Fredy Ramsoondar Deposition excerpts *Note no updates of Hearing held on March 19, 2015 before Judge Rakoff as of this posting on Summary Judgement and Trial date for Fredy Ramsoondar and FGI. Fredy Ramsoondar deposition Jan 2015 – a few beginning excerpts from 180 page document Page 4 Would you state your name for the record for me, please. • • • • •A.• •Fredy Ramsoondar. • • • • •Q.• •What is your home address? • • • • •A.• •5044 McLuhan Road, Edmonton, Alberta, • •Canada. • • • • •Q.• •Do you have any other addresses? • • • •A.• •No, I don't. • • • • •Q.• •So that is where you live throughout the • •year? • • • • •A.• •Yes. • • • • •Q.• •Where did you go to school? • • • • •A.• •I went to school in several places: Page 5. • • •Guyana, Barbados, South Africa. • •• • • • •Q.• •Do you have any degrees? • • • • •A.• •I have a bachelor's degree from Durbin • •• •University.••That is all that I have • • • • • •I have a commerce -- sorry, a diploma • •• •from the Toronto School of Business. • •• • • • •Q.• •What is your bachelor's degree in? • •• • • • •A.• •It's just generic, accounting, nothing •• •specific. •• • • • •Q.• •When did you achieve that? •• • • • •A.• •I believe it was 1998. Page 11• • • • • Q.• •Is there any reason why you can't testify truthfully today, perhaps you are •• • on some kind of medication, or something to that effect? • • • • A.• •No. • • • • •Q.• •I want to go back to where we were. GPS Security Group, you said that your wife is the owner of that company; is that correct? • • • • •A.• •That's correct. • • • • •Q.• •Are there any other owners of that company? • • • • •A.• •No, there are not. Q.• •Do you know when GPS Security Group was started? • • • • •A.• •April 2013. • • • • •Q.• •Who incorporated GPS Security? • • • • •A.• •I did. Page 12 Q.• What is your citizenship? • • • • •A.• •I am Canadian and I am Guyanese. Page 13 Q.• •In April of 2013, when you incorporated GPS Security, how many • • • employees did it have at or around that time? • • • • •A.• •It didn't have any employees. • • •Q.• •Did it provide services? • • • A.• •It started providing services in April, that's correct. Page 19 Q.• •As CFO, what were your duties? •• • • • •A.• •Prepare the quarterly statements. •• • • • •Q.• •Anything else? • • • • •A.• •That was basically what it was, just preparing quarterly statements. •• • • • •Q.• •Did you have anyone that worked under you? Page 20 A.• •Yes, there were several people. • • • • • • •There was an accountant, and there were • • •several other people that worked in the company as well. • • • • • •Q.• •About how many people reported to you when you were CFO? • • • • •A.• •Four. • • • • • •Q.• •What were their duties? • • • •A.• •Payroll, invoicing, accounts payable, and general accountant. • • • • •Q.• •So you were responsible for those duties • •as well through those subordinates? • • • •A.• •Yes. Q.• •Then you became CEO, I believe you said, • •in December of 2011. What would you describe your duties as as • •CEO? • • • • •A.• •Mostly marketing.•I did mostly marketing, attracting new clients, and trying to promote the stock. • • • • •Q.• •How many people reported to you when you were CEO? • • • • •A.• •I didn't have anyone directly working for me at that time that reported to me.