First Deposition II

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

 

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 MR. BROOKS:

Q: Good Afternoon, Mr Corazzo. I’d like to go back to you encounters with Ms. Eugene.

A: Okay.

Q: You’re a legal aide, in your own words, swamped with work and a woman is messaging you on a weekly basis. What do you do?

WILKINSON: Objection. Asked and answered.

HOLMES: Sustained.

BY MR. BROOKS:

Q: Did you tell your mentor at Welch and Fowler about the messages?

A: No.

Q: Did you tell any of the other lawyers that you worked with?

A: No.

Q: Did you tell the police?

A: No.

Q: Why not, Mr Corazzo?

A: I thought it was harmless.

Q: What about when Ms. Eugene approached you, did you tell anyone about that?

A: I told my girlfriend.

Q: But none of the senior staff at your workplace?

A: No.

Q: Why not?

A: I don’t know. I figured it was not a work matter.

Q: But you knew why Ms. Eugene was approaching you. According to you, it was to offer you a job. Why not tell your mentor so they could intercede on your behalf or provide the LRI with willing council?

A: I assumed if that was what Ms. Eugene wanted, she wouldn’t be pursuing me personally.

Q: So you knew that she was interested in you personally?

A: I assumed, given her dedication to the cause, there was something about me, in particular, yes.

Q: And had she let you know why she was interested in you personally?

A: Dr. Quentin liked my work.

Q: Just your work? Not your colleagues? Mr Davenport or Miss Shrewsbury for example.

A: (No audible response)

Q: Mr Corrazzo.

A: I don’t know.

Q: But you did talk to Mr Davenport and Miss Shrewsbury about the LRI approaching them.

A: (No audible response)

Q: Mr Corazzo, we have a copy of their sworn depositions where both of them claim to have spoken to you about the LRI and Ms Eugene in particular.

A: Right.

Q: So you knew that Ms. Eugene was actively pursuing all those who had worked the case that you met Dr. Quentin on?

A: Yes.

Q: And so you advised Mr Davenport and Ms Shrewsbury to go to HR about Ms Eugene’s attempts to get in contact with them. Is that true?

A:(No audible response)

Q: Mr Corazzo, it’s a simple yes or no answer.

A: I said if it was bothering them they should do something about it.

Q: But you made it apparent that by ‘do something’ you meant ‘let Welch and Fowler know what was going on’?

WILKINSON: Objection, leading the witness-

HOLMES: Overruled. Answer the questions Mr Corazzo.

BY MR CORAZZO:

A: I don’t remember what I said exactly. But I could have said that vaguely.

Q: And by going to HR, you knew that if anything happened in the future between Welch & Fowler and the LRI, you knew that Ms Shrewsbury and Ms Davenport would be exempt from working for them.

A: I didn’t know that.

Q: You didn’t know Welch and Fowler’s Fit and Proper policy? I have a copy here that you signed that year, would you like to read it again?

A: (No audible reply)

Q: So I did you or did you not know the rules concerning relationships between clients and members of staff, Mr Corazzo?

A: I didn’t make them go to HR.

Q: Please answer the question addressed to Mr. Corazzo.

A: (No audible response)

HOLMES: Mr. Corazzo, may I remind you that you are under oath, and we are under time constraints. MR Brooks repeat the question, Mr. Corazzo answer it.

BY MR. BROOKS:

Q: Did you know, that by going to HR about Ms. Eugene and the LRI, Mr. Davenport and Ms. Shrewsbury would not be allowed to work with the LRI should they be made clients?

A: Yes.

Q: Did you tell Mr Davenport or Miss Shrewsbury about your interactions with Miss Eugene?

A: No.

Q: Did you tell HR about your relations with Ms. Eugene?

A: No.

WILKINSON: Excuse me. Can we go off the record for a minute and take a break?

BROOKS: Sure.

VIDEO SPECIALIST: We are off the record at 14:48.

(A recess was taken.)

VIDEO SPECIALIST: We are back on the record at 15:00.

BY MR. BROOKS:

Q: And then you got made partner after how long at the company?

A: A year and eight months.

Q: And in the thirty years Welch and Fowler had been around before you joined, how long roughly did it take a lawyer to become partner?

A: Anywhere between six and a half to thirteen years.

Q: But you made partner in a year and eight months. Did this strike you as odd at all?

A: Maybe.

Q: It either did or it didn’t, Mr. Corazzo.

A: I don’t think odd is the word I would use. It caught me by surprise.

Q: And why did it catch you by surprise?

A: (No audible response.)

Q: Mr Corazzo.

A: I didn’t expect it to be that quick.

Q: So we can say that your being made partner after a year was an unusual occurrence?

A: I suppose.

Q: At least to you and your practice.

A: Yes.

Q: And naturally, being a man of great intelligence-

WILKINSON: Objection. Speculation.

BROOKS: Speculation of what?

WILKINSON: Of my client’s intelligence.

BROOKS: He’s an Oxford graduate.

WILKINSON: Postgraduate. And that proves nothing. You’re an Oxford graduate. Boris Johnson is an Oxford graduate and he, as our mayor, got on, and then got stuck on, a zip wire. School is not an accurate measure of intelligence.

BROOKS: What would you consider to be an accurate measure of intelligence?

WILKINSON: Who knows? But the burden of proof is on you, Mr. Brooks, not me.

HOLMES: Mr. Brooks, please rephrase your question.

BY MR. BROOKS:

Q: Were you quizzical about your promotion?

A: No. Not really.

Q: So an unusual occurrence took place, involving you, and you had no questions about it, made no inquiries about it?

A: No.

Q: Why not?

A: Because I was taught not to look a gift horse in the mouth.

Q: That’s a good saying. Have you heard the one about something seeming too good to be true?

WILKINSON: Objection. Relevance.

HOLMES: Mr Brooks-

BROOKS: I’ll rephrase it.

BY MR BROOKS:

Q: So you just took the job?

A: Yes.

Q: Did you wonder why they offered it to you?

A: I assumed I was their last resort.

Q: You assumed that in a company of how many- sixty seven lawyers- all of them turned down the chance to become partner apart from you?

A: No. my department knew that they were looking for a partner in our field. I assumed the other lawyers in my department had turned it down.

Q: And how many people would that be?

A: Seven.

Q: Seven senior lawyers-

A: Five seniors.

Q: You thought five senior lawyers turned down partner and the company didn’t consider a new hire, or sending some other senior off for more training?

A: I figured I was probably cheaper.

Q: Did you know before your promotion that LRI was about to become a client at Welch and Fowler?

A: No.

Q: Did you know once you got your promotion that you’d been a condition in Welch and Fowler winning LRI as a client?

A: No.

Q: So as far as you were concerned your relationship with LRI had nothing to do with your promotion to partner.

A: At the time, that is what I believed.

Q: despite how instrumental you had been in narrowing the pool of candidates.

WILKINSON: Objection. My client has already attested to the fact that he did not make anyone go to HR. This is irrelevant.

BROOKS: It is not irrelevant to my argument if you would let me finish making it.

HOLMES: Mr Brooks, please continue to the point.

BY MR. BROOKS:

Q: Mr Corazzo, you never reported the emails. You never reported the gifts. You never reported meeting Ms. Eugene. You encouraged other potential candidates to go to HR with their complaints and then you got made partner because of it. You benefited entirely from LRI being a client of Welch & Fowler and you used that same shrewd and ambitious acumen once you started working directly for the Facility, didn’t you?

A: No. No-

Q: You knew what was going on and you were there to help them cut corners.

A: No! No. I did not know about the kids. I did not know about the kids in East Block!

HOLMES: Mr Corazzo, calm down.

CORAZZO: I did not know! You have to understand that I did not know that was happening in that house.

WILKINSON: Excuse me. Can we- Can we-

CORAZZO: I told them-

HOLMES: We’ll hold you in contempt, Mr. Corazzo.

WILKINSON: Can we take a break?

BROOKS: I’m fine with that.

VIDEO SPECIALIST: We are off the record at 15:28.

(A recess was taken.)

 

 

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