Free Motion for Miscellaneous Relief - District Court of Colorado - Colorado

Case 1:04-cv-01225-MSK-BNB

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Malik M. Hasan, M.D., et al. v. Goldman Sachs 1998 Exchange Place Fund, LP, et al.

EXHIBIT F T EN ME D F N A T ' TO F RP E L SO A D H A D E E D N S MO I N O R C U I N N OTHER RELIEF LORRAINE M. TOZZO DEPOSITION EXCERPTS

EXHIBIT F 04-cv-1225-MSK-BNB

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO 3 HON. MARCIA S. KRIEGER Civil Action No. 04-MK-1225 (BNB) 4 Consolidated with 04-MK-1226 (BNG) 5----------------------------------------------- x 6 MALIK M. HASAN, M.D., an individual; and SEEME G. HASAN, 7 an individual, 8 Plaintiffs, 9 vs. 10 GOLDMAN SACH 1998 EXCHANGE PLACE FUND, L.P., a Delaware limited 11 partnership; GOLDMAN SACHS 1999 EXCHANGE PLACE FUND, L.P., a 12 delaware limited partnership; GOLDMAN SACHS MANAGEMENT 13 PARTNERS, L.P., a Delaware limited partnership; GOLDMAN 14 SACHS MANAGEMENT, INC., a Delaware corporation; THE 15 GOLDMAN SACHS GROUP, INC., a Delaware corporation; THE 16 GOLDMAN SACHS GROUP, INC., a Delaware corporation; GOLDMAN, 17 SACHS & CO., a New York limited partnership; JOHN DOES 1-100, 18 individual persons whose true identities are unknown; and 19 LENDER PARTIES 1-100, business entities whose true identities 20 are unknown, 21 Defendants. 22----------------------------------------------- x 23 DEPOSITION OF LORRAINE M. TOZZO 24 THURSDAY, JUNE 9, 2005 25

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Deposition of LORRAINE M. TOZZO taken in the above-entitled matter before Mark luzzolino, a Certified Shorthand Reporter (License No. XIO01 103) and Notary Public of the State of New Jersey, taken at the offices of CLEARY, GOTITLIEB, STEEN & HAMILTON, ESQS, One Liberty Plaza, New York New York 10006, on THURSDAY, JUNE 9, 2005, commencing at 9: 10 a.m.

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LORRAINE M. TOZZO having been first duly sworn, was examined and testified as follows: DIRECT EXAMINATION BY MR. MERRICK: Q. Good morning, Ms. Tozzo. Would you please state your full name and spell your last name? A. Lorraine M. Tozzo, T-o-z-z-o. Q. Ms. Tozzo, what is your business address and telephone number? A. 477 Madison Avenue, New York, New York 10022, 212-303-9442. Q. Is there a suite or floor? A. The entire eighth floor. Q. And what business is located at that address, ma'am? A. The name of the company now is Halcyon Asset Management, LLC. We're an asset management firm. Pretty much sums it up what we do. We take people's money and invest it. Q. And what position do you hold with Halcyon?
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AP P EA RAN C ES: SENN, VISCIANO, KIRSCHENBAUM & MERRICK, P.C. 1801 California Street, Suite 4300 Denver, Colorado 80202-2604 303-298-9101 BY: GLENN W. MERRICK, ESQ. Attorneys for the Plaintiffs FEATHERSTONE & DESISTO, LLP 600 17th Street Suite 2400 Denver, CO 80202 BY: BRUCE A. FEATHERSTONE, ESQ. Attorneys for the Defendants CLEARY, GOTrrLIEB, STEEN & HAMILTON, ESQS One Liberty Plaza New York New York 10006 BY: STEPHEN THOMAS KAISER, ESQ. Attorneys for the Defendants

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Tozzo A. I am the assistant to Alan B. Slifika, who is the founder of the firm. The company's name used to be Halcyon Alan B. Slifka Management, and Mr. Slifka is sort of semi-retired now, and I'm still with him as his assistant. He's co-chairman now. Q. How long have you been with Halcyon and Mr. Slifka? A. I'll be with him this summer 14 years. Q. Has the business always been located at that address? A. No. They originally -- when the firm started in 1979 prior to my being there, they were downtown here. I don't know. I think Hanover Square. I don't remember the exact number. Q. When did the firm move to its current location? A. I think in the '80s sometime, early '80s, mid-'80s. Q. Has it been at that address during the entire time that you've been with the firm? A. Absolutely. Q. What is your home address and telephone number, please? 2 (Pages 2 to 5)

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Tozzo A. Yes. They contacted me one other
time
--

Q. Okay.
A. -- and they asked me if I would come to Denver. And I told them I would get back to them. I'd have to think about it. And I spoke to Mr. Slifka about it, and he felt it was necessary for me to go. And so I went to Denver. Q. So you were contacted now a third time, this time by whom asking you to go to Denver? A. Inna Reznik. Q. Ms. Rez~nik asked you to fly to Denver. Correct? A. That's correct. Q. And you flew to Denver for a court hearing? A. Yes, I did. Q. Did you testify at that hearing? A. No, I did not. Q. So then you flew home. Correct? A. Yes. Q. And were you contacted yet again by either Mr. Featherstone's office or by Cleary, Gottlieb, Hamilton & Steen?
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Tozzo

Q. During the conversations that you
related to us, were all of those conversations about the notarization that's contained on page 39 of Exhibit 1OA? A. Absolutely. Q. Were there any other topics discussed that you can recall? A. Oh, excuse me. Mr. Gitter knew Mr. Slifka because his son and Alan Slifka's son both went to the same school. That was the only other conversation. Q. Now, do you know Malik Hasan? A. No, Ido not. Q. Do you know Seeme G. Hasan? A. No, Ido not. Q. Do you recall at some point in the past I called you and asked you about notarization? Do you recall that? A. Of course. Q. Do you recall during the course of that conversation I suggested that you could see a picture of Dr. Hasan on the internet? A. Yes. Q. And did you, in fact, pull up that
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Tozzo A. I was contacted again by Inna Reznik to ask me if I would be able to do this deposition on this date. Q. Were you contacted yet again about scheduling a meeting with Mr. Featherstone and Ms. Reznik a couple of days ago? A. At that time she gave me two dates. She gave me a date to have a meeting, and then she gave me the date of this meeting. Q. The deposition? A. Yes, deposition. Excuse me. Q. So today is Thursday. Do you remember what day you met with Ms. Reznik and Mr. Featherstone? A. I'd have to check my book, but I think it's a week ago Tuesday. Q. Were there additional contacts of you by either Mr. Featherstone's office or by Cleary, Gottlieb? A. No. Q. Did you initiate any contacts with Mr. Featherstone or any persons associated with Cleary, Gottlieb, Hamilton & Steen? A. No.

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Tozzo picture? A. Yes, I did. Q. And do you recall telling me that you did not recognize Dr. Hasan? MR. FEATHERSTONE: Objection. Leading. Also object to the form. Q. Do you recall telling me that you did not recognize Dr. Hasan? MR. FEATI{ERSTONE: Same objection. Q. You can answer. MR. FEATHERSTONE: Yes, you can. You need to respond if you can to the question, notwithstanding my objection, unless and I don't think it will happen in this case there's an instruction not to answer. A. No, I did not recognize him. Q. Would you be good enough to open to page 39 of Exhibit I A, which has been placed in front of you by Mr. Featherstone? Ms. Tozzo, at the lower half of page 39 of Exhibit 1OA, there's a signature for the notary. Is that your signature? A. Yes, it is. Q. I note that you were using a different
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Tozzo name at that point in time. A. Yes. I was married at that time. Q. But you now go by Lorraine Tozzo? A. Which is my maiden name. Q. I note here it says that -- on the notarization that on the 22nd day of October, before you "personally came and appeared Malik M. Hasan, to me known and known to me to be the individual described in and who executed the foregoing instrument." Do you see that? A. Yes, I do. Q. Now, when I contacted you maybe a couple of months ago and you took a look at the picture, you didn't recognize Dr. Hasan from the picture. Correct? A. Yes. MR. FEATHERSTONE: Objection. Leading and cumulative. Q. How many notarizations do you think you do on the average per year? A. A few dozen. Q. And has that been true consistent since approximately 1998, beginning in 1998? A. I would say so, yes.
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Tozzo

Q. During earlier testimony you indicated
that you're an in-house notary. Do you recall that? A. Yes. Q. What do you mean by that? A. I don't do any public notaries. Basically I notarize documents that relate to Halcyon, that relate to individuals at Halcyon. I also notarize other notaries' signatures, family's, friends'. Q. Do you know whether or not Dr. Hasan is associated with Halcyon in any way? A. I do not think so in any way. Q. Do you know whether Dr. Hasan is associated or affiliated with any individuals at Halcyon? A. I do not think so. Q. Do you know whether Dr. Hasan is a friend or associate or business colleague of any persons at Halcyon? A. I do not think so. Q. Do you know whether Dr. Hasan has any personal relationship of any kind with any individuals associated with Halcyon?
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Tozzo

Q. Was it true prior to 1998?
A. Yes. Q. When did you first become a notary? A. In 1971. Q. Since you've been at Halcyon, has it been true that you've been doing a couple of dozen notarizations per year on average? A. Yes. Q. Do you maintain a notary book? A. No, I do not. Q. Have you ever maintained a notary book? A. It is not required in New York State. Q. But have you, whether or not it's required, ever maintained a notary book? A. No, I have not. Q. Do you keep any records of any kind or nature with respect to the notaries -notarizations that you do for individuals or enterprises? A. No, I do not. Q. Have you ever kept any such records or notes or other documents reflecting the notarizations that you've done? A. No, Ihave not.

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Tozzo A. I don't think so. Q. Do you have any affiliation or relationship with Dr. Hasan or Seeme Hasan? A. Absolutely not. Q. Have you ever had any affiliation or association with Dr. Hasan or Seeme Hasan? A. Absolutely not. Q. Do you have any recollection whatsoever of the notarization which appears on the lower half of Exhibit 1OA at page 39? A. No, Ido not. Q. Let me walk you through the procedure that you've described for us a little bit earlier. When you were testifying a bit ago, you indicated that -- how you go about notarizing signatures. Do you recall that? A. Yes. Q. And I think you said that you do such notarizations only if someone introduces you, someone from Halcyon introduces you to somebody. Is that correct? A. That's correct. Q. Explain as best you can recall what you believe may have happened with respect to the 6 (Pages 18 to 21)

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Tozzo notarization there? A. I tried recalling the day. I looked in Mr. Slifka's, you know, calendar as to what was going on, any meetings. Mr. Slifka wasn't even in the office that day. I sit on the trading desk, which is a very busy area. Two things could have happened. Someone could have walked over to my desk, a professional at the firm, and said to me, "Lorraine, I'd like to introduce you to" whomever. "Would you be kind enough to notarize the signature?", and I would. Or I was asked to call into a conference room. We have three conference rooms. And someone, again, would say, "Lorraine, I'd like to introduce you to" whomever. "Would you be kind enough to notarize his signature?" Q. When someone requests a notarization from you of another person whom you do not know personally, do you require an introduction or an affirmation by somebody at Halcyon that the person whose signature is being notarized is, in fact, that person? A. Halcyon is a veiy reputable firm, and everyone who's employed at Halcyon is an "A" person, a fab -- honest and true. I would never
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Tozzo notarize a document, I would assume 100 percent that person is who that person is. Did I explain myself correctly? Q. Let me take you back to the October-of-1998 time frame. If you had been asked to notarize a document of an individual, would you require someone from Halcyon to tell you that this individual is who is claiming to sign, to identify' the person claiming to sign? A. Yes. Q. Would you notarize a document in that time frame without having somebody from Halcyon affirm to you that the person signing this, in fact, is the person who he claims to be? A. I would not notarize a document if they didn't affirm to me who that person is. Q. Based on that testimony, is it fair to say that since you didn't know Dr. Hasan in October of 1998, that someone at Halcyon would have told you that the person who was appearing before you to sign page 39 of Exhibit iQOA was, in fact, Dr. Malik Hasan? A. I would be very disappointed if that happened, that someone lied to me.
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Tozzo question. I would never question anyone at Halcyon. MR. PLF: The question is whether you require -A. Right. I would never require that. Q. Wait. Let me try the question again because I think we may have asked and answered different questions. A. All right. Q. When you're asked to do a notarization with respect to a person that you do not know -and I'll invite your attention, please, to the October of 1998 time frame to the extent it makes any difference. A. Right. Q. In that time frame, if you were asked to do a notarization of a person that you did not know, would you require that someone at Halcyon introduce you to that person or affirmn to you that the person whose signature you are notarizing is, in fact, the person claimed to be? NMR. PLF: Objection. Compound. A. At Halcyon, because I trust everyone there, if someone came over to me and asked me to

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Tozzo

Q. No, no. Please listen to the question.
Based on the fact that you did not know Dr. Malik Hasan in October of 1998 -- is that true? A. That's true. Q. -- is it fair to say that you would not have notarized this document on the lower half of page 39 of Exhibit I1OA unless someone from Halcyon represented to you that the person signing the document was Malik M. Hasan? A. Yes. Q. That's a true statement? A. I'm getting confused here. You're really confusing me the way you're saying this to me. Q. We'll take it a little bit at a time because I want to make sure I've got your testimony correct. A. Okay. Q. Did you or did you not know Malik M. Hasan in October of 1998? A. No, I did not know Malik M. Hasan in 1998. Q. Okay. So is it fair to say that in October of 1998 you would not have known whether 7 (Pages 22 to 25)

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Tozzo or not the person signing this document was Malik M. Hasan? A. That's correct. Q. And did you, in fact, notanize this document in October of 1998? A. Yes, I did. Q. And is it fair to say that in October of 1998 your practice was not to notarize the signature of a person you did not know unless someone from Halcyon represented to you that the person signing was, in fact, Malik M. Hasan? A. I don't know how to answer that. I'm so confused right now. My head is absolutely spinning. All I know is that I would not notarize a document without a person signing it in front of me. Q. I understand that. A. All right? I would not notarize a document if somebody just walking over to my desk and saying, "Would you notarize my name?", and I look at that person and I don't know who that person is. I would not do that. That's only happened once, and I asked that person for identification and a copy -- and to see his
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Tozzo

Q. Other than that one occasion where the
security guard asked you to notarize the signature of another tenant in your building, you've always used this practice that you described for us. Correct? A. Absolutely. Q. And the practice that you described for us is if you're going to notarize the signature of a person you do not know, you require an introduction from a person at Halcyon, who tells you that the person signing is who that person claims to be. Correct? A. That's correct. Q. So it's fair to say that somebody from Halcyon would have said to you in October of 1998, "The person signing this document, Ms. Tozzo, is, in fact, Malik M. Hasan. " Is that fair? A. That is fair, and that is correct. Q. So in October of 1998 somebody from Halcyon would have said, "Please, notarize this signature. This is, in fact, Malik M. Hasan"? A. That is correct. Q. Do you recall who at Halcyon represented to you that the person signing this document was
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Tozzo driver's license. What I do recall in all my instances of being a notary at Halcyon is that if someone asked me to notarize someone's signature, they would come to me or I would be asked -- I would have been called into a board room, and they would say, "I'd like to introduce you to" whomever. "Would you attest to signature?" They would sign their name. I would attest the signature. And that's my practice. Q. I think you just said -- and correct me if I misstate -- that there's only been one exception to that practice that you've just described for us, and in that one exception you required a driver's license or other venification of signature. A. Yes. Q. And that's the only time you deviated? A. The only time because it was - the security guard on the main floor in my building, who said, "I heard you're a notary. Would you notarize for another tenant on the fourth floor?", he came up to my office, and I didn't know who he was. It was a security guard asking me to do it. I asked for identification.

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Tozzo Malik M. Hasan? A. No, I haven't. And I have absolutely no recollection. And also, we had subtenants at that time, so it could also have been one of the subtenants. Q. I thought you told me you would only do this if it was a Halcyon person who introduced Dr. Hasan to you. A. Well, anyone at Halcyon, and I consider the subtenants part of Halcyon. Q. Who are the subtenants in October of 1998? A. I tried. I know one was Global TelSystems Group, which was a telecommunications firm, which is now defunct. There was another tenant by the name of Pennwood Capital.

Q. Pennwood?
A. Pennwood Capital. And Mason Hill.

Q. Mason Hill?
A. Mason Hill. I think it's Mason Hill Capital. Q. Any other subtenants? A. No, that's it. Q. Did you regard all of the employees and 8 (Pages 26 to 29)

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Tozzo persons who worked at Global TelSystems Group to have impeccable integrity? A. Yes, I did. Q. Did you regard all of the persons employed by and represented by Pennwood Capital to have impeccable integnity? A. Yes, I did. Q. Did you regard all the persons employed by and associated with Mason Hill Capital to have impeccable integrity? A. Yes, I did. Q. Do you know whether Dr. Hasan was known by any of the persons at Global TelSystems Group? A. I have no -- I would have no recollection. I would have no -- no one would have informed me of that. I don't know. Q. Do you know whether Dr. Hasan was known by or had any association whatsoever with Pennwood Capital? A. I have no idea. Q. Do you know whether Dr. Hasan was known by or had any affiliation with Mason Hill Capital? A. No, I didn't. Q. So is it fair to say that in October of
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Tozzo October of 1998? A. No, I did not. Q. So your notarization would have been based exclusively upon the introduction to you of Dr. Hasan by somebody at Halcyon, Global TelSystems Group, Pennwood Capital, and/or Mason Hill Capital? MR. PLF: Objection. Leading. Q. Is that a fair statement? MR. PLF: And it misstates. Q. You can answer it. A. Correct. Q. Is there any other way you would have known the person signing it? You have to answer verbally. A. Oh, no. Q. In the notarization that appears on the lower half of page 39 of Exhibit I A, you represent that Malik M. Hasan is "to you known and known to you to be the individual described in and who executed the instrument." Do you see that? A. Yes, Ido. Q. What is the basis of how you knew that the person signing was Dr. Malik M. Hasan -Page 33

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Tozzo 1998 you would not have notarized this document unless someone from Halcyon or Global TelSystems Group or Pennwood Capital or Mason Hill Capital would have said to you, "Ms. Tozzo, this is Malik M. Hasan. He is going to be signing this document. Please notarize it"? A. Correct. Q. And do you know whether any of those people or any of those organizations know or ever heard of Malik M. Hasan? MR. FEATHERSTONE: Objection. Repetitive.

Q. Do you know?
A. No, I do not. Q. And can you be any more specific about the person who represented to you that Malik M. Hasan was signing this document? A. I have no recollection. Q. When you are introduced to somebody as the person signing and for whom you will be notarizing, do you require the production of a form of identification from the person signing? A. No, I do not. Q. Did you require any identification in

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Tozzo MR. PLF: Objection. Repetitive. Q. -- other than what you've already told us? A. Exactly what I said, if someone came to me and asked me to attest a person's signature, I would not question them. I would attest the signature. Q. If Dr. Hasan were to testify that he has never been in the offices of Halcyon or even in the building in which your office is located, can you explain how your signature got on this document? A. Absolutely not. I have absolute -absolutely not. Q. Have you ever signed a document as a notary when asked to do so when the person wasn't present mn front of you? A. The only time I've ever done that is when it's a close personal relationship of someone who signed in front of me in the past, as an example, Alan's mother and his sister, my sister, who's a notary, notarizing her signature. That's the only time I've ever done that. I would never do it with someone I didn't know personally. 9 (Pages 30 to 33)

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Tozzo MR. FEATHERSTONE: And the Alan in your answer is Alan Slifka? THE WITNESS: Excuse me? MR. MERRICK: Can you wait for cross-examination, counsel, please? Q. Ms. Tozzo, on how many separate occasions have you notarized a document where the person whose signature you're notarizing was not personally before you when signing? A. Maybe about a dozen times. Q. How many times have you done that in the year 2005? A. I've only taken maybe two notaries this year. Q. Have you ever notarized a document without having the person signing appear before you when someone you trusted has said, "This is the signature of the person signing" even though you didn't know that person? A. No. I would never do that. Q. So if Mr. Slifka came to you and said, "Ms. Tozzo, here's the signature of a business affiliate of mine. I need to get this notarized." If you didn't know that business affiliate, you
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Tozzo some dozen times that you've done that -A. Right. Q. -- you use the same notarization form? A. Absolutely. I have one stamp. MR. MERRICK: That's all I have. Thank you. CROSS-EXAMINATION BY MR. FEATHERSTONE: Q. I have some questions, Ms. Tozzo. To further develop the background, you testified that you've been a notary -- that you were first a notary in 1971. A. That's right. Q. Have you been a notary continuously since that time? A. Yes, I have. Q. In response to Mr. Merrick's questions, you stated that you have worked for Halcyon, whatever the former name might be, for 14 years? A. That's correct. Q. And continuously for 14 years? A. That's correct. Q. Have you ever been an employee of Goldman Sachs -Page 37

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Tozzo would refuse to notarize? A. Absolutely, and he would never ask. Q. What if some other person whose integrity you thought was unquestioned at Halcyon or any of these other subtenants made a similar request? A. I wouldn't do that. Q. Can you say it has never happened? A. Yeah. Q. Do you use the same notarization formn for all of your notaries -- notarizations that appears on the lower half of Exhibit 39? A. Well, I have a new one now because I changed my name. Q. Other than the change of your name, is the notarization form the same? A. Yeah, absolutely. My number and -- oh, I'm not qualified in King's County any longer. I'm just New York County. Q. So when you execute documents for people who do not appear before you -- let me start the question again. It was a bad question. When you notarize the signatures of persons who have not actually appeared before you, this

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Tozzo A. Absolutely not. Q. -- or any of its affiliates? A. Absolutely not. Q. At any time sincel1971, have you ever served as a commercial notary as opposed to a private notary? A. Absolutely not. Q. You gave the address of your current location, your current office where you work. And the address that you gave was, in fact, the address where you were officed on or about October 22, 1998? MR. MERRICK: Objection to the form of the question. A. That's correct. Q. About how far is that location from One New York Plaza? A. It's got to be 5, 6 miles because One New York Plaza, I think, is downtown. I'm all the way up at Rockefeller Center. Q. And we're talking about five or six Manhattan miles? A. True. MR. MERRICK: Is there a special

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Tozzo distance in Manhattan? THE WITNESS: Yes. MR. FEATHERSTONE: I'm inclined to say: Why don't you wait until your time to redirect?, but you can ask that. That was fine. I won't complain about that. Q. I'm asking you now specifically about the notarization of page 39 of Exhibit A -- I A. You've testified in response to Mr. Merrick that you did not know Dr. Malik Hasan at that time. Correct? A. That is correct. Q. You testified that in October of 1998 you would have required a person you did not know whose signature was to be notarized to appear in front of you. Is that correct? A. That's correct. MR. MERRICK: Object to the form of the question. Q. You required that that person to be identified as to who he is -A. That is correct. Q. -- by someone you trusted and who you knew? Is that correct?
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Q. That is, in fact, your signature on page
39? A. Absolutely. Q. That is, in fact, your notarization stamp and seal on page 39? A. Absolutely. Q. So that I can have a picture of this, did you have - would you describe the stamp that you used? A. It's a black stamp pad with a stamp with a handle. And I just stamp it on the ink and stamp it there, and then I have one of those seals, which is right there. Q. And the notarization pad is what has the ink that you applied the stamp? A. Right. Q. I think we could tell this by the tone of your voice, but let me put the question to you directly because this transcript will be in print. Are you absolutely certain that you did not notarize page 39 without Dr. Hasan being in front of you? MR. MERRICK: Objection to the formn. A. Absolutely.
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Tozzo MR. MERRICK: Object to the form Of the question. A. That is correct. Q. That would apply to Dr. Malik Hasan on October 22, 1998. Is that correct? MR. MERRICK: Object to the form of the question. A. That is correct. Q. And did you also require Dr. Malik Hasan to sign in front of you? MR. MERRICK: Object to the form of the question. A. Yes. Q. So he would have been -- he was physically present and he signed page 39 in front of you. Is that correct? MR. MVERRICK: Objection to the form of the question. A. Yes. Q. Mr. Merrick asked about the notarization form. When he asked you that in relation to page 39, what's shown on page 39, what did you understand him to be referring to? A. I thought he was referring to my stamp.

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Q. Are you absolutely certain that you
notarized page 39 only after Dr. Hasan signed that document in front of you? A. That is correct. Q. Are you absolutely certain that you both were introduced to Dr. Hasan and saw him sign and date page 39? A. That is correct. Q. Mr. Merrick asked you some questions about Halcyon and its subtenants. I take it that even at Halcyon people come and go? A. Absolutely. Q. And people have joined and left that company since October of 1998? A. Yes. Q. Approximately how many employees, if that's the right word, did Halcyon have in October of 1998? A. Oh, I would say Halcyon itself -- I would say maybe about 30. Q. And you mentioned the subtenants. Are the subtenants included in that count? A. No, they are not. Q. Can you give us an estimate of the I11 (Pages 38 to 4 1)

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