Case 1:13-cv-06326-TPG Document 281-1 Filed 05/13/15 Page 1 of 386
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`Page 1
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` UNITED STATES DISTRICT COURT
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` SOUTHERN DISTRICT OF NEW YORK
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`--------------------------------X
`UNITED STATES OF AMERICA,
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` Plaintiff,
`
` VS. Case No. 1:13-CV-06326(TPG)
` ECF CASE
`PREVEZON HOLDINGS LTD.,
`et al.,
`
` Defendants.
`--------------------------------X
`
` VIDEOTAPED DEPOSITION
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` OF
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` WILLIAM F. BROWDER
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` Wednesday, April 15, 2015
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` 30 Rockefeller Plaza
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` New York, New York
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`Reported by:
`AYLETTE GONZALEZ, RPR, CLR, CCR
`JOB NO. 91742
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`Page 1
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` UNITED STATES DISTRICT COURT
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` SOUTHERN DISTRICT OF NEW YORK
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`--------------------------------X
`UNITED STATES OF AMERICA,
`
` Plaintiff,
`
` VS. Case No. 1:13-CV-06326(TPG)
` ECF CASE
`PREVEZON HOLDINGS LTD.,
`et al.,
`
` Defendants.
`--------------------------------X
`
` VIDEOTAPED DEPOSITION
`
` OF
`
` WILLIAM F. BROWDER
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` Wednesday, April 15, 2015
`
` 30 Rockefeller Plaza
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` New York, New York
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`Reported by:
`AYLETTE GONZALEZ, RPR, CLR, CCR
`JOB NO. 91742
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`TSG Reporting - Worldwide 877-702-9580
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`Case 1:13-cv-06326-TPG Document 281-1 Filed 05/13/15 Page 2 of 386
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`Page 2
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` DATE: April 15, 2015
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` TIME: 9:30 a.m.
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` Videotaped Deposition of WILLIAM F.
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`BROWDER, held at the offices of BAKER BOTTS,
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`LLP, 30 Rockefeller Plaza, New York, New
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`York 10112, pursuant to NOTICE, before
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`AYLETTE GONZALEZ, a Registered Professional
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`Reporter, Certified LiveNote Reporter,
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`Certified Court Reporter and Notary Public
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`of the States of New York and New Jersey.
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`Case 1:13-cv-06326-TPG Document 281-1 Filed 05/13/15 Page 3 of 386
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`Page 3
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`A P P E A R A N C E S:
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`UNITED STATES DEPARTMENT OF JUSTICE
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`Counsel for Plaintiff
`
` One St. Andrew's Plaza
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` New York, New York 10007
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`BY: PAUL MONTELEONI, ESQ.
`
`BY: ANDREW ADAMS, ESQ.
`
`BAKER & HOSTETLER
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`Counsel for Defendants
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` 1050 Connecticut Avenue, N.W.
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` Washington, District of Columbia 20036
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`BY: MARK CYMROT, ESQ.
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`BY: PAUL LEVINE, ESQ.
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`BY: MORITZ ABRAMOVITZ, ESQ.
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`///
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`Case 1:13-cv-06326-TPG Document 281-1 Filed 05/13/15 Page 4 of 386
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`A P P E A R A N C E S: (Continued)
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`BAKER BOTTS
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`Counsel for Defendants
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` 30 Rockefeller Plaza
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` New York, New York 10112
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`BY: SETH TAUBE, ESQ.
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`BY: JOYCE YOUNG, ESQ.
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`KOBRE & KIM
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`Counsel for the Witness
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` 800 Third Avenue
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` New York, New York 10022
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`BY: MICHAEL KIM, ESQ.
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`BY: LINDSEY WEISS, ESQ.
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`ALSO PRESENT:
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` LEM LATTIMER, Videographer
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` THE VIDEOGRAPHER: This is the
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`Tape No. 1 for the videotaped
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`deposition of William Browder in the
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`matter of United States of America vs.
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`Prevezon Holdings Ltd., et al.
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` We are now going on the record.
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`The time is 9:35 a.m.
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` Will counsel please state their
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`appearances for the record.
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` MR. KIM: This is Michael Kim and
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`Lindsay Weiss of Kobre & Kim for the
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`witness, William Browder.
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` MR. MONTELEONI: Paul Monteleoni
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`and Andrew Adams for the Southern
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`District of New York U.S. Attorney's
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`Office.
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` MR. TAUBE: Seth Taube and
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`Joyce Young, Baker Botts, for
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`Defendants.
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` MR. CYMROT: Mark Cymrot and
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`Paul Levine for Defendants.
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` THE VIDEOGRAPHER: Will the Court
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`Reporter please swear the witness in.
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` ********************
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` WILLIAM F. BROWDER (4/15/15)
`
` W I L L I A M F. B R O W D E R,
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` called as a witness, having been
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` first duly sworn by a Notary Public
`
` of the State of New York, was
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` examined and testified as follows:
`
` EXAMINATION BY
`
` MR. CYMROT:
`
` Q. Mr. Browder, my name is
`
`Mark Cymrot. I represent the Defendants in
`
`this action.
`
` You're here pursuant to Subpoena?
`
` A. I'm sorry, is that a question?
`
` Q. Yes. Are you here pursuant to a
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`Subpoena?
`
` A. Yes.
`
` Q. And a court order?
`
` A. I think so.
`
` Q. Let me show you what I'll mark as
`
`Browder Exhibit 1.
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` MR. KIM: Sorry, Mark, can I do
`
` the confidentiality?
`
` MR. CYMROT: Oh, I'm sorry, yes, I
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` skipped that. Yes.
`
` MR. KIM: All right. Sorry about
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` WILLIAM F. BROWDER (4/15/15)
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`that.
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` So this is Michael Kim. So we
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`still do not have a Confidentiality
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`Agreement or Order from the court.
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`I'm not faulting anybody, that's just
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`objectively the situation we're in.
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` It would be our preference to
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`obviously have this deposition only
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`when covered by a court ordered
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`Confidentiality Order. But given that
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`we're under Subpoena, we will proceed
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`in the manner that -- that Plaintiff
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`wishes.
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` And as I understand it, and I
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`discussed this with Mr. Cymrot before
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`the deposition began, there are other
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`people listening in who, I believe,
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`has identified three names, and I'll
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`ask him to just state what his
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`understanding is for the record.
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`We -- we, on Mr. Browder's part, were
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`made to understand that certain client
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`representatives would be attending.
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` I did not understand the word
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` WILLIAM F. BROWDER (4/15/15)
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`"attending" to mean unnamed persons or
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`persons I can't verify who's listening
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`in or listening in. That's fine.
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`Given we're under Subpoena, we're
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`willing to proceed based on the
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`understanding that the contents of
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`this Subpoena are covered by the same
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`arrangements that was in the
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`March 20th letter from us, which was
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`subsequently agreed to by Defendants,
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`with the exception that the client
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`representatives who will be identified
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`as listening in would be allowed to
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`access this deposition on the
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`undertaking by all that the contents
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`of the deposition will not be passed
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`on to any other persons pending
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`further order of the Court.
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` And I think after the deposition
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`we understand we'll try to get the
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`Confidentiality Agreement finalized
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`and submitted to Judge Griesa as soon
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`as we're able to.
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` MR. CYMROT: Right. I would just
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` WILLIAM F. BROWDER (4/15/15)
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`say that we've gotten this far in our
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`discussions as the point where the
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`judge has before him on the Government
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`confidentiality proposal the same
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`issues, so they'll be resolved when he
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`resolves them.
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` In terms of people looking in,
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`there are other attorneys and others
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`associated with our law firm;
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`Gabriella Volshteyn as client
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`representative, Nataliya Vaselnitskaya
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`and Denis Katsyv, the client
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`representatives. And those are the
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`ones I'm aware of.
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` But anybody looking in will be
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`subject to the same restrictions, that
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`it cannot be used for any other
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`purpose other than this lawsuit as we
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`set forth in that letter.
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` MR. KIM: Just one question. Are
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`you able to verify who's actually
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`listening and who's not to a degree of
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`certainty.
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` MR. CYMROT: I am not sitting
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` WILLIAM F. BROWDER (4/15/15)
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` here, no.
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` MR. KIM: Okay. So we object to
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` proceeding, but given we're under
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` Subpoena, we'll just note the
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` objection and proceed as we just
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` discussed. So thank you. Sorry to
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` interrupt. Proceed.
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` MR. CYMROT: Okay. Exhibit 1.
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` All right. So I'm marking for
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` identification as Browder Exhibit 1 a
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` letter dated December 4, 2012 to the
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` New York County District Attorney's
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` office, I believe Mr. Browder signed
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` this, and attachments.
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` Let's get the Court Reporter to
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` initial it, I'm sorry.
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` Why don't you use this copy which
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` has tabs.
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` (Browder Exhibit 1, document Bates
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` stamped PREV_000003127_001 through
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` '166 was marked for identification, as
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` of this date.)
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`BY MR. CYMROT:
`
` Q. All right. Mr. Browder, can you
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` WILLIAM F. BROWDER (4/15/15)
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`tell us what that letter is?
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` A. Can I correct a statement that you
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`made, is that --
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` Q. I guess you can.
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` A. This is not a letter that I signed.
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` Q. Who signed it?
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` A. This was signed by Brown Rudnick,
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`LLP.
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` Q. Do you recognize that as a letter
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`you authorized?
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` A. This was a letter that I'd
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`authorized, yes, on -- yeah.
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` Q. Okay.
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` MR. CYMROT: And let me mark as
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` Exhibit 2 the Verified Claimant, the
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` original. The original.
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` BY MR. CYMROT:
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` Q. So how did -- while we're waiting
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`for that, how did that letter come about,
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`Mr. Browder?
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` A. This letter came about based on
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`a -- an investigation that we did into the
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`proceeds of the Magnitsky crime.
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` Q. And who is "we"?
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` WILLIAM F. BROWDER (4/15/15)
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` A. My -- my legal team and myself.
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` Q. And who's your legal team or who
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`was your legal team at the time?
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` A. My legal team started out with
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`John Moscow from BakerHostetler and included
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`Neil Micklethwaite from Brown Rudnick,
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`Jonathan Weiner from APCO, John Ashcroft from
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`Ashcroft Associates, various Russian lawyers.
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` Q. Brown Rudnick?
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` A. Brown Rudnick; Neil Micklethwaite I
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`mentioned.
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` Q. Okay. And who at Hermitage was
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`working on this?
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` A. Pretty much Vadim Kleiner,
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`Ivan Cherkasov.
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` Q. And yourself?
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` A. And my- -- well, yeah.
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` Q. You were working on it, right?
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` A. Yeah.
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` Q. So you sent this letter to the U.S.
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`Attorney, and what happened next, or it
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`actually went to the State District Attorney,
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`correct?
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` A. So John Moscow introduced me to
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` WILLIAM F. BROWDER (4/15/15)
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`Adam Kaufmann, who was head of investigations
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`division of the New York District Attorney's
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`office. I walked it into his office on the
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`4th of December 2012 or maybe possibly one or
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`two days later, and then they took up the
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`case.
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` Q. John Moscow wasn't representing you
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`at this time?
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` A. No, he wasn't, but he did introduce
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`me to Adam Kaufmann earlier.
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` Q. When was that?
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` A. I can't recall exactly, but one or
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`two -- I met Adam Kaufmann through John Moscow
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`at the Cambridge crime conference in
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`Cambridge, England.
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` Q. And when was that?
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` A. I can't recall exactly.
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` Q. And John Moscow represented you
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`for, what, six months in 2007 and '8, was it?
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` A. And sort of informally afterwards,
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`after we -- after he got called on to another
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`case and didn't have time for us.
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` Q. Well, all right, we don't need to
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`get into the subject, but isn't it true that
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` WILLIAM F. BROWDER (4/15/15)
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`you discharged John Moscow and BakerHostetler?
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` A. I wouldn't -- I wouldn't -- no.
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` Q. You stopped relying upon
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`BakerHostetler's advice, correct?
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` A. BakerHostetler -- John Moscow
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`stopped returning our phone calls because he
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`got busy on another case.
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` Q. And you stopped relying upon his
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`advice?
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` A. No, not true.
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` Q. Never, to this day?
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` A. Well, when he became adverse to us
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`in this case, obviously his advice was no
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`longer objective.
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` Q. I see. And when was the last time
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`before -- what would it be, December,
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`November of 2013 that you spoke to
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`John Moscow?
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` A. I don't recall.
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` Q. Years before that?
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` A. I think it was at the Cambridge
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`crime conference that I last spoke to him.
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` Q. Which was when?
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` A. I -- I don't remember which --
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` WILLIAM F. BROWDER (4/15/15)
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`Page 15
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`which year it was.
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` Q. 2012, 2011?
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` A. I'd have to --
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` Q. No idea?
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` A. I would have to look at the -- at
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`the Cambridge crime conference schedule and
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`see, see when he was there and Adam Kaufmann
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`was there.
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` Q. So at the time of this letter,
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`December 4, 2012, you walked into the New York
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`County District Attorney's office; is that
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`what I understand?
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` A. That's correct.
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` Q. With whom?
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` A. On my own.
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` Q. I see. And you presented this
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`letter?
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` A. Correct.
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` Q. And what was that -- what happened
`
`after that?
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` A. At that point they accepted the
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`letter.
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` Q. And was there a conversation?
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` A. And then perhaps a few weeks later
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`I was informed that the -- they were taking up
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`the case.
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` Q. In the New York County District
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`Attorney's office?
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` A. That's correct.
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` Q. All right. And what happened in
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`terms of the case after that?
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` A. They -- I'm trying -- I can't
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`remember the name of the investigator --
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`started to do some work on it and then
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`eventually decided that it was a real case.
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` Q. And when did it get to the U.S.
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`Attorney's Office?
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` A. After that.
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` Q. When after that?
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` A. I don't recall.
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` Q. How much work was done in the
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`D.A.'s office in New York?
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` A. I don't work in the D.A.'s office.
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` Q. How much work did they tell you
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`they did?
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` A. They don't -- I'm not a member of
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`their staff, they don't -- they don't tell me
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`what they're doing or not doing.
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` WILLIAM F. BROWDER (4/15/15)
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` Q. After the first conversation, did
`
`you have additional conversations with the
`
`investigator?
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` A. I did.
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` Q. How many?
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` A. I can't recall.
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` Q. Did you record them?
`
` A. No.
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` Q. Did you take notes?
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` A. No.
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` Q. So what were they about?
`
` A. Just status reports.
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` Q. What did he tell you about the
`
`status?
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` A. They were working on it.
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` Q. Nothing more?
`
` A. That it was a real case.
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` Q. How long did the conversations
`
`last?
`
` A. I don't recall.
`
` Q. No idea; hour, two hours, three
`
`hours?
`
` A. No.
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` Q. Less than that?
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` A. Less than that.
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` Q. Fifteen minutes?
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` A. Perhaps. I don't recall.
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` Q. How many of these conversations did
`
`you have?
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` A. I don't remember exactly.
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` Q. All right. When did it go to the
`
`U.S. Attorney's Office, approximately?
`
` A. After the -- sometime after we
`
`submitted this, but I -- but I can't remember
`
`the dates.
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` Q. I see. How long before it was
`
`filed in federal court?
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` A. It was filed in federal court I
`
`think a year later or some- -- maybe in the
`
`fall of 2013.
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` Q. It was filed in, I believe,
`
`November or December of 2013, so it's about a
`
`year later; so how long before the Complaint
`
`was filed did you first have your conversation
`
`with the U.S. Attorney's Office?
`
` A. Quite a bit.
`
` Q. Months?
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` A. Yes.
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` Q. Nine months?
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` A. Perhaps.
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` Q. So it was about three months in the
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`D.A.'s office and then nine months in the U.S.
`
`Attorney's Office?
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` A. I don't know the timing.
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` Q. All right. Who did you talk to in
`
`the U.S. Attorney's Office?
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` A. I spoke to Sharon Levin,
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`Paul Monteleoni.
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` Q. Did you speak to Todd Hyman, the
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`investigator?
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` A. He might have been present, but my
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`first contact was with Sharon Levin.
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` Q. All right. And what were your
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`conversations with Sharon Levin?
`
` A. That they had taken over the case
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`from the New York D.A.'s office.
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` Q. Anything else?
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` A. That they were proceeding with the
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`case.
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` Q. Did they tell you that they were
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`investigating?
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` A. They weren't sharing with me their
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`internal conversations.
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` Q. Did they ask you for more
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`information?
`
` A. Not at that meeting.
`
` Q. The first meeting?
`
` A. At the first meeting they just --
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`it was just a very simple meeting.
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` Q. So you were there alone?
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` A. I don't remember if anyone was
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`there with me or not.
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` Q. I see. And there were three people
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`on the side of the United States?
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` A. There were more than three people,
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`but I don't know who else was there.
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` Q. I see. Did there come a time when
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`they --
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` A. Actually let me correct that.
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`Somebody from the New York D.A.'s office was
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`there as well.
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` Q. Okay. And who was that?
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` A. That -- I don't remember the name
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`of the person.
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` Q. Investigator or a lawyer?
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` A. I don't know.
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` Q. Did they give you cards?
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` A. I don't remember.
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` Q. How many meetings between the first
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`meeting and the filing of the Complaint did
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`you have with the U.S. Attorney's Office?
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` A. I can't say for certain, but I
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`think there was maybe one more in-person
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`meeting.
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` Q. Other people from Hermitage or your
`
`lawyers meet with the U.S. Attorney's Office
`
`before the case was filed?
`
` A. No.
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` Q. So it was just you?
`
` A. Yes.
`
` Q. Did there come a time when they
`
`asked you for more information other than
`
`what's in this letter?
`
` A. Yeah.
`
` Q. When was that?
`
` A. Spring or summer of 2013, I can't
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`remember exactly.
`
` Q. What did they ask you?
`
` A. They asked -- well, they didn't --
`
`didn't ask me personally; they asked people on
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` WILLIAM F. BROWDER (4/15/15)
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`my team for more information.
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` Q. Who did they ask?
`
` A. Vadim Kleiner.
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` Q. How did they get to meet people on
`
`your team if they weren't at the meetings?
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` A. I maybe introduced them on the
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`phone, I don't re- -- I don't recall.
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` Q. So they asked Mr. Kleiner for more
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`information?
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` A. Yes.
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` Q. What more information?
`
` A. I wasn't part of those
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`conversations.
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` Q. Did their files at Hermitage about
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`what was given the U.S. Attorney's Office?
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` A. Surely there are files.
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` Q. But you haven't given them to us in
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`response to the Subpoena; is that right?
`
` A. I don't know.
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` Q. Who's responsible for that?
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` A. There's a whole team of people
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`responsible for that.
`
` Q. Well, you're ultimately responsible
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`for your Subpoena to you, isn't it?
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` A. Subpoena is to me.
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` Q. Are you supervising the production
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`of the documents?
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` A. I've got a whole team of people
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`who's working on that, and they report to me
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`from time to time.
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` Q. I see. And have they reported to
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`you that they provided us with files that you
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`gave the U.S. Attorney's Office?
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` A. They've reported to me lots of
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`stuff, but I -- you know, I don't know the
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`details.
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` Q. I see. So you have no idea what
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`you gave the U.S. Attorney's Office --
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`Hermitage gave the U.S. Attorney's Office in
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`response to their request; is that right?
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` MR. KIM: Objection to form.
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` MR. CYMROT: Yeah, I'll restate
`
` it.
`
` Q. You have no idea what Mr. Kleiner
`
`gave to the U.S. Attorney's Office in response
`
`to their request; is that correct?
`
` A. That's correct.
`
` Q. And he didn't tell you at the time?
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` A. He told me he was in conversations,
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`but he didn't tell me specifically what he was
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`providing.
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` Q. Did he tell you what the substance
`
`of the conversations was?
`
` A. Just backing up different parts of
`
`the Complaint.
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` Q. What parts of the Complaint?
`
` A. I don't know.
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` Q. Did you see a draft of the
`
`Complaint before it was filed?
`
` A. I think we might have, but I can't
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`remember for sure.
`
` Q. Did you tell the U.S. Attorney's
`
`Office that the allegations in the Complaint
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`were accurate as far as you knew?
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` A. I was never asked or never told.
`
` Q. Did you ever see anything that you
`
`saw in -- you've read the Complaint, correct?
`
` A. I have.
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` Q. And did you see anything that --
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`that you felt was inaccurate?
`
` A. No.
`
` Q. So as far as you're concerned,
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`everything in the original Complaint was
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`accurate?
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` A. It seemed to me that it was
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`accurate. I should point out that some --
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`there -- there are parts of the Complaint that
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`I wasn't familiar with that I wouldn't -- not
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`know about.
`
` Q. But the parts that you were
`
`familiar with, as far as you're concerned is
`
`accurate?
`
` A. The parts I was familiar with
`
`are -- I was thinking is accurate.
`
` Q. For instance, Mr. Magnitsky is an
`
`attorney; you think that's accurate?
`
` A. He was my attorney.
`
` Q. He was your attorney?
`
` A. Yes.
`
` Q. Acting as --
`
` A. Acting in court representing me.
`
` Q. I see. And he had a law degree in
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`Russia?
`
` A. I'm not aware that he did.
`
` Q. I see. And -- and he had -- he
`
`went to law school?
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` A. No.
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` Q. He didn't go to law school, he
`
`didn't have a law degree, but he was your
`
`lawyer?
`
` A. And he represented me in court.
`
` Q. I see.
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` A. I should say represented Hermitage
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`Fund Companies in court.
`
` Q. Okay. And he did other work; he
`
`gave you advice on taxes?
`
` A. Correct.
`
` Q. And he was given a power of
`
`attorney to do certain things for certain of
`
`your companies, correct?
`
` A. I believe so.
`
` Q. All right. So he acted not just as
`
`an attorney, he acted in other capacities?
`
` MR. KIM: Objection to form.
`
` Q. Do you know who drafted the
`
`Complaint?
`
` A. I would imagine that the U.S.
`
`attorney drafted the Complaint.
`
` Q. And you had no idea what
`
`investigation the U.S. attorney did beyond the
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`information that you and Mr. Kleiner gave to
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`the U.S. attorney?
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` A. I don't work in the U.S. Attorney's
`
`Office.
`
` Q. Well, you're aware that Mr. Hyman
`
`says that's the investigation that was done,
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`took documents from your company, talked to
`
`you and Mr. Kleiner, so this case arises from
`
`your information; that's news to you?
`
` A. I don't understand the question.
`
` Q. You didn't understand when the
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`Complaint was being filed that it was based
`
`upon information that you and Mr. Kleiner
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`provided to the U.S. Attorney's Office?
`
` A. Yes.
`
` Q. You understood that?
`
` A. Yeah.
`
` Q. All right. Let me show you the
`
`Complaint we're talking about that I'll mark
`
`as Browder Exhibit 2. It's a Verified
`
`Complaint. It was filed on
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`September 10, 2013.
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` (Browder Exhibit 2, Verified
`
` Complaint, Filed on 9/10/13 was marked
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` WILLIAM F. BROWDER (4/15/15)
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` for identification, as of this date.)
`
` BY MR. CYMROT:
`
` Q. So Exhibit 2 is the Complaint we've
`
`been talking about, correct?
`
` A. This?
`
` Q. Yes.
`
` A. Yes.
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` Q. And that's the Complaint that you
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`read and saw nothing inaccurate in it; is that
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`right?
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` MR. KIM: Objection to form.
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` Q. You could answer.
`
` A. Sorry?
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` MR. KIM: When I say objection to
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` form, that doesn't mean don't answer;
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` it's just a legal objection I'm
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` stating to the form of the question.
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` THE WITNESS: Right.
`
` A. If -- if we go back to what I said
`
`before, the parts of the Complaint that I'm
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`familiar with are accurate.
`
` Q. And we're talking about that
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`Complaint, Exhibit 2, right?
`
` A. Correct.
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` WILLIAM F. BROWDER (4/15/15)
`
` Q. Going back to Exhibit 1, which is
`
`the letter to the D.A.'s office, all right?
`
` If you take a look at Tab 8.
`
` A. Tab A?
`
` Q. Eight.
`
` A. Eight.
`
` Q. Can you tell us what these
`
`documents are, the cover says "Bank
`
`Transactions"?
`
` A. Yeah.
`
` Q. By the way, if you find some
`
`illegible, that's because that's the way it
`
`was produced to us.
`
` So let's start with '3128096. Can
`
`you tell me what that is?
`
` A. Where is this?
`
` Q. It's the first document. If you
`
`look at the lower right-hand corner, it has
`
`numbers.
`
` A. I don't know.
`
` Q. Well, who put these documents
`
`together?
`
` A. My team.
`
` Q. Who on your team?
`
`TSG Reporting - Worldwide 877-702-9580
`
`
`
`Case 1:13-cv-06326-TPG Document 281-1 Filed 05/13/15 Page 30 of 386
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`Page 30
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` WILLIAM F. BROWDER (4/15/15)
`
` A. My lawyers, Vadim Kleiner.
`
` Q. And which lawyers?
`
` A. My -- I've got a team of Russian
`
`lawyers. I think Neil nickel weight was
`
`involved, his people on his team.
`
` Q. Okay. So you have no idea what
`
`this is, it says "Refund decision"; you have
`
`no idea what it is?
`
` A. No.
`
` Q. And page '97, '097, "Refund
`
`decision," you have no idea what that is?
`
` A. No.
`
` Q. '98, '99, going all the way through
`
`'102, you have no idea what they are?
`
` A. No.
`
` Q. So when it comes to a document
`
`that's in Russian -- do you read Russian?
`
` A. No.
`
` Q. Who do you rely upon if the
`
`translation is in Russian?
`
` A. I have a team of people who are
`
`Russian nationals.
`
` Q. Working in Hermitage?
`
` A. Yep.
`
`TSG Reporting - Worldwide 877-702-9580
`
`
`
`Case 1:13-cv-06326-TPG Document 281-1 Filed 05/13/15 Page 31 of 386
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` WILLIAM F. BROWDER (4/15/15)
`
` Q. And where are they, in London?
`
` A. Yep.
`
` Q. Okay. So --
`
` A. I should say working in Hermitage
`
`or external counsel from Russia.
`
` Q. Right. So you have no idea what
`
`this is?
`
` A. No.
`
` Q. Is it an official Russian document?
`
` A. I don't know.
`
` Q. Do you know how you obtained it?
`
` A. No.
`
` Q. No idea?
`
` A. No.
`
` Q. Do you know whether it's fake?
`
` A. I would assume it's real.
`
` Q. But you have any -- any idea
`
`whether it's fake?
`
` A. I don't think my team would have
`
`put together fake documents.
`
` Q. But you don't know?
`
` A. I trust my team to put together
`
`real documents.
`
` Q. Do you know where they got them?
`
`TSG Reporting - Worldwide 877-702-9580
`
`
`
`Case 1:13-cv-06326-TPG Document 281-1 Filed 05/13/15 Page 32 of 386
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`Page 32
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` WILLIAM F. BROWDER (4/15/15)
`
` A. No.
`
` Q. Do you know whether they stole
`
`them?
`
` A. I don't think my team -- no. No,
`
`they didn't steal them.
`
` Q. Do you know whether they bribed
`
`somebody to get them?
`
` A. They didn't bribe anybody to get
`
`them.
`
` MR. KIM: Sorry. Objection to
`
` form. What's the "them" we're talking
`
` about.
`
` MR. CYMROT: '103, '104, 105 are
`
` examples.
`
` Q. Do you have any idea?
`
` A. '104; nobody bribed anybody, we
`
`haven't bribed anybody.
`
` Q. Well, Mr. Kleiner says he has
`
`contacts within Moscow -- this is in your
`
`books, he has contacts within Moscow and then
`
`he shows up with some documents, right?
`
` MR. KIM: Objection to form.
`
` Q. Central Ban
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