To: scion who wrote (574 ) 10/25/2002 7:39:53 PM From: scion Read Replies (1) | Respond to of 1136 The continuing saga – Part 21 Reformatted for easier reading – errors in the ‘original’ have not been corrected. Q Directing your attention to paragraph -- excuse me, page 7. I'm looking at the second paragraph first full paragraph on page 7 of 67 of exhibit 13, and the second line, the sentence begins: Richard Marchese according to one of the two social security members he is associated with, is an A.K.A. of Susan L. Nicolini, N-I-C-O-L-I-N-I, can you -- strike that. What evidence do you have that Mr. Richard Marchese has two social security numbers? A I didn't say two. He has -- he's associated to multiple social security numbers and that comes from a background I paid a P.I. to run. Q What do you mean associated with two social security numbers? A His name is associated to multi social security numbers and aliases. Q I don't understand what you mean by the term associated. Can you define for me how you use the term "associated" in this sentence? A Just other than what's in websters I can't think of anything else. Q You use this word, sir. I want you to tell me how someone is associated with -- with a social security number? A Both their names are associated to that social security number. Q That means he has two social security number or does it mean something else? A It means his name is associated -- according to one of two numbers social security number is associated with -- Q You can't define any further how you used the term associated in the context of this sentence? A No. It's pretty clear. Q So, what, he -- he knows somebody with the social security number that you're referring to? Is that associated with a social security number? A Associated -- his name as well as another name is associated to the same social security number. Q That is it is a -- it is assigned to him that social security number you're talking about was given by the social security administration to Mr. Marchese. Is that what you mean by associated? A According to one of the two social security numbers he's associated with his an A.K.A. as Susan L. Nicolini. In other words Richard Marchese's name is associated to -- as an A.K.A. of Susan L. Nicolini. Q So my question is: When you say associated are you saying that the social security administration has assigned him two different social 24 security numbers to Mr. Marchese? A I'm saying on a paid-for P.I. background the Richard Marchese is an A.K.A. of a Susan L. Nicolini, is associated to the same social security number. Q What do you mean he's an AKA of Susan L. Nicolini? A As known as. Q You're saying Mr. Marchese has used the name Susan Nicolini? A No what I said is Richard Marchese according to to one of the two social security numbers he's associated is an A.K.A. of Susan L. Nicolini. Q And you can't elaborate on that statement any more than you have? A I think it's pretty clear. Q What evidence do you have to support that statement? A A background I paid for by a licensed private investigator. Q Do you have any documents that would support that statement? A Just what I have from the P.I. Q Have you turned those over to your counsel? A I think they're on my computer in Bob's inspection but I'm not sure. Q So you would possibly have documents regarding this issue? A If I have it -- if it hasn't been turned over, I would be happy to give it to you. Q Okay. I believe that would be responsive to -- to this -- to the previous requests and if it has not been turned over I'm requesting that they be turned over immediately and reserve the right to reexamine you regarding these documents. A No problem. Q I want to direct your attention to page 50 of this document. Do you -- by the way do you -- Mr. Marchese to be a part of -- of this new world order that you discuss in this -- in this document? A I'm -- I'm just doing research trying to find out everything that's going on out there. You know, I have no conclusion, until I finish the book. Q Okay. My question is: -- okay. Do you believe that Mr. Marchese is a part of this new world order? A I believe I told you I'm still conducting research. The book finished yet. Q So you have no belief either way as to whether Mr. Marchese is participating in this new world order which you describe in exhibit 13? A Well, now here to talk about my belief, but -- I mean, my belief is note relevant to litigation of this lawsuit. Q Well, throughout this document, what you say is a metaphor for the new world order, you discuss Mr. Marchese on repeated occasions, do you not? A Do I -- pardon me. Can you say that again. Q There are repeated references in this document to Mr. Marchese, are there not? A Sure. Q And this document, as you said is a discussion or metaphor for the new world order. A Mr. Marchese's a high-profile stock scofflaw so, of course there are a lot of things in here about Richard Marchese because that's the focus of my research. MR. ARGENTAR: So Mr. Marchese is the focus of the research. A No. Q Which sees itself as -- manifests itself in this document? A That's not what I said Mr. Argentar. I said that Richard Marchese is a notorious penny stock scofflaw. He's a public figure. Been in the papers all the times. Has dealings with power securities, barred from the securities industry, been indicted for money laundering. He plays a role on the Internet. If you go to the Internet right now, you will see his employee probably having a conversation with me right now. So, yes, Mr. Marchese is a high-profile figure in the -- in this paradigm. Q Which is -- which you've referred to as the new world order? A If we're referring in the context of what's in here, I -- I told you earlier what -- what I used the term new world order for and how I use it.