Page 1. VERITEXT REPORTING COMPANY

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1 Page UNITED STATES BANKRUPTCY COURT 3 EASTERN DISTRICT OF WISCONSIN x 4 In Re: JAMES E. PUTMAN and CHRISTINE A. PUTMAN, Case No.: mdm 5 Debtors x DAVID M. AND BARBARA G. ANGELL, et al, 7 Plaintiffs, 8 vs. Adversary No mdm 9 JAMES E. PUTMAN, 10 Defendant x 11 TONY P. TRIMBLE, Plaintiff of the TONY P. TONY P. TRIMBLE REVOCABLE TRUST AGREEMENT 12 dated September 4, 1998, 13 Plaintiff, 14 vs. Adversary No.: mdm 15 JAMES E. PUTMAN, 16 Defendant x January 5, :30 a.m. 19 One Battery Park Plaza 20 New York, New York DEPOSITION of JOSEPH AARON, in the above-entitled action, held at the above time and 23 place, taken before Randi Friedman, RPR and a Notary Public of the State of New York, pursuant 24 to the Federal Rules of Civil Procedure, Order and stipulations between Counsel. 25

2 2 A P P E A R A N C E S : 3 MELNICK & MELNICK, S.C. 4 Attorneys for Plaintiffs N. Port Washington Road, Suite Mequon, Wisconsin BY: DAVID A. MELNICK, ESQ. 7 8 STEPHANIE L. MELNICK, ESQ. 9 SEWARD & KISSEL, LLP Attorneys for the Deponent, Joseph Aaron 10 One Battery Park Plaza New York, New York BY: MICHAEL B. WEITMAN, ESQ. 13 * * * Page 2

3 Page 3 2 S T I P U L A T I O N S 3 IT IS HEREBY STIPULATED AND AGREED, by 4 and among counsel for the respective parties 5 hereto, that the filing, sealing and 6 certification of the within deposition shall be 7 and the same are hereby waived; 8 IT IS FURTHER STIPULATED AND AGREED that 9 all objections, except as to form of the 10 question, shall be reserved to the time of the 11 trial; 12 IT IS FURTHER STIPULATED AND AGREED that the 13 within deposition may be signed before any Notary 14 Public with the same force and effect as if 15 signed and sworn to before the Court. 16 * * * *

4 Page 4 2 * * * 3 J-O-S-E-P-H A-A-R-O-N, the 4 witness herein, after having first been duly 5 sworn by a Notary Public of the State of New 6 York, was examined and testified as follows: 7 * * * 8 9 EXAMINATION 10 BY MR. MELNICK: 11 Q. Good morning, Mr. Aaron. My name is 12 David Melnick. This is Stephanie Melnick. As we 13 talked off the record, you are a witness in a 14 proceeding that has been brought against Jim 15 Putman and his wife in an adversary proceeding, 16 it's called, in Bankruptcy Court. 17 And you understand you're just a 18 witness in that case? 19 A. I do. 20 Q. Okay. I also took the time so I 21 wouldn't -- I'm trying -- you've been through 22 this a few times before, and I'm trying not to go 23 over -- so I'm not going to worry about 24 background, establishment questions. I'm just 25 going to get to the heart of everything; okay?

5 Page 5 2 A. Okay. 3 Q. So I'm going to start with the 4 insurance companies. 5 Going through your records, I noticed 6 that you would authorize your bank to pay the 7 insurance companies, whether it was first-year 8 premium or second-year premium, and the bank 9 would pay the insurance company directly; is that 10 your understanding? 11 A. Yes. 12 Q. So MR. WEITMAN: I'm sorry. I don't 14 mean to disrupt. 15 MR. MELNICK: Go ahead. 16 MR. WEITMAN: I appreciate the not 17 doing all the background, but if we could 18 maybe get some clarification with, you know, 19 you and your bank account and what we're 20 talking about exactly. 21 MR. MELNICK: Oh, if you want me 22 to ask establishment questions, I will. I 23 know how to do it. I know how to do it. 24 MR. WEITMAN: Just to keep the 25 record clear so there's a difference between

6 Page 6 2 Mr. Aaron, the funds, Wood, Hat & Silver. 3 That's all. 4 BY MR. MELNICK: 5 Q. Then let's start over again, 6 Mr. Aaron; okay? 7 You were the general partner for 8 various funds, and maybe still are, between -- 9 and the years I'm talking about are between and the present; is that correct? 11 A. Yes. 12 MR. WEITMAN: Object to the form. 13 BY MR. MELNICK: 14 Q. Those funds are Baetis and Brown? 15 A. Yes. Two of them. 16 Q. Two of them. And what are the other 17 funds? 18 A. Tippet, Convertible Arbitrage Fund of 19 Funds. Caddis, C-A-D-D-I-S. Mayfly, 20 M-A-Y-F-L-Y. Stonefly, S-T-O-N-E-F-L-Y. And 21 there's others that just don't come to mind right 22 now. 23 Q. I can help you a little bit. Here we 24 go. Quetzal, Q-U-E-T-Z-A-L? 25 A. No, I had no association with Quetzal.

7 Page 7 2 Q. Watchstone? 3 A. I had no association with Watchstone. 4 Q. And Pantera? 5 A. I had no association with Watchstone. 6 They were investors. Watchstone was an investor 7 in either Baetis or Brown. 8 Q. Okay. And that would apply to Griffin 9 and Palisades also? 10 A. That's correct. 11 Q. Yeah, okay. Now, which of the funds 12 which you've enumerated -- by the way, if this 13 refreshes your recollection, there was Cutthroat, 14 Calibaetis, Greyling A. Those are the names. 16 Q. Okay. And you were also A. I was the general partner of those 18 funds. And I was the sole general partner of Wood, Hat & Silver was the general partners of 20 those funds. I am the sole shareholder I should 21 say. 22 Q. Of Wood, Hat & Silver? 23 A. Of Wood, Hat & Silver, LLC. 24 Q. Okay. Now, these -- which of these 25 funds invested in insurance premium financing?

8 Page 8 2 A. Baetis, Brown, Tippet and Caddis, to 3 the best of my recollection. 4 Q. Let me help you out a little bit 5 because I'm not here to put any mine fields. 6 Didn't Stonefly also invest in insurance premium 7 funds? 8 A. Yes, it did. Thank you. 9 Q. And -- now, Cutthroat -- did Cutthroat 10 precede one of these funds? That is, did 11 Cutthroat either merge or meld into one of these 12 funds because Cutthroat was also invested in it 13 at one time; didn't it? 14 MR. WEITMAN: Objection. 15 MR. MELNICK: I know there was two 16 questions. It was a compound question. 17 BY MR. MELNICK: 18 Q. First of all, did Cutthroat invest in 19 insurance premiums funds? 20 A. I don't think so. 21 Q. Okay. And the second question was, 22 did Cutthroat become, either by merger or any 23 other process, another one of the funds where 24 Cutthroat would have stopped and the other fund 25 continued?

9 Page 9 2 MR. WEITMAN: Object to the form 3 of the question. 4 THE WITNESS: My recollection is 5 that Cutthroat held an investment in an 6 entity named MKA. And if it did, we 7 transferred the MKA interest -- well, to 8 Baetis and Brown or to one of the two firms' 9 funds. 10 BY MR. MELNICK: 11 Q. Now, within the insurance premium 12 financing area, the funds like Baetis and Brown, 13 would invest in life insurance policies, and in 14 that process, they would pay the premiums for the 15 applicant? 16 A. That's correct. 17 Q. And I understand it's a more elaborate 18 process, but I'm trying to get to the question I 19 first started out with because I'm a very direct 20 person. I wanted to get there, but I've got to 21 finish this process. 22 So then in paying the insurance 23 premiums, if you were funding a policy, you would 24 send -- you being, I guess, three or four 25 entities, Joe Aaron, Wood, Hat & Silver, Baetis

10 Page 10 2 and Brown, and I don't know if there are any 3 other -- would in that process send a premium to 4 the insurance company that the policy applied to? 5 MR. WEITMAN: Object to the form 6 of the question. 7 THE WITNESS: The general partner, 8 Wood, Hat & Silver, would direct the 9 custodian, Union Bank of California, to wire 10 funds to the carrier that issued the 11 individual policies that were held in Brown 12 and Baetis. And as I recall, Brown and 13 Baetis are the only ones -- only 14 partnerships associated with Wealth 15 Management. No. And Caddis, C-A-D-D-I-S. 16 BY MR. MELNICK: 17 Q. Now, what I'm trying to do is follow 18 the money from Baetis to the insurance companies. 19 A. Sure. 20 Q. You and -- and I notice that on the 21 documents you would say whether it was first 22 year's premium or second-year premium? 23 A. Yes. 24 Q. Correct? 25 A. That's correct.

11 Page 11 2 Q. Would you also say, obviously, who was 3 the name on the policy if it was, quote, John 4 Brown or Jim Jones, that would be there also; 5 correct? 6 A. The statement would generally be, this 7 is a first-year premium or second-year premium or 8 additional premium on the Smith case, and that 9 would be the direction that would show on the 10 custodial statements. 11 Q. But it would also have the 12 insurance -- the insurance policy number that you 13 were funding; wouldn't it? 14 A. It would be included in the 15 instructions, yes. 16 Q. Right. And it would go -- and this is 17 the key part. This is the question I was trying 18 to ask in the beginning. It would go from Baetis 19 or Brown directly to the insurance company that 20 was issuing the policy? 21 A. That's correct. 22 Q. Okay. The information that was on 23 the -- what did you call it, forwarding document 24 or what was the name of the document that you 25 would -- that would be a record of the bank

12 Page 12 2 transaction to the insurance company? 3 A. It didn't really have a name. We just 4 referred to it as the custodial instructions. 5 Q. So if I call it during the rest of the 6 deposition custodial instructions, we all know 7 what we're talking about or not? 8 A. I would. 9 MR. WEITMAN: Okay. If the 10 witness does, that's fine. 11 THE WITNESS: Custodial 12 instructions is what we write on the 13 memoranda that goes to the custodian and 14 gives them authority to send the money. 15 That's what they charged us monthly fees 16 for. 17 MR. WEITMAN: Just so I -- I just 18 want to make sure I'm on the same page. Are 19 you referring to the letters that instruct 20 funds to be wired from MR. MELNICK: Yes. And I will 22 show examples. 23 MR. WEITMAN: No problem. 24 MR. MELNICK: I'm trying to get to 25 where I started out first. Sorry for the

13 Page 13 2 long process here. 3 THE WITNESS: No problem. 4 BY MR. MELNICK: 5 Q. So then you would send the money to 6 those insurance companies, and you would have 7 been given a policy number to put on your 8 custodial instructions? 9 A. I would think so. 10 Q. Now, where did you get that 11 information from; the insurance company, a 12 representative of the insurance company or the 13 insurance agent licensed to that company? 14 A. The insurance agent. 15 Q. So the insurance agent, who would have 16 had to have been licensed to that company right? 18 A. Correct. 19 Q. -- would forward that information to 20 you? 21 A. Correct. 22 Q. Was it ever in writing? I didn't come 23 across anything in writing. Or did they give it 24 to you orally? 25 A. If we -- I would have to refer to the

14 Page 14 2 individual letters of instructions to the 3 custodian to see if we put them down. We always 4 put the name of the case. 5 Q. Yeah. 6 A. And we always said, this is a first or 7 second-year premium payment. I don't know if we 8 listed the account numbers -- excuse me, the 9 policy numbers or not on every one. I'd have to 10 go through them and see. 11 Q. I'll just tell you and you'll see them 12 later, but you did. The policies numbers were on 13 there. 14 But my question is the agent's name 15 wasn't on there? 16 A. No. The agent's name wouldn't appear 17 there, I don't think. 18 Q. I'm talking about on your 19 forwarding A. On the custodial instruction, it would 21 not. 22 Q. Okay. Do you remember the insurance 23 companies that you did business with; that is, 24 you sent money to? 25 A. Well, by and large they're all generic

15 Page 15 2 names in the insurance business, and I would 3 recognize most of them, yes. 4 Q. Off the top of your head, can you tell 5 me what you remember? 6 A. Lincoln, AXA -- 7 Q. A-X-A? 8 A. Right, A-X-A. AIG. Those are the 9 three that come to mind. 10 Q. Phoenix? 11 A. Nationwide. Phoenix, yes, a lot with 12 Phoenix. 13 Q. Sun? 14 A. Yes, that would be a name. 15 Q. Okay. I mean, again, I understand we 16 can probably obtain all this. I'm trying to 17 figure out what you remember in terms of these 18 companies. 19 A. It was not important to me the name of 20 the company. The rating, if they were A rated or 21 not, was important. Nothing else was important 22 there. 23 Q. Were all these companies, to your 24 knowledge, A rated at the time you invested? 25 A. At the time we invested, we financed a

16 Page 16 2 policy. 3 Q. Now, the policies that you financed, 4 at the end of the day, the buck ended with you, 5 did it not? You decided what would get financed? 6 A. No. 7 MR. WEITMAN: Object to the form. 8 THE WITNESS: I did not. In 2006, 9 after a routine -- I registered as an 10 investment advisor with the SEC in In , six months, approximately, after I had 12 registered, they did a routine inspection 13 that they do of every new registrant. And 14 they went through the material and insisted 15 I make disclosures to the limited partners. 16 Those limited partners, two of which were 17 Baetis -- excuse me, Griffin -- well, 18 partnerships in which Wealth Management 19 acted as the general partner. The 20 instruction was that there were other 21 investors in, for example, Baetis other than 22 Wealth Management clients, and I had to 23 disclose to these other investors that I 24 had, in effect, ceded investment authority 25 to Wealth Management.

17 Page 17 2 BY MR. MELNICK: 3 Q. Okay. Let me try my question again. 4 I want to walk through the process of how a 5 policy gets funded. 6 Again, if we want to break up the time 7 period then let's talk about 2003 through 8 mid-2006; okay? 9 During that period of time, various 10 insurance agents would bring policies to your 11 attention? 12 A. That's correct. 13 Q. And these were policies that 14 presumably they had already written, but wouldn't 15 submit unless they could be financed? 16 A. That would be correct. 17 Q. Okay. 18 A. That would be my understanding. 19 Q. Okay. And then you would have to sort 20 through all the policies you were given and 21 decide which was appropriate for funding? 22 A. That's correct. 23 Q. And then -- my assumption is, and is that there were policies that you did not 25 fund?

18 Page 18 2 A. That would be correct. 3 Q. Okay. And am I also correct saying 4 there were more you did not fund than you 5 actually did fund? 6 A. I don't recall. 7 Q. So you had determined, at least, 8 again, through midway through '06, from 2003 to 9 mid-2006 what policies were going to be financed, 10 and then you would forward the money to the 11 insurance company? 12 A. That's correct. 13 Q. Now, the process that had taken place 14 prior to that, to your knowledge, is that an 15 agent would somehow obtain an applicant; right? 16 A. Correct. 17 Q. Do you know how these agents obtained 18 these applicants? That is, were these people 19 they had long-term relationships with or were 20 they soliciting older people? 21 MR. WEITMAN: Object to the form. 22 BY MR. MELNICK: 23 Q. To your knowledge? 24 A. No. I didn't know. 25 Q. You did not know?

19 Page 19 2 A. I did not know. 3 Q. Okay. So at any rate, a policy would 4 be issued, and the insurance company, to my 5 knowledge, would have already gone through their 6 underwriting process of whatever is required for 7 that policy to have been issued prior to it 8 getting into your hands? 9 MR. WEITMAN: Object to the form. 10 THE WITNESS: The terminology, I 11 think, that is more appropriate would be to 12 say the insurance carrier issued an 13 illustration. That illustration would be 14 the basis of which we would determine this 15 policy met our criteria for funding. The 16 policy -- we might say yes, we're going to 17 finance this policy. But the policy might 18 be issued by the carrier a month later or 19 six months later or not at all. You 20 never -- you never knew. 21 BY MR. MELNICK: 22 Q. But you're not going to fund it until 23 it's issued? 24 A. Correct. 25 Q. All right. And you have, as I recall,

20 Page days or the applicant has 30 days from the 3 time the company says we're issuing the policy to 4 pay the policy, or the policy's canceled? 5 A. I think that varied from carrier to 6 carrier, but that's a fair generalization. We 7 had plenty of time. 8 Q. And it was during that period of time 9 when you would decide what gets funded? 10 A. Correct. 11 Q. Now, just so I understand the timing 12 of this, when you decide to fund -- when you 13 decided, that is, to fund a particular policy 14 under Baetis and Brown, was there a guarantee 15 that if you funded it, that although not right 16 away, but at some point in time, the insurance 17 company was going to issue a policy? 18 A. Yes. 19 MR. WEITMAN: Object to the form. 20 (Whereupon, there was an 21 interruption.) 22 THE WITNESS: I'm sorry, I'm going 23 to ask you to repeat the question. 24 (Whereupon, the reporter read back 25 the requested portion of the record.)

21 Page 21 2 THE WITNESS: I wouldn't say there 3 was a guarantee. They could always back 4 out. They had full authority to back out. 5 BY MR. MELNICK: 6 Q. Did any back out? 7 A. To my knowledge, no. 8 Q. Now, when you review the policy, you 9 said there was certain criteria? 10 A. Correct. 11 Q. That you used? 12 A. There were certain standards that I 13 had. There was a software program that we had 14 purchased from Milliman, M-I-L-L-I-M-A-N, 15 Associates. They're the world's largest 16 actuarial firm. 17 Q. I see. 18 A. And I think we paid in excess of 19 $20, for that software. 20 Q. When you say "we," Wood, Hat & Silver, 21 Baetis, Brown? 22 A. Wood, Hat & Silver. 23 And we would enter the information 24 from the illustration into the software. And it 25 would come back and give us an imputed rate of

22 Page 22 2 return based upon the age and life expectancy of 3 the insured, as well as the terms of that policy. 4 Q. So a 75-year-old who buys her first 5 insurance policy at that age for five 6 million-dollar -- universal life policy, you're 7 saying that you would feed the illustration into 8 that software and it would give you information 9 on what the policy is worth or -- I'm still not 10 understanding what kind of information? 11 A. If we paid the first and second-year 12 premium, would we be able to sell it for enough 13 to recoup our principal and interest in the 14 profits. 15 Q. Now, again, I'm trying to understand 16 it because I'm very familiar with Milliman and 17 when it was Milliman and Robertson. My question 18 was: How would that software determine what a 19 sale price would be in an industry that between 2003 and mid-2006, was pretty new? 21 MR. WEITMAN: Object to the form. 22 THE WITNESS: I have no idea. 23 BY MR. MELNICK: 24 Q. Okay. Now, the other criteria that 25 you used were what? Milliman was just one;

23 Page 23 2 right? 3 A. It was the standards. It was the deal 4 breaker. I could look at a policy and say this 5 one's going to work. After you ran Milliman, it 6 didn't. We would be surprised, but there was 7 always a reason, and you would call up Milliman 8 and they would try to explain it to you. You 9 could say one isn't going to make it and it would 10 come through as financeable. It varied from case 11 to case. 12 Q. But other than the Milliman software, 13 I wanted to know what tools you used to make your 14 decisions. 15 A. One of the items that was required to 16 run the Milliman software was two life expectancy 17 reports. Life expectancy companies, that was the 18 business. They would look at the medical records 19 which, of course, had to have been provided to 20 the insurance carrier. They would provide the 21 same information to the life insurance -- life 22 expectancy company. The life expectancy company 23 would issue a report and say this 80-year-old 24 woman is -- she's in good health. She's probably 25 going to live another ten years. And that was

24 Page 24 2 something that Milliman, of course, had no 3 control over. And I had no control over. But 4 that was a criteria that was needed to complete 5 the software. 6 Q. So we had Milliman and two LE 7 companies that you would use, which was 21st 8 Services and AVS? 9 A. That's correct. There were three or 10 four other companies, but they had no standing in 11 the industry. 12 Q. Well, Fasano did; didn't it? 13 A. Fasano did. 14 Q. At any rate, so was there any other 15 criteria that you used other than the AVS -- AVS 16 only would tell you how long you said -- you used I used 75. Makes no difference. The year-old living ten years. That's all that LE 19 company is going to tell you, how long they the possibilities are that she's A. And they expressed it. 22 MR. WEITMAN: I object. 23 THE WITNESS: Sorry. 24 MR. WEITMAN: Sorry. 25 BY MR. MELNICK:

25 Page 25 2 Q. And it would be like 122 months. 3 A. Correct. 4 Q. And that meant something to you? 5 A. Yes. 6 Q. Because that will be a little over ten 7 years, 122 months? 8 A. Correct. 9 Q. And you're saying there was nothing 10 else other than the Milliman software and the LE 11 companies that you would use to base your 12 decisions on? 13 A. Well, you could give me a 50-year-old 14 and the life expectancy companies would say 15 they're going the live a full 100 months. It 16 would never, of course, be approved, so the 17 agents knew to not submit a policy for 18 consideration unless it hit the sweet spot. And 19 the sweet spot fell, I'm going to say, I 20 preferred 78 to 82. If you got above 82 the cost 21 of insurance would go up. That would make 22 policies unfinanceable. 23 If it was below 78, the number of 24 payments, along the LE's estimate of longevity 25 would make the policy unfinanceable on a cash

26 Page 26 2 flow discounted basis. 3 Q. So the record's clear, the 78 to 82, 4 you're talking about is years old, not months to 5 be alive? 6 A. Yeah. I'm sorry, absolutely. That's 7 a very key distinction there. You're right. 8 Q. I knew what you were talking about. 9 A. Did I say months? 10 Q. No, you didn't. That's why I wanted 11 to clear the record. Okay. 12 So at any rate, yes, you had -- I 13 didn't want to cover this because you've covered 14 it before. You were looking at the 75 and above 15 and probably had a 10-year span in there? 16 A. Correct. 17 Q. That's who was your targeted audience 18 of -- or user of the services; correct? 19 A. Correct. 20 Q. Yeah, okay. Now, in order for me to 21 ask some other questions, I want to go over some 22 names and just so I understand how they fit into 23 things. Elizabeth Branstetter, 24 B-R-A-N-S-T-E-T-T-E-R? 25 A. Correct.

27 Page 27 2 Q. Who is she? 3 A. Elizabeth was the fund's accountant. 4 Q. Which fund's accountant? 5 A. Baetis and Brown and all of the funds 6 in which Wood, Hat & Silver acted as general 7 partner. 8 Q. Okay. From what years to what years? 9 A. To the best of my recollection, forward. 11 Q. Okay. So she still is in that 12 position? 13 A. She no longer -- no. Yes, she is. 14 She's still doing some reporting for the receiver 15 on the Baetis fund. 16 Q. Okay. And the receiver, we're talking 17 about is Faye Feinstein who was appointed by the 18 Federal Court? 19 A. That would be correct. 20 Q. But in terms of what she had been 21 doing, when did her normal activities as the 22 accountant for the various funds end? 23 A. When we could no longer afford to pay 24 her. 25 Q. And that would have been about the

28 Page 28 2 time the receiver took over in May of '09? 3 A. No. It would have been after that. 4 I'm trying to remember when she went from being a 5 flat payment to an hourly basis. 6 Q. Okay. Tyler Adams, who is he? 7 A. Tyler was the predecessor to Elizabeth 8 Branstetter. 9 Q. He's an accountant? 10 A. I don't recall if he was an accountant 11 or not. 12 Q. Now, he worked for you from what years 13 to what years? 14 A. I misspoke. Tyler was not the 15 accountant. That would have been Maren Eattock. 16 Tyler worked for me, let's see, 2005 to 2006, to 17 the best of my recollection. And after he left 18 us we hired Elizabeth. 19 Q. Just so I understand, I'm not sure I 20 understand his duties. You say he wasn't an 21 accountant but he did accounting? 22 A. He assisted with the accounting. He 23 was not the independent accountant. 24 Q. Okay. The independent accountant 25 during those 2005 to by the way, believe

29 Page 29 2 me, I'm not here to argue with you, I thought he 3 and one other person left your employ in One went back to school and they both left before 5 the end of But, again, if that refreshes 6 your recollection, fine. 7 A. It does. 8 Q. If it doesn't, I'm not here to argue 9 with you. 10 A. It does. I can correct -- that is Maren Eattock, E-A-T-T-O-C-K, and Maren is 12 M-A-R-E-N. Maren Eattock left to attend business 13 school. And she did the accounting for us from 14 the time she left my employment. Tyler worked 15 for me to put the accounting material together, 16 lower our costs and save time as a bridge between 17 the funds and Maren. And -- but they both quit 18 at about the same time. 19 Q. Okay. Just so as a general rule, your 20 attorney was kind enough to provide me with 21 probably over 50,000 documents. 22 To your knowledge, were all those 23 business documents made in the ordinary course of 24 your business? 25 A. Yes.

30 Page 30 2 Q. Okay. You didn't make any special 3 just for Stephanie and I; did you? 4 A. No, there were plenty. There were 5 plenty to spread around, yes. 6 Q. But you didn't make any new documents? 7 All those documents were made in the ordinary 8 course of business? 9 A. Correct. 10 Q. All right. So if it has Tyler Adam's 11 name on it, it would have been made when he was 12 your employee? 13 A. Absolutely. In spite of my failure to 14 remember when he worked for me. 15 Q. Brian P-U-N-G, Pung? 16 A. I'm sorry, I don't recall that name. 17 Q. That's okay. 18 A. Brian Pung, P-U-N-G; okay. 19 Q. I'm sure your attorney told you, don't 20 guess. Tell us what you know. We all do. 21 Now, this one I know you'll know. And 22 you can separate it or put them together, Dan 23 Miller and RangeTree. 24 A. Correct. 25 Q. Now, are they one and the same or are

31 Page 31 2 they actually two separate entities, so to speak? 3 A. Dan Miller was the sole shareholder to 4 RangeTree to my understanding. 5 Q. And what business was RangeTree in? 6 And in years again, so I think your attorney 7 knows this, but we're talking about 2003 through 8 to the present. 9 A. Correct. 10 Q. Okay. 11 A. 'Cause Dan Miller's -- I think 12 RangeTree still exists as an entity. 13 Q. What did they do? 14 A. Dan Miller was not an insurance agent. 15 While he might have been licensed with various 16 carriers, he was what in the industry we refer to 17 as an aggregator. An aggregator would find the 18 agents, knew enough about premium finance, that 19 they could pick the policies that would be 20 financed, and they would funnel them to us. 21 Q. Do you know how Mr. Miller had this 22 relationship with insurance agents? 23 A. I do not. 24 Q. I guess what I was really trying to 25 ask in that, other than this insurance premium

32 Page 32 2 financing, had RangeTree been in the insurance 3 selling business or some other business related 4 where they would know these agents, to your 5 knowledge? 6 A. I know Dan had worked in -- I can say 7 in checking Dan out, I confirmed he had worked as 8 an analyst for Oppenheimer in the -- for an 9 analyst, he was a young man. For an analyst 10 covering insurance companies at Oppenheimer. 11 Then he went to work for what we call a general 12 agent. I don't know what he did there. 13 Q. How did you meet Dan Miller? 14 A. He was introduced by a former employee 15 of mine. 16 Q. Beau Gayner? 17 A. Beau Gayner, B-E-A-U, G-A-Y-N-E-R. 18 Q. And again not to argue with you, is 19 that his real name or is it Michael Gayner? 20 A. It's Michael Gayner. 21 Q. That's right. Do you know where 22 Mr. Gayner is now? 23 A. I have no idea. 24 Q. Okay. 25 A. I think he's in -- no, I do not know

33 Page 33 2 where his residence is. 3 Q. But if in the course of this 4 proceeding and with your attorney's permission, 5 if we call him Beau Gayner, we're talking about, 6 even though his name is Michael Gayner, everybody 7 called him Beau? 8 A. That's correct. 9 Q. Okay. 10 A. His father is Michael Gayner. 11 Q. Beau Gayner was -- you said you met 12 Dan Miller through Beau Gayner? 13 A. Yes. 14 Q. Beau Gayner, at the time you met him, 15 as I recall, was in 2003? 16 A. Okay. That would be Q. That's about it. 18 A. Not when I met Beau Gayner. 19 Q. No, no, Dan Miller. 20 A. Dan Miller. The introduction was made 21 by Beau in approximately Q. Do you know how Beau Gayner met Dan 23 Miller? 24 A. I don't recall. 25 Q. Do you know if they were ever in

34 Page 34 2 business together? 3 A. I do not think they were in business 4 together prior to Beau's introduction. 5 Q. Now, eventually Beau Gayner left you? 6 A. Beau Gayner had -- I had to let Beau 7 go in the bear market -- between 2000 and He was my employee. His job was to raise 9 capital. It was hard to raise money in those 10 years, even if you were making money, which I 11 was. 12 Q. And so you let him go. Do you know 13 what he did after he left you? 14 A. I don't recall. 15 Q. Okay. When did he form UTC, if you 16 know? 17 A or Q. And to test your memory a little bit, 19 how do you know -- whether in five or six, makes 20 no difference to me. How do you know when it 21 was -- about when it was formed? 22 A. That will clear it up. Beau, after he 23 introduced Dan Miller, within a month he had quit 24 his employment at a broker/dealer now that my 25 memory is refreshed. He joined RangeTree. And

35 Page 35 2 sometime within a year to two years, Beau left 3 RangeTree to start UTC. 4 Q. And what business was UTC in, if you 5 know? 6 A. It was an aggregator much like 7 RangeTree. 8 Q. So we have our definitions correct, an 9 aggregator was a person who brought other agents 10 to the table who had clients within your 11 designated sweet spot for the purpose of funding 12 insurance -- life insurance policies? 13 MR. WEITMAN: Object to the form. 14 THE WITNESS: Correct. Correct. 15 BY MR. MELNICK: 16 Q. I'm not trying to put words in your 17 mouth. If you can define it better than I did, 18 go ahead. Tell me in your words what you think 19 an aggregator is if I didn't do a good enough 20 job. 21 A. An aggregator, they get paid if I 22 finance a policy. And I'm only going to finance 23 a policy that fits the criteria and pass the 24 test. And while they know I use the Milliman 25 model, they through experience of what gets

36 Page 36 2 financed and doesn't, they know what to send. So 3 they are constantly sending illustrations that we 4 would examine because we were looking for the 5 best policies. 6 Q. And at the time -- and again, I want 7 to make sure my timing -- at the time they would 8 send you these illustrations they had already had 9 the client fill out an application and had 10 submitted that to the insurance company in order 11 to get those illustrations? 12 A. That's correct. 13 Q. Okay. Was there any other company 14 named that Beau Gayner went under other than UTC, 15 to your knowledge? 16 A. There was, and -- but the one that 17 stuck was UTC. 18 Q. Okay. Another easy one, Tom Riek? 19 A. Yes. 20 Q. Who is Tom Riek? 21 A. Tom Riek found me on the Internet. I 22 was one of the -- because I was in the hedge fund 23 business and we picked short, managers in short, 24 we were making money in the bear market. And he 25 called and made inquiries. He became an

37 Page 37 2 investor, and eventually became a capital 3 formation officer, raised money for me, as an 4 employee, and then he left my employment in -- 5 Q. Spring of '04. 6 A. Thank you. 7 Q. Is that right? I don't want to put 8 words -- 9 A. That would purport with my knowledge. 10 Q. Okay. And just so we get the timing 11 down, and I think I'm correct, but go ahead and 12 tell me if I'm not. Gayner leaves in '02. Riek 13 effectively comes onboard first as an investor 14 and then as this employee who effectively was 15 paid on commission based on the capital he raised 16 in '02, from '02 to the spring of '04; is that 17 about right? 18 A. That's about right, but I think Beau 19 was let go in either -- closer to 2000 and Q. So there was a gap between when Beau 21 Gayner was let go A. There was. 23 Q. -- and Tom Riek came on A. And Tom Riek came on, uh-huh. 25 Q. Okay. Now, Mr. Riek left your

38 Page 38 2 employment in the spring of '04, but you 3 continued to have a relationship with him over 4 the years subsequent to that; didn't you? 5 A. That's correct. 6 Q. And, in fact, you're in business with 7 him right now; aren't you? 8 A. I am not. 9 Q. He's not with you in some kind of 10 Internet business? 11 A. No. 12 Q. Never been? 13 A. Ever been? 14 Q. Well, I took his deposition, so I'm 15 only going by what he said under oath. 16 A. Uh-huh. 17 Q. I'm trying to understand. Are you 18 saying that subsequent to all these issues with 19 Brown and Baetis and so on, so this would have 20 been, I guess, in 2010, did you two partner up or 21 invest together in some kind of Internet 22 business? 23 A. We had invested as individual 24 shareholders. He as one individual and me as 25 another. I don't know how he registered his

39 Page 39 2 investment, with a company Lexy, L-E-X-Y. And 3 I'm going to say that was 2005, Q. Okay. Let me ask this question as 5 clearly as I can. 6 During 2011, were you two investors in 7 Lexy? 8 A. Lexy, in 2011, I think Lexy ceased to 9 exist in It was shut down. The company 10 went out of business. 11 Q. All right. At the time it shut down, 12 that was 2010, were both of you still investors 13 at the time it shut down? 14 A. Correct. 15 Q. Okay. But to your knowledge, neither 16 of you had controlling shares? 17 A. I am absolutely certain we did not 18 have controlling shares. Tom invested 100. I 19 invested 300. That was it. 20 Q. Neither of you were officers or 21 directors of Lexy? 22 A. Neither. 23 Q. Greg Lindae, L-I-N-D-A-E, who is he? 24 A. He was an investor of mine who first 25 was an investor. Then became a friend. I

40 Page 40 2 recommended him for business school. He's more 3 than a business associate, I'd say. 4 Q. But in terms of involvement in the 5 insurance premium financing business, who 6 involvement, if any, did he have? 7 A. As an investor. Strictly as an 8 investor. 9 Q. So when you say "an investor," what do 10 you mean by that? He would invest, for example, 11 $100, in Baetis or Brown or what would he 12 do? 13 A. Correct. 14 Q. He would invest it in a fund? 15 A. As a limited partner. Yes. 16 Q. Like Wealth Management? 17 A. Exactly. He was an investment 18 advisor. 19 Q. Cove Management, what's that? 20 A. Cove Q. Now, I'm going to put these names 22 together. I'm going to give you a little help 23 here because you're going to try to sort this. 24 A. I know Cove. 25 Q. Cove, Highlander, Golden Triangle.

41 Page 41 2 A. Thank you. 3 Q. See, I knew that. 4 A. They are entities formed by RangeTree 5 to make an investment in -- to make an investment 6 in premium finance. 7 Q. They were formed by RangeTree? 8 A. They were formed by RangeTree, and I'm 9 trying to think of the other name of the company 10 that RangeTree did this with. 11 Q. I'll help you there, but weren't you 12 involved with A. As an investor. 14 Q. So I know the word you, 'cause that 15 was too general, who was the investor; Baetis or 16 Brown? 17 A. Caddis. 18 Q. Caddis was the investor in that, of 19 which you were the general partner -- Wood, Hat & 20 Silver was the general partner? 21 A. Correct. 22 Q. Okay. And there was Wealth Management 23 money invested in one way or another in Caddis? 24 A. Correct. 25 Q. Was there Wealth Management money

42 Page 42 2 invested at any time in Cove, Highlander and 3 Golden Triangle? 4 A. Was there Wealth Management -- 5 Q. Money through any of their funds 6 invested in any of those three entities, directly 7 or indirectly? 8 A. I don't remember the details of that. 9 I don't remember the details that were outlined 10 in those documents, so I can't say. 11 Q. And put that aside. I understand that 12 sometimes documents say one thing but life says 13 another. I don't care about that. What I'm 14 trying to do is what's your recollection with 15 regard to whether any of the Wealth Management 16 money end up directly or indirectly in any of 17 those three entities? 18 A. Yes, they did. 19 Q. Okay. 20 A. In Caddis specifically, but I do not 21 know if it ended up in the other three. I'm 22 not -- I can't remember if it ever left Caddis to 23 go to one of those three entities. It could 24 have. 25 Q. And those three entities were in the

43 Page 43 2 insurance premium financing business? 3 A. I would say so, yes. 4 Q. Okay. And were they, in fact, if they 5 were in the insurance premium financing business, 6 were they competitors of yours? 7 A. That's a good question. When 8 RangeTree -- RangeTree is sending policies to 9 Caddis and let's say Baetis and Brown. 10 Q. Okay. 11 A. They're acting as an aggregator. They 12 are the -- actually the only aggregator I'm 13 dealing with at that point in time that we're 14 referring to is Cove, Highlander, et cetera. 15 Q. Just -- 'cause I know your attorney 16 will question me about it. That period of time. 17 What period of time are we talking about? Are we 18 talking about 2005 through 2008? Are we talking 19 about 2003? 20 A. I think we're talking 2003 or Q. Okay. Through the current; right, 22 through 2008 at least? 23 A. I would say Caddis was shut down in , Q. Okay. Now, go ahead then and answer

44 Page 44 2 when you said about -- 3 A. Yeah. There was an entity that was 4 going to loan Cove, Highlander, et cetera, 5 $50 million, and they needed to post collateral, 6 which Caddis did. For some reason it was five to 7 eight million, to the best of my recollection. 8 And that entity said to RangeTree, you can no 9 longer -- we get first choice on all your 10 policies. You can't -- we don't know if you're 11 going to be selling the best ones to Wood, Hat & 12 Silver's limited partnerships or to your other 13 clients so if we're going to give you this million you have to stop doing business with 15 these other firms. And so we were told -- I was 16 told, Gee, Joe, we're sorry. You can either 17 continue to do business with RangeTree and put up 18 this collateral; or you can -- we'll find 19 somebody else. 20 And so they stopped sending policies 21 to be funded. It was maybe a year later when I 22 think Caddis was funded that the entity that put 23 up the 50 million allowed RangeTree to send us 24 other policies. 25 Q. If I'm understanding 'cause some of

45 Page 45 2 the language was broad and I want to try to be 3 specific. This entity, and we'll identify it at 4 some point, who lent the 50 million said to 5 RangeTree, we've got to get in the sense the pick 6 of litter of these insurance policies; right? 7 A. Correct. 8 Q. So as you look back on it, what was 9 the pick of the litter in, let's say, the '05/'06 10 period? What would have been the pick of the 11 litter that they were talking about, if you know? 12 MR. WEITMAN: Object to form. 13 THE WITNESS: I don't know. 14 BY MR. MELNICK: 15 Q. Well, do you have any idea from your 16 standpoint what would have been the very best 17 policies to fund? 18 A. Well, it would be the same policies 19 that we were funding. 20 Q. But what's the difference? 21 A. There wouldn't be. But the 50-million 22 dollar entity had no way of knowing that the 23 perfect case that comes out to be real profitable 24 would not be sold to me, and then the other good 25 cases would be sold to them. Or financed through

46 Page 46 2 them. 3 Q. Right. And let's put that term on the 4 table. When we say "sold" -- and I do understand 5 what you're talking about, but the record needs 6 to be clear -- what you're talking about, here is 7 the policy. It's a great policy. We 8 cherry-picked this policy. And we're going to 9 fund it. That's what you mean by "sold to" in 10 your last reference? 11 A. Yes. 12 Q. And then they would fund it. If there 13 were profits from the policy, they would benefit? 14 A. In two years they would benefit. 15 Q. Okay. But during this period of time 16 when you were -- when I say you now, Baetis and 17 Brown. 18 A. Uh-huh. 19 Q. You have to answer yes or no. 20 A. Yes. 21 Q. Any other entities of yours that were 22 cut off from RangeTree during this period of 23 time? 24 A. Well, that would have been Caddis. 25 Q. Caddis was cut off. Wasn't Baetis and

47 Page 47 2 Brown also cut off? 3 A. Yes. As I recall, no policies were 4 ever -- they might have been financed in Baetis. 5 I think we -- well, I can't recall. I shouldn't 6 say that. 7 Q. So during that period of time when you 8 weren't getting anything from RangeTree, how did 9 you stay in business? 10 A. Well, the policies we had and the 11 investments we had allowed us to stay in 12 business. 13 Q. Did you go to any other aggregator 14 other than RangeTree? 15 A. No. 16 Q. Well, subsequent to you getting cut 17 off from RangeTree, you said a year later you 18 got -- the spigot got turned back on? 19 A. Yes. 20 Q. Okay. And it got turned back on 21 because of what reason, if you know? 22 A. According to Dan Miller, he had 23 received permission from the 50-million dollar 24 investor because he had already, in effect, 25 funded 30, 40 million of it to their

48 Page 48 2 satisfaction, having fit their criteria, and he 3 had more policies than they did -- 4 Q. All right. 5 A. -- that fit their criteria, so he said 6 you can also sell these to others. 7 Q. So after the spigot got turned on and 8 you started getting policies from RangeTree, 9 would you get policies from any other aggregator 10 after that? 11 A. After that, I did, yes. 12 Q. And that would be after '06? 13 A. Yes. 14 Q. And who was that? 15 A. That would be UTC. And PRG. 16 Q. That was -- UTC was Beau Gayner's 17 company. And PRG was an Italian named Gabrielli 18 or something, or A. Gabriel. Gabe something. 20 MS. MELNICK: I think it's 21 Giordano. 22 THE WITNESS: Giordano would be 23 close enough. I have no idea how to spell 24 that. 25 BY MR. MELNICK:

49 Page 49 2 Q. Anyone else other than -- and I do 3 recall PRG and UTC. Anyone else? 4 A. Kevin Yurkes, Y-U-R-K-E-S. 5 Q. And who would he work for? 6 A. I do not recall the name of his 7 company. 8 Q. What about Jeff Keller? 9 A. Jeff Keller, correct. I do not recall 10 the name of Jeff Keller's number. 11 Q. Anyone else you can think of? 12 A. No. 13 Q. Maybe I'll come across those names for 14 you. Again, the interrelationship of Cove 15 Management, Highlander and Golden Triangle, did 16 all these three entities do the same things or 17 did one do something different? 18 A. I don't recall. 19 Q. You had nothing to do with the 20 management of any of those three entities, 21 Highlander, Golden Triangle or Cove Management? 22 A. No. 23 Q. That was all Dan Miller? 24 A. Correct. 25 Q. New name. Justin Mecklenborg?

50 Page 50 2 A. Yes. 3 Q. M-E-C-K-L-E-N-B-O-R-G. Who is he? 4 A. He was Dan Miller's right-hand man. 5 Chief operating officer. 6 Q. During what period? 7 A. From the day I met him -- the day I 8 met Dan Miller, Justin was working for him, until Q. And did he leave or was he terminated? 11 A. I don't know. 12 Q. Do you know where he is now? 13 A. Yes. 14 Q. Where is he now? 15 A. In San Diego. 16 Q. Doing what? 17 A. I don't know. 18 Q. How did you know he was in San Diego? 19 A. I speak to him from time to time. 20 Q. Are you in business with him? 21 A. No. 22 Q. Deutsche Bank. Now, I know who 23 Deutsche Bank is. It's a bank. 24 Did you ever do business with Deutsche 25 Bank?

51 Page 51 2 A. Me directly, no. 3 Q. Thank you. And that helps clarify. 4 Let's break it down separately. 5 So you as Joe Aaron did not do 6 business with Deutsche Bank; correct? 7 A. That's correct. 8 Q. You as Wood, Hat & Silver? 9 A. That's correct, did not do business. 10 Q. You as general partner of Baetis and 11 Brown? 12 A. Did not do business with Deutsche 13 Bank. 14 Q. Okay. Did any of the entities that 15 you were general partner of do business with 16 Deutsche Bank, to your knowledge? 17 A. The entities, no. 18 Q. Who did? 19 A. The agents and the aggregators. 20 Q. And what kind of business did they do 21 with Deutsche Bank? 22 A. Let me correct that. That would be 23 the aggregators. It would not include the 24 agents. 25 Q. Okay. What business, to your

52 Page 52 2 knowledge, did the aggregators do with Deutsche 3 Bank? 4 A. Sell the policies. 5 Q. So the aggregators, if I understand 6 you correctly, not only brought people -- agents 7 to the table with people to fund the policy, they 8 also brought money to the table to buy policies; 9 is that correct? 10 A. That's one way of looking at it, 11 correct. 12 Q. What other way should I look at it? 13 A. I could have shopped it myself. 14 Q. You could have shopped what yourself? 15 A. I could have gone to Deutsche Bank 16 myself. 17 Q. To do what? 18 A. To sell the policies. 19 Q. But you didn't? 20 A. No. 21 Q. Why? 22 A. Because the aggregators were in a 23 better position, spoke the language better and 24 were in a better position to get a better price 25 than I was, 'cause we tried it a few times.

53 Page 53 2 Q. When you say "we tried it," who's 3 "we"? 4 A. Me. 5 Q. "We" is -- the king, you mean we or -- 6 A. Me, the king of Wood, Hat & Silver. 7 Q. You weren't with anybody else when you 8 did that? 9 A. No. 10 Q. To your knowledge, did Deutsche Bank 11 fund policies that were sold through these 12 aggregators? 13 A. Fund? 14 Q. Well, somebody has to come up with the 15 money to buy these policies; right? 16 A. Funding is different from purchasing. 17 Q. Thank you. So I had the wrong 18 terminology. So let me go both ways, okay? 19 To your knowledge, did Deutsche Bank 20 fund the purchase of any policies? 21 A. Correct, they did. 22 Q. They did. What about the purchase of 23 policies as you distinguish it? 24 A. No. No. They don't fund the 25 purchase. They say I'll buy this policy and this

54 Page 54 2 is what I'll give you. They don't fund anything. 3 Deutsche Bank funds nothing. They bought it 4 outright. I do not have knowledge if they funded 5 the finance of a policy like I did. I do not 6 have that knowledge. 7 Q. Okay. And I understand that. I'm 8 actually talking what I call the back end now. 9 I'm talking about at the sale of the policy, what 10 I understand you to be saying is certain of the 11 aggregators that you dealt with sold policies sold them to Deutsche Bank? 13 A. Correct. 14 Q. Now are you saying that they sold them 15 to the bank or the bank acted as a facilitator to 16 someone else? 17 A. On reflex, I am certain Deutsche Bank 18 held some for their own portfolio and they 19 purchased them for individual clients they had 20 across the world. 21 Q. Do you know what years these purchases 22 took place? 23 A. No. 24 Q. Was there any years you could 25 eliminate? You can eliminate '03 and '04 'cause

55 Page 55 2 you had just started the business and the two 3 years hadn't run, right? 4 A. That would be fine. I do not know 5 when they stopped buying. I do not know what 6 year. 7 Q. Okay. Did you deal with anybody at 8 Deutsche Bank, you personally? 9 A. I made calls to Deutsche Bank. 10 Q. Do you remember who you dealt with 11 there? 12 A. No. 13 Q. Do you remember who the aggregators 14 dealt with at Deutsche Bank? 15 A. No. 16 Q. The policies, to your knowledge, that 17 Deutsch Bank bought, did they come out of Baetis 18 and Brown or did they come out of some other 19 fund? 20 A. The money to purchase the policies 21 that were held in Baetis, Brown and Caddis in the 22 case of Deutsche Bank either came from their 23 proprietary funds or from investors they 24 represented. 25 Q. I didn't ask that question right. I

56 Page 56 2 was talking about our end of the transaction. 3 That is, the policies they bought on the back 4 end. 5 A. Yes. 6 Q. And you know what I mean by that? 7 A. Yes, I do. 8 Q. Were they Baetis and Brown and Caddis' 9 policies or were they other funds' policies? 10 What did they buy? 11 A. They bought the policies in any fund 12 that we were selling. If they were the buyer at 13 the time, we sold to the highest bidder whether 14 it be Deutsche Bank, Peachtree, any other Coventry, any other group. 16 Am I not understanding your question? 17 Q. I'm trying to figure out the policies 18 that Deutsche Bank bought came from Baetis, Brown 19 and Caddis, or did they come from other funds? 20 A. At Wood, Hat & Silver? Other funds at 21 Wood, Hat & Silver? 22 Q. Yeah. 23 A. They could have purchased policies 24 from Tippet, which held policies. But I think 25 that would --

57 Page 57 2 Q. Stonefly? 3 A. And Stonefly. They certainly could 4 have, yes. 5 Q. Okay. Anyone else? 6 A. Not that I can recall. 7 Q. Okay. Do you know how many policies 8 Deutsche Bank bought? 9 A. No idea. 10 Q. Now, I was going to ask you this 11 later, but your attorney was kind enough to 12 provide me with some evidence on the sale of 13 policies. 14 A. Correct. 15 Q. You're aware of that? 16 A. Yes. 17 Q. That he provided that to me? 18 A. I am. 19 Q. Okay. 20 A. I provided it to him. 21 Q. Okay. What I'm trying to find is 22 during the years, and again, 2003, certainly 23 through 2008, I can't find evidence of sale of 24 policies to anybody except one company, and that 25 was River Rock. One policy they bought from you

58 Page 58 2 at River Rock, Goldberg? 3 A. Wow. 4 Q. And we don't have any evidence of 5 those documentation. 6 A. Okay. 7 Q. Do you know where that documentation 8 is? I'm going to stop you because I'm going to 9 ask a foundation question. 10 A. Uh-huh. 11 Q. When you sold a policy, were there 12 documents created like you did when you financed 13 the policy to evidence the sale of a policy? 14 A. Documents were created by the buyer. 15 They would -- there would be always one document 16 signed by me acknowledging they were purchased. 17 And I would -- but I would not see the documents 18 that the insured signed or the life insurance 19 agent signed or the aggregator signed. I would 20 not see any of those other documents. I only saw 21 what I had a need to see. They did not always 22 need me to see. 23 Q. But there were proceeds paid on these 24 policies; correct? 25 A. Correct.