First Deposition

CERTIFIED EXCERPT

Transcript of Rueben Z. Corazzo, Esq.

Date: May 27, 2012

Case: The Royal London Research Institute -v- European Court of Human Rights

ON BEHALF OF PLAINTIFF:

LAMIA GRAHAM, ESQUIRE

JAMES F. BROOKS, ESQUIRE

MICHAEL GEERHADT, ESQUIRE

ROMILY J. ORFANEDES, ESQUIRE

THE EUROPEAN COURT OF HUMAN RIGHTS

 

13 ON BEHALF OF DEFENDANT:

ILANA WILKINSON, ESQUIRE

RONAN BERMAN, ESQUIRE

STEVEN A. MYERS, ESQUIRE

LORNE NICOLS STERLING, ESQUIRE

ROGER ABRAMS, ESQUIRE

CARROLL NOBLE, ESQUIRE

THE ROYAL LONDON RESEARCH INSTITUTE

 

VIDEO SPECIALIST: The court reporter today is Brenda Huff. Would the reporter please swear in the witness.

RUEBEN Z. CORAZZO, ESQ. having been duly sworn, testified as follows:

EXAMINATION BY COUNSEL FOR PLAINTIFF BY MS. GRAHAM:

Q: Good morning, Mr. Corazzo.

A: Good Morning.

Q: I know you’re a lawyer, and we’re days into the deposition, so I’m sure you’re familiar with the rules.

A: Yes.

Q: I just want to go briefly over your history. If you can just tell me about your education background, college and law school.

A: I went to the LSE for undergraduate, and then Oxford for Post.

Q: Okay. And when did you graduate from LSE?

A: 2002 and from Kings College in 2005.

Q: Thank you. And in 2005 you went to a law firm. Is that right?

A:  I did. I went to work at Welch & Fowler, which is a law firm here in London.

Q: And what did you do for them, practice as a litigator?

A: I represented health facilities that were being investigated for unexplained deaths.

Q: Okay. Is that litigation?

A: It was an array of activities that also included litigation.

Q: And how long were you there for?

A: From 2005-2008.

Q: And that’s when you started working for LRI?

A: I was working for LRI while at Welch too.

Q: How does that work?

A: I was headhunted and subsequently offered a job at LRI.

Q: When you say headhunted, what exactly did that entail, and how did it come about?

A: Doctor Quentin attended a hearing that I was counsel for in 2006. After the verdict, he approached all of us on the bench.

Q: All of you being

WILKINSON: Objection. I’m going to object because it’s beyond the scope and is not really relevant to what the four corners of the – I mean, general background, but it doesn’t relate to the case-

GRAHAM: I don’t — we don’t need to go over everything that was done in the courtroom, but, rather, with respect to the background of Mr. Corazzo and why he was chosen by the LRI, I believe this line of questioning is relevant to the scope.

HOLMES: Overruled. Ms. Graham, please continue. Pointedly.

GRAHAM: Thank you.

BY MS. GRAHAM:

Q: What did Dr. Quentin say when he approached you and your colleagues?

A: He commended us on a job well done. He explained that he was from the LRI and that they could use counsel like us for an upcoming operation. My colleague, the lead defence, advised him to contact the practice but Dr. Quentin explained that, given the size of the operation, they would need ongoing in house counsel. He asked if any of us were looking for ‘career growth’. My other colleague, who was second chair, displayed an interest. Dr Quentin then asked for all of our business cards. I didn’t have one at the time so I just told him my name. He then asked who wrote the closing argument and I replied that it was me. Then we went our separate ways.

Q: Why did you not have a business card?

A: I was still a legal aide at the time. At Welch and Fowler, legal aides do not have business cards.

Q: Was it normal for a legal aide to write the closing arguments for a case?

A: No, but at the time we were juggling a lot of cases. I wrote something for each and every one, just so we could keep our heads above water. Welch & Fowler were a fledgling practice during the recession. Without people like me, it wouldn’t still exist now.

Q: So out of all three people approached, you were the least qualified?

  1. WILKINSON: Objection-
  2. GRAHAM: least senior, then?

A: Yes.

BY MS. GRAHAM:

Q: Was that the last time you spoke to Dr. Quentin?

A: For a while, yes.

Q: and in the interim, you had no dealings with the LRI?

A: Not exactly. I was contacted that week and subsequently every week by the Head of HR at the LRI.

Q: Can you identify this person by name?

A: Constance Eugene.

Q: And what form did this contact take?

A: A host. Emails, phonecalls, letters. Invites to LRI Events. Gifts.

Q: To your place of work?

A: To my place of work, my flat, my childhood home, my then girlfriend’s tenement in Buenos Aires where she was volunteering at the time.

Q: I’m sorry?

A: Ms. Eugene had found out that I was visiting my girlfriend in Buenos Aires for 2 weeks and sent us tickets to the opera.

Q: How did she find this out?

A: I don’t know. I don’t know how she managed any of what she did, to be honest. If you ask me, it wasn’t natural.

WILKISON: Objection. That last bit was irrelevant, unadmissable. He answered the question with ‘I don’t know.’ Everything following is unnecessary.

GRAHAM: Are you saying that your client’s testimony is unnecessary?

WILKINSON: I’m saying he answered the question and you paused to allow him to implicate himself.

GRAHAM: Unfounded.

HOLMES: Ms Wilkinson, are you accusing Ms. Graham of leading the witness?

WILKINSON: I am asking that only Mr Corazzo’s first answer be admissible.

HOLMES: Sustained.

BY MS. GRAHAM:

Q: Back to this contact, was it a back and forth between you and Ms. Eugene?

A: I missed the first couple of calls. I replied to an email inviting me to LRI for a chat, and explained I was swamped with work and would not have the time, that I appreciated the interest but I was happy at Welch. There were more calls and emails after that that I did not reply to. Then Ms Eugene intercepted me on my way back from court to Welch.

Q: How long after your first encounter with Dr. Quentin did this happen?

A: About a month. Just over a month.

  1. Were the other people who met with Dr. Quentin also being pursued in this way?

A: If they were, it wasn’t for very long.

  1. So would you say Ms. Eugene and the LRI were focused on you?

A: Out of everyone in my circle, yes. I can only speak to that.

Q: And were the gifts sent during this time?

A: No. After.

Q: What was the nature of your fist encounter with Ms Eugene?

A: She had understood that I was too busy to talk at the LRI, so she brought the chat to me. We shared a cab back to the office.

Q: What was discussed at this meeting?

A: Mostly me.

Q: Can you go into any more detail?

A: She asked me about school, about Welch and Fowler.

Q: Did she tell you why the LRI wanted in house counsel?

A: Not until I asked.

Q: What was her reply?

A: That the LRI had been tasked with investigating an existing condition in its early stages and that the experiment would be quite large, involving multiple subjects, and spanning a couple of years. They needed someone to keep an eye on the ethics of the experiment.

Q: Were those her exact words?

A: She probably used more words, but it was to that effect.

Q: That the LRI had been tasked? As in asked to undertake this research?

A: Yes. That was what was communicated to me.

Q: What was the outcome of this meeting?

A: Much like before, I thanked her for her interest in me, but I assured her that I wanted to make partner at Welch and I wasn’t interested in anything else until then.

Q: And what was Ms Eugene’s reply?

A: She was cordial.

Q: And after this, your contact ended?

A: No, it ramped up. This is when the gifts started, when we went to the Opera in Buenos Aires.

Q: And how long did this period last?

A: Until I was made partner.

Q: And when roughly was that?

A: (No verbal response.)

Q: Mr Corazzo?

A: Three months later.

 

 

 

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