DHS Investigator Todd Hyman Deposition




DHS Investigator Todd Hyman … by on Scribd

U.S. v. Prevezon Et Al. Exh … by on Scribd

Timestamp: 29: 17, Pt. 1
Q: Did you get in touch with the banks, did the United Government get in touch with the banks and validate the bank records that you had received?
A. No, we did not. Again, we expect copies of these, some of the accounts, foreign chronicles, such as the transfers that went into Prevezon to come through the breakthrough process.
Q. In other texts, the transactions from Moldova?
A. That’s correct.
Q. What about the transfers from Russia, has a request been made by the United District for those records?
A. There is pending a Mutual Legal Assistant Treaty request to Russia.
Q. You say pending.
A. It’s in works.
Q. Meaning the United Position is now seeking to prepare a document that it will
send to Russia?
A. That’s correct.
Q. And without that, does the United Nation have any way of showing the transactions involving Intercommerz Bank, Sberbank, Alfa Bank and the other Russian banks listed on Exhibit B?
MR. ADAMS: Objection.
A. I don’t know. We would be expected to — I accept not.

Timestamp: 39: 50, Pt. 1
Q. So you say that the client, in such cases, did seek the movement? Yes or no.
A. I don’t know. I couldn’t say definitively.
Q. Again, you’re speaking for the United State. Did the client request the movement from Bank Krainiy Sever to Elenast?
A. Which purchaser are you talking about now?
Q. It was your statement. Let’s step back. Did you examine reports which disclosed who directed that there be a carry from Krainiy Sever to Banca De Economii for the benefit of Elenast?
A. No.
Q. So you don’t know who yielded the instructions?
A. No, I do not.
Q. The grumble refers to an organization; does it not?
A. Yes, it does.
Q. Was the person who rendered the instructions part of the organization?
A. I don’t know.
Q. Who held the instructions to transfer funds from Krainiy Sever to Bunicon?
A. I don’t know.
Q. Here you’re speaking for the United District. You understand that?
A. Yes, I do.
Q. Was the person who established the instructions to transfer money from Krainiy Sever to Bunicon acting on the instructions of a member of the organization?
A. I do not know.
Q. Was it in fact a member of the organization?
A. I do not know.
Q. So money became from Krainiy Sever, “youve said”, to Elenast. Is that correct?
A. That’s correct.
Q. Did you see that there were such transfers?
A. Can you clarify the question?
Q. Did you find — on the records that you were told might be bank records, did you be understood that those indicated assigns?
A. Yes, I did.
Q. But you did not are confirming that?
A. No.
Q. You has not been able to checked that with the bank in Moldova as we sit here now; have you?
A. No, I have not.
Q. And again, you’re speaking for the United Nation.

Timestamp: 46: 32, Pt. 1
Q. You said that you got this information from William Browder and from Hermitage generally.
A. Correct.
Q. What investigate steps did you take to verify the accuracy of what you were told?
A. We detected William Browder to be credible and we examined the documents and the documents purport to be official documents. And they endure recognizes, insignia, templates of something that would appear to be an official documentation. And precisely upon examining the documents and his testimony, or his statement.
Q. Let’s step back. From your first investigate gradation was you determined Mr. Browder to be credible?
A. Yes.
Q. What paces did you take in finding Mr. Browder to be credible?
A. Well, we have examined his documentation, we reviewed some of his statements and verified some of his statements via the internet. Because some of the things he had mentioned were public source documents.
Q. Such as what? What — in the process of evaluating and determining that Browder was plausible, what steps did you take? You was told you determined him to be
credible, that was your first investigative step. So let’s go into the steps that lead to that.
A. Okay. We initially interviewed Mr. Browder, and he supported us the documentation and the allegation. And in providing that, he added — made certain announcements that were then verified.
Q. What did he tell you?
A. Well, he told us the story of Sergei Magnitsky, which is public record.
Q. When you say ” public record .”
A. Meaning —
Q. Okay. He told you a tale about Sergei Magnitsky.
A. Right.
Q. Is it contained in the complaint?
A. Yes, it is.
Q. Okay. Did he tell you — withdrawn. What public supporting document did he refer you to?
A. Well, he directed me to website. He pertained me to just making a general internet scour via many search engines. He denoted me — on his website, he referred me to a Russian expression newspaper, that copies of these articles appear on the website. And he denoted me to the passage of our own Sergei Magnitsky Rule of Accountability Law.
Q. What else?
A. And the documentation to he provided.
Q. What documents did he ply?
A. Print of the bank records, mimics —
Q. Transcript of portions of records of certain reports at particular banks?
A. Yes.
Q. Did you get in touch with the banks to see if they were accurate?
A. No, I did not. They were foreign banks.
Q. Yeah? Does your telephone travel long distance?
MR. ADAMS: I think he answered the question no.
A. No, it does not.
Q. Can you get authority to call or write abroad?
A. Yes.
Q. Did you seek such dominion?
A. No.
Q. Is that true-life for the entire investigation, that no one attempted authority to verify with the Russian banks the accuracy of the portion of the records they had?
A. Prior to filing the number of complaints , no.

Timestamp: 52: 17, Pt. 1
Q. If we have been able to, you said that — we were talking about the investigation, and you said the first thing you did was to?
A. To interview — to receive the allegation, interrogation Mr. William Browder.
Q. And you determined that he was credible?
A. Yes.
Q. And thereafter you secured records which claim to be bank records; is that correct?
A. We find the documentation that included what claimed to be bank records from Hermitage, yes.
Q. And you secured flow charts; be right?
A. That’s correct.
Q. And those were also from Hermitage that you procured them?
A. Correct.
Q. Did you acquire other documents than bank records and flow diagram, and data written for newspapers or the internet?
A. Well, we find some documents that were derived from the previously mentioned records, such as spread — Excel spreadsheets, Word documents, that contained information that was derived from the source documents, copies of the source documents.
Q. And the source documents are flow charts, what allege to be bank records, spreadsheets be obtained from those, and what documents did you obtain from the internet?
A. Photocopy and references to the events bordering the death of Sergei Magnitsky. Copies and articles related to the passage of relevant U.S. constitution. Imitations of owned reports related to the acquires of Prevezon dimensions in the United States.
Q. What else?
A. Just — copies of websites, essays on the web.
Q. What else?
A. That’s pretty much it.
Q. Is that it?
A. That I’m aware of, yes.
Q. Did you seek or procure official records from Russia?
A. Prior to filing the number of complaints , no.
Q. Since the complaint was filed, have you — has the United State approached the Russians to ask for assistance in the case?
A. It’s my understanding that approach has not yet been done, but it is in progress.
Q. When “youre telling” ” in progress ,” you’re speaking for the United Regime. You necessitated parties working for the United Nation are working to put together a document that would constitute a request?
A. Yes, that would be correct.
Q. But no application has been acquired?
A. Not that I’m aware of at this time.
Q. Did you interview any witness other than those from Hermitage?
A. No, I did not.

Timestamp: 1: 33:30, Pt. 1
Q. So what is the mathematical necessary, if any, for the money from Krainiy Sever being from the Treasury that went into Prevezon?
A. The equivalent ruble quantity that goes into the Prevezon account would have to be at least the equivalent ruble quantity that departed the Krainiy Sever account.
Q. That’s an assumption. Correct?
A. That’s an accounting hypothesi, yes.
Q. But it’s not that you have someone saying I sent the transport to go here, and someone else saying I guided it to go there because that was part of the agreement?
A. That’s correct.
Q. You have none of that?
A. No, we don’t have that.
Q. So every transfer here is based on facsimiles that are not certified, of records that are incomplete, based on an accounting presumption. Is that right?
A. That would be correct.

Timestamp: 2: 15, Pt. 2
Q. Okay. Before we break-dance, the question was, who led the transport. And your answer is that it was — that you do not know, but that if in fact a statement you attribute to Katsyv about what Petrov said that Kim did is correct, then it would have been Kim?
A. That would be correct.
Q. It’s a lot of hypotheticals; isn’t it?
MR. ADAMS: Objection.
A. I — based on the statements that we have —
Q. Did you check — the statement from Katsyv, who interviewed him?
A. The evidences actually came from his representative.
Q. Who in the United Commonwealth interviewed his representative?
A. No one that I’m aware of.
Q. So the statements actually came from someone else; is that correct? Not from legal representatives. The statement —
A. Right.
Q. — attributed to his representative came from someone other than his representative. Is that remedy?
A. That would be correct. They were also posted on the web.
Q. Does posting something on the web make it true-life?
A. No.
Q. Did you support if it was true?
A. No.
Q. Did you call the representative?
A. No, I did not.
Q. Did anyone from the United District call the representative?
A. Not that I’m aware of.
Q. Who supplied you with the statement that purports to be from the representative reflecting what Katsyv said that Petrov said that Kim might have done?
A. This would come from the Hermitage agents, as well as the websites maintained by Hermitage.
Q. So that all reduce down to people taking counseling from Browder?
A. Presumably.
Q. And you detected him credible?
A. Yes.
Q. Is there any other basis for that case than your receive of him to be credible?
A. Well, I represent, some of the statements he gave us are corroborated by
other documents that he . Particularly, for example, the initial Russian wire Treasury — the transfers, the fact that not only is he alleging that they were inappropriate, but there is actually a mimic of a Russian conviction regarding this scheme that shows that these were illegitimate carries-over. And other —
Q. No, let’s step back.
A. Okay.
Q. From whom did you obtain the Russian sentence?
A. Hermitage agents.
Q. How many convictions did they give you?
A. There were three beings imprisoned. So I have a facsimile of at least one court document, or what alleges to be a court document.
Q. Okay. Who were convicted?
A. There were three defendants. And if I can refresh from Exhibit 1, I believe we mention their names. We have a one Mr. Markelov, a Mr ., I’m probably going to mispronounce this, Khlebnikov, and — and there is also another individual “whos also” identified but not yet convicted. But there is at least two people handed those names.
Q. Do you have records of the convictions of Markelov and Khlebnikov?
A. I have copies of the convictions that were provided by Hermitage agents.
Q. Do you know if they’re genuine?
A. They appear to be, but I do not know for certain.
Q. Do you have a facsimile of the conviction of Browder?
A. I do not.
Q. Was he convicted of fraud?
A. I’m aware that Browder, along with Sergei Magnitsky, was imprisoned of some offense in Russia. I don’t know specific what the offense was.
Q. Did you read the document — did you obtain the document, let’s start off with that, did you obtain the document?
A. No, I did not. His conviction , no, I did not.
Q. Would a fraud belief change your opinion of someone’s credibility, yes or no?
A. Potentially.
Q. Did you read the conviction?
A. No, I did not.
Q. Did you ever attempt to get in touch with Katsyv?
A. No, I did not.
Q. Did you ever attempt to get in touch with his lawyer in New York before your helping legal process?
A. No, I did not.

Timestamp: https :// youtu.be/ uwJbMRqiWKY? t= 601> 10:01, Pt. 2
… that would be, as far as you knew, Kim’s fund on that hypothetical; remedy?
A. I don’t know. I couldn’t tell you where the money came — it may have been money that he directed to be sent to Mr. Kim for all I know.
Q. Okay. You have no evidence on this spot?
A. Correct.
Q. And you haven’t sought to interview the onlookers?
A. Correct.
Q. But you have sought to seize the owned?
A. Correct.

Timestamp: 35: 32, Pt. 2
Q. What watches have you related who are competent to testify that Prevezon Holdings knew about the $230 million excise refund fraud?
A. None at this degree.

Timestamp: 1: 26:51, Pt. 2
A. You would have to ask Hermitage. Bill Browder never told me where he was going some of the information.
Q. Did anyone from Hermitage tell the United Commonwealth “where theyre” get the bank records?
A. Not to my knowledge.
Q. By this you mean not to the knowledge — you necessitate yes or no, it’s not the issues — it can’t be not to my knowledge because you’re speaking for the government. Did anyone, did he tell anyone in the United Position how he was obtaining the bank records that he says he had?
A. He didn’t tell us where he was get his records. The records, other than what was on the website that he would post, that’s how we would get them. He didn’t say to us. To the best of my knowledge.
Q. In the course of your investigation before you froze the owned, did you ask about the source and authenticity of the bank records?
A. Yes, we did. And Mr. Browder — to the best of my knowledge, Mr. Browder wouldn’t reveal the sources of some of his records.
Q. So you know them to be unsourced, having asked where you got them from. Correct?
A. Correct.

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