Free Response to Motion - District Court of Federal Claims - federal

Case 1:06-cv-00407-ECH

Document 75-8

Filed 10/15/2007

Page 1 of 7

(ÒfP)f
2 IN THE UNITED STATES COURT OF FEDERAL CLAIMS

1

3 No. 06-407T
4 (into which have been consolidated Nos. 06-408T,

5 06-409T, 06-410T, 06-411T, 06-810T, 06-811T)
6

-----x

7 ALPHA I, L. P., by and through

8 ROBERT SANDS, a notice partner,

10 -vs13
14

9

Plaintiff

) Case No. 06-407T

11 THE UNITED STATES,

12 Defendant

--------------x

15 Deposi tion of RICHARD SANDS taken pursuant to
16 notice at Constellation Brands, 370 Woodcliff Drive,

17 Suite 300, Fairport, New York on Tuesday, June 12, 2007

18 commencing at 9: 30 a.m.
19

20 Reported by:
21 COMPUTER REPORTING SERVICE

22 Amy M. Condon, CSR, RPR
23 270 Reynolds Arcade Building

24 16 East Main Street
25 Rochester, New York 14614
~ GOVERNMENT
EXHIBIT

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COMPUTER REPORTING SERVICE

I

APP-A-00037

Case 1:06-cv-00407-ECH
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A. Yes. 2 Management Corp? 6 A. Yes. 7 trust? 9
Document 75-8
17
R. Sands - Examination by Ms. Johns

Filed 10/15/2007
your memory.

Page 2 of 7

R. Sands - Examination by Ms. Johns

IS

Q. What does it do today? 3
Q. And are you one of

Q. Let me show you something that may refresh

A. It I believe is an investor in Alpha today. 4

A. I don't know what it means to be familiar
with an LLC. Q. Well, let's start this way. I'll show you this letter, and Tom, do you want to go ahead and pull
it out and we'll mark it. This has a government exhibit on it it because it

the shareholders ofRRM&C 5

Q. Are you familiar with the Marvin Sands master 8

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A. Yes. 10 A. Yes. 12
Q. And are you a trustee of that trust? 11
Q. We mentioned before the trust created for the 13

was attached to our MSJ and we'll mark it Exhibit 1 for
the deposition.
(v. S. Exhibit No. 1 - letter - marked for

identification.
BY MS. ,JOHNS:

benefit of Andrew Stern, Zachary Stern and Abby Stern. 14

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them, do ayouofknow? 16 A. I believe I'm trustee all of them, but I 17
Q. Okay. I think that's all the entities, 19
except for the charitable remainder trusts that we'll 20

Are you a trustee of any of those trusts, all of 15

Q. This is a letter dated March 29th, 2001
addressed to you from someone named Chet Decker. Do you recall -- do you want to take a minute to
look at this letter?

could be incorrect. 18

MR. JONES: I'll note for the record this
isn't a signed copy, and you said it comes from your

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talk about later on. 21
Heritage Organization, LLC? 23
A. I'm uncertain as to really what your question 24

fies?
MS. JOHNS: I think it does, yeah. MR. JONES: So it's an unsigned perhaps draft
of a letter.

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BY MS. JOHNS:

Now, are you familiar with an entity called The 22

THE WITNESS: Okay.
COMPUTER REPORTING SERVICE

COMPUTER REPORTING SERVICE

R. Sands - Examination by Ms. Johns

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R. Sands - Examination by Ms Johns

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correct - incorrect.

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Q. Do you recall this letter? A. No. Q. Do you recall receiving it? A. No. Q. Do you think this is the first time you've seen it or do you think you might have seen it back in March of2001 or you just don't '"emember it?

Q. At what point did you decide you wanted to

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actually have a face to face meeting with Heritage?

A. I never decided that.
Q. Okay. Did you -- let me ask this: Did you
ever have a face to face meeting with Heritage'!

A. Yes. I was involved in a face to face
meeting with Heritage. Q. And when was that meeting'!
A. I don't remember.

A. From reading the first paragraph it looks to
me as if

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this is a follow-up to cold calls that

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Heritage placed to me.

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Q. Okay.

Q. Was it in 2001? A. I would suspect so.
Q. Okay. How many face to face meetings with
Heritage did you have?

A. Which I receive thousands of.
Q. SO let's start from your very first interaction with The Heritage Organization. You said you got some cold calls?

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A. I don't recalL.
Q. Now, you said that the cold calls -- at somc
point the cold calls --

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A. I got a cold call.
Q. Do you remember when that was? Just
generally. I don't need an exact date.

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A. Call.
Q. Cold call? A. Potential call.
Q. Became a face to face meeting. Who made that
decision to finally say, okay, let's meet with Heritage?

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A. Early 2001.

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Q.
A.

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Q.
A.

Okay. What did they say on the call? I don't remember to be quite honest. And how many times did they call you? I think once, twice maybe. Again, I could be

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A. My brother.
COMPUTER REPORTING SERVICE

COMPUTER REPORT ING SERVICE

APP-A-00038

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Document 75-8
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Filed 10/15/2007
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R. Sands - Examination by Ms. Johns

R. Sands - Examination by Ms. Johns

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Q. Robert?

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A. Uhm-uhm. Q. In that first face to face meeting, was it here?

Q. Now, how many - I don't think I asked you this already, but how many face to face meetings with Heritage did you have?

A. No idea, I don't recall.
Q. And you don't ever remember traveling to Dallas to meet with Heritage?

A. I don't recall.
Q. Do you remember flying to Dallas for the meeting?

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A. I don't recall traveling to Dallas to meet
with Heritage.

A. I don't recall.
Q. Okay. Who was at this first face to face
meeting with Heritage?

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Q. At this first meeting that we talked about,
this first face to face meeting with Heritage in 2001, what was discussed?

It
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A. I really don't recall specifically anyone,
but I believe Gary Kornman was certainly there, but I could be incorrect.
Q. SO the only person from the Heritage side you

A. I don't recall. I don't recall any specifics
of any meetings.

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remember being there was Gary?

Q. Okay. Would reviewing this letter refresh your memory at all about maybe what was discussed at
the meeting?

A. That's not what I said. I said I don't
recall at all who was there. MR. JONES: Let me advise the witness that you should not speculate on answering the questions. THE WITNESS: Very good. I don't recall who
was there.
BY MS. JOHNS:

A. Not one bit.
Q. Can you say today why Heritage -- why would Heritage contact you, why would they make a cold call
to you, do you know?
A. I can't speculate about why they would do

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Q. Who from your family was at the meeting?

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A. I don't recall.
COMPUTER REPORTING SERVICE

anything. Q. Do you know why Robert finally agreed to meet with Heritage?

COMPUTER REPORTING SERVICE

R. Sands - Examination by Ms. Johns

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R. Sands - Examination by Ms. Johns

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A. Yes.
Q. Why was that?

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family A. We had discussed a potential sale of owned Constellation stock along with some estate planning and philanthropic plans along with certain uncertainties that we would face once we started the process of sellng family stock. And I told Rob as I believe, okay -- this is really reconstruction - of the fact that this group had called me and talked about similar things. That's what I believe, but that may
not be precise. That's the connection.

as Exhibit 1 states in the fourth paragraph entitled capital gains, it says, we offer strategies that can eliminate the total tax liabilty on capital gains. Was one of your goals to eliminate the total tax
liabilty on capital gains?

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MR. JONES: I'm going to object to the form of the question only because you refer to this as a letter. It's an unsigned copy of something and it hasn't been established that it was sent or received. So 1 object to the characterization that it's a letter. It's not supported by the record. You can
answer the question if you understood it.

Q. Okay. In your meeting with Heritage and in
the time leading up to the implementation of

these

THE WITNESS: Could you repeat the question
BY MS. JOHNS:

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transactions, what were your goals for the transactions
that are at issue in this litigation?

Q. This letter states that Heritage offers
strategies that can eliminate the total tax liability
on capital gains.

A. One, to make a profit; two, to diversify our
holdings which were very concentrated in Constellation

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stock. These are not in order of priority necessarily. Three, to do some estate planning work; four, to provide for the philanthropic needs that we would be
having at the time and in the future. 1 think that's

Was one of the these goals on these transactions to
eliminate the total tax liabilty on capital gains with

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respect to the sale of the Constellation stock?

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basically, you know, a basic family business plan or
financial plan you would calL.

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A. The question is not clear to me. If the
question is -- was it the goal to eliminate totally capital gains tax?

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Q. Now, this letter I've shown you that I marked

Q. Right. Well, that's-COMPUTER REPORTING SERVICE

COMPUTER REPORTING SERVICE

APP-A-00039

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Document 75-8
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Filed 10/15/2007
A. Yes.

Page 4 of 7
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R. Sands - Examination by Ms. Johns

R. Sands - Examination by Ms Johns

A.

No.

Q.

Well, why are you -- why do you disagree with

Q. And do you understand that as a result of the
transactions at issue in this litigation that you pay little to no tax in connection with the sale of the
Constellation stock?

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that?
A. Because it was not a goal to eliminate totally capital gains tax. Okay. Now, before the transactions at issue Q. in this litigation happened, did you know what the tax
effects would have been of an outright sale of your

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A. Yes.
Q. Now, back to the meetings with Heritage. know you say you don't recall much. Let me ask my questions and if you don't recall just say that.
Do you remember whether there were any -- what we

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Constellation stock?
A.

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Yes.

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Q. A. Q. A. Q.
A.

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Can you tell me what that would have been? Normal payment of tax against the gain. SO you understand the concept of basis?
Yeah.
And do you remember what the basis of your

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would call a wipe board presentation at the Heritage meeting, something similar to that?

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A. 1 don't recall.
Q. What about a power point presentation?
A. On a screen?

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Constellation stock was around the year 2001?
No.

Q. Sure.

A. I don't recall.
Q. Other than the two transactions that are at
issue in this litigation, did Heritage advise you
regarding any other sort of strategies or planning

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But was -- do you recall whether the basis of Q. the stock was low relative to the overall value of the stock? A. Oh, yes. you hadn't entered into SO you understood if Q. these transactions you would have had to have paid a capital gains tax on the sale of the stock?

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techniques? A. Yes.

Q. What strategies or planning techniques wei'e
those?

COMPUTER REPORTING SERVICE

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R. Sands - Examination by Ms. Johns

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R. Sands - Examination by Ms. Johns

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We had very, very broad conversations about A. estate planning, family partnerships, inner family loaning, creating trusts, you know, hedging strategies against concerns that we had, noncorrelated investment
strategies to our concentrated position, diversification strategies. Boy, you know,
philanthropic discussions.

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documentation and documentation and implementation. In the other strategies that we're talking about, other
than the two at issue in this litigation, did Hei"itage

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help you with implementation? MR. JONES: I'll object to the question because I think it's confusing. We're talking very broadly, but if you understand the question, please
answer it.

Q. A.

Okay.
1 mean, those are broad topics.

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Q.

That's fine.

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you would rephi"ase th THE WITNESS: Well, if question. Did Heritage implement for us other

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I don't recall specifics in each one of A. those, but vei"), very broad discussions about family financial planning and how familes function. Okay. Other than the two transactions that Q. are at issue in this litigation, did you enter into any of these other Heritage strategies that you just talked about? Did you implement any of these Heritage ideas
or strategies.

strategies?
BY MS. ,JOHNS,

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Q. That's exactly what I'm asking you. You got

it right there. Other than the two at issue in this
litigation.
A. Did Heritage implement through preparing

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A. Q.

Over the long-term, yes. Did you implement those with help of

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documentation or anything of that nature, no. Q. Thank you. Do you recall signing a nondisclosure agreement with Heritage?

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Heritage?

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A. Yes, because I've reviewed it. Q. Okay. What was your understanding of this
nondisclosure agreement?

I don't know what help means. Well, for instance, in these two transactions we know that Heritage helped with preparation of
A.

Q.

A. What was my understanding, you said?

Q. Right.
COMPUTER REPORTING SERVICE

COMPUTER REPORTING SERVICE

APP-A-00040

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Document 75-8
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Filed 10/15/2007
look at.

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R. Sands - Examination by Ms. Johns

R. Sands - Examination by Ms. Johns

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A. I don't recall what my understanding was at

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the time.
Q. Do you have an understanding of

Q. It would be on the third page, Article 7, and
it's 7.3.

that

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agreement now?

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A. Yes.

Q. What is that understanding now? A. That's too far broad of a question for me to
answer. I mean, could you be more specific please?

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A. Okay. Q. EssentiaIly what I was describing before, it appears to be basicaIly a two milion dollar penalty if you reveal the transaction to anyone. Is that what your understanding was?
A. Yes, that's what my understanding is.

Q. From what I recaIl from the agreement you
were I guess forbidden from disclosing it to other individuals. I hate to paraphrase. MR. JONES: I object to the form of the
question. Counsel is testifYing.

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Q. Okay. My question is: Did you ever --

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A. I believe I understood it at the time also. Q. Okay. Did you ever discuss the transactions
with anyone other than Heritage?

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MS. JOHNS: I can show you the agreement if you'd like. That might make things easier. THE WITNESS: Whatever you'd like.
(V. S Exhibit No. 2 - nondisclosure agreement - marked for identification.
BY MS. JOHNS:

A. Yes, other advisors.
Q. Do you know whether they also signed an
agreement similar to this when reviewing the Heritage

strategies?
A. 1 don't know.
Q. I'm going to come back to this agreement, but

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Q. Does this agreement look familar to you?

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A. Yes.
Q. Okay. I don't know if minute to review it. It's kind of

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we'll leave it for the time being. A. Okay.

you want to take a
wordy, but--

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A. Why don't you point out what you'd like me to
COMPUTER REPORTING SERVICE

Q. Now, I think -- I just want to talk about some people with Heritage, and you may have never met them. I don't know. I just want to ask the questions.

COMPUTER REPORTING SERVICE

R. Sands - Examination by Ms. Johns

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R. Sands - Examination by Ms. Johns

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We talked about Gary Kornman. A. Uhm-uhm. I think you said you maybe recaIled meeting Q.
him once?

Q. Do you know someone by the name of Rodney

Johnson?

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A. I don't recaIl.
Q. Other than Gary did you have any other

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A.

Q.
A.

WeIl, I recaIl Gary, yes. How many times did you -I don't know specifically how many times I

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contacts with any Heritage personnel that you can remember?

A. I had contact with other personnel, but i
don't remember who.

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met with him.

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Did you talk to Gary on the telephone? I did. Do you recall approximately how many times Q. you might have spoken with him on the phone?
Q.
A. A.

Q. Okay. Did you ever have a telephone
conversation with Brian Czerwinski?
A. Probably so.

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Q. Do you recall what was discussed in those
conversations?

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No.

Q.
A.

Q.

When was the last time you spoke with Gary? Years and years ago. I don't know. Did you - do you know someone named Ralph

A. I don't.
MR. JONES: Excuse me. Could you spell Czerwinski for us? MS. JOHNS: It's C-z-e-r-w-i-n-s-k-i.

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Canada.
I don't recaIl. He would have been a Heritage employee. No? Q. A. I don't know. I mean, I don't recall. Do you recaIl meeting someone named Brian Q. Czerwinski? A. I recall the name. I do not remember whether I met him or didn't meet him.
A.

MR. JONES: Thank you.
BY MS. JOHNS:

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Q. Did you ever have any discussions with anyone

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regarding Heritage's experience with financial 0'"

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investment matters prior to entering into these transactions?
A. With anyone?

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APP-A-00041

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Document 75-8
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R. Sands - Examination by Ms. Johns

R. Sands - Examination by Ms. Johns

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Like, did you get any references is kind of Q. what I'm referring to. I believe Rob may have. A. But you didn't personally? Q.
A.

memory and I reaIly do. I can't remember anything.

Q. That's fine. 1 just have to ask the
questions.

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No.

A. It's okay. I hope you don't mind the answer. Q. No.
Do you know who primarily dealt with Heritage on behalf of your family? A. Rob.

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At the meeting that you had with Heritage did Q. anyone from Heritage associate these two strategies, the two transactions, with the potential amount of taxes to be saved? A. At the meeting?
Q.
A.

Q. Okay.

The meeting.
The meeting?

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I don't know.

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A. I need to correct that. 1 mean, 1 was present. I dealt with them. I just don't remember anything.
Q. Do you think Robert had more contact with

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Q.

The one face to face meeting that you do

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recaIl having in 2001 A. Wait. I said to you I do not recaIl the specifics of any meetings that I had, but I assume I had meetings and more than one. I ask you any question about Okay. So if Q.
what was discussed at those meetings your answer is

Heritage than you did?

A. I can't speculate.
Q. Okay.
A. I'm withdrawing my answer when I said Rob,

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because I don't know who primarily dealt with them. We both dealt with Heritage.
Q. Do you recaIl whether Andrew Stern ever met
with Heritage or spoke with Heritage on the phone'!

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going to be you don't remember anything; is that correct? A. That is correct. Okay. Q. A. Now -- that is correct. I have a very bad

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A. 1 don't recall whether he ever met with
Heritage or spoke to Heritage. Q. What about your mother Marilyn, do you recaIl

COMPUTER REPORTING SERVICE

COMPUTER RE PORT I NG SERV I CE

R. Sands - Examination by Ms. Johns

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R. Sands - Examination by Ms. Johns

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whether -A. She never met Heritage or spoke to Heritage.

those have great profit potentiaL. And there were many
other investments -- transactions you could say,

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Q. Okay. Like I said, I'm going to ask you
these questions. If

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investment transactions, I really should say that had
profit potentiaL.

you don't remember, that's fine.

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But I have to at least ask them.

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Q. What other investment transactions are you
referring to?

A. It's okay.
Q. At the meeting with Heritage or meetings that

you may have had, did anyone discuss any sort of time line that the strategies would need to generate the results?

A. Buy other stocks, go long on treasuries, go short on treasuries. Q. You don't mean specific to these transactions. Are you talking in general?

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A. I don't recalL. Q. Okay. Was there any discussion about profit
potential from the transactions at the meetings?

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A. Yeah, in general.
Q. I was referring to these two specific
transactions and what kind of profit potential you sa" in these transactions. MR. JONES: \-Vhen you use the word transactio it's unclear to me, I don't know if it's clear to the
witness. It's unclear to me whether you're talking

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A. I believe so in that that was our number one
motive is to make money.
Q. Now, we'i"e talking about the transactions, the first and the second transaction. profit that you believed What were the sources of existed with respect to these transactions?

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A. WeIl, one, I believe we made short sales of
treasuries, highly leveraged short sales of treasuries which can result in a huge return on your investment. We had in the second transaction purchased Yahoo and Corning which as I recall were at all time low. So

about these specific historical transactions included excluding everything else or you're talking about the organizations that conducted those transactions.
There's a built in ambiguity. i know you'i"e doing it in shorthand. I'm not trying to interfere with your

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questioning but there's a built in ambiguity in that question.

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APP-A-00042

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R. Sands - Examination by Ms. Johns

R. Sands - Examination by Ms. Johns

won't mark this as an exhibit.

A. Which is the first?
Q. Yes, the first one. There is really no need
to mark it. This says that the short sale was closed

were somewhere - and I'm just talking about you now one point three milion, and the -- there was
essentially a net loss on the short sales of the

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treasuries between the first and the second set of
partnerships. Would you agree with that? Do you have

and a net loss of $424,000 was recognized.

A. Okay.

any reason to doubt that after what we just looked at!

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Q. Would you agree with that after seeing the
complaint?

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A. I don't have any reason to doubt it. Q. Okay. So let me ask you this: Do you
consider that the fees that you paid to Heritage to be

A. Well, yeah, I guess so.
Q. Okay.

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MR. JONES: The right way to start that
question is do you have any reason to doubt that. THE WITNESS: I have no reason to doubt it.
BY MS. JOHNS:

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high compared to the amount of profit that you earned on these transactions?

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A. I don't look at the fees that way. Q. How do you look at the fees? A. I look at the fees on profit potential, not
on actual.
Q. Can you give me a better explanation of

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Q. And this is the -- let me just clarify for the record, this is the Alpha I, LP complaint and in paragraph 30 it states that the short sales were closed and a gain was recognized of ninety thousand dollars.
Do you have any reason to doubt that?

what

you mean by profit potential?
A. Sure. When you make a highly leveraged

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A. No. Q. And this Alpha transaction was the second set
of

transaction, whether it be a short sale or a purchase especially of treasuries which I think only require
two, three percent margin, small fluctuations in interest can result in millons of dollars of gain.

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partnerships that we've talked about.

A. Okay. Q. SO we mentioned the fees paid to Heritage
COMPUTER REPORTING SERVICE

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Q. Okay. Was that what you were anticipating
would happen here?

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R. Sands - Examination by Ms. Johns

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A. That is what one always desires to happen is
to make a profit. There are no guarantees.

Q. I'm going to ask you this question.
you don't recall, but I have to ask it anyway. A. Okay.
understand if

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Q. Were there other fees that were also
associated with the first set of partnerships and the
second set of partnerships other than the fees you paid

Q. In your meetings with Heritage did you -- did
Heritage discuss with you all the steps necessary to implement the first set of partnerships and the second set of partnerships?

to Heritage? For instance, let me give you some examples, some appraisal fees. Do you recall whether there were any fees related to any appraisals?

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A. Well, I recall that in the first transactions
there were appraisals. So - I don't recall the fee though.

A. I do not recall the specifics of any of the
meeting or meetings. Q. Okay. Do you recall today as we're talking the steps necessary to implement the first set of transactions and the second set of transactions?
A. The steps?

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Q. What about any other legal fees? Do you
recall paying any additional legal fees?

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A. I don't recall any specific fees.
fees I'm talking Q. SO those are the types of about. Can you recall any other fees?

Q. Creation of the partnerships, transfer of the
short sales.
A. I recall from having reviewed, okay, the

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A. I don't i"ecall any other fees. I need to just stop you. I mean, we are a family. We are a
business. We are paying lawyers, accountants, advisors, all the time.

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21

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partnerships we created. MR. JONES: I think we need a more specific question if you have one.
BY MS. JOHNS:

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Q. Okay.

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A. Okay. 1 don't recall specifics to this transaction. It doesn't mean that there weren't
others.

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Q. Well, this is my ultimate question. I'm not sure it's going to be more specific but let me ask it anyway.

COMPUTER REPORTING SERVICE

COMPUTER REPORTING SERVICE

APP-A-00043