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28 1 IN THE CIRCUIT COURT OF THE 11TH JUDICIAL CIRCUIT IN AND FOR 2 MIAMI-DADE COUNTY, FLORIDA 3 CASE NO: CA 03 4 EMBRAER FINANCE LTD., 5 Plaintiff, 6 vs. 7 SERVICIOS AEREOS PROFESIONALES, S.A., 8 Defendant. 9 / 10 VERITEXT REPORTING 19 West Flagler, Suite Miami, Florida January 18th, :00 a.m DEPOSITION OF JOSE M. PATIN, Taken on behalf of the Plaintiff, before Jaime 18 Koganovsky, Court Reporter, Notary Public in and for 19 the State of Florida at Large, pursuant to Notice of 20 Taking Deposition in the above cause

29 1 APPEARANCES: 2 ROBERT C. OWENS, ESQUIRE, OF THE FIRM OF ROBERT C. OWENS, P.A Southwest 264 Street Miami, Florida On Behalf of the Plaintiff. 5 JOSE CERVERA, ESQUIRE 7950 West Flagler Street, Suite Miami, Florida On Behalf of the Defendant. 7 ALSO PRESENT: 8 CHRISTINA VELARDE (SPANISH INTERPRETER) 9 10 I N D E X 11 WITNESS DIRECT CROSS 12 JOSE PATIN PLAINTIFF'S EXHIBITS 14 NUMBER PAGE

30 1 THEREUPON, 3 2 CHRISTINA VELARDE, 3 was called to translate from Spanish to English and English 4 to Spanish to the best of her ability the following: 5 THEREUPON, 6 JOSE M. PATIN, 7 was called as a witness by the Plaintiff and, having been 8 first duly sworn, testified as follows: 9 DIRECT EXAMINATION 10 BY MR. OWENS: 11 Q Would you state your full name please. 12 A Jose Miguel Patin Eusebio, E-U-S-E-B-I-O. 13 Q Good morning, I'm Robert Owens the 14 attorney for Embraer Finance Limited. 15 A It's a pleasure to meet you. 16 Q Thank you. 17 A A pleasure to meet you. 18 Q I would like to make sure you understand 19 your answers will be under oath just as if you were 20 testifying in court. 21 A I understand. 22 Q I'd like to ask you to respond to each of 23 my questions with a verbal response because the 24 court reporter cannot take down a nod. 25 A I understand.

31 1 Q If you need a break, let me know and we'll 4 2 take a break. 3 A Fine. 4 Q If you don't understand the question, tell 5 me so and I'll rephrase it. 6 A Fine. 7 Q Please let me finish my full questions 8 before you respond. 9 A Fine. Could I borrow one of those 10 notebooks, please? 11 Q Yes. 12 If you do not know or cannot remember the answer 13 to a question, you can just say so. 14 A Fine. 15 Q What is your address? 16 A 520 Brickell Key, Apartment 914. Zip code , Florida. 18 Q How long have you lived there? 19 A I've been living there for approximately 20 five years. 21 Q Where did you live before that? 22 A I lived in a leased apartment in the 23 southwest area, but I don't recall the exact address 24 now. 25 Q Is the United States your full -- your

32 1 domicile? 5 2 A Yes, the United States is where I live. 3 Q And how long have you had your domicile in 4 the U.S.? 5 A Eight or nine years. 6 Q Is that when you became a U.S. citizen? 7 A During that period. During that period my 8 family and us. 9 Q Your family and us did what? 10 A My children. 11 Q Became citizens? 12 A Yes. 13 Q What is your business address? 14 A At this time here? 15 Q What is the exact address? 16 A I'm asking you if you want the current 17 one, the one now? 18 Q Yes. 19 A We don't have one here at this time. 20 Q Well, where is your business address? 21 A In Santa Domingo. 22 Q Could you give me the exact address, 23 please? 24 A Aeropuerto del Higuero, Santo Domingo, 25 Dominican Republic.

33 1 Q What is the name of your business? 6 2 A Servicios Aereos Profesionales, S.A. 3 Q Do you hold any titles or positions in 4 that company? 5 A No, not at this time. 6 Q Have you ever held any positions or titles 7 in that company? 8 A Yes, until December of last year. 9 Q When did you first hold a position with 10 that company? 11 A After my father passed away, about four 12 years ago. Can't you speak? Okay. Well, then, I 13 don't recall exactly how many years exactly. 14 Q When did -- may I call it SAPSA? 15 A Servicios Aereos Profesionales. 16 Q In order to be able to speak quickly, may 17 I refer to it as SAPSA? 18 A I prefer Servicios Aereos Profesionales in 19 order not to Q Okay. When did Servicios Aereos 21 Profesionales, S.A. begin operation? 22 A Servicios Aereos Profesionales began its 23 operation 30 years ago. 24 Q And was that a family business? 25 A It's a company that my father initiated --

34 1 started. 7 2 Q What was your father's name? 3 A Jose Miguel Patin Hernandez. 4 Q Did his father have any association with 5 the company? 6 A His father. 7 Q Yes. 8 A No, my grandfather passed away many years 9 ago, more than 25 years ago. 10 Q Mr. Patin, when your A And his name was not Jose Miguel either, 12 it was Conrado Patin. 13 Q Prior to your father passing away, did you 14 hold any position or employment or do any work for 15 Servicios Aereos Profesionales, S.A.? 16 A Okay. Yes, I would fly as an advisor and 17 I would fly as a pilot and as an instructor, but at 18 the time I was a pilot for an airline, Dominican 19 Airlines. 20 Q Prior to your father passing away, did you 21 have any officership with the company? 22 A Could you repeat the question? 23 Q Prior to your father passing away, did you 24 have any position or employment with the company 25 other than as a pilot?

35 1 A I was an advisor to the company with my 8 2 father. 3 Q Do you now or have you ever owned any 4 stock in the company? 5 A Yes, we still own stock in the company, 6 and those stock we were asked to -- we still own 7 stock. 8 Q How many shares do you own? 9 A If she can't speak, I can't recall 10 exactly. We have some stock. 11 Q Do you recall how many shares the company 12 has outstanding? 13 A I don't recall. 14 Q Do you recall what percentage of the 15 company you own? 16 A I don't recall right now. 17 Q Do you recall approximately? 18 A No. 19 Q Who are the other shareholders in the 20 company? 21 A Shareholders in Santo Domingo, some of 22 them are my children, and then there are other 23 shareholders, also, in Santo Domingo, but I don't 24 recall their names exactly. I don't recall their 25 names.

36 1 Q Any of them? 9 2 A Yes, I could recall some, my children. 3 Q Please name them. 4 A Joan, Isabel Maria, Marisol Azar, that I 5 recall. 6 Q These are all children of yours? 7 A Some are, some are not. Some are just 8 businessmen that are involved in the company. 9 Q Well, is Joan your child? 10 A Yep. 11 Q How old is she? 12 A He is 24 or Q Would you please spell his name? 14 A Joan, J-O-A-N, Miguel, Patin, P-A-T-I-N. 15 Q Where does he live? 16 A Santa Domingo. 17 Q Does he have any residence here in the 18 U.S.? 19 A No. 20 Q What is his address in Santa Domingo? 21 A I don't know his address. I know where he 22 lives, I just don't know exactly what the physical 23 address is. 24 Q Is Isabel Maria one of your children? 25 A Yep.

37 1 Q And her last name is Patin? 10 2 A Patin Hernandez. 3 Q And how old is she? 4 A She is about Q Okay. And Marisol Azar? 6 A She is one of the shareholders of the 7 company. 8 Q She is not one of your children? 9 A No. 10 Q How many shares does Joan own? 11 A I don't recall mine correctly, I can't 12 recall anybody else's. I don't recall anybody's 13 shares or anybody's number of stock. 14 Q Is there anyone that you know of that owns 15 a majority of the shares? 16 A I don't recall. 17 Q Are there any other shareholders that you 18 can recall besides Joan, Isabel and Marisol? 19 A My other son, Jose Miguel. I would like 20 to ask my wife something, but if I can't ask her 21 then I don't recall who the others are. 22 Q You're fine to ask her if you want. 23 A My mother. 24 Q What is her name? 25 A Pura Eusebio.

38 1 Q Where does she live? 11 2 A Santa Domingo. 3 Q And Jose Miguel Patin, where does he live? 4 A Lives in Santa Domingo. 5 Q And Isabel Patin? 6 A Santa Domingo. 7 Q And Marisol Azar? 8 A Santa Domingo. 9 Q Do you recall the addresses of any of 10 these people? 11 A No. I know where they live, I just don't 12 have the physical address to be able to give it to 13 you, the numbers. 14 Q Do you own shares in the company jointly 15 with your wife? 16 A My shares are mine. 17 Q And your wife has separate shares? 18 A I think so. 19 Q Why do you say you think so? 20 A Because I think so because I'm not sure. 21 Q Would you please describe your education. 22 A I have a secondary school degree, 23 bachelor, then I came to study in the U.S., I became 24 a pilot. I attended several different pilot schools 25 here in the U.S., and then I went back to the

39 1 Dominican Republic and started flying. After that I 12 2 was captain for the 727 and many other planes. I 3 was also an instructor in the Dominican Republic. 4 Q Were you a citizen of the Dominican 5 Republic prior to being a citizen of the United 6 States? 7 A Yes. 8 Q Do you still hold citizenship with the 9 Dominican Republic? 10 A Yes. 11 Q What titles or positions did you hold with 12 the company after your father passed away? 13 A When my father passed away I became the 14 president of the company. 15 Q And as the president of the company, did 16 you know who the shareholders were? 17 A Yes, I know more or less who the 18 shareholders are, I believe there is seven and I've 19 given you about five, the ones I recall. 20 Q Actually, you've given me seven. 21 A Well, then, those are it. 22 Q Okay. 23 A I don't know if there is more. The 24 Dominican Republic requests or asks that I have a 25 minimum of seven so there could be more, there could

40 1 be ten, but those are the ones I recall Q Is there a roster or a document in the 3 company that shows who the shareholders are and how 4 many shares they own? 5 A Those documents should be in the Dominican 6 Republic. 7 Q In the company's records? 8 A In the record of the company in the 9 Dominican Republic. 10 Q Is that information also on file with the 11 government or Santa Domingo -- the Dominican 12 Republic, I'm sorry? 13 A Yes, I imagine so. 14 Q Do you and your wife own a majority of the 15 stock of the company? 16 A I don't recall that right now. I don't 17 know how the company is split, the stocks. I know I 18 used to be the president of the company. 19 Q And do you recall -- strike that. 20 MR. OWENS: Let me mark this as Exhibit 1 21 to this deposition. 22 (Whereupon, the referred-to documents were 23 marked as Plaintiff's Exhibit Number 1 for 24 Identification.) 25

41 1 BY MR. OWENS: 14 2 Q Do you recognize this document? 3 A I would like for the interpreter to 4 translate this document. 5 Q Have you ever seen that document before? 6 A Something like that -- something similar, 7 but I don't know if this is exactly it. And I 8 prefer if it's interpreted to me because then I 9 could be able to remember some things that are here. 10 Q Have you brought any documents with you 11 today? 12 A Yes, we have brought some documents. 13 Q May I see them, please. 14 You recall being served with a subpoena? 15 A Yes. 16 Q Did you have an opportunity to have that 17 document reviewed and/or translated so that you 18 understand what was in it? 19 A We went to our attorneys with the 20 document. 21 Q Did you come to understand what was in 22 that subpoena that was served on you? 23 A Bring some documents, whatever I had 24 available, whatever I was able to bring. 25 Q And did you do that today?

42 1 A I brought some of the documents that have 15 2 been requested and that I have been able to obtain. 3 They are practically the bank's documents. 4 Q May I see them, please. 5 MR. OWENS: Let mark this as Exhibit 2, 6 please. 7 (Whereupon, the referred-to documents were 8 marked as Plaintiff's Exhibit Number 2 for 9 Identification.) 10 BY MR. OWENS: 11 Q Do you recognize the document in Exhibit 12 2? 13 A Are these the ones I just handed you? 14 Q Yes. 15 A Oh, yes. 16 Q You recognize them? 17 A Yes. 18 Q You have to say yes or no. 19 A Yes, yes. 20 Q What account is that? 21 A That was -- no longer is. Okay, that 22 account exists, the only thing is that Embraer froze 23 this account. 24 Q And so the company does not use the 25 account any more?

43 1 A Okay. No, it hasn't used it for almost 16 2 two years as soon as the order came from New York to 3 freeze, or to take over the account it hasn't been 4 used again. It can't be used, the accounts are -- 5 there is -- 6 MR. OWENS: Would you mark this as Exhibit 7 3, please. 8 (Whereupon, the referred-to documents were 9 marked as Plaintiff's Exhibit Number 3 for 10 Identification.) 11 BY MR. OWENS: 12 Q I want to show you the document we've 13 marked as Exhibit 3 relating to the account of the 14 company. 15 Do you recognize that? 16 A Yes. 17 Q And does the company use that account 18 anymore? 19 A Same response I gave you before, same 20 date. As soon as the account was froze because of 21 an order that was filed in New York. 22 Q Do you have any other documents with you 23 today? 24 MR. OWENS: Mark this as Exhibit (Whereupon, the referred-to documents were

44 1 marked as Plaintiff's Exhibit Number 4 for 17 2 Identification.) 3 BY MR. OWENS: 4 Q Do you recognize this document or the 5 documents marked as Exhibit 4? 6 A Yes. 7 Q And what are those documents? 8 A These are bank statements for the years 9 you requested, I believe 2007, 2008, something like 10 that, until the accounts were closed or seized by 11 them. 12 Q What purpose did these accounts have? 13 A Those were basically the operating 14 accounts. One was an operating account for the 15 company for purchases -- parts or purchase orders 16 that would be requested from here. It always had 17 about 4,000 $5,000 in it. And the other one was the 18 company's main account basically to receive the 19 income -- the company's income from charter flights, 20 and to pay gas or fuel, parts. Also to do business 21 deals with planes. It was a -- the company's 22 general account, normally was all the official 23 things the company did. 24 Q Which account was that? 25 A One of the two.

45 1 Q Do you know which? 18 2 A Servicios Aereos Profesionales, S.A. 3 Q We don't have to use the translator if you 4 don't want to. 5 A Just in case there is something I don't 6 understand, because this is my mother tongue. 7 Q Okay. 8 A I prefer to have the interpreter. 9 This is an account, here it states it's a 10 technical account, it is the first one I mentioned. It was 11 used for the company to purchase here all the way from crews 12 to paint, shampoo for cleaning planes, detergent for 13 cleaning planes, that type of thing. 14 Q You were just referring to the accounts 15 marked as Exhibit 4? 16 A A technical account, yeah. 17 Q It is marked as Exhibit 4, correct? 18 A You marked it as 4, yes. 19 Q Now, which account is number two? 20 A I think this is it, this is marked number 21 2, Exhibit Q Which account was that, is that the main 23 account? 24 A The company's main account. The company's 25 main account that we use to pay -- the main account.

46 1 Q What kind of account was Exhibit Number 3? 19 2 A Oh, these are the same accounts, it is 3 just that they've been divided to the years you have 4 requested. 5 Q Well, when I look at the account numbers 6 on these two exhibits and I see different account 7 numbers. 8 A One is a technical account which is the 9 technical account here. 10 Q Exhibit 4? 11 A And this is Q If you A May I see because they both have same 14 names here. It is basically the same bank -- I 15 don't know if these are the same banks. 16 I can ask her. 17 Q Fine. 18 A Okay. This is Bank of America and these 19 would -- the technical and other one are from Mellon 20 Bank. 21 Q So the documents in Exhibit 2, did you say 22 they relate to an operating account of the company? 23 A Yes, an operating account of the company. 24 Q Does the company still maintain funds at 25 Bank of America?

47 1 A Exactly the same thing happened with this 20 2 account as with the other accounts. 3 Q Where does the company keep its funds in 4 the United States? 5 A Nowhere, it doesn't maintain it. We have 6 no funds here. 7 Q Do you have any? 8 A Not here nor there either. The accounts 9 in the Dominican Republic have also been seized. 10 Q By whom? 11 A First by them, and then after that by 12 different entities. 13 Q By Embraer? 14 A By Embraer many years ago, and after that 15 other entities also. 16 Q Where does the company maintain its bank 17 accounts now? 18 A We don't have bank accounts at this time. 19 Q Anywhere? 20 A Nowhere. 21 Q You do all your business by cash? 22 A We don't do business by cash. At this 23 time the company doesn't even have planes, we lease 24 planes. If we get a request then we lease a plane. 25 Q From who?

48 1 A Whatever plane is available, whoever has a 21 2 plane available. 3 Q From other of your companies? 4 A Whoever has planes available in Santa 5 Domingo. 6 Q Do you have companies that have planes? 7 A Companies that have planes? No, I don't 8 have any company that has planes. 9 Q Let me go back, if I may, to this subpoena 10 that has been marked as Exhibit A Yes. Which one is that? Okay, this, 12 fine. 13 Q That one. 14 When you got served with a subpoena did someone 15 translate it for you? 16 A If this is the one that was served to me 17 we analyzed it with our attorney. 18 Q And so you fully understood what you 19 needed to produce here today? 20 A Yeah, more or less. 21 Q And then did you have any documents with 22 you in the United States at that time that you have 23 not produced today? 24 A I had no document in the U.S., not even 25 these.

49 1 Q What assets does the company have? 22 2 A Assets the company? Assets the company? 3 I believe the company has a plane to its name, but 4 its financed by Cessna Finance, and it has another 5 plane which is the Embraer plane which you can take 6 if you want. 7 Q What is the call sign on that one, 8 registration mark? 9 A May I ask my wife? 10 Q Let's go back to the airplane that is 11 financed by Cessna Finance. What kind of airplane 12 is that? 13 A It's a Cessna Caravan Q Do you recall the call sign of that 15 aircraft? 16 A I believe it's HI Q And the Embraer is not operational, is it? 18 A I kept it in the same condition that they 19 sold it to me in, inoperable. 20 Q The company has an operating certificate 21 from the Dominican Republic, is that correct? 22 A Yes. 23 Q Does it hold operating certificates of any 24 type from any other countries? 25 A I have a 129 from the same company. I

50 1 didn't understand your question Q The company, Servicios Aereos 3 Profesionales, S.A. has a part 129 certificate from 4 the USFAA? 5 A No, Santa Domingo. 6 Q That's the operating certificate? 7 A Yes. 8 Q And what does that certificate allow the 9 company to do? 10 A Charter flights. Charter flights. 11 Q No scheduled service? 12 A No. 13 Q And when the company sells a charter 14 flight, where does it receive the money? 15 A The company leases a plane and based on 16 the credit that the company has there, which is not 17 the best in the Dominican Republic. When we lease a 18 plane the first thing that is done, for example, is 19 if it is a charter that costs $1,000, the company 20 that I lease a plane from collects their money, the 21 fuel, everything. And then what's left over, 100, 22 $200, whatever, and they pay for that and they pay 23 for it practically in cash because it's a small 24 amount to pay for the maintenance, employees, 25 because we have planes in dry lease.

51 1 Q The company has aircraft on dry lease? 24 2 A That's how it operates. 3 Q What's the term of these dry leases? 4 A The company leases -- they allow me to use 5 the plane and I provide the pilots and the 6 maintenance. 7 Q What companies are providing these planes? 8 A Different companies in the Dominican 9 Republic. 10 Q What are the names of these companies? 11 A Caribe Air. Different companies in Santa 12 Domingo, whoever has an available plane. When the 13 request comes in, and sometimes they do the request 14 themselves with their pilots. 15 Q What company's planes does -- I'm sorry. 16 What company's planes does Servicios Aereos 17 Profesionales, S.A. maintain? 18 A Different companies. 19 Q What are the names of those companies? 20 A I told you Caribe Air, and we have -- from 21 different companies, many companies. 22 Q Name them. 23 A What's the name of the company? Different 24 companies. We lease from -- on some occasions we 25 lease from Air Century, Caribe Air and Santo

52 1 Domingo, sometimes we even lease from Haiti Q Is that an airline? 3 A Yes. 4 Q What is the name of the airline? 5 A Caribe Inter Haiti. 6 Q Spell Inter. 7 A I-N-T-E-R. 8 Q And Santa Domingo, is that Air Santa 9 Domingo? 10 A Yes. 11 Q Who owns Air Santo Domingo? 12 A Another company also that is part of the 13 family. 14 Q What is the family that you're talking 15 about? 16 A Family. There is some members of our 17 family and then there's other members of the 18 company, our partners. 19 Q Who are the owners of that company? 20 A Part of that company is myself and about 21 ten other partners, and I don't recall their names 22 right now. 23 Q You don't recall any of their names? 24 A There is me, I believe my wife, and then 25 there is about seven or eight more.

53 1 Q Who are the others? 26 2 A I don't recall. 3 Q Was that company ever owned by Servicios 4 Aereos Profesionales, S.A.? 5 A No, no. That is a Spanish company that 6 used to belong to Air Europa. 7 Q Where is it incorporated? 8 A Dominican Republic. 9 Q So you and these other people bought Air 10 Santa Domingo from Air Europa? 11 A But it's been many years, over 12 or years. 13 Q What kind of business is that company? 14 A Charter business. 15 Q Same business as Servicios Aereos 16 Profesionales, S.A.? 17 A More or less the same type of business 18 except that is 30 years old and this one is about or Q What type of planes does Air Santa Domingo 21 have? 22 A Jet stream Lets plane. 23 Q L-E-T-S, is that correct? 24 A Yes. 25 Q What others?

54 1 A Twin otter 200, the small one Q Any other planes? 3 A It has a Short 360, I think. 4 Q It is Short, S-H-O-R-T, correct? 5 A Yes, Q Any others? 7 A I don't recall any more, I think that is 8 it. 9 Q Were these aircrafts owned by Servicios 10 Aereos Profesionales, S.A. at one time? 11 A I believe that the Short did belong to 12 Servicios Aereos Profesionales. The others, if I'm 13 not mistaken, were aircrafts that were acquired from 14 other companies. 15 Q When was the Short sold by the company to 16 Air Santa Domingo? 17 A I believe several years ago, but I don't 18 recall how many years. 19 Q Is it your testimony today that the only 20 aircraft that was transferred from Servicios Aereos 21 Profesionales, S.A. to Air Santa Domingo was the 22 Short? 23 A That I recall now. That I recall. 24 Q Are you involved in any way in a company 25 called Professional Air Services, LLC?

55 1 A No Q Have you ever been involved with that 3 company? 4 A No. 5 MR. OWENS: Would you mark this as Exhibit (Whereupon, the referred-to documents were 8 marked as Plaintiff's Exhibit Number 5 for 9 Identification.) 10 BY MR. OWENS: 11 Q Mr. Patin, look at Exhibit 5. Are you the 12 Jose M. Patin that is listed on that corporation 13 with the Florida Secretary of State? 14 A No. 15 Q Do you know who that person is? 16 A That must be my son. 17 Q Does Servicios Aereos Profesionales, S.A. 18 lease aircraft from Professional Air Services, LLC? 19 A Not that I'm aware of. 20 Q And in your possession as president of the 21 company, you would be aware of it if it did lease 22 aircraft from your son, right? 23 A I think so. 24 MR. OWENS: Mark (Whereupon, the referred-to documents were

56 1 marked as Plaintiff's Exhibit Number 6 for 29 2 Identification.) 3 BY MR. OWENS: 4 Q I'd like to show you a document that we've 5 marked as Exhibit 6. 6 While he's looking at that, do you own any part of 7 this company, Professional Air Services, LLC? 8 A No. 9 Q Where does your son live? 10 A In the Dominican Republic. 11 Q Does he have a house here? 12 A No. 13 Q Do you know what this company does, 14 Professional Air Services, LLC? 15 A I'm looking at this, just a second. 16 (Whereupon, the reporter read back the requested 17 portion of the transcript, and the proceedings resumed as 18 follows:) 19 THE WITNESS: It's a company that is my 20 son's and what it does is purchase and sell 21 planes and leases planes, that type of thing. 22 BY MR. OWENS: 23 Q Do you see the highlighted aircraft listed 24 on Exhibit 5, those registered with the FAA to 25 Professional Air Services, LLC?

57 1 A Yes. I see it there, yes Q Okay. And are any of those aircraft 3 aircraft that Servicios Aereos Profesionales, S.A. 4 has leased in the past? 5 A I believe there were two aircrafts of the 6 Jetstreams, but I'm not completely sure. Servicios 7 Aereos Profesionales is no longer operating because 8 of lack of payment, they weren't paid. 9 Q Who wasn't paid? 10 A Servicios did not pay whoever was leasing 11 them. 12 Q Servicios did not pay Professional Air 13 Services, LLC? 14 A The lease, and then it wasn't able to make 15 its payments. 16 Q Did Servicios Aereos Profesionales, S.A. 17 lease the Jetstreams from Professional Air Services? 18 A That's correct. Correct. 19 Q Did it lease either of the Learjets? 20 A No. 21 Q Did it lease the Beech B90? 22 A No. 23 Q Did it lease the Beech 1900C? 24 A Neither. 25 Q Have you ever held any position or title

58 1 with the company Professional Air Services, LLC? 31 2 A No. 3 Q Have you ever owned any part of that 4 company? 5 A No. 6 Q Have you ever owned any part of 7 Professional Aviation Group, LLC? 8 A No. 9 Q Do you know who owns that company? 10 A I believe it's my son. 11 Q And has Servicios Aereos Profesionales, 12 S.A. ever leased aircraft from Professional Aviation 13 Group? 14 A Perhaps yes, perhaps no. If you were to 15 show me a list because it's -- I've leased so many 16 planes because I didn't own planes that I can't tell 17 you. The last three years -- I've leased so many 18 planes the last three years, so I can't recall 19 unless you give me a list. 20 Q When you first became president of 21 Servicios Aereos Profesionales, how many aircraft 22 did the company own? 23 A I can't recall exactly the number of 24 aircraft. 25 Q Can you list -- go ahead.

59 1 A But we used to operate some planes that 32 2 were later discontinued in the Dominican Republic. 3 Did you bring the pictures? 4 There are some Lets planes, there were about ten 5 Lets planes. Some of those planes were -- belonged to 6 Servicios, but then there was a regulation in the Dominican 7 Republic that the planes needed to have -- the tass had to 8 be installed. 9 Q T-A-S-S? 10 A Yes. And the flight data computer had to 11 be installed and the voice recording needed to be 12 installed. Those four pieces of equipment cost more 13 to install than the planes -- then what the plane 14 cost, so that's why those planes were used for a 15 while until the engines and everything else expired. 16 Those planes are there parted out. These were the 17 planes that Servicios Aereos Profesionales would use 18 for internal flights, for most of the flights. 19 Q And so when did the company retire those 20 aircraft? 21 A About four years ago. About four years 22 ago. 23 Q What other planes did the company have 24 besides the ten Lets? 25 A The Short, the Twin Otter, and I believe

60 1 one or two Jetstreams Q What happened to the Twin Otter? 3 A The Twin Otter was lost because of a loan 4 that we had gotten in order to pay the attorneys in 5 New York, and a couple more things with them. 6 Q What did the attorneys in New York have to 7 do with this aircraft? 8 A They needed to be paid monies, so we got a 9 loan on the Twin Otter in order to pay the attorneys 10 their -- it was mortgaged. 11 Q The attorneys in the Embraer lawsuit? 12 A Yeah. Yes. 13 Q And that aircraft was repossessed? 14 A Correct. 15 Q What happened to the Jetstreams? 16 A Part of the planes were also lost because 17 of loans. In order to make the payment to Embraer 18 we paid 18 months of the Embraer. We paid almost 19 about $2 million on the Embraer in payments. 20 Q So what happened to the Jetstreams? 21 A The company wasn't able to pay the loan 22 from different companies, and for that reason the 23 planes were repossessed. 24 Q Do you recall who repossessed the 25 Jetstreams?

61 1 A Aerolineas, A-E-R-O-L-I-N-E-A-S, Santa 34 2 Domingo was one of the companies that repossessed 3 the Jetstreams because Aerolineas Santa Domingo, 4 together with all the planes they had, had flights, 5 and then there was a very big bill accrued. The 6 company couldn't pay it and the guarantees were 7 those planes. 8 Q So Aerolineas Santa Domingo repossessed 9 the aircraft? 10 A I believe two Jetstreams. 11 Q Were there any other Jetstreams owned by 12 the company? 13 A I think so. I believe there was one more 14 or so jets, or two more Jetstreams that belonged to 15 Aerolineas Santa Domingo. 16 Q They were leasing the planes to you? 17 A Now they're leasing planes so the company 18 can continue operating because otherwise they will 19 close -- close the company. I just have not wanted 20 to file bankruptcy for the company. In order to 21 close the company out, I close the company. But I 22 am not able to pay Embraer or anyone else. We keep 23 working just to see if at some point the company 24 will be able to recover. 25 Q Recover from what?

62 1 A To be closed to the bankruptcy where it is 35 2 at this time. 3 Q Did SAPSA own any other aircraft other 4 than the Lets, Twin Otter and Short? 5 A No. 6 Q What does the company own now besides the 7 Cessna and Embraer? 8 A Cessna and Embraer. That's the only thing 9 the company has, the Cessna and Embraer, and it does 10 not belong to us, it belongs to Cessna Finance. It 11 is under our name and it has two liens, one from 12 Cessna and another one from a private investor. 13 Q So there is no equity in the aircraft? 14 A Doesn't belong to me, it belongs to 15 Cessna. 16 Q Does the company lease the Cessna? 17 A It's the only thing the company has now, 18 and it's practically not operating anymore because 19 it is a single engine plane. It is a nine passenger 20 plane, but the company needs to have a plane in its 21 certificate otherwise the Dominican Republic will 22 close down the company. The only reason that that 23 plane is being paid for is so that Cessna will not 24 take it, and we're also behind in the payments. 25 We've been in default many times and then we pay

63 1 part and then we pay again, and Q Going back to this Professional Aviation 3 Group that is owned by your son, where is that 4 company organized? 5 A I really don't know exactly. 6 Q Let me show you a document that we marked 7 as Exhibit 7. 8 (Whereupon, the referred-to documents were 9 marked as Plaintiff's Exhibit Number 7 for 10 Identification.) 11 THE WITNESS: When you say organized, what 12 do you mean by organized? 13 BY MR. OWENS: 14 Q Incorporated. 15 A Oh, I don't know. 16 Q Do you know where it operates from? 17 A No. 18 Q Has the company, meaning Servicios Aereos 19 Profesionales, S.A., ever leased aircraft from that 20 company? 21 A Not that I recall. 22 Q You answered that after reviewing Exhibit 23 7? 24 A Which is Exhibit 7? 25 Q This (indicating).

64 1 A Oh. I don't think we leased one. I don't 37 2 remember a plane that they leased to us. 3 Q Do you know where this company's office 4 is? 5 A The company's office? 6 Q Professional Aviation Group, LLC? 7 A What address does it have there? 8 Q It does not have an address on it there. 9 A No. 10 Q You don't know? 11 A No. I'm not sure, I think it was in 12 Delaware or something, but I don't recall. 13 Q I'm asking about their office, not where 14 they were incorporated. 15 A I don't know. 16 Q Do you know where the office of 17 Professional Air Services, LLC is? 18 A No. 19 Q Do you know -- let me ask you this: Has 20 Servicios Aereos Profesionales, S.A. ever had an 21 office in the United States? 22 A At some point, yes, it had offices here. 23 Q When? 24 A Years ago it had an office in SheltAir, 25 Fort Lauderdale International until last year.

65 1 Q S-H-E-L-T, A-I-R A In SheltAir in the FBO of Hollywood 3 International. 4 Q Fort Lauderdale/Hollywood International? 5 A Yes. But it was not -- but not an office, 6 only a place where we received the parts and 7 mailings, no accounting or nothing like that. 8 Because the mail in Santa Domingo you lose the parts 9 and that type of thing, so the deliveries were made 10 to this office and then they would be sent to Santa 11 Domingo with someone who could take parts for us, or 12 through DHL or something like that. 13 Q Did Professional Services, LLC ever have 14 an office for the company at SheltAir? 15 A Well, I can't answer that. Perhaps they 16 used that address, but I didn't know about it. I 17 don't know if they used that address. We also 18 shared the rent with another company called Trim 19 Air, and at the end Trim Air kept the office because 20 we couldn't pay for it. 21 Q Did Servicios Aereos Profesionales ever 22 share office space with Professional Aviation Group? 23 A Perhaps, but not as their office, perhaps 24 they had a mailing address there. Not as an office. 25 Q Have you ever heard of a company called

66 1 SAP, Inc.? 39 2 A Yes. 3 Q What is that company? 4 A It's a charter company, an airline 135 and 5 it's U.S. 6 Q So is that the same thing as Servicios 7 Aereos Profesionales, Inc.? 8 A Would you repeat the question? What was 9 the previous question? 10 Q The previous question was SAP, Inc A Yes, it's the same, Servicios Aereos 12 Profesionales, Inc. 13 Q So there is not a separate company SAP, 14 Inc.? 15 A Servicios Aereos Profesionales, Inc. is 16 the same company as SAP, Inc. 17 Q Where is that company incorporated? 18 A That company used to be or was 19 incorporated in Puerto Rico, and now it's being 20 incorporated here in Miami. 21 Q I want to go back to Professional Aviation 22 Group, LLC. Have you ever held a position with that 23 company? 24 A I don't recall having held any position 25 with that company.

67 1 Q Have you ever owned any part of that 40 2 company? 3 A No. 4 Q Have you ever owned any part of SAP, Inc.? 5 A Yes, we've been owners of SAP, Inc. 6 Q Who is we? 7 A My wife and I. 8 Q You own 100 percent of the stock? 9 A No, we're -- I don't recall exactly what 10 the percentage is. 11 Q Do you own a majority of the stock? 12 A Probably, yes, in that one. 13 Q Who are the other stockholders? If you 14 don't know just say you don't know. 15 A I don't recall. 16 Q Okay. Is that company in operation now? 17 A Yes, that company is in operation. 18 Q What does that company do? 19 A Charters. 20 Q Where is it based? 21 A That company is based in Puerto Rico, and 22 now we're -- it is going to be based here in Fort 23 Lauderdale. 24 Q At SheltAir? 25 A No.

68 1 Q Where? 41 2 A The executive airport. 3 Q Does that company own any aircraft? 4 A No. 5 Q So the Dominican Air Lines, Servicios 6 Aereos Profesionales, S.A., has never leased 7 aircraft from that company? 8 A Could you ask that again? I didn't 9 understand that. 10 Q Has Servicios Aereos Profesionales ever 11 leased aircraft from SAP, Inc.? 12 A On some occasions, yes. 13 Q What aircraft was that? 14 A I think it was a Q And SAP, Inc. no longer owns that 16 aircraft? 17 A No. 18 Q What happened to the aircraft? 19 A It was delivered to Beechcraft. 20 Q Repossessed? 21 A Repossessed. 22 Q Do you recall SAP, Inc. ever owning a 23 Hawker Siddeley 125? 24 A Yes. Yes, I think one Hawker. 25 Q Where is that aircraft now?

69 1 A That aircraft hasn't moved from the 42 2 Dominican Republic in the past three years, it has 3 inspections that have not been -- have not taken 4 place. 5 Q So SAP, Inc. owns that aircraft? 6 A Yes. That plane is still being paid for. 7 And we're in default and the plane hasn't moved for 8 three years in Santa Domingo. 9 Q Have you ever heard of a company named SAP 10 Express? 11 A SAP Express? It's a company in Santa 12 Domingo that leased planes, isn't that SAP Express? 13 Yes, in Santa Domingo. 14 Q It leased aircraft to? 15 A To whoever. 16 Q Including Servicios Aereos Profesionales, 17 S.A.? 18 A Yes, some time ago. That company is no 19 longer operational, it hasn't been for the past two 20 years. 21 Q Did you ever own any part of that company? 22 A I don't think so. 23 Q Did you ever hold a position with that 24 company? 25 A No, I don't think so.

70 1 Q Do you hold a position with Air Santa 43 2 Domingo? 3 A Yes. 4 Q What is your position? 5 A Vice president of Air Santa Domingo. 6 Q Who is the president? 7 A It is a gentleman by the name of Henry 8 Azar. 9 Q Does he have any relation to Marisol Azar? 10 A Marisol is the wife. 11 Q And you and your wife own stock in Air 12 Santa Domingo? 13 A We own stock in Air Santa Domingo. 14 Q Do you own a majority of the stock? 15 A No, I don't think so. 16 Q Does your son Jose Miguel Patin have an 17 additional name? 18 A What -- when you say additional, what do 19 you mean by additional? 20 Q Well, as I understand it, you have a 21 suffix Escusio (sic)? 22 A I didn't understand that. 23 MR. CERVERA: Eusebio. 24 THE WITNESS: Eusebio, okay. My son's 25 name is Jose Miguel Patin Hernandez because his

71 1 mother's last name is Hernandez. These are 44 2 coincidences. My father was Hernandez and he 3 is also Hernandez, but they have nothing to do 4 -- they're not the same. 5 MR. OWENS: Mark 8. 6 (Whereupon, the referred-to documents were 7 marked as Plaintiff's Exhibit Number 8 for 8 Identification.) 9 BY MR. OWENS: 10 Q I'd like to show you a document we've 11 marked as Exhibit 8. And I'm going to ask you about 12 the two pages that have tabs on them. My question 13 is, are those your signatures on the last page and 14 on the two pages up from the last page? 15 A That's my signature. 16 Q And that's on page 23 of 25? At the 17 bottom you see page 23 of A The page 23, that's my signature -- my 19 signature, yes, and this is my signature, also. 20 Q On 25? 21 A 25, yes. 22 Q And is your signature -- I'm sorry, let me 23 get to that one page. And your signature is, again, 24 on page 15? 25 A Yep, that's my signature.

72 1 Q Okay. I'd like to show you documents 45 2 we've marked as Exhibits 9 and (Whereupon, the referred-to documents were 4 marked as Plaintiff's Exhibit Numbers 9 and 10 for 5 Identification.) 6 BY MR. OWENS: 7 Q I'd like you to look at Exhibits 9 and 10 8 and tell me if you recognize the signature on those? 9 A All I know is that they're not mine. 10 Q Do you know whose they are? 11 A May I ask my wife something? 12 Q Sure. 13 A Let me see. Let me see. Both signatures 14 look quite different than this one like this. 15 Q Want to say it in Spanish? 16 A It seems that the signatures have slight 17 differences, but they look like my son's, but I 18 would not be able to guaranty that. 19 Q Have you heard of a company called Orlando 20 Air Link? 21 A Yes. 22 Q What is that company? 23 A That's been closed by the FAA already. 24 Q What kind of company was it? 25 A I believe it was a company that had been

73 1 purchased for charter purchases Q Why did the FAA close it? 3 A It did not comply with the FAA 4 requirements. 5 Q Did it actually have a certificate at one 6 time? 7 A It had a certificate for a while and then 8 they were going to take away the certificate -- they 9 wanted to take away the certificate. The 10 certificate had been suspended. 11 Q The company is closed now? 12 A Yes. 13 Q Did SAPSA ever lease any aircraft from 14 Orlando Air Link? 15 A No, not that I recall. 16 Q Did A I believe that company never owned 18 aircraft. 19 Q Do you know Wayne Hazelwood? 20 A Sure. 21 Q What does he do? 22 A He's the owner of Trim Air, to my 23 understanding. 24 Q What kind of business is that? 25 A Charter, aircraft lease throughout the

74 1 whole United States Q Has Servicios Aereos Profesionales, S.A. 3 ever leased aircraft from that company? 4 A I believe at some point for a charter -- 5 for a charter or something like that, because it's a 6 charter company, so at some point -- 7 Q How many times? 8 A Five, six times, but in a seven or eight 9 year period. 10 Q Okay. 11 A I don't recall exactly. 12 Q Have you ever owned any part of that 13 company? 14 A No. 15 Q I'm going to show you documents we marked 16 as Exhibits 11 and (Whereupon, the referred-to documents were 18 marked as Plaintiff's Exhibits Number 11 and 12 for 19 Identification.) 20 BY MR. OWENS: 21 Q I'd like you to look at those two 22 documents and tell me if your signature is on those 23 two documents. 24 A May I ask my wife a question? 25

75 1 Q Sure A What does this have to do with Trim Air? 3 Q I didn't ask about Trim Air. 4 A Okay. 5 Q My question is -- 6 A The thing is that you were asking me -- so 7 we were talking about the office and then you give 8 me these documents, so I thought they were related 9 to the previous question. 10 Q No. 11 A Okay. These were two certificates that we 12 had in the bank, and they do recognize that. We 13 used them as lines of credit. We used those monies 14 to pay for the fuel and our bills and our things, 15 because sometimes we didn't have the money and some 16 of the other bank's checks would be returned. So we 17 had this C.D. in order to get a line of credit, and 18 it was used through the years. It was finally used 19 in fuel and payments. 20 Q You signed as Jose M. Patin, aka, Jose 21 Miguel Patin Hernandez, correct? 22 A No, I signed here as Jose Miguel Patin 23 president of Servicios Aereos Profesionales company. 24 Q Do you know why it says also known as Jose 25 --

76 1 A No, no Q You don't know why it has Hernandez after 3 your name? 4 A Surely because my father used to be the 5 previous president of the company and he had the 6 same name, but my father's last name was Hernandez. 7 Q So it is a mistake then? 8 A Yes. I signed here as Jose M. Patin and 9 president of Servicios Aereos Profesionales at that 10 time when my father was already deceased. 11 Q Okay. So the signature -- your signature 12 appears at the last page of each of Exhibits 12 and and 12? 14 A Correct, and correct. 15 Q I'd like to show you document that we are 16 marking as Exhibit (Whereupon, the referred-to documents were 18 marked as Plaintiff's Exhibit Number 13 for 19 Identification.) 20 BY MR. OWENS: 21 Q Do you recognize that signature on that 22 document? 23 A It says Jose Patin, but that is not my 24 signature. 25 Q Do you recognize the signature?

77 1 A No Q Have you ever heard of a company that's 3 referred to itself as the SAP Group? 4 A SAP Group? 5 Q Yes, it's in Santa Domingo. What is that 6 entity? 7 A It's a group of companies of the FASAP 8 company. 9 Q Owned by the SAP company? 10 A I don't understand your question. 11 Q Is SAP Group a legal entity? 12 A I don't think so. I think it was just 13 given that name. I don't think it is a legal 14 entity. 15 Q Who gave it that name? 16 A In Santa Domingo our attorneys -- it's not 17 a company, it's a commercial name, business name, a 18 corporation. 19 Q Are these companies that work together? 20 A No. 21 Q The companies don't work together? 22 A No. 23 Q Why is it called SAP Group? 24 A Because we look like it is a -- because 25 there you call group -- many times you use the word

78 1 group when you have different companies and so on Q These companies are unrelated to each 3 other? 4 A No, no. 5 Q Let me ask that question again. Do these 6 companies under the SAP Group have any relation with 7 each other? 8 A No, no relation. 9 Q They don't do business together? 10 A SAP Group, no. 11 Q All of the entities under the SAP Group 12 are completely separate? 13 A It's completely separate. 14 Q And you don't do business with each other? 15 A No. 16 Q Did you have anything to do with creating 17 the website for SAP Group? 18 A No, basically that's something commercial 19 for your advertising. SAP Group is like a broker as 20 if it were a broker. 21 Q Tell me what business SAP Group is in? 22 A I cannot tell you, it's only a commercial 23 entity, it's a commercial name. 24 Q Well, I thought you said that it acts as a 25 broker.

79 1 A No, basically it's a commercial entity Q And what does the commercial entity do? 3 A Nothing. Commercially, nothing, that I 4 recall. 5 Q Did you have any involvement in creating 6 the use of that name? 7 A No. 8 Q Have you ever used that name? 9 A No. 10 Q Have you ever read the website of SAP 11 Group? 12 A No. 13 Q Have you ever read the website of SA Air? 14 A SA? Yes. 15 Q Is the information on that website 16 accurate? 17 A I haven't seen it for quite a while. 18 Q When was the last time you saw it? 19 A Some time ago, I'm really not very good 20 with computers, that's why. 21 Q But how long ago? 22 A Perhaps when it was being designed a year 23 ago, two years ago. I understand that that keeps 24 being modified regularly by people that know about 25 websites.

80 1 Q When you were president did you have any 53 2 involvement in the modifications of that website? 3 A No. 4 Q When you looked at it did you determine 5 that the information on the website was correct? 6 A Basically I don't know if it was correct 7 or not, if I was looking for something it was 8 something in the commercial aspect. 9 Q Who at the company was in charge of 10 ensuring that the information on the website was 11 correct? 12 A It's a company that you pay so they will 13 do something that is commercial, marketable, pretty, 14 attracts attention. 15 Q Who at Servicios Aereos Profesionales, 16 S.A. was in charge of ensuring that the information 17 on the website was correct? 18 A I don't know. 19 Q No? 20 A I don't know. That was basically with that was just for commercial criteria, commercial 22 purposes, commercial effect. 23 Q It was advertising? 24 A Advertising. 25 Q Who was in charge of designing the website

81 1 from the SAP Group? 54 2 A A company in the Dominican Republic, the 3 company that does that type of thing. They were 4 paid. They would take pictures of planes, some were 5 ours and others were not, the planes that were there 6 in the company that we had leased. And they would 7 even use helicopter signs and the company does not 8 have helicopters. They mention medical emergencies, 9 but we don't have medical emergencies. But if a 10 plane was leased from the U.S. it could come and a 11 service could be provided, that was the purpose of 12 the website. 13 Q Who on the part of the SAP entities gave 14 the information to the website design company? 15 A Perhaps the marketing department, the 16 commercial department. 17 Q What is the marketing department? 18 A We have two employees in the commercial 19 department. 20 Q Who are they? 21 A Could I ask her for the name? 22 Q You don't know the name? 23 A Mr. Harold, he's German, he's the one in 24 charge of the marketing department. 25 Q What is his full name?

82 1 A Harold Heyer Q Spell it, please. 3 MRS. HERNANDEZ: May I say? 4 MR. OWENS: Sure. 5 MRS. HERNANDEZ: H-E-I -- H-E-Y-E-R, 6 Heyer. 7 BY MR. OWENS: 8 Q And who sells in the department? 9 A Second category employees that they visit 10 clients. 11 Q What's their names? 12 A Geraldo, Paulino. 13 Q So between these two people they were in 14 charge of designing the website. 15 A Yeah, take the photographs. My 16 understanding was that they hired people to go to 17 the planes, take photographs of the planes and that 18 type of thing. Planes that we leased and 19 helicopters that we had the possibility of leasing, 20 also for medical emergencies, medical services from 21 the U.S. We went to different websites that we had 22 seen and -- they went to different websites they had 23 seen and got something similar out of that. 24 Q I'd like to show you a document we've 25 marked as Exhibit 14.

83 1 (Whereupon, the referred-to documents were 56 2 marked as Plaintiff's Exhibit Number 14 for 3 Identification.) 4 THE WITNESS: Yes, this is exactly what 5 I'm saying. People who were hired to take 6 pictures of the planes and whatever. 7 BY MR. OWENS: 8 Q I'd like you to look at Exhibit 14 and 9 tell me if the first sentence is correct? 10 A Which is the first sentence? 11 Q Where it says the SAP Group is formed. 12 A That is not correct. 13 Q What is incorrect about it? 14 A It's not formed by any of those groups, it 15 is just a commercial name. 16 Q Is the second sentence correct? 17 A Let's look at it. It's not correct 18 either. 19 Q Why not? 20 A My understanding is that the SAP Group please interpret this for me. 22 Q Would you read the second sentence 23 beginning with our commitment? 24 (Whereupon, the interpreter interpreted the above 25 sentence from English to Spanish.)

84 1 THE WITNESS: SAP Group does not exist 57 2 since BY MR. OWENS: 4 Q Servicios Aereos Profesionales, S.A. has 5 existed since 1981, correct? 6 A That's correct, but not SAP, not SAP 7 Group. 8 Q And I'd like you to translate the last 9 sentence there beginning with based in Santa 10 Domingo. 11 (Whereupon, the interpreter interpreted the above 12 requested portion of the transcript from English to 13 Spanish.) 14 THE WITNESS: That's something commercial, 15 many companies use that when they have people 16 that they work with in Puerto Rico or here or 17 in Venezuela. That is commercial, commercial 18 strategy. 19 BY PLAINTIFF'S ATTORNEY 1: 20 Q Was SAP, Inc. based in the Dominican 21 Republic? 22 A It was based in Puerto Rico. 23 Q So when that last sentence referred to a 24 branch in San Juan, it is referring to SAP, Inc.? 25 A Whatever I can use in Puerto Rico -- any

85 1 entity I can use in Puerto Rico, just like any 58 2 entity that I could use here in Miami or Central 3 America or in Panama. 4 Q It also says that you have a base in Fort 5 Lauderdale, which company had a base in Fort 6 Lauderdale -- a branch in Fort Lauderdale? Let me 7 say that again. 8 It also said that a branch in located in Fort 9 Lauderdale, which company had a branch in Fort Lauderdale? 10 A Servicios Aereos Profesionales, Inc. is 11 now moving to Fort Lauderdale from San Juan, it's 12 moving here for commercial purposes. 13 Q It has been in the website for over a 14 year. 15 A Commercial purposes. 16 Q So there is A If I have someone that wants to call me 18 and I tell them I'm only based in Puerto Rico, how 19 do I get any flights here in Florida? What I do is 20 I can do some sort of advertising and then you lease 21 a plane -- I lease a plane here and then you just 22 make a small commission. 23 Q So Servicios Aereos Profesionales A The same thing I do if I'm in Panama, they 25 call me from Panama. I have companies in Panama and