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Federal Criminal Trialtrial-daytrial-dayThane RehnDanielle R. SassoonMark S. CohenDavid F. LisnerRobert BoroujerdiCan SundirectcrossredirectDay 12 - October 19, 2023Can Sun testified about FTX's customer-asset representations, Alameda's special account treatment, a $7 billion withdrawal shortfall, and his search for legal explanations. Third Point investor Robert Boroujerdi described the firm's understanding of FTX and Alameda, its investment decision, and the loss of its $60 million investment.
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Day 12 - October 19, 2023

Can Sun on Customer Funds and Legal Explanations; Third Point’s FTX Investment

Judge Lewis A. Kaplan
7Proceedings
2Pages
2Witnesses
1,719Lines
2Sidebars
Day 12 of 19
Appearing:

Can Sun testified about FTX's customer-asset representations, Alameda's special account treatment, a $7 billion withdrawal shortfall, and his search for legal explanations. Third Point investor Robert Boroujerdi described the firm's understanding of FTX and Alameda, its investment decision, and the loss of its $60 million investment.

Full day summary

Can Sun testified that, as FTX's general counsel, he relied on management, finance personnel, and company statements when describing customer assets as safeguarded and FTX and Alameda as separate. He said he never approved lending customer money to Alameda. Sun described learning that Alameda was exempt from auto-liquidation, seeking removal of the exemption, and understanding that proposed changes were not implemented before FTX collapsed. He testified that a November 7 spreadsheet showed a $7 billion customer-withdrawal shortfall and money Alameda might return. When Bankman-Fried asked for legal justifications, Sun said none of the theories he examined was supported by the facts. On cross-examination, Sun discussed his housing loan, FTX's terms of service, the legal team's assumptions about Alameda's funds, and why he did not resign when he first learned of Alameda's special account treatment. The defense also questioned the incentive created by his nonprosecution agreement; on redirect, Sun read language stating that the agreement made no determination that he had violated federal law. Robert Boroujerdi testified that Third Point relied on FTX's financial information and understood FTX and Alameda to operate independently, without Alameda receiving a risk-engine exemption or access to customer funds. He said Third Point would not have invested had it known otherwise and valued its $60 million FTX International investment at zero. Cross-examination addressed Third Point's understanding of FTX's transaction partners and related parties.

1. Can Sun — Direct/Cross/Redirect

Can Sun completed direct, cross, and redirect examination on Day 12, addressing FTX's customer-asset representations, Alameda's special treatment, executive loans, the $7 billion shortfall, and his nonprosecution agreement.

Procedural
Trial Scheduling and Proposed Jury Instructions Can Sun
37 lines
Direct
Can Sun — Direct Can Sun Danielle R. Sassoon
869 lines

FTX general counsel Can Sun testified about customer-asset protections, Alameda's special account treatment, documented founder loans, and his November 7 conclusion that no legal justification supported the missing customer funds.

2 sidebars inside this proceeding
  1. Scope of FTX Terms ExhibitCounsel discussed whether FTX's terms of service could be used beyond their effect on readers and how the provisions could be examined before the jury.
  2. Dispute Over Government Exhibit 514The parties disputed whether Government Exhibit 514 concerning FTX Digital Markets policies could be used outside its truth and whether its differing entity context would confuse or prejudice the jury.
Cross
Can Sun — Cross Can Sun Mark S. Cohen
483 lines

Defense counsel tested Can Sun's knowledge and credibility through his compensation, FTX's legal structures, Alameda's special account treatment, the November shortfall, and his nonprosecution agreement.

Redirect
Can Sun — Redirect Can Sun Danielle R. Sassoon
28 lines

Can Sun clarified that his government agreement made no determination that he violated federal law and said he voluntarily cooperated and traveled from Japan to tell the truth.

Highlights

Can Sun — Direct“Never approved anything like that, and I would never have done it either.”— Can SunSun expressly denied approving any lending of FTX customer money to Alameda.Can Sun — DirectrulingThe court received the May 2022 terms of service only for the limited purpose stated by the government, deferred the defense's request for another basis until cross, and said the document's legal import was likely a question of law for the court rather than the jury.Can Sun — Directtestimony highlightSun testified that he was shocked when he learned in August or September 2022 that Alameda was exempt from auto-liquidation, sought removal of the exemption, and understood that the proposed replacement and disclosures had not been implemented before FTX collapsed.Can Sun — Directtestimony highlightSun testified that a November 7 spreadsheet showed FTX was $7 billion short of satisfying customer withdrawals and listed money Alameda could return; he said the responses to his questions were absent or vague and that his suspicion of misappropriation grew.Can Sun — Direct“I was shocked because it showed that FTX was short $7 billion to satisfy customer withdrawals, and there was a separate tab in that spreadsheet that showed the amounts of money that Alameda could return to FTX to satisfy customer withdrawals.”— Can SunSun described the financial information that changed his understanding during the November 7 capital-raising effort.Can Sun — DirectconfrontationSun testified that Bankman-Fried asked him for legal justifications for the missing funds, that Sun found none supported by the facts, and that Bankman-Fried reacted without surprise when Sun explained the three theoretical arguments.Can Sun — CrossimpeachmentThe defense introduced Sun's nonprosecution agreement and questioned the incentive it created. Sun repeatedly stated that truthful testimony would protect him from prosecution.

2. Robert Boroujerdi — Direct/Cross

Day 12 continued with Robert Boroujerdi's testimony about Third Point's FTX investment, followed by cross-examination concerning financial statements and transaction partners.

Direct
Robert Boroujerdi — Direct Robert Boroujerdi Thane Rehn
252 lines

Third Point managing director Robert Boroujerdi testified that the firm relied on FTX's financial information and representations about Alameda and customer assets before investing $60 million, an investment he valued at zero.

Cross
Robert Boroujerdi — Cross Robert Boroujerdi David F. Lisner
33 lines

Defense counsel tested Robert Boroujerdi's knowledge of FTX's related-party transaction arrangements; he described transaction partners identified during diligence but could not say whether any technically qualified as related parties.

Procedural
Adjournment and Post-Testimony Matters
17 lines

Highlights

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