Monoleche Deposition Transcript

Case 0:08-md-01916-KAM Document 944-4 Entered on FLSD Docket 11/24/2015 Page 1 of 80
Exhibit 3
IN THE UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA
CASE NO.: 08-01916-MD-MARRA/JOHNSON
IN RE:
CHIQUITA BRANDS INTERNATIONAL, INC.,
ALIEN TORT STATUTE AND

SHAREHOLDER DERIVATIVE LITIGATION
____________________________________________/
This Document Relates To:
ATS ACTIONS
_____________________________________________/
ATS ACTIONS
08-80421-CIV-MARRA
08-80465-CIV-MARRA
08-80508-CIV-MARRA
10-60573-CIV-MARRA
08-80480-CIV-MARRA
07-cv-60821-KAM
Colombia
Second Penal Court of the Circuit of Itag
Docket No. 11001-67-00-000-2015-21489-00
DEPOSITION OF JESUS IGNACIO RLDAN PEREZ
(Via Interpreter)
Wednesday, August 12, 2015
10:14 a.m. - 1:20 p.m.
Mxima Seguridad
Cra. 70, Itagui
Antioquia, Colombia
Stenographically Reported By:
ROBIN L. MERKER, RPR, FPR
Registered Professional Reporter
Florida Professional Reporter
WWW.USLEGALSUPPORT.COM
561-835-0220
2
1
APPEARANCES
2
3
4
5
6
7
8
9
10
11
12
13
14
On behalf of the Plaintiffs:

LAW OFFICES OF JUDITH BROWN CHOMSKY
Post Office Box 29726
Eighteenth and Arch Streets
Elkins Park, Pennsylvania 19027
215.782.8367
jchomsky@igc.org
BY: JUDITH BROWN CHOMSKY, ESQUIRE
EARTHRIGHTS INTERNATIONAL
1612 K Street NW
Suite 401
Washington, D.C. 20006-2826
202.466.5188
marissa@earthrights.org
juan@earthrights.org
BY: MARISSA ANN VAHLSING, ESQUIRE
JUAN PABLO CALDERON-MEZA, ESQUIRE
Carrera 57 #51-222
Edificio Calle Nueva
Medelln Colombia
310-614-0321
Alexlawyernumber1@hotmail.com
BY: ALEX ALBERTO MORALES CRDOBA
15
16
17
18
19
20
21
22
23
On behalf of the Defendants:

COVINGTON & BURLING, LLP
One City Center
850 Tenth Street, NW
Washington, DC 20001-4956
202.662.5273
sduraiswamy@cov.com
jarvelo@cov.com
BY: SHANKAR DURAISWAMY, ESQUIRE
JOS E. ARVELO, ESQUIRE
PRAS CADAVID ABOGADOS
Calle 99 No. 7A - 77 Of. 203
Bogot D.C., Colombia
PBX: +(571)743062
pcadavid@priascadavid.com
BY: PAULA CADAVID LONDOO, ESQUIRE
24
25
561-835-0220
3
1
2
Also Present:
LUIS FELIPE BARRERA, Interpreter
NANCY K. HAND, Interpreter
WILLIAM LEN ACOSTA, Plaintiffs' Assistant
3
4
5
INDEX OF PROCEEDINGS
6
7
DEPOSITION OF JESUS IGNACIO RLDAN PEREZ
EXAMINATION BY THE COURT:

DIRECT EXAMINATION BY MS. VAHLSING:
CROSS-EXAMINATION BY MR. MORALES:
CROSS-EXAMINATION BY MR. DURAISWAMY:
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
561-835-0220
PAGE
9
41
54
56
4
1
THE COURT:
Today is Wednesday, August 12,
2015, at 10:12 in the morning.
District -- Judicial District opens this public
hearing on behalf of the Southern District of the
State of Florida of the United States.
being Chiquita Brands International --
INTERPRETER HAND:
The Second
The matter
The interpreter requests a
repetition of the case number, the remaining parts of
the name, and the case number.
10
11
12
13
14
THE COURT:
For the record, may the parties,
please state their appearances.

MR. MORALES:
Good morning, Your Honor, and to
all those present.

My name is Alex Alberto Morales Crdoba.
I am
15
here representing Dr. Paul David Wolf, who is an
16
attorney representing over 4,000 families who are
17
victims of the armed conflict.
18
And I identify myself here by my professional
19
license number 121671 issued by the Superior Judicial
20
Council and my citizen ID 71723789.
21
And for purposes of legal notifications, my
22
address is Carrera 51 -- 57, No. 51-222 Edificio
23
Calle Nueva in Medelln.
24
number is 310-614-0321.
25
purposes of official notification, is
My number -- telephone
My e-mail address, also for
561-835-0220
5
1
Alexlawyernumber1@hotmail.com.
INTERPRETER BARRERA:
Barrera.
interpreter.
My name is Luis Felipe
I am an English-Spanish/Spanish-English
INTERPRETER HAND:
Nancy Hand, certified
federal court interpreter, U.S. certified federal
court interpreter.
8
9
10
MR. ACOSTA:
I am a translator for the
plaintiffs, U.S. citizen.

MR. CALDERON-MEZA:
That's all.
My name is Juan Pablo
11
Calderon-Meza.
12
am also the bearer of professional license number
13
169463 of the Supreme Judicial Council.
14
assisting the attorneys for the plaintiffs.
15
My citizen ID number is 10272988.
MS. VAHLSING:
And I am
Hello, my name is Marissa
16
Vahlsing.
17
identified with the professional card 1025043 for the
18
Bar of the District of Columbia.
19
a representative for the plaintiffs.
20
I'm a United States citizen.
MS. CHOMSKY:
I'm
I am here today as
Good morning, Your Honor and
21
colleagues.
22
professional license is from the Supreme Court of the
23
Commonwealth of Pennsylvania.
24
number is 21537.
25
MR. ARVELO:
My name is Judith Brown Chomsky.
My
Good morning.
My number -- my bar
I am Jos Arvelo.
561-835-0220
6
1
2
I am U.S. counsel for Chiquita Brands International.

MS. CADAVID:
Good morning.
My name is Paula
Cadavid and I'm a Colombian attorney.
is 39784735.
33424.
Chiquita Brands International.
My ID number
My professional license number is
I am here assisting the attorneys for
MR. DURAISWAMY:
Good morning.
My name is
Shankar Duraiswamy.
States, here representing the defendants in this
10
11
I'm an attorney from the United
litigation.
Your Honor, may I request the Court's
12
permission to make some preliminary inquiries
13
regarding the procedures for today's proceeding?
14
THE COURT:
15
MR. DURAISWAMY:
Go ahead.
I'm now speaking on behalf of
16
the attorneys, both for the plaintiffs and the
17
defendants, in this matter.
18
Your Honor, last week the judge in the United
19
States, who is presiding over these lawsuits, issued
20
an amended letter rogatory requesting that the
21
parties have the opportunity to conduct seven hours
22
of oral examination per side, and requesting that the
23
Court schedule additional days of testimony, as
24
needed, to give the parties that time.
25
I do not know, Your Honor, if you have received
561-835-0220
7
1
the amended letter.
provide it to you, if that would be helpful.
We have a copy of it and can
But we wanted to inquire of the Court whether
it would be willing to schedule additional days of
testimony in the future, on the next available date,
in order to accommodate the request of the U.S.
judge.
THE COURT:
to follow the order.
10
11
Yes, I did receive it.
We're going
We are going to follow the
order of the commission that has been sent to us.

First, the direct examination will be carried
12
out, which is stipulated here.
13
will be given the floor to conduct their own
14
examination.
15
With regard to the time, today we have until --
16
what time, Diego?
17
afternoon.
18
And then the parties
-- until 4:00 o'clock in the
In terms of the court calendar, we are already
19
into December.
20
scheduling additional dates, and we will have to look
21
at the calendar, and we can do that today.
22
it will not be immediate.
23
mind the time frame that we're working on.
The Court has no issue with
24
MR. DURAISWAMY:
25
MR. MORALES:
However,
We will have to keep in
Thank you, Your Honor.
Your Honor, I would like to know,
561-835-0220
8
1
with greater clarity, how this proceeding and how the
time will be managed, and who will have what time
after you are finished.
4
5
THE COURT:
Yes, we will go over that as we
move along.
Please stand.
Good morning.
THE WITNESS:
THE COURT:
Good morning, Your Honor.
You have been subpoenaed to give
10
testimony under oath in a court proceeding against a
11
company, a judicial entity, known as Chiquita Brands
12
International.
13
Details will be given later.
You -- that means that (indicating) -- that
14
means that you are required to answer truthfully all
15
of the questions put to you today, without hiding or
16
twisting any of the facts, because if you are to hide
17
or twist any of the facts, you would be committing
18
the crime of false testimony, which is a crime.
19
I also would like to make known to you
20
Article 385 of the Penal Procedural Code, which
21
states you cannot be forced to testify against
22
yourself, against your spouse, against any relative
23
of the fourth degree -- any blood relative in the
24
first -- fourth degree or second degree of affinity.
25
If you -- knowing all of this, do you swear to
561-835-0220
Case 0:08-md-01916-KAM Document 944-4 Entered on FLSD Docket 11/24/2015 Page 10 of

80
tell the truth?
2
3
THE WITNESS:
I do so swear.
Thereupon,
JESUS IGNACIO RLDAN PEREZ,
having been first duly sworn or affirmed, was examined and
testified as follows:
EXAMINATION
8
9
THE COURT:
fully.
Please tell us -- identify yourself
Please tell us your full name, the number of
10
your identification document, where you were born,
11
how many years you went to school, if you are married
12
or single.
13
14
THE WITNESS:
Good morning, Your Honor.
Good
morning, Your Honor, and to all those present.
15
My name is Jesus Ignacio Rldan Perez.
My
16
citizen identification number is 8 thousand 011973.
17
I was born in Guadalupe, Antioquia.
18
I have nine children.
19
I am separated.
I was a member of the auto -- of the
20
self-defense group of the brothers Castao, Fidel
21
Carlos, and Vincente.
22
second semester of 1968.
23
and I was demobilized under the justice and peace
24
law.
25
I entered in 1968, during the

I was demobilized in 2004,
(Interpreter Barrera continues.)
561-835-0220

80
10
The commission states the plaintiffs would like
to examine the witness, Mr. Rldan, in regard to the
payment arrangements between Chiquita Brands and the
AUC, specifically in the -- in the meeting that took
place in 1997, in which Chiquita Brands executives
arranged -- made payment arrangements with the AUC
members.
8
9
10
11
12
13
14
15
16
17
18
19
For reasons of methodology, would the

interpreters like for the interventions to be
shorter?
Yes, it would be helpful,
thank you.
THE COURT:
And I excused because I noticed
that you were struggling.

Meetings between executives of Chiquita and
Banadex and AUC commanders.
Question:
Did executives from Chiquita Banadex
met with commanders of the AUC?

THE WITNESS:
Your Honor, I inform you, and I
20
inform you, all the people present, that I don't have
21
any knowledge regarding any of the -- how this was
22
negotiated.
23
These negotiations were conducted between
24
cattle businessmen and Mr. Ral Hasbn, alias Pedro
25
Bonito.
He was the person in charge, by Carlos and
561-835-0220

80
11
Vincente Castao, who was ordered by Carlos Castao
to conduct business with those businessmen and cattle
businessmen from the region.
Therefore, Your Honor, I repeat that I don't
have any knowledge about those negotiations, nor did
I participate in any of those negotiations.
would like to reiterate the fact that I don't know
how those payment arrangements were carried out.
THE COURT:
And I
Regarding your answer, the Court
10
is -- is compelled to -- to interrogate you regarding
11
this matter and you've been -- you've been informed.
12
Question:
13
discuss?
14
this?
15
If they did meet, what did they
And how do you know that they discussed
THE WITNESS:
I repeat, Your Honor, I don't
16
have any knowledge regarding this, because I did not
17
participate in these negotiations with these
18
businessmen -- with the businessmen.
19
THE COURT:
Seeing what the -- what the witness
20
has answered, we're going to ask two questions as
21
one.
22
If they did meet, what did they discuss in
23
these meetings?
24
meetings?
25
And were you present in any of these
THE WITNESS:
No, Your Honor, I didn't attend
561-835-0220

80
12
any of those meetings.
THE COURT:
Question:
Please tell us
everything you know about payment arrangements
between Chiquita and the AUC, or any division of the
AUC.
arrangements?
And how do you know about these payment
THE WITNESS:
Your Honor, as I said before, the
person who has full knowledge of this situation was
Mr. Ral Hasbn, alias Pedro Bonito.
He was the
10
person in charge, or ordered by Vincente Carlos
11
Castao to conduct these negotiations, not only with
12
Chiquita, but with businessmen from the region.
13
14
15
MR. ARVELO:
On the record, let me just
interject for a moment.

I ask the translator, please be precise with
16
translation.
17
several times as "negotiation.
18
record, I wanted to raise this issue.
"Meeting," you translated "meeting"

So, just for the
19
(Interpreter Hand continues.)
20
21
MR. MORALES:
Okay.
Your Honor, he has been clear
22
that they are negotiations.
23
clearly.
He has said that
24
THE COURT:
25
Okay.
561-835-0220

80
13
THE WITNESS:
Your Honor, I just wanted to clarify why -- why
Your Honor, if I may continue.
did Ral Hasbn -- why it was Ral Hasbn appointed
by Carlos Vincente to conduct these meetings with --
with businessmen, with the banana businessmen.
Mr. Ral Hasbn used to be a banana businessmen
himself when he first entered the AUC.
person who can tell you all about these meetings
and...
10
THE COURT:
This is the
Were there -- was there any
11
paramilitary unit that provided services for either
12
Chiquita or Banadex, and how do you know this?
13
THE WITNESS:
Your Honor, the knowledge that
14
I -- that I have is because I was a member of the
15
organization.
16
I repeat:
The person in charge of conducting
17
those meetings was Mr. Pedro Hasbn.
18
those business meetings with cattle businessmen,
19
banana businessmen.
20
21
22
He conducted
Everyone, and all the companies in the region,

were involved in extortion payments.
MS. VAHLSING:
I would like to object to the
23
translation please, and request that the term
24
"vacuna" be translated literally and with precision.
25
561-835-0220

80
14
1
2
3
MR. ARVELO:
I will say for the record that he
translated the term "vacuna" accurately.

MR. MORALES:
I would like to say that I
support the -- I support counsel's motion, and I also
would like to have the term clarified.
THE COURT:
If any paramilitary unit offered to
provide services for Chiquita or Banadex, were those
services offered in exchange for payments?
you know this?
10
11
12
THE WITNESS:
How do
Your Honor, I don't have any
knowledge regarding your question.

THE COURT:
Question:
Did Chiquita or Banadex
13
make any arrangement to hide those payments from the
14
controlled entities of the government?
15
know this?
16
17
18
THE WITNESS:
How do you

I would like to repeat that all this
19
information is in -- the person who has all this
20
information is Mr. Ral Hasbn, alias Pedro Bonito.
21
THE COURT:
If there was any arrangement that
22
was made to hide the payments that were carried out,
23
what -- which type of arrangements were these?
24
do you know this?
25
THE WITNESS:
561-835-0220
How

80
15
1
2

THE COURT:
Question:
What did AUC do with the
money received from Chiquita and Banadex, and how do
you know this?
5
6
7
THE WITNESS:
I don't have any knowledge
regarding your question, Your Honor.

THE COURT:
Question:
Was the money received
by the AUC, from Chiquita and Banadex, important for
the AUC?
10
11
12
How do you know this?
THE WITNESS:

THE COURT:
We're not going to ask the
13
following question, because the answer that the
14
witness just -- has provided, the last answer that
15
the witness provided, is enough answer for the
16
following question.
17
Question:
Did Chiquita and Banadex know what
18
the AUC did with the money that was paid to them?
19
20
21
22
23
24
25
THE WITNESS:

THE COURT:
Did Chiquita or Banadex ask the AUC
to use the money for a specific purpose?

THE WITNESS:
561-835-0220

80
16
THE COURT:
Question:
If Chiquita or Banadex
did ask the AUC to use the money that was paid with a
specific purpose, what was that purpose, and how do
you know this?
5
6
THE WITNESS:
THE COURT:
question.
document.
10
11
I'm going to interpret the
I'm not going to read it as it is in the
Do you know if there was an answer on behalf of

Banadex or Chiquita, regarding the use of that money?
12
13
THE WITNESS:
14
THE COURT:
Did Chiquita or Banadex request
15
from the AUC not to use that money with a specific
16
purpose?
17
18
THE WITNESS:
19
THE COURT:
Would you like to elaborate your
20
answer, why don't you have any knowledge regarding
21
this?
22
THE WITNESS:
Your Honor, as I stated before, I
23
never took part in these meetings.
24
don't have any knowledge regarding them.
25
That's why I
I -- I would like to be -- I would like to
561-835-0220

80
17
clarify that Ral Hasbn is the person who knows
everything about these meetings.
3
4
5
THE COURT:
This Court will mix the two last
questions that are contained in the second numeral.

You have been answering this regarding this
specific point.
once again, since it is contained in this document.
8
9
10
11
12
13
14
Nevertheless, you will be questioned
Do you know anything regarding that money not

being used with a specific purpose?
THE WITNESS:

THE COURT:
Numeral 3.
Other aid or -- aid
from Chiquita or Banadex to the AUC.

Question:
Do you know if Chiquita or Banadex
15
provided support for the AUC to acquire -- to procure
16
ammunition or weapons?
17
THE WITNESS:
18
19

I would like to clarify.
My knowledge comes
20
from being in charge of the security -- of the
21
security branch for the Castao brothers in the AUC.
22
The money paid as taxes for drug trafficking, and
23
that was collected from cattle businessmen and banana
24
businessmen, was all used for buying ammunition,
25
weapons, and camouflage uniforms for the AUC.
561-835-0220

80
18
THE COURT:
Question:
Do you know whether
Chiquita or Banadex supported the AUC in buying
weapons or ammunition?
that you know regarding this issue.
5
6
7
8
THE WITNESS:
Please explain everything

THE COURT:
Numeral 4.
Alignment between the
AUC and Chiquita/Banadex.
Did the AUC perceive their interests as being
10
in line with those of Chiquita and Banadex, in the
11
context of the civil war?
12
13
THE WITNESS:
I don't have knowledge regarding
your question, Your Honor.
14
MR. MORALES:
Your Honor, may I approach?
15
MS. CHOMSKY:
This is not okay.
16
MR. MORALES:
Saying it out loud.
17
The questioner contains some titles that I
18
would suggest, Your Honor, that you wouldn't read.
19
This is not to direct the witness.
20
21
22
THE COURT:
Please, anyone who wants to take
the -- to be given the floor, raise your hand.

MS. VAHLSING:
On behalf of the -- the
23
plaintiffs, I would like to state for the record that
24
my -- myself, my person, that I am the only U.S.
25
attorney authorized to speak and ask questions on
561-835-0220

80
19
behalf of the plaintiffs in this proceeding.
Whether there are issues under Colombian law,
it's fine that Colombian lawyers participate, but in
terms of the questions that will be attributed to the
plaintiffs, I am only the representative that is
authorized to speak according to the court order,
which can be found in Section 13 of the letters
rogatory.
Thank you.
THE COURT:
10
Anyone else want to intervene?
Do the parties consider that there is
11
inconvenience, or problem, in continuing reading
12
these titles, or would they like me to continue doing
13
so?
14
MR. DURAISWAMY:
On behalf of the defendants,
15
Your Honor -- on behalf of the defendants, Your
16
Honor, it is fine with us if you do not read the
17
titles.
18
MS. VAHLSING:
On behalf of the plaintiffs,
19
Your Honor, we are also in agreement that it is best
20
not to read the titles to the questions.
21
THE COURT:
Okay.
Question:
If the AUC did --
22
did perceive their interests to be in line with those
23
of Chiquita and Banadex, in which way was this?
24
25
THE WITNESS:
I don't have any knowledge, Your
Honor.
561-835-0220

80
20
Your Honor, may I ask a question?
THE COURT:
THE COURT:
No, you cannot ask any questions.
Did Chiquita or Banadex see their
interests as aligned with those of AUC, do you know?
THE WITNESS:
Here, in this hearing, there are defenders
I have no knowledge, Your Honor.
present.
can be carried out without a defense attorney,
And I would like to know if this hearing
10
without my own defense attorney, if it is acceptable
11
to carry out this hearing, because I was notified of
12
this hearing, but my defense attorney is not here.
13
So I would like to know if that is permissible.
14
THE COURT:
15
THE WITNESS:
Are you asking me?

Your Honor, I asked you the
16
question, but you said that I could not ask you any
17
questions.
18
would like to know if it is necessary for my defense
19
attorney to be here, or if I will not have any
20
problems as a result of the fact that my
21
representative is not here, if that is okay.
22
So I'm asking the question because I
THE COURT:
I repeat what I said to you at the
23
beginning.
24
no charges are being made against you in this
25
hearing.
This is a hearing for testimony.
And also I repeat, that you have no
561-835-0220
This --

80
21
obligation to testify against yourself.
guarantee.
THE WITNESS:
THE COURT:
That is a
I understand, Your Honor.
Question:
Did Chiquita or Banadex
see their interests as -- interests as allied with
those of AUC?
THE WITNESS:
THE COURT:
9
10
Question:
Did any employee of
Chiquita or Banadex have contact with any individual,

or unit, of AUC?
11
THE WITNESS:
12
Your Honor, I would like to clarify that
13
question.
14
person in charge of meeting with all of those
15
companies in Urab, who has full knowledge of all of
16
that, is Mr. Ral Hasbn.
17
know of who was responsible for those meetings, Your
18
Honor.
19
I repeat what I said before.
THE COURT:
The only
He is the only person I
Let's clarify something.
The other
20
questions, there is no sense in asking the other
21
questions included on the basis of the answers that
22
he has given.
23
them to be asked, we can ask them, No. 5, the four
24
last ones.
25
However, if the parties would like for
MR. DURAISWAMY:
Your Honor, the defendant
561-835-0220

80
22
agrees that it is not necessary to ask those
questions.
MS. VAHLSING:
Your Honor, the plaintiffs agree
it is not necessary to ask those questions.
you.
MR. MORALES:
Thank
Your Honor, as a representative
of the victims in Colombia, there is a need to
clarify and to arrive at the truth.
request that they be asked.
10
11
12
13
THE COURT:
So I would
The attorney stated that she is the
representative of the plaintiffs -MS. VAHLSING:
I have available for Your Honor,
a copy of the --
14
(Conversation between the Court and clerk.)
15
THE COURT:
16
We are going to take a break, because the
-- so who do you represent?
17
prosecutor's office needs to make notification to the
18
witness.
19
(A discussion was held off the record.)
20
THE COURT:
21
MS. VAHLSING:
Have they resolved?

Your Honor, just to support the
22
position that we are making before the Court, we
23
present to you a copy of the letters rogatory with
24
the name of Marco Simons as the designated attorney
25
for the plaintiffs, by the consensus of all
561-835-0220

80
23
plaintiffs' lawyers, other than Mr. Wolf, who is
represented today by Mr. Morales.
In addition to that, I present a power of
attorney signed by Mr. Marco Simons, authorizing
myself, Judith Chomsky, and Juan Pablo Crdenas-Meza,
as the attorneys who represent the plaintiffs in this
proceeding.
8
9
Thank you.
If I may, in addition we have an order from the

Court in Florida, that was signed by the judge in
10
Florida, agreeing that there would be only one
11
representative present in this proceeding on behalf
12
of the plaintiffs.
13
MR. MORALES:
Your Honor, my name is Alex
14
Alberto Morales Cordoba and, as I stated, I am an
15
attorney assisting Dr. Paul David Wolf, who is
16
identified by Foreign Citizen Identity Document
17
No. 305797.
18
attorney representing the plaintiffs in the United
19
States, in cases in the United States.
Paul David Wolf is the attorney -- an
20
And also now present to you a power -- rather,
21
an authorization of myself as a supporting attorney
22
in his representation.
23
contracts or agreements that Mr. Paul David Wolf made
24
with the victims of the violence in Urab by Chiquita
25
Brands International.
And in addition, one of the
561-835-0220

80
24
THE COURT:
MR. DURAISWAMY:
THE COURT:
Muy bien.
Your Honor, may I?
It is decided then that it is not
necessary to ask the remaining four questions of
No. 5, on the basis of the answers given by the
witness to the first two questions.
interpreter correction -- the first two numbers.
Or rather --
(Conversation between Judge and clerk.)
THE COURT:
The commission includes some
10
questions that says the following:
11
wish to ask the following questions."
12
The judge will ask them.
13
Question:
"The defendants
There are 19.
When did you act as, or when were
14
you a member of the self-defense or paramilitary
15
organizations, including the AUC, and what was your
16
role?
17
THE WITNESS:
Your Honor, as I mentioned
18
previously, I entered in 1988, during the second
19
semester of 1988.
20
of one of the Castao brothers, Fidel Castao.
21
22
INTERPRETER HAND:
25
The interpreter would like
to ask a question of clarification.
23
24
For some time I was the bodyguard
(Spanish between Interpreter Hand and the

witness.)
THE WITNESS:
Bodyguard of John Ernaldo, who
561-835-0220

80
25
1
2
was the manager of livestock farms of Fidel Castao.

THE COURT:
Question No. 2:
As a paramilitary
person, did you operate, or command, any of the
divisions in the banana-growing region of Urab,
Antioquia, or Magdalena?
THE WITNESS:
Your Honor, I'm going to finish
the preceding question, which I didn't finish because
of the --
From being the bodyguard of John Ernaldo, I
10
became a manager of farms of Fidel Castao.
11
manager of a farm in Crdoba, a farm called Costa de
12
Oro, close to Crdoba.
13
INTERPRETER HAND:
14
15
I was a
Interpreter correction.
Close to Tiega Alta -- Tierralta.

THE WITNESS:
From there, from Crdoba, Fidel
16
Castao bought some farms in the area of San Pedro de
17
Urab.
18
San Pedro de Urab.
19
From there I went to manage those farms in
I was the manager of those farms until the year
20
1994, when Fidel Castao died.
21
seeks his brother Vicente to replace Fidel, and then
22
I become the manager of security for Carlos and
23
Vincente.
24
1997 as -- in charge of security for the two
25
brothers, brother Vicente and Carlos.
Carlos then comes,
And I was there -- I stayed there until
561-835-0220
And then,

80
26
beginning in 1997, I stayed just with Vicente until
2004, which was my demobilization.
And your second question, Your Honor, I did not
have any group under my command, nor did I operate in
Magdalena.
THE COURT:
Clarification of the second
question.
department of Magdalena, but also the area of Urab.
The second question refers not just to the
THE WITNESS:
Your Honor, I did not have groups
10
under my charge, combat groups, in the area of Urab.
11
I only had, under my command, security personnel for
12
the Castao brothers.
13
their security.
14
charge.
15
I was only responsible for
I did not have any groups under my
The commander in charge of those groups was
16
Commander 00, who was a retired military army
17
commander, who was the army commander of the Castao
18
brothers.
19
THE COURT:
Question No. 3:
Did the
20
paramilitary groups obtain effective control over the
21
regions where they operated?
22
THE WITNESS:
Your Honor, in the areas where
23
the self-defense groups operated, fighting the
24
guerrillas, for many, many years control was
25
100 percent under -- under the control of the force
561-835-0220

80
27
1
2
that operated in that area.

THE COURT:
Question No. 4:
In your opinion,
did the AUC provide security to the population in the
regions under its control?
THE WITNESS:
Please explain.
Your Honor, in the zones where I
was located, in the department of Crdoba and San
Pedro de Urab, this is where the Castaos -- Castao
brothers operated, and there was 100 percent control
in those areas.
10
And being there, I was part of that.
But there were commanders that were responsible
11
for providing protection to the population, to the
12
campesinos in those areas.
13
in those areas, I was part of providing security to
14
the population there.
15
THE COURT:
And logically, as I was
Question No. 5:
Did the
16
paramilitaries commit acts of violence against those
17
who refused to obey their orders or demands?
18
THE WITNESS:
Your Honor, these areas were
19
under the control of the self-defense groups.
20
Honor, if an order was issued, it was followed.
21
Someone in that area who did not obey the order left
22
the area, or died.
23
24
25
THE COURT:
Your
Are you going to continue, or had
you finished?
THE WITNESS:
I finished.
561-835-0220

80
28
THE COURT:
No. 6:
Was the Colombian
government prepared to, or able to, hamper or counter
the actions of the AUC?
THE WITNESS:
Your Honor, in 1994 the FARC
guerrillas had power in Colombia, in almost all of
the regions of Colombia.
Fidel Castao, before he died, Your Honor,
negotiated with the FARC to join forces with the
FARC.
Carlos Castao sought out his brother, Vicente
10
who, at that time, was not part of the effort, and
11
was not working with Fidel.
12
Fidel died.
13
He sought him out after
Carlos told Vicente that there were
14
negotiations with the FARC, and he asked him if those
15
negotiations should continue.
16
if he was to come in, that it would be to put an end
17
to the FARC.
18
Vicente said no, that
Vicente Castao, Your Honor, began to arm small
19
groups, self-defense groups, together with
20
Commander 00, who was a military commander.
21
began arming small groups in the different regions of
22
San Pedro, Urab, Turbo, Mecocle, Apartad,
23
Chigorod, and extending from there.
24
25
And they
Your Honor, in all of those towns that I

mentioned, there were police, and there were army in
561-835-0220

80
29
all of those neighborhoods.
office.
state supported the entrance of these self-defense
groups, in order to be able to go into those towns.
There was a prosecutor's
There, all of these people representing the
The growth of these -- of this organization,
Your Honor, was done with the support of the
Colombian government, with many officials and
politicians.
And the growth was very fast.
In 12 years
10
there were 30,000 armed men.
11
around, go into these towns, and the police never
12
detained us, Your Honor.
13
detained us, but it did not because it needed an
14
armed group to fight the guerrillas, to go into homes
15
at night and take out the militias, take out the
16
guerrillas, and murder them.
17
that.
18
And we would move
The state could have
The state was not doing
The state allowed our growth, Your Honor.
And
19
then, when the state saw that by 2002-2003, we had
20
the guerrillas basically cornered in the -- in the
21
jungle, and in Medelln, cities like Medelln, for
22
example, there wasn't a single guerrilla fighter; in
23
Bogot, it was about 40 percent clean; the highways
24
about 90 percent, without any problems.
25
And to conclude Your Honor, the state had full
561-835-0220

80
30
knowledge of the fact that we existed, and allowed
this growth, Your Honor.
THE COURT:
Question No. 7:
What portion of
the funds from the AUC came from drug trafficking,
kidnapping, and extortion, and came from Chiquita or
other sources, and how do you know this?
8
9
THE WITNESS:
correctly --
10
11
Your Honor, if I understood
THE COURT:
Would you want me to repeat the
question?
12
THE WITNESS:
13
THE COURT:
Yes, Your Honor.

This is a question and not a
14
statement:
15
the funding of the AUC came from drug trafficking,
16
kidnapping, extortion, from Chiquita Brands or other
17
sources, and how do you know this?
18
What -- again, what portion of the -- of
THE WITNESS:
To my knowledge, the funding for
19
this organization mostly came from drug trafficking,
20
Your Honor.
21
22
23
THE COURT:
They also ask:
How do you know
this?
THE WITNESS:
Your Honor, I know this because
24
in all areas -- well, in where there was presence of
25
the AUC in Urab or -- or there was Pedro Hasbn,
561-835-0220

80
31
H.H., and El Alemn, there was -- tax was collected
for each kilo of drugs that was trafficked.
kilo trafficked, 50 U.S. dollars paid per kilo.
was by order of Vicente Castao.
THE COURT:
Question No. 12:
For each
This
Did the AUC
collect vaccines, extortion, and bribes?
companies paid for this?
for -- or to make those payments?
those who refused -- if so, what happened to those
10
11
Which
Did anyone refuse to pay

What happened to
who refused?
THE WITNESS:
Your Honor, in the areas where
12
the AUC entered, there had been taxes collected by
13
the guerrilla long before those were collected from
14
cattle businessmen.
15
burn their farms, kill their managers.
16
Whoever didn't pay, they would
When the AUC entered these areas, they did it
17
in -- in a lighter way.
18
collected 100 pesos, the paramilitary would collect
19
50 pesos tax.
20
So if the guerrilla
The AUC entered these areas and it stayed
21
there.
22
was -- had business in those areas with presence of
23
the AUC would pay, would make these payments.
24
25
So farmers, businessmen, companies, whoever
Your Honor, there were even businessmen who saw

that in areas where AUC group -- entered by AUC
561-835-0220

80
32
groups were -- were formerly -- with former guerrilla
presence, where the -- where the cattle businessmen
may return, these businessmen sought out -- sought
out Vincente and Carlos.
versions.
Vicente and Carlos for them to form armed groups in
the area of Valle del Cauca.
businessmen from the sugar cane -- from the sugar
mills, for them to form armed groups in this area.
10
This was stated in previous
Over ten or 12 businessmen approached
THE COURT:
They would approach the
Question No. 9:
Do you have
11
personal and firsthand information regarding payments
12
from Chiquita Brands to paramilitary?
13
14
15
THE WITNESS:
No, Your Honor, I don't -- I do
not.
THE COURT:
Question No. 10:
Do you have any
16
personal or firsthand information regarding payments
17
made by the Convivir Papagayo, Tagua de Darien, and
18
Punta de Piedra to the AUC?
19
THE WITNESS:
No, Your Honor.
But I would like
20
to clarify that these convivir were under the command
21
of Mr. Ral Hasbn.
22
Your Honor, I would like to clarify.
These
23
convivir were organized by Ral Hasbn, alongside
24
Vincente and Carlos Castao.
25
is something that I just heard.
I wasn't present.
This
Ral told Vicente
561-835-0220

80
33
that this convivir needed to be organized in order to
collect funding from businessmen.
under the administration of former president --
4
5
THE COURT REPORTER:
Those were formed
I'm sorry, former
president?
THE INTERPRETER:
THE COURT:
Alvaro Uribe Velez.
Question No. 11:
Have you met or
had any communication with executives,
representatives, or officials of Chiquita?
10
THE WITNESS:
11
THE COURT:
No, Your Honor, I have not.
Question No. 12:
Have you killed,
12
ordered the killing, or participated in the killings,
13
of individuals?
14
participate?
15
If so, how many, and how did you
THE WITNESS:
Your Honor, with all due respect,
16
I don't understand the question.
17
included in my free versions before prosecutors and
18
attorneys.
19
MS. VAHLSING:
This is all
Your Honor, if I may, on behalf
20
of the plaintiffs, it is not necessary for us that
21
this question be answered.
22
the defense counsel, since it's their question.
23
THE COURT:
24
THE WITNESS:
25
But we should hear from
The question was already answered.

I just wanted to clarify one --
when the oath was taken, the witness was told that he
561-835-0220

80
34
1
2
would have certain guarantees.

THE COURT:
Is this correct?
It is repeated.
You're -- you're
not compelled to declare against yourself, your
permanent companion, or your children.
guarantee that is provided to you.
6
7
8
9
Question No. 13:
This is a
Did you help in killing or
organizing the killing of Carlos Castao?

THE WITNESS:
Your Honor, this is part of my
confession in the justice and peace law.
Prosecutors
10
and justices already have this confession.
11
like to request for you to respect this confession.
12
THE COURT:
I would
Did the prosecution try to remove
13
you from the justice and peace law process, because
14
they estimated that you had lied in your testimony?
15
THE WITNESS:
Your Honor, unfortunately in this
16
process we were summoned to tell the truth.
17
whenever we affected important figures of the
18
country, so to speak, we were deemed as -- as liars.
19
But
I have had very honest prosecutors, as well
20
as -- there are honest prosecutors, as well as
21
corrupt prosecutors.
22
Ms. Liliana Calle who replaced Dr. Aponte.
23
didn't review my documents, and she immediately
24
requested for me to be removed from the justice and
25
peace law -- for my removal from the justice and
For instance, I had a
561-835-0220
She

80
35
1
2
peace law.
Fortunately, I had the support of over 4,000
victims.
from the justice and peace law, as well as nine
judges from Bogot.
They stated that they -- against my removal
THE COURT:
Question No. 15:
Before today,
have you spoken to any representatives of the
defendants in the case against Chiquita Brands?
9
10

MS. VAHLSING:
Objection to translation.
11
believe word used was "demandantes, and that it was
12
for plaintiffs.
13
14
THE COURT:
15
16
17
18
question.
I would like to repeat the
Maybe I read wrong.
Maybe I misread.
Before today, have you talked to anyone

regarding the claims against Chiquita?
THE WITNESS:
Your Honor, not today, and not
19
for the nine years that I have been in prison have I
20
discussed anything related to this process, Your
21
Honor.
22
THE COURT:
Question No. 16:
Has someone asked
23
you to provide testimony regarding Chiquita, or has
24
anyone given you an affidavit for you to sign
25
regarding Chiquita?
If so, who?
561-835-0220

80
36
THE WITNESS:
Your Honor, no one has approached
me regarding this.
refuse, because my goal is to tell the truth, even if
this affect figures and businessmen.
If they did, I would -- I would
The interpreter would
like to request for the witness to clarify regarding
this answer.
8
9
(Spanish between Interpreter Barrera and

witness.)
10
THE WITNESS:
And I wouldn't let anyone
11
influence me into providing testimony that is not
12
true.
13
I wouldn't let this happen.

THE COURT:
Question No. 17:
Has anyone
14
approached you, or anyone that you know, with --
15
offering valuables for you to testify in favor of
16
Chiquita?
17
18
If so, who?
THE WITNESS:
No, Your Honor, I haven't been
offered, absolutely nothing.
19
20
MR. ARVELO:
For the record, I wanted to
21
correct another translation error, if I may, Your
22
Honor.
23
offered you, or anyone you know, anything of value to
24
testify about Chiquita, not in favor of Chiquita.
25
That the question was:
THE COURT:
Has anyone given or
I think that he didn't understand
561-835-0220

80
37
the question.
it is written here, and you can discuss it in the
court with the judge.
The Court is reading the question as
Question No. 18:
Has anyone provided, offered,
or paid for security protection for you, or anyone
you know?
If so, who?
THE WITNESS:
Your Honor, at this moment, the
only entities that are providing security for me are
10
the National Penitentiary Institute and the attorney
11
general's office, no one else.
12
THE COURT:
Question No. 19:
Are any of the
13
Colombians suing Chiquita at risk from reprisals from
14
you, for having sued Chiquita?
15
THE WITNESS:
Your Honor, I would never.
In
16
regard to me, they can sleep tight and they can know
17
for sure that I do not represent any danger to these
18
people.
19
Your Honor, if you would allow me, I would like
20
to add in front of the attorneys of the victims, and
21
many more victims that are not present, that this
22
should be done convicted, and should be paid for.
23
All the businessmen, the politicians, that paid for
24
this -- for this organization to kill fellow
25
Colombians, hurt greatly the country with all the
561-835-0220

80
38
contributions from politicians: weapons, ammunition,
and uniforms were bought.
that this shouldn't go without a conviction.
So I would like to state
MS. VAHLSING:
would like to clarify that the witness also said that
there were contributions from both companies and
politicians for weapons and ammunition and uniforms.
I'd like to clarify that with the witness, please.
10
Thank you.
11
12
THE COURT:
13
We have finished with the questioner from the
14
15
So noted.
defendant.
It also says here from -- coming from the judge
16
in the Florida court, that the plaintiffs may ask
17
questions as well.
18
Let's clarify something.
Let us not repeat
19
questions that have been answered already.
20
please take into account that the witness isn't
21
compelled to declare against himself.
22
23
Who is asking questions?
And
Your name for the
record?
24
25
MS. VAHLSING:
My name is Marissa Ann Vahlsing.
561-835-0220

80
39
I am an attorney from the United States.
acting in the case on behalf of the victims who are
the plaintiffs in this case, with the exception of
the victims represented by the attorney Paul Wolf.
THE COURT:
MR. DURAISWAMY:
And I am
You may state your appearance.

Your Honor, may I make a brief
statement before Ms. Vahlsing begins her questioning?
THE COURT:
MR. DURAISWAMY:
About what issue?

Your Honor, the parties agree,
10
consistent with the procedure at U.S. depositions,
11
that all objections to questions are reserved except
12
for objections to the form of the question.
13
Accordingly, the attorneys may make objections
14
to the form of the question made by -- asked by
15
either side, but this will be decided later by the
16
U.S. judge, and should not affect the examination
17
here.
18
written record.
19
THE COURT:
It is just to state the objection on the
So noted.
It states -- so states
20
here that the objections will be resolved -- decided
21
by the judge at a later time.
22
MR. MORALES:
Your Honor, Alex Alberto.
Again,
23
good afternoon to you, Your Honor.
24
Morales Cordoba and I represent Paul Wolf as an
25
assisting attorney.
I'm Alex Alberto
He is the attorney for more than
561-835-0220

80
40
4,000 families of victims of the violence in Urab.
And I also would like to request that I be given the
opportunity to ask questions of the witness.
MS. VAHLSING:
THE WITNESS:
If I may be heard?
Your Honor, with all due respect
to you, and to all those present, I would like to
again clarify that I had no participation and no
knowledge of negotiations between the company that
you mentioned, or companies that you mentioned.
10
We've been here talking about it for an hour and a
11
half, two hours, and I have no knowledge.
12
And I would ask you -- I'm open to an
13
investigation being opened regarding myself and to
14
determine whether or not I have any -- any knowledge.
15
But I would ask you, today is Wednesday, today is the
16
visiting day, and my family is here at the prison.
17
don't know if you can help me with this, but I have
18
no knowledge of this company.
19
information of the person who has all of the
20
knowledge, who can tell you specifics about the dates
21
of meetings, with whom, how much money was paid, if
22
it was voluntary, if there were threats, and that
23
person is Ral Hasbn.
24
25
And I have given the
I have no knowledge whatsoever.
I wish that I
did have such knowledge, in order to be able to get
561-835-0220

80
41
to the bottom of it.
wish I had been present at a meeting with Vincente
and Carlos and Ral Hasbn and Chiquita, so that I
would have the knowledge and I could provide the
knowledge to you, and to the justice and peace
commission.
have no knowledge.
8
9
10
But I have no knowledge.
But I swear to you, Your Honor, that I
THE COURT:
You have every right to see your
family and that cannot be violated.
Until what time
is that occurring?
11
THE WITNESS:
12
afternoon, Your Honor.
13
THE COURT:
Until 4:00 o'clock in the
So we will spend an hour, because
14
the attorneys for the plaintiff and the defendant
15
also have the right to ask questions.
16
THE WITNESS:
17
THE COURT:
18
21
Okay.
Okay.
Attorneys for the
plaintiffs.
19
20
Agreed.
Agreed?
DIRECT EXAMINATION
BY MS. VAHLSING:
Q.
I'm going to begin an introduction in Spanish
22
to the witness and then I will proceed in English.
23
(In Spanish) Good afternoon, Sr. Rldan.
Thank
24
you for your time and your attention.
25
today is the family visit day and that you wish to see
I understand that
561-835-0220

80
42
your family.
I understand that that is very important.
understand that there may be things about which you do
have some knowledge, and we will try to clarify which
matters those may be in a short period of time, so that
you will be able to see your family.
We want you to be able to see your family.

I also
I want to thank you very much for cooperating
with this testimony, for taking -- for taking the time.
We have travelled very far to see you, and I want to
10
thank you again very much for your cooperation.
11
My name is Marissa Vahlsing and I am an
12
attorney in the United States, representing victims in a
13
civil suit in the United States against Chiquita and some
14
of their high-level executives.
15
clarify, is exclusively against that company and some of
16
its high-level executives.
17
And that case, I want to
(In English) Mr. Rldan, you mentioned earlier
18
that you gave testimony in the justice and peace process.
19
I am handing you what we believe is a transcript of a
20
testimony that you gave on the 11th of September of the
21
year 2007.
22
Do you recognize this testimony?
23
A.
Well, I'd have to read all of this.
24
Q.
How about I draw your attention to page -- hold
25
on one second -- to the last page of the document.
561-835-0220

80
43
1
2
THE COURT:
A moment, question.
The Court asks
counsel if this document is complete.
MS. VAHLSING:
Counsel wishes to state for the
record that this document was provided to us by the
defendants' counsel during an exhibit exchange.
have the same question.
7
8
INTERPRETER HAND:
We
The witness attorney, the
defense attorney?
MS. VAHLSING:
10
THE COURT:
No, the defense counsel.
Because this is not a testimony.
11
This is a free version.
12
statement, is something that is received in Colombia
13
when a person may be a victim or a party to a case.
A free version, or voluntary
14
So, please reformulate your question taking
15
into account these clarifications offered by the
16
Court.
17
18
19
MS. VAHLSING:
Okay.
BY MS. VAHLSING:
Q.
Mr. Rldan, if you could, please turn to the
20
last page of the document and review the text on that
21
last page.
22
A.
I would ask that you read it for me.
I didn't
23
bring my glasses and I can't see well, so if you could
24
read it for me, please.
25
MR. CALDERON-MEZA:
Juan Pablo Calderon.
561-835-0220

80
44
May the interpreter have
a moment to locate the text?
MR. CALDERON-MEZA:
4
5
It starts on the previous
page.
THE COURT:
You said the last page.
The last
page says, "I am talking about the zone of San Pedro
de Urab.
8
9
That's what the question referred to.
MR. CALDERON-MEZA:
It says the following:
"I
am talking about the zone of San Pedro de Urab, and
10
then the zones of Turbo, Apartad, Carepa, and
11
Chigorod.
12
There, they did have to pay.
13
companies all had to pay.
14
zone of Hernn Hernndez, they paid.
15
Michael, they paid.
16
Postobn, beer companies.
17
pays something, and they paid voluntarily because
18
they were --
There was a different kind of management.

All of the banana
It was managed -- in the

In the zone of
Companies paid, for example,
19
20
INTERPRETER HAND:
Everyone who had companies
Excuse me, Your Honor.
The interpreters are
21
consulting regarding a term.
22
MR. CALDERON-MEZA:
23
THE COURT:
24
MS. VAHLSING:
25
THE WITNESS:
Under pressure.
Did you understand the question?

There was no question.
I would like to -- I understand
561-835-0220

80
45
that -- well, I would like to clarify that Michael
was the second commander of Ral Hasbn, of Pedro
Hasbn.
with businessmen, agricultural producers.
commander.
Michael was the one in charge of meeting

He was the
You asked a question about the Postobn, and
that the companies paid voluntarily and, well, what I
want to say is that with guerrillas in there ruining
all of the companies by paying -- charging extremely
10
high taxes, when the self-defense groups started
11
coming in and they were charging way less taxes, all
12
of them looked to finance the self-defense groups.
13
Logically, some of them also did it out of fear.
14
of course, nobody likes to give away the money out of
15
their pockets.
16
did pay it voluntarily because they saw that the
17
self-defense groups were providing security, and they
18
wanted to protect their wealth.
19
20
21
22
And
But the -- but many of the companies
BY MS. VAHLSING:
Q.
Mr. Rldan, I'm wondering if you could tell me
how you knew this.

A.
Well, let's see.
As, you know, Your Honor, in
23
2007 we were just starting with -- to tell versions.
24
prosecutor's office didn't even know what justice and
25
peace was.
The
It was a process that was just starting, it
561-835-0220

80
46
was being invented.
I told what I knew, but I was not there.
I did
not go to Postobn and talk with the manager.
things that I heard, hearsay.
justice and peace process, the official, Nubia Chavez,
wanted to know what was going on in Turbo, Apartad --
Turbo, Apartad, and these areas, and Mr. Castao had
fled.
information.
10
These are
So the justice -- in the
And so there was going to be a big void in the
And so I said what I knew.
Vincente would go
11
and talk to Pedro and then say -- tell me, so-and-so is
12
going to be charged, this and that.
13
was not there.
14
these -- this was -- these are versions starting in 2007,
15
because they wanted to advance with the process.
16
But it's not -- I
These are things that I heard.
And
And then Mr. Castao did turn himself in and
17
began to collaborate and, in my opinion, Your Honor, he
18
is collaborating, he is telling the truth.
19
INTERPRETER HAND:
And the interpreter would
20
like to state that the interpreter missed the last
21
portion of the answer and would like to request a
22
repetition, or request that the attorney re-ask the
23
question.
24
25
And the interpreter would also like to request

that the witness be instructed to give shorter
561-835-0220

80
47
answers.
THE COURT:
(In Spanish between the Court and Ms. Cadavid.)
THE COURT:
MS. VAHLSING:
THE WITNESS:
Sure.
But we will replay the tape.

Okay.
So the last question that the
doctor asked me was about the financing of Postobn,
and how did I know.
what I heard.
And I said that I knew this by
And at that time Mr. Pedro Hasbn had
10
not been detained and Ms. Chavez wanted me to say --
11
to tell everything that I knew.
12
MS. VAHLSING:
For the record, I'd like to
13
clarify that my question was not specific to
14
Postobn.
15
THE COURT:
16
THE WITNESS:
He has not finished.

So you asked me how did I know.
17
I heard it, because I was not there in those
18
negotiations with Postobn, or the other companies.
19
But I would like to ask the attorney to listen
20
to Ral Hasbn.
21
dollars, in pesos, by Postobn, by Chiquita, by all
22
of the companies and all of the businessmen.
23
24
25
THE COURT:
He can tell you how much was paid in
Another question.
BY MS. VAHLSING:
Q.
You mentioned that you heard this information
561-835-0220

80
48
from others.
this information from anyone else?
3
4
A.
7
8
9
10
I heard it from Vincente Castao, who gave
orders to Ral Hasbn.
5
6
In addition to Ral Hasbn, did you hear

By MS. VAHLSING:
Q.
What type of orders was Vincente Castao giving
to Ral Hasbn, if you know?

MR. DURAISWAMY:
THE WITNESS:
Object to the form.
I repeat, that regarding the
11
financing in Urab, Vincente Castao is dead,
12
unfortunately.
13
information is Mr. Ral Hasbn.
14
So the person who can provide that
If I knew, trust me, with all due respect, that
15
I would sit here and tell you everything that I --
16
that I would know.
17
anything regarding Urab, or the financing in Urab,
18
or the banana companies.
19
here for days and tell you all about this would be
20
Ral Hasbn.
21
THE COURT:
But I don't.
I -- I don't know
The person who could sit
Excuse me.
Since Mr. Rldan has
22
his family waiting for him, and he has been in prison
23
for many years, he has every right to see them.
24
would like to ask for the plaintiffs to ask two more
25
questions, and allow the defendants to ask their
561-835-0220
So I

80
49
questions.
MS. VAHLSING:
If I can request, Your Honor,
for you to give us 30 seconds, or one minute, to
discuss among the plaintiffs what are the questions
that we would like to raise.
THE COURT:
MS. VAHLSING:
Should we continue?
Yes, we're ready, Your Honor.
BY MS. VAHLSING:
10
Q.
My first question is:
Mr. Rldan, when you
11
heard about conversations about financing, were you a
12
member of the AUC?
13
A.
Yes, Counselor.
14
Q.
And the rest of the people who you heard these
15
conversations from, were they members of the AUC at the
16
time?
17
A.
18
19
MS. VAHLSING:
question.
20
21
22
23
24
25
Yes, Counselor.
That was part of a single
Is it okay if I proceed?
THE COURT:
Very sure.
BY MS. VAHLSING:
Q.
Mr. Rldan, were you ever charged with
extorting Chiquita or Banadex?

A.
Not to my knowledge, not -- not to the day.

THE COURT:
You can ask a couple of more
561-835-0220

80
50
questions.
We can --
MS. VAHLSING:
THE COURT:
MS. VAHLSING:
5
6
Okay.
-- go for a little bit longer.

Okay.
BY MS. VAHLSING:
Q.
Mr. Rldan, do you know the identities of any
the individuals who are plaintiffs against Chiquita, in
the lawsuit against Chiquita Brands, in the United
States?
10
A.
No, Counselor.
11
Q.
Mr. Rldan, do you know if records were kept
12
13
14
for the financing of the AUC?

A.
Every commander kept those records in their
areas.
15
Q.
Do you know if those records exist today?
16
A.
We would have to ask the commander, for
17
18
19
20
21
22
instance, in this case, Mr. Ral Hasbn.

Q.
Sr. Rldan, do you know if the AUC ever
received shipments of arms from outside the country?

A.
That is to say, that they came from a foreign
country?
Q.
I can clarify.
Do you know if the AUC ever
23
received arms on ships that arrived at ports in Colombia,
24
on boats from outside of the country, outside of
25
Colombia?
561-835-0220

80
51
1
2
A.
Yes, Counselor.
I have knowledge of a big
weapons shipment that came to the Urab Gulf.
The person who has all the knowledge regarding
this is Mr. Ral Hasbn, because he was the person who
received that shipment.
6
7
Q.
Did Ral Hasbn tell you anything about that
arms shipment that arrived in the port in Urab?
MR. DURAISWAMY:
THE WITNESS:
Object to the form.
He didn't tell me anything
10
personally, but that a weapons shipment came, or
11
reached Vincente Castao himself.
12
13
14
15
16
17
18
BY MS. VAHLSING:
Q.
Did Vincente Castao tell you anything about
the arms shipment?

A.
He said that it -- that shipment arrived the
Gulf of Urab.
Q.
Did you ever hear if the ship arrived at a port
of Banadex?
19
MR. DURAISWAMY:
20
THE WITNESS:
Object to the form.
I don't -- I don't have
21
knowledge.
22
a certain area, but I -- I don't have further
23
knowledge of the shipment.
24
arrived to Urab specifically.
I just know that that shipment arrived to
And I don't know if it
25
561-835-0220

80
52
BY MS. VAHLSING:
Q.
Mr. Rldan, in addition to giving the versin
libres as a part of the justice and appeals process, did
you take any other steps during your demobilization?
MR. DURAISWAMY:
THE WITNESS:
Object to the form.
I don't understand.
What do you
mean by "adopting"?
like to state for the record that the word "adopting"
10
was part of the interpretation in Spanish, and not
11
literal from the question itself.
12
THE COURT:
Excuse me, if you -- if you
13
collaborated otherwise, different from the free
14
versions.
15
16
MS. VAHLSING:
I can reformulate.
BY MS. VAHLSING:
17
Q.
Sr. Rldan, did you provide the authorities in
18
Colombia with any other source of information, other than
19
oral testimony, during the demobilization process?
20
A.
In many, a thousand different ways.
21
Q.
Did any of that information include documents?
22
A.
Documents?
Are you referring to land
23
scriptures, or what type of documents are you referring
24
to?
25
Q.
I can be more specific.
561-835-0220

80
53
1
2
3
I'm wondering if you handed over any e-mails of

Vincente Castao?
A.
4
5
6
7
Yes, in the justice and peace process.

THE COURT:
Last question.
BY MS. VAHLSING:
Q.
Last question.
Can you tell us what those
e-mails said?
MR. DURAISWAMY:
THE WITNESS:
10
MS. VAHLSING:
12
question.
13
insist.
14
16
17
It would take a year for me to do
so.
11
15
Object to the form.
I think it was the last
It was the last question, I wouldn't
THE COURT:
Do you have another question
related to that question?

BY MS. VAHLSING:
Q.
Okay.
So along the same lines my question is:
18
Did any of those e-mails, to your knowledge, mention
19
Chiquita?
20
MR. DURAISWAMY:
21
THE WITNESS:
Objection.
Form.
Foundation.
I had provided a thumb drive that
22
belonged to Vincente Castao, where he mentioned a
23
lot of people.
24
suggest for you, Counsel, to request that -- that
25
information.
I would like to request for you -- I
561-835-0220

80
54
1
2
THE COURT:
Wolf.
3
4
5
The representative of Attorney Paul
CROSS-EXAMINATION
BY MR. MORALES:
Q.
Thank you very much, Mr. Jesus Ignacio Rldan,
for your time and your clarity.
because I would like for you to enjoy the company of your
family.
I won't take very long,
I would like to ask you regarding a term that
10
you used.
11
what does the term "vaccines" mean?
12
13
The question is, for the AUC and yourself,
(Ms. Chomsky left the proceedings in progress.)

A.
Counsel, for the AUC, "vaccines" referred to
14
funding.
15
businessman, or a cattle raiser, and you tell them, for
16
instance, to provide 10 million pesos.
17
means, funding.
18
Q.
This is when you approach a company, a
That's what it
Mr. Jesus Ignacio Rldan, can you specify, or
19
clarify, what was the purpose of the AUC whenever they
20
received this funding?
21
MR. DURAISWAMY:
22
THE WITNESS:
23
would like to clarify.
24
pay members that were patrolling the areas, to get
25
medicine, to buy groceries, weapons, and ammunition,
Objection.
Foundation.
Form.
I think I said it already, but I

This funding would be used to
561-835-0220

80
55
and helicopters that the AUC had.
(Ms. Chomsky rejoined the proceedings in
progress.)
BY MR. MORALES:
Q.
Mr. Rldan, can you clarify, or elaborate in
your own words, do you think that Chiquita Brands or
Banadex paid those vaccines to the AUC?
8
9
10
MR. DURAISWAMY:
foundation.
Objection.
Lack of
Form.
THE WITNESS:
As I said before, I did not
11
attend these meetings, so I wouldn't be able to say
12
how much that -- did this company pay.
13
Mr. Ral Hasbn, as I've said before, is the
14
person who has all the knowledge regarding this
15
situation.
16
Also, I think -- I cannot assure, but I think
17
Commander Jorge Cuarenta, who is currently in prison
18
in the United States, has information regarding this.
19
Being in prison in Pavilion 1 here, in this --
20
in this prison facility, I overheard Jorge saying
21
that -- that this company, Chiquita, paid him.
22
again, I would like for you to approach and try to
23
get to Jorge Cuarenta, Commander Jorge Cuarenta, to
24
get more information regarding this issue.
25
THE COURT:
Counsel for the defendants.
561-835-0220
But

80
56
1
2
3
CROSS-EXAMINATION
BY MR. DURAISWAMY:
Q.
Thank you, Sr. Rldan.
I apologize, we did not
know this was being done on a day that you were expecting
visitors.
be very happy to let you go and see your family.
I have just a few questions, and then we would
Mr. Rldan, do you have any reason to believe
that Salvatore Mancuso has any firsthand personal
knowledge about interactions between the AUC and
10
Chiquita?
11
12
MS. VAHLSING:
Objection.
14
like to clarify the question.
15
repeat the question?
16
MR. DURAISWAMY:
18
Lack of
foundation.
13
17
Form.
Could you please
Sure.
By MR. DURAISWAMY:
Q.
Mr. Rldan, do you have any reason to believe
19
that Salvatore Mancuso has any firsthand personal
20
knowledge about interactions between the AUC and
21
Chiquita?
22
MS. VAHLSING:
23
THE WITNESS:
Objection.
Form.
Counsel, Salvatore Mancuso was a
24
member of the AUC, of the Castao house, who served
25
under the Castao house under Carlos and Vincente.
561-835-0220

80
57
He knew about all the companies funding the AUC.
He entered as a commander -- he started in 1995
under the Castao house.
to Cordoba, and then Magdalena.
Carlos, Vincente, and Salvatore Mancuso would meet at
least -- would meet frequently, at least four times a
week, and they would tell all.
Salvatore Mancuso attended several of those meetings
regarding -- in which it was discussed, companies and
10
He went from Urab, went on

So I would say
So I know that
the funding of the AUC.
11
I would like to clarify to you, Your Honor, and
12
to you, Counsel, that Salvatore Mancuso was the
13
commander under Jorge Cuarenta.
14
15
MS. VAHLSING:
18
19
20
THE WITNESS:
Jorge Cuarenta.
Mancuso was the commander over
Jorge Cuarenta was below Mancuso.
BY MR. DURAISWAMY:
Q.
Mr. Rldan, is Mr. Hasbn in this prison
currently?
21
22
Was
he under or over Jorge Cuarenta?
16
17
MS. VAHLSING:
Objection.
Form.
BY MR. DURAISWAMY:
23
Q.
If you know.
24
A.
Yes, yes, he is in this prison right now.
25
Q.
Do you consider him to be a friend?
561-835-0220

80
58
A.
Both friend and a serious man.
Q.
Has Mr. Hasbn ever told you he was in
discussions with U.S. lawyers to receive money for
providing testimony in these cases?
MS. VAHLSING:
THE WITNESS:
7
8
Form.
No, he never did.
BY MR. DURAISWAMY:
Q.
9
10
Objection.
Has he ever talked to you about this case?

MR. MORALES:
Your Honor, the witness has
answered that question several times already.
11
THE COURT:
12
THE WITNESS:
Go ahead and answer it.

I know, and he has told me that
13
he has knowledge regarding all the companies that
14
provided funding for the AUC, including Chiquita
15
Brands.
16
heard, but -- and that he has told me.
17
something that I know firsthand.
18
that he -- that Mr. Hasbn knows who paid how much,
19
how many companies, how the shipment got -- how the
20
weapons shipment got to Colombia, who brought it.
21
know this is all information that Mr. Ral Hasbn
22
knows.
23
24
25
I -- again, this is something that I've

This is not
But I -- I know
BY MR. DURAISWAMY:
Q.
And other than Mr. Hasbn and Vincente Castao,
you're not aware of any other individual who is
561-835-0220

80
59
knowledgeable about interactions between the AUC and
Chiquita; is that correct?
A.
The people that may know a lot more about this
are probably dead, but were Carlos and Vincente Castao.
Some other people may know, may have
information regarding this, such as Freddy Rendn
Herrera, who was close with Pedro, and they were -- they
were close friends, and they were also commanders in
nearby areas.
10
11
THE WITNESS:
Your Honor, I would also like to
12
say that there is another person who is
13
collaborating, both with the justice and peace
14
process and with cases in the United States, who has
15
been extradited, and that's Hebert Veloza, H.H.,
16
care-pollo, because he was in charge of the
17
neighboring -- the area neighboring Pedro's area.
18
And so he was in constant communication with Vincente
19
Castao and Pedro Hasbn.
20
also have information about the those who financed
21
and supported the AUC in that those regions.
22
23
24
25
And so I believe he would
BY MR. DURAISWAMY:
Q.
Did Mr. Rendn ever tell you personally that he
has -- he was involved in interactions with Chiquita?

MS. VAHLSING:
Objection.
Form.
561-835-0220

80
60
1
2
3
4
5
INTERPRETER HAND:
I'm sorry, Counsel, did you
say Mr. Rendn?

By MR. DURAISWAMY:
Q.
Rendn ever tell you personally that he was
involved in interaction with Chiquita?
A.
No, Counsel.
Q.
And did Salvatore Mancuso ever tell you
personally that he was involved in interactions with
Chiquita?
10
A.
Well, these were commanders, Counsel, who were
11
in communication, ongoing communication, meetings, with
12
Carlos Vincente, Salvatore Mancuso.
13
room, in a kiosk, frequently, and talk about all of these
14
things.
15
counsel.
16
But did Salvatore tell me personally?
Q.
No,
Sr. Rldan, thank you so much for your time.
17
have no more questions.
18
to meet with your family today.
19
They would meet in a
A.
I hope you have an opportunity
Thank you very much to all of you.
20
MS. VAHLSING:
Thank you as well, on the part
21
of the plaintiffs, the victims, we thank you very
22
much.
23
24
25
THE WITNESS:
Thank you very much, and may God
bless you.
(Jesus Ignacio Rldan Perez was excused at
561-835-0220

80
61
1:05 p.m.)
THE COURT:
Given the time that was set aside
for this hearing, I would ask you if it would be
necessary to identify another date to continue with
the examination of this witness.
you can consult among yourselves.
If you would like,
Another point -- and another point, another
attorney came, who represented herself as the
attorney of Freddy Rendn Herrera.
They were unaware
10
that the hearing was today, they went to a different
11
court, to the Second Civil Circuit, and this is the
12
penal criminal circuit.
13
So there was an error there.
She did not authorize us to give out this phone
14
number, but the name, yes.
15
Ayala.
16
provide testimony, and you all can get in touch with
17
her.
18
Her name is Victoria
And she also said that he is prepared to
So the questions are, if you need for Ignacio
19
Rldan to give more testimony and, also, if you would
20
like to hear from Freddy Rendn Herrera.
21
MR. DURAISWAMY:
Your Honor, for the
22
defendants, we believe it is clear that Mr. Rldan
23
does not have knowledge of information relevant to
24
this case.
25
schedule an additional date of testimony for him.
So we do not believe it is necessary to
561-835-0220

80
62
THE COURT:
The representative of Attorney Paul Wolf.
MR. MORALES:
Thank you very much.
Your Honor, I believe that
Mr. Jos Rldan has stated what he knows.
think it is necessary.
MS. VAHLSING:
I do not
Your Honor, on the part of the
rest of the plaintiffs, we apologize that we cannot
take this decision today.
number of teams that we coordinate with, and I'm not
We need -- we have a
10
authorized to speak on their behalf without
11
conferring with them.
12
do not think it should be necessary, but I cannot
13
confirm that until I speak with the other teams.
14
But I can say now, that I -- I
Insofar as Mr. Rendn, we do wish to continue
15
with his testimony, if that is possible in any way.
16
We do reserve our right to take that testimony.
17
Thank you.
18
(Conversation between the Court and clerk.)
19
MR. DURAISWAMY:
20
Your Honor, may I articulate
the perspective of the defendants?
21
THE COURT:
22
MR. DURAISWAMY:
Yes, of course.
Your Honor, the defendants
23
believe that it's not necessary to proceed with
24
scheduling the date for Mr. Rendn's deposition,
25
given that the reason that the U.S. Court allowed the
561-835-0220

80
63
deposition to be taken is that he was in prison, and
that is no longer the case.
Having said that, this may be an issue that we
need to take up with the judge in the United States.
And we believe that we will -- we recognize that it
is within the authority of the Court in the United
States and the Court in Colombia to decide on this
issue until we -- until we discuss the issue further.
MS. VAHLSING:
Your Honor, with all due
10
respect, on the part of the plaintiffs, I would like
11
to say that I do believe that this issue of whether
12
or not Sr. Rendn's testimony should still be taken
13
is a matter that I respectfully leave to the court in
14
the United States, although I understand that it will
15
also need to be coordinated with the authorities
16
here.
17
In addition to the motivation that -- for the
18
letters being issued, that Mr. Rendn was in the jail
19
at that time, and that he has now been released, the
20
Court also recognized that there were other reasons
21
for granting the request, in addition, that he would
22
have every incentive to go underground, to hide,
23
after his release, and that he is being threatened,
24
and other arguments were made to the Court that also
25
factored into the decision by the Court to grant that
561-835-0220

80
64
request.
We also bring to this Court's attention that
even after Mr. Rendn's release from prison, about
two weeks ago, if I have the date correct, the Court
in the United States continued to issue amended
letters rogatory authorizing his testimony under U.S.
law.
Thank you.
THE COURT:
MR. MORALES:
That's enough.
I would also like to make a
10
statement for the record.
11
just stated by the attorney for the plaintiffs.
12
I would also like to make it clear for the
I support the position
13
record, and for the recording, that Mr. Rendn has
14
the obligation to collaborate with the justice and
15
peace commission, also to collaborate with
16
reparations, and also to provide clarification.
17
being free, he still has that obligation to
18
collaborate.
19
Even
Thank you.
MR. ARVELO:
Just for the record -- just for
20
the record, there was mistranslation.
21
he said that he agreed with the defendants as opposed
22
to the plaintiffs.
I believe that
23
24
MR. ARVELO:
25
(Conversation between Court and clerk.)
I stand corrected.
561-835-0220

80
65
INTERPRETER HAND:
So he objected to the
translation and asked the witness, did you say that
you agree with the defendant -- what the position of
the plaintiffs or the defendants.
clarified that he was expressing agreement with the
position of the plaintiffs.
corrected.
8
9
10
11
THE COURT:
And the gentleman
And he said I stand
The Court, therefore, being part of
the commission regarding Freddy Rendn Herrera, shall

maintain such to be heard.
The logistical details depend on the parties
12
and the security team of this person, which he
13
certainly has, taking into account what the person
14
who attests to be his attorney said.
15
And this Court is willing to provide the
16
service for localization.
17
decision regarding this point.
So we will await the
18
MS. VAHLSING:
19
Thank you, Your Honor.
May I ask a question?

Just a question, a
20
small question for the parties.
21
would be possible to take testimony outside of the
22
jail in the case of Mr. Rendn.
23
might be easier to hold the testimony in another
24
location.
25
THE COURT:
I don't know if it
I don't know, it
So to conclude, so we then will
561-835-0220

80
66
review the judicial calendar and define the details
at a later date, in terms of a date and time, and
please advise us.
4
5
This session is closed.

*****
(The deposition was concluded at 1:20 p.m.)
(Reading and signing of the deposition was
waived by the witness and all parties.)
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
561-835-0220

80
67
CERTIFICATE OF REPORTER
2
3
THE STATE OF FLORIDA,
COUNTY OF PALM BEACH.
5
6
I, Robin L. Merker, Registered Professional
Reporter, Florida Professional Reporter, certify that I
was authorized to and did stenographically report the
deposition of Jesus Ignacio Rldan Perez; pages 1 through
10
66; that a review of the transcript was not requested;
11
and that the transcript is a true record of my
12
stenographic notes.
13
I further certify that I am not a relative,
14
employee, attorney, or counsel of any of the parties, nor
15
am I a relative or employee of any of the parties'
16
attorneys or counsel connected with the action, nor am I
17
financially interested in the action.
18
19
Dated this 18th day of August, 2015.
20
21
22
____________________________________
Robin L. Merker, RPR, FPR
Registered Professional Reporter
Florida Professional Reporter
23
24
25
561-835-0220
Case 0:08-md-01916-KAM Document 944-4 Entered on FLSD Docket 11/24/2015 Page

69 of1
Page
80
A
a.m 1:20
able 28:2 29:4
40:25 42:1,6
55:11
ABOGADOS 2:21
absolutely 36:18
acceptable 20:10
accommodate 7:6
account 38:20
43:15 65:13
accurately 14:2
ACOSTA 3:2 5:8
acquire 17:15
act 24:13
acting 39:2
action 67:16,17
actions 1:7,10
28:3
acts 27:16
add 37:20
addition 23:3,8,22
48:1 52:2 63:17
63:21
additional 6:23
7:4,20 61:25
address 4:22,24
administration
33:3
adopting 52:7,9
advance 46:15
advise 66:3
affect 36:4 39:16
affidavit 35:24
affinity 8:24
affirmed 9:5
afternoon 7:17
39:23 41:12,23
ago 64:4
agree 22:3 39:9
65:3
agreed 41:15,16
64:21
agreeing 23:10
agreement 19:19
65:5
agreements 23:23
agrees 22:1
agricultural 45:4
ahead 6:14 58:11
aid 17:12,12
Alberto 2:14 4:14
23:14 39:22,23
Alemn 31:1
Alex 2:14 4:14
23:13 39:22,23
Alexlawyernumb...
2:14 5:1
alias 10:24 12:9
14:20
ALIEN 1:4
aligned 20:5
Alignment 18:7
allied 21:5
allow 37:19 48:25
allowed 29:18 30:1
62:25
alongside 32:23
Alta 25:14
Alvaro 33:6
amended 6:20 7:1
64:5
ammunition 17:16
17:24 18:3 38:1
38:8 54:25
Ann 2:10 38:25
answer 8:14 11:9
15:13,14,15
16:10,20 36:7
46:21 58:11
answered 11:20
33:21,23 38:19
58:10
answering 17:5
answers 21:21 24:5
47:1
Antioquia 1:22
9:17 25:5
Apartad 28:22
44:10 46:6,7
apologize 56:3
62:7
Aponte 34:22
appeals 52:3
appearance 39:5
appearances 2:1
4:11
appointed 13:3
approach 18:14
32:7 54:14 55:22
approached 32:5
36:1,14
Arch 2:4
area 25:16 26:8,10
27:1,21,22 32:7
32:9 51:22 59:17
59:17
areas 26:22 27:9
27:12,13,18
30:24 31:11,16
31:20,22,25 46:7
50:14 54:24 59:9
arguments 63:24
arm 28:18
armed 4:17 29:10

29:14 32:6,9
arming 28:21
arms 50:19,23 51:7
51:14
army 26:16,17
28:25
arranged 10:6
arrangement 14:13
14:21
arrangements 10:3
10:6 11:8 12:3,6
14:23
arrive 22:8
arrived 50:23 51:7
51:15,17,21,24
Article 8:20
articulate 62:19
Arvelo 2:20 5:25
5:25 12:13 14:1
36:20 64:19,24
aside 61:2
asked 20:15 21:23
22:9 28:14 35:22
39:14 45:6 47:7
47:16 65:2
asking 20:14,17
21:20 38:22
asks 43:1
Assistant 3:2
assisting 5:14 6:5
23:15 39:25
assure 55:16
ATS 1:7,10
attend 11:25 55:11
attended 57:8
attention 41:24
42:24 64:2
attests 65:14
attorney 4:16 6:3
6:8 18:25 20:9
20:10,12,19
22:10,24 23:4,15
23:17,18,21
37:10 39:1,4,25
39:25 42:12 43:7
43:8 46:22 47:19
54:1 61:8,9 62:2
64:11 65:14
67:14
attorneys 5:14 6:5
6:16 23:6 33:18
37:20 39:13
41:14,17 67:16
attributed 19:4
AUC 10:4,6,16,18
12:4,5 13:7 15:2
561-835-0220
15:8,9,18,22
16:2,15 17:13,15
17:21,25 18:2,8
18:9 19:21 20:5
21:6,10 24:15
27:3 28:3 30:5
30:15,25 31:5,12
31:16,20,23,25
31:25 32:18
49:12,15 50:12
50:18,22 54:10
54:13,19 55:1,7
56:9,20,24 57:1
57:10 58:14 59:1
59:21
August 1:19 4:1
67:19
authorities 52:17
63:15
authority 63:6
authorization
23:21
authorize 61:13
authorized 18:25
19:6 62:10 67:8
authorizing 23:4
64:6
auto 9:19
available 7:5
22:12
await 65:16
aware 58:25
Ayala 61:15
B
Banadex 10:16,17
13:12 14:7,12
15:3,8,17,22
16:1,11,14 17:13
17:14 18:2,10
19:23 20:4 21:4
21:9 49:23 51:18
55:7
banana 13:5,6,19
17:23 44:12
48:18
banana-growing
25:4
bar 5:18,23
Barrera 3:1 5:2,3
9:25 10:11 12:20
12:25 30:3 35:13
36:5,8 37:4
38:11 44:1,19
48:5 52:8 56:13
basically 29:20
basis 21:21 24:5

70 of2
Page
80
BEACH 67:4
bearer 5:12
beer 44:16
began 28:18,21
46:17
beginning 20:23
26:1
begins 39:7
behalf 2:2,15 4:4
6:15 16:10 18:22
19:1,14,15,18
23:11 33:19 39:2
62:10
believe 35:11
42:19 56:7,18
59:19 61:22,24
62:3,23 63:5,11
64:20
belonged 53:22
best 19:19
bien 24:1
big 46:8 51:1
bit 50:3
bless 60:24
blood 8:23
boats 50:24
bodyguard 24:19,25
25:9
Bogot 2:22 29:23
35:5
Bonito 10:25 12:9
14:20
born 9:10,17
bottom 41:1
bought 25:16 38:2
Box 2:3
branch 17:21
Brands 1:3 4:6 6:1
6:6 8:11 10:3,5
23:25 30:16
32:12 35:8 50:8
55:6 58:15
break 22:16
bribes 31:6
brief 39:6
bring 43:23 64:2
brother 25:21,25
28:9
brothers 9:20
17:21 24:20
25:25 26:12,18
27:8
brought 58:20
Brown 2:3,6 5:21
BURLING 2:16
burn 31:15
business 11:2
13:18 31:22
businessman 54:15
businessmen 10:24
11:2,3,18,18
12:12 13:5,5,6
13:18,19 17:23
17:24 31:14,21
31:24 32:2,3,5,8
33:2 36:4 37:23
45:4 47:22
buy 54:25
buying 17:24 18:2
C
Cadavid 2:21,23
6:2,3 47:3
Calderon 43:25
Calderon-Meza 2:11
5:10,11 43:25
44:3,8,22
calendar 7:18,21
66:1
Calle 2:12,21 4:23
34:22
called 25:11
camouflage 17:25
campesinos 27:12
cane 32:8
card 5:17
Crdenas-Meza 23:5
care-pollo 59:16
Carepa 44:10
Carlos 9:21 10:25
11:1 12:10 13:4
25:20,22,25 28:9
28:13 32:4,6,24
34:7 41:3 56:25
57:5 59:4 60:12
Carrera 2:12 4:22
carried 7:11 11:8
14:22 20:9
carry 20:11
case 1:2 4:8,9
35:8 39:2,3
42:14 43:13
50:17 58:8 61:24
63:2 65:22
cases 23:19 58:4
59:14
Castao 9:20 11:1
11:1 12:11 17:21
24:20,20 25:1,10
25:16,20 26:12
26:17 27:7 28:7
28:9,18 31:4
32:24 34:7 46:7
46:16 48:3,7,11
51:11,13 53:2,22
56:24,25 57:3
58:24 59:4,19
Castaos 27:7
cattle 10:24 11:2
13:18 17:23
31:14 32:2 54:15
Cauca 32:7
Center 2:16
certain 34:1 51:22
certainly 65:13
CERTIFICATE 67:1
certified 5:5,6
certify 67:7,13
charge 10:25 12:10
13:16 17:20
21:14 25:24
26:10,14,15 45:3
59:16
charged 46:12
49:22
charges 20:24
charging 45:9,11
Chavez 46:5 47:10
Chigorod 28:23
44:11
children 9:18 34:4
Chiquita 1:3 4:6
6:1,6 8:11 10:3
10:5,15,17 12:4
12:12 13:12 14:7
14:12 15:3,8,17
15:22 16:1,11,14
17:13,14 18:2,10
19:23 20:4 21:4
21:9 23:24 30:6
30:16 32:12 33:9
35:8,17,23,25
36:16,24,24
37:13,14 41:3
42:13 47:21
49:23 50:7,8
53:19 55:6,21
56:10,21 58:14
59:2,24 60:5,9
Chiquita/Banadex
18:8
Chomsky 2:3,6 5:20
5:21 18:15 23:5
54:12 55:2
circuit 1:16 61:11
61:12
cities 29:21
citizen 4:20 5:9
5:11,16 9:16
23:16
City 2:16
561-835-0220
civil 18:11 42:13

61:11
claims 35:17
clarification
24:22 26:6 64:16
clarifications
43:15
clarified 14:5
65:5
clarify 13:2 17:1
17:19 21:12,19
22:8 32:20,22
33:24 36:6 38:6
38:9,18 40:7
42:4,15 45:1
47:13 50:22
54:19,23 55:5
56:14 57:11
clarity 8:1 54:6
clean 29:23
clear 12:21 61:22
64:12
clearly 12:23
clerk 22:14 24:8
62:18 64:25
close 25:12,14
59:7,8
closed 66:4
Code 8:20
collaborate 46:17
64:14,15,18
collaborated 52:13
collaborating
46:18 59:13
colleagues 5:21
collect 31:6,18
33:2
collected 17:23
31:1,12,13,18
Colombia 1:15,22
2:13,22 22:7
28:5,6 43:12
50:23,25 52:18
58:20 63:7
Colombian 6:3 19:2
19:3 28:1 29:7
Colombians 37:13
37:25
Columbia 5:18
combat 26:10
come 28:16
comes 17:19 25:20
coming 38:15 45:11
command 25:3 26:4
26:11 32:20
commander 26:15,16
26:17,17 28:20

71 of3
Page
80
28:20 45:2,5
50:13,16 55:17
55:23 57:2,13,16
commanders 10:16
10:18 27:10 59:8
60:10
commission 7:10
10:1 24:9 41:6
64:15 65:9
commit 27:16
committing 8:17
Commonwealth 5:23
communication 33:8
59:18 60:11,11
companies 13:20
21:15 31:7,21
38:7 40:9 44:13
44:15,16,16 45:7
45:9,15 47:18,22
48:18 57:1,9
58:13,19
companion 34:4
company 8:11 40:8
40:18 42:15 54:7
54:14 55:12,21
compelled 11:10
34:3 38:21
complete 43:2
conclude 29:25
65:25
concluded 66:6
conduct 6:21 7:13
11:2 12:11 13:4
conducted 10:23
13:17
conducting 13:16
conferring 62:11
confession 34:9,10
34:11
confirm 62:13
conflict 4:17
connected 67:16
consensus 22:25
consider 19:10
57:25
consistent 39:10
constant 59:18
consult 61:6
consulting 44:21
contact 21:9
contained 17:4,7
contains 18:17
context 18:11
continue 13:1
19:12 27:23
28:15 49:7 61:4
62:14
continued 64:5
continues 9:25
12:19,25 13:25
20:3 30:3 35:9
35:13 36:19 37:4
38:4,11,24 48:5
59:10
continuing 19:11
contracts 23:23
contributions 38:1
38:7
control 26:20,24
26:25 27:4,8,19
controlled 14:14
Conversation 22:14
24:8 62:18 64:25
conversations
49:11,15
convicted 37:22
conviction 38:3
convivir 32:17,20
32:23 33:1
cooperating 42:7
cooperation 42:10
coordinate 62:9
coordinated 63:15
copy 7:1 22:13,23
Cordoba 23:14
39:24 57:4
Crdoba 2:14 4:14
25:11,12,15 27:6
cornered 29:20
correct 34:1 36:21
59:2 64:4
corrected 64:24
65:7
correction 24:7
25:13
correctly 30:9
corrupt 34:21
Costa 25:11
Council 4:20 5:13
counsel 6:1 33:22
43:2,3,5,9 53:24
54:13 55:25
56:23 57:12 60:1
60:6,10,15 67:14
67:16
counsel's 14:4
Counselor 49:13,17
50:10 51:1
counter 28:2
country 34:18
37:25 50:19,21
50:24
COUNTY 67:4
couple 49:25
course 45:14 62:21

court 1:1,16 3:8
4:1,10 5:6,7,22
6:14,23 7:3,8,18
7:19 8:4,9,10
9:8 10:13 11:9,9
11:19 12:2,24
13:10 14:6,12,21
15:2,7,12,22
16:1,7,14,19
17:3,3,12 18:1,7
18:20 19:6,9,21
20:2,4,14,22
21:4,8,19 22:10
22:14,15,20,22
23:9 24:1,3,9
25:2 26:6,19
27:2,15,23 28:1
30:4,10,13,21
31:5 32:10,15
33:4,7,11,23
34:2,12 35:6,14
35:22 36:13,25
37:1,3,12 38:12
38:16 39:5,8,19
41:8,13,17 43:1
43:1,10,16 44:5
44:23 47:2,3,4
47:15,23 48:21
49:7,20,25 50:3
52:12 53:4,14
54:1 55:25 58:11
61:2,11 62:1,18
62:21,25 63:6,7
63:13,20,24,25
64:4,8,25 65:8,8
65:15,25
Court's 6:11 64:2
COVINGTON 2:16
Cra 1:21
crime 8:18,18
criminal 61:12
CROSS-EXAMINATION
3:9,9 54:3 56:1
Cuarenta 55:17,23
55:23 57:13,15
57:17,17
currently 55:17
57:20
D
D.C 2:8,22
danger 37:17
Darien 32:17
date 7:5 61:4,25
62:24 64:4 66:2
66:2
561-835-0220
Dated 67:19
dates 7:20 40:20
David 4:15 23:15
23:17,23
day 40:16 41:25
49:24 56:4 67:19
days 6:23 7:4
48:19
DC 2:17
de 25:11,16,18
27:7 32:17,18
44:7,9
dead 48:11 59:4
December 7:19
decide 63:7
decided 24:3 39:15
39:20
decision 62:8
63:25 65:17
declare 34:3 38:21
deemed 34:18
defendant 21:25
38:14 41:14 65:3
defendants 2:15
6:9,17 19:14,15
24:10 35:8 43:5
48:25 55:25
61:22 62:20,22
64:21 65:4
defenders 20:7
defense 20:9,10,12
20:18 33:22 43:8
43:9
define 66:1
degree 8:23,24,24
del 32:7
demandantes 35:11
demands 27:17
demobilization
26:2 52:4,19
demobilized 9:22
9:23
department 26:8
27:6
depend 65:11
deposition 1:18
3:7 62:24 63:1
66:6,7 67:9
depositions 39:10
DERIVATIVE 1:5
designated 22:24
details 8:12 65:11
66:1
detained 29:12,13
47:10
determine 40:14
died 25:20 27:22

72 of4
Page
80
28:7,12
Diego 7:16
different 28:21
44:11 52:13,20
61:10
direct 3:8 7:11
18:19 41:19
discuss 11:13,22
37:2 49:4 63:8
discussed 11:13
35:20 57:9
discussion 22:19
49:6 64:23
discussions 58:3
District 1:1,1 4:3
4:3,4 5:18
division 12:4
divisions 25:4
Docket 1:16
doctor 47:7
document 1:6 9:10
16:9 17:7 23:16
42:25 43:2,4,20
documents 34:23
52:21,22,23
doing 19:12 29:16
dollars 31:3 47:21
Dr 4:15 23:15
34:22
draw 42:24
drive 53:21
drug 17:22 30:5,15
30:19
drugs 31:2
due 33:15 40:5
48:14 63:9
duly 9:5
Duraiswamy 2:19
3:9 6:7,8,15
7:24 19:14 21:25
24:2 39:6,9 48:9
51:8,19 52:5
53:8,20 54:21
55:8 56:2,16,17
57:18,22 58:7,23
59:22 60:3 61:21
62:19,22
E
E 2:20
e-mail 4:24
e-mails 53:1,7,18
earlier 42:17
EARTHRIGHTS 2:7
easier 65:23
Edificio 2:12 4:22
effective 26:20
effort 28:10
Eighteenth 2:4
either 13:11 39:15
El 31:1
elaborate 16:19
55:5
Elkins 2:4
employee 21:8
67:14,15
English 41:22
42:17
English-Spanis...
5:3
enjoy 54:7
entered 9:21 13:7
24:18 31:12,16
31:20,25 57:2
entities 14:14
37:9
entity 8:11
entrance 29:3
Ernaldo 24:25 25:9
error 36:21 61:12
ESQUIRE 2:6,10,11
2:19,20,23
estimated 34:14
examination 3:8,8
6:22 7:11,14 9:7
39:16 41:19 61:5
examine 10:2
examined 9:5
example 29:22
44:15
exception 39:3
exchange 14:8 43:5
exclusively 42:15
Excuse 44:19 48:21
52:12
excused 10:13
60:25
executives 10:5,15
10:17 33:8 42:14
42:16
exhibit 43:5
exist 50:15
existed 30:1
expecting 56:4
explain 18:3 27:4
expressing 65:5
extending 28:23
extorting 49:23
extortion 13:21
30:6,16 31:6
extradited 59:15
extremely 45:9
F
facility 55:20
fact 11:7 20:20
30:1
factored 63:25
facts 8:16,17
false 8:18
families 4:16 40:1
family 40:16 41:9
41:25 42:1,1,6
48:22 54:8 56:6
60:18
far 42:9
FARC 28:4,8,9,14
28:17
farm 25:11,11
farmers 31:21
farms 25:1,10,16
25:17,19 31:15
fast 29:9
favor 36:15,24
fear 45:13
federal 5:6,6
Felipe 3:1 5:2
fellow 37:24
Fidel 9:20 24:20
25:1,10,15,20,21
28:7,11,12
fight 29:14
fighter 29:22
fighting 26:23
figures 34:17 36:4
finance 45:12
financed 59:20
financially 67:17
financing 47:7
48:11,17 49:11
50:12
fine 19:3,16
finish 25:6,7
finished 8:3 27:24
27:25 38:13
47:15
first 7:11 8:24
9:5 13:7 24:6,7
49:10
firsthand 32:11,16
56:8,19 58:17
fled 46:8
floor 7:13 18:21
Florida 1:1,25 4:5
23:9,10 38:16
67:3,7,22
follow 7:9,9
followed 27:20
following 15:13,16
24:10,11 44:8
follows 9:6
561-835-0220
force 26:25
forced 8:21
forces 28:8
foreign 23:16
50:20
form 32:6,9 39:12
39:14 48:9 51:8
51:19 52:5 53:8
53:20 54:21 55:9
56:11,22 57:21
58:5 59:25
formed 33:2
former 32:1 33:3,4
formerly 32:1
Fortunately 35:2
found 19:7
foundation 53:20
54:21 55:9 56:12
four 21:23 24:4
57:6
fourth 8:23,24
FPR 1:24 67:21
frame 7:23
Freddy 59:6 61:9
61:20 65:9
free 33:17 43:11
43:11 52:13
64:17
frequently 57:6
60:13
friend 57:25 58:1
friends 59:8
front 37:20
full 9:9 12:8
21:15 29:25
fully 9:9
funding 30:15,18
33:2 54:14,17,20
54:23 57:1,10
58:14
funds 30:5
further 51:22 63:8
67:13
future 7:5
G
general's 37:11
gentleman 65:4
give 6:24 8:9
45:14 46:25 49:3
61:13,19
given 7:13 8:12
18:21 21:22 24:5
35:24 36:22 40:2
40:18 61:2 62:25
giving 48:7 52:2
glasses 43:23

73 of5
Page
80
go 6:14 8:4 29:4
29:11,14 38:3
46:3,10 50:3
56:6 58:11 63:22
goal 36:3
God 60:23
going 7:8,9 11:20
15:12 16:7,8
22:16 25:6 27:23
41:21 46:6,8,12
good 4:12 5:20,25
6:2,7 8:7,8 9:13
9:13 39:23 41:23
government 14:14
28:2 29:7
grant 63:25
granting 63:21
greater 8:1
greatly 37:25
groceries 54:25
group 9:20 26:4
29:14 31:25
groups 26:9,10,13
26:15,20,23
27:19 28:19,19
28:21 29:4 32:1
32:6,9 45:10,12
45:17
growth 29:5,9,18
30:2
Guadalupe 9:17
guarantee 21:2
34:5
guarantees 34:1
guerrilla 29:22
31:13,17 32:1
guerrillas 26:24
28:5 29:14,16,20
45:8
Gulf 51:2,16
H
H.H 31:1 59:15
half 40:11
hamper 28:2
hand 3:2 4:7 5:5,5
12:19 13:25
18:21 20:3 24:21
24:23 25:13 35:9
36:19 38:4,24
43:7 44:20 46:19
59:10 60:1 65:1
handed 53:1
handing 42:19
happen 36:12
happened 31:8,9
happy 56:6
Hasbn 10:24 12:9

13:3,3,6,17
14:20 17:1 21:16
30:25 32:21,23
40:23 41:3 45:2
45:3 47:9,20
48:1,4,8,13,20
50:17 51:4,6
55:13 57:19 58:2
58:18,21,24
59:19
hear 33:21 48:1
51:17 61:20
heard 32:25 40:4
46:4,13 47:9,17
47:25 48:3 49:11
49:14 58:16
65:10
hearing 4:4 20:7,8
20:11,12,23,25
61:3,10
hearsay 46:4
Hebert 59:15
held 22:19 49:6
64:23
helicopters 55:1
Hello 5:15
help 34:6 40:17
helpful 7:2 10:11
Hernn 44:14
Hernndez 44:14
Herrera 59:7 61:9
61:20 65:9
hide 8:16 14:13,22
63:22
hiding 8:15
high 45:10
high-level 42:14
42:16
highways 29:23
hold 42:24 65:23
homes 29:14
honest 34:19,20
Honor 4:12 5:20
6:11,18,25 7:24
7:25 8:8 9:13,14
10:19 11:4,15,25
12:7,21 13:1,2
13:13 14:10,16
14:25 15:6,11,20
15:25 16:6,13,18
16:22 17:11,18
18:6,13,14,18
19:15,16,19,25
20:1,6,15 21:3,7
21:11,12,18,25
22:3,6,12,21
23:13 24:2,17
25:6 26:3,9,22
27:5,18,20 28:4
28:7,18,24 29:6
29:12,18,25 30:2
30:8,12,20,23
31:11,24 32:13
32:19,22 33:10
33:15,19 34:8,15
35:18,21 36:1,17
36:22 37:8,15,19
39:6,9,22,23
40:5 41:6,12
44:19 45:22
46:17 49:2,8
57:11 58:9 59:11
61:21 62:3,6,19
62:22 63:9 65:19
hope 60:17
hour 40:10 41:13
hours 6:21 40:11
house 56:24,25
57:3
hurt 37:25
I
ID 4:20 5:11 6:3
identification
9:10,16
identified 5:17
23:16
identify 4:18 9:8
61:4
identities 50:6
Identity 23:16
Ignacio 1:18 3:7
9:4,15 54:5,18
60:25 61:18 67:9
immediate 7:22
immediately 34:23
important 15:8
34:17 42:2
incentive 63:22
include 52:21
included 21:21
33:17
includes 24:9
including 24:15
58:14
inconvenience
19:11
INDEX 3:5
indicating 8:13
individual 21:9
58:25
individuals 33:13
50:7
561-835-0220
influence 36:11
inform 10:19,20
information 14:19
14:20 32:11,16
40:19 46:9 47:25
48:2,13 52:18,21
53:25 55:18,24
58:21 59:6,20
61:23
informed 11:11
inquire 7:3
inquiries 6:12
insist 53:13
Insofar 62:14
instance 34:21
50:17 54:16
Institute 37:10
instructed 46:25
interaction 60:5
interactions 56:9
56:20 59:1,24
60:8
interested 67:17
interests 18:9
19:22 20:5 21:5
21:5
interject 12:14
International 1:3
2:7 4:6 6:1,6
8:12 23:25
interpret 16:7
interpretation
52:10
interpreter 1:18
3:1,2 4:7,7 5:2
5:4,5,6,7 9:25
10:11 12:19,20
12:25 13:25 20:3
24:7,21,21,23
25:13,13 30:3
33:6 35:9,13
36:5,5,8,19 37:4
38:4,11,24 43:7
44:1,1,19,20
46:19,19,20,24
48:5 52:8,8
56:13,13 59:10
60:1 65:1
interpreters 10:9
44:20
interrogate 11:10
intervene 19:9
interventions 10:9
introduction 41:21
invented 46:1
investigation
40:13

74 of6
Page
80
involved 13:21
59:24 60:5,8
issue 7:19 12:18
18:4 39:8 55:24
63:3,8,8,11 64:5
issued 4:19 6:19
27:20 63:18
issues 19:2
Itagui 1:21
Itag 1:16
J
jail 63:18 65:22
jarvelo@cov.com
2:19
jchomsky@igc.org
2:5
Jesus 1:18 3:7 9:4
9:15 54:5,18
60:25 67:9
John 24:25 25:9
join 28:8
Jorge 55:17,20,23
55:23 57:13,15
57:17,17
Jos 2:20 5:25
62:4
Juan 2:11 5:10
23:5 43:25
juan@earthrigh...
2:10
judge 6:18 7:7
23:9 24:8,12
37:3 38:15 39:16
39:21 63:4
judges 35:5
judicial 4:3,19
5:13 8:11 66:1
Judith 2:3,6 5:21
23:5
jungle 29:21
justice 9:23 34:9
34:13,24,25 35:4
41:5 42:18 45:24
46:4,5 52:3 53:3
59:13 64:14
justices 34:10
K
K 2:7 3:2
keep 7:22
kept 50:11,13
kidnapping 30:6,16
kill 31:15 37:24
killed 33:11
killing 33:12 34:6
34:7
killings 33:12
kilo 31:2,3,3
kind 44:11
kiosk 60:13
knew 45:21 46:2,10
47:8,11 48:14
57:1
know 6:25 7:25
11:7,13 12:3,5
13:12 14:9,15,24
15:4,9,17,19
16:4,10 17:8,14
18:1,4,11 20:5,8
20:13,18 21:17
30:7,17,21,23
36:14,23 37:7,16
40:17 45:22,24
46:6 47:8,16
48:8,16,16 50:6
50:11,15,18,22
51:21,23 56:4
57:7,23 58:12,17
58:17,21 59:3,5
65:20,22
knowing 8:25
knowledge 10:21
11:5,16 12:8
13:13 14:11,17
15:1,5,10,21,24
16:5,12,17,20,24
17:10,17,19 18:5
18:12 19:24 20:6
21:7,11,15 30:1
30:18 40:8,11,14
40:18,20,24,25
41:1,4,5,7 42:4
49:24 51:1,3,21
51:23 53:18
55:14 56:9,20
58:13 61:23
knowledgeable 59:1
known 8:11,19
knows 17:1 58:18
58:22 62:4
L
L 1:24 67:6,21
Lack 55:8 56:11
land 52:22
law 2:3 9:24 19:2
34:9,13,25 35:1
35:4 64:7
lawsuit 50:8
lawsuits 6:19
lawyers 19:3 23:1
58:3
leave 63:13
left 27:21 54:12

legal 4:21
LEN 3:2
let's 21:19 38:18
45:22
letter 6:20 7:1
letters 19:7 22:23
63:18 64:6
liars 34:18
libres 52:3
license 4:19 5:12
5:22 6:4
lied 34:14
lighter 31:17
likes 45:14
Liliana 34:22
line 18:10 19:22
lines 53:17
listen 47:19
literal 52:11
literally 13:24
litigation 1:5
6:10
little 50:3
livestock 25:1
LLP 2:16
localization 65:16
locate 44:2
located 27:6
location 65:24
logically 27:12
45:13
logistical 65:11
LONDOO 2:23
long 31:13 54:6
longer 50:3 63:2
look 7:20
looked 45:12
lot 53:23 59:3
loud 18:16
Luis 3:1 5:2
M
Magdalena 25:5
26:5,8 57:4
maintain 65:10
making 22:22
man 58:1
manage 25:17
managed 8:2 44:13
management 44:11
manager 25:1,10,11
25:19,22 46:3
managers 31:15
Mancuso 56:8,19,23
57:5,8,12,16,17
60:7,12
561-835-0220
Marco 22:24 23:4

Marissa 2:10 5:15
38:25 42:11
marissa@earthr...
2:9
married 9:11
matter 4:5 6:17
11:11 63:13
matters 42:5
Mxima 1:21
mean 52:7 54:11
means 8:13,14
54:17
Mecocle 28:22
Medelln 2:13 4:23
29:21,21
medicine 54:25
meet 11:12,22 57:5
57:6 60:12,18
meeting 10:4 12:16
12:16 21:14 41:2
45:3
meetings 10:15
11:23,24 12:1
13:4,8,17,18
16:23 17:2 21:17
40:21 55:11 57:8
60:11
member 9:19 13:14
24:14 49:12
56:24
members 10:7 49:15
54:24
men 29:10
mention 53:18
mentioned 24:17
28:25 40:9,9
42:17 47:25
53:22
Merker 1:24 67:6
67:21
met 10:18 33:7
methodology 10:8
Michael 44:15 45:1
45:3
military 26:16
28:20
militias 29:15
million 54:16
mills 32:9
mind 7:23
minute 49:3
misread 35:15
missed 46:20
mistranslation
64:20
mix 17:3

75 of7
Page
80
moment 12:14 37:8
43:1 44:2
money 15:3,7,18,23
16:2,11,15 17:8
17:22 40:21
45:14 58:3
Morales 2:14 3:9
4:12,14 7:25
12:21 14:3 18:14
18:16 22:6 23:2
23:13,14 39:22
39:24 54:4 55:4
58:9 62:3 64:9
morning 4:2,12
5:20,25 6:2,7
8:7,8 9:13,14
motion 14:4
motivation 63:17
move 8:5 29:10
murder 29:16
Muy 24:1
N
name 4:9,14 5:2,10
5:15,21 6:2,7
9:9,15 22:24
23:13 38:22,25
42:11 61:14,14
Nancy 3:2 5:5
National 37:10
nearby 59:9
necessary 20:18
22:1,4 24:4
33:20 61:4,24
62:5,12,23
need 22:7 61:18
62:8 63:4,15
needed 6:24 29:13
33:1
needs 22:17
negotiated 10:22
28:8
negotiation 12:17
negotiations 10:23
11:5,6,17 12:11
12:22 28:14,15
40:8 47:18
neighborhoods 29:1
neighboring 59:17
59:17
never 16:23 29:11
37:15 58:6
Nevertheless 17:6
night 29:15
nine 9:18 35:4,19
noted 38:12 39:19
notes 67:12
noticed 10:13
notification 4:25
22:17
notifications 4:21
notified 20:11
Nubia 46:5
Nueva 2:12 4:23
number 4:8,9,19,23
4:24 5:11,12,23
5:24 6:3,4 9:9
9:16 61:14 62:9
numbers 24:7
numeral 17:4,12
18:7
NW 2:7,17
O
o'clock 7:16 41:11
oath 8:10 33:25
obey 27:17,21
object 13:22 48:9
51:8,19 52:5
53:8
objected 65:1
objection 35:10
38:5 39:17 53:20
54:21 55:8 56:11
56:22 57:14,21
58:5 59:25
objections 39:11
39:12,13,20
obligation 21:1
64:14,17
obtain 26:20
occurring 41:10
offered 14:6,8
36:18,23 37:5
43:15
offering 36:15
office 2:3 22:17
29:2 37:11 45:24
OFFICES 2:3
official 4:25 46:5
officials 29:7
33:9
okay 12:20,24
18:15 19:21
20:21 41:16,17
43:17 47:5 49:19
50:2,4 53:17
once 17:7
ones 21:24
ongoing 60:11
open 40:12
opened 40:13
opens 4:3
operate 25:3 26:4
operated 26:21,23
27:1,8
opinion 27:2 46:17
opportunity 6:21
40:3 60:17
opposed 64:21
oral 6:22 52:19
order 7:6,9,10
19:6 23:8 27:20
27:21 29:4 31:4
33:1 40:25
ordered 11:1 12:10
33:12
orders 27:17 48:4
48:7
organization 13:15
29:5 30:19 37:24
organizations
24:15
organized 32:23
33:1
organizing 34:7
Oro 25:12
outside 50:19,24
50:24 65:21
overheard 55:20
P
p.m 1:20 61:1 66:6
Pablo 2:11 5:10
23:5 43:25
page 3:7 42:24,25
43:20,21 44:4,5
44:6
pages 67:9
paid 15:18 16:2
17:22 31:3,7
37:6,22,23 40:21
44:14,15,15,17
45:7 47:20 55:7
55:21 58:18
PALM 67:4
Papagayo 32:17
paramilitaries
27:16
paramilitary 13:11
14:6 24:14 25:2
26:20 31:18
32:12
Park 2:4
part 16:23 27:9,13
28:10 34:8 49:18
52:3,10 60:20
62:6 63:10 65:8
participate 11:6
11:17 19:3 33:14
participated 33:12
561-835-0220
participation 40:7
parties 4:10 6:21
6:24 7:12 19:10
21:22 39:9 65:11
65:20 66:8 67:14
67:15
parts 4:8
party 43:13
patrolling 54:24
Paul 4:15 23:15,17
23:23 39:4,24
54:1 62:2
Paula 2:23 6:2
Pavilion 55:19
pay 31:7,14,23
44:12,13 45:16
54:24 55:12
paying 45:9
payment 10:3,6
11:8 12:3,5
payments 13:21
14:8,13,22 31:8
31:23 32:11,16
pays 44:17
PBX 2:22
pcadavid@prias...
2:23
peace 9:23 34:9,13
34:25 35:1,4
41:5 42:18 45:25
46:5 53:3 59:13
64:15
Pedro 10:24 12:9
13:17 14:20
25:16,18 27:7
28:22 30:25 44:6
44:9 45:2 46:11
47:9 59:7,19
Pedro's 59:17
penal 1:16 8:20
61:12
Penitentiary 37:10
Pennsylvania 2:4
5:23
people 10:20 29:2
37:18 49:14
53:23 59:3,5
perceive 18:9
19:22
percent 26:25 27:8
29:23,24
Perez 1:18 3:7 9:4
9:15 60:25 67:9
period 42:5
permanent 34:4
permissible 20:13
permission 6:12

76 of8
Page
80
person 10:25 12:8
12:10 13:8,16
14:19 17:1 18:24
21:14,16 25:3
40:19,23 43:13
48:12,18 51:3,4
55:14 59:12
65:12,13
personal 32:11,16
56:8,19
personally 51:10
59:23 60:4,8,14
personnel 26:11
perspective 62:20
pesos 31:18,19
47:21 54:16
phone 61:13
Piedra 32:18
place 10:5
plaintiff 41:14
plaintiffs 2:2 3:2
5:9,14,19 6:16
10:1 18:23 19:1
19:5,18 22:3,11
22:25 23:1,6,12
23:18 33:20
35:12 38:16 39:3
41:18 48:24 49:4
50:7 60:21 62:7
63:10 64:11,22
65:4,6
please 4:11 8:6
9:8,9 12:2,15
13:23 18:3,20
27:4 38:9,20
43:14,19,24
56:14 66:3
pockets 45:15
point 17:6 61:7,7
65:17
police 28:25 29:11
politicians 29:8
37:23 38:1,8
population 27:3,11
27:14
port 51:7,17
portion 30:4,14
46:21
ports 50:23
position 22:22
64:10 65:3,6
possible 62:15
65:21
Post 2:3
Postobn 44:16
45:6 46:3 47:7
47:14,18,21
power 23:3,20 28:5

preceding 25:7
precise 12:15
precision 13:24
preliminary 6:12
prepared 28:2
61:15
presence 30:24
31:22 32:2
present 3:1 4:13
9:14 10:20 11:23
20:8 22:23 23:3
23:11,20 32:24
37:21 40:6 41:2
president 33:3,5
presiding 6:19
pressure 44:22
previous 32:4 44:3
previously 24:18
PRAS 2:21
prison 35:19 40:16
48:22 55:17,19
55:20 57:19,24
63:1 64:3
probably 59:4
problem 19:11
problems 20:20
29:24
Procedural 8:20
procedure 39:10
procedures 6:13
proceed 41:22
49:19 62:23
proceeding 6:13
8:1,10 19:1 23:7
23:11
proceedings 3:5
54:12 55:2
process 34:13,16
35:20 42:18
45:25 46:5,15
52:3,19 53:3
59:14
procure 17:15
producers 45:4
professional 1:24
1:25 4:18 5:12
5:17,22 6:4 67:6
67:7,22,22
progress 54:12
55:3
prosecution 34:12
prosecutor's 22:17
29:1 45:24
prosecutors 33:17
34:9,19,20,21
protect 45:18
protection 27:11
37:6
provide 7:2 14:7
27:3 35:23 41:4
48:12 52:17
54:16 61:16
64:16 65:15
provided 13:11
15:14,15 17:15
34:5 37:5 43:4
53:21 58:14
providing 27:11,13
36:11 37:9 45:17
58:4
public 4:3
Punta 32:18
purpose 15:23 16:3
16:3,16 17:9
54:19
purposes 4:21,25
put 8:15 28:16
Q
question 10:17
11:12 12:2 14:11
14:12,17 15:1,2
15:6,7,11,13,16
15:17,21,25 16:1
16:6,8,13,18
17:11,14,18 18:1
18:6,13 19:21
20:1,16,17 21:4
21:8,13 24:13,22
25:2,7 26:3,7,7
26:19 27:2,15
30:4,11,13 31:5
32:10,15 33:7,11
33:16,21,22,23
34:6 35:6,15,22
36:13,22 37:1,1
37:5,12 39:12,14
43:1,6,14 44:7
44:23,24 45:6
46:23 47:6,13,23
49:10,19 52:11
53:4,6,12,12,14
53:15,17 54:10
56:14,15 58:10
65:18,19,20
questioned 17:6
questioner 18:17
38:13
questioning 39:7
questions 8:15
11:20 17:4 18:25
19:4,20 20:2,17
21:20,21 22:2,4
561-835-0220
24:4,6,10,11
38:17,19,22
39:11 40:3 41:15
48:25 49:1,4
50:1 56:5 60:17
61:18
R
raise 12:18 18:21
49:5
raiser 54:15
Ral 10:24 12:9
13:3,3,6 14:20
17:1 21:16 32:21
32:23,25 40:23
41:3 45:2 47:20
48:1,4,8,13,20
50:17 51:4,6
55:13 58:21
re-ask 46:22
reached 51:11
read 16:8 18:18
19:16,20 35:15
42:23 43:22,24
reading 19:11 37:1
66:7
ready 49:8
reason 56:7,18
62:25
reasons 10:8 63:20
receive 7:8 58:3
received 6:25 15:3
15:7 43:12 50:19
50:23 51:5 54:20
recognize 42:22
63:5
recognized 63:20
record 4:10 12:13
12:18 14:1 18:23
22:19 36:20
38:23 39:18 43:4
47:12 49:6 52:9
64:10,13,19,20
64:23 67:11
recording 64:13
records 50:11,13
50:15
referred 44:7
54:13
referring 52:22,23
refers 26:7
reformulate 43:14
52:15
refuse 31:7 36:3
refused 27:17 31:9
31:10
regard 7:15 10:2

77 of9
Page
80
37:16
regarding 6:13
10:21 11:9,10,16
14:11,17 15:1,6
15:11,21,25 16:6
16:11,13,18,20
16:24 17:5,8,11
17:18 18:4,6,12
32:11,16 35:17
35:23,25 36:2,6
40:13 44:21
48:10,17 51:3
54:9 55:14,18,24
57:9 58:13 59:6
65:9,17
region 11:3 12:12
13:20 25:4
regions 26:21 27:4
28:6,21 59:21
Registered 1:24
67:6,22
reiterate 11:7
rejoined 55:2
related 35:20
53:15
Relates 1:6
relative 8:22,23
67:13,15
release 63:23 64:3
released 63:19
relevant 61:23
remaining 4:8 24:4
removal 34:25 35:3
remove 34:12
removed 34:24
Rendn 59:6,23
60:2,4 61:9,20
62:14 63:18
64:13 65:9,22
Rendn's 62:24
63:12 64:3
reparations 64:16
repeat 11:4,15
13:16 14:18
20:22,25 21:13
30:10 35:14
38:18 48:10
56:15
repeated 34:2
repetition 4:8
46:22
replace 25:21
replaced 34:22
replay 47:4
report 67:8
Reported 1:23
Reporter 1:24,25
33:4 67:1,7,7,22
67:22
represent 22:15
23:6 37:17 39:24
representation
23:22
representative
5:19 19:5 20:21
22:6,11 23:11
54:1 62:2
representatives
33:9 35:7
represented 23:2
39:4 61:8
representing 4:15
4:16 6:9 23:18
29:2 42:12
reprisals 37:13
request 6:11 7:6
13:23 16:14 22:9
34:11 36:6 40:2
46:21,22,24 49:2
53:23,24 63:21
64:1
requested 34:24
67:10
requesting 6:20,22
requests 4:7
required 8:14
reserve 62:16
reserved 39:11
resolved 22:20
39:20
respect 33:15
34:11 40:5 48:14
63:10
respectfully 63:13
responsible 21:17
26:12 27:10
rest 49:14 62:7
result 20:20
retired 26:16
return 32:3
review 34:23 43:20
66:1 67:10
right 41:8,15
48:23 57:24
62:16
risk 37:13
Robin 1:24 67:6,21
rogatory 6:20 19:8
22:23 64:6
Rldan 1:18 3:7
9:4,15 10:2
41:23 42:17
43:19 45:20
48:21 49:10,22
50:6,11,18 52:2
52:17 54:5,18
55:5 56:3,7,18
57:19 60:16,25
61:19,22 62:4
67:9
role 24:16
room 60:13
RPR 1:24 67:21
ruining 45:8
S
Salvatore 56:8,19
56:23 57:5,8,12
60:7,12,14
San 25:16,18 27:6
28:22 44:6,9
saw 29:19 31:24
45:16
saying 18:16 55:20
says 24:10 38:15
44:6,8
schedule 6:23 7:4
61:25
scheduling 7:20
62:24
school 9:11
scriptures 52:23
sduraiswamy@co...
2:18
second 1:16 4:2
8:24 9:22 17:4
24:18 26:3,6,7
42:25 45:2 61:11
seconds 49:3
Section 19:7
security 17:20,21
25:22,24 26:11
26:13 27:3,13
37:6,9 45:17
65:12
see 20:4 21:5 41:8
41:25 42:1,6,9
43:23 45:22
48:23 56:6
Seeing 11:19
seeks 25:21
Seguridad 1:21
self-defense 9:20
24:14 26:23
27:19 28:19 29:3
45:10,12,17
semester 9:22
24:19
sense 21:20
sent 7:10
separated 9:17
561-835-0220
September 42:20
serious 58:1
served 56:24
service 65:16
services 13:11
14:7,8
session 66:4
set 61:2
seven 6:21
Shankar 2:19 6:8
SHAREHOLDER 1:5
ship 51:17
shipment 51:2,5,7
51:10,14,15,21
51:23 58:19,20
shipments 50:19
ships 50:23
short 42:5
shorter 10:10
46:25
side 6:22 39:15
sign 35:24
signed 23:4,9
signing 66:7
Simons 22:24 23:4
single 9:12 29:22
49:18
sit 48:15,18
situation 12:8
55:15
sleep 37:16
small 28:18,21
65:20
so-and-so 46:11
sorry 33:4 60:1
sought 28:9,11
32:3,3
source 52:18
sources 30:7,17
Southern 1:1 4:4
Spanish 24:23 36:8
41:21,23 47:3
52:10
speak 18:25 19:6
34:18 62:10,13
speaking 6:15
specific 15:23
16:3,15 17:6,9
47:13 52:25
specifically 10:4
51:24
specifics 40:20
specify 54:18
spend 41:13
spoken 35:7
spouse 8:22
Sr 41:23 50:18

78 10
of
Page
80
52:17 56:3 60:16
63:12
stand 8:6 64:24
65:6
started 45:10 57:2
starting 45:23,25
46:14
starts 44:3
state 4:5,11 18:23
29:3,12,16,18,19
29:25 38:2 39:5
39:17 43:3 46:20
52:9 67:3
stated 16:22 22:10
23:14 32:4 35:3
62:4 64:11
statement 30:14
39:7 43:12 64:10
states 1:1 4:5
5:16 6:9,19 8:21
10:1 23:19,19
39:1,19,19 42:12
42:13 50:9 55:18
59:14 63:4,7,14
64:5
STATUTE 1:4
stayed 25:23 26:1
31:20
stenographic 67:12
stenographically
1:23 67:8
steps 52:4
stipulated 7:12
Street 2:7,17
Streets 2:4
struggling 10:14
subpoenaed 8:9
sued 37:14
sugar 32:8,8
suggest 18:18
53:24
suing 37:13
suit 42:13
Suite 2:8
summoned 34:16
Superior 4:19
support 14:4,4
17:15 22:21 29:6
35:2 64:10
supported 18:2
29:3 59:21
supporting 23:21
Supreme 5:13,22
sure 37:17 47:2
49:20 56:16
swear 8:25 9:2
41:6
sworn 9:5
T
Tagua 32:17
take 18:20 22:16
29:15,15 38:20
52:4 53:9 54:6
62:8,16 63:4
65:21
taken 33:25 63:1
63:12
talk 46:3,11 60:13
talked 35:16 58:8
talking 40:10 44:6
44:9
tape 47:4
tax 31:1,19
taxes 17:22 31:12
45:10,11
team 65:12
teams 62:9,13
telephone 4:23
tell 9:1,8,9 12:2
13:8 34:16 36:3
40:20 45:20,23
46:11 47:11,20
48:15,19 51:6,9
51:13 53:6 54:15
57:7 59:23 60:4
60:7,14
telling 46:18
ten 32:5
Tenth 2:17
term 13:23 14:2,5
44:21 54:9,11
terms 7:18 19:4
66:2
testified 9:6
testify 8:21 21:1
36:15,24
testimony 6:23 7:5
8:10,18 20:23
34:14 35:23
36:11 42:8,18,20
42:22 43:10
52:19 58:4 61:16
61:19,25 62:15
62:16 63:12 64:6
65:21,23
text 43:20 44:2
thank 7:24 10:12
19:8 22:4 23:7
38:10 41:23 42:7
42:10 54:5 56:3
60:16,19,20,21
60:23 62:1,17
64:7,18 65:19
things 42:3 46:4

46:13 60:14
think 36:25 53:11
54:22 55:6,16,16
62:5,12
thousand 9:16
52:20
threatened 63:23
threats 40:22
thumb 53:21
Tiega 25:14
Tierralta 25:14
tight 37:16
time 6:24 7:15,16
7:23 8:2,2 24:19
28:10 39:21 41:9
41:24 42:5,8
47:9 49:16 54:6
60:16 61:2 63:19
66:2
times 12:17 57:6
58:10
titles 18:17 19:12
19:17,20
today 4:1 5:18
7:15,21 8:15
23:2 35:6,16,18
40:15,15 41:25
50:15 60:18
61:10 62:8
today's 6:13
told 28:13 32:25
33:25 46:2 58:2
58:12,16
TORT 1:4
touch 61:16
towns 28:24 29:4
29:11
trafficked 31:2,3
trafficking 17:22
30:5,15,19
transcript 42:19
67:10,11
translated 12:16
13:24 14:2
translation 12:16
13:23 35:10
36:21 38:5 57:14
65:2
translator 5:8
12:15
travelled 42:9
true 36:12 67:11
trust 48:14
truth 9:1 22:8
34:16 36:3 46:18
truthfully 8:14
561-835-0220
try 34:12 42:4

55:22
Turbo 28:22 44:10
46:6,7
turn 43:19 46:16
twist 8:17
twisting 8:16
two 11:20 17:3
24:6,7 25:24
40:11 48:24 64:4
type 14:23 48:7
52:23
U
U.S 5:6,9 6:1 7:6
18:24 31:3 39:10
39:16 58:3 62:25
64:6
unaware 61:9
underground 63:22
understand 21:3
33:16 36:25
41:24 42:2,3
44:23,25 52:6
63:14
understood 30:8
unfortunately
34:15 48:12
uniforms 17:25
38:2,8
unit 13:11 14:6
21:10
United 1:1 4:5
5:16 6:8,18
23:18,19 39:1
42:12,13 50:8
55:18 59:14 63:4
63:6,14 64:5
Urab 21:15 23:24
25:4,17,18 26:8
26:10 27:7 28:22
30:25 40:1 44:7
44:9 48:11,17,17
51:2,7,16,24
57:3
Uribe 33:6
use 15:23 16:2,11
16:15
V
vaccines 31:6
54:11,13 55:7
vacuna 13:24 14:2
Vahlsing 2:10 3:8
5:15,16 13:22
18:22 19:18 22:3
22:12,21 33:19

79 11
of
Page
80
35:10 38:5,25,25
39:7 40:4 41:20
42:11 43:3,9,17
43:18 44:24
45:19 47:5,12,24
48:6 49:2,8,9,18
49:21 50:2,4,5
51:12 52:1,15,16
53:5,11,16 56:11
56:22 57:14,21
58:5 59:25 60:20
62:6 63:9 65:18
Valle 32:7
valuables 36:15
value 36:23
Velez 33:6
Veloza 59:15
version 43:11,11
versin 52:2
versions 32:5
33:17 45:23
46:14 52:14
Vicente 25:21,25
26:1 28:9,13,15
28:18 31:4 32:6
32:25
victim 43:13
victims 4:17 22:7
23:24 35:3 37:20
37:21 39:2,4
40:1 42:12 60:21
Victoria 61:14
Vincente 9:21 11:1
12:10 13:4 25:23
32:4,24 41:2
46:10 48:3,7,11
51:11,13 53:2,22
56:25 57:5 58:24
59:4,18 60:12
violated 41:9
violence 23:24
27:16 40:1
visit 41:25
visiting 40:16
visitors 56:5
void 46:8
voluntarily 44:17
45:7,16
voluntary 40:22
43:11
W
waiting 48:22
waived 66:8
want 19:9 30:10
42:1,7,9,14 45:8
wanted 7:3 12:18
13:2 33:24 36:20

45:18 46:6,15
47:10
wants 18:20
war 18:11
Washington 2:8,17
wasn't 29:22 32:24
way 19:23 31:17
45:11 62:15
ways 52:20
we're 7:8,23 11:20
15:12 49:8
We've 40:10
wealth 45:18
weapons 17:16,25
18:3 38:1,8 51:2
51:10 54:25
58:20
Wednesday 1:19 4:1
40:15
week 6:18 57:7
weeks 64:4
went 9:11 25:17
57:3,3 61:10
whatsoever 40:24
WILLIAM 3:2
willing 7:4 65:15
wish 24:11 40:24
41:2,25 62:14
wishes 43:3
witness 8:8 9:2,13
10:2,19 11:15,19
11:25 12:7 13:1
13:13 14:10,16
14:25 15:5,10,14
15:15,20,24 16:5
16:12,17,22
17:10,17 18:5,12
18:19 19:24 20:6
20:15 21:3,7,11
22:18 24:6,17,24
24:25 25:6,15
26:9,22 27:5,18
27:25 28:4 30:8
30:12,18,23
31:11 32:13,19
33:10,15,24,25
34:8,15 35:18
36:1,6,9,10,17
37:8,15 38:6,9
38:20 40:3,5
41:11,16,22 43:7
44:25 46:25 47:6
47:16 48:10 51:9
51:20 52:6 53:9
53:21 54:22
55:10 56:23
57:16 58:6,9,12
59:11 60:23 61:5
65:2 66:8
Wolf 4:15 23:1,15
23:17,23 39:4,24
54:2 62:2
wondering 45:20
53:1
word 35:11 52:9
words 55:6
working 7:23 28:11
wouldn't 18:18
36:10,12 53:12
55:11
written 37:2 39:18
wrong 35:15
X
Y
year 25:19 42:21
53:9
years 9:11 26:24
29:9 35:19 48:23
Z
zone 44:6,9,14,14
zones 27:5 44:10
0
00 26:16 28:20
011973 9:16
07-cv-60821-KAM
1:13
08-01916-MD-MA...
1:2
08-80421-CIV-M...
1:11
08-80465-CIV-M...
1:11
08-80480-CIV-M...
1:13
08-80508-CIV-M...
1:12
1
1 55:19 67:9
1:05 61:1
1:20 1:20 66:6
10 32:15 54:16
10-60573-CIV-M...
1:12
10:12 4:2
10:14 1:20
100 26:25 27:8
31:18
1025043 5:17
561-835-0220
10272988 5:11
11 33:7
11001-67-00-00...
1:16
11th 42:20
12 1:19 4:1 29:9
31:5 32:5 33:11
121671 4:19
13 19:7 34:6
15 35:6
16 35:22
1612 2:7
169463 5:13
17 36:13
18 37:5
18th 67:19
19 24:11 37:12
19027 2:4
1968 9:21,22
1988 24:18,19
1994 25:20 28:4
1995 57:2
1997 10:5 25:24
26:1
2
2 25:2
20001-4956 2:17
20006-2826 2:8
2002-2003 29:19
2004 9:22 26:2
2007 42:21 45:23
46:14
2015 1:19 4:2
67:19
202.466.5188 2:9
202.662.5273 2:18
203 2:21
215.782.8367 2:5
21537 5:24
29726 2:3
3
3 17:12 26:19
30 49:3
30,000 29:10
305797 23:17
310-614-0321 2:13
4:24
33424 6:5
385 8:20
39784735 6:4
4
4 18:7 27:2
4,000 4:16 35:2
40:1

80 12
of
Page
80
4:00 7:16 41:11
40 29:23
401 2:8
41 3:8
5
5 21:23 24:5 27:15
50 31:3,19
51 4:22
51-222 2:12 4:22
54 3:9
56 3:9
57 2:12 4:22
571)743062 2:22
6
6 28:1
66 67:10
7
7 30:4
70 1:21
71723789 4:20
77 2:21
7A 2:21
8
8 9:16
850 2:17
9
9 3:8 32:10
90 29:24
99 2:21
561-835-0220

Monoleche Deposition Transcript

Transféré par

Informations du document

Copyright

Formats disponibles

Partager ce document

Partager ou intégrer le document

Options de partage

Avez-vous trouvé ce document utile ?

Ce contenu est-il inapproprié ?

Droits d'auteur :

Formats disponibles

Monoleche Deposition Transcript

Transféré par

Droits d'auteur :

Formats disponibles

Case 0:08-md-01916-KAM Document 944-4 Entered on FLSD Docket 11/24/2015 Page 1 of 80

Case 0:08-md-01916-KAM Document 944-4 Entered on FLSD Docket 11/24/2015 Page 2 of 80

IN THE UNITED STATES DISTRICT COURT

CHIQUITA BRANDS INTERNATIONAL, INC.,

ALIEN TORT STATUTE AND

Case 0:08-md-01916-KAM Document 944-4 Entered on FLSD Docket 11/24/2015 Page 3 of 80

On behalf of the Plaintiffs:

On behalf of the Defendants:

Case 0:08-md-01916-KAM Document 944-4 Entered on FLSD Docket 11/24/2015 Page 4 of 80

DEPOSITION OF JESUS IGNACIO RLDAN PEREZ

EXAMINATION BY THE COURT:

Case 0:08-md-01916-KAM Document 944-4 Entered on FLSD Docket 11/24/2015 Page 5 of 80

Today is Wednesday, August 12,

2015, at 10:12 in the morning.

District -- Judicial District opens this public

hearing on behalf of the Southern District of the

State of Florida of the United States.

being Chiquita Brands International --

The interpreter requests a

repetition of the case number, the remaining parts of

the name, and the case number.

For the record, may the parties,

please state their appearances.

Good morning, Your Honor, and to

all those present.

here representing Dr. Paul David Wolf, who is an

attorney representing over 4,000 families who are

victims of the armed conflict.

And I identify myself here by my professional

license number 121671 issued by the Superior Judicial

Council and my citizen ID 71723789.

And for purposes of legal notifications, my

address is Carrera 51 -- 57, No. 51-222 Edificio

Calle Nueva in Medelln.

purposes of official notification, is

Case 0:08-md-01916-KAM Document 944-4 Entered on FLSD Docket 11/24/2015 Page 6 of 80

My name is Luis Felipe

Nancy Hand, certified

federal court interpreter, U.S. certified federal

I am a translator for the

plaintiffs, U.S. citizen.

am also the bearer of professional license number

169463 of the Supreme Judicial Council.

assisting the attorneys for the plaintiffs.

My citizen ID number is 10272988.

Hello, my name is Marissa

identified with the professional card 1025043 for the

Bar of the District of Columbia.

a representative for the plaintiffs.

I'm a United States citizen.

Good morning, Your Honor and

professional license is from the Supreme Court of the

My name is Judith Brown Chomsky.

Case 0:08-md-01916-KAM Document 944-4 Entered on FLSD Docket 11/24/2015 Page 7 of 80

I am U.S. counsel for Chiquita Brands International.

Cadavid and I'm a Colombian attorney.

Chiquita Brands International.

My professional license number is

I am here assisting the attorneys for

States, here representing the defendants in this

I'm an attorney from the United

permission to make some preliminary inquiries

regarding the procedures for today's proceeding?

the attorneys, both for the plaintiffs and the