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R. Leonard, C.S.R., Inc. Certified Shorthand Reporters 818.995.2449 SHEET 43 PAGE 169 PAGE 171 1 SOMETIMES HE'D BLAME THE DEAL, SOMETIMES HE WOULD 09:45:13 1 A THAT AGAIN, THAT ONE I'M NOT SURE ABOUT, 2 BLAME - HE'D BLAME EVERYTHING BUT HIPISELF UNTIL 2 YOU'RE ASKING ABOUT A GROUP WHERE THERE WAS SOMEBODY 3 SOMETIME IN MID JANUARY HE STARTED TO BLAME HIMSELF AND 3 ELSE CLAIMING TO HAVE A RELATIONSHIP THERE. 4 I ACTUALLY KEPT HIM IN THE DEAL LOOKING FOR FINANCING 09:45:13 4 Q DID MR. DALESANDRO ATTEND A 14EETIIIG WITH YOU 5 MUCH LONGER BECAUSE I HAD HAD IT WITH HIM, I WAS 5 AND ROCKWOOD? 6 INCENSED, I KNEW I HAD TO GO SAVE MY INVESTMENT AND I 09:45:13 6 A I HONESTLY CAN'T RECALL IF HE WAS THERE OR NOT. 7 WAS MOVING TO DO ANYTHING AND EVERYTHING TO SAVE THE 7 I REMEMBER MEETING WITH HIM BUT I DON'T KNOW IF HE WAS 8 DEAL. 8 THERE, 09:15:13 9 BUT HE CAME CLEAN TO ME AND SAID 'YOU KNOW, I 09:45:13 9 Q DID ANYONE FROM ROCKWDOD TELL YOU ANYTHING 10 USED TO WORK AT A BANK, I USED TO GET A CHECK. I WENT 10 MR. DALEBANDRO DID WAS NOT TRUTHFUL? 1' OUT ON MY OWN. I HAVEN'T DONE AS WELL AS I THOUGHT. 09:45:13 11 A DID YOU ASK ME IF ROCKWOOD SAID TEAT? 12 MAYBE YOU COULD GIVE ME SOME ADVICE. MAYBE WE COULD 09:45:13 12 Q CORRECT. DID ANYONE FROM ROCKWELL -- ROCKWOOD 13 WORK THROUGH IT." 13 TELL YOU THAT MR. DALESANDRO SAID SOMETHING THAT WAS NOT 09:15:13 14 AND I GUESS WITHOUT KNOWING IT I WAS LOOKING 14 TRUTHFUL? 15 FOR SOME HUMILITY AND HE WAS A GUY THAT WOULD -- JUST 09:45:13 15 A I DON'T RECALL IF IT WAS ROCKWOOD OR OTHER 16 LACKED HUMILITY. WHEN HE FINALLY CAPE WITH SOME 16 COMPANIES. 17 HUMILITY SOMETIME MID TO LATE JANUARY, I KIND OF RR -SET 09:45:13 11 Q WELL, YOU IDENTIFIED ROCKWOOD AS A COMPANY THAT 18 WITH HIM A LITTLE BIT AND HUNG IN THERE ANOTHER MONTH 1S MR. DALESANDRO HAD MADE ONE OF HIS HUNDREDS OF LIES TO 19 WITH HIM TO SEE WHERE HE COULD TAKE IT AND IT STILL 19 YOU ABOUT; IS THAT RIGHT? 20 DIDN'T WORK. 09:45:13 20 A I SAID MISREPRESENTATIONS. 09:45:13 21 Q WHAT WAS THE FALSE REPRESENTATION 09:45:13 21 Q WHAT'S THE DIFFERENCE BETWEEN A LIE AND A 22 MR. DALESANDRO MADE ABOUT THE ARIA FUND? 22 MISREPRESENTATION? 09:45:13 23 A IT WAS JUST A NAME HE HAD MENTIONED TO ME THAT 09:45:13 23 A I DON'T KNOW, 24 WAS LOOKING AT THE DEAL AND THEY LIKED THE DEAL, 09:45:13 24 Q DO YOU HAVE A DIFFERENCE IN YOUR OWN MIND 09:45:13 25 I'M NOT TELLING YOU DEFINITIVELY ARIA. I COULD 25 BETWEEN LIE AND MISREPRESENTATION? 169 171 PAGE 170 PAGE 172 _ TELL YOU DEFINITIVELY THAT HE TOLD ME ROCKWOOD WAS GOING 09:45:13 1 A I THINK LIE IS A COMMENT THAT YOU KNOW 2 TO DO THE DEAL, HE TOLD ME USAA WAS GOING TO DO THE 2 DEFINITIVELY AT THE 71E IS INACCURATE. A 3 DEAL. HE JUST KEPT COMING WITH THESE NAME AFTER NAME 3 MISREPRESENTATION IS SORT OF SKEWING THE TRUTH. 4 SAYING THEY'RE UNDERWRITING, THEY LIKE IT, WE'RE GOING 00:45:13 4 Q HOW DID MR. DALESANDRO MISREPRESENT ROCKWOOD TO 5 TO GET THERE. 5 YOU? D9:45:13 6 AND I WOULD SAY FROM LATE DECEMBER THROUGH LATE 09:45:13 6 A IN GENERAL -- AND AGAIN, I'M NOT TALKING ABOUT 7 JANUARY IT WAS THE SAME SONG AND DANCE UNTIL HE CAi4E 7 ONE GROUP - IT WAS THE SAME STORY EVERY TIME. THIS 8 CLEAN WITH ME IN LATE JANUARY AND SAID "I CAN'T GET THIS 8 GROUP LIEES THE NUMBERS, IT WORKS FOR THEM, THEY'RE 9 DONE. I'M NOT GOING TO BE ABLE TO FIND FINANCING. 9 COMING IN, WE'RE GOING TO GET IT DONE, AND HE KNEW I WAS 10 YOU'VE GOT TO TAKE IT DOWN ON YOUR OWN BALANCE SHEET, 10 BELIEVING IN HIS REPRESENTATIONS, HE KNEW I WAS RELYING 11 WE'RE NOT GOING TO BE ABLE TO FIND YOU A PARTNER TO 11 ON HIS REPRESENTATIONS, AND BASED ON THAT I MOVED, D9:45:13 12 DEVELOP THIS SITE," 12 CONTINUED TO HAVE A RELATIONSHIP WITH THE MAN IN ORDER 09:45:13 13 Q AND YOU SAID THAT HE SAID SOMETHING ABOUT 13 TO ALLOW HIM THE ROOM TO BE SUCCESSFUL AND RAISE THE 14 ROCKWOOD. WHAT'S ROCKWOOD? 14 CAPITAL, 09:45:13 15 A INSTITUTIONAL CAPITAL PARTNER THAT INVESTS IN 09:45:13 15 Q DID YOU EVER DETERMINE THAT ANYTHING HE TOLD 16 REAL ESTATE. 16 YOU ABOUT ROCKWOOD WAS NOT TRUE? 09:45:13 17 Q WHAT DID MR. DALESANDRO TELL YOU ABOUT 09:45:13 17 A I DON'T REMEMBER SPECIFICALLY ROCKWOOD. I 18 ROCKWOOD? IS COULD TELL YOU -- 09:45:13 19 A HE SAID THEY HAD AN INTEREST. 09:45:13 19 Q SO SITTING HERE NOW, YOU HAVE NO KNOWLEDGE, YOU 09:15:13 20 Q DID SOMEONE FROM ROCKWELL (SIC.) TELL YOU THAT, 20 CAN'T THINK OF ANYTHING MR, DALESANDRO TOLD YOU ABOUT 21 IN PACT, THEY NEVER HAD AN INTEREST? 21 ROCKWOOD THAT WAS NOT TRUE; IS THAI RIGHT? 09:45:13 22 A I WOULDN'T SAY THAT, 09:45:13 22 A NO, THAT'S NOT RIGHT. 01:45:13 23 Q DID YOU EVER MEET WITH ANYONE FROM ROCKWOOD? 09:45:13 23 Q SO WHAT DID MR. DALESANDRO TELL YOU ABOUT 09:45:13 24 A YES, 24 ROCKWOOD THAT TURNED OUT NOT TO BE TRUE? 09:49:13 25 Q DID MR. DALESANDRO ARRANGE THE MEETING? 09:15:13 25 A THEY'RE GOING TO FINANCE THE DEAL, 1701 172 Dalesandro vs. Ogulnick Deposition of Ryan Andrew Ogulnick, Vol. 1 August 13, 2012