EFTA01128746.pdf

Nardello VICo. Nardello & Co. 1.1C 565 Fifth Avenue New York, NY 10017 Ti +1 212 537 5300 Fs +1 212 537 5333 www.nardelloaudco.com PRIVILEGED AND CONFIDENTIAL ATTORNEY CLIENT AND WORK PRODUCT COMMUNICATION MEMORANDUM TO: Brad S. Karp, Esq. Lorin L. Reisner, Esq. Paul, Weiss, Rifkind, Wharton & Garrison LLP FROM: Nardello & Co. LLC RE: Draft Transcript of Meeting with DATE: August 13, 2015 The following is a draft transcript of a recording of a conversation between John Doe (JD) and GG) which took place on August 12, 2015 at the Four Seasons Restaurant, 99 E. 52e' Street, ew or New York between approximately 1:00 pm and 2:30 pm. The recording was made with the consent of JD. Notations of "UI" represent speech that was unintelligible during our initial review. This transcription is subject to revision and all time stamps are approximate. Time Stamp Speaker Conversation 0 to 25:00 Various Preamble, walking, small talk, waiter in restaurant taking order. 24:56 JD Could I get an iced tea please? Do you want anything, glass of wine, tea? GG I'm fine. JD How are you? GG OK. JD Now you've been in the states the whole time. So I guess you still have lots of friends — and [laughs] seeing people. GG Imagine that. JD No, no, I do imagine it. So how does it work, because I thought a year ago you had to leave because of the visa thing, but now you're here for most of the summer, and there's no issue. EFTA01128746 PRIVILEGED AND CONFIDENTIAL ATTORNEY CLIENT AND/OR Nardello WORK PRODUCT COMMUNICATION Co. Time Stamp Speaker Conversation GG I have a tourist visa. JD So a tourist visa is fine once you no longer have a residence. OK, OK, well, that's good. And Sasha has been with his grandparents the whole time? And he's good? GG Yeah, he's OK, he's missing another school year because we cannot go to England because I didn't do my documentation on time, [0] during the summer. It's really hard because there are no schools in English in Russia really. I had one where we were harassed. I don't know he may have to be home schooled or something. JD Does he speak Russian? GG Not very good. Not to the point to study in school with other kids. JD But the flat in London, you can go to it or no? GG I have a flat and it's very expensive, but now -- JD But you can't use it because you can't stay in London a lot? GG No. JD And he's not in school? GG No. JD So you still need to get a visa there? GG And how was yours? JD It was nice, it was a nice birthday. It was a quick get-away like five days — six days. We went to Normandy first. You know that's where D-Day, the invasion was. So we saw the cliffs and the beaches where they all landed, I had my kids with me which was nice and then we went to the south of France, had a birthday dinner, and then went to somebody else's birthday and stayed for a few days. Half the kids left, they had to go back to work. Thank you (to the waiter). It was a nice getaway, and then of course I got back and I got sick. I don't know if it was the airplane, or summer or what? 28:00 GG Planes aren't very (UI) especially if you're hung over, I think. DRAFT: FOR DISCUSSION PURPOSES ONLY 2 EFTA01128747 PRIVILEGED AND CONFIDENTIAL ATTORNEY CLIENT AND/OR Nardello WORK PRODUCT COMMUNICATION Co. Time Stamp Speaker Conversation JD Right. I'm not a big drinker, so I don't think I was hung over. GG You know, if you're tired, I don't think your immune system is...I think flying is very difficult for the body. JD Right. And you've been enjoying NY? GG One week I was in the Hamptons, then I came back here. JD Which Hampton did you go to? GG South. JD You were in Southampton? 28:30 GG I stayed at a friend's house and then this weekend I went to Sag Harbor to American Hotel. JD That's nice. It's a cute town. GG Yes, it's very nice. JD Very cute. I didn't realize you were in Southampton. GG No, that was when you were away. JD That's when I was away. You look tan, you went to the beach? GG When I was in the Hamptons I was in a pool in Southampton. What do you want to eat? [Discussion re: lunch order.] JD How was the Gansevoort hotel? GG I booked it because they have a pool. JD You keep switching. You started at the Mercer, then you went to the Four Seasons, I did that one summer when we were doing construction and we tried out like ten different hotels just to see what it was like [laughs] in New York. GO You get sick of something, you know [laughs]. JD Which do you like the most? GG No, I also stay in my friend's apartment, I didn't want to go to the Four DRAFT: FOR DISCUSSION PURPOSES ONLY 3 EFTA01128748 PRIVILEGED AND CONFIDENTIAL ATTORNEY CLIENT AND/OR Nardello WORK PRODUCT COMMUNICATION 1,4Co. Time Stamp Speaker Conversation Seasons, Four Seasons for me like this is dated. 30:08 JD It's very California, it's LA. GO You know they are closing this Four Seasons. JD Well yes, it's being taken over by Aby Rosen... GG Italians... JD Well, he's Israeli-German... GG It's Aby Rosen, but he's going to bring in Italian cooks JD You're talking about the chef? Ah, ok. Well, he took it over and he doesn't like the management and he thinks it should be spiffed up and he's going to create two different restaurants. It's like this New York institution, it's a little sad [pause in conversation while speakers order lunch from waiter, then a pause] 32:00 JD So how long are you planning to stay? GG I don't know. It depends. JD So you can stay for a while? GG I wouldn't want to, because I need to get my son's education, I need to take care of that. JD And that's back in Russia? GG That's the only choice I have right now JD What happened when you said he was harassed in school? You went back to Moscow, you moved from here and you went to Moscow to start out a new... 32:59 GG It started also here. I told you that once, he was given very, very bad grades and the parents approached me and they said let's go and fight, we are immigrants and are Russians and we have to fight. I am pretty sure it's all connected to you and I'm pretty sure they wanted to kind of, punish me for my son, to teach me lessons. And I said, no, I'm not going to go, I'm not going to fight for these grades. And this same woman, in front of a hundred people, she said it's not very clear whether I'm a slut or a whore DRAFT: FOR DISCUSSION PURPOSES ONLY 4 EFTA01128749 PRIVILEGED AND CONFIDENTIAL ATTORNEY CLIENT AND/OR Nardello WORK PRODUCT COMMUNICATION V..41Co. Time Stamp Speaker Conversation when we were applying for this school. And then, er, then [pauses] and then when we , the same thing was when he went to the camp, I am pretty sure he was harassed and there were accusations made that made me feel very uncomfortable. My son would come home from school saying expressions that I never taught him. For example, expression "let me color you black so it would remind me of the old days." JD Let me what? GG "Let me color you black so it would remind me of the old days." JD What does that mean? GG I don't know. JD I've never heard that before. GG He was taught this expression at school, to tell me. JD I don't even know what it means. GG I don't know what it means. I felt it was many other things. For example, I was invited to the game and I would see all the parents kind of acting very strange and when he started shooting, they would say "Sasha, we love you, we love you" but in a very acted out manner, which made me very uncomfortable. Then there was this guy [who] started pursuing us, saying Sasha had to be in a professional league for basketball and he was all dressed up and he was all sexual to me and to my son and when I refused to join the team, he said "you have to pay for my clothes." It was just, it was just terrible.... JD Somebody from the school? 35:15 GG Just some random guy, like black guy, started like harassing us, that my son used to — but then I have to pay him — ummm, we can go through the admission processes like in Horace Mann. I went to parents' week. Everywhere I went, there were kind of jokes and assumptions were made towards me and my son that they know that I'm with you and that I am a terrible person and I have to change. And when I would go to parents conferences-- JD But I'm, I'm- DRAFT: FOR DISCUSSION PURPOSES ONLY 5 EFTA01128750 PRIVILEGED AND CONFIDENTIAL ATTORNEY CLIENT AND/OR Nardello WORK PRODUCT COMMUNICATION 'Ai Co. Time Stamp Speaker Conversation GG The teachers would like, you know, made me bad about myself too — made me feel bad. JD Sasha was at PSI for what 3-- GG PS6 JD PS6 GG Yeah JD For what 3-4 years? GG 5 JD For 5 years. GG Yeah JD I remember at the beginning it was a little rocky. GG It was a rocky, yeah JD At the beginning, but then he was acclimating. I remember he had friends. GG Yes and then-- JD You said he was happy. He had sleepover dates— GO And then, and then the rumors— JD He was doing better at school - 36:15 GG Okay. Okay and then the rumors started that we are together and that was for other people an excuse to attack him and me. JD (Pause) Okay. So why during this whole period didn't you tell me any of this? GG I have been telling you sometimes. I told you he was getting bad grades. And I (Up— JD You told me he was getting bad grades-- GG It was very strange. No, No-- DRAFT: FOR DISCUSSION PURPOSES ONLY 6 EFTA01128751 PRIVILEGED AND CONFIDENTIAL ATTORNEY CLIENT AND/OR Nardello WORK PRODUCT COMMUNICATION Time Stamp Speaker Conversation JD Kids get bad grades sometimes. I got bad grades. GG No, but okay. I wasn't realizing what's going on. I wasn't realizing — I mean it was very strange and it, you know, I told you like people tried to drug me— JD But you never told me any of this when you were here— GG Okay, I told you— JD Not once-- GG Okay, you come to my apartment. I said I think I was drugged. I have been sick for two weeks. You said, "Oh, no" and started grabbing my boobs. You didn't even listen. I remember I told you that and you didn't even listen. Because I tripped for two weeks. That's the reason why I moved out from New York because I was scared. 37:19 JD No, you told me because of the visa issues you moved— GG I was afraid that you— JD You had just gotten your Columbia— GO Okay, okay-- JD You had just gotten your -- GG I was also— JD Columbia degree -- GG Okay, I was also— JD Okay. You graduated, you were looking for a job. I was trying to get you something at Goldman. Mort gave you something, um, at his— GG Okay, in Mort-- JD At his magazine. 37:41 GG In Mort's magazine, the articles were written for me and the words were twisted in a way that they, um, make me look that I have a certain point of view. Those articles I did not write. I was surprised that they were published articles writing them for me. And when they asked me to write DRAFT: FOR DISCUSSION PURPOSES ONLY 7 EFTA01128752 PRIVILEGED AND CONFIDENTIAL ATTORNEY CLIENT AND/OR Nardello WORK PRODUCT COMMUNICATION RI Co. Time Stamp Speaker Conversation the third article, I realized the things, the words they put in the articles are made in a way to diminish me, to make me look in a certain way, that 1 have a certain point of view on politics and economy. JD Why would they do that? GG I have no idea. JD Why would someone poison you? GG I have no idea. And I was scared, I was scared to tell you because I thought, maybe it was you who was doing that. ID Why would I do that? GG To get rid of me. JD Why would I get rid of you? [Pauses.) All I knew is that you had the visa issue and that you told me you had to leave. GG But you don't even know me! It's true. You don't know me. You don't know that I will stand up for myself. I'm not going to just let this go. It's true; you flicked me for six years, ok, let's say that for that last year we didn't see each other, it was six years and you don't know who I am. You have no idea what I'm made of. JD Alright. I guess what I don't understand is that we met six, seven years ago, I liked you, you liked me. I met you when you were living at 686 street in one room with Sasha, you needed a place to live near the school, PS 6. I got you an apartment so you that could be near PS 6, because you needed to be in that district; I agreed not even to come up to that apartment out of respect for you and your relation with your son; I was supportive and after nine months, you said that you didn't want to see me anymore, so we stopped seeing each other for about nine months. 40:19 GG No, you took me to museum, you took me to see Scream thing, to show me that it is a jealous person, a crazy person, who went crazy because they are jealous and then you had to take me to Frick museum and send me messages...you didn't stop...just the fact that... JD I didn't stop what? GO You didn't stop trying to see me. DRAFT: FOR DISCUSSION PURPOSES ONLY 8 EFTA01128753 PRIVILEGED AND CONFIDENTIAL ATTORNEY CLIENT AND/OR Nardello WORK PRODUCT COMMUNICATION .113Co. Time Stamp Speaker Conversation JD You stopped seeing me for nine months, then you said you wanted to get together again. GG I said that? 40:50 JD Yes; and then we got together again. And then you asked for a loan, and I gave you four years of loans. And then you had to leave because of your visa and I wanted to help you have a new start and I gave you some money, but I don't understand why you didn't come to me and say that you needed some help. Why, why all the threats? Why the extortion? I just don't get it. I want to help, I said I'd help, but we're into a whole extortion chapter right now and I don't understand why you're threatening my family. This is not something that we ever had with each other. GG I'm pretty sure that you are connected to all of this harassment and blame. JD Why would I harass you? GG I don't know. JD For what possible reason would I be supporting you and harassing you? It makes no sense. GG So you think people are just doing it because they want it? JD I think some of it maybe, you're feeling a bit paranoid but I don't know. When you say that waiters and hairdressers... GG Yes, yes JD ...I don't know what to make of that. I've never heard of anything like that. GG The way I look at things, during the last six, seven years, I was like a wife to you, right? You did all the things to me that usually a man does to woman when she is his wife. JD No, no, no. That is just not true. Number one, you knew that I had a wife and a family, you stopped seeing me for nine months, we got together, we saw each other maybe once a month, that is not everything Rill a man and a woman do together.... GG [interrupting) Did you read the newspaper yesterday? DRAFT: FOR DISCUSSION PURPOSES ONLY 9 EFTA01128754 PRIVILEGED AND CONFIDENTIAL ATTORNEY CLIENT AND/OR Nardello WORK PRODUCT COMMUNICATION .`•1Co Time Stamp Speaker Conversation JD ...I never forced myself on you in any way, so... 43:20 GG You exploited sex and exchanged a visa, and work, and paying for my rent. JD How did I exploit sex? GG Yeah, you exploited sex for promising me to find a job, to find me...Did you read an article yesterday? JD What article? GG About a young woman who sued a Wall Street guy. She slept with him four times and she got S80 million. JD Right... GG Yeah JD And he fired her and he defamed her? What does that have to do... GG You defamed me. JD How did I defame you? 43:50 GG You defamed me! Your friends defamed me. You did it through your friends because you are smart enough not to do it in my face, so you made your friends to destroy my life. JD What friends? GG Mort, Upstein [sic]. Who else? Bloomberg, Blavatnik. I got threats from all of them. JD Uh-uh GG Uh-uh. So you did it through your friends. It will be harder to prove, but you did it! It's because of you. JD That I got Mon and Bloomberg to threaten you, is that what you think? GG To treat me in a very disrespectful way. JD I didn't even know you knew Bloomberg. DRAFT: FOR DISCUSSION PURPOSES ONLY 10 EFTA01128755 PRIVILEGED AND CONFIDENTIAL ATTORNEY CUENT AND/OR Nardello WORK PRODUCT COMMUNICATION t4.ijCo. Time Stamp Speaker Conversation GG I told you. Are you going to tell me I didn't told you? JD If you did, I don't remember. I knew you knew Mort. Did you ever meet Epstein? 44:47 GG No, but he called me. Yes, I met with him and when we came to his place, this girl, she told me that you have to understand that these men, they need a few women a day, if you don't do it, they're not going to be happy. I'm not that type of woman. JD Why would I want to defame you and I was supporting you? GG Because you're scared that I would go public. You got scared that I would go public. JD Go public with what? GG With our relationships. You're not scared? JD That I had an affair with you? And treated you well? 45:30 GG No, you sexually harassed me. And [UI, possibly "irritated" me]. JD How did I sexually harass you? GO You're entitled to have an opinion. I didn't have a choice. You kept me in fear and in poverty and you managed to organize that I don't have a job... JD How did I do that? What job did you try to get? GG ...you masterfully manipulated me to be dependent on you and stay small. JD And that's why I put you through school at Columbia. GG You didn't put me, I went there. JD Who paid for it? GO Yes, and I took loan from you. You paid for it, you paid for it because you just wanted to make sure that... JD Because I didn't want you to get a job, when you wanted to go back to school? GG Why are you doing this, you are a very smart man! You are a very smart DRAFT: FOR DISCUSSION PURPOSES ONLY II EFTA01128756 PRIVILEGED AND CONFIDENTIAL ATTORNEY CLIENT AND/OR Nardello WORK PRODUCT COMMUNICATION p. Co. Time Stamp Speaker Conversation man, why are we doing this? Can you tell me? JD We're doing this because I don't understand. GG You don't understand? 46:30 JD Right now, this is, you're threatening me, this is an extortionist plot and I want to put this behind me. My wife's cancer has come back, my sister's cancer is back and it's a very pessimistic prognosis, I don't think she is going to last very long. GG Ok. JD Ok, I don't want to be dealing with extortion. I'm sad that that's what this has come to, because I think, at one point, we cared about each other, but this is, why in the world, you've talked about how...I'11 tell you what I'm willing to do, I want you to have some security, I want you to have some security with Sasha. You know, in the first few years we knew each, I think I paid you a million dollars, then you had a million dollars of loans for four years and then when you went away, I gave you a million dollars, basically to help you get a new start. I was sad when you went away, I didn't want you to go away, but you had to go away because you had a visa issue. GG No, never, that's why you were making jokes before I told you "oh, who is she, who is she" with your friends. JD No, I never talked to my friends about you... GG Ok, whatever. JO ...so I don't know why you're saying that, that's not true. It's just not true. GG Ok JD So, on average, I gave you about $300,000 to $350,000 a year. What I'm willing to do, I do believe it's total extortion, but I do want to put this behind me, is to do $600,000 for eight years. So you have eight years of a good living, you don't have to worry about money, that's after-tax money. I have to pay a gift tax on that of 50%. 49:00 GG You know, for you, it's about money. I don't think you care about my family, I don't think you care about your family, I think you care about your business. And for me, it's not about money, it's about respect. I think DRAFT: FOR DISCUSSION PURPOSES ONLY 12 EFTA01128757 PRIVILEGED AND CONFIDENTIAL ATTORNEY CLIENT AND/OR Nardello WORK PRODUCT COMMUNICATION ,` ,Co. Time Stamp Speaker Conversation you were very unfair to me, I think you were abusive... JD How was I abusive to you? GG You know, you liked to... JD I was never abusive to you. GG You liked to make to me feel worthless and to, you know, put me down and make me feel like I'm nothing. JD And that's why I paid for your ski holidays, your beach holidays, gave you and your son basketball tickets, because I was putting you down? That's why I put you through school and told you how proud I was of you, because I thought you were worthless. GO That's not the way I look at it. JD How was I putting you down? GG I think that's not the way I look at it and in the last two or three years, your friends and other people have been extremely unfair and abusive to me, you know. JD What this is, Bloomberg and Epstein and Mort and Blavatnik? GO And at my son's schools, all over the world? JD I don't know anybody at your son's schools. GG Ok, I know, I know what happened to me at my son's schools and it happened... JD Why would I do that, why would you think it was me who did that and at the same time as I am supporting you? GG No, I don't have any proof that you've done it, right, but it all comes from our relationship. If we didn't have a relationship, this wouldn't happen to me or my son. JD Well, you're right, he wouldn't have been at that school because he wouldn't have had an apartment there. 51:00 GG Ok, and so, for me, it's about, it's about me being happy with myself, I cannot sleep very well, I cannot wake up and look at myself in the mirror DRAFT: FOR DISCUSSION PURPOSES ONLY 13 EFTA01128758 PRIVILEGED AND CONFIDENTIAL ATTORNEY CLIENT AND/OR Nardello WORK PRODUCT COMMUNICATION `'A Co. Time Stamp Speaker Conversation and to say, that is right. You know, I cannot have sex with anyone, I cannot start a relationship. I am afraid to look for a job because of the way I was treated at jobs interviews right, from Goldman Sachs etc. Ah, my life is for me, it's terrible and I don't want any other woman to go through the feelings that I felt during our relationship with me and you and after. Ok? And um, so for me it's very important to, you know, to get it out of my chest and just, you know, um, and to say that it is wrong and it's been very, very painful. It's been extremely painful. And I am not the type of woman who lives with a man just for the rent. JD But you didn't live with me. GG And I'm not the woman who would say it's ok for people to harass my son and to harass me just because my rent is paid for another couple of years, even if it's 8 years. This is not OK. JD And so you've come to the conclusion that it's not about the money but the only way to have your respect back is for me to pay you 100 million dollars. But it's not about the money. 52:25 GG I think if you can take care of my financial stability which you can do, that would be great. Um...and I also feel that in the best case scenario our relationships were as though we are a couple and you have an obligation to me. You're a wealthy man. You're capable after 6 or 7 years, you're capable of providing for the rest my life. You know if you want to look at it differently, in the worst case, there was a lot of abuse and ah, mistreatment from your side and others. And harassment and all this stuff - defamation retaliation, um, battery, abuse, uh...you name it. JD And this is what you would claim? 53:27 GG Lots more. Sexual harassment. I would claim that I lived in fear because I didn't know where to go. I'm an immigrant. I was a 25 year old when we met. I was just really afraid. And you promised me to get a job, which you never did. You promised to help me get a visa, you never did. And you did it on purpose to keep me dependent on you. Yes. 54:01 JD So unless...you're saying, 100 million dollars you're going go and basically ruin my reputation GG What? DRAFT: FOR DISCUSSION PURPOSES ONLY 14 EFTA01128759 PRIVILEGED AND CONFIDENTIAL ATTORNEY CLIENT AND/OR Nardello WORK PRODUCT COMMUNICATION !ZI Co. Time Stamp Speaker Conversation JD Basically you're out to ruin my reputation. GO I...ah...My reputation is ruined. I'm just going to tell the truth about my reputation. JD Right. But the purpose is, the cost of my reputation is 100 million dollars 54:29 GG I'm thinking you know, if you can take care of me and make me happy with this money, I can protect my family from all the things you've done to me. JD I haven't done anything except be kind to you. And you know and I know it. JD I've never harassed you. I've never abused you. This is pure nonsense, fiction, extortion. 55:18 JD Ouzel, 5 million dollars is a lot of money GG It's not about money for me. It's about... JD And yet you talk about 100 million dollars and then you say it's not about money. Which one is it? GG I think that is what would be fair. 55:40 Waiter delivers food, discussion with waiter. 56:37 JD How did you come to 100 million dollars? 56:40 GG I told you how. I need to find a job. 1 need to have enough money in the bank...(UB... And I also need a British passport. (U0 57:05 GG If I was your wife, I would be entitled to a couple of billion dollars. I don't know how much you've made in the last 7 years, how much money you've made. JD A lot...a lot...but... GG And I think I deserve every penny of it. Because you've been very controlling. Very rigid. And you took over my life. You took over my life. JD I didn't take over anything. DRAFT: FOR DISCUSSION PURPOSES ONLY 15 EFTA01128760 PRIVILEGED AND CONFIDENTIAL ATTORNEY CLIENT AND/OR Nardello WORK PRODUCT COMMUNICATION Co. Time Stamp Speaker Conversation GG You took over my life. JD You broke off the relationship. You asked for a loan. I gave it you. We saw each other once a month. How did I take over your life? And then you had to leave. 57:54 ID And all this harassment. I never heard a word of it. I never heard a word of any of these issues. And it's only a year later After we haven't seen each for a year, it's coming out. GG I'm telling you now. JD You know, I want to put this behind me but, I mean, there's no place to go with 100 million dollars. First of all I don't have the type of money around. I have debt. I have...my kids have trusts. Um...it's 50 million of gift taxes on top of that. GG (UI). For me it's safer. You know. Because for me, I know my son will not be harassed. I know that I will not be harassed. JD You said he choked on a piece of steak a month ago and that that was my fault. GG I didn't say that. JD Oh, yes you did. At breakfast. You said you thought he was emotionally upset cause he saw you were upset and therefore that's why he choked and therefore it's my fault. What do you do with that? GG You don't understand that... JD I'm trying to understand. That's why I'm saying I want to put this behind me as I said my sister and wife both have cancer that have come back, that's really serious. The woman may be dying. I don't want to have to deal with this. That why I thought something very generous of 5 million which is a lot more than what you lived on while we were together... is fair and reasonable... even though it's total extortion. GG I disagree. JD I mean where is all this coming from? Is this from Alissa? Is this your husband and his colleagues? DRAFT: FOR DISCUSSION PURPOSE ONLY 16 EFTA01128761 PRIVILEGED AND CONFIDENTIAL ATTORNEY CLIENT AND/OR Nardello WORK PRODUCT COMMUNICATION !la Co. Time Stamp Speaker Conversation 1:00:33 GG You know, it's very simple. Yes or no. And I'm not going to wait any longer from today. If it's no, I'm going to lawyers and I'm going public. And that's it. I cannot wait anymore. I can't put my life on hold. 7 years is enough. 1:01:22 GG How can you be with a woman for 7 years, sleep with her, share a bed with her, do everything for her and then you say oh, I don't even know who you are and I don't want to help you. How can you do that? It's impossible. JD I don't think that's what I said. I said I do want to help you. And I want to help you for 8 years at twice the amount that I was helping you when we were together. I mean, how do you say that that's not helping you? 1:02:01 I went through a lot of public humiliation. My reputation is really damaged. My son's future opportunity... JD But I didn't do that. GG Permanently... GG But it's because of our relationship. It's a consequence... JD I didn't do that. GG It's a consequence of our relationship. And, as a man, as a decent man. As a fair man, you can understand that. And you can help. It's not difficult for you to help me. 1:02:25 JD And I am helping you. 5 million dollars over 8 years is a lot of money. It's a lot more then you lived on for the last six years. 1:02:37 GG Ok, all those years I lived very badly. And you could have taken care of me ...better care. You could have given me a job. You could have given me a visa. JD You were in school for a bunch of that time. GG Listen, You wanted to keep you small. JD No, I didn't want to keep you small and 1 never wanted to stop you from working. DRAFT: FOR DISCUSSION PURPOSES ONLY 17 EFTA01128762 PRIVILEGED AND CONFIDENTIAL ATTORNEY CLIENT AND/OR Nardello WORK PRODUCT COMMUNICATION LWCo. Time Stamp Speaker Conversation 1:02:53 GG And this time...I want to tell you and I want to do what's right for me. I totally deserve it. I deserve more. 1:03:26 If I'll sue you, I'll sue you for a billion dollars for all the damage you've done to me and my life. And you know what, in business you're going to lose even more. Nobody's going to invest with you. You understand that. 1:03:50 JD So this is just pure out and out extortion. GG It's not an extortion. It's not an extortion. 1:03:54 JD How is it not? When you're threatening my family, my business... 1:03:59 GG It's not an extortion. JD But unless you know, unless you get an exorbitant amount of money.