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`EXHIBIT 3
`FILED: NEW YORK COUNTY CLERK 11/18/2025 10:05 PMINDEX NO. 100559/2014
`NYSCEF DOC. NO. 3428 RECEIVED NYSCEF: 11/18/2025
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`PURSUANT TO PROTECTIVE ORDER
`1 SUPERIOR COURT OF THE STATE OF CALIFORNIA
`FOR THE COUNTY OF SAN FRANCISCO
`2 -----------------------------------------X
`STATE OF CALIFORNIA, ex rel.,
`3 EDELWEISS FUND, LLC,
`4
`Plaintiff, Case No.
`5 CGC-14-54077
`vs.
`6
`JPMORGAN CHASE BANK, N.A.,
`7
`Defendants.
`8 -----------------------------------------X
`9
`10 HIGHLY CONFIDENTIAL
`11 PURSUANT TO THE PROTECTIVE ORDER
`12 VIDEOTAPED DEPOSITION
`13 OF
`14 BRADLEY WENDT
`15 Wednesday, April 30, 2025
`16 Vol. I
`17
`18
`19
`20
`21
`22
`23 REPORTED BY:
`24 LINDA J. GREENSTEIN
`25 NO. 7326156
`Page 1
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`PURSUANT TO PROTECTIVE ORDER
`1 message?
`2 A. Never.
`3 Q. Did you communicate with that
`4 person by phone?
`5 A. No, I'd just go upstairs and
`6 flop down next to him.
`7 Q. Do you remember Jeff Roald from
`8 your time at Goldman Sachs?
`9 A. Yes, I do.
`10 Q. What was his role during the
`11 time you supervised the short-term desk?
`12 A. He had transitioned from the
`13 firm at that point.
`14 Q. Do you remember John Bartolomeo
`15 from your time at Goldman Sachs?
`16 A. I certainly remember the name.
`17 I can't tell you any specific role.
`18 Q. Do you remember Cynthia Klein
`19 from your time at Goldman Sachs?
`20 A. Yeah.
`21 Q. And what do you remember about
`22 Ms. Klein?
`23 A. I remember she was in the
`24 short-term area and I'd say a majority of
`25 her time, at least by my memory, was more
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`PURSUANT TO PROTECTIVE ORDER
`1 in sales or customer outreach. But I -- I
`2 don't want to say that's a yes but I give
`3 that 50 percent confidence in terms of the
`4 role she played day in/day out.
`5 Q. Isn't it a fact, Mr. Wendt,
`6 that Cynthia Klein was the primary
`7 rate-setter from 1996 onwards?
`8 MR. CHERNOV: Objection.
`9 A. No.
`10 Q. Are you aware that Ms. Klein
`11 testified under oath in the federal VRDO
`12 case?
`13 A. I am unaware of that.
`14 Q. Would it surprise you to know
`15 that she testified that she was the
`16 primary rate-setter during the period you
`17 claim you were supervising the short-term
`18 desk?
`19 MR. CHERNOV: Objection.
`20 A. I would have to ask her how
`21 she's using the term "primary," yes, I
`22 would ask her that, but she might have
`23 been the backup, and I think you might
`24 have a definitional issue there.
`25 Q. During the period you
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`1 supervised the short-term desk, did your
`2 responsibilities include compliance?
`3 A. Of course compliance is
`4 everyone's responsibility. I was not a
`5 compliance officer, but I was certainly a
`6 -- in charge of compliance for every
`7 derivative product that was executed on
`8 the municipal side.
`9 Q. How much time did you spend on
`10 compliance matters?
`11 A. Probably 20 percent of my time,
`12 it would be a factor that was
`13 compliance-related, I'd say, and that's
`14 across VRDOs and all products, they're
`15 very compliance-oriented, yes.
`16 Q. Did Goldman Sachs comply with
`17 its rate-setting and remarketing
`18 obligations during the period you
`19 supervised the short-term desk?
`20 A. In my opinion, yes.
`21 Q. During the period you
`22 supervised the short-term desk, Goldman
`23 Sachs sold most of its VRDOs to tax-free
`24 money market funds; correct?
`25 MR. CHERNOV: Objection.
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`1 SUPERIOR COURT OF THE STATE OF CALIFORNIA
`FOR THE COUNTY OF SAN FRANCISCO
`2 -----------------------------------------X
`STATE OF CALIFORNIA, ex rel.,
`3 EDELWEISS FUND, LLC,
`4
` Plaintiff, Case No.
`5 CGC-14-54077
`vs.
`6
`JPMORGAN CHASE BANK, N.A.,
`7
` Defendants.
`8
`-----------------------------------------X
`9
`10 HIGHLY CONFIDENTIAL
`11 PURSUANT TO THE PROTECTIVE ORDER
`12 VIDEOTAPED DEPOSITION
`13 OF
`14 BRADLEY WENDT
`15 VOLUME II
`16 Thursday, May 1, 2025
`17
`18
`19
`20
`21
`22
`23 REPORTED BY:
`24 SHARON PEARCE, RDR, CRR, CRC, NYRCR
`25 NO. 7326208
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`FILED: NEW YORK COUNTY CLERK 11/18/2025 10:05 PMINDEX NO. 100559/2014
`NYSCEF DOC. NO. 3428 RECEIVED NYSCEF: 11/18/2025
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`1 LIBOR because of LIBOR is not a security,
`2 and the scandals. I dismissed tax-exempt
`3 commercial paper because it was priced off
`4 the same desk. I only know which other
`5 one I could cite.
`6 Q. Okay. Okay. So you agree that
`7 municipal commercial paper may be an
`8 exemption to the statement that you made
`9 at the end of your paragraph 22?
`10 MR. CHERNOV: Objection.
`11 A. I don't agree with that at all,
`12 because I think it has the same systematic
`13 inflation that VRDOs do, because the
`14 depositions show that the same people
`15 priced them were the same desk pricing.
`16 Q. You haven't done any work to
`17 show that rates on municipal commercial
`18 paper were inflated; correct?
`19 A. I -- I said earlier in my
`20 deposition that I have criticisms of the
`21 tenor he used, but I'm assuming his
`22 numbers are correct, and that was the
`23 basis of every statement I just said. I
`24 said that earlier.
`25 Q. And that wasn't a statement
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`NYSCEF DOC. NO. 3428 RECEIVED NYSCEF: 11/18/2025
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`1 about the relationship between VRDOs and
`2 municipal commercial paper. It was not a
`3 statement about whether municipal
`4 commercial paper rates were inflated;
`5 correct?
`6 A. No.
`7 MR. CHERNOV: Objection.
`8 A. There's -- but there's the
`9 extrapolation of the three, because all
`10 three of them have been compared to each
`11 other -- A to B, B to C.
`12 Q. So let me have you look at your
`13 Exhibit 101, page -- and this time, I'm
`14 going to be clear. I'm saying page 15.
`15 Okay. On page 15, Figure 9,
`16 you're comparing nominal interest rates on
`17 VRDOs to nominal interest rates on
`18 AA-rated commercial paper; right?
`19 A. Yes.
`20 Q. And you found that the
`21 defendants' VRDO rates were sometimes
`22 higher -- the nominal rates were sometimes
`23 higher than those on taxable commercial
`24 paper; right?
`25 A. Yes.
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`FILED: NEW YORK COUNTY CLERK 11/18/2025 10:05 PMINDEX NO. 100559/2014
`NYSCEF DOC. NO. 3428 RECEIVED NYSCEF: 11/18/2025
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