THE WITNESS: Oh, okay, I don’t have a bank account. I don’t have any money to put in the bank. I wish I did.
MS. MONRO: Have you had a bank account - since January 1st, t996, you have had no personal banking account?
THE WITNESS: Correct.
MS. MONRO: Have you had control over any bank account in the name of another person or entity?
THE WITNESS: No.
MS. MONRO: Document request number 27 requires Amazon to produce all documents relating or referring to AZNT’s attempts to raise capital.
Has Amazon produced all such documents in its possession, custody or control?
THE WITNESS: Yes.
MS. MONRO: And when were those documents produced?
THE WITNESS: That was mailed to you, the private placement memorandum.
MS. MONRO: Is the private placement memorandum the only document responsive to document request number 27 that Amazon has?
THE WITNESS: Yes
MS. MONRO: Document request number 29 requires Amazon to produce all inventory logs or other documents or records listing or referring to the periodic inventory of Amazon’ s products from January 1st, 1996 to the date of your document production.
Has Amazon produced all such documents in its possession, custody or control?
THE WITNESS: Yes, and they’re in the Kinko’s boxes.
MS. MONRO: Has Amazon produced all corporate organizational charts as required by document request number 29?
THE WITNESS: We don’t have any. And we did but they’re gone. They went with - which Mike wants to get into later with the shorters and everything.
MS.MONRO: At one point in tine you had corporate organizational charts?
THE WITNESS: Yeah.
MS. MONRO: What did they look like?
THE WITNESS: You know like a, they had chairman of the board, president. They had each of the officers and the salesmen, and you know, the general managers on down to the different departments.
.
MS. MONRO: Was this kept in a computer file or was it –
THE WITNESS: Yes, computer file.
MS. MONRO: Document request number 30 requires Amazon to produce accounting and finance policies and procedures manual, including but not limited to policies, procedures, forms and internal controls in place.
THE WITNESS: Okay, we have that in the Kinko’s documents.
MS. MONRO: Document request number 31 requires Amazon to produce all unaudited, audited, compiled or otherwise prepares financial statements for certain years.
Has Amazon produced all such documents?
THE WITNESS: Yes, they’re in the Kinko’s boxes.
MS. MONRO: Document request 33 requires Amazon to produce periodic budgeted versus actual income statements.
Has Amazon --
THE WITNESS: They’re in the Kinko’s boxes.
MS. MONRO: Document request number 34 requires Amazon to produce five—year projected financial statements.
Has Amazon produced those?
THE WITNESS: In the Kinko’s boxes.
MS. MONRO: Has Amazon produced all documents required by document number 34?
THE WITNESS: In the Kinko’s boxes. That’s easy.
MS. MONRO: Document request number 35 requires Amazon to produce all sales journals and other similar documents.
THE WITNESS: In the Kinko’s boxes.
MS. MONRO: Document request number 36 requires all Amazon product and service pricing sheets.
THE WITNESS: In Exhibit 3.
MS. MONRO: Document 36 requires all invoices or statements generated by AZNT.
Has Amazon produced all such documents?
THE WITNESS: In the Kinko’s boxes.
MS. MONRO: Did you also produce some documents to me by mail that contained invoices?
THE WITNESS: I don’t recall. Did you get them?
MS. MONRO: I believe so.
THE WITNESS: Okay.
MS. MONRO: We’ll go through those later.
THE WITHESS: Okay.
MS. MONRO: Has Amazon produced all tax returns and related forms?
THE WITNESS: In the Kinko’s boxes.
MS. MONRO: Has Amazon produced all documents requested In document number 39, including forms W—2, forms 1099?
THE WITNESS: In the Kinko’s boxes.
MS. MONRO: Number 40 requires Amazon to produce documents sufficient to identify all current and former AZNT directors, officers, accountants, sales representatives and other employees and agents.
Has Amazon produced all such documents?
THE WITNESS: Yes. We gave those to Tim Dunn.
MS. MONRO: And what did these documents consist of?
THE WITNESS: It was -- he wanted a list of the names, addresses and telephone numbers of all the people and what they did.
MS. MONRO: All which people?
THE WITNESS: All the employees. Yes, that’s it.
MS. MONRO: Okay, when you say, ‘that’s it’, you’re referring to a document I’m holding in my hand that’s been Bate stamped 4321.
THE WITNESS: Yeah, that’s It.
MS. MONRO: I’m going to mark it as Exhibit 5.
(SEC Exhibit No.5 was marked for identification)
MS. MONRO: I’m handing you what’s been marked as Exhibit 5. Can you identify this for me, please?
(Witness proffered document,)
THE WITNESS: This is the list that was made for Tim Dunn.
MS. MONRO: And what does it contain?
THE WITNESS: Employees’ names,
MS. MONRO: Are these current or former employees?
THE WITNESS: Current.
MS. MONRO: Document request number 40 requires information pertaining to former directors, officers, employees, et cetera.
Has Amazon produced those documents?
THE WITNESS: Well, everything is the same except former employees. Oh, okay, we didn’t do that. I’ll have to do that. I can get a list.
MS. MONRO: Okay.
THE WITNESS: Okay? Do you want me to have her start working on it now?
MS. MONRO: You could do it later, that’s fine.
THE WITNESS: Okay.
MS. MONRO: I’m going to take that back.
THE WITNESS: How did we miss that?
MS. MONRO: It’s a long question. Document request number 42 requires Amazon to produce charts of accounts in use at any time during the period covered by this document request.
Has Amazon produced –
THE WITNESS: In the Kinko’s boxes.
MS.MONRO: 42 requires documents relating to or concerning communications or contact with any broker/dealer, investment banker or financial analyst.
Has Amazon produced such documents?
THE WITNESS: They’re in the lawsuit, the Andy Mann lawsuit. Did I send it to you separately also? I don’t recall.
MS. MONRO: Sir, which documents would be reflective of communications with any broker/dealer, investment banker or financial analyst?
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