MS. MONRO: Document request number 16 requires Amazon to produce documents sufficient to identify each market maker for Amazon stock for the period January 1st, 1996 to the date of your current document production.
THE WITNESS: Okay, we discussed that on the phone and you were going to get those because I have no idea how to do that because I have no idea who the market makers are.
MS. MONRO: For toe record, sir, you have not produced any documents in response to request number 16.
THE WITNESS: Correct. You make it sound bad.
MS. MONRO: No, just for the record I’m trying to establish which documents we have and which we do not. So, just that.
MS. MONRO: Document 17 request -— document request number 17 requires Amazon to produce all correspondence from January 1st. 1966, the date of your document production between AZNT and any market maker.
THE WITNESS: Okay, we don’t have any.
MS. MONRO: There’s no --
THE WITNESS: So no.
MS. MONRO: No. Document request number 18 requires Amazon to produce all contracts, agreements, and understandings between AZNT and any market maker.
THE WITNESS: Okay, we don’t have any.
MS. MONRO: So no contracts, agreements or understandings exist between Amazon and any market maker.
THE WITNESS: No, just the fact that we’re going to be suing then all shortly for shorting our stock.
MS. MONRO: Document request number 19 requires Amazon to produce all promotional documents including but not limited to research reports, recommendations, pro formas, brochures or other documents received, prepared, used or disseminated by AZNT.
Has Amazon produced all such documents?
THE WITNESS: That would be in the catalog, the brochure that we — in previous –
MS. MONRO: That Exhibit Humber 3?
THE WITNESS: Other exhibits, yes, 3 and -- right.
MS. MONRO: For clarification, Exhibit 3 is a catalog. Are you also stating that the brochure also contains information responsive to document request number 19?
THE WITNESS: Right, the brochure, the other book.
MS. MONRO: Clinical studies book?
THE WITNESS: The clinical studies book.
MS. MONRO: Have there been any other research reports, brochures or other such documents disseminated by AZNTT that have not been produced?
THE WITNESS: No.
MS. MONRO: Document request number 20 requires Amazon to produce all draft and final version of press releases from January 1st 1996 to the date of your current production.
Has Amazon produced all such documents?
THE WITNESS: Yes, you have a book there, press release book.
MS. MONRO: Just so we’re clear, make sure we’re talking about the same thing, I’ll ask the Court Reporter to mark this as Exhibit 4.
(SEC Exhibit No. 4 was marked for identification.)
THE WITNESS: I don’t remember it that thick. It grew.
(Witness proffered document.)
MS. MONRO: Mr. Sylver, the Court Reporter has just handed you what’s been marked as Exhibit 4, and it’s Bate stamped 1817 through 1847.
THE WITNESS: Right.
MS. MONRO: Actually, may I have that back for a minute, please?
THE WITNESS: Sure.
MS. MONRO: I think there’s –
THE WITNESS: Okay, that didn’t belong in there.
MS. MONRO: No.
THE WITNESS: That’s one of those SI posts.
MS. MONR0: Is this the -- is Exhibit 4 the press releases that you were referring to as being responsive to document request number 20?
THE WITNESS: Yes.
MS. MONRO: Have there been any other press releases that were issued that were not included in this press release?
THE WITNESS: No,
MS. MONRO: Document request number 20 (sic) requires Amazon to produce all incoming and outgoing correspondence between Amazon and Wellrich.
Has Amazon produced documents in response to document request number 21?
THE WITNESS: Right, we have no letters. There’s just that one letter you got from the attorney.
MS.MONRO: you mentioned one letter that I received from the attorney. Are you referring to what I’m handing you?
THE WITNESS: Yes.
MS. MONRO: That’s a document Bate stamped 1849 to 1850 and we’ll cone back to this later.
THE WITNESS: Okay.
MS. MONRO: This is the only correspondence you have between Amazon and Wellrich?
THE WITNESS: Correct.
MS. MONRO: Are there any other documents that -- are there any other correspondence between Amazon and Wellrich that you haven’t produced for any other reason?
THE WITNESS: No because anything else that we had was in the lawsuit that Tim also got copied. Remember we went - yeah.
MS. MONRO: So are you saying that the lawsuit documents also are responsive to document request number 21?
THE WITNESS: Correct.
MS. MONRO: Is there any other correspondence between Amazon and Wellrich that are not included In the Bate stamp letter 1849 to 1850 and the lawsuit documents that haven’t been produced by Amazon?
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THE WITNESS: No but that’s not to say, because there’s a lot of documents that we’ve -- we had Las Vegas Metropolitan Police Department’s forensic documents examiner find documents that we used in the court case that they forged my signature on and he has written testimony that it’s not my signature. I don’t know if there’s other documents floating around that we had no idea what they are, okay, that’s very possible, but we have already — they’ve already forged my signature on documents.
MS. MONRO: But it is your testimony right now that Amazon does not have any documents, correspondence between Amazon and Wellrich that have not yet been produced.
THE WITNESS: Correct.
MS. MONRO: Document request number 22 requires Amazon to produce all contracts, agreements and understanding between Amazon end Wellrich. Have you produced all such documents?
THE WITNESS: Yes, it’s in the lawsuit papers.
Ms. MONRO: Document request number 23 requires Amazon to produce copies of all pleadings filed by or on behalf of all parties in any judicial, administrative or arbitration proceedings between Amazon and any other person or entity?
THE WITNESS: Yes, Tim Dunn took those to Kinko’s and got them copied.
Ms. MONRO: And how many lawsuits have you produced documents for?
THE WITNESS: The three.
MS. MONRO: Could you list them for me, please?
THE WITNESS: The Andy Mann, the Nextech/Charles Kricfalusi, and the Wellrich.
MS. MONRO: Could you please spell for the Court Reporter each of those three lawsuits?
THE WITNESS: Andy Mann, M-A-N-N. Kricfalusi, now you’ve got me. Do you want me to call out to the office?
MS. MONRO: I can do it.
THE WITNESS: K-R-I-I-C --.
MS. MONRO: K-R-I-C –
THE WITNESS: -- F-A-L --
MS. MONRO: U-S-I.
THE WITNESS: -- S-I --. Something like that.
MS. MONRO: Could you please spell Nextech. too?
THE WITNESS: Oh, it’s N-E-X-T-E-C. N-E-X-T-E-C. (sic) Now that’s something we need to - we’ll get into that, right, later.
MS: MONRO: And Wellrich is W-E-L-L-R-I-C-H.
THE WITNESS: There’s a lot of Wellrich’s I’ve found out, Wellrich and company, Wellrich Associates.
MS MONRO: Document request number 24 requires Amazon to produce all pro forma and other financial documents relied on by AZNT to support statements made by AZNT in press releases issued from January 1st, 1996 through the date of your production regarding AZNT’s projected revenues and earnings.
Has Amazon produced all such documents in its possession, custody or control?
THE WITNESS: Yes.
MS. MONRO: And which documents did it produce?
THE WITNESS: Okay, those would be the press releases that explain about the shorting and what they were doing and what it caused and on thee Web site, too, with the Wall Street Journal article, interactive and the Las Vegas Sun article.
MS.MONRO: Sir, have you produced documents supporting projected revenues and earnings made by Amazon in press releases and Web sites? –
THE WITNESS: Yes.
MS. MONRO: And which documents are those?
THE WITNESS: In the press release book, the Wall Street Journal, what’s it called, the Wall Street Journal newspaper article, and the Las Vegas Sun newspaper article that’s on the Web site, our Web site. It explains the reason that things didn’t happen the way they were supposed to happen.
MS. MONRO: Why don’t you give us the dates of the Wall Street Journal article?
THE WITNESS: Oh. let’s see, It had to be — I think it was in late June or early July.
MS. MONRO: Of 1999?
THE WITNESS: ‘9, yeah. And the Las Vegas Sun, I don’t have, know the day off-hand but it’s right on the front page of our Web site.
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MS. MONRO: Okay, just so we’re clear, I’ve asked you for pro formas and financial documents relied on to support projected revenues and you are —
THE WITNESS: Oh, oh, oh, I ‘m all, mixed up. Yes, we have those in those Kinko documents. Okay, I’m sorry, I’m thinking about — forget everything we said, it didn’t make any sense.
MS. MONRO: So you produced all supporting documents?
THE WITNESS: Right.
MS. MONRO: Today?
THE WITNESS: Yes.
.
MS. MONRO: Document request number 25 requires Amazon to produce for each bank, savings and loan or other institution accounts in AZNT’s name or for its benefit certain documents, listed A through C.
Has Amazon produced all such documents?
THE WITNESS: Yes.
MS. MONRO: And when did Amazon produce the documents?
THE WITNESS: Thursday or whenever Kinko’s came and picked up the box. They were at Kinko’s.
MS. MONRO: So the documents that are in boxes here at the U.S. Attorney’s office contain the required documents in number 25.
THE WITNESS: Correct.
MS. MONRO: Has Amazon produced an documents required in document request number 26?
THE WITNESS: That’s the same as 25.
.
MR. MACPHAIL: Let me read it for you.
THE WITNESS: Yeah.
MS. MONRO: For each bank, savings and loan, and other financial institution accounts used or controlled by Michael Sylver, produce the following for the period January 1st, 1996 to the date of your document production.
Now, these documents in document request number 26 require banking information for accounts controlled by you as opposed to accounts controlled by Amazon Natural Treasures.
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