 Q Did you come to understand what was in

22 that subpoena that was served on you?

23 A Bring some documents, whatever I had

24 available, whatever I was able to bring.

25 Q And did you do that today?
15

1 A I brought some of the documents that have

2 been requested and that I have been able to obtain.

3 They are practically the bank's documents.

4 Q May I see them, please.

5 MR. OWENS: Let mark this as Exhibit 2,

6 please.

7 (Whereupon, the referred-to documents were

8 marked as Plaintiff's Exhibit Number 2 for

9 Identification.)

10 BY MR. OWENS:

11 Q Do you recognize the document in Exhibit

12 2?

13 A Are these the ones I just handed you?

14 Q Yes.

15 A Oh, yes.

16 Q You recognize them?

17 A Yes.

18 Q You have to say yes or no.

19 A Yes, yes.

20 Q What account is that?

21 A That was -- no longer is. Okay, that

22 account exists, the only thing is that Embraer froze

23 this account.

24 Q And so the company does not use the

25 account any more?
16

1 A Okay. No, it hasn't used it for almost

2 two years as soon as the order came from New York to

3 freeze, or to take over the account it hasn't been

4 used again. It can't be used, the accounts are --

5 there is --

6 MR. OWENS: Would you mark this as Exhibit

7 3, please.

8 (Whereupon, the referred-to documents were

9 marked as Plaintiff's Exhibit Number 3 for

10 Identification.)

11 BY MR. OWENS:

12 Q I want to show you the document we've

13 marked as Exhibit 3 relating to the account of the

14 company.

15 Do you recognize that?

16 A Yes.

17 Q And does the company use that account

18 anymore?

19 A Same response I gave you before, same

20 date. As soon as the account was froze because of

21 an order that was filed in New York.

22 Q Do you have any other documents with you

23 today?

24 MR. OWENS: Mark this as Exhibit 4.

25 (Whereupon, the referred-to documents were
17

1 marked as Plaintiff's Exhibit Number 4 for

2 Identification.)

3 BY MR. OWENS:

4 Q Do you recognize this document or the

5 documents marked as Exhibit 4?

6 A Yes.

7 Q And what are those documents?

8 A These are bank statements for the years

9 you requested, I believe 2007, 2008, something like

10 that, until the accounts were closed or seized by

11 them.

12 Q What purpose did these accounts have?

13 A Those were basically the operating

14 accounts. One was an operating account for the

15 company for purchases -- parts or purchase orders

16 that would be requested from here. It always had

17 about 4,000 $5,000 in it. And the other one was the

18 company's main account basically to receive the

19 income -- the company's income from charter flights,

20 and to pay gas or fuel, parts. Also to do business

21 deals with planes. It was a -- the company's

22 general account, normally was all the official

23 things the company did.

24 Q Which account was that?

25 A One of the two.
18

1 Q Do you know which?

2 A Servicios Aereos Profesionales, S.A.

3 Q We don't have to use the translator if you

4 don't want to.

5 A Just in case there is something I don't

6 understand, because this is my mother tongue.

7 Q Okay.

8 A I prefer to have the interpreter.

9 This is an account, here it states it's a

10 technical account, it is the first one I mentioned. It was

11 used for the company to purchase here all the way from crews

12 to paint, shampoo for cleaning planes, detergent for

13 cleaning planes, that type of thing.

14 Q You were just referring to the accounts

15 marked as Exhibit 4?

16 A A technical account, yeah.

17 Q It is marked as Exhibit 4, correct?

18 A You marked it as 4, yes.

19 Q Now, which account is number two?

20 A I think this is it, this is marked number

21 2, Exhibit 2.

22 Q Which account was that, is that the main

23 account?

24 A The company's main account. The company's

25 main account that we use to pay -- the main account.
19

1 Q What kind of account was Exhibit Number 3?

2 A Oh, these are the same accounts, it is

3 just that they've been divided to the years you have

4 requested.

5 Q Well, when I look at the account numbers

6 on these two exhibits and I see different account

7 numbers.

8 A One is a technical account which is the

9 technical account here.

10 Q Exhibit 4?

11 A And this is --

12 Q If you --

13 A May I see because they both have same

14 names here. It is basically the same bank -- I

15 don't know if these are the same banks.

16 I can ask her.

17 Q Fine.

18 A Okay. This is Bank of America and these

19 would -- the technical and other one are from Mellon

20 Bank.

21 Q So the documents in Exhibit 2, did you say

22 they relate to an operating account of the company?

23 A Yes, an operating account of the company.

24 Q Does the company still maintain funds at

25 Bank of America?
20

1 A Exactly the same thing happened with this

2 account as with the other accounts.

3 Q Where does the company keep its funds in

4 the United States?

5 A Nowhere, it doesn't maintain it. We have

6 no funds here.

7 Q Do you have any?

8 A Not here nor there either. The accounts

9 in the Dominican Republic have also been seized.

10 Q By whom?

11 A First by them, and then after that by

12 different entities.

13 Q By Embraer?

14 A By Embraer many years ago, and after that

15 other entities also.

16 Q Where does the company maintain its bank

17 accounts now?

18 A We don't have bank accounts at this time.

19 Q Anywhere?

20 A Nowhere.

21 Q You do all your business by cash?

22 A We don't do business by cash. At this

23 time the company doesn't even have planes, we lease

24 planes. If we get a request then we lease a plane.

25 Q From who?
21

1 A Whatever plane is available, whoever has a

2 plane available.

3 Q From other of your companies?

4 A Whoever has planes available in Santa

5 Domingo.

6 Q Do you have companies that have planes?

7 A Companies that have planes? No, I don't

8 have any company that has planes.

9 Q Let me go back, if I may, to this subpoena

10 that has been marked as Exhibit 1.

11 A Yes. Which one is that? Okay, this,

12 fine.

13 Q That one.

14 When you got served with a subpoena did someone

15 translate it for you?

16 A If this is the one that was served to me

17 we analyzed it with our attorney.

18 Q And so you fully understood what you

19 needed to produce here today?

20 A Yeah, more or less.

21 Q And then did you have any documents with

22 you in the United States at that time that you have

23 not produced today?

24 A I had no document in the U.S., not even

25 these.
22

1 Q What assets does the company have?

2 A Assets the company? Assets the company?

3 I believe the company has a plane to its name, but

4 its financed by Cessna Finance, and it has another

5 plane which is the Embraer plane which you can take

6 if you want.

7 Q What is the call sign on that one,

8 registration mark?

9 A May I ask my wife?

10 Q Let's go back to the airplane that is

11 financed by Cessna Finance. What kind of airplane

12 is that?

13 A It's a Cessna Caravan 208.

14 Q Do you recall the call sign of that

15 aircraft?

16 A I believe it's HI760.

17 Q And the Embraer is not operational, is it?

18 A I kept it in the same condition that they

19 sold it to me in, inoperable.

20 Q The company has an operating certificate

21 from the Dominican Republic, is that correct?

22 A Yes.

23 Q Does it hold operating certificates of any

24 type from any other countries?

25 A I have a 129 from the same company. I
23

1 didn't understand your question.

2 Q The company, Servicios Aereos

3 Profesionales, S.A. has a part 129 certificate from

4 the USFAA?

5 A No, Santa Domingo.

6 Q That's the operating certificate?

7 A Yes.

8 Q And what does that certificate allow the

9 company to do?

10 A Charter flights. Charter flights.

11 Q No scheduled service?

12 A No.

13 Q And when the company sells a charter

14 flight, where does it receive the money?

15 A The company leases a plane and based on

16 the credit that the company has there, which is not

17 the best in the Dominican Republic. When we lease a

18 plane the first thing that is done, for example, is

19 if it is a charter that costs $1,000, the company

20 that I lease a plane from collects their money, the

21 fuel, everything. And then what's left over, 100,

22 $200, whatever, and they pay for that and they pay

23 for it practically in cash because it's a small

24 amount to pay for the maintenance, employees,

25 because we have planes in dry lease.
24

1 Q The company has aircraft on dry lease?

2 A That's how it operates.

3 Q What's the term of these dry leases?

4 A The company leases -- they allow me to use

5 the plane and I provide the pilots and the

6 maintenance.

7 Q What companies are providing these planes?

8 A Different companies in the Dominican

9 Republic.

10 Q What are the names of these companies?

11 A Caribe Air. Different companies in Santa

12 Domingo, whoever has an available plane. When the

13 request comes in, and sometimes they do the request

14 themselves with their pilots.

15 Q What company's planes does -- I'm sorry.

16 What company's planes does Servicios Aereos

17 Profesionales, S.A. maintain?

18 A Different companies.

19 Q What are the names of those companies?

20 A I told you Caribe Air, and we have -- from

21 different companies, many companies.

22 Q Name them.

23 A What's the name of the company? Different

24 companies. We lease from -- on some occasions we

25 lease from Air Century, Caribe Air and Santo
25

1 Domingo, sometimes we even lease from Haiti.

2 Q Is that an airline?

3 A Yes.

4 Q What is the name of the airline?

5 A Caribe Inter Haiti.

6 Q Spell Inter.

7 A I-N-T-E-R.

8 Q And Santa Domingo, is that Air Santa

9 Domingo?

10 A Yes.

11 Q Who owns Air Santo Domingo?

12 A Another company also that is part of the

13 family.

14 Q What is the family that you're talking

15 about?

16 A Family. There is some members of our

17 family and then there's other members of the

18 company, our partners.

19 Q Who are the owners of that company?

20 A Part of that company is myself and about

21 ten other partners, and I don't recall their names

22 right now.

23 Q You don't recall any of their names?

24 A There is me, I believe my wife, and then

25 there is about seven or eight more.
26

1 Q Who are the others?

2 A I don't recall.

3 Q Was that company ever owned by Servicios

4 Aereos Profesionales, S.A.?

5 A No, no. That is a Spanish company that

6 used to belong to Air Europa.

7 Q Where is it incorporated?

8 A Dominican Republic.

9 Q So you and these other people bought Air

10 Santa Domingo from Air Europa?

11 A But it's been many years, over 12 or 15

12 years.

13 Q What kind of business is that company?

14 A Charter business.

15 Q Same business as Servicios Aereos

16 Profesionales, S.A.?

17 A More or less the same type of business

18 except that is 30 years old and this one is about 12

19 or 15.

20 Q What type of planes does Air Santa Domingo

21 have?

22 A Jet stream Lets plane.

23 Q L-E-T-S, is that correct?

24 A Yes.

25 Q What others?
27

1 A Twin otter 200, the small one.

2 Q Any other planes?

3 A It has a Short 360, I think.

4 Q It is Short, S-H-O-R-T, correct?

5 A Yes, 360.

6 Q Any others?

7 A I don't recall any more, I think that is

8 it.

9 Q Were these aircrafts owned by Servicios

10 Aereos Profesionales, S.A. at one time?

11 A I believe that the Short did belong to

12 Servicios Aereos Profesionales. The others, if I'm

13 not mistaken, were aircrafts that were acquired from

14 other companies.

15 Q When was the Short sold by the company to

16 Air Santa Domingo?

17 A I believe several years ago, but I don't

18 recall how many years.

19 Q Is it your testimony today that the only

20 aircraft that was transferred from Servicios Aereos

21 Profesionales, S.A. to Air Santa Domingo was the

22 Short?

23 A That I recall now. That I recall.

24 Q Are you involved in any way in a company

25 called Professional Air Services, LLC?
28

1 A No.

2 Q Have you ever been involved with that

3 company?

4 A No.

5 MR. OWENS: Would you mark this as Exhibit

6 5.

7 (Whereupon, the referred-to documents were

8 marked as Plaintiff's Exhibit Number 5 for

9 Identification.)

10 BY MR. OWENS:

11 Q Mr. Patin, look at Exhibit 5. Are you the

12 Jose M. Patin that is listed on that corporation

13 with the Florida Secretary of State?

14 A No.

15 Q Do you know who that person is?

16 A That must be my son.

17 Q Does Servicios Aereos Profesionales, S.A.

18 lease aircraft from Professional Air Services, LLC?

19 A Not that I'm aware of.

20 Q And in your possession as president of the

21 company, you would be aware of it if it did lease

22 aircraft from your son, right?

23 A I think so.

24 MR. OWENS: Mark 6.

25 (Whereupon, the referred-to documents were
29

1 marked as Plaintiff's Exhibit Number 6 for

2 Identification.)

3 BY MR. OWENS:

4 Q I'd like to show you a document that we've

5 marked as Exhibit 6.

6 While he's looking at that, do you own any part of

7 this company, Professional Air Services, LLC?

8 A No.

9 Q Where does your son live?

10 A In the Dominican Republic.

11 Q Does he have a house here?

12 A No.

13 Q Do you know what this company does,

14 Professional Air Services, LLC?

15 A I'm looking at this, just a second.

16 (Whereupon, the reporter read back the requested

17 portion of the transcript, and the proceedings resumed as

18 follows:)

19 THE WITNESS: It's a company that is my

20 son's and what it does is purchase and sell

21 planes and leases planes, that type of thing.

22 BY MR. OWENS:

23 Q Do you see the highlighted aircraft listed

24 on Exhibit 5, those registered with the FAA to

25 Professional Air Services, LLC?
30

1 A Yes. I see it there, yes.

2 Q Okay. And are any of those aircraft

3 aircraft that Servicios Aereos Profesionales, S.A.

4 has leased in the past?

5 A I believe there were two aircrafts of the

6 Jetstreams, but I'm not completely sure. Servicios

7 Aereos Profesionales is no longer operating because

8 of lack of payment, they weren't paid.

9 Q Who wasn't paid?

10 A Servicios did not pay whoever was leasing

11 them.

12 Q Servicios did not pay Professional Air

13 Services, LLC?

14 A The lease, and then it wasn't able to make

15 its payments.

16 Q Did Servicios Aereos Profesionales, S.A.

17 lease the Jetstreams from Professional Air Services?

18 A That's correct. Correct.

19 Q Did it lease either of the Learjets?

20 A No.

21 Q Did it lease the Beech B90?

22 A No.

23 Q Did it lease the Beech 1900C?

24 A Neither.

25 Q Have you ever held any position or title
31

1 with the company Professional Air Services, LLC?

2 A No.

3 Q Have you ever owned any part of that

4 company?

5 A No.

6 Q Have you ever owned any part of

7 Professional Aviation Group, LLC?

8 A No.

9 Q Do you know who owns that company?

10 A I believe it's my son.

11 Q And has Servicios Aereos Profesionales,

12 S.A. ever leased aircraft from Professional Aviation

13 Group?

14 A Perhaps yes, perhaps no. If you were to

15 show me a list because it's -- I've leased so many

16 planes because I didn't own planes that I can't tell

17 you. The last three years -- I've leased so many

18 planes the last three years, so I can't recall

19 unless you give me a list.

20 Q When you first became president of

21 Servicios Aereos Profesionales, how many aircraft

22 did the company own?

23 A I can't recall exactly the number of

24 aircraft.

25 Q Can you list -- go ahead.
32

1 A But we used to operate some planes that

2 were later discontinued in the Dominican Republic.

3 Did you bring the pictures?

4 There are some Lets planes, there were about ten

5 Lets planes. Some of those planes were -- belonged to

6 Servicios, but then there was a regulation in the Dominican

7 Republic that the planes needed to have -- the tass had to

8 be installed.

9 Q T-A-S-S?

10 A Yes. And the flight data computer had to

11 be installed and the voice recording needed to be

12 installed. Those four pieces of equipment cost more

13 to install than the planes -- then what the plane

14 cost, so that's why those planes were used for a

15 while until the engines and everything else expired.

16 Those planes are there parted out. These were the

17 planes that Servicios Aereos Profesionales would use

18 for internal flights, for most of the flights.

19 Q And so when did the company retire those

20 aircraft?

21 A About four years ago. About four years

22 ago.

23 Q What other planes did the company have

24 besides the ten Lets?

25 A The Short, the Twin Otter, and I believe
33

1 one or two Jetstreams.

2 Q What happened to the Twin Otter?

3 A The Twin Otter was lost because of a loan

4 that we had gotten in order to pay the attorneys in

5 New York, and a couple more things with them.

6 Q What did the attorneys in New York have to

7 do with this aircraft?

8 A They needed to be paid monies, so we got a

9 loan on the Twin Otter in order to pay the attorneys

10 their -- it was mortgaged.

11 Q The attorneys in the Embraer lawsuit?

12 A Yeah. Yes.

13 Q And that aircraft was repossessed?

14 A Correct.

15 Q What happened to the Jetstreams?

16 A Part of the planes were also lost because

17 of loans. In order to make the payment to Embraer

18 we paid 18 months of the Embraer. We paid almost

19 about $2 million on the Embraer in payments.

20 Q So what happened to the Jetstreams?

21 A The company wasn't able to pay the loan

22 from different companies, and for that reason the

23 planes were repossessed.

24 Q Do you recall who repossessed the

25 Jetstreams?
34

1 A Aerolineas, A-E-R-O-L-I-N-E-A-S, Santa

2 Domingo was one of the companies that repossessed

3 the Jetstreams because Aerolineas Santa Domingo,

4 together with all the planes they had, had flights,

5 and then there was a very big bill accrued. The

6 company couldn't pay it and the guarantees were

7 those planes.

8 Q So Aerolineas Santa Domingo repossessed

9 the aircraft?

10 A I believe two Jetstreams.

11 Q Were there any other Jetstreams owned by

12 the company?

13 A I think so. I believe there was one more

14 or so jets, or two more Jetstreams that belonged to

15 Aerolineas Santa Domingo.

16 Q They were leasing the planes to you?

17 A Now they're leasing planes so the company

18 can continue operating because otherwise they will

19 close -- close the company. I just have not wanted

20 to file bankruptcy for the company. In order to

21 close the company out, I close the company. But I

22 am not able to pay Embraer or anyone else. We keep

23 working just to see if at some point the company

24 will be able to recover.

25 Q Recover from what?
35

1 A To be closed to the bankruptcy where it is

2 at this time.

3 Q Did SAPSA own any other aircraft other

4 than the Lets, Twin Otter and Short?

5 A No.

6 Q What does the company own now besides the

7 Cessna and Embraer?

8 A Cessna and Embraer. That's the only thing

9 the company has, the Cessna and Embraer, and it does

10 not belong to us, it belongs to Cessna Finance. It

11 is under our name and it has two liens, one from

12 Cessna and another one from a private investor.

13 Q So there is no equity in the aircraft?

14 A Doesn't belong to me, it belongs to

15 Cessna.

16 Q Does the company lease the Cessna?

17 A It's the only thing the company has now,

18 and it's practically not operating anymore because

19 it is a single engine plane. It is a nine passenger

20 plane, but the company needs to have a plane in its

21 certificate otherwise the Dominican Republic will

22 close down the company. The only reason that that

23 plane is being paid for is so that Cessna will not

24 take it, and we're also behind in the payments.

25 We've been in default many times and then we pay
36

1 part and then we pay again, and --

2 Q Going back to this Professional Aviation

3 Group that is owned by your son, where is that

4 company organized?

5 A I really don't know exactly.

6 Q Let me show you a document that we marked

7 as Exhibit 7.

8 (Whereupon, the referred-to documents were

9 marked as Plaintiff's Exhibit Number 7 for

10 Identification.)

11 THE WITNESS: When you say organized, what

12 do you mean by organized?

13 BY MR. OWENS:

14 Q Incorporated.

15 A Oh, I don't know.

16 Q Do you know where it operates from?

17 A No.

18 Q Has the company, meaning Servicios Aereos

19 Profesionales, S.A., ever leased aircraft from that

20 company?

21 A Not that I recall.

22 Q You answered that after reviewing Exhibit

23 7?

24 A Which is Exhibit 7?

25 Q This (indicating).
37

1 A Oh. I don't think we leased one. I don't

2 remember a plane that they leased to us.

3 Q Do you know where this company's office

4 is?

5 A The company's office?

6 Q Professional Aviation Group, LLC?

7 A What address does it have there?

8 Q It does not have an address on it there.

9 A No.

10 Q You don't know?

11 A No. I'm not sure, I think it was in

12 Delaware or something, but I don't recall.

13 Q I'm asking about their office, not where

14 they were incorporated.

15 A I don't know.

16 Q Do you know where the office of

17 Professional Air Services, LLC is?

18 A No.

19 Q Do you know -- let me ask you this: Has

20 Servicios Aereos Profesionales, S.A. ever had an

21 office in the United States?

22 A At some point, yes, it had offices here.

23 Q When?

24 A Years ago it had an office in SheltAir,

25 Fort Lauderdale International until last year.
38

1 Q S-H-E-L-T, A-I-R.

2 A In SheltAir in the FBO of Hollywood

3 International.

4 Q Fort Lauderdale/Hollywood International?

5 A Yes. But it was not -- but not an office,

6 only a place where we received the parts and

7 mailings, no accounting or nothing like that.

8 Because the mail in Santa Domingo you lose the parts

9 and that type of thing, so the deliveries were made

10 to this office and then they would be sent to Santa

11 Domingo with someone who could take parts for us, or

12 through DHL or something like that.

13 Q Did Professional Services, LLC ever have

14 an office for the company at SheltAir?

15 A Well, I can't answer that. Perhaps they

16 used that address, but I didn't know about it. I

17 don't know if they used that address. We also

18 shared the rent with another company called Trim

19 Air, and at the end Trim Air kept the office because

20 we couldn't pay for it.

21 Q Did Servicios Aereos Profesionales ever

22 share office space with Professional Aviation Group?

23 A Perhaps, but not as their office, perhaps

24 they had a mailing address there. Not as an office.

25 Q Have you ever heard of a company called
39

1 SAP, Inc.?

2 A Yes.

3 Q What is that company?

4 A It's a charter company, an airline 135 and

5 it's U.S.

6 Q So is that the same thing as Servicios

7 Aereos Profesionales, Inc.?

8 A Would you repeat the question? What was

9 the previous question?

10 Q The previous question was SAP, Inc. --

11 A Yes, it's the same, Servicios Aereos

12 Profesionales, Inc.

13 Q So there is not a separate company SAP,

14 Inc.?

15 A Servicios Aereos Profesionales, Inc. is

16 the same company as SAP, Inc.

17 Q Where is that company incorporated?

18 A That company used to be or was

19 incorporated in Puerto Rico, and now it's being

20 incorporated here in Miami.

21 Q I want to go back to Professional Aviation

22 Group, LLC. Have you ever held a position with that

23 company?

24 A I don't recall having held any position

25 with that company.
40

1 Q Have you ever owned any part of that

2 company?

3 A No.

4 Q Have you ever owned any part of SAP, Inc.?

5 A Yes, we've been owners of SAP, Inc.

6 Q Who is we?

7 A My wife and I.

8 Q You own 100 percent of the stock?

9 A No, we're -- I don't recall exactly what

10 the percentage is.

11 Q Do you own a majority of the stock?

12 A Probably, yes, in that one.

13 Q Who are the other stockholders? If you

14 don't know just say you don't know.

15 A I don't recall.

16 Q Okay. Is that company in operation now?

17 A Yes, that company is in operation.

18 Q What does that company do?

19 A Charters.

20 Q Where is it based?

21 A That company is based in Puerto Rico, and

22 now we're -- it is going to be based here in Fort

23 Lauderdale.

24 Q At SheltAir?

25 A No.
41

1 Q Where?

2 A The executive airport.

3 Q Does that company own any aircraft?

4 A No.

5 Q So the Dominican Air Lines, Servicios

6 Aereos Profesionales, S.A., has never leased

7 aircraft from that company?

8 A Could you ask that again? I didn't

9 understand that.

10 Q Has Servicios Aereos Profesionales ever

11 leased aircraft from SAP, Inc.?

12 A On some occasions, yes.

13 Q What aircraft was that?

14 A I think it was a 1900.

15 Q And SAP, Inc. no longer owns that

16 aircraft?

17 A No.

18 Q What happened to the aircraft?

19 A It was delivered to Beechcraft.

20 Q Repossessed?

21 A Repossessed.

22 Q Do you recall SAP, Inc. ever owning a

23 Hawker Siddeley 125?

24 A Yes. Yes, I think one Hawker.

25 Q Where is that aircraft now?
42

1 A That aircraft hasn't moved from the

2 Dominican Republic in the past three years, it has

3 inspections that have not been -- have not taken

4 place.

5 Q So SAP, Inc. owns that aircraft?

6 A Yes. That plane is still being paid for.

7 And we're in default and the plane hasn't moved for

8 three years in Santa Domingo.

9 Q Have you ever heard of a company named SAP

10 Express?

11 A SAP Express? It's a company in Santa

12 Domingo that leased planes, isn't that SAP Express?

13 Yes, in Santa Domingo.

14 Q It leased aircraft to?

15 A To whoever.

16 Q Including Servicios Aereos Profesionales,

17 S.A.?

18 A Yes, some time ago. That company is no

19 longer operational, it hasn't been for the past two

20 years.

21 Q Did you ever own any part of that company?

22 A I don't think so.

23 Q Did you ever hold a position with that

24 company?

25 A No, I don't think so.
43

1 Q Do you hold a position with Air Santa

2 Domingo?

3 A Yes.

4 Q What is your position?

5 A Vice president of Air Santa Domingo.

6 Q Who is the president?

7 A It is a gentleman by the name of Henry

8 Azar.

9 Q Does he have any relation to Marisol Azar?

10 A Marisol is the wife.

11 Q And you and your wife own stock in Air

12 Santa Domingo?

13 A We own stock in Air Santa Domingo.

14 Q Do you own a majority of the stock?

15 A No, I don't think so.

16 Q Does your son Jose Miguel Patin have an

17 additional name?

18 A What -- when you say additional, what do

19 you mean by additional?

20 Q Well, as I understand it, you have a

21 suffix Escusio (sic)?

22 A I didn't understand that.

23 MR. CERVERA: Eusebio.

24 THE WITNESS: Eusebio, okay. My son's

25 name is Jose Miguel Patin Hernandez because his
44

1 mother's last name is Hernandez. These are

2 coincidences. My father was Hernandez and he

3 is also Hernandez, but they have nothing to do

4 -- they're not the same.

5 MR. OWENS: Mark 8.

6 (Whereupon, the referred-to documents were

7 marked as Plaintiff's Exhibit Number 8 for

8 Identification.)

9 BY MR. OWENS:

10 Q I'd like to show you a document we've

11 marked as Exhibit 8. And I'm going to ask you about

12 the two pages that have tabs on them. My question

13 is, are those your signatures on the last page and

14 on the two pages up from the last page?

15 A That's my signature.

16 Q And that's on page 23 of 25? At the

17 bottom you see page 23 of 25.

18 A The page 23, that's my signature -- my

19 signature, yes, and this is my signature, also.

20 Q On 25?

21 A 25, yes.

22 Q And is your signature -- I'm sorry, let me

23 get to that one page. And your signature is, again,

24 on page 15?

25 A Yep, that's my signature.
45

1 Q Okay. I'd like to show you documents

2 we've marked as Exhibits 9 and 10.

3 (Whereupon, the referred-to documents were

4 marked as Plaintiff's Exhibit Numbers 9 and 10 for

5 Identification.)

6 BY MR. OWENS:

7 Q I'd like you to look at Exhibits 9 and 10

8 and tell me if you recognize the signature on those?

9 A All I know is that they're not mine.

10 Q Do you know whose they are?

11 A May I ask my wife something?

12 Q Sure.

13 A Let me see. Let me see. Both signatures

14 look quite different than this one like this.

15 Q Want to say it in Spanish?

16 A It seems that the signatures have slight

17 differences, but they look like my son's, but I

18 would not be able to guaranty that.

19 Q Have you heard of a company called Orlando

20 Air Link?

21 A Yes.

22 Q What is that company?

23 A That's been closed by the FAA already.

24 Q What kind of company was it?

25 A I believe it was a company that had been
46

1 purchased for charter purchases.

2 Q Why did the FAA close it?

3 A It did not comply with the FAA

4 requirements.

5 Q Did it actually have a certificate at one

6 time?

7 A It had a certificate for a while and then

8 they were going to take away the certificate -- they

9 wanted to take away the certificate. The

10 certificate had been suspended.

11 Q The company is closed now?

12 A Yes.

13 Q Did SAPSA ever lease any aircraft from

14 Orlando Air Link?

15 A No, not that I recall.

16 Q Did --

17 A I believe that company never owned

18 aircraft.

19 Q Do you know Wayne Hazelwood?

20 A Sure.

21 Q What does he do?

22 A He's the owner of Trim Air, to my

23 understanding.

24 Q What kind of business is that?

25 A Charter, aircraft lease throughout the
47

1 whole United States.

2 Q Has Servicios Aereos Profesionales, S.A.

3 ever leased aircraft from that company?

4 A I believe at some point for a charter --

5 for a charter or something like that, because it's a

6 charter company, so at some point --

7 Q How many times?

8 A Five, six times, but in a seven or eight

9 year period.

10 Q Okay.

11 A I don't recall exactly.

12 Q Have you ever owned any part of that

13 company?

14 A No.

15 Q I'm going to show you documents we marked

16 as Exhibits 11 and 12.

17 (Whereupon, the referred-to documents were

18 marked as Plaintiff's Exhibits Number 11 and 12 for

19 Identification.)

20 BY MR. OWENS:

21 Q I'd like you to look at those two

22 documents and tell me if your signature is on those

23 two documents.

24 A May I ask my wife a question?

25
48

1 Q Sure.

2 A What does this have to do with Trim Air?

3 Q I didn't ask about Trim Air.

4 A Okay.

5 Q My question is --

6 A The thing is that you were asking me -- so

7 we were talking about the office and then you give

8 me these documents, so I thought they were related

9 to the previous question.

10 Q No.

11 A Okay. These were two certificates that we

12 had in the bank, and they do recognize that. We

13 used them as lines of credit. We used those monies

14 to pay for the fuel and our bills and our things,

15 because sometimes we didn't have the money and some

16 of the other bank's checks would be returned. So we

17 had this C.D. in order to get a line of credit, and

18 it was used through the years. It was finally used

19 in fuel and payments.

20 Q You signed as Jose M. Patin, aka, Jose

21 Miguel Patin Hernandez, correct?

22 A No, I signed here as Jose Miguel Patin

23 president of Servicios Aereos Profesionales company.

24 Q Do you know why it says also known as Jose

25 --
49

1 A No, no.

2 Q You don't know why it has Hernandez after

3 your name?

4 A Surely because my father used to be the

5 previous president of the company and he had the

6 same name, but my father's last name was Hernandez.

7 Q So it is a mistake then?

8 A Yes. I signed here as Jose M. Patin and

9 president of Servicios Aereos Profesionales at that

10 time when my father was already deceased.

11 Q Okay. So the signature -- your signature

12 appears at the last page of each of Exhibits 12 and

13 13 -- 11 and 12?

14 A Correct, and correct.

15 Q I'd like to show you document that we are

16 marking as Exhibit 13.

17 (Whereupon, the referred-to documents were

18 marked as Plaintiff's Exhibit Number 13 for

19 Identification.)

20 BY MR. OWENS:

21 Q Do you recognize that signature on that

22 document?

23 A It says Jose Patin, but that is not my

24 signature.

25 Q Do you recognize the signature?
50

1 A No.

2 Q Have you ever heard of a company that's

3 referred to itself as the SAP Group?

4 A SAP Group?

5 Q Yes, it's in Santa Domingo. What is that

6 entity?

7 A It's a group of companies of the FASAP

8 company.

9 Q Owned by the SAP company?

10 A I don't understand your question.

11 Q Is SAP Group a legal entity?

12 A I don't think so. I think it was just

13 given that name. I don't think it is a legal

14 entity.

15 Q Who gave it that name?

16 A In Santa Domingo our attorneys -- it's not

17 a company, it's a commercial name, business name, a

18 corporation.

19 Q Are these companies that work together?

20 A No.

21 Q The companies don't work together?

22 A No.

23 Q Why is it called SAP Group?

24 A Because we look like it is a -- because

25 there you call group -- many times you use the word
51

1 group when you have different companies and so on.

2 Q These companies are unrelated to each

3 other?

4 A No, no.

5 Q Let me ask that question again. Do these

6 companies under the SAP Group have any relation with

7 each other?

8 A No, no relation.

9 Q They don't do business together?

10 A SAP Group, no.

11 Q All of the entities under the SAP Group

12 are completely separate?

13 A It's completely separate.

14 Q And you don't do business with each other?

15 A No.

16 Q Did you have anything to do with creating

17 the website for SAP Group?

18 A No, basically that's something commercial

19 for your advertising. SAP Group is like a broker as

20 if it were a broker.

21 Q Tell me what business SAP Group is in?

22 A I cannot tell you, it's only a commercial

23 entity, it's a commercial name.

24 Q Well, I thought you said that it acts as a

25 broker.
52

1 A No, basically it's a commercial entity.

2 Q And what does the commercial entity do?

3 A Nothing. Commercially, nothing, that I

4 recall.

5 Q Did you have any involvement in creating

6 the use of that name?

7 A No.

8 Q Have you ever used that name?

9 A No.

10 Q Have you ever read the website of SAP

11 Group?

12 A No.

13 Q Have you ever read the website of SA Air?

14 A SA? Yes.

15 Q Is the information on that website

16 accurate?

17 A I haven't seen it for quite a while.

18 Q When was the last time you saw it?

19 A Some time ago, I'm really not very good

20 with computers, that's why.

21 Q But how long ago?

22 A Perhaps when it was being designed a year

23 ago, two years ago. I understand that that keeps

24 being modified regularly by people that know about

25 websites.
53

1 Q When you were president did you have any

2 involvement in the modifications of that website?

3 A No.

4 Q When you looked at it did you determine

5 that the information on the website was correct?

6 A Basically I don't know if it was correct

7 or not, if I was looking for something it was

8 something in the commercial aspect.

9 Q Who at the company was in charge of

10 ensuring that the information on the website was

11 correct?

12 A It's a company that you pay so they will

13 do something that is commercial, marketable, pretty,

14 attracts attention.

15 Q Who at Servicios Aereos Profesionales,

16 S.A. was in charge of ensuring that the information

17 on the website was correct?

18 A I don't know.

19 Q No?

20 A I don't know. That was basically with --

21 that was just for commercial criteria, commercial

22 purposes, commercial effect.

23 Q It was advertising?

24 A Advertising.

25 Q Who was in charge of designing the website
54

1 from the SAP Group?

2 A A company in the Dominican Republic, the

3 company that does that type of thing. They were

4 paid. They would take pictures of planes, some were

5 ours and others were not, the planes that were there

6 in the company that we had leased. And they would

7 even use helicopter signs and the company does not

8 have helicopters. They mention medical emergencies,

9 but we don't have medical emergencies. But if a

10 plane was leased from the U.S. it could come and a

11 service could be provided, that was the purpose of

12 the website.

13 Q Who on the part of the SAP entities gave

14 the information to the website design company?

15 A Perhaps the marketing department, the

16 commercial department.

17 Q What is the marketing department?

18 A We have two employees in the commercial

19 department.

20 Q Who are they?

21 A Could I ask her for the name?

22 Q You don't know the name?

23 A Mr. Harold, he's German, he's the one in

24 charge of the marketing department.

25 Q What is his full name?
55

1 A Harold Heyer.

2 Q Spell it, please.

3 MRS. HERNANDEZ: May I say?

4 MR. OWENS: Sure.

5 MRS. HERNANDEZ: H-E-I -- H-E-Y-E-R,

6 Heyer.

7 BY MR. OWENS:

8 Q And who sells in the department?

9 A Second category employees that they visit

10 clients.

11 Q What's their names?

12 A Geraldo, Paulino.

13 Q So between these two people they were in

14 charge of designing the website.

15 A Yeah, take the photographs. My

16 understanding was that they hired people to go to

17 the planes, take photographs of the planes and that

18 type of thing. Planes that we leased and

19 helicopters that we had the possibility of leasing,

20 also for medical emergencies, medical services from

21 the U.S. We went to different websites that we had

22 seen and -- they went to different websites they had

23 seen and got something similar out of that.

24 Q I'd like to show you a document we've

25 marked as Exhibit 14.
56

1 (Whereupon, the referred-to documents were

2 marked as Plaintiff's Exhibit Number 14 for

3 Identification.)

4 THE WITNESS: Yes, this is exactly what

5 I'm saying. People who were hired to take

6 pictures of the planes and whatever.

7 BY MR. OWENS:

8 Q I'd like you to look at Exhibit 14 and

9 tell me if the first sentence is correct?

10 A Which is the first sentence?

11 Q Where it says the SAP Group is formed.

12 A That is not correct.

13 Q What is incorrect about it?

14 A It's not formed by any of those groups, it

15 is just a commercial name.

16 Q Is the second sentence correct?

17 A Let's look at it. It's not correct

18 either.

19 Q Why not?

20 A My understanding is that the SAP Group --

21 please interpret this for me.

22 Q Would you read the second sentence

23 beginning with our commitment?

24 (Whereupon, the interpreter interpreted the above

25 sentence from English to Spanish.)
57

1 THE WITNESS: SAP Group does not exist

2 since 1991.

3 BY MR. OWENS:

4 Q Servicios Aereos Profesionales, S.A. has

5 existed since 1981, correct?

6 A That's correct, but not SAP, not SAP

7 Group.

8 Q And I'd like you to translate the last

9 sentence there beginning with based in Santa

10 Domingo.

11 (Whereupon, the interpreter interpreted the above

12 requested portion of the transcript from English to

13 Spanish.)

14 THE WITNESS: That's something commercial,

15 many companies use that when they have people

16 that they work with in Puerto Rico or here or

17 in Venezuela. That is commercial, commercial

18 strategy.

19 BY PLAINTIFF'S ATTORNEY 1:

20 Q Was SAP, Inc. based in the Dominican

21 Republic?

22 A It was based in Puerto Rico.

23 Q So when that last sentence referred to a

24 branch in San Juan, it is referring to SAP, Inc.?

25 A Whatever I can use in Puerto Rico -- any
58

1 entity I can use in Puerto Rico, just like any

2 entity that I could use here in Miami or Central

3 America or in Panama.

4 Q It also says that you have a base in Fort

5 Lauderdale, which company had a base in Fort

6 Lauderdale -- a branch in Fort Lauderdale? Let me

7 say that again.

8 It also said that a branch in located in Fort

9 Lauderdale, which company had a branch in Fort Lauderdale?

10 A Servicios Aereos Profesionales, Inc. is

11 now moving to Fort Lauderdale from San Juan, it's

12 moving here for commercial purposes.

13 Q It has been in the website for over a

14 year.

15 A Commercial purposes.

16 Q So there is --

17 A If I have someone that wants to call me

18 and I tell them I'm only based in Puerto Rico, how

19 do I get any flights here in Florida? What I do is

20 I can do some sort of advertising and then you lease

21 a plane -- I lease a plane here and then you just

22 make a small commission.

23 Q So Servicios Aereos Profesionales --

24 A The same thing I do if I'm in Panama, they

25 call me from Panama. I have companies in Panama and
59

1 help -- if there is a medical emergency here or an

2 individual that is sick here, I call a medical

3 company in Miami just to rent an airplane. That's

4 basically commercial purposes.

5 Q So for commercial purposes Servicios

6 Aereos Profesionales, S.A. said they had branches in

7 San Juan and Fort Lauderdale?

8 A Not for commercial purposes, I would lease

9 a plane so it would provide, or rent a plane to

10 provide that service.

11 Q Were those locations --

12 A Same thing I could say flights to Europe.

13 Q You didn't say that, did you, it only says

14 Fort Lauderdale and --

15 A Because it's very difficult for you to

16 find someone that is going to rent a plane from here

17 to Europe. I have to look for it, the needs of the

18 continent where I work in. It even mentioned

19 Central America and all that.

20 THE INTERPRETER: Excuse me, can we take a

21 break, a short break, whenever you're ready.

22 MR. OWENS: Now is fine.

23 (Whereupon, a short recess was had and the

24 proceedings resumed as follows.)

25
60

1 BY MR. OWENS:

2 Q I'd like you to look at this document

3 marked as Exhibit 15, and it says in there that

4 Servicios Aereos Profesionales, S.A. obtained

5 authorization to fly to the United States. Is that

6 correct?

7 A Yes, I recognize it.

8 Q Is that correct?

9 A Yeah, that's correct.

10 (Whereupon, the referred-to documents were

11 marked as Plaintiff's Exhibit Number 15 for

12 Identification.)

13 BY MR. OWENS:

14 Q And that was under the Dominican Republic

15 certificate?

16 A Until six months ago all the companies in

17 the Dominican Republic, none of them could fly here

18 to the U.S., that started about ten years ago until

19 about six, seven months ago. The Dominican aviation

20 was a category three, you couldn't fly here to

21 anywhere in the U.S.

22 Then the Dominican Republic acquired a category

23 two to be -- in order to be able to fly, then after that the

24 companies needed to be recertified after that. The

25 procedure took four or five months, which was a trial period
61

1 with supervision. And then the company was granted

2 permission to be able to fly to the U.S.

3 We are not flying because we do not have the

4 appropriate plane for that, and it costs a lot of money to

5 operate in the Dominican Republic with planes that are

6 leased and the taxes or the duties that need to be paid for,

7 so normally we do not fly to the U.S.

8 Q When did this authorization to fly to the

9 U.S. occur, did you say six months ago?

10 A To fly to the U.S. they changed categories

11 approximately about nine months ago, nine months or

12 ten months, so then for us to be granted permission

13 to be able to fly for the company to be able to fly

14 it's been about six, seven months.

15 Q When you say Dominican Republic aircraft

16 could not fly to the United States, we're talking

17 about in an air carrier capacity?

18 A No, no type of commercial activity, none.

19 Q But you could fly the plane here for

20 maintenance?

21 A Yes, maintenance.

22 Q And for your personal use?

23 A Private use? I don't use my planes for

24 private use. I do not use company planes for

25 personal use, in that case I use airlines. And the
62

1 planes that can come here that are not SAPs come for

2 maintenance, some type of maintenance that cannot be

3 done in the Dominican Republic.

4 Q Do SAP aircrafts regularly fly into Fort

5 Lauderdale International Airport?

6 A SAP basically does not have any aircraft,

7 it has leased aircraft.

8 Q Does -- do SAP leased aircraft fly

9 regularly into Fort Lauderdale?

10 A Regularly, no, just when -- it flies in

11 when it comes for maintenance or something like

12 that, some big maintenance or big inspections.

13 Q So if I went to SheltAir and asked how

14 often SAP aircraft come in, they would tell me not

15 often?

16 A No, of course, not often, when they come

17 here for maintenance.

18 Q Do they go to Fort Lauderdale for

19 maintenance?

20 A Fort Lauderdale is the official entry, and

21 then from there the plane flies to the different

22 shops here to Miami or where there is a maintenance

23 center, or different places or something that

24 belongs to avionics.

25 Q Is that a company?
63

1 A No, different companies in avionics. If

2 the company has a maintenance problem that cannot be

3 done there.

4 Q I'd like you to look at the document we've

5 marked as Exhibit 16.

6 A Yes.

7 (Whereupon, the referred-to documents were

8 marked as Plaintiff's Exhibit Number 16 for

9 Identification.)

10 BY MR. OWENS:

11 Q Do you know who owns the Learjet 35?

12 A It's financed.

13 May I ask her something?

14 Q Sure.

15 THE WITNESS: Who's under -- whose name is

16 this 35? It's being operated by Servicios

17 Aereos Profesionales, Inc?

18 MRS. HERNANDEZ: I don't exactly -- I

19 don't recall.

20 BY MR. OWENS:

21 Q Who owns that aircraft? Do you recall who

22 owns it?

23 A I believe one of the other companies that

24 you mentioned.

25 Q And Servicios Aereos Profesionales, S.A.
64

1 leases the aircraft to operate it?

2 A No, not Servicios Aereos Profesionales,

3 S.A.

4 Q SAP, Inc. does?

5 A Inc. is operating.

6 Q Who operates the Learjet 25.

7 A No one. No one.

8 Q None of the SAP Group entities?

9 A No.

10 Q Who operates the Hawker 125?

11 A No, no, it's grounded for four years.

12 Q There is a Jetstream showing on the top of

13 the second page. Would you look at that?

14 A I saw it.

15 Q Who operates that aircraft?

16 A It's leased by SAPSA. It's a lease.

17 Q Who owns that aircraft?

18 A I cannot see the registration here.

19 Q How many Jetstreams does Servicios Aereos

20 Profesionales, S.A. lease?

21 A There is about three planes.

22 Q What aircraft are those?

23 A Jetstreams -- I don't recall. I don't

24 recall what the number is.

25 Q Do these --
65

1 A I don't recall the number.

2 Q Are they registered in the U.S.?

3 A No, no, no. They're all HI, Dominican

4 planes.

5 Q Who owns those planes?

6 A Some airlines, the ones I already

7 mentioned before, and others of Air Santa Domingo.

8 Q Do those aircraft have on the side of them

9 SAPAIR.com?

10 A Yes. That's advertising. All the planes

11 right now, even the European planes that you lease

12 have their website up so people will call. That's

13 marketing that's used now.

14 Q What operates the Beechcraft 1900C shown

15 on the second page?

16 A The lease is operated by SAP -- rented.

17 Q SA or Inc.?

18 A SAP. It was in Inc., but this plane is

19 not being used right now because it's out of the --

20 it's outside of Inc's certificate. It's not in

21 Inc's certificate.

22 Q It's not on their operating authority?

23 A No, it stopped.

24 Q It was but it seized, is that correct?

25 A It seized, yes. That plane is U.S.
66

1 registration, November.

2 Q Is SAP -- I'm sorry, Servicios Aereos

3 Profesionales, S.A. allowed to operate registered

4 aircraft in its chartered operations?

5 A SAP?

6 Q SAP,S.A.?

7 A It's not permitted to operate in November

8 in U.S. registration.

9 Q So SAP, S.A. can only operate HI

10 registered aircraft?

11 A Yes. And it could lease or it could

12 rent -- not lease, rent. It could rent any aircraft

13 from anywhere, not just November. You have an

14 aircraft here that belongs to a company and I can

15 rent it from you so it will provide the service, but

16 I cannot operate it. There you operate as a broker

17 and you make a small commission.

18 Q So it's a wet lease?

19 A No, it's not a wet lease -- no, it's not a

20 wet lease and it's not a dry lease either.

21 Q Okay.

22 A It's rent.

23 Q Who operates the Short 360 shown on the

24 website on the second page?

25 A It's Dominican registration and Servicios
67

1 Aereos Profesionales rents it.

2 Q SAP, S.A., correct?

3 A Yes.

4 Q Who operates the De Havila Twin Otter DHC 6

5 shown on the website?

6 A Same thing.

7 Q Same as with the Short?

8 A It represents it from other companies,

9 yes.

10 Q And the Cessna Grand Caravan shown on the

11 second page, that is the one leased by Cessna?

12 A Yes.

13 Q Or is it leased by Cessna to SAP, S.A., or

14 is it sold to SAP, S.A. with a lien on it?

15 A It's sold by -- it's sold to SA and it has

16 two liens, one by Cessna and another one by a

17 businessman over there that loaned some money to pay

18 for the plane when the airplane was in default.

19 Q What is that fellow's name?

20 A It was a bank.

21 Q What is the name of the bank?

22 A I forgot. I have the information, but I

23 forgot the name.

24 Q Where do you have the information?

25 A The company has it in the Dominican
68

1 Republic.

2 Q At the very bottom of the second page it

3 shows a Let Aircraft, who operates that aircraft?

4 A As I told you, those aircraft are no

5 longer operating in the Dominican Republic. It's

6 over there, but it is no longer operating because

7 they did not have the appropriate equipment to

8 continue operating the planes. That's for

9 commercial use, that is why it is here. Someone

10 requested a Let from the company, specifically a

11 Let. There is a company there that you can -- where

12 you can rent it. Not there, but the company can

13 rent it from Haiti where they have them.

14 Q Tropical Airways?

15 A Could be Tropical -- no, Tropical doesn't

16 have those planes. Caribe Inter is the one that has

17 the planes there. I already mentioned that company,

18 and other companies.

19 Q Does SAP lease its Lets to anybody?

20 A I didn't understand your question.

21 Q SAP, S.A. has Lets, correct?

22 A No, SAP no longer has Lets.

23 Q They were parted out? SAP, S.A. no longer

24 has the parts?

25 A No, we even left more than eight planes in
69

1 the old airport, and that's where they are, four

2 years ago. And there is two other planes of those

3 that have been abandoned in Higuero, that airport.

4 They can no longer operate.

5 Q Did you say the planes are junk?

6 A Yeah, junk. Even the wings and the tail

7 have been removed. Because they had to be removed

8 from there and dumped somewhere else because that

9 land no longer belongs to an airport or anything,

10 but I've been allowed to keep it there.

11 Q Okay.

12 A The tail, the engines, everything has been

13 removed in order to be able to move it -- to move it

14 down the street to go dump it someplace to a

15 chopper.

16 Q Who operates the Cessna 172 shown on the

17 last page?

18 A That aircraft, I believe it is not being

19 operated.

20 Q Who else --

21 A Would you allow me to ask a question?

22 Q Sure.

23 THE WITNESS: The 172 is under whose name?

24 MRS. HERNANDEZ: I don't know.

25 THE WITNESS: I think Air Santa Domingo, I
70

1 think.

2 BY MR. OWENS:

3 Q Who operates the Bell Jet Ranger?

4 A That's not being operated, that is not a

5 commercial plane.

6 Q Who owns it?

7 A I believe that one of the companies that

8 you mentioned before, I don't know which one,

9 Professional Group or one of those. Those are

10 private planes, all we do there is just keep the

11 planes and someone pays us a small rent for keeping

12 the planes. We have advertising when someone calls

13 for a helicopter, which is a rare occasion, we call

14 a company that has been approved for flying

15 helicopters so that they will conduct this flight

16 for us. It's a large helicopter company there that

17 does all the helicopter flights.

18 Q Is there a Jetstream in SAP colors with a

19 N number of N972JX?

20 A Jetstream 972, no.

21 Q Owned by Wells Fargo and leased to Trident

22 Aviation Leasing Services?

23 A No.

24 Q You don't know of that plane?

25 A No, no. May I ask a question?
71

1 Q Sure.

2 A Would you repeat the question?

3 (Whereupon, the reporter read back the requested

4 portion of the transcript, and the proceedings resumed as

5 follows:)

6 BY MR. OWENS:

7 Q Do you know of a Jetstream that is owned

8 by Wells Fargo as owner/trustee for Trident Aviation

9 Leasing Services Ireland Limited?

10 A That was a promise to purchase this plane,

11 but it has not been carried through. The plane is

12 parted out at the Tamiami Airport.

13 Q Who was going to purchase it?

14 A It was purchased probably by Servicios

15 Aereos Profesionales, S.A., but it hasn't had the

16 means to purchase it. It's there parked in Tamiami

17 almost parted out.

18 Q So SAPSA never closed on the aircraft?

19 A No, it was just intended to purchase.

20 Q I'd like you to look at Exhibit 17.

21 (Whereupon, the referred-to documents were

22 marked as Plaintiff's Exhibit Number 17 for

23 Identification.)

24 BY MR. OWENS:

25 Q Particularly the card, not the information
72

1 above it.

2 Do you recognize that as your business card?

3 A Yes.

4 Q Do you still use that business card?

5 A No, because I have been -- everything that

6 is Servicios Aereos has been taken away from me.

7 I'm not the president. I cannot use a card as a

8 president, I'm no longer a president.

9 Q But you were up until December, correct,

10 the president?

11 A Until mid-December.

12 Q And that was your business card until the

13 middle of December?

14 A Yes.

15 Q I'd like to show you a document that has

16 been marked at Exhibit 18.

17 (Whereupon, the referred-to documents were

18 marked as Plaintiff's Exhibit Number 18 for

19 Identification.)

20 BY MR. OWENS:

21 Q Do you recognize that?

22 A I recognize it, that used be -- used to be

23 the company's office, our office.

24 Q Did the company have any employees there?

25 A No.
73

1 Q Did Wayne Hazelwood act on your behalf?

2 A That's practically his, all we did there

3 was receive parts and we would share the rent.

4 Q Until when?

5 A Until the contract expires. Now there is

6 a new contract.

7 Q When?

8 A In December.

9 Q There is a new contract?

10 A Yeah.

11 Q To do what?

12 A Ask him.

13 Q Okay.

14 A Whatever he's been doing. If you were to

15 examine this, this card has a different address from

16 this one. This one is Suite 327 and this one is

17 Suite 13 (indicating).

18 Q Well, were you at one time at Suite 327?

19 A Four years ago.

20 Q Okay. Would you take a look at Exhibit

21 19, please.

22 A Yes.

23 (Whereupon, the referred-to documents were

24 marked as Plaintiff's Exhibit Number 19 for

25 Identification.)
74

1 BY MR. OWENS:

2 Q My question is, tell me whether SAPSA

3 still owns the aircraft?

4 A May I -- I can ask her?

5 Q Sure.

6 A The question again?

7 Q Let's ask this question: Did SAPSA own

8 those aircrafts in June of 2008?

9 A June 2008 SAPSA owned 7 of 624, it still

10 owns Embraer 720, and it still owns -- 720 is

11 Embraer's plane, and the other plane, the 760 is the

12 Cessna 207. The other planes are at the old

13 airport, the Herrera H-E-R-R-E-R-A, Airport parted

14 out.

15 Q In June of 2008 SAPSA owned HI 658,

16 correct?

17 A 658, yes, in June, and that plane has been

18 parted out in Hererra parked there for ten years at

19 that airport. The airport is closed and there is no

20 way to take it -- there is no way of getting it out.

21 Q That is not the same as the Short 360?

22 A That was not the Short 360, because there

23 were two Short 360s. That aircraft is parked and

24 it's destroyed by a hurricane, that one.

25 Q Okay.
75

1 A The others that you mentioned are the Lets

2 planes that are parked there, they're old.

3 Q I marked that wrong -- this is Exhibit 20,

4 so let me correct that.

5 Do you recognize the sign in Exhibit 18?

6 A Yes, I recognize that.

7 Q It's the sign of SAP, S.A. until December?

8 A Until December, until mid-December when

9 the contract expired.

10 Q The contract with Trim Air Charter?

11 A No, with SheltAir.

12 (Whereupon, the referred-to documents were

13 marked as Plaintiff's Exhibit Number 18 for

14 Identification.)

15 BY MR. OWENS:

16 Q And that was on the door of SAP, S.A.'s

17 office at SheltAir?

18 A In SheltAir.

19 Q Are you familiar with the company or a

20 group known as PAS Group?

21 A Let me ask her a question, I don't recall

22 this.

23 THE WITNESS: What is that, PAS Group? I

24 think this is a commercial page for PAS Group.

25 I don't recognize that. I don't recognize
76

1 that.

2 BY MR. OWENS:

3 Q Do you have an e-mail address at

4 SAPAIR.com?

5 A Me, no, no. Not me, the company does.

6 Q Well, when you say the company, you're

7 referring to who?

8 A SAPAIR.com, that's an e-mail for the

9 company.

10 Q Well, that's a website?

11 A Yes, could be.

12 Q Do you have an e-mail address at

13 SAPAIR.com?

14 A If I have an e-mail address in SAPAIR?

15 Q Correct.

16 A Yes, I had one, but I don't use it because

17 I'm not -- I have -- I'm not good with computers.

18 Q What is your e-mail address?

19 A JMPatin@SAPair.com.

20 Q JMPatin?

21 A Yeah.

22 Q Who is J.Patin@SAPAIR.com?

23 MR. CERVERA: Objection to the

24 translation. Could you repeat the term again,

25 I think there was one letter that was
77

1 misspelled.

2 THE WITNESS: I don't know who that is.

3 BY MR. OWENS:

4 Q You notice that in Exhibit 20 it says at

5 the top that the PAS Group is at the Joaquin

6 Balaguer International Airport?

7 A That's what airport -- the airport moved.

8 We were in Hererra four years ago and then that

9 airport was closed and we moved to this one, this is

10 Higuero.

11 Q Do your son's businesses, Professional

12 Aircraft Services and Professional Aviation Group do

13 business in Santa Domingo?

14 A Yes, I think they do business both here

15 and in Santa Domingo.

16 Q Do they have an office at the airport?

17 A If they have an office there in the

18 airport? I don't think so, not that I know of.

19 Q What business do they do in Santa Domingo?

20 A Negotiate with aircraft, someone that

21 needs aircraft in the U.S.

22 THE WITNESS: Do you think we can get more

23 water, please?

24 MR. OWENS: Sure.

25 (Whereupon, a brief recess was had and the
78

1 proceedings resumed as follows:)

2 BY MR. OWENS:

3 Q I'd like to show you a document that we

4 marked as Exhibit 21.

5 (Whereupon, the referred-to documents were

6 marked as Plaintiff's Exhibit Number 21 for

7 Identification.)

8 BY MR. OWENS:

9 Q I'm going to ask you questions about the

10 tabbed pages.

11 A Okay.

12 Q I'd like you to go through that list of

13 stockholders for SAP, S.A. and tell me which, if

14 any, of them still owns stock, to your knowledge?

15 Now I'm referring to Exhibit 1.

16 A This one?

17 Q Exhibit 1 which is contained within

18 Exhibit 21 to this depo.

19 MR. CERVERA: I take it you're asking the

20 witness to read from a document that he hasn't

21 identified as having seen before, and you're

22 asking him about the information contained on

23 the page as to whether or not the names there

24 are still shareholders -- names of the

25 shareholders of a particular corporation?
79

1 MR. OWENS: This is a petition filed by

2 SAP, S.A.

3 MR. CERVERA: The witness hasn't been

4 asked to identify the exhibit.

5 MR. OWENS: I'll start off with that.

6 BY MR. OWENS:

7 Q Do you recognize the exhibit, 21?

8 A I haven't seen this before. This was

9 prepared by our aviation consultant in Puerto

10 Rico -- the company's aviation consultant Mr. Luis

11 Irizarry, aviation consultant. I think that is in

12 1997.

13 Q Who is Pura Eusebio?

14 A It's my mother.

15 Q Does she still own stock in the company?

16 A Yes, I think she still owns some stock in

17 the company.

18 Q Does Laura Rosa Patin own stock in the

19 company?

20 A I think so. I think so.

21 Q Do you have a relationship with Laura, a

22 family relationship?

23 A Yeah, that's my sister.

24 Q And Marisol Hernandez is the same as

25 Marisol Azar?
80

1 A Yes.

2 Q Who is Jose Antonio Patin?

3 A He's not in the company.

4 Q Who is that person?

5 A He's my brother, he hasn't been in the

6 company for the last ten years.

7 Q And who is Janet Altagracia Patin? I'm

8 not saying that right.

9 A Altagracia, my sister.

10 Q Is she still a stock owner?

11 A I think so, I'm not sure.

12 Q The spelling is A-L-T-A-G-R-A-C-I-A.

13 I'd like you to look at Petitioner's Exhibit 1 to

14 the Exhibit 21, and tell me if that refreshes your

15 recollection as to the amount of stockholdership by any of

16 the persons you've named?

17 A I don't think this is -- would be true

18 now. My father appears there. My father appears

19 here, this is when the company was first formed or

20 incorporated.

21 Q Does the company still have 14,500 shares

22 outstanding?

23 A No, I don't think so. There was a change

24 in the shares of the company, but I don't recall

25 which ones is the change. We're talking about 1997.
81

1 Q Was --

2 A My father was the president of the company

3 at the time.

4 Q Was Henry Azar at one time the shareholder

5 of Air Santa Domingo?

6 A Yes.

7 Q And you and your wife purchased shares

8 from him?

9 A Not that I recall.

10 Q I thought I remembered you telling me, and

11 I wrote down here that you --

12 A He's president of the company and I am

13 vice president.

14 Q Correct. And do you and your wife own the

15 stocks in Air Santa Domingo?

16 A May I ask her a question?

17 THE WITNESS: Do you recall that we have

18 stock in Air Santa Domingo?

19 MRS. HERNANDEZ: I think so.

20 THE WITNESS: I think so, but I don't

21 recall how many. Not major.

22 BY MR. OWENS:

23 Q Who are the officers of SAP, S.A. now, do

24 you know?

25 A I don't recall right now because they were
82

1 changed -- they were changed in January. One of

2 them I think is Jose Fernandez. No, I'm sorry, I

3 think that they were changed in December, this is by

4 the time we -- Mr. Jose Hernandez Fernandez.

5 Q Became what?

6 A Secretary.

7 Q Who became president?

8 A The president is -- may I ask her for the

9 name? I don't recall. I'm really bad at names and

10 numbers. Luis Perez.

11 Q How do you spell it?

12 A Luis is L-U-I-S, and Perez is P-E-R-E-Z.

13 Q What relationship did they have to the

14 company before they became secretary and president?

15 A None, none.

16 Q Did you know them?

17 A Yeah, I know them.

18 Q How did you know them?

19 A Years ago. Years ago, but I did not meet

20 them in the aviation area. Investor.

21 Q They don't know about aviation?

22 A Not really that much. Not really too

23 much.

24 Q Do you advise SAP, S.A. now?

25 A Advisor for SAP.
83

1 Q Does SAP pay you for that?

2 A SAP pays me a minimum $1,000 a month when

3 they're able to pay me. I haven't been paid in six

4 months.

5 Q You weren't paid when you were president?

6 A Whenever there was money to pay me.

7 Q So you were not paid for the last five

8 months as president?

9 A I had not been paid because of the

10 company's situation.

11 Q Who were the other officers of SAPSA when

12 you were replaced as president?

13 A My wife who was the secretary, and I was

14 the president. We were the officers.

15 Q There were no other officers?

16 A No.

17 Q Are there any other officers besides Jose

18 and Luis now?

19 A No.

20 Q Who were the employees of SAPSA at the

21 time you left, besides the two that you mentioned in

22 marketing?

23 A There are employees in accounting, in

24 maintenance, there was employees in marketing.

25 Q How many employees did SAPSA have when you
84

1 left?

2 A It had about 60 employees, but we had to

3 cut down because of the company's conditions, almost

4 bankrupt. And what's left is maintenance,

5 operations, there are two persons, marketing and

6 management area.

7 Q So when you cut back from 60 you cut back

8 to what level?

9 A About 30.

10 Q Who is in charge of finance?

11 A There is a financial department, there are

12 two people there, two persons there.

13 Q And what are their titles?

14 A One is in charge of the finance department

15 and the other one receives -- they're both in charge

16 -- it's a helper, they're both in charge of the

17 finance department.

18 Q Is anyone in the capacity of chief

19 financial officer at that company?

20 A No, there is no financial officer there.

21 Q So you as president made the financial

22 decisions for the company?

23 A Many times.

24 Q Most of the decisions?

25 A Many times.
85

1 Q Did SAPSA file tax returns with the

2 Dominican Republic?

3 A Yes, it has to.

4 Q And you signed them?

5 A If I signed them?

6 Q Yes.

7 A When they would bring me the report, the

8 financial report, the person in charge of finances

9 was the one that handled that.

10 Q Signed the tax return?

11 A To sign it.

12 Q And the person in charge of finances was?

13 MR. CERVERA: We missed something here.

14 He was stating something and all of a sudden

15 you started to formulate another question, but

16 the translation hadn't been made yet. So can

17 we go back so we can have a record of what his

18 answer was. I know there was an answer

19 somewhere and I think she got caught in

20 between. The translator got caught -- the

21 interpreter got caught in between and didn't

22 finish the sentence.

23 (Whereupon, the reporter read back the requested

24 portion of the transcript, and the proceedings resumed as

25 follows:)
86

1 THE WITNESS: A person in the finance

2 department.

3 BY MR. OWENS:

4 Q A person in the finance department signed

5 the tax returns?

6 A He signs the taxes. It has to be signed

7 by the person in charge of finances.

8 Q Okay. And who was that person at SAPSA?

9 A I don't recall the name.

10 Q In all the time that you worked there, you

11 don't recall the name of the person in charge of

12 finances?

13 A No. I know it's there, but I don't recall

14 his name. I don't recall his name.

15 Q Was that same person there for the five

16 years that you were present?

17 A Perhaps longer than that, but I don't

18 recall his name or last name.

19 Q None of his names?

20 A I don't recall. I'm trying to recall, but

21 I don't recall.

22 Q Who are the --

23 A He goes there, but he doesn't work every

24 day. He doesn't go every day and that's why we have

25 another person who is his assistant, and I don't
87

1 recall the assistant's name either.

2 Q Who are the officers of SAP, Inc.?

3 A May I ask a question? I think my wife and

4 I are the officers.

5 Q Are there any other officers?

6 A No.

7 Q You told me who the president was, and

8 Henry is the president and you are the vice

9 president of Air Santa Domingo?

10 A Yes.

11 Q Who are the other officers, if any?

12 A Officers? Who are the officers? Let me

13 ask her the question.

14 MRS. HERNANDEZ: I think --

15 THE WITNESS: I think that it's us also,

16 but I'm not sure.

17 BY MR. OWENS:

18 Q Do you remember going to -- well, let me

19 ask you this, have you got any relationship with

20 Transporte Logistico Corporation?

21 A I don't even know what you're talking

22 about.

23 Q It is a corporation --

24 A Transporte Logistico Corporation, no.

25 Q It's a Florida corporation that lists Jose
88

1 M. Patin.

2 A No. Transporte Logistico Corporation, no.

3 Q Do you have any relationship with the

4 Florida company called JR Caribbean Import and

5 Export, Inc.?

6 A Absolutely not.

7 Q Okay. Did you go to a -- let me ask this,

8 are there any board members -- board of directors of

9 SAP, S.A.?

10 A Board of director members? I'm the

11 president, or I was the president. I would make the

12 decisions, the decisions would be made there.

13 Q So it had no board of directors?

14 A Yes, there was a board, basically the

15 shareholders themselves.

16 Q Are there any board members of SAP, Inc.?

17 A The shareholders, the same shareholders.

18 Q And for Air Santa Domingo, is there a

19 board of directors?

20 A Neither. The same people, the

21 shareholders.

22 Q The shareholders are the directors?

23 A Um-hum.

24 Q Is that a yes or no?

25 A Yes, they're the directors.
89

1 Q When did this board meeting occur when you

2 were removed as president?

3 A When the petitions that existed were

4 brought in December -- November or December, around

5 there.

6 Q Did you --

7 A And then the directors there told me that

8 they removed me as president, or the shareholders.

9 Q Did you call the meeting?

10 A I called so that we could look at this

11 document that was being requested.

12 Q The subpoena?

13 A Yes, the subpoena. Before that the other

14 -- the court order that I saw here.

15 Q Are you referring to Exhibit 1?

16 A Yes.

17 Q And what was said at that meeting?

18 A That the company refused or said that they

19 didn't need to provide those documents because

20 they're in the Dominican Republic. And I was

21 removed then. They asked for my resignation, so I

22 had to resign.

23 Q Did you tell them whether or not to comply

24 with the subpoena?

25 A I made the suggestion.
90

1 Q Would you say it in Spanish?

2 A I made the suggestion.

3 Q To who?

4 A To the shareholders, the ones that were

5 shareholders of the company at the time.

6 Q Who was there at that shareholders

7 meeting?

8 A Pura, Laura -- no, no, the majority of

9 them, the majority.

10 Q Well, who?

11 A Joanne was there, Isabel was there,

12 Marisol.

13 Q Anyone else?

14 A From what I recall I think practically all

15 of them were there.

16 Q Your son, Jose?

17 A Yes, I think so. I think he was.

18 Q And you were there?

19 A For sure, yes.

20 Q And how did you vote on that?

21 A I didn't vote. I was the one that

22 presented the suggestion or the request, and I did

23 not vote.

24 Q You presented the suggestion that you

25 resign?
91

1 A Excuse me? No, no, no. No, when I

2 requested the documents then they presented this

3 request suggesting for me to, or telling me to

4 resign.

5 Q Well, there were two resolutions presented

6 at the meeting, was there not?

7 A I think so.

8 Q And do you recall the second resolution?

9 A I would be grateful if you tell me what it

10 was because I don't recall well, the second one. I

11 think it had to do with the sale of my shares or the

12 purchase of my shares, something like that.

13 Q Did you discuss at the shareholders

14 meeting that you should refuse to get -- to give

15 information to Embraer or the Court?

16 A I just brought this request, I made no

17 comments.

18 Q Were you instructed at that board meeting

19 not to provide documents?

20 A I was not instructed, but I was not

21 authorized to take any documents, they would not

22 authorize me to get any document.

23 Q Were you instructed not to sit for a

24 deposition?

25 A No, I wasn't given instructions on that.
92

1 Q Were you instructed not to give

2 information about the company verbally to Embraer or

3 the court?

4 A So far no, they have not instructed or

5 forbidden me. I had no instructions on that.

6 Q Were you there for the whole board

7 meeting -- I'm sorry, shareholders meeting?

8 A Say that again.

9 Q Were you present at the entire

10 shareholders meeting?

11 A Of that particular --

12 Q Yes.

13 A I think so. I was -- I think I was there

14 almost all the time, perhaps at some point I got up

15 to urinate because I'm a diabetic.

16 Q Were two resolutions passed at that

17 shareholders meeting?

18 A I think so, two. One substituting us, and

19 the other one if you can remind me of it, I don't

20 recall it.

21 Q Did the company agree to buy your stock?

22 A No, what they did do is they demanded

23 almost that I sell my shares so I would not belong

24 to the company.

25 Q Did you sell the shares?
93

1 A It's being negotiated. I practically

2 handed them over my shares, I was so pissed off and

3 I -- I was pissed off so I handed in my shares.

4 Q You did not agree with resigning?

5 A What's that? I have to, that is what they

6 request. I have to, that is what they demanded. I

7 had to.

8 Q Do you and your wife own more than 50

9 percent of the shares of the company?

10 A No, no.

11 Q Are you close to owning 50 percent?

12 A No, no.

13 Q It seems at the beginning of the company

14 your mother owned a substantial part of the company?

15 A Yes, my mother holds the majority of the

16 shares just like my father used to hold the majority

17 of the shares, because when my father passed away

18 she kept a majority of the shares.

19 Q Well, in -- okay. Would you look at the

20 document we marked as Exhibit 22.

21 (Whereupon, the referred-to documents were

22 marked as Plaintiff's Exhibit Number 22 for

23 Identification.)

24 BY MR. OWENS:

25 Q Have you ever seen that document before?
94

1 A Yes.

2 Q And this meeting was on November 18, 2009?

3 A I think so. That date, yes.

4 Q Now, at the beginning of that document it

5 refers to the secretary preparing a roster of

6 shareholders. I'm sorry, I withdraw that question.

7 At the beginning there's a suggestion that the

8 shareholders of SAP, S.A. listed on the roster prepared by

9 the secretary attended this shareholders meeting. Is that

10 correct?

11 A I don't understand your question.

12 Q The beginning of this document suggests

13 that the secretary of the company prepared a roster,

14 did you see the roster?

15 A Yeah, that's the first paragraph.

16 Q Did you see this roster?

17 A If I saw it? Practically everybody was

18 there.

19 Q Do you have a copy of the roster?

20 A If I have a copy? No, I don't have a

21 copy.

22 Q Did you read the second resolution?

23 A Yeah, I read the second resolution.

24 Q Was that resolution passed at that

25 shareholder's meeting?
95

1 A Surely, yes, it was passed.

2 Q Did you turn over documents to the company

3 at that point in time?

4 A The company had most of those documents,

5 the company, and then I handed in the ones I had, I

6 gave them to the company.

7 Q What ones were those?

8 A The documents, company documents from the

9 day-to-day. Whatever I had I basically gave. The

10 company documents, but the little I had because

11 those documents are kept over there in different

12 departments; permits, similar aromatics, all those

13 certificates, specific operations, the requested

14 services, all that. All that.

15 Q Do you have any financial statements or

16 tax returns of the company here in Miami?

17 A I don't. There is no reason to have that

18 in Miami.

19 Q I asked you do you.

20 A No, no, I don't.

21 Q It --

22 A We brought what we were able to compile

23 here in Miami, the bank accounts.

24 Q I'd like you to look at the last sentence

25 of the second resolution.
96

1 A Which is that one?

2 Q The Segunda Resolucion.

3 A Do you want me to read it completely or

4 the second sentence?

5 Q The last sentence beginning with asimismo.

6 A It states that I was -- forbade me to --

7 of providing information to any foreign tribunal or

8 court. My understanding is that this is not a

9 tribunal or a court, or I misunderstood.

10 Q Did your wife vote on this resolution?

11 A She was not able to vote because we

12 decided not to vote facing this resolution.

13 Q You did not vote on the second resolution?

14 A None of the two.

15 Q Okay.

16 MR. OWENS: Do you want to take a short

17 lunch break and we can figure out if I have

18 anything left on him?

19 MR. CERVERA: Sure, because it is 2:35

20 now.

21 MR. OWENS: Do you want to adjourn it and

22 do it another day?

23 THE WITNESS: As you wish. As you wish.

24 The only thing I want is -- the only thing I

25 wish is that whenever it is possible for me to
97

1 go back to Santa Domingo to see the lives I can

2 save in Haiti and the hunger that can be

3 resolved in Haiti.

4 MR. OWENS: Well, I'm out of town for ten

5 days and I'll work with you to do it when it is

6 convenient.

7 MR. CERVERA: Okay. I'm going to be out

8 of town, too, next Friday.

9 THE WITNESS: That's okay.

10 MR. OWENS: You do come back to town from

11 time to time?

12 THE WITNESS: Yes, yes. I practically

13 live here. I go to Santa Domingo to give some

14 sort of instructions, flight instructions.

15 MR. OWENS: Right.

16 THE WITNESS: And supervise things, but

17 I'm here any time.

18 MR. OWENS: Okay. So between you and me

19 we agree --

20 MR. CERVERA: Yes.

21 MR. OWENS: -- to come back on a more

22 convenient time?

23 MR. CERVERA: All right.

24 MR. OWENS: I'll order.

25 MR. CERVERA: I'll take a copy.
98

1 (Whereupon, the deposition was adjourned at

2 2:34 p.m.)

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99

1 CERTIFICATE OF OATH

2

STATE OF FLORIDA )

3 ) SS:

COUNTY OF DADE )

4

 I, JAIME KOGANOVSKY, Professional

5 Reporter, and Notary Public in and for the State of

Florida at Large, certify that the witness, JOSE M.

6 PATIN, personally appeared before me and was duly

sworn.

7 WITNESS my hand and official seal this

31st day of January, 2010.

8

 _______________________________

9 JAIME KOGANOVSKY,

 Notary Public, State of Florida

10 My commission Notary #DD385120

expires, April 24, 2009

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25
100

1 REPORTER'S DEPOSITION CERTIFICATE

2

 I, JAIME KOGANOVSKY, Court Reporter and

3 Notary Public, certify that I was authorized to and

did stenographically report the deposition of JOSE

4 M. PATIN, the witness herein; that a review of the

transcript was requested; that the foregoing pages

5 numbered from 1 to 104, inclusive is a true and

complete record of my stenographic notes of the

6 deposition by said witness; and that this

computer-assisted transcript was prepared under my

7 supervision.

 I further certify that I am not a

8 relative, employee, attorney or counsel of any of

the parties, nor am I a relative or employee of any

9 of the parties' attorney or counsel connected with

the action.

10 DATED this 31st day of January, 2010.

11

12 _____________________________

 JAIME KOGANOVSKY

13

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25
101

1 RE : EMBRAER FINANCE LTD., vs. SERVICIOS AEREOS

PROFESIONALES, S.A.

2 DEPO OF: JOSE M. PATIN

TAKEN : January 18th, 2010

3

4 EXCEPT FOR ANY CORRECTIONS

 MADE ON THE ERRATA SHEET BY

5 ME, I CERTIFY THIS IS A TRUE

 AND ACCURATE TRANSCRIPT.

6 FURTHER DEPONENT SAITH NOT.

7 ___________________________

 JOSE M. PATIN

8

STATE OF FLORIDA )

9 ) SS:

COUNTY OF DADE )

10

11 Sworn and subscribed to before me this

12 ___________ day of ________________, 2010.

13 PERSONALLY KNOWN ______ OR I.D.___________________

14 ____________________________

 Notary Public in and for

15 the State of Florida at

 Large.

16

My commission expires: April 24, 2009

17 My commission #385120

18

19

20

21

22

23

24

25
102

1 ERRATA SHEET

2 RE : EMBRAER FINANCE LTD., vs. SERVICIOS AEREOS

PROFESIONALES, S.A.

3 DEPO OF: JOSE M. PATIN

TAKEN : January 18th, 2010

4

 DO NOT WRITE ON TRANSCRIPT, ENTER ANY CHANGES HERE

5

Page #| Line #| Change | Reason

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21

State of Florida )

22 County of Dade )

23 Under penalties of perjury, I declare that I have

read my deposition transcript, and it is true and

24 correct subject to any changes in form or

substance entered here.

25 _____________ __________________________
103

1 VERITEXT FLORIDA, LLC

 BENOWITZ - BERMAN - COOK - MATZ TRAKTMAN

2 Suite 1020 - Biscayne Building

 19 West Flagler Street

3 Miami, Florida 33130

 (305) 371-1884

4 (305) 377-1100 (fax)

5

January 31st, 2010

6

JOSE CERVERA, ESQUIRE

7 7950 West Flagler Street, Suite 108

Miami, Florida 33144

8

9 RE : EMBRAER FINANCE LTD., vs. SERVICIOS AEREOS

PROFESIONALES, S.A.

10 DEPO OF: JOSE M. PATIN

TAKEN : January 18th, 2010

11 Number of pgs: 104

HELD UNTIL: March 1st, 2010

12

Dear Mr. Jose Cervera, Esquire:

13

This letter is to advise you that the transcript

14 of the deposition listed above is completed and

is awaiting reading and signing.

15

Please arrange to stop by our office in Suite 1020,

16 19 West Flagler Street, Miami, Florida to read and

sign the transcript. Our office hours are from

17 8:00 a.m. to 4:00 p.m. Monday through Friday.

Depending on the length of the transcript, you

18 should allow yourself sufficient time.

19 If the reading and signing has not been completed

prior to the referenced date, we shall conclude

20 that you have waived the reading and signing of the

deposition transcript.

21

Your prompt attention to this matter is appreciated.

22

Sincerely,

23

24 JAIME KOGANOVSKY

25 cc: (copy to all counsel)
104

1 VERITEXT FLORIDA, LLC

 BENOWITZ - BERMAN - COOK - MATZ TRAKTMAN

2 Suite 1020 - Biscayne Building

 19 West Flagler Street

3 Miami, Florida 33130

 (305) 371-1884

4 (305) 377-1100 (fax)

5

January 31st, 2010

6

ROBERT C. OWENS, ESQUIRE

7 ROBERT C. OWENS, P.A.

18890 Southwest 264 Street

8 Miami, Florida 33031

9 RE : EMBRAER FINANCE LTD., vs. SERVICIOS AEREOS

PROFESIONALES, S.A.

10 DEPO OF: JOSE M. PATIN

TAKEN : January 18th, 2010

11 Number of pgs: 104

HELD UNTIL: March 1st, 2010

12

13 Dear Mr. Robert Owens, Esquire:

14 The original transcript of the deposition listed

above is enclosed for your file. The witness

15 did not waive reading and signing and was duly

notified to come in and read the transcript.

16

____ Attached to this letter you will find a copy

17 of the corrections made by the witness.

 PLEASE ATTACH THEM TO YOUR COPY OF THE

18 DEPOSITION SO IT WILL BE COMPLETE.

19 ____ The witness made no corrections to transcript.

20 ____ As of the above date, the witness has not come

 in to read and sign the transcript which has

21 been noted on the original transcript.

22 Sincerely,

23

JAIME KOGANOVSKY

24

25
800-726-7007 305-376-8800

Veritext Florida Reporting Co.

105

A

abandoned 69:3

ability 3:4

able 6:16 11:12 14:9

14:24 15:2 30:14

33:21 34:22,24

45:18 60:23 61:2,13

61:13 69:13 83:3

95:22 96:11

Absolutely 88:6

account 15:20,22,23

15:25 16:3,13,17,20

17:14,18,22,24 18:9

18:10,16,19,22,23

18:24,25,25 19:1,5

19:6,8,9,22,23 20:2

accounting 38:7

83:23

accounts 16:4 17:10

17:12,14 18:14 19:2

20:2,8,17,18 95:23

accrued 34:5

accurate 52:16 101:5

acquired 27:13 60:22

act 73:1

action 100:9

activity 61:18

acts 51:24

additional 43:17,18

43:19

address 4:15,23 5:13

5:15,20,22 9:20,21

9:23 11:12 37:7,8

38:16,17,24 73:15

76:3,12,14,18

addresses 11:9

adjourn 96:21

adjourned 98:1

advertising 51:19

53:23,24 58:20

65:10 70:12

advise 82:24 103:13

advisor 7:16 8:1

82:25

Aereos 1:7 6:2,15,18

6:20,22 7:15 18:2

23:2 24:16 26:4,15

27:10,12,20 28:17

30:3,7,16 31:11,21

32:17 36:18 37:20

38:21 39:7,11,15

41:6,10 42:16 47:2

48:23 49:9 53:15

57:4 58:10,23 59:6

60:4 63:17,25 64:2

64:19 66:2 67:1

71:15 72:6 101:1

102:2 103:9 104:9

Aerolineas 34:1,3,8

34:15

Aeropuerto 5:24

ago 6:12,23 7:9,9

20:14 27:17 32:21

32:22 37:24 42:18

52:19,21,23,23

60:16,18,19 61:9,11

69:2 73:19 77:8

82:19,19

agree 92:21 93:4

97:19

ahead 31:25

air 24:11,20,25,25

25:8,11 26:6,9,10

26:20 27:16,21,25

28:18 29:7,14,25

30:12,17 31:1 37:17

38:19,19 41:5 43:1

43:5,11,13 45:20

46:14,22 48:2,3

52:13 61:17 65:7

69:25 75:10 81:5,15

81:18 87:9 88:18

aircraft 22:15 24:1

27:20 28:18,22

29:23 30:2,3 31:12

31:21,24 32:20 33:7

33:13 34:9 35:3,13

36:19 41:3,7,11,13

41:16,18,25 42:1,5

42:14 46:13,18,25

47:3 61:15 62:6,7,8

62:14 63:21 64:1,15

64:17,22 65:8 66:4

66:10,12,14 68:3,3

68:4 69:18 71:18

74:3,23 77:12,20,21

aircrafts 27:9,13

30:5 62:4 74:8

airline 7:18 25:2,4

39:4

airlines 7:19 61:25

65:6

airplane 22:10,11

59:3 67:18

airport 41:2 62:5

69:1,3,9 71:12

74:13,13,19,19 77:6

77:7,7,9,16,18

Airways 68:14

aka 48:20

allow 23:8 24:4 69:21

103:18

allowed 66:3 69:10

Altagracia 80:7,9

America 19:18,25

58:3 59:19

amount 23:24 80:15

analyzed 21:17

and/or 14:17

answer 4:12 38:15

85:18,18

answered 36:22

answers 3:19

Antonio 80:2

anybody 10:12 68:19

anybody's 10:12,13

anymore 16:18 35:18

apartment 4:16,22

APPEARANCES 2:1

appeared 99:6

appears 49:12 80:18

80:18

appreciated 103:21

appropriate 61:4

68:7

approved 70:14

approximately 4:19

8:17 61:11

April 99:10 101:16

area 4:23 82:20 84:6

aromatics 95:12

arrange 103:15

asimismo 96:5

asked 8:6 62:13 79:4

89:21 95:19

asking 5:16 37:13

48:6 78:19,22

asks 12:24

aspect 53:8

assets 22:1,2,2

assistant 86:25

assistant's 87:1

association 7:4

ATTACH 104:17

Attached 104:16

attended 11:24 94:9

attention 53:14

103:21

attorney 3:14 21:17

57:19 100:8,9

attorneys 14:19 33:4

33:6,9,11 50:16

attracts 53:14

authority 65:22

authorization 60:5

61:8

authorize 91:22

authorized 91:21

100:3

available 14:24 21:1

21:2,4 24:12

aviation 31:7,12 36:2

37:6 38:22 39:21

60:19 70:22 71:8

77:12 79:9,10,11

82:20,21

avionics 62:24 63:1

awaiting 103:14

aware 28:19,21

Azar 9:4 10:5 11:7

43:8,9 79:25 81:4

A-E-R-O-L-I-N-E-...

34:1

A-I-R 38:1

A-L-T-A-G-R-A-C...

80:12

a.m 1:12 103:17

B

bachelor 11:23

back 11:25 21:9

22:10 29:16 36:2
800-726-7007 305-376-8800

Veritext Florida Reporting Co.

106

39:21 71:3 84:7,7

85:17,23 97:1,10,21

bad 82:9

Balaguer 77:6

bank 17:8 19:14,18

19:20,25 20:16,18

48:12 67:20,21

95:23

bankrupt 84:4

bankruptcy 34:20

35:1

banks 19:15

bank's 15:3 48:16

base 58:4,5

based 23:15 40:20,21

40:22 57:9,20,22

58:18

basically 17:13,18

19:14 51:18 52:1

53:6,20 59:4 62:6

88:14 95:9

Beech 30:21,23

Beechcraft 41:19

65:14

began 6:22

beginning 56:23 57:9

93:13 94:4,7,12

96:5

behalf 1:17 2:4,6

73:1

believe 12:18 17:9

22:3,16 25:24 27:11

27:17 30:5 31:10

32:25 34:10,13

45:25 46:17 47:4

63:23 69:18 70:7

Bell 70:3

belong 26:6 27:11

35:10,14 92:23

belonged 32:5 34:14

belongs 35:10,14

62:24 66:14 69:9

BENOWITZ 103:1

104:1

BERMAN 103:1

104:1

best 3:4 23:17

big 34:5 62:12,12

bill 34:5

bills 48:14

Biscayne 103:2 104:2

board 88:8,8,10,13

88:14,16,19 89:1

91:18 92:6

borrow 4:9

bottom 44:17 68:2

bought 26:9

branch 57:24 58:6,8

58:9

branches 59:6

break 4:1,2 59:21,21

96:17

Brickell 4:16

brief 77:25

bring 14:23,24 32:3

85:7

broker 51:19,20,25

66:16

brother 80:5

brought 14:10,12

15:1 89:4 91:16

95:22

Building 103:2 104:2

business 5:13,20 6:1

6:24 17:20 20:21,22

26:13,14,15,17

46:24 50:17 51:9,14

51:21 72:2,4,12

77:13,14,19

businesses 77:11

businessman 67:17

businessmen 9:8

buy 92:21

B90 30:21

C

C 2:2,2 104:6,7

CA 1:3

call 6:14 22:7,14

50:25 58:17,25 59:2

65:12 70:13 89:9

called 3:3,7 27:25

38:18,25 45:19

50:23 88:4 89:10

calls 70:12

capacity 61:17 84:18

captain 12:2

Caravan 22:13 67:10

card 71:25 72:2,4,7

72:12 73:15

Caribbean 88:4

Caribe 24:11,20,25

25:5 68:16

carried 71:11

carrier 61:17

case 1:3 18:5 61:25

cash 20:21,22 23:23

categories 61:10

category 55:9 60:20

60:22

caught 85:19,20,21

cause 1:20

cc 103:25

center 62:23

Central 58:2 59:19

Century 24:25

certificate 22:20 23:3

23:6,8 35:21 46:5,7

46:8,9,10 60:15

65:20,21 99:1 100:1

certificates 22:23

48:11 95:13

certify 99:5 100:3,7

101:5

Cervera 2:5 43:23

76:23 78:19 79:3

85:13 96:19 97:7,20

97:23,25 103:6,12

Cessna 22:4,11,13

35:7,8,9,10,12,15

35:16,23 67:10,11

67:13,16 69:16

74:12

change 80:23,25

102:5

changed 61:10 82:1,1

82:3

changes 102:4,24

charge 53:9,16,25

54:24 55:14 84:10

84:14,15,16 85:8,12

86:7,11

charter 17:19 23:10

23:10,13,19 26:14

39:4 46:1,25 47:4,5

47:6 75:10

chartered 66:4

Charters 40:19

checks 48:16

chief 84:18

child 9:9

children 5:10 8:22

9:2,6,24 10:8

chopper 69:15

CHRISTINA 2:8 3:2

CIRCUIT 1:1,1

citizen 5:6 12:4,5

citizens 5:11

citizenship 12:8

cleaning 18:12,13

clients 55:10

close 34:19,19,21,21

35:22 46:2 93:11

closed 17:10 35:1

45:23 46:11 71:18

74:19 77:9

code 4:16

coincidences 44:2

collects 23:20

colors 70:18

come 14:21 54:10

62:1,1,14,16 97:10

97:21 104:15,20

comes 24:13 62:11

comments 91:17

commercial 50:17

51:18,22,23 52:1,2

53:8,13,21,21,22

54:16,18 56:15

57:14,17,17 58:12

58:15 59:4,5,8

61:18 68:9 70:5

75:24

Commercially 52:3

commission 58:22

66:17 99:10 101:16

101:17

commitment 56:23

companies 21:3,6,7

24:7,8,10,11,18,19

24:21,21,24 27:14

33:22 34:2 50:7,19
800-726-7007 305-376-8800

Veritext Florida Reporting Co.

107

50:21 51:1,2,6

57:15 58:25 60:16

60:24 63:1,23 67:8

68:18 70:7

company 6:4,7,10,25

7:5,21,24 8:1,4,5,11

8:15,20 9:8 10:7

11:14 12:12,14,15

13:3,8,15,17,18

15:24 16:14,17

17:15,23 18:11

19:22,23,24 20:3,16

20:23 21:8 22:1,2,2

22:3,20,25 23:2,9

23:13,15,16,19 24:1

24:4,23 25:12,18,19

25:20 26:3,5,13

27:15,24 28:3,21

29:7,13,19 31:1,4,9

31:22 32:19,23

33:21 34:6,12,17,19

34:20,21,21,23 35:6

35:9,16,17,20,22

36:4,18,20 38:14,18

38:25 39:3,4,13,16

39:17,18,23,25 40:2

40:16,17,18,21 41:3

41:7 42:9,11,18,21

42:24 45:19,22,24

45:25 46:11,17 47:3

47:6,13 48:23 49:5

50:2,8,9,17 53:9,12

54:2,3,6,7,14 58:5,9

59:3 61:1,13,24

62:25 63:2 66:14

67:25 68:10,11,12

68:17 70:14,16

72:24 75:19 76:5,6

76:9 79:15,17,19

80:3,6,19,21,24

81:2,12 82:14 84:19

84:22 88:4 89:18

90:5 92:2,21,24

93:9,13,14 94:13

95:2,4,5,6,8,10,16

company's 13:7

17:18,19,21 18:24

18:24 24:15,16 37:3

37:5 72:23 79:10

83:10 84:3

compile 95:22

complete 100:5

104:18

completed 103:14,19

completely 30:6

51:12,13 96:3

comply 46:3 89:23

computer 32:10

computers 52:20

76:17

computer-assisted

100:6

conclude 103:19

condition 22:18

conditions 84:3

conduct 70:15

connected 100:9

Conrado 7:12

consultant 79:9,10

79:11

contained 78:17,22

continent 59:18

continue 34:18 68:8

contract 73:5,6,9

75:9,10

convenient 97:6,22

COOK 103:1 104:1

copy 94:19,20,21

97:25 103:25

104:16,17

corporation 28:12

50:18 78:25 87:20

87:23,24,25 88:2

correct 18:17 22:21

26:23 27:4 30:18,18

33:14 48:21 49:14

49:14 53:5,6,11,17

56:9,12,16,17 57:5

57:6 60:6,8,9 65:24

67:2 68:21 72:9

74:16 75:4 76:15

81:14 94:10 102:24

corrections 101:4

104:17,19

correctly 10:11

cost 32:12,14

costs 23:19 61:4

counsel 100:8,9

103:25

countries 22:24

County 1:2 99:3

101:9 102:22

couple 33:5

course 62:16

court 1:1,18 3:20,24

89:14 91:15 92:3

96:8,9 100:2

creating 51:16 52:5

credit 23:16 48:13,17

crews 18:11

criteria 53:21

CROSS 2:11

current 5:16

cut 84:3,7,7

C.D 48:17

D

D 2:10

Dade 99:3 101:9

102:22

data 32:10

date 16:20 94:3

103:19 104:20

DATED 100:10

day 86:24,24 96:22

99:7 100:10 101:12

days 97:5

day-to-day 95:9

DD385120 99:10

De 67:4

deals 17:21

Dear 103:12 104:13

deceased 49:10

December 6:8 72:9

72:13 73:8 75:7,8

82:3 89:4,4

decided 96:12

decisions 84:22,24

88:12,12

declare 102:23

default 35:25 42:7

67:18

Defendant 1:8 2:6

degree 11:22

del 5:24

Delaware 37:12

delivered 41:19

deliveries 38:9

demanded 92:22

93:6

department 54:15,16

54:17,19,24 55:8

84:11,14,17 86:2,4

departments 95:12

Depending 103:17

depo 78:18 101:2

102:3 103:10

104:10

DEPONENT 101:6

deposition 1:15,20

13:21 91:24 98:1

100:1,3,6 102:23

103:14,20 104:14

104:18

describe 11:21

design 54:14

designed 52:22

designing 53:25

55:14

destroyed 74:24

detergent 18:12

determine 53:4

DHC 67:4

DHL 38:12

diabetic 92:15

differences 45:17

different 11:24 19:6

20:12 24:8,11,18,21

24:23 33:22 45:14

51:1 55:21,22 62:21

62:23 63:1 73:15

95:11

difficult 59:15

DIRECT 2:11 3:9

director 88:10

directors 88:8,13,19

88:22,25 89:7

discontinued 32:2

discuss 91:13

divided 19:3

document 13:2 14:2

14:4,5,17,20 15:11
800-726-7007 305-376-8800

Veritext Florida Reporting Co.

108

16:12 17:4 21:24

29:4 36:6 44:10

49:15,22 55:24 60:2

63:4 72:15 78:3,20

89:11 91:22 93:20

93:25 94:4,12

documents 13:5,22

14:10,12,23 15:1,3

15:7 16:8,22,25

17:5,7 19:21 21:21

28:7,25 36:8 44:6

45:1,3 47:15,17,22

47:23 48:8 49:17

56:1 60:10 63:7

71:21 72:17 73:23

75:12 78:5 89:19

91:2,19,21 93:21

95:2,4,8,8,10,11

doing 73:14

domicile 5:1,3

Domingo 5:21,24

8:21,23 9:16,20

11:2,4,6,8 13:11

21:5 23:5 24:12

25:1,8,9,11 26:10

26:20 27:16,21 34:2

34:3,8,15 38:8,11

42:8,12,13 43:2,5

43:12,13 50:5,16

57:10 65:7 69:25

77:13,15,19 81:5,15

81:18 87:9 88:18

97:1,13

Dominican 5:25 7:18

12:1,3,4,9,24 13:5,9

13:11 20:9 22:21

23:17 24:8 26:8

29:10 32:2,6 35:21

41:5 42:2 54:2

57:20 60:14,17,19

60:22 61:5,15 62:3

65:3 66:25 67:25

68:5 85:2 89:20

door 75:16

dry 23:25 24:1,3

66:20

duly 3:8 99:6 104:15

dump 69:14

dumped 69:8

duties 61:6

E

E 2:10

education 11:21

effect 53:22

eight 5:5 25:25 47:8

68:25

either 7:11 20:8

30:19 56:18 66:20

87:1

else's 10:12

Embraer 1:4 3:14

15:22 20:13,14 22:5

22:17 33:11,17,18

33:19 34:22 35:7,8

35:9 74:10 91:15

92:2 101:1 102:2

103:9 104:9

Embraer's 74:11

emergencies 54:8,9

55:20

emergency 59:1

employee 100:8,8

employees 23:24

54:18 55:9 72:24

83:20,23,24,25 84:2

employment 7:14,24

enclosed 104:14

engine 35:19

engines 32:15 69:12

English 3:3,3 56:25

57:12

ensuring 53:10,16

ENTER 102:4

entered 102:24

entire 92:9

entities 20:12,15

51:11 54:13 64:8

entity 50:6,11,14

51:23 52:1,2 58:1,2

entry 62:20

equipment 32:12

68:7

equity 35:13

ERRATA 101:4

102:1

Escusio 43:21

Esquire 2:2,5 103:6

103:12 104:6,13

Europa 26:6,10

Europe 59:12,17

European 65:11

Eusebio 3:12 10:25

43:23,24 79:13

everybody 94:17

exact 4:23 5:15,22

exactly 6:13,13 8:10

8:24 9:22 14:7 20:1

31:23 36:5 40:9

47:11 56:4 63:18

EXAMINATION 3:9

examine 73:15

example 23:18

Excuse 59:20 91:1

executive 41:2

exhibit 13:20,23 15:5

15:8,11 16:6,9,13

16:24 17:1,5 18:15

18:17,21 19:1,10,21

21:10 28:5,8,11

29:1,5,24 36:7,9,22

36:24 44:7,11 45:4

49:16,18 55:25 56:2

56:8 60:3,11 63:5,8

71:20,22 72:16,18

73:20,24 75:3,5,13

77:4 78:4,6,15,17

78:18 79:4,7 80:13

80:14 89:15 93:20

93:22

exhibits 2:13 19:6

45:2,7 47:16,18

49:12

exist 57:1

existed 57:5 89:3

exists 15:22

expired 32:15 75:9

expires 73:5 99:10

101:16

Export 88:5

Express 42:10,11,12

e-mail 76:3,8,12,14

76:18

E-U-S-E-B-I-O 3:12

F

FAA 29:24 45:23

46:2,3

facing 96:12

familiar 75:19

family 5:8,9 6:24

25:13,14,16,17

79:22

far 92:4

Fargo 70:21 71:8

FASAP 50:7

father 6:11,25 7:4,6

7:13,20,23 8:2

12:12,13 44:2 49:4

49:10 80:18,18 81:2

93:16,17

father's 7:2 49:6

fax 103:4 104:4

FBO 38:2

fellow's 67:19

Fernandez 82:2,4

figure 96:17

file 13:10 34:20 85:1

104:14

filed 16:21 79:1

finally 48:18

finance 1:4 3:14 22:4

22:11 35:10 84:10

84:14,17 86:1,4

101:1 102:2 103:9

104:9

financed 22:4,11

63:12

finances 85:8,12 86:7

86:12

financial 84:11,19,20

84:21 85:8 95:15

find 59:16 104:16

fine 4:3,6,9,14 10:22

19:17 21:12 59:22

finish 4:7 85:22

FIRM 2:2

first 3:8 6:9 18:10

20:11 23:18 31:20

56:9,10 80:19 94:15

five 4:20 12:19 47:8

60:25 83:7 86:15

Flagler 1:10 2:5
800-726-7007 305-376-8800

Veritext Florida Reporting Co.

109

103:2,7,16 104:2

flies 62:10,21

flight 23:14 32:10

70:15 97:14

flights 17:19 23:10

23:10 32:18,18 34:4

58:19 59:12 70:17

Florida 1:2,11,19 2:3

2:6 4:17 28:13

58:19 87:25 88:4

99:2,5,9 101:8,15

102:21 103:1,3,7,16

104:1,3,8

fly 7:16,17 60:5,17,20

60:23 61:2,7,8,10

61:13,13,16,19 62:4

62:8

flying 12:1 61:3

70:14

following 3:4

follows 3:8 29:18

59:24 71:5 78:1

85:25

forbade 96:6

forbidden 92:5

foregoing 100:4

foreign 96:7

forgot 67:22,23

form 102:24

formed 56:11,14

80:19

formulate 85:15

Fort 37:25 38:4

40:22 58:4,5,6,8,9

58:11 59:7,14 62:4

62:9,18,20

four 6:11 32:12,21,21

60:25 64:11 69:1

73:19 77:8

freeze 16:3

Friday 97:8 103:17

froze 15:22 16:20

fuel 17:20 23:21

48:14,19

full 3:11 4:7,25 54:25

fully 21:18

funds 19:24 20:3,6

further 100:7 101:6

G

gas 17:20

general 17:22

gentleman 43:7

Geraldo 55:12

German 54:23

getting 74:20

give 5:22 11:12 31:19

48:7 91:14 92:1

97:13

given 12:19,20 50:13

91:25

go 21:9 22:10 31:25

39:21 55:16 62:18

69:14 78:12 85:17

86:24 88:7 97:1,13

goes 86:23

going 36:2 40:22

44:11 46:8 47:15

59:16 71:13 78:9

87:18 97:7

good 3:13 52:19

76:17

gotten 33:4

government 13:11

Grand 67:10

grandfather 7:8

granted 61:1,12

grateful 91:9

grounded 64:11

group 31:7,13 36:3

37:6 38:22 39:22

50:3,4,7,11,23,25

51:1,6,10,11,17,19

51:21 52:11 54:1

56:11,20 57:1,7

64:8 70:9 75:20,20

75:23,24 77:5,12

groups 56:14

guarantees 34:6

guaranty 45:18

H

Haiti 25:1,5 68:13

97:2,3

hand 99:7

handed 15:13 93:2,3

95:5

handled 85:9

happened 20:1 33:2

33:15,20 41:18

Harold 54:23 55:1

Havila 67:4

Hawker 41:23,24

64:10

Hazelwood 46:19

73:1

heard 38:25 42:9

45:19 50:2

held 6:6 30:25 39:22

39:24 103:11

104:11

helicopter 54:7 70:13

70:16,17

helicopters 54:8

55:19 70:15

help 59:1

helper 84:16

Henry 43:7 81:4 87:8

Hererra 74:18 77:8

Hernandez 7:3 10:2

43:25 44:1,2,3

48:21 49:2,6 55:3,5

63:18 69:24 79:24

81:19 82:4 87:14

Herrera 74:13

Heyer 55:1,6

HI 65:3 66:9 74:15

highlighted 29:23

Higuero 5:24 69:3

77:10

hired 55:16 56:5

HI760 22:16

hold 6:3,9 7:14 12:8

12:11 22:23 42:23

43:1 93:16

holds 93:15

Hollywood 38:2

hours 103:16

house 29:11

hunger 97:2

hurricane 74:24

H-E-I 55:5

H-E-R-R-E-R-A

74:13

H-E-Y-E-R 55:5

I

Identification 13:24

15:9 16:10 17:2

28:9 29:2 36:10

44:8 45:5 47:19

49:19 56:3 60:12

63:9 71:23 72:19

73:25 75:14 78:7

93:23

identified 78:21

identify 79:4

imagine 13:13

Import 88:4

Including 42:16

inclusive 100:5

income 17:19,19

incorporated 26:7

36:14 37:14 39:17

39:19,20 80:20

incorrect 56:13

Inc's 65:20,21

indicating 36:25

73:17

individual 59:2

information 13:10

52:15 53:5,10,16

54:14 67:22,24

71:25 78:22 91:15

92:2 96:7

initiated 6:25

inoperable 22:19

inspections 42:3

62:12

install 32:13

installed 32:8,11,12

instructed 91:18,20

91:23 92:1,4

instructions 91:25

92:5 97:14,14

instructor 7:17 12:3

intended 71:19

Inter 25:5,6 68:16

internal 32:18

International 37:25

38:3,4 62:5 77:6

interpret 56:21

interpreted 14:8

56:24 57:11
800-726-7007 305-376-8800

Veritext Florida Reporting Co.

110

interpreter 2:8 14:3

18:8 56:24 57:11

59:20 85:21

investor 35:12 82:20

involved 9:8 27:24

28:2

involvement 52:5

53:2

Ireland 71:9

Irizarry 79:11

Isabel 9:4,24 10:18

11:5 90:11

I-N-T-E-R 25:7

I.D 101:13

J

Jaime 1:17 99:4,9

100:2,12 103:24

104:23

Janet 80:7

January 1:11 82:1

99:7 100:10 101:2

102:3 103:5,10

104:5,10

Jet 26:22 70:3

jets 34:14

Jetstream 64:12

70:18,20 71:7

Jetstreams 30:6,17

33:1,15,20,25 34:3

34:10,11,14 64:19

64:23

JMPatin 76:20

JMPatin@SAPair....

76:19

Joan 9:4,9,14 10:10

10:18

Joanne 90:11

Joaquin 77:5

jointly 11:14

Jose 1:15 2:5,12 3:6

3:12 7:3,11 10:19

11:3 28:12 43:16,25

48:20,20,22,24 49:8

49:23 80:2 82:2,4

83:17 87:25 90:16

99:5 100:3 101:2,7

102:3 103:6,10,12

104:10

JR 88:4

Juan 57:24 58:11

59:7

JUDICIAL 1:1

June 74:8,9,15,17

junk 69:5,6

J-O-A-N 9:14

J.Patin@SAPAIR....

76:22

K

keep 20:3 34:22

69:10 70:10

keeping 70:11

keeps 52:23

kept 22:18 38:19

93:18 95:11

Key 4:16

kind 19:1 22:11

26:13 45:24 46:24

know 4:1,12 9:21,21

9:22 10:14 11:11

12:16,17,23 13:17

13:17 14:7 18:1

19:15 28:15 29:13

31:9 36:5,15,16

37:3,10,15,16,19

38:16,17 40:14,14

45:9,10 46:19 48:24

49:2 52:24 53:6,18

53:20 54:22 63:11

69:24 70:8,24 71:7

77:2,18 81:24 82:16

82:17,18,21 85:18

86:13 87:21

knowledge 78:14

known 48:24 75:20

101:13

Koganovsky 1:18

99:4,9 100:2,12

103:24 104:23

L

lack 30:8

land 69:9

large 1:19 70:16 99:5

101:15

Lauderdale 37:25

40:23 58:5,6,6,9,9

58:11 59:7,14 62:5

62:9,18,20

Lauderdale/Holly...

38:4

Laura 79:18,21 90:8

lawsuit 33:11

Learjet 63:11 64:6

Learjets 30:19

lease 20:23,24 23:17

23:20,25 24:1,24,25

25:1 28:18,21 30:14

30:17,19,21,23

35:16 46:13,25

58:20,21 59:8 64:16

64:20 65:11,16

66:11,12,18,19,20

66:20 68:19

leased 4:22 30:4

31:12,15,17 36:19

37:1,2 41:6,11

42:12,14 47:3 54:6

54:10 55:18 61:6

62:7,8 64:16 67:11

67:13 70:21

leases 23:15 24:3,4

29:21 64:1

leasing 30:10 34:16

34:17 55:19 70:22

71:9

left 23:21 68:25

83:21 84:1,4 96:18

legal 50:11,13

length 103:17

letter 76:25 103:13

104:16

Let's 22:10 56:17

74:7

level 84:8

lien 67:14

liens 35:11 67:16

Limited 3:14 71:9

line 48:17 102:5

lines 41:5 48:13

Link 45:20 46:14

list 31:15,19,25 78:12

listed 28:12 29:23

94:8 103:14 104:14

lists 87:25

little 95:10

live 4:21 5:2 9:15

11:1,3,11 29:9

97:13

lived 4:18,22

lives 9:22 11:4 97:1

living 4:19

LLC 27:25 28:18

29:7,14,25 30:13

31:1,7 37:6,17

38:13 39:22 103:1

104:1

loan 33:3,9,21

loaned 67:17

loans 33:17

located 58:8

locations 59:11

Logistico 87:20,24

88:2

long 4:18 5:3 52:21

longer 15:21 30:7

41:15 42:19 68:5,6

68:22,23 69:4,9

72:8 86:17

look 19:5 28:11 45:7

45:14,17 47:21

50:24 56:8,17 59:17

60:2 63:4 64:13

71:20 73:20 80:13

89:10 93:19 95:24

looked 53:4

looking 29:6,15 53:7

lose 38:8

lost 33:3,16

lot 61:4

Luis 79:10 82:10,12

83:18

lunch 96:17

L-E-T-S 26:23

L-U-I-S 82:12

M

M 1:15 3:6 28:12

48:20 49:8 88:1

99:5 100:4 101:2,7

102:3 103:10
800-726-7007 305-376-8800

Veritext Florida Reporting Co.

111

104:10

mail 38:8

mailing 38:24

mailings 38:7

main 17:18 18:22,24

18:25,25

maintain 19:24 20:5

20:16 24:17

maintenance 23:24

24:6 61:20,21 62:2

62:2,11,12,17,19,22

63:2 83:24 84:4

major 81:21

majority 10:15 13:14

40:11 43:14 90:8,9

93:15,16,18

management 84:6

March 103:11 104:11

Maria 9:4,24

Marisol 9:4 10:5,18

11:7 43:9,10 79:24

79:25 90:12

mark 13:20 15:5 16:6

16:24 22:8 28:5,24

44:5

marked 13:23 15:8

16:9,13 17:1,5

18:15,17,18,20

21:10 28:8 29:1,5

36:6,9 44:7,11 45:2

45:4 47:15,18 49:18

55:25 56:2 60:3,11

63:5,8 71:22 72:16

72:18 73:24 75:3,13

78:4,6 93:20,22

marketable 53:13

marketing 54:15,17

54:24 65:13 83:22

83:24 84:5

marking 49:16

matter 103:21

MATZ 103:1 104:1

mean 36:12 43:19

meaning 36:18

means 71:16

medical 54:8,9 55:20

55:20 59:1,2

meet 3:15,17 82:19

meeting 89:1,9,17

90:7 91:6,14,18

92:7,7,10,17 94:2,9

94:25

Mellon 19:19

members 25:16,17

88:8,10,16

mention 54:8

mentioned 18:10

59:18 63:24 65:7

68:17 70:8 75:1

83:21

Miami 1:11 2:3,6

39:20 58:2 59:3

62:22 95:16,18,23

103:3,7,16 104:3,8

MIAMI-DADE 1:2

middle 72:13

mid-December 72:11

75:8

Miguel 3:12 7:3,11

9:14 10:19 11:3

43:16,25 48:21,22

million 33:19

mine 10:11 11:16

45:9

minimum 12:25 83:2

missed 85:13

misspelled 77:1

mistake 49:7

mistaken 27:13

misunderstood 96:9

modifications 53:2

modified 52:24

Monday 103:17

money 23:14,20

48:15 61:4 67:17

83:6

monies 33:8 48:13

month 83:2

months 33:18 60:16

60:19,25 61:9,11,11

61:12,14 83:4,8

morning 3:13

mortgaged 33:10

mother 10:23 18:6

79:14 93:14,15

mother's 44:1

move 69:13,13

moved 42:1,7 77:7,9

moving 58:11,12

N

N 2:10 70:19

name 3:11 6:1 7:2,11

9:3,13 10:1,24 22:3

24:22,23 25:4 35:11

43:7,17,25 44:1

49:3,6,6 50:13,15

50:17,17 51:23 52:6

52:8 54:21,22,25

56:15 63:15 67:19

67:21,23 69:23 82:9

86:9,11,14,14,18,18

87:1

named 42:9 80:16

names 8:24,25 19:14

24:10,19 25:21,23

55:11 78:23,24 82:9

86:19

need 4:1 61:6 89:19

needed 21:19 32:7,11

33:8 60:24

needs 35:20 59:17

77:21

Negotiate 77:20

negotiated 93:1

Neither 30:24 88:20

never 41:6 46:17

71:18

new 16:2,21 33:5,6

73:6,9

nine 5:5 35:19 61:11

61:11

nod 3:24

normally 17:22 61:7

Notary 1:18 99:5,9

99:10 100:3 101:14

notebooks 4:10

noted 104:21

notes 100:5

notice 1:19 77:4

notified 104:15

November 66:1,7,13

89:4 94:2

number 2:14 10:13

13:23 15:8 16:9

17:1 18:19,20 19:1

28:8 29:1 31:23

36:9 44:7 47:18

49:18 56:2 60:11

63:8 64:24 65:1

70:19 71:22 72:18

73:24 75:13 78:6

93:22 103:11

104:11

numbered 100:5

numbers 11:13 19:5

19:7 45:4 82:10

N972JX 70:19

O

oath 3:19 99:1

Objection 76:23

obtain 15:2

obtained 60:4

occasion 70:13

occasions 24:24

41:12

occur 61:9 89:1

office 37:3,5,13,16,21

37:24 38:5,10,14,19

38:22,23,24 48:7

72:23,23 75:17

77:16,17 103:15,16

officer 84:19,20

officers 81:23 83:11

83:14,15,17 87:2,4

87:5,11,12,12

officership 7:21

offices 37:22

official 17:22 62:20

99:7

Oh 15:15 19:2 36:15

37:1

okay 6:12,20 7:16

10:5 12:22 15:21

16:1 18:7 19:18

21:11 30:2 40:16

43:24 45:1 47:10

48:4,11 49:11 66:21

69:11 73:13,20

74:25 78:11 86:8

88:7 93:19 96:15
800-726-7007 305-376-8800

Veritext Florida Reporting Co.

112

97:7,9,18

old 9:11 10:3 26:18

69:1 74:12 75:2

ones 12:19 13:1

15:13 65:6 80:25

90:4 95:5,7

operate 32:1 61:5

64:1 66:3,7,9,16,16

69:4

operated 63:16 65:16

69:19 70:4

operates 24:2 36:16

64:6,10,15 65:14

66:23 67:4 68:3

69:16 70:3

operating 17:13,14

19:22,23 22:20,23

23:6 30:7 34:18

35:18 64:5 65:22

68:5,6,8

operation 6:21,23

40:16,17

operational 22:17

42:19

operations 66:4 84:5

95:13

opportunity 14:16

order 6:16,19 16:2,21

33:4,9,17 34:20

48:17 60:23 69:13

89:14 97:24

orders 17:15

organized 36:4,11,12

original 104:14,21

Orlando 45:19 46:14

otter 27:1 32:25 33:2

33:3,9 35:4 67:4

outside 65:20

outstanding 8:12

80:22

Owens 2:2,2 3:10,13

13:20 14:1 15:5,10

16:6,11,24 17:3

28:5,10,24 29:3,22

36:13 44:5,9 45:6

47:20 49:20 55:4,7

56:7 57:3 59:22

60:1,13 63:10,20

70:2 71:6,24 72:20

74:1 75:15 76:2

77:3,24 78:2,8 79:1

79:5,6 81:22 86:3

87:17 93:24 96:16

96:21 97:4,10,15,18

97:21,24 104:6,7,13

owned 8:3 26:3 27:9

31:3,6 34:11 36:3

40:1,4 46:17 47:12

50:9 70:21 71:7

74:9,15 93:14

owner 46:22 80:10

owners 25:19 40:5

owner/trustee 71:8

owning 41:22 93:11

owns 10:14 25:11

31:9 41:15 42:5

63:11,21,22 64:17

65:5 70:6 74:3,10

74:10 78:14 79:16

P

page 2:14 44:13,14

44:16,17,18,23,24

49:12 64:13 65:15

66:24 67:11 68:2

69:17 75:24 78:23

102:5

pages 44:12,14 78:10

100:4

paid 30:8,9 33:8,18

33:18 35:23 42:6

54:4 61:6 83:3,5,7,9

paint 18:12

Panama 58:3,24,25

58:25

paragraph 94:15

parked 71:16 74:18

74:23 75:2

part 23:3 25:12,20

29:6 31:3,6 33:16

36:1 40:1,4 42:21

47:12 54:13 93:14

parted 32:16 68:23

71:12,17 74:13,18

particular 78:25

92:11

Particularly 71:25

parties 100:8,9

partners 25:18,21

parts 17:15,20 38:6,8

38:11 68:24 73:3

PAS 75:20,23,24 77:5

passed 6:11 7:8 12:12

12:13 92:16 93:17

94:24 95:1

passenger 35:19

passing 7:13,20,23

Patin 1:15 2:12 3:6

3:12 7:3,10,12 9:14

10:1,2 11:3,5 28:11

28:12 43:16,25

48:20,21,22 49:8,23

79:18 80:2,7 88:1

99:6 100:4 101:2,7

102:3 103:10

104:10

Paulino 55:12

pay 17:20 18:25

23:22,22,24 30:10

30:12 33:4,9,21

34:6,22 35:25 36:1

38:20 48:14 53:12

67:17 83:1,3,6

payment 30:8 33:17

payments 30:15

33:19 35:24 48:19

pays 70:11 83:2

penalties 102:23

people 11:10 26:9

52:24 55:13,16 56:5

57:15 65:12 84:12

88:20

percent 40:8 93:9,11

percentage 8:14

40:10

Perez 82:10,12

period 5:7,7 47:9

60:25

perjury 102:23

permission 61:2,12

permits 95:12

permitted 66:7

person 28:15 80:4

85:8,12 86:1,4,7,8

86:11,15,25

personal 61:22,25

personally 99:6

101:13

persons 80:16 84:5

84:12

petition 79:1

Petitioner's 80:13

petitions 89:3

pgs 103:11 104:11

photographs 55:15

55:17

physical 9:22 11:12

pictures 32:3 54:4

56:6

pieces 32:12

pilot 7:17,18,25

11:24,24

pilots 24:5,14

pissed 93:2,3

place 38:6 42:4

places 62:23

Plaintiff 1:5,17 2:4

3:7

Plaintiff's 2:13 13:23

15:8 16:9 17:1 28:8

29:1 36:9 44:7 45:4

47:18 49:18 56:2

57:19 60:11 63:8

71:22 72:18 73:24

75:13 78:6 93:22

plane 20:24 21:1,2

22:3,5,5 23:15,18

23:20 24:5,12 26:22

32:13 35:19,20,20

35:23 37:2 42:6,7

54:10 58:21,21 59:9

59:9,16 61:4,19

62:21 65:18,25

67:18 70:5,24 71:10

71:11 74:11,11,17

planes 12:2 17:21

18:12,13 20:23,24

21:4,6,7,8 23:25

24:7,15,16 26:20

27:2 29:21,21 31:16

31:16,18 32:1,4,5,5

32:7,13,14,16,17,23
800-726-7007 305-376-8800

Veritext Florida Reporting Co.

113

33:16,23 34:4,7,16

34:17 42:12 54:4,5

55:17,17,18 56:6

61:5,23,24 62:1

64:21 65:4,5,10,11

68:8,16,17,25 69:2

69:5 70:10,11,12

74:12 75:2

please 3:11 4:7,10

5:23 9:3,13 11:21

14:13 15:4,6 16:7

55:2 56:21 73:21

77:23 103:15

104:17

pleasure 3:15,17

point 34:23 37:22

47:4,6 92:14 95:3

portion 29:17 57:12

71:4 85:24

position 6:9 7:14,24

30:25 39:22,24

42:23 43:1,4

positions 6:3,6 12:11

possession 28:20

possibility 55:19

possible 96:25

practically 15:3

23:23 35:18 73:2

90:14 93:1 94:17

97:12

prefer 6:18 14:8 18:8

prepared 79:9 94:8

94:13 100:6

preparing 94:5

present 2:7 86:16

92:9

presented 90:22,24

91:2,5

president 12:14,15

13:18 28:20 31:20

43:5,6 48:23 49:5,9

53:1 72:7,8,8,10

81:2,12,13 82:7,8

82:14 83:5,8,12,14

84:21 87:7,8,9

88:11,11 89:2,8

pretty 53:13

previous 39:9,10

48:9 49:5

prior 7:13,20,23 12:5

103:19

private 35:12 61:23

61:24 70:10

probably 40:12 71:14

problem 63:2

procedure 60:25

proceedings 29:17

59:24 71:4 78:1

85:24

produce 21:19

produced 21:23

Profesionales 1:7 6:2

6:15,18,21,22 7:15

18:2 23:3 24:17

26:4,16 27:10,12,21

28:17 30:3,7,16

31:11,21 32:17

36:19 37:20 38:21

39:7,12,15 41:6,10

42:16 47:2 48:23

49:9 53:15 57:4

58:10,23 59:6 60:4

63:17,25 64:2,20

66:3 67:1 71:15

101:1 102:2 103:9

104:9

Professional 27:25

28:18 29:7,14,25

30:12,17 31:1,7,12

36:2 37:6,17 38:13

38:22 39:21 70:9

77:11,12 99:4

promise 71:10

prompt 103:21

provide 24:5 59:9,10

66:15 89:19 91:19

provided 54:11

providing 24:7 96:7

Public 1:18 99:5,9

100:3 101:14

Puerto 39:19 40:21

57:16,22,25 58:1,18

79:9

Pura 10:25 79:13

90:8

purchase 17:15 18:11

29:20 71:10,13,16

71:19 91:12

purchased 46:1

71:14 81:7

purchases 17:15 46:1

purpose 17:12 54:11

purposes 53:22 58:12

58:15 59:4,5,8

pursuant 1:19

P-A-T-I-N 9:14

P-E-R-E-Z 82:12

P.A 2:2 104:7

p.m 98:2 103:17

Q

question 4:4,13 7:22

23:1 39:8,9,10

44:12 47:24 48:5,9

50:10 51:5 68:20

69:21 70:25 71:2

74:2,6,7 75:21

81:16 85:15 87:3,13

94:6,11

questions 3:23 4:7

78:9

quickly 6:16

quite 45:14 52:17

R

Ranger 70:3

rare 70:13

read 29:16 52:10,13

56:22 71:3 78:20

85:23 94:22,23 96:3

102:23 103:16

104:15,20

reading 103:14,19,20

104:15

ready 59:21

really 36:5 52:19

82:9,22,22

reason 33:22 35:22

95:17 102:5

recall 4:23 6:13 8:9

8:11,13,14,16,17,24

8:24 9:2,5 10:11,12

10:12,16,18,21 11:9

12:19 13:1,16,19

14:14 22:14 25:21

25:23 26:2 27:7,18

27:23,23 31:18,23

33:24 36:21 37:12

39:24 40:9,15 41:22

46:15 47:11 52:4

63:19,21 64:23,24

65:1 75:21 80:24

81:9,17,21,25 82:9

86:9,11,13,14,18,20

86:20,21 87:1 90:14

91:8,10 92:20

receive 17:18 23:14

73:3

received 38:6

receives 84:15

recertified 60:24

recess 59:23 77:25

recognize 14:2 15:11

15:16 16:15 17:4

45:8 48:12 49:21,25

60:7 72:2,21,22

75:5,6,25,25 79:7

recollection 80:15

record 13:8 85:17

100:5

recording 32:11

records 13:7

recover 34:24,25

refer 6:17

referenced 103:19

referred 50:3 57:23

referred-to 13:22

15:7 16:8,25 28:7

28:25 36:8 44:6

45:3 47:17 49:17

56:1 60:10 63:7

71:21 72:17 73:23

75:12 78:5 93:21

referring 18:14 57:24

76:7 78:15 89:15

refers 94:5

refreshes 80:14

refuse 91:14

refused 89:18

registered 29:24 65:2

66:3,10

registration 22:8
800-726-7007 305-376-8800

Veritext Florida Reporting Co.

114

64:18 66:1,8,25

regularly 52:24 62:4

62:9,10

regulation 32:6

relate 19:22

related 48:8

relating 16:13

relation 43:9 51:6,8

relationship 79:21,22

82:13 87:19 88:3

relative 100:8,8

remember 4:12 14:9

37:2 87:18

remembered 81:10

remind 92:19

removed 69:7,7,13

89:2,8,21

rent 38:18 59:3,9,16

66:12,12,12,15,22

68:12,13 70:11 73:3

rented 65:16

rents 67:1

repeat 7:22 39:8 71:2

76:24

rephrase 4:5

replaced 83:12

report 85:7,8 100:3

reporter 1:18 3:24

29:16 71:3 85:23

99:5 100:2

REPORTER'S 100:1

REPORTING 1:10

repossessed 33:13,23

33:24 34:2,8 41:20

41:21

represents 67:8

Republic 5:25 12:1,3

12:5,9,24 13:6,9,12

20:9 22:21 23:17

24:9 26:8 29:10

32:2,7 35:21 42:2

54:2 57:21 60:14,17

60:22 61:5,15 62:3

68:1,5 85:2 89:20

request 20:24 24:13

24:13 90:22 91:3,16

93:6

requested 15:2 17:9

17:16 19:4 29:16

57:12 68:10 71:3

85:23 89:11 91:2

95:13 100:4

requests 12:24

requirements 46:4

residence 9:17

resign 89:22 90:25

91:4

resignation 89:21

resigning 93:4

Resolucion 96:2

resolution 91:8 94:22

94:23,24 95:25

96:10,12,13

resolutions 91:5

92:16

resolved 97:3

respond 3:22 4:8

response 3:23 16:19

resumed 29:17 59:24

71:4 78:1 85:24

retire 32:19

return 85:10

returned 48:16

returns 85:1 86:5

95:16

review 100:4

reviewed 14:17

reviewing 36:22

Rico 39:19 40:21

57:16,22,25 58:1,18

79:10

right 8:16 13:16

25:22 28:22 65:11

65:19 80:8 81:25

97:15,23

Robert 2:2,2 3:13

104:6,7,13

Rosa 79:18

roster 13:2 94:5,8,13

94:14,16,19

S

s 75:16

SA 52:13,14 65:17

67:15

SAITH 101:6

sale 91:11

San 57:24 58:11 59:7

Santa 5:21 9:16,20

11:2,4,6,8 13:11

21:4 23:5 24:11

25:8,8 26:10,20

27:16,21 34:1,3,8

34:15 38:8,10 42:8

42:11,13 43:1,5,12

43:13 50:5,16 57:9

65:7 69:25 77:13,15

77:19 81:5,15,18

87:9 88:18 97:1,13

Santo 5:24 8:21,23

24:25 25:11

SAP 39:1,10,13,16

40:4,5 41:11,15,22

42:5,9,11,12 50:3,4

50:9,11,23 51:6,10

51:11,17,19,21

52:10 54:1,13 56:11

56:20 57:1,6,6,20

57:24 62:4,6,8,14

64:4,8 65:16,18

66:2,5,9 67:2,13,14

68:19,21,22,23

70:18 75:7,16 78:13

79:2 81:23 82:24,25

83:1,2 87:2 88:9,16

94:8

SAPAIR 76:14

SAPAIR.com 65:9

76:4,8,13

SAPs 62:1

SAPSA 6:14,17 35:3

46:13 64:16 71:18

74:2,7,9,15 83:11

83:20,25 85:1 86:8

SAP,S.A 66:6

save 97:2

saw 52:18 64:14

89:14 94:17

saying 56:5 80:8

says 48:24 49:23

56:11 58:4 59:13

60:3 77:4

scheduled 23:11

school 11:22

schools 11:24

seal 99:7

second 29:15 55:9

56:16,22 64:13

65:15 66:24 67:11

68:2 91:8,10 94:22

94:23 95:25 96:4,13

secondary 11:22

secretary 28:13 82:6

82:14 83:13 94:5,9

94:13

see 14:13 15:4 19:6

19:13 29:23 30:1

34:23 44:17 45:13

45:13 64:18 94:14

94:16 97:1

seen 14:5 52:17 55:22

55:23 78:21 79:8

93:25

Segunda 96:2

seized 17:10 20:9

65:24,25

sell 29:20 92:23,25

sells 23:13 55:8

sent 38:10

sentence 56:9,10,16

56:22,25 57:9,23

85:22 95:24 96:4,5

separate 11:17 39:13

51:12,13

served 14:14,22

21:14,16

service 23:11 54:11

59:10 66:15

services 27:25 28:18

29:7,14,25 30:13,17

31:1 37:17 38:13

55:20 70:22 71:9

77:12 95:14

Servicios 1:7 6:2,15

6:18,20,22 7:15

18:2 23:2 24:16

26:3,15 27:9,12,20

28:17 30:3,6,10,12

30:16 31:11,21 32:6

32:17 36:18 37:20

38:21 39:6,11,15

41:5,10 42:16 47:2
800-726-7007 305-376-8800

Veritext Florida Reporting Co.

115

48:23 49:9 53:15

57:4 58:10,23 59:5

60:4 63:16,25 64:2

64:19 66:2,25 71:14

72:6 101:1 102:2

103:9 104:9

seven 12:18,20,25

25:25 47:8 60:19

61:14

shampoo 18:12

share 38:22 73:3

shared 38:18

shareholder 81:4

shareholders 8:19,21

8:23 10:6,17 12:16

12:18 13:3 78:24,25

88:15,17,17,21,22

89:8 90:4,5,6 91:13

92:7,10,17 94:6,8,9

shareholder's 94:25

shares 8:8,11 10:10

10:13,15 11:14,16

11:17 13:4 80:21,24

81:7 91:11,12 92:23

92:25 93:2,3,9,16

93:17,18

SHEET 101:4 102:1

SheltAir 37:24 38:2

38:14 40:24 62:13

75:11,17,18

shops 62:22

short 27:3,4,11,15,22

32:25 35:4 59:21,23

66:23 67:7 74:21,22

74:23 96:16

show 16:12 29:4

31:15 36:6 44:10

45:1 47:15 49:15

55:24 72:15 78:3

showing 64:12

shown 65:14 66:23

67:5,10 69:16

shows 13:3 68:3

sic 43:21

sick 59:2

Siddeley 41:23

side 65:8

sign 22:7,14 75:5,7

85:11 103:16

104:20

signature 44:15,18

44:19,19,22,23,25

45:8 47:22 49:11,11

49:21,24,25

signatures 44:13

45:13,16

signed 48:20,22 49:8

85:4,5,10 86:4,6

signing 103:14,19,20

104:15

signs 54:7 86:6

similar 14:6 55:23

95:12

Sincerely 103:22

104:22

single 35:19

sister 79:23 80:9

sit 91:23

situation 83:10

six 47:8 60:16,19

61:9,14 83:3

slight 45:16

small 23:23 27:1

58:22 66:17 70:11

sold 22:19 27:15

67:14,15,15

someplace 69:14

son 10:19 28:16,22

29:9 31:10 36:3

43:16 90:16

son's 29:20 43:24

45:17 77:11

soon 16:2,20

sorry 13:12 24:15

44:22 66:2 82:2

92:7 94:6

sort 58:20 97:14

southwest 2:3 4:23

104:7

space 38:22

Spanish 2:8 3:3,4

26:5 45:15 56:25

57:13 90:1

speak 6:12,16 8:9

specific 95:13

specifically 68:10

spell 9:13 25:6 55:2

82:11

spelling 80:12

split 13:17

SS 99:3 101:9

start 79:5

started 7:1 12:1

60:18 85:15

state 1:19 3:11 28:13

99:2,5,9 101:8,15

102:21

statements 17:8

95:15

states 4:25 5:2 12:6

18:9 20:4 21:22

37:21 47:1 60:5

61:16 96:6

stating 85:14

stenographic 100:5

stenographically

100:3

stock 8:4,5,6,7,10

10:13 13:15 40:8,11

43:11,13,14 78:14

79:15,16,18 80:10

81:18 92:21

stockholders 40:13

78:13

stockholdership

80:15

stocks 13:17 81:15

stop 103:15

stopped 65:23

strategy 57:18

stream 26:22

street 2:3,5 69:14

103:2,7,16 104:2,7

strike 13:19

study 11:23

subject 102:24

subpoena 14:14,22

21:9,14 89:12,13,24

subscribed 101:11

substance 102:24

substantial 93:14

substituting 92:18

sudden 85:14

sufficient 103:18

suffix 43:21

suggesting 91:3

suggestion 89:25

90:2,22,24 94:7

suggests 94:12

Suite 1:10 2:5 73:16

73:17,18 103:2,7,15

104:2

supervise 97:16

supervision 61:1

100:7

sure 3:18 11:20 30:6

37:11 45:12 46:20

48:1 55:4 63:14

69:22 71:1 74:5

77:24 80:11 87:16

90:19 96:19

Surely 49:4 95:1

suspended 46:10

sworn 3:8 99:6

101:11

S-H-E-L-T 38:1

S-H-O-R-T 27:4

S.A 1:7 6:2,21 7:15

18:2 23:3 24:17

26:4,16 27:10,21

28:17 30:3,16 31:12

36:19 37:20 41:6

42:17 47:2 53:16

57:4 59:6 60:4

63:25 64:3,20 66:3

66:9 67:2,13,14

68:21,23 71:15 75:7

75:16 78:13 79:2

81:23 82:24 88:9

94:8 101:1 102:2

103:9 104:9

T

tabbed 78:10

tabs 44:12

tail 69:6,12

take 3:24 4:2 16:3

22:5 35:24 38:11

46:8,9 54:4 55:15

55:17 56:5 59:20

73:20 74:20 78:19

91:21 96:16 97:25
800-726-7007 305-376-8800

Veritext Florida Reporting Co.

116

taken 1:17 42:3 72:6

101:2 102:3 103:10

104:10

talking 25:14 48:7

61:16 80:25 87:21

Tamiami 71:12,16

tass 32:7

tax 85:1,10 86:5

95:16

taxes 61:6 86:6

technical 18:10,16

19:8,9,19

tell 4:4 31:16 45:8

47:22 51:21,22 56:9

58:18 62:14 74:2

78:13 80:14 89:23

91:9

telling 81:10 91:3

ten 13:1 25:21 32:4

32:24 60:18 61:12

74:18 80:6 97:4

term 24:3 76:24

testified 3:8

testifying 3:20

testimony 27:19

Thank 3:16

thing 15:22 18:13

20:1 23:18 29:21

35:8,17 38:9 39:6

48:6 54:3 55:18

58:24 59:12 67:6

96:24,24

things 14:9 17:23

33:5 48:14 97:16

think 11:18,19,20

18:20 27:3,7 28:23

34:13 37:1,11 41:14

41:24 42:22,25

43:15 50:12,12,13

69:25 70:1 75:24

76:25 77:14,18,22

79:11,16,20,20

80:11,17,23 81:19

81:20 82:2,3 85:19

87:3,14,15 90:14,17

90:17 91:7,11 92:13

92:13,18 94:3

thought 48:8 51:24

81:10

three 31:17,18 42:2,8

60:20 64:21

time 5:14,19 6:5 7:18

20:18,23 21:22

27:10 35:2 42:18

46:6 49:10 52:18,19

73:18 81:3,4 82:4

83:21 86:10 90:5

92:14 95:3 97:11,11

97:17,22 103:18

times 35:25 47:7,8

50:25 84:23,25

title 30:25

titles 6:3,6 12:11

84:13

today 14:11,25 16:23

21:19,23 27:19

told 24:20 68:4 87:7

89:7

tongue 18:6

top 64:12 77:5

town 97:4,8,10

TRAKTMAN 103:1

104:1

transcript 29:17

57:12 71:4 85:24

100:4,6 101:5 102:4

102:23 103:13,16

103:17,20 104:14

104:15,19,20,21

transferred 27:20

translate 3:3 14:4

21:15 57:8

translated 14:17

translation 76:24

85:16

translator 18:3 85:20

Transporte 87:20,24

88:2

trial 60:25

tribunal 96:7,9

Trident 70:21 71:8

Trim 38:18,19 46:22

48:2,3 75:10

Tropical 68:14,15,15

true 80:17 100:5

101:5 102:23

trying 86:20

turn 95:2

Twin 27:1 32:25 33:2

33:3,9 35:4 67:4

two 16:2 17:25 18:19

19:6 30:5 33:1

34:10,14 35:11

42:19 44:12,14

47:21,23 48:11

52:23 54:18 55:13

60:23 67:16 69:2

74:23 83:21 84:5,12

84:12 91:5 92:16,18

96:14

type 18:13 22:24

26:17,20 29:21 38:9

54:3 55:18 61:18

62:2

T-A-S-S 32:9

U

Um-hum 88:23

understand 3:18,21

3:25 4:4 14:18,21

18:6 23:1 41:9

43:20,22 50:10

52:23 68:20 94:11

understanding 46:23

55:16 56:20 96:8

understood 21:18

United 4:25 5:2 12:5

20:4 21:22 37:21

47:1 60:5 61:16

unrelated 51:2

urinate 92:15

use 15:24 16:17 18:3

18:25 24:4 32:17

50:25 52:6 54:7

57:15,25 58:1,2

61:22,23,23,24,24

61:25,25 68:9 72:4

72:7 76:16

USFAA 23:4

U.S 5:4,6 9:18 11:23

11:25 21:24 39:5

54:10 55:21 60:18

60:21 61:2,7,9,10

65:2,25 66:8 77:21

V

VELARDE 2:8 3:2

Venezuela 57:17

verbal 3:23

verbally 92:2

VERITEXT 1:10

103:1 104:1

vice 43:5 81:13 87:8

visit 55:9

voice 32:11

vote 90:20,21,23

96:10,11,12,13

vs 1:6 101:1 102:2

103:9 104:9

W

waive 104:15

waived 103:20

want 5:16 10:22

16:12 18:4 22:6

39:21 45:15 96:3,16

96:21,24

wanted 34:19 46:9

wants 58:17

wasn't 30:9,14 33:21

91:25

water 77:23

way 18:11 27:24

74:20,20

Wayne 46:19 73:1

website 51:17 52:10

52:13,15 53:2,5,10

53:17,25 54:12,14

55:14 58:13 65:12

66:24 67:5 76:10

websites 52:25 55:21

55:22

Wells 70:21 71:8

went 11:25 14:19

55:21,22 62:13

weren't 30:8 83:5

West 1:10 2:5 103:2

103:7,16 104:2

wet 66:18,19,20

we'll 4:1

we're 35:24 40:9,22

42:7 61:16 80:25

we've 16:12 29:4
800-726-7007 305-376-8800

Veritext Florida Reporting Co.

117

35:25 40:5 44:10

45:2 55:24 63:4

wife 10:20 11:15,17

13:14 22:9 25:24

40:7 43:10,11 45:11

47:24 81:7,14 83:13

87:3 93:8 96:10

wings 69:6

wish 96:23,23,25

withdraw 94:6

witness 2:11 3:7

29:19 36:11 43:24

56:4 57:1,14 63:15

69:23,25 75:23 77:2

77:22 78:20 79:3

81:17,20 86:1 87:15

96:23 97:9,12,16

99:5,7 100:4,6

104:14,17,19,20

word 50:25

work 7:14 50:19,21

57:16 59:18 86:23

97:5

worked 86:10

working 34:23

WRITE 102:4

wrong 75:3

wrote 81:11

X

X 2:10

Y

yeah 18:16 21:20

33:12 55:15 60:9

69:6 73:10 76:21

79:23 82:17 94:15

94:23

year 6:8 37:25 47:9

52:22 58:14

years 4:20 5:5 6:12

6:13,23 7:8,9 16:2

17:8 19:3 20:14

26:11,12,18 27:17

27:18 31:17,18

32:21,21 37:24 42:2

42:8,20 48:18 52:23

60:18 64:11 69:2

73:19 74:18 77:8

80:6 82:19,19 86:16

Yep 9:10,25 44:25

York 16:2,21 33:5,6

Z

Zip 4:16

$

$1,000 23:19 83:2

$2 33:19

$200 23:22

$5,000 17:17

#

#385120 101:17

0

0 2:12

03 1:3

08-16913 1:3

1

1 2:15 13:20,23 21:10

57:19 78:15,17

80:13 89:15 100:5

1st 103:11 104:11

10 2:19 45:2,4,7

10:00 1:12

100 23:21 40:8

1020 1:10 103:2,15

104:2

104 100:5 103:11

104:11

108 2:5 103:7

11 2:20 47:16,18

49:13

11TH 1:1

12 2:20 26:11,18

47:16,18 49:12,13

125 41:23 64:10

129 22:25 23:3

13 2:15,21 49:13,16

49:18 73:17

135 39:4

14 2:21 55:25 56:2,8

14,500 80:21

15 2:15,22 26:11,19

44:24 60:3,11

16 2:16,16,22 63:5,8

17 2:23 71:20,22

172 69:16,23

18 2:23 33:18 72:16

72:18 75:5,13 94:2

18th 1:11 101:2

102:3 103:10

104:10

18890 2:3 104:7

19 1:10 2:24 73:21,24

103:2,16 104:2

1900 41:14

1900C 30:23 65:14

1981 57:5

1991 57:2

1997 79:12 80:25

2

2 2:15 15:5,8,12

18:21,21 19:21

2:34 98:2

2:35 96:19

20 2:24 75:3 77:4

200 27:1

2007 17:9

2008 17:9 74:8,9,15

2009 94:2 99:10

101:16

2010 1:11 99:7

100:10 101:2,12

102:3 103:5,10,11

104:5,10,11

207 74:12

208 22:13

21 2:25 78:4,6,18

79:7 80:14

22 93:20,22

23 44:16,17,18

24 9:12 99:10 101:16

25 7:9 9:12 44:16,17

44:20,21 64:6

264 2:3 104:7

28 2:17,17

3

3 2:12,16 16:7,9,13

19:1

30 6:23 26:18 84:9

305 103:3,4 104:3,4

31st 99:7 100:10

103:5 104:5

32 10:4

327 73:16,18

33031 2:3 104:8

33130 1:11 103:3

104:3

33131 4:17

33144 2:6 103:7

35 63:11,16

36 2:18

360 27:3,5 66:23

74:21,22

360s 74:23

371-1884 103:3 104:3

377-1100 103:4 104:4

4

4 2:16 16:24 17:1,5

18:15,17,18 19:10

4,000 17:17

4:00 103:17

44 2:18

45 2:19,19

47 2:20,20

49 2:21

5

5 2:17 28:6,8,11

29:24

50 93:8,11

520 4:16

56 2:21

6

6 2:17 28:24 29:1,5

67:4

60 2:22 84:2,7

624 74:9

63 2:22

658 74:15,17

7

7 2:18 36:7,9,23,24

74:9

71 2:23

72 2:23

720 74:10,10
800-726-7007 305-376-8800

Veritext Florida Reporting Co.

118

727 12:2

73 2:24

760 74:11

77 2:24

78 2:25

7950 2:5 103:7

8

8 2:18 44:5,7,11

8:00 103:17

9

9 2:19 45:2,4,7

914 4:16

972 70:20