Q. Did you ever witness Mr. Shapiro paying any money to any University of Miami football or basketball players?
A. Yes.
Q. And can you remember those instances when they were and to whom they were?
A. I don't remember the specifics.
Q. Do you know what year that was?
A. I don't remember exactly what year it would have been.
Q. Do you know how much money was exchanged?
A. I don't know specifics. It was relatively small amounts, hundreds, low hundreds.
Q. And what would be the purpose of that?
A. I suppose sometimes generosity. Other times he would do, you know, like bowling events. Whoever won would receive money and stuff like that.
Q. Did you ever pay any money out on behalf of Mr. Shapiro to any University of Miami football
or basketball players?
A. No.
Q. And you don't remember the names of the players who you observed receiving money from Mr. Shapiro?
A. I really don't remember specific players.
Q. But it had to have been in '08/'09, correct?
A. Yes, '08/'09 and probably on occasions before that as well.
----------------------------------------------------------------
Q. Okay. Now, was there ever a time that you gave $10,000 to Jake Morton?
A. I don't remember doing that.
Q. Do you know who Jake Morton is?
A. Yes, I do.
Q. Okay. How do you know him?
A. He was a basketball coach at the University of Miami. And to be frank, I know this story because it was published, and I really just
do not remember that.
Q. Now, would it be fair to say that the fact that you don't remember, does that necessarily mean it didn't happen or just that you don't remember?
A. Right. State that again.
Q. Well, you say you just don't remember. The fact that you don't remember, does that mean that it could have never happened, or is it possible that it could have happened but you just don't remember?
A. It's possible it could have happened. I just really don't remember.
Q. And what I mean it's possible, I mean like would that have been outside the realm of things that Nevin was doing?
A. It would have surprised me with that amount of money, but nothing I guess really surprises me with Nevin.
Q. Well, did you know Nevin to be someone that would give money to people like, you know, athletes from the University of Miami, coaches, staff just in a benevolent way, the way that he would give it to you?
****THE BOLDED PART IS SOMETHING THE TRUSTEE WOULD REALLY ASK IMO****
A. Yes, but not that large of a quantity.
Q. But we have transfers to your account in the amount of $20,000.
A. I thought we were talking about the people at the University of Miami.
Q. Right, generally. I mean people --
A. Oh, generally people --
Q. Yeah. I mean he's disbursing money to you, 19, $20,000 and you're not keeping it. You're disbursing it on his behalf. So why would that amount to Jake Morton be so shocking?
A. I just didn't find him to be that big of a supporter of the University of Miami basketball. Again, it could have happened. I don't remember. It just seems like it was a lot.
Q. But he did give $50,000 to the basketball team, didn't he, at the fundraiser at Lucky Strike?
A. I was there. I don't remember the amount, but I was there for that. He did give a check.
Q. So he did give money to the basketball team?
A. Yes. I just never found him to be a big fan of the basketball team. He was always about football.
Q. Okay. Well, what would you be disbursing over a hundred thousand dollars for, what kinds of things? Typical things. Aside from what we've already discussed that you may not remember because it wasn't something that you did every day but it could have occurred.
A. I mean really specifically, the one time I remember was giving money cash to Adam Meyer who -- my understanding was that it was his bookie. My -- we'll get into assumptions here because he never told me what he was doing.
Q. And I don't want you to assume anything.
****THAT IS BECAUSE IT DOESN'T HELP THE NCAA IF HE PAID LARGE AMOUNTS TO A BOOKIE AND NOT PLAYERS/PROGRAM***
A. Okay. Then I won't even say.
Q. Okay.
A. Because I really -- I didn't know -- he didn't tell me what the money was for.
Q. Now, when you delivered cash, how would you deliver it, in an envelope, in a bag?
A. Envelope, if it fit.
---------------------------------------------
Q. Okay. Who else was present, if you remember?
A. At the house I remember a couple guys from UM showed up, although I think they had already graduated. They weren't in school anymore. I remember Jon Beason being there, Francesco. I don't remember who else was in the group. I remember a friend of Nevin's, Leott, was there. I don't know his last name. Those are the ones I specifically remember, but I know there was more people than that.
Q. Now, when you say that you remember some people from the University of Miami being there, what kind of people, staff, students?
****OBV IRRELEVANT BUT WHY IS SHE ASKING ABOUT IT****
A. Former athletes. Former student athletes at the time. They were no longer students at that time.
Q. And how do you know that?
A. How do I know --
Q. That they were no longer students at the
time.
A. Because I know them.
Q. Who are they?
A. Jon Beason being one, Francesco. They were no longer student athletes.
***NOT A VIOLATION IF NOT ENROLLED***
--------------------------------------
Q. Okay. And how many times did you attend Mr. Shapiro's suite at the Sun Life Stadium during the time that you had a relationship with him?
A. I would go up there probably every game, but I was also on the sideline, so I didn't spend too much time. I kind of flip-flopped back and forth, upstairs and down.
Q. Did you ever bring any players to Mr. Shapiro's suite, any perspective players or recruits?
****YOU CAN ONLY LAUGH AT THIS BULL ********
A. Yeah, one time that I remember.
Q. Who did you bring?
A. Jeff Godfrey and I believe Teddy Bridgewater was with him.
Q. Okay. And what was the purpose of you doing that?
A. Just bringing them up there to see it. There was no real purpose I guess.
Q. Well, would it be -- did you -- were you trying to introduce Mr. Shapiro to Mr. Godfrey for any reason?
****AGAIN BULL ********
A. I think I did introduce them, but there was no real reason behind it.
***Okay move on***
Q. Are you sure?
****FURTHER PRESSING ON A IRRELEVANT QUESTION IN A BANKRUPTCY CASE****
A. Not that I remember at that time being -- I mean I probably introduced him as my boss and come check out the suite.
Q. Who else was present, if you remember, during the times that the games would take place? Who were the usual suspects?
A. The usual suspects? Judd Hayes would generally go. One of his bodyguards I guess you would call him, Mario --
Q. Okay.
A. -- would be there I think every game.
----------------------------------------------
Q. Now, during the course of you working for Access was there ever a time when you brought or introduced someone you thought was a potential recruit from the University of Miami?
****AGAIN BULL ********
A. A potential recruit for the University of Miami?
Q. From the University of Miami.
A. From? I'm sure there was.
Q. Do you remember who you brought?
A. I'm trying to think of that time frame, who would be in that time frame. It would be Kyle Wright, Jon Beason, Tavares Gooden, Devin Hester. I could be missing somebody. I'm just trying to think of that time frame.
Q. Sure. And of course these individuals were still at the university looking to be in the pros, correct?
A. Yes.
Q. And what would you do -- tell me, give me a description of what you did to bring these individuals to the sports agency.
A. I didn't do so much as to really bring them to the sports agency. It was more of bringing them around Nevin I guess you would say, and he was the one that would talk to them about that sort of stuff. I mean I did have conversations with them, but I didn't really push too hard with them. So it would be more like just bringing them over to Nevin's house to hang out, or if he said, hey, see
if the guys want to come to a club tonight, stuff of that nature.
Q. Okay. And of the people you identified as individuals who you brought over as recruits that were still at the University of Miami, did any of those individuals, did you observe, have an opportunity to observe any financial transactions between them and Mr. Shapiro?
****THE RELEVANT PART IS THE MONEY, NOT THE STATUS OF PEOPLE WHO RECEIVED MONEY (i.e. Enrolled v. Not-Enrolled)***
A. I don't remember that specifically happening, but I'll go back to the question, the way we answered it before.
Q. Okay.
A. I'm not saying it never did, but I don't remember.
Q. You don't remember a specific instance?
A. A specific instance, yes.
Q. Do you remember if you ever yourself disbursed any money to any of the individuals that you identified as recruits, such as Devin Hester, etcetera?
A. I know I personally did.
Q. Okay. Can you tell me who you gave money to?
A. Probably all of those guys.
Q. Okay. Why don't you give me the list of their names again so we could be sure now --
A. No, I can't say for sure it was everyone. Like this is five years ago.
Q. I want you to only tell me the ones that you know of --
A. For sure?
Q. -- for sure that you gave them money.
A. Tavares Gooden. Devin Hester. I believe Roger McIntosh I believe. We're talking small amounts of cash, you know, $50 here, that sort of thing, because it was my own money.
***NOT $50.00, THIS DEPOSITION PROBABLY COST THOUSANDS***
Q. Okay. Did you ever give anything in the range of a thousand, 2,000, anything like that?
A. Me?
Q. Um-hum.
A. No.
Q. Did Nevin ever instruct you to go out and buy anything with the money, any goods, jewelry, cars, anything like that for any of the players that you identified?
A. No.
Q. Now, what was the purpose of giving them the money? Did they confer any kind of benefit that you know of, on Capitol or Nevin?
A. The purpose of Nevin giving them money?
Q. Or you disbursing money.
A. Me, it was just, you know, helping them out. It wasn't really -- like I said, it was small amounts. It wasn't a big deal. In terms of Nevin's relationship with them, I can't really speak for him, but I think it was twofold. One, I think he enjoyed being around them, but the other part was that he ultimately wanted them to sign with Access Sports.
Q. Okay. And when you were working with Access, is that what you ultimately wanted when you brought over the recruits, for them to sign with Access?
A. Sure, it's fair.
Q. Did the University of Miami know that that was going on?
****MORE TAINTED QUESTIONING THAT IS IRRELEVANT IN BANKRUPTCY PROCEEDINGS***
A. They knew that I worked for Access Sports. I don't know -- they knew that -- actually I can't speak to what they knew. They knew that I worked there.
Q. Was your presence known? Do you know if anyone saw you bringing over these recruits, whether it be at a game, at Mr. Shapiro's suite?
A. He didn't have a suite at that time.
Q. Okay.
A. But no, I don't think anybody knew about that stuff.
Q. But they knew you worked at Access. Why do you say it with such affirmation? You said that they knew you worked at Access, meaning the University of Miami knew?
***YOU CANNOT MAKE THIS **** UP***
A. Well, not the entire university.
Q. Right. Staff, staff.
A. Right, staff, because I mean obviously working there as a student I developed a friendship, relationships with people there, and after I left I would still return and naturally they would ask me, you know, what are you doing, where are you working, that sort of thing.
Q. Do you remember any one person that you reported this to at the University of Miami, about you working for Access?
A. I know Bobby Revilla knew who was my supervisor. I know Tony Hernandez knew. I don't know who else. I'm sure there were others, because like I said, I had, you know, had friends there and --
Q. The people you just identified, did you ever have an opportunity to observe Nevin conferring any kind of financial benefit, whether
it be in terms of money or other consideration, like buying something for that person, of people that you just identified or knew?
A. You said from that person?
Q. For. Did you ever see any financial transactions between Nevin and any of the individuals you just identified as people or staff
at the university and that knew you worked for Access?
A. Yes, but not at that time. It was probably prior to me working at Access.
Q. Okay. Can you tell me about that and who was involved?
A. I'm sorry. Nevin would go into the equipment room and purchase jerseys. I don't know if he paid cash, check. I'm not sure of the nature of how it was done, but he would go and purchase jerseys from Bobby Revilla.
Q. What do you mean purchase jerseys, signed jerseys?
A. I don't know if they were signed.
Q. Or just regular jerseys?
A. Could have been. I know that Bobby had signed jerseys. He had signed helmets. Actually I know that he bought a signed helmet from Bobby because it was in his house. It was signed by four national championship coaches.
Q. Okay.
A. You know, my understanding, that money was to the university. It wasn't personally to Bobby Revilla.
Q. Okay, that's important. Okay. And do you know -- did you have an opportunity to know -- did you see what was done with those jerseys? Were they sold --
A. The ones that --
Q. -- by Nevin? The one that Nevin, the Jerseys Nevin acquired.
A. The last time I was ever in Nevin's house, as far as I know, those jerseys were still hanging in his closet.
Q. Okay.
A. That was something he -- anybody that came over to visit his house, he brought up into his closet and showed them the jerseys.
Q. And I was just going to say, why would you have an opportunity to be in his closet --
A. Right.
Q. -- but you answered my question.
A. Everybody was in his closet.
Q. Okay. So you'd come over and he'd go, let's go to my closet?
****RELEVANCY?****
A. He would give the tour and that was part of it, was to walk in there and look at all the jerseys.
Q. And tell me about that. Tell me about the things that you saw in Nevin's house that were part of the tour, that were paraphernalia from the University of Miami or other kind of paraphernalia.
A. That's really it in terms of -- I knew there was the helmet that was signed by coaches from the University of Miami. I know there was the jerseys. Other than that, nothing relating to the University of Miami. A lot of pictures with him and people, but that was about it.
Q. All right. I'm going to show what's been marked -- oh, before I move on, did Nevin ever tell you how much money he paid for any one of those items, jersey, helmet, anything?
A. If he did I don't remember.
Q. Okay. Was it part of the tour?
A. No.
------------------------------------
A. -- middle is Frank Haith, and to the far Jake Morton.
Q. Okay. Now, do you have a relationship, other than a business relationship, with either
A. No.
Q. And do you know who they are?
A. Yes. They both -- well, Frank Haith used to be the head coach for the University of Miami men's basketball team and Jake Morton was one of his assistants. Neither one of them are there any longer.
Q. Okay.
A. Excuse me.
Q. Now, during the time that you were associating with Nevin, either social or business, how many times would you say -- you can give me an approximate. It doesn't have to be an exact -- how many times would you say that you went out with either Mr. Haith or Mr. Morton?
****MORE BS****
A. Myself?
Q. And Mr. Shapiro.
A. I remember one specific time and maybe two, but I only really remember one specific time.
Q. Okay. And can you tell me about that?
A. We went to dinner at Phillipe Chow.
Q. Okay.
A. That actually may be this picture. I'm not even sure.
Q. Okay.
A. I don't know. But we went to dinner at Phillipe Chow.
Q. Okay.
A. And then I believe afterwards we went to Solid Gold.
Q. Okay. And why do you remember that night? Was it an event? Anything in particular occur that night?
A. Well, yeah. I really didn't spend much time with them, so I do remember that.
Q. Okay.
A. I guess that's the reason why I remember it.
Q. Now, on the night that you guys went out did you have an opportunity to observe who paid for the events of the evening, either dinner or the strip club or both?
A. I don't know if I observed, but I can say with certainty that Nevin paid for all that.
Q. Did you pay for anything?
A. No.
Q. Okay. Aside from Mr. Morton, Mr. Haith, and Mr. Shapiro and yourself, who else was present, if you know, either at dinner or at the club?
A. I want to say there was others there, but I'm not a hundred percent sure, so I probably shouldn't say.
Q. Okay. Normally other people would have been there. It wouldn't have just been you guys?
A. Right. Well, I'm going to also -- this is an assumption I'm okay making --
Q. Sure.
A. -- is that there was probably one of his bodyguards, if not --
Q. Okay.
A. -- two there.
Q. Okay.
A. Because he didn't go to a strip club without at least one of them.
Q. Okay. Now, at anytime during the course of your relationship with Mr. Shapiro, and during the time that you guys had an opportunity to spend time together with Mr. Haith and Mr. Morton, did you ever see or observe Mr. Shapiro confer any
financial benefit on any of these individuals, whether it be in cash, or a gift, or anything like that?
A. The meals and the night at the strip club I guess I would consider -- it wasn't cash, but entertainment.
Q. Was there ever a time that you witnessed someone else at the direction of Mr. Shapiro give either of these individuals any cash monies or any gifts?
****AMAZING****
A. I don't remember that ever happening. He's going to be mad. I'll interject for a second. I know we talked about the thing with Jake Morton. Other than that, which I stand by what I said. Other than that, nothing even --
Q. Which basically -- right. What you said is that it could have happened, but you don't remember, and just because you don't remember doesn't mean it didn't happen?
****AMAZING****
A. Correct. And other than that --
Q. You would have been a good lawyer. Okay. So you think this is the night that you guys went to the strip club?
A. I'm guessing that, because I don't -- we didn't hang out a lot.
Q. Did Nevin ever tell you that he was hanging out with these guys at times when you weren't present, if you remember?
A. Yeah, occasionally.
Q. Now, what do you -- if you know. Only if you know because you were present. What do you think that night cost? What do you think -- what's a typical night out?
A. I have no idea, no clue.
Q. And would it be fair to say you have no idea because you never paid?
A. Right.
Q. Did you ever see anyone else paying aside from Nevin?
A. I don't think so. Not that I can remember.
---------------------------------------------------------------
Q. Well, if you notice, Mr. Shapiro's wearing the same shirt he's wearing in the picture with yourself and Mr. Campbell. Would you remember if, when you took Mr. Godfrey up to the suite, if Mr. Campbell was present at that time?
A. I don't remember. I don't know if it was the same date.
Q. Well, was there ever a time when you were all together, Mr. Godfrey, Mr. Shapiro, Mr. Campbell and yourself?
A. I don't remember specifically that. I don't remember.
Q. Do you know Mr. Godfrey personally aside from your relationship with Mr. Shapiro?
A. Yes.
Q. How do you know him?
A. Through my involvement with youth football.
Q. Did you mentor Mr. Godfrey?
A. I guess it depends how you define mentor.
Q. In any way, any way. Did you help him out in any way? Did you promote him? Did you want him to sign on with Access?
A. No.
Q. Did you want him to go to UM?
****NICE TRY *********
A. No. Well --
Q. What was the purpose of you bringing him in?
A. A good kid who, you know, I just wanted best for. In fact, Miami was never even really serious in him playing football there, so that wouldn't factor into the equation.
****SHOULD BE END OF QUESTIONING ON IT****
Q. Why do you say that?
A. Because that's what -- the coaches told me that.
Q. What's the basis of your opinion?
A. The basis of --
Q. Of your opinion that you just gave me, that the university wasn't really interested in him?
A. I don't even know if I would call that opinion because -- to make this as simple as possible, Jeff played quarterback, they did not
want him as a quarterback, thus there was really no recruiting of him.
****FUNNY STUFF, MESSAGE BOARD FIGHTS****
Q. And was there anytime did you observe Mr. Shapiro confer a financial benefit on Mr. Godfrey either directly or through anyone else, including yourself?
A. Jeff and I were at Nevin's house one time and I remember Nevin giving him a pair of old, like sneakers, or not -- I shouldn't say old, used sneakers after he gave the tour of the closet. I want to say that Nevin gave me some sort of, maybe a hundred bucks or something and said go out to eat, but I can't tell you the exact amount.
***Not used sneakers, this is great questioning in an almost billion dollar bankruptcy case***
Q. Okay. And was Nevin doing that in a benevolent way or was it geared towards business, if you know, based on your discussions?
A. Benevolent way.
Q. Benevolent, okay. Do you still have a relationship with Mr. Godfrey?
A. I spoke to him when the, around the time, but when the Yahoo story came out. I really haven't spoken to him since. Not because of that, we just don't really speak that often.
Q. And what ended up happening with him?
A. Actually he just left UCF. He's transferring out unrelated to, you know, any -- he's just leaving.
Q. But did he ever do anything with the University of Miami or no?
A. No, no, no. He signed with the University of Central Florida. That was kind of why we lost touch a little bit.
__________________________________________
Q. How many times would you say you went to the suite and found either Mr. Morton or Mr. Haith at the suite?
A. More than one, less than four.
Q. Okay. What kinds of activities occur in the suite? Is it alcohol, sales, food? Is Nevin paying for things? What kinds of things are going on in the suite?
A. There was alcohol. There's food. There's watching the game. I don't know what agreement Nevin had with the others in the suite on how that was paid for.
Q. Okay.
A. That's one thing where I don't know if he picked up the check or if they split it. I don't know how they did that.
Q. When you say they, who would you be referring to?
A. The people who had tickets in the suite.
Q. Do you know who they are?
A. No.
Q. Do you know who the regulars were that shared the suite with Mr. Shapiro, not just attended?
Q. Now, did any players ever go to the suite, any players from the university, I mean whether it be the football or basketball program, what did you ever see them there drinking or eating?
***MORE BS***
A. The football players would have been.
Q. Anyone. Were there old players --
A. Oh. Yeah, occasionally you'd see player in there. The only one I can remember off the top of my head is Cornelius Green.
***Not Cornelius Green***
Q. Okay.
A. But I know occasionally that there were former players in there.
[I omitted apart about Joey Porter that she didn't follow up on because probably no relation to the Hurricanes]
------------------------------------
Q. Okay. I'm going to show you what's been marked for identification as Defense Exhibit Number 14, and I want you to look through the pictures, and I want you to tell me if you can recognize them, the individual pictures. There's one, two there's three pictures that make up this exhibit.
A. Yeah. I recognize all three as photographs I guess you would call them, 8x10s, that these individuals, Jon Beason, Tavares Gooden and Devin Hester signed and gave to Nevin.
Q. Now, if you notice, each of them are addressed to Little Luke.
A. Right.
Q. Is that Nevin?
A. Yes.
Q. If you know, why was he referred to as Little Luke? Why are players calling him Little Luke, if you know?
A. Yeah.
Q. What's the correlation?
A. Luke or Nevin started that himself, actually calling himself that, because he was comparing his behavior in relationship, in his
mind, I guess, with what was alleged of Luther Campbell back a decade, two decades prior.
Q. And that would be what, of a booster?
A. As a -- I mean I really can't say, because I want to think that was a lot at a time when Luke was doing that stuff, so I can only tell you what I read.
Q. Right. So the correlation was that Luther was a former booster and now Nevin was the new booster?
A. No. With the renegade sort of stigma attached to it. That was the, what people said about Luke, that he was doing things like that, like taking the players out and giving them cash and going to strip clubs. Now, whether that happened I don't know, but that was then Nevin calling himself Little Luke.
Q. Well, during the course of your relationship with Mr. Shapiro and the University of Miami and the people we will refer to as the usual suspects, would it be fair to say that Mr. Shapiro did, in fact, confer various financial benefits on the University of Miami Athletic Program and its players?
****Can't make this stuff up, why does it matter in Bankruptcy if it is related to University of Miami****
A. Can you -- I'm not quite sure what you're asking.
Q. Would it be fair to say that during the course of your relationship with Mr. Shapiro, during that time did he confer a significant
financial benefit on either the University of Miami or its athletes, whether it be basketball or football?
A. -- donated a lot of money there and I think that's proven. And with regards to the student athletes -- what was the term used again?
Q. Did you ever have an opportunity to observe, you know, Mr. Shapiro conferring a financial benefit on any players, whether it be
basketball or football?
A. Yes. Financial benefit, yes.
Q. And would it be fair to say that during the course of your relationship with Mr. Shapiro a lot of the money that you did not keep for yourself, you disbursed to individuals associated with the University of Miami Athletic Program?
A. No, that's not accurate
Q. Would it be fair to say that you disbursed it to, amongst the players for the University of Miami Athletic Program?
A. I don't remember specifics with the checks and transfers that we discussed, but I never remember him specifically writing me a check or transferring money and instructing me to give it to a student athlete, a former athlete, anything of that, in that realm.
Q. So let me ask you this: When you answered my question earlier and you said when I asked you specifically if you ever observed either yourself or a third party in your presence give Jake Morton money on Mr. Shapiro's behalf, your statement was
that you don't remember, but the fact that you don't remember doesn't mean it didn't happen and you're confident when you say that. What is your opinion based on?
A. For that statement?
Q. Um-hum.
A. Because I remember being in the house with Jake and Nevin. That's the only reason why to me I can leave that possibility out there, but I don't remember the money changing hands.
Q. When you were at the house with Jake, with Mr. Morton and Mr. Shapiro at the time it may have happened but you're not sure, who else was present?
A. I remember it just being the three of us, but there could have been somebody else somewhere, but it was the three of us where his pool table was.
Q. Now, what is it about Nevin being at his house together with Morton and yourself, that refreshes your recollection as to the money? Why do you feel like that memory --
A. It doesn't refresh my recollection with money. I'm just saying I remember being there with Nevin and Coach Morton. As I said before, to be quite frank, the only reason I really even knew about this initially was because I read it in the Yahoo story.
Q. But you hung out -- I mean I've shown you pictures. There's multiple times when you've been in the presence of Mr. Morton, Mr. Haith and Mr.Shapiro, correct?
------------------------------
Q. Okay. Let me show you what's been marked for identification as Composite Exhibit Number 15. I want you to tell me if you recognize it and what it is.
A. It's really difficult to see some of these. I can't make out who all the person is on the left. I can't see who the person is second to
left, but then it's DJ Williams. In front of him is Nevin. In the middle is Kellen Winslow. I don't know who the person is with his hand over Kellen's shoulder, and I can't make out who the person to the far right is, and then the person with the white sleeveless shirt, I don't know who that is.
Q. Okay. Did you ever have an opportunity to observe any financial transactions between Nevin and any of the individuals that you can identify in this picture?
A. Again, by financial transactions, that just means cash or --
Q. Either money or gifts.
A. Gifts or entertainment.
Q. Entertainment --
A. Yes. Entertainment, yes. Kellen and DJ which were the only two I can identify, both -- it looks like this picture is even on the boat. We'd go on the boat. There would normally be food and drinks on the boat. They would go out to the club occasionally with Nevin.
Q. Did you ever attend any activities on the boat?
***IRRELEVANT FOR BANKRUPTCY***
A. Yeah. I went on the boat ten times, a dozen times.
Q. And on those occasions what was the, what would occur? What was the activity?
A. It was either he was just bringing somebody over to see the boat, and we were just sitting there and kind of talk and hang out, you know, just for him to show people the boat. Then when we would go out -- I mean I think the only times I ever went out, there were athletes on the boat and, like I said, there would be, you know, alcohol, there would be food. Sometimes guys would bring their
girlfriends or Nevin's girlfriend at the time, whoever it may have been would be there, go jetskiing. That was the popular thing, was the jetskiing.
Q. Okay. And in those events was there alcohol and food served?
A. Yes.
Q. If you know, was Mr. Shapiro the one that was paying for all that?
A. I don't -- I mean I don't know. It wasn't anything fancy. I don't know.
Q. It was just on a yacht?
A. No, no. I'm talking about the food Because I remember he would have somebody go pick up stuff from Publix.
Q. Okay.
A. But I don't know if he paid for it --
Q. Okay.
A. -- or whoever picked it up paid for it.
Q. Now, do you know an individual by the name Drew Rosenhaus?
A. Can you be more specific in how you want me to say if I know him?
Q. Do you know him? Do you know him in any way?
A. I know who he is and I believe he knows who I am, but we don't really have a relationship, if that makes sense.
Q. Did you have the same kind of relationship that you had with Mr. Shapiro, with Mr. Rosenhaus with regards to players?
A. No.
Q. Did you ever give any money to any of the players at the University of Miami on behalf of Mr. Rosenhaus?
***WHERE DID THIS BS COME FROM*****
A. No.
Q. Did you ever give any money to any players at the University of Miami at the direction of any of Mr. Rosenhaus' agents or affiliates?
A. No.
Q. Did you ever work together with any football coach at the University of Miami to create any non-profit --
***IS SHE CONCERNED ABOUT OUR TAX LIABILITY***
A. Oh, I discussed with Corey Bell who was the director of football operations at the University of Miami for the football, obviously for
the football team, about reorganizing Randy Shannon's football camp as a non-profit, but we really never did anything about it.
Q. What was the purpose of that though, just to do that?
A. At the time it seemed like it may have met, may have made more sense as a structure, but like I said, it was -- I don't know. To be honest with you it was kind of stupid.
Q. Was Mr. Shapiro involved in that financially?
A. No. I didn't even know he knew about that.
Q. To the best of your knowledge Mr. Shapiro did not give any money to that project?
A. You know, are we talking about the same thing here?
Q. Yeah. Well, I'm hoping. I'm asking a question, you're giving me an answer. So I'm just --
A. If we're talking about what I'm talking about, then not that I'm aware of.
Q. Okay. Well, did you ever try to open a non-profit on more than one occasion where this only occurred one time?
A. A non-profit, yes. And we never even got even near the point of trying to open it.
Q. Okay. Now, just to be clear, when you were employed or associated with Access Sports, which players did you recruit for Access?
***THIS IS A LOT FUN THIS PART***
A. It would be --
Q. Because you gave me a list, but --
A. Right, right. That's why I'm --
Q. Would Jon Beason be one of them?
A. Jon Beason would be one.
Q. Would Devin Hester be another one?
A. Yes.
Q. Would Tavares Gooden be another one?
A. Yes.
Q. Would Frank Gore be another one?
A. Yes.
Q. Roger McIntosh?
A. Yes.
Q. Orion Harris?
A. Yes.
Q. Kyle Wright?
A. Yes.
Q. Tyrone Moss?
A. Yes.
Q. Is there anyone that I'm missing?
A. Not that comes to mind.
Q. In your presence did you ever observe any financial transactions between Mr. Shapiro and any of these individuals?
***BECAUSE WE ONLY CARE ABOUT MIAMI PLAYERS***
A. I vaguely remember Nevin, because this was a long time ago, Nevin giving Tyrone Moss some sort of money for his baby or something like that. It was the first time, I believe, that Tyrone actually met Nevin.
Q. Okay.
A. Because I want to say that I brought Tyrone to the house.
Q. Okay.
A. But again, this was a long time ago and it's kind of fuzzy, but --
Q. Why were you bringing anybody? I mean --
A. It was one of two things. Either Nevin would specifically ask me to bring this player or, you know, through the grapevine a certain player would hear about Nevin and ask me to introduce him to Nevin.
Q. Now, when you were working for the University of Miami did you have an opportunity because of your position, to know beforehand, before a game, if any player was injured or was not going to play, did you have access to that kind of information?
****ARE WE SHAVING POINTS? THROWING GAMES? HOW IS THIS RELEVANT?***
A. I mean I would probably notice it at practice, if a guy wasn't practicing or anything like that. I mean I didn't have specific injury
reports, but --
Q. But you would have to access to that information --
A. I could see who was not practicing.
Q. And did you ever provide that kind of information to Mr. Shapiro before a game?
A. I don't think so. He never asked really about that sort of stuff.