7 8 9 Who is your immediate superior? Bruce Brougham. Q Under your supervision, are what is their title or function? head. a group of individuals Α We function, with Mr. Brougham, as the District I am the Deputy District head, and we have two groups of teams under me and Mr. Brougham, one headed up by Betsy Viener, responsible for Georgia and Alabama, and another 10 individual responsible for our business in Florida. 11 Q I would like to draw your attention to the spring of 1975, your first contact with Mr. Bert Lance. Do you recall, or have any recollection of the meeting you attended in April of 1975? 12 13 14 15 Do you have any recollection of a prior meeting, Q I would like to show you what has been identified as C of C Number 2, and ask you if that is a memorandum you Q Can you testify as to what took place at that particular meeting? A Yes, I can. 3 MR. GERWIN: Yes, sir. MR. SERINO: You understand that if at any time you would like to speak to counsel you may stop the proceedings and speak to counsel? 12 13 14 THOMAS GERWIN was called as a witness and, having been first duly sworn by the notary public, was examined and testified as follows: 15 16 Q How are you presently employed, Mr. Gerwin? 17 18 A I am the Vice President, Deputy District Head in the Southern Division of the - Southern District of the National Division. Q How long have you been so employed? A I have been with the bank for about ten years, and in this position about five or six. Q In that capacity, what are your principal functions? A I am responsible for our banking relationships and corporate relationships in the State of Florida, Alabama, 7 8 9 Who is your immediate superior? Bruce Brougham. Under your supervision, are a group of individuals what is their title or function? head. A We function, with Mr. Brougham, as the District I am the Deputy District head, and we have two groups of teams under me and Mr. Brougham, one headed up by Betsy Viener, responsible for Georgia and Alabama, and another 10 individual responsible for our business in Florida. 11 12 Q I would like to draw your attention to the spring of 1975, your first contact with Mr. Bert Lance. Do you 13 recall, or have any recollection of the meeting you attended Q Do you have any recollection of a prior meeting, 16 17 prior to that particular meeting? A 18 No, sir. I would like to show you what has been identified as C of C Number 2, and ask you if that is a memorandum you prepared concerning that particular meeting with Mr. Lance. 6 Q What did take place? Mr. Lance and Mr. Cleveland came in and visited with 3 Mr. Brougham and myself. The primary purpose was to inform 4 5 6 7 8 9 us of his desire to purchase the National Bank of Georgia, to determine whether we had any interest in assisting him in the financing of the stock that he potentially could purchase. Q Did you have any discussion at that time concerning the possibility of obtaining the correspondent bank business of the National Bank of Georgia? 10 - 11 A Not as such. We met primarily with Mr. Lance to have him tell us the that he had an opportunity to purchase 12 13 14 15 16 this bank, and at the time he was really asking us whether we were willing to assist him in financing this transaction. Q Did he indicate at that time that he in fact was an official of the bank? A I don't recall. 17 Q Do you know whether or not he was in fact an official of the bank at the time hewas seeking a loan from If you would look, I draw your attention to the last paragraph of that memorandum, and there is some discussion concerning your relationship with Citibank. Do you have any recollection of that discussion? |