Case 1:13-cv-06326-TPG Document 465-24 Filed 12/08/15 Page 1 of 26
`Case 1:13—cv—O6326—TPG Document 465-24 Filed 12/08/15 Page 1 of 26
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`Exhibit 24
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`Case 1:13—cv—O6326—TPG Document 465-24 Filed 12/08/15 Page 1 of 26
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`Exhibit 24
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`Case 1:13-cv-06326-TPG Document 465-24 Filed 12/08/15 Page 2 of 26
`Case 1:13—cv—O6326—TPG Document 465-24 Filed 12/08/15 Page 2 of 26
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`** CONFIDENTIAL **
`
`UNITED STATES DISTRICT COURT
`SOUTHERN DISTRICT OF NEW YORK
`_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _X
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`UNITED STATES OF AMERICA,
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`Plaintiff,
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`~ vs—
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`PREVEZON HOLDINGS, LTD, FERENCOI
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`INVESTMENTS LTD, KOLEVINS LTD,
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`et al.,
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`_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _X
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`Defendants.
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`)
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`)
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`)
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`)
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`)
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`)
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`)
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`No. 1:13—CV—O6326
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`(TPG)
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`Confidential Videotaped Deposition of
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`ALEKSANDER SCHWARTZMAN,
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`taken by Defendants, at
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`the offices of Baker Hostetler, 45 Rockefeller
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`Plaza, New York, New York, on October 7, 2015,
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`commencing at 1:12 p.m., before Jeffrey Benz, a
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`Certified Realtime Reporter, Registered Merit
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`Reporter and Notary Public within and for the
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`State of New York.
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`Case 1:13-cv-06326-TPG Document 465-24 Filed 12/08/15 Page 3 of 26
`Case 1:13—cv—O6326—TPG Document 465-24 Filed 12/08/15 Page 3 of 26
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`00|.\)l——*
`
`A P P E A R A N C E S:
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`US ATTORNEY'S OFFICE
`
`FOR THE SOUTHfiRN D STRTCT OF NEW YORK
`
`Attorneys for the Plaintiff
`
`One St. Andrews Plaza
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`New York, New York
`
`10007
`
`BY:
`
`MARGARET GRAHAM, ESQ.
`
`PAUL MONTELEONI, ESQ.
`
`BAKER HOSTETLER
`
`.C
`Attorneys for De_endants
`
`45 Rockefeller Plaza
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`New York, New York
`
`10111
`
`BY:
`
`LOURA L. ALAVERDI, ESQ.
`
`NICHOLAS M. ROSE, ESQ.
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`(Remote Participant)
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`ALSO PRESENT:
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`JOSE RIVERA, Videographer
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`NATALIYA VESELNITSKAYA (Remote Participant)
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`GABRIELLA VOLSHTEYN
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`(Remote Participant)
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`
`
`
`
`
`
`
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`Case 1:13-cv-06326-TPG Document 465-24 Filed 12/08/15 Page 4 of 26
`Case 1:13—cv—O6326—TPG Document 465-24 Filed 12/08/15 Page 4 of 26
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`Schwartzman — Confidential
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`Prevezon or --
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`MS. ALAVERDI:
`
`The Prevezon team.
`
`Q.
`
`A.
`
`I'm sorry.
`
`Oh,
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`the Prevezon team. That's easy.
`
`I'm sorry. That's just Special Agent Hyman and
`
`Special Agent Angert, and my supervisor, Shawn
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`Polonet.
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`Q.
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`Okay.
`
`I'll be more specific going forward.
`
`T apologize for that.
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`A.
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`Q.
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`Sure.
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`And within the Prevezon investigation
`
`team, who do you report to, if anyone?
`
`A.
`
`Q.
`
`I report ~— T report to Shawn Polonet.
`
`Okay.
`
`And who gives you your assignments on
`
`the Prevezon case?’
`
`A.
`
`I've gotten assignments from both
`
`Special Agent Hyman and Shawn Polonet.
`
`Q.
`
`Have you traveled internationally in
`
`connection with the investigation of the
`
`Prevezon case?
`
`A.
`
`I have.
`
`Q. Where have you traveled to?
`
`
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`15
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`Case 1:13-cv-06326-TPG Document 465-24 Filed 12/08/15 Page 5 of 26
`Case 1:13—cv—O6326—TPG Document 465-24 Filed 12/08/15 Page 5 of 26
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`Schwartzman — Confidential
`
`A.
`
`I've traveled to Lithuania, Latvia,
`
`and Estonia.
`
`sh-
`
`ONO"!
`
`Q.
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`When did you travel to Lithuania for
`
`the Prevezon case?
`
`A.
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`Approximately May 17,
`
`sometime the
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`second half o: May.
`
`Q.
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`A.
`
`Q.
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`A.
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`Q.
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`A.
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`Q.
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`2015?
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`And that's 2015, correct?
`
`2015, yes.
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`And how long were you in Lithuania?
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`Approximately two days.
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`Did you visit Lithuania on May 17,
`
`I'm sorry.
`
`Did you go back to Lithuania after
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`May 17, 2015?
`
`A. After leaving Lithuania did I return
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`to Lithuania?
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`Q.
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`Right. Was that your only visit,
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`May 17, 2015,
`
`for two days? Was that the only
`
`visit you made to Lithuania?
`
`A.
`
`Oh, yeah,
`
`that was the only visit,
`
`yes.
`
`Q.
`
`A.
`
`When did you visit Latvia?
`
`I visited Latvia right after
`
`
`
`
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`Case 1:13-cv-06326-TPG Document 465-24 Filed 12/08/15 Page 6 of 26
`Case 1:13—cv—O6326—TPG Document 465-24 Filed 12/08/15 Page 6 of 26
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`U1nJ>(iJR)}-—‘
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`Schwartzman — Confidential
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`Lithuania.
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`2
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`Q.
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`A.
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`Q.
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`How long were you in Latvia?
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`Also approximately two,
`
`three days.
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`And was that the only occasion on
`
`which you traveled to Latvia in connection with
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`the Prevezon case?
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`A.
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`Q.
`
`That's correct.
`
`Okay.
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`And when did you travel to Estonia in
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`connection with the Prevezon case?
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`A.
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`This Estonia trip was immediately
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`after the Latvia.
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`Q.
`
`Okay.
`
`How long were you in Estonia for the
`
`Prevezon case?
`
`A.
`
`That was also approximately two or
`
`three days.
`
`Q.
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`Okay.
`
`And is that the only occasion when you
`
`traveled to Estonia in connection with the
`
`Prevezon case?
`
`A.
`
`Q.
`
`That's correct.
`
`Have you seen the complaint in this
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`Prevezon case?
`
`
`
`
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`Case 1:13—cv—O6326—TPG Document 465-24 Filed 12/08/15 Page 7 of 26
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`Schwartzman — Confidential
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`investigate how this elaborate tax refund fraud
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`scheme was committed?
`
`MS. GRAHAM: Objection.
`
`I have not.
`
`And did anyone ask you to do that?
`
`MS. GRAHAM: Objection.
`
`No.
`
`And just to clarifiy for you since
`
`A.
`
`Q.
`
`A.
`
`Q.
`
`you've not been deposed,
`
`from time to time
`
`you'll hear the government lawyers inject
`
`objections, and that's just a legalese thing.
`
`But unless they tell you not to answer, you can
`
`wait for them to object and you can go ahead and
`
`give me the answer.
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`But there are times, hopefully not
`
`today, where they will tell you you should not
`
`answer and I will ask you if you will follow
`
`their advice or not.
`
`A.
`
`Q.
`
`Okay. Fair enough.
`
`Thank you.
`
`Okay.
`
`Now, earlier you testified that you
`
`traveled to Lithuania in connection with the
`
`Prevezon case, correct?
`
`A.
`
`That's correct.
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`Case 1:13-cv-06326-TPG Document 465-24 Filed 12/08/15 Page 8 of 26
`Case 1:13—cv—O6326—TPG Document 465-24 Filed 12/08/15 Page 8 of 26
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`Schwartzman — Confidential
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`Q. What was your purpose for traveling to
`
`Lithuania?
`
`A.
`
`I have traveled to assist with
`
`obtaining documents from Lithuanian officials.
`
`Q.
`
`A.
`
`Okay.
`
`Relating to the investigation they
`
`were conducting.
`
`Q.
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`Okay.
`
`Do you know if a request was made to
`
`the Lithuanian officials for documents in the
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`Prevezon case?
`
`A.
`
`Q.
`
`I don't know.
`
`Okay.
`
`What did you do when you went to
`
`Lithuania in terms of actually getting documents
`
`from officials in Lithuania?
`
`How did you do
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`that?
`
`A.
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`We arrived at the ~— the official's
`
`office, offices of the —— the prosecutor of
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`Lithuania.
`
`Q.
`
`A.
`
`You said "we." Who was with you?
`
`Oh, it was Special Agent Hyman,
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`the
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`Assistant U.S. Attorney Paul Monteleoni, and
`
`myself.
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`(wk)
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`Case 1:13-cv-06326-TPG Document 465-24 Filed 12/08/15 Page 9 of 26
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`Q.
`
`Okay.
`
`And you said you went to the
`
`prosecutor's office in Lithuania?
`
`A.
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`" be'ieve that's what it's called, but
`
`—— it was —— you know, it was the o‘f‘ces
`
`where the —~ you know,
`
`the prosecutor,
`
`the --
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`the attorney for the Lithuanian government was
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`present, along with some investigators of the
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`Lithuanian government.
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`Q.
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`How long was this meeting with the
`
`prosecutor in Lithuania?
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`A.
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`I don't remember specifics.
`
`IIt's -- l
`
`don't remember whether it took one day or two
`
`days.
`
`Q.
`
`Okay.
`
`And what happened during these
`
`meetings with the prosecutor in Lithuania?
`
`A.
`
`Special Agent Hyman and U.S. —— and
`
`Assistant U.S. Attorney Paul Monteleoni have
`
`been discussing the case that the Lithuanian
`
`authorities were working on, and they were
`
`discussing documents that the Lithuanian
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`authorities were to provide to us.
`
`Q.
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`Was there any discussions on why the
`
`
`
`
`
`
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`Case 1:13-cv-06326-TPG Document 465-24 Filed 12/08/15 Page 10 of 26
`Case 1:13—cv—O6326—TPG Document 465-24 Filed 12/08/15 Page 10 of 26
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`Schwartzman - Confidential
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`Lithuanian officials started investigating?
`
`23
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`O\U‘ls-l>U)R)
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`MS. GRAHAM: Objection. One sec.
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`We would object to the extent that
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`this question calls for any information
`
`about the -— any Lithuanian investigation
`
`taken independently, its history,
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`its
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`status, its nature.
`
`To the extent that it
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`concerns information provided by the
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`Lithuanian government to us in our case,
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`U.S. v. Prevezon Holdings,
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`the witness can
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`answer.
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`MS. ALAVERDI: And just for my own
`
`clarification, what is the basis of that
`
`objection, if I understand it correctly?
`
`So you're saying he can testify about the
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`help that they provided to the U.S.
`
`government, but to the extent they talked
`
`about what they did to collect information,
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`he can't tell me about that.
`
`Is that what
`
`you're saying?
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`MS. PHILLIPS:
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`: may —— you know,
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`the
`
`basis for the objection is the —— is a law
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`enforcement privilege the witness has
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`testified that there's been cooperation
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`
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`Case 1:13-cv-06326-TPG Document 465-24 Filed 12/08/15 Page 11 of 26
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`Schwartzman — Confidential
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`between the Lithuanian officials in
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`connection with this, and regarding the
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`course of how the Lithuanians are
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`investigating the sort of describing
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`details about how an investigation is
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`progressing is —— is covered by the law
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`enforcement privilege.
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`The actual facts that were disclosed
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`in that investigation about the offenses
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`that were —— that took place,
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`that then got
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`transmitted to the U.S.,
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`the witness can
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`inquire about, but inquiring about the
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`status or proceedings of the investigation
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`that the Lithuanians are conducting,
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`is —~
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`falls within the law enforcement privilege.
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`So —~ and that's why my colleague has
`
`instructed the witness not to answer to
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`that extent.
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`MS. ALAVERDI: Okay.
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`So that's
`
`limited to the status and how the}
`
`investigation is actually progressing, not
`
`the information.
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`MR. MONTELEONI: And the history,
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`the
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`sort o: procedural parts as opposed to the
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`
`
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`Case 1:13-cv-06326-TPG Document 465-24 Filed 12/08/15 Page 12 of 26
`Case 1:13—cv—O6326—TPG Document 465-24 Filed 12/08/15 Page 12 of 26
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`(ORDI-‘
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`Schwartzman — Confidential
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`facts discovered.
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`MS. ALAVERDI: Let me ask some
`
`questions just to make sure I understand
`
`what you mean by "history."
`
`Q.
`
`The Lithuanian investigators —— strike
`
`that. Let me back up.
`
`A
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`Do you know what a mutual legal
`
`assistant —~ assistance treaty is?
`
`A.
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`I have heard of it. You know,
`
`I --
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`MS. GRAHAM: Objection.
`
`I have an idea.
`
`Okay.
`
`You know, I've heard of it.
`
`It's —— I
`
`A.
`
`Q.
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`A.
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`believe it's -— a —— the federal version of a
`
`subpoena to the —— the international government.
`
`Q.
`
`Okay.
`
`Do you know if there was a mutual
`
`legal assistance treaty with Lithuania?
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`MS. GRAHAM: Objection.
`
`I don't know.
`
`Do you know if the U.S. government
`
`A.
`
`Q.
`
`made an —~ I'll abbreviate mutual assistance
`
`treaty. We generally refer to an MLAT.
`
`Do you
`
`know i: the U.S. government made —— issued any
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`26
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`Case 1:13-cv-06326-TPG Document 465-24 Filed 12/08/15 Page 13 of 26
`Case 1:13—cv—O6326—TPG Document 465-24 Filed 12/08/15 Page 13 of 26
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`Schwartzman — Confidential
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`MLAT requests to Lithuania in connection with
`
`the Prevezon case?
`
`A.
`
`--
`
`believe you posed this question
`
`before.
`
`I don't know.
`
`I don't know if they
`
`did.
`
`Q.
`
`You just know you went to Lithuania to
`
`obtain governments from the officials, correct?
`
`A.
`
`To assist in obtaining the ~- right.
`
`Q.
`To assist in obtaining.
`assistance that you were expected to provide,
`
`And the
`
`was that solely in connection with your language
`
`skills?
`
`MS. GRAHAM: Objection.
`
`A.
`
`It's ~— it's a —— I believe a part of
`
`it as well.
`
`T believe my language skills could
`
`have been iti_ized there; however,
`
`they weren't.
`
`Q.
`
`Did you do anything while you were
`
`meeting with the officials in Lithuania?
`
`MS. GRAHAM: Objection.
`
`A.
`
`I was —— I was present at the meetings
`
`and I don't know if my presence there
`
`constitutes an action.
`
`I've witnessed the
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`documents being provided, and the —— secured by
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`a USA —— may I call Assistant U.S. Attorney a
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`27
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`Case 1:13-cv-06326-TPG Document 465-24 Filed 12/08/15 Page 14 of 26
`Case 1:13—cv—O6326—TPG Document 465-24 Filed 12/08/15 Page 14 of 26
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`Schwartzman — Confidential
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`(.UI\)
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`"AUSA"?
`
`Q.
`
`A.
`
`Sure.
`
`I observed the documents being handed
`
`over to AUSA Monteleoni.
`
`So basically my role
`
`there was limited to observations and —— and
`
`presence there, being there.
`
`Q.
`
`Did you look —~ did you actually
`
`examine the documents that were provided to the
`
`AUSA?
`
`A.
`
`Q.
`
`A.
`
`Q.
`
`No,
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`I have not.
`
`I'm sorry?
`
`I have not.
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`I did not examine.
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`Did you ask any questions about the
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`documents during the meeting?
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`A.
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`Q.
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`I did not.
`
`Do you know what the documents were
`
`that were turned over to the AUSA?
`
`A.
`
`I have an idea that these documents
`
`may be documents obtained during the course of
`
`the investigation that the Lithuanian government
`
`has conducted.
`
`JIR Q.
`
`Did the Lithuanian government indicate
`
`to you why they initially started their
`
`investigation?
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`MS. GRAHAM: Objection.
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`I'm going to
`
`instruct the witness not to answer that as
`
`it goes to law enforcement privilege.
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`MS. ALAVERDI: As to why foreign
`
`country started an investigation, correct.
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`MS. GRAHAM: Correct.
`
`MS. ALAVERDI: You're saying that's a
`
`law enforcement privilege that the United
`
`States can assert?
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`MR. MONTELEONI: Yes.
`
`As —— I
`
`mentioned before,
`
`just ~~ but just to point
`
`out, as we previously pointed out,
`
`the
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`witness has already testified that there is
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`cooperation happening between U.S. and this
`
`foreign government concerning investigation
`
`into overlapping facts and that implicate
`
`our law enforcement privileges.
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`MS. ALAVERDI: Okay.
`
`I mean,
`
`I
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`disagree with your analysis, but I just
`
`want to make sure I understand your
`
`objection. We disagree. We don't think
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`that that is covered by the law enforcement
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`privilege in terms of what a foreign
`
`country —— why a foreign country initiates
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`Schwartzman S Confidential
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`an investigation before the U.S. government
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`ever even makes Contact with that foreign
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`country to start assistance.
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`So you're backtracking and saying
`
`whatever they may have done years ago falls
`
`under the umbrella, and to me,
`
`that does ——
`
`that's not covered under law enforcement
`
`privilege. But if it's your position that
`
`you're instructing with the witness to not
`
`answer, we can take that up with the Court
`
`another time.
`
`MR. MONTELEONI:
`
`Just one moment.
`
`MS. ALAVERDZ:
`
`Sure.
`
`Take your time.
`
`(The United States attorneys
`
`conferred.)
`
`MR. MONTELEONI:
`
`Thank you, Counsel.
`
`The only thing that we would add is that to
`
`the extent that -— that —— if there are
`
`facts that are public about the progress of
`
`a —— an investigation that a foreign —— a
`
`criminal investigation that a foreign
`
`country is conducting,
`
`then they can be
`
`obtained publicly.
`
`But to the extent that they're not
`
`-—
`
`
`
`
`
`30
`
`Case 1:13-cv-06326-TPG Document 465-24 Filed 12/08/15 Page 17 of 26
`Case 1:13—cv—O6326—TPG Document 465-24 Filed 12/08/15 Page 17 of 26
`
`
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`\ICfiU'|(;.)h)}—‘
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`19
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`20
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`21
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`22
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`23
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`24
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`25
`
`Schwartzman — Confidential
`
`and so, since they can be obtained
`
`publicly, we think in the absence of an
`
`absolutely conclusive understanding that
`
`they are public, we're going to assume that
`
`they're not.
`
`For any fact that is not
`
`public, that's not known to be public,
`
`the ~— we have an interest in avoiding a
`
`criminal investigation by a country that's
`
`cooperating with us from being jeopardied
`
`by the premature disclosure of nonpublic
`
`details of that investigation,
`
`just like we
`
`would have that interest with one of our
`
`own investigations.
`
`So that's why
`
`nonpublic deals about what's happening in
`
`an investigation and the course that is
`
`progressing implicates the law enforcement
`
`bridge.
`
`MS. GRAHAM:
`
`Can we go off the record
`
`for one second?
`
`MS. ALAVERDI: Yes.
`
`THE VIDEOGRAPHER:
`
`The time is
`
`1:48 p.m. and we're going off the record.
`
`(A recess was taken.)
`
`THE VIDEOGRAPHER:
`
`The time is
`
`
`
`
`
`
`
`31
`
`Case 1:13-cv-06326-TPG Document 465-24 Filed 12/08/15 Page 18 of 26
`Case 1:13—cv—O6326—TPG Document 465-24 Filed 12/08/15 Page 18 of 26
`
`Schwartzman — Confidential
`
`1:55 p.m. and we are back on the record.
`
`MS. GRAHAM:
`
`So thank you for the
`
`break. We withdraw the previous objection,
`
`and Agent Schwartzman can answer to the
`
`extent he knows.
`
`MS. ALAVERD:: Okay.
`
`I knew there was
`
`a trick.
`
`Q.
`
`And my question before we went off the
`
`record is whether the Lithuanian officials
`
`informed you at that meeting what caused them to
`
`begin their investigation.
`
`A.
`
`I don't recall specifics.
`
`T
`
`remember
`
`that they were investigating money laundering in
`
`the country and that they identified some
`
`companies that may have been used for that
`
`purpose.
`
`Q.
`
`Do you recall the names of the
`
`companies that they said may have been used for
`
`that purpose of money laundering?
`
`A.
`
`Q.
`
`No,
`
`I don't recall.
`
`Okay.
`
`Does the name, Reaton Limited,
`
`sound
`
`familiar to you?
`
`A.
`
`It does.
`
`10
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`11
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`Case 1:13-cv-06326-TPG Document 465-24 Filed 12/08/15 Page 19 of 26
`Case 1:13—cv—O6326—TPG Document 465-24 Filed 12/08/15 Page 19 of 26
`
`37
`
`(.A)I\)
`
`I-’CDkO
`
`Schwartzman — Confidential
`
`Q. After you left —— since the time you
`
`were in Lithuania, have you actually reviewed
`
`any of the documents that the Lithuanian
`
`officials turned over to the U.S. government?
`
`MS. GRAHAM: Objection.
`
`A.
`
`I'm sorry. Are you asking me if I
`
`reviewed any?
`
`Q.
`
`I'm asking. After the documents were
`
`retrieved from the Lithuanian officials and came
`
`back to the United States, have you had an
`
`opportunity since then, since May of 2015,
`
`to
`
`actually look at any of these documents?
`
`MS. GRAHAM: Objection.
`
`No,
`
`I did not.
`
`And no one asked you to?
`
`No one asked me to.
`
`A.
`
`Q.
`
`A.
`
`Q. After Lithuania you said that you
`
`traveled to Latvia, correct? This is in May of
`
`2015.
`
`A.
`
`Q.
`
`A.
`
`I traveled to Latvia, yeah.
`
`You sound hesitant.
`
`Yeah, because I was just thinking
`
`about the previous question.
`
`I might have
`
`looked at some of the documents that came from
`
`
`
`
`
`
`
`38
`
`Case 1:13-cv-06326-TPG Document 465-24 Filed 12/08/15 Page 20 of 26
`Case 1:13—cv—O6326—TPG Document 465-24 Filed 12/08/15 Page 20 of 26
`
`Schwartzman — Confidential
`
`that trip to Lithuania. However,
`
`they were not
`
`identified as such.
`
`So I might have been tasked
`
`to look at the documents,
`
`just general
`
`documents.
`
`I don't know if this —— you know,
`
`the exact source of them.
`
`Q.
`
`Okay.
`
`The documents that you have in mind
`
`right now,
`
`that you remember looking at, what
`
`were those documents about?
`
`A.
`
`I —— you know,
`
`I've looked at various
`
`documents for the purposes of ~— mainly the
`
`Russian language documents for the purposes o;
`
`just helping with identification, what they are,
`
`really, and
`
`Q.
`
`And you —— just to move this along,
`
`were you looking at them to identify them as to
`
`what they are so that they could get certified
`
`translation or was there some other purpose?
`
`A.
`
`Yeah,
`
`for that —~ so they could get
`
`translated so —— you know,
`
`so that they could
`
`basically identify it as significant enough
`
`to —— to be sent for translation.
`
`Q.
`
`Were you the one making the decision
`
`on what was significant enough to translate?
`
`\I(fiU‘|sJ>(,«)R)
`
`1O
`
`ll
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`12
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`19
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`2O
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`21
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`22
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`23
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`24
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`25
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`
`
`
`39
`
`Case 1:13-cv-06326-TPG Document 465-24 Filed 12/08/15 Page 21 of 26
`Case 1:13—cv—O6326—TPG Document 465-24 Filed 12/08/15 Page 21 of 26
`
`O\U‘I»J>-(iJl\)I—‘
`
`1O
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`11
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`12
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`13
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`14
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`15
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`16
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`17
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`18
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`19
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`20
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`21
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`22
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`23
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`24
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`25
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`Schwartzman — Confidential
`
`No.
`
`Okay.
`
`You were just identifying what the
`
`documents
`
`were, correct?
`
`A.
`
`Q.
`
`,_
`
`Well, helping with ~— identified them.
`
`Okay.
`
`Did you do anything to investigate any
`
`o:
`
`the facts in these documents that you
`
`reviewed?
`
`A.
`
`Q.
`
`MS. GRAHAM: Objection.
`
`No.
`
`By investigate,
`
`just to be clear,
`
`I
`
`mean, did
`
`you actually physically go and
`
`interview
`
`witnesses and look up information?
`
`A.
`
`Q.
`
`No.
`
`And after you left Lithuania, you
`
`testified
`
`earlier that you traveled to Latvia.
`
`Do you recall that?
`
`Yes.
`
`Who was with you when you went to
`
`Latvia?
`
`A.
`
`T was with Special Agent Hyman and the
`
`AUSA Monteleoni.
`
`Q.
`
`Okay. Was Shawn Polonet with you?
`
`
`
`
`
`
`
`
`
`40
`
`Case 1:13-cv-06326-TPG Document 465-24 Filed 12/08/15 Page 22 of 26
`Case 1:13—cv—O6326—TPG Document 465-24 Filed 12/08/15 Page 22 of 26
`
`U.)[\)l—‘
`
`1O
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`11
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`12
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`13
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`14
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`15
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`16
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`22
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`23
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`24
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`25
`
`Schwartzman ~ Confidential
`
`A.
`
`No.
`
`Q.
`
`A.
`
`Q.
`
`Was Agent Angert with you?
`
`No.
`
`And what did you do when you arrived
`
`in Latvia? Did you meet with anyone?
`
`A.
`
`Yes. We met with the Latvian
`
`o "icials. That
`
`included attorneys.
`
`Q.
`
`And what was the purpose of that
`
`meeting?
`
`A.
`
`To discuss the investigation conducted
`
`by the Latvian officials,
`
`the relationship with
`
`our investigation, and to receive documents from
`
`the —~ from Latvian officials.
`
`Q.
`
`Okay.
`
`Do you know what
`
`language is spoken in
`
`A.
`
`Q
`
`A.
`
`Q
`
`Latvian.
`
`Do you speak Latvian?
`
`I don't.
`
`Okay.
`
`What was your purpose in —— in
`
`traveling to Latvia with the U.S. attorneys and
`
`Agent Hyman?
`
`A.
`
`To assist in -— in getting the
`
`
`
`
`
`
`
`
`
`
`
`47
`
`Case 1:13-cv-06326-TPG Document 465-24 Filed 12/08/15 Page 23 of 26
`Case 1:13—cv—O6326—TPG Document 465-24 Filed 12/08/15 Page 23 of 26
`
`Schwartzman — Confidential
`
`A.
`
`Q.
`
`I did not.
`
`Okay.
`
`Do you know if anyone else on your
`
`team did?
`
`A.
`
`I —— I don't —~ no,
`
`I don't think so.
`
`Q. After you left Latvia, you testified
`
`earlier that you trave_
`
`Do you remember that?
`
`I
`
`remember.
`
`Who accompanied you to Estonia?
`
`Special Agent Hyman and AUSA
`
`A.
`
`Q.
`
`A.
`
`Monteleoni.
`
`Q.
`
`Okay.
`
`And did you meet with anyone when you
`
`were in Estonia?
`
`A.
`
`Yes. We met with Estonian government
`
`officials.
`
`Q. What was the purpose of that meeting?
`
`A.
`
`The purpose was to obtain documents
`
`from Estonian officials as well as discuss their
`
`cooperation in ~— and their case that they're
`
`conducting.
`
`Q.
`
`Okay.
`
`Did the Estonian officials discuss
`
`
`
`
`
`
`
`Case 1:13-cv-06326-TPG Document 465-24 Filed 12/08/15 Page 24 of 26
`Case 1:13—cv—O6326—TPG Document 465-24 Filed 12/08/15 Page 24 of 26
`
`48
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
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`11
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`12
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`13
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`14
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`15
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`16
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`22
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`23
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`24
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`25
`
`Schwartzman — Confidential
`
`with you what caused them to begin an
`
`investigation?
`
`A.
`
`Q.
`
`I don't remember.
`
`Okay.
`
`Do you know what documents the
`
`Estonian officials turned over to the U.S.
`
`government?
`
`A.
`
`Q.
`
`No.
`
`Did you look at the documents that
`
`they turned over to the U.S. government while
`
`you were in Estonia?
`
`A.
`
`I have observed documents, but
`
`I
`
`didn't look at them and examine them.
`
`Q.
`
`A.
`
`Okay.
`
`But I observed the actual transfer of
`
`documents from them to us.
`
`Q.
`
`Okay.
`
`Did the name William Browder come up
`
`during the meetings with public officials in
`
`Estonia?
`
`A.
`
`Q.
`
`I don't remember.
`
`Okay.
`
`After you obtained the documents from
`
`the officia's in Estonia, did you take any steps
`
`
`
`
`
`
`
`49
`
`Case 1:13-cv-06326-TPG Document 465-24 Filed 12/08/15 Page 25 of 26
`Case 1:13—cv—O6326—TPG Document 465-24 Filed 12/08/15 Page 25 of 26
`
`U7(,Ol\)|—*
`
`O\
`
`Schwartzman - Confidential
`
`to verify the accuracy of any of the information
`
`contained in those documents?
`
`MS. GRAHAM: Objection.
`
`I did not.
`
`Do you know if anyone on the Prevezon
`
`A.
`
`Q.
`
`investigation team did so?
`
`MS. GRAHAM: Objection.
`
`I don't know.
`
`Have you traveled anywhere outside of
`
`A.
`
`Q.
`
`the United States other than Lithuania, Latvia,
`
`and Estonia in connection with the Prevezon
`
`case?
`
`A.
`
`Q.
`
`I have not.
`
`Okay.
`
`During the meetings between the U.S.
`
`officials and Estonian officials, was there any
`
`representation made by the U.S. government that
`
`the Prevezon case in the U.S.
`
`is a criminal
`
`case?
`
`that.
`
`A.
`
`I don't remember any —~ anything like
`
`Q.
`
`During the meetings between the U.S.
`
`officials and Latvian officials, was there any
`
`representation made by the U.S. government that
`
`
`
`
`
`
`
`
`
`Case 1:13-cv-06326-TPG Document 465-24 Filed 12/08/15 Page 26 of 26
`Case 1:13—cv—O6326—TPG Document 465-24 Filed 12/08/15 Page 26 of 26
`
`Schwartzman - Confidential
`
`the Prevezon case in the U.S.
`
`is a criminal
`
`case?
`
`(JR)
`
`50
`
`MS. GRAHAM: Objection. Asked and
`
`answered.
`
`MS. ALAVERDI:
`
`Pardon me.
`
`MS. GRAHAM:
`
`I apologize. Withdrawn.
`
`MS. ALAVERDI: Okay.
`
`A.
`
`I don't remember the Prevezon case
`
`being mentioned as a criminal case.
`
`Q.
`
`Okay. And the same question about
`
`meetings with Lithuanian officials.
`..C
`Same answer ior the Lithuanians.
`
`A.
`
`don't remember any mention of a Prevezon case
`
`being a criminal case.
`
`Q.
`
`Okay.
`
`In addition to traveling to these
`
`countries to obtain documents, have you done
`
`anything else to obtain documents from other
`
`sources for the Prevezon case?
`
`A.
`
`I have obtained documents from other
`
`sources, yes.
`
`Q.
`
`Can you tell me what sources you
`
`obtained documents from?
`
`A.
`
`I have obtained documents from —— or
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