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Federal Criminal Trialtrial-daytrial-dayNicolas RoosDanielle R. SassoonChristian R. EverdellCaroline EllisonGary WangcrossredirectcolloquyrecrossdirectDay 5 - October 10, 2023Gary Wang's cross and redirect examined Alameda's balances, special FTX privileges, promissory notes, and cooperation. Caroline Ellison then began direct testimony about customer funds, Bankman-Fried's role in major decisions, and Alameda's investment risks.
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Day 5 - October 10, 2023

Wang on Alameda Balances and Loan Notes, Followed by Ellison's Direct Testimony

Judge Lewis A. Kaplan
6Proceedings
2Pages
2Witnesses
3,340Lines
1Sidebars
Day 5 of 19
Appearing:

Gary Wang's cross and redirect examined Alameda's balances, special FTX privileges, promissory notes, and cooperation. Caroline Ellison then began direct testimony about customer funds, Bankman-Fried's role in major decisions, and Alameda's investment risks.

Full day summary

Gary Wang's cross-examination focused on Alameda's balances, asset valuations, promissory notes, and his cooperation with prosecutors. Wang agreed that correcting an accounting bug initially produced a positive net asset value, while qualifying that some assets were illiquid or dependent on uncertain valuations. Nine promissory notes were admitted, and the defense questioned him about his guilty pleas, government meetings, trial preparation, and hope for a sentencing letter. On redirect, Wang testified that Alameda's special FTX features enabled approximately $8 billion in withdrawals and were not necessary for market making. Using Government Exhibit 50, he described balances ranging from negative $2.8 billion in Alameda's main account to negative $16 billion when a large FTT-holding account was excluded. He also maintained that FTX's public assurance about its assets was misleading because the exchange lacked enough money to meet customer withdrawals. The court later questioned him about a $35 million promissory note and his uncertain understanding of the related investment. Caroline Ellison then began direct testimony. She admitted fraud, conspiracy, and money laundering with Bankman-Fried and testified that he directed her conduct. She described Alameda's special line of credit, customer deposits routed through Alameda accounts, the Binance stake buyback, efforts to support FTT's price, and Bankman-Fried's authority over major decisions. Ellison also discussed a spreadsheet modeling whether Alameda could repay recalled loans after further venture investments. After the jury left, the court considered but did not resolve issues involving proposed remote testimony, the value of an Anthropic investment, and Ellison's November 9 all-hands statements.

1. Gary Wang — Testimony (Part 3)

Gary Wang’s testimony on Day 5 concluded after continued cross-examination, redirect about Alameda’s privileges and balances, and questions from the court and defense about promissory notes and possible investment interests.

Cross
Gary Wang — Cross Gary Wang Christian R. Everdell
1464 lines

The defense used Alameda balance calculations, promissory notes, Wang's earlier statements, and his cooperation history to argue for solvency and operational explanations while challenging his credibility and incentive to assist prosecutors.

Redirect
Gary Wang — Redirect Gary Wang Nicolas Roos
484 lines

Gary Wang testified that Alameda's special privileges supported billions in non-market-making withdrawals, its balance depended partly on illiquid FTT, and he admitted crimes with Bankman-Fried before obtaining a cooperation agreement.

1 sidebar inside this proceeding
  1. Exhibit 545 Time-Zone ObjectionThe defense raised a time-zone concern about Exhibit 545, and counsel also asked when to submit letters concerning the next day's testimony.
colloquy
Court's Examination of Gary Wang Gary Wang
40 lines

The court questioned Gary Wang about a $35 million promissory note, the uncertain investment behind it, whether Wang received any proceeds or assets, and Alameda Research's ownership.

Recross
Gary Wang — Recross Gary Wang Christian R. Everdell
5 lines

Gary Wang said his rough understanding was that he probably received equity stakes through the investments, but he was not entirely sure and had no paper documenting a specific holding.

colloquy
Court's Examination of Gary Wang Gary Wang
16 lines

The court clarified Wang's indirect interest in an Alameda investment and elicited his uncertain recollection of Sam's explanation for why he signed the note.

Highlights

Gary Wang — Crosstestimony highlightWang agreed that correcting the fiat@ bug produced a positive overall Alameda NAV and initially brought relief, but he qualified that the assets might be illiquid and that later positive-NAV calculations depended heavily on investment valuations.Gary Wang — Cross“I said it was true but misleading.”— Gary WangWang resisted the defense's attempt to characterize his initial assessment of the November 7 assets tweet as simply true.Gary Wang — Crossevidence eventNine promissory notes signed by Wang were admitted. One published note reflected an approximately $35 million obligation, annual interest, Wang's signature, and Caroline's signature for Alameda.Gary Wang — CrossconfrontationThe defense examined Wang's cooperation incentive, establishing five initial proffer sessions, four guilty pleas carrying a stated maximum of 50 years, continued preparation meetings, and his hope for a government sentencing letter.Gary Wang — Redirecttestimony highlightWang rejected market making as the sole explanation for Alameda's special features, attributing approximately $8 billion in withdrawals to them and saying neither those withdrawals nor the $65 billion credit line was necessary for market making.Gary Wang — Redirectevidence eventUsing Government Exhibit 50, Wang identified a negative $2.8 billion balance in Alameda's main account, said excluding a large FTT-holding account made Alameda's balance negative $16 billion, and described a negative $14 billion balance by September 2022.Gary Wang — Redirecttestimony highlightWang said FTX's public statement that its assets were fine was misleading because FTX lacked enough money to satisfy customer withdrawals, then testified that he admitted crimes with Bankman-Fried at his first government meeting before receiving an agreement.Gary Wang — Redirect“Because it was unlike -- regardless of how you define assets, FTX did not have enough money to satisfy customer withdrawals.”— Gary WangWang explained why he regarded the public assurance about FTX's assets as misleading.

2. Caroline Ellison — Direct (Part 1)

Caroline Ellison's Day 5 direct examination addressed Alameda's use of FTX customer funds, Sam Bankman-Fried's authority over major decisions, misleading lender balance sheets, and investments made despite liquidity risks.

Direct
Caroline Ellison — Direct Caroline Ellison Danielle R. Sassoon
1331 lines

Caroline Ellison admitted crimes involving FTX customers and Alameda lenders, attributed major decisions to Sam, and used contemporaneous records to explain Alameda's special access to customer assets, lender balance sheets, FTT practices, and investment risks.

Highlights

Caroline Ellison — DirectadmissionEllison admitted committing fraud, conspiracy, and money laundering with Sam, identified FTX customers, FTX investors, and Alameda lenders as the affected groups, and testified that he directed her conduct.Caroline Ellison — Direct“I sent balance sheets to our lenders at the direction of Sam that incorrectly stated the amount of our assets and our liabilities and made Alameda's balance sheet look less risky than it really was.”— Caroline EllisonEllison admitted sending misleading lender balance sheets and attributed the action to Sam's direction.Caroline Ellison — Directtestimony highlightEllison testified that Sam approved using Alameda's FTX line of credit to finance the Binance stake buyback, including approximately $1 billion she identified as customer cryptocurrency.Caroline Ellison — Direct“It showed that at a high level, making $3 billion more of venture investments and funding that with open-term loans would put Alameda in a significantly riskier position and make it much less likely or almost impossible that we would be able to pay off our loans if all of our loans were called at once.”— Caroline EllisonEllison summarized the central conclusion of her contemporaneous risk analysis.Caroline Ellison — Directevidence eventUsing the admitted NAV Minus Sam Coins spreadsheet, Ellison testified that an additional $3 billion in venture investments could leave Alameda unable to meet recalled loans in the modeled downturn even when customer funds were included; she said most loans ultimately remained open term.
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