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CHARLES W. JENNESS - March 03, 2010
Page L @
ms rte cup sts me sTRICE COURT t APPEaRANGE
For 7 S007 ch IUSTRIOT8 OF ALBEE 2 FOR BLYN U HOLDING, LLC:
SEERA Dy VEE MR. MARC KUTNER
oR 28 YACHTS, AN SPAGNOLETTI A ASSOCIATES:
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oP CRAEON 8 ce oH ON 0 LOUSIANA STREET, 8TH FLOOR
Bis HOUSTON, TEXAS (Da:
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7 AND BEN FURKE
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fenan BEC. Ua TRKAR 08 ST, FRANOIS STREE
5 Ae,wen b o BELLUY MOBILE, ALABAMA 9680-344
12 Seeenpeecrs 10 Phone 291.45; 172
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USE se agcenans 42 FOR CORE BANK:
14 BIS, LINDAR. BOYLE
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* ATITTER i nh aR SESTRECE COURT BRACEWELL & GIULIADS
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6 i se SH EUW, TEMAS ia HOUSTON, TEXAS 77002-2770
7 u ur Ba a, Phone: 745.221.1541
RU. 1 f BORTEON y 15 bax: 719.202.8287
18 TOR SOTA Eoniil: inva, boyle@@belip.cam.com
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CRAL BEPOSITION OF CHARLES W. JENNESS roducsd as INDEX
2 PAGE
a witness. st the inctance of the PLAINTIFS, and duly Appearars
a eRWOrT, Wa laken is the above- styled and numbered 98 Stipuatoas,
4on MARCH 3, 2018, frum 10:4 a.m to 12:00 p.m. before BGHARLES W. JENNESS
B Moric A. Mith ESE in and forthe State of Texas, Exiunination by Mr, nes 45
Exaay ran ty Me. C DEIR. at
§ reporter! by wnachine shorthand,al the offic sof
7 Bracewell & Giuliani, LLP, 744 Louisians, Suite 29 1
Signature and Changes.
@ Houston, AS, DUTSUEME te Nol and the provisions
78
9 slated on the cacord or attached herelo. 22 Roporter's Cartifgate...
10 2"3
i Expire
4
12 NO. DESCRIPTION PACE, EXHIBIT
48 a6
+ Notiog of Deposition i “Ay
14 1G 2 Gresit Aaproval Form, 8/9/08
15 2. PrePurchase Condition \ratsation 59
174 Credit Anproval Fi ion Form a0
16 & Cosnpany Resolution to Barrow 5e
46.6 Oredit Approval Form, 16/19/06 2
7 7. Marine Management, inc, Valsation Be
18 49.8 Gredit Approval Form, 2075487 54
19 & Credit Approval Form, 2
20 10 Cranit Approval F fa, LEEOOE
20 41 Credit Appraval Gorm, 2720907
21 12 Marina Management. {nc., Yatuation ao
zt 13 Re PRE iotorma Budget 50
2 22 22 $4 Praterred Mortgage, 6/1/07 Bt A ERHIRT.
15 Limites Uablity Company Centfeate 82
28 29.18 Credit Approval Form, We WO3 8S Deponet 1 SOANTESS
24 47 Credit Approval Form, Ned Ancepted 87
2
2a
a6 Date. Brot.
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Page 2 (Pages 5-8}
CHARLES W. JENNESS - March 03, 2010
Page 5 Page 7
1 THE REPORTER: Would yau like to take the 4 Q@. {BY MR. KUTNER) And why were you calling
2 deposition by the rules? 2 tar. Goodloe?
3 MR. KUTNER: Yes. 3 A. Thad met Russell and he said that Lawyer
4 THE REPORTER: Would you agree to waive 4 Goodice would he a good person to have represent us
5 Rule 39{b)5 A and C? 5 down there.
6 MR. KUTNER; Yes. 6 a. Represent the bank?
7 THE REPGRTER: Would you like for the 7 A. Yeah,
8 witness fo read and sign his deposition? 8 Q In Alabama?
9 MS. BOYLE: Yes. 9 A. Yeah.
10 THE VIDEOGRAPHER: Stand by. The time ts 10 Qa. And you didn't realize at the time that you
44 four minutes after 10:00 a.m. We're on the record. 11 were calling him that he was already representing
12 (Exhibit 1 was marked) 42 Crimson?
13 CHARLES W., JENNESS, 18 A I didn't have a clus. it was merely a
14 having been duly swom, testified as follows: 14 friendship deal and that — that's it.
16 EXAMINATION 15 Q. Was that in the calendar year 2009 Ihat that
te BY MR, KUTNER: 16 phone call tock piace?
7 Q. Will you please state your name for the 17 AL Yes.
18 record? 18 Q. Do you understand that we are here for your
19 A Charles W. Jenness, 49 deposition se that you can be asked some questions
20 Q. And what narne du you go by, Mr, Jenness? ) ahout your invalvement in the finaneing of the project
at A.Chuck. 21 lo renovate the BETTY LYN Ii?
22 a.I'm here on behalf of BLYN ft Holding, LLC and 22 A Ide.
23 the owners of fhe BETTY LYN Hl motor yacht. My name is a Q. Allright. | want fo be abie to rety on what
24 Mark Kutner. | work for the faw fir of Spagnotett & 24 you fell me here today, Wir. Jenness, as being truthful
25 Company, 25 and accurate.
Page 6 Page 8
1 You and | have not had an opportunity to speak 4 Do you understand thal the oath that you have
2 before this deposition, have we? 2 sworn is the same oath that you would take in a
3 A. We have not. 3 courtroom if we were in front of a judge and jury ata
4 Q. Have you had an opportunity to speak with 4 trial of this lawsuit?
5 Mr, Goodloe before the deposition here today? 6 A, Ido,
6 A. Briefly. 6 Q. We have a video camera that is recording this
7 Q. Okay. And t wasn't referring to the 7 and although that video camera will be able to pisk up
8 conversation that took place in the roam here this 8 head nods, and hand gestures, ard the microphone will
9 morning. ¢ be uble te pick up your voice, we have a court
10 Have you aver had any other conversations with 10 reporter, whe is stenographically taking down your
11 him? 11 testimony as well.
1? a | have. 12 In order for Mr. Miller fo be able to
13 Q. When was that? 18 accurately take down your testimony, it's important
1” A. Amonth ago, | sailad him on the phone and he 14 that he hear what is said word-for-word. ft will make
18 informed me that he was representing the shipyard. 16 his job a tot easier If only one parson speaks at a
16 That was the extent of the conversation. 16 time, so if you'll do me the courtesy, as you are right
47 G. Were you calling him about anything that had 7 now of just listening, while | speak, | will try not to
18 to de with the financing of the BETTY LYN I), or the 48 out you off when you begin te answer. Okay?
49 lawsuits that have arisen, or was it about a separate 1 &. Good.
20 matter? 20 9. if Lask yeu @ question that calls in part for
24 A. It was — it was ~ he is a close personal 21 ayes or ano, I'm going to ask you to use the wards
22 friead of a friend of mine. 22 yes and no. Sometimes people use slang terminology
23 @. And who is that friend of yours? 23 like uh-huh,
24 A. What's his name? 24 When Mr. Miller has tc type out a transcript
25 MR. GOOCLOE: Russell Steiner. 26 of fhe deposition, it makes it very difficult to
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Page 3 (Pages 9-12)
CHARLES W. JENNESS - Marck 03, 2010
Page 9 Page LL
1 understand whether you meant yes or no, if you use a 1 Q. Okay. I you've worked at 20 different
2 slang term. Hf you do, I just potitely remind you 2 companies, i don't necessarily want to go through every
3 that fread a yes or ana, Okay? 3 ona of those companies, but if you've been at four or
4 A. Absolutely. 4 five different employers, and you can name thom for me,
5 Q. | will sometimes ask long, protracted, 5 Fwould like to do that.
6 confusing questions, Net intentionally, but it 6 Can you give me some astimate of how many
happens. if task you a question that you de net 7 different places you've worked atin your adult life?
3 understand, will you agree {o tell me that you den't 8 A [don’t know off the top of my head, but!
9 understand the question, rather than guessing with your 4 think the most prominent one, when | came to Houston,
18 answer? 40 after the paper company would be Walter M. Mischer, Sr.
Wi A twill. 4 Interests.
2 a. [would like to ge trough your backgronnd 12 Q. What does that business do?
19 just a litte bit 13 A. Well, we had 152 corporations in development,
14 Gan you tell me where you were raised, what 14 banking, manufacturing.
15 state? 18 Q. What did you do for that company?
16 A. Iwas born in Boston, raised in Evanston, 16 aw iwas his assistant.
a7 Illinois. Ww Qa To the CEO?
Ww Q. Okay. How far did you go in school? 1B aw To Mr. Mischer.
19 A. Graduated from the business school of indiana 19 a How tong did you work for Wailer M. Mischer
20 University. 20 Interests’?
2 G. When did you graduate from business school? at A. 20 years approximately.
am A In ‘63. 22 @. And that would have run through approximately
23 Q._ And in your professional life since you 23 what year? When would it nave ended?
24 graduated from college, have you had many jobs or just 24 A, Saventy ~ around '77, ‘78.
2b a few jobs? 28 Q. And what led you to leave Waller M, Mischer
Page 10 Page 12
1 A, Well, | wag initially a combat officer and 1 Interests?
2 then, | would say that I've had a number of jobs, but | 2 A I went Into the of! and gas business.
3 I've basically built -- built my own companies. 3 Q. Did you start a company? Did you go to work
4 Q. Did you go inta the service directly out of 4 for a. company?
95 college? 5 A. joined a company by the name of Mid-American
8 i did. 6 Ol & Gas.
7 What branch of the service were you in? 7 @. And what was your position with Mid-American
8 fwas in the Army. | was a tank commander, | 8 Cil & Gas?
8 Where did you serve? ° A. Vice president.
19 Fort Knox and Germany. 10 Q, What were your job duties for the ail company?
AV Haw long did you serva in the Army? 1 4. We raised money. That was my primary
W Little over two years. 12 function.
43 Were you honorably discharged? 13 a When did you leave Mid-American Cif & Gas?
4 Excuse me? a A Maybe 1983.
1S Were you honorably discharged? 48 a And why did you leave?
16 Yes, | was, 8 A. Mid-American Oil & Gas, Iwas skeady building
7 Okay. And when you gol out of the service, 17 some hiding companies, separate and apart from that.
18 what fine of work dict you go into? 48 One being Superior Derrick Services, which built
15 A. Iwas assistant
to the chainman of Champion 19 driiting sigs.
20 Intemational. 20 Q. Sa you went to work for another company ar dick
24 @. And what was Champion Interiational's 21 you — you started another company?
22 business? 22 A. Yeah, | awned the company.
23 A. I's a paper company. Qa And what was the name of that company, again?
2 Q. How long did you work there? 24 A ‘Superior Derrick Services.
25 &. Approximately
five years. 28 Q How tong did you operate that company for?
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Page 4 (Pages 13-16)
CHARLES W. JENNESS ~ March 63, 2010
Page 13 Page 18
1 A. Probably four years. 4 money man, you raise finances?
2 Q. Allright, And did you sell the company, did 2 A. Yes.
3 you disband, dissolve the company? 3 Q. How long did you work for Coventry
4 A. Sold the company. 4 Investments?
§ Q. And what did you do after you sold that 5 A. Eight -- eight ~ probably elght or nine
9 company? 6 years.
7 A. | put together what is now Camden Property 7 Q. Do you stil have any role oF any interest in
8 Trust. At the time it was the Centeq Companies, 8 Coveniry Investments?
3 C-E-N-T-E-Q. | do not.
10 Q. And what is the business of the Camden 10 And why did you leave there?
41 Property Trust? “ Because | wanted to.
12 A. [think that today they're the fourth largest 12 Just needed a change?
13 apartment REIT in the country. 48 I saw another opportunity.
14 Q. And R-E--T is real estate investment trust? 14 What was that opportunity?
15 AL Yes, sir. 16 The opportunity was to put the capital
46 Q. Do you still own any part or have any role in 18 together for what is now Encore Bank.
17 the Camden Property Trust? 17 GQ I wauld like you fo explain, if you can, what
18 A, [do nat. 18 that means, putting the capital logether for Encore
19 Q. When -- what was your role when you were 49 Bank?
20 involved with the Camden Property Trust or its 20 A. Weil, lwas formerly on the board of Guardian
24 predecessor? 21 Savings & Loan and Guardian got in some financial
22 A. Putting the money together. 22 trouble, and | put together a deat with Jim D'Agosting
23 Q How tong did you do that for? 23 to take over Guardian, andi we changed the name to
24 A Around four years, 24 Encore.
25 Q Would that get us lo the late '80s7 25 G. Whatis the entity that actually baught the
Page 14 Page 16
1 A. Yes. 4 assets or the business that was Guardian Savings &
2 Q. What did you do next? 2 Loan?
3 A thecanis vice chairman of Coventry 3 A. Encore Baneshares.
4 Investments. 4 Q. And who are the principals behind Encore
5 Q. What was the business of Coventry investments? 5 Bancshares?
6 A. We owned commercial buildings here in Houston. 6 A, Weil, we're 2 public company.
7 Q. Which reminds mo, that somewhere along the 7 Q. Have you always been a public company?
8 line you~ you mentioned coming to Houston, ard l 8 A. Na,
9 meant to ask you, what was it that brought you to 8 Q. When -- when you first bought Guardian Savings
40 Houston? 10 & Loan, when Guardian Savings & Loan was first
1 A. Champion brought me to Houston fo support them 11 purchased, was if purchased by private invesiers?
42 in reorganizing their distribution division, Nationwide: 12 AL Yes.
13 Papers. 13 Q@. Whe were those privale investors?
14 G. Were you already working for Champion 4 A. Walter Misches, Sr., Dan Duncan, Fayez
45 somewhere coc? 15 Sarofim, David Weekiy, and then, probaly 40, 40
418 A. Yeah, | was assistantto the chairman. i was 16 others.
17 up In Chicago. w Q. Those are some pretty well-known businessmen
18 Q. Have you been in Houston ever since Champion 48 in the City of Houston?
49 brought you here to town’? 19 A. Yes.
20 A. Yes, thave. 20 @, When did the company become publicly traded?
a4 Q. As vice chairman of Coventry Investments, what at A. Ob, | think it was 08. Don't hold me to
22 was your role? 22 that, Later "07 or "08.
23 A. Raising money. 23 @. That's fine. And if task you a question and
24 you don’t know the exact answer, but you have what you
24 Q Sounds like most of what you have dene for the
25 corporations that you have warked for, is you're a 25 consider ta be a pretty good estimate, as lang as you
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Page 55 (Pages 17-20)
CHARLES W. JENNESS - March 03, 2010
Page 17 Page 19
1 tell me it's an estimate, that's fine. 1 Q. Bo you have an office at Buffalo Marine
2 A. Okay. That — that's an estimate, ‘07, ‘08 in 2 Services?
3 there. a AL do not.
4 Q, When you put the deal togather for the 4 Q. How much time do you aciually spend at Buffalo
5 gentlemen, who you named, to purchase Guardian Savings 5 Marine Services?
6 & Loan, were you one of the — the owners of the new 6 AL day a week.
7 bank? 7 ©, How do you spend most of your time during the
8 A. Who are the gentlemen you're talking about? 6 work hours of the week, now?
9 Q. When Walter Mischer, Sr., an Dunean, Fayoz 9 A. J usually have a contact and talk to a lot of
10 Sarofim, David Weekly and the 40 others purchased 40 people during the mornings, and I like te play golf in
1 Guardian Savings & Loan, wee you one of the 11 the afternoons.
42 purchasers? 12 Q. Fair enough, Other than Encore Bancshares and
3 AL Yes. 13 Buffalo Marine Services, are there any other companies
14 @, And you ~ do you still own shares in Encore 14 that you work for, even if your work consists of
5 Baneshares? 1§ sitting on their board or as a director or an officer?
16 aL Yes. 6 A, No.
7 Q. What percentage interest do you have in the Ww Q. When you make these phone calls and have these
48 bank; do you know? 18 contacts during the woek, whet you aren't playing golf,
419 A idon't. You know it’s probably -- estimated, 19 is that in your capacity with Encore Bancshares?
20 less than two percent. 20 A I would say both Encore and Buffalo because
a Q. When — when did Walter Mischer, Dan Duncan, 21 it’s dealing with — in the case of Buffalo, Is dealing
22 Fayez Sarofim, David Weekly and the 40 others purchase 22 with the customers we have, and when it comes to
23 Guardian Savings & Loan, what year was that? 23 Encore, it's new business.
24 A It was approximately ‘85 or "90. 28 G. Are your job duties today for Encore
2 Q. Have you been with the bank, in some capacily, 25 Bancshares the same as they were In 2007, 20087
Page 18 vage 20
ever since? 1 A. Yes.
A Ihave. 2 Q. You understand I'm here te talk to you about
Q. Okay. When the bank wes first purchased, what 3 your involvement, if you had any, in financing
was your role? 4 iransactions and communications that had to do with the
A in putting the money and the board together. 6 BETTY LYN II?
a Okay. Did you have a tite? 8 AL Yes.
A. Na, i don't think so. 7 @. And during the time that you may have been,
a, Do you have a lille now? @ involved in the financing of the BETTY LYN |! were your
A. Yes. I'm chairman of the executive committe 9 job responsibilities the same as they ara today?
a9 a. Are your functions and duties today — well, 10 A. They were and | wasn't invaived in the
a tiest of all, tet me ask you this, 11 financing.
12 Bo you work anywhere else or tor any olher w Q. Okay. Maybe that’s a wrong term fo use
a company, other than Encore Bancshares today? 13 describe your role,
14 A. ido. 14 Did you have ary role in the BETTY LYN Il
a Whare eise do you work? 415 project on behalf of Encore Bancshares?
16 A. Bulfala Marine. 18 A i Introduced them to Encore.
7 a. What is Buffalo Marine's business? 17 Qa Yau liroduced who?
18 A i's a barge company, Buffalo Marine Services. 18 A, The partners,
49 Where are they focaled? 49 Q. How did you know — who did you know of the
20 A Houston Ship Channel. 20 partners?
a Whai do you de for Buffalo Marine Services? 24 A I knew Rob Taylor. Remind me of the names and
22 A i'm a consultant. 22 Hit tell you.
2a Q. And what are your dutias as a consultant for 23 G. Blake Liedtke?
24 Buffalo Marine Services? 24 A [know who he is.
25 A. Finance, and short and long-term planning. 25 Q. Jody McCord?
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Page 6 (Rages 21-24)
CHARLES W. JENNESS - March 03, 2010
Page 21 Page 23
1 A. Jody, | know, know his father-in-law, Harry 4 the beard of directors, eventually, ! guess he works
2 Cullen, 2 for me, but he doesn’t work for me personally.
3 a ts that C U-L-L-U-M, is that what you said, 8 G, You haid ¢ position in the bank that is senior
4 Cullum? 4 te David Webster's pasiflan?
5 A. Cullen, C-U-L-L-E-N_ 5 A. That's correct.
6 Q. Oh, Cullen. That I'm familiar with, 1 6 a So if the chairman of the executive commiltee
7 thought Lwas hearing Cullum. 7 goes to a senior VP loan officer and says, I'd like you
a the meet these gentlemen who are looking for some.
8 When you — how did -- first of all, how do
9 you know Rob Taylor? 9 financing, generally the senior VP is going to listen
10. A. Just know him because [ know a lot of peopic. ‘40 lo the director of tha executive committee, correct?
41 Lmean, there is no particular, you know, he offices 1 A. Abankis in tusiness to loan money, so, you
12 with Joc Jamail, and 1 know him, casually. 12 know, it's not like I have to tell somebody to do that.
13 Q. Did you ever work for a bank that did any 43 These people are looking for a bank, so that's
14 business withi Rob Taylor? 44 what we do.
15 A, No. 15 Q. Okay. Before we got started with the
18 @. Have you ever done any business before the 16 depasition here today, did you review any documents fo
47 BETTY LYN Ht with Jody McCord? 17 get ready for the deposition?
18 A. No, sir. 8 A. Ereviewed one and that document was when the
19 board approved the loan to your clients.
w Q. Did you ever do business with his.
20 father-inlaw? 20 Q is that the {loan approval?
2 A. Na, f did not. 21 A, ft assume it was.
22 Q. So explain to me, if you can, how iteame 22 @, Afler you introduced the partners lo David
23 about thal you introduced them to Encore Bank? 23 Webster, did you have — did you falaw the
24 Did they approach you about it? Did you 24 relationship at alt?
suggest if to then, how did it come up? 25 Did you communicate with Diavid Webster to find
25
Page 22 Page 24
1 A Iwas at the River Oaks tennis tournament, and + out whal was going on with their interest in obtaining
2 Jody was there, and said he was going ta get 2 financing for the purchase and renovation of the beat?
3 Mr. Liedtke's, whe built Pannzoil's boat, and redo it, a A. Possibly in passing, but not as a direct ~
4 and needed a bank, and | introduced him to the bank. 4 I'd moved on at that time.
6 Q, Who at the bank did you introduce him to? 5 Q. Okay.
6 A I think it was David Webster. 6 ‘A. Whore is my -- that's what | do.
7 Q. And who — what is David Webster's role al he z Q. You were going on te find other customers for
& bank? 8 the bank?
8 A. He's a senior vice president and a ican 9 A. Aad for the barge company.
10 officer. 40 Q. You mentioned that you reviewed a document
“1 Q. Althe time that you introduced tie partners +1 when the loan — that documents the foan being approved
12 to David Webster, was it just ody that you introduced 42 by the bank, correct?
43 to David Webster or was it all of them? 13 AL Yes.
14 A. Well, L arranged for them to have a meeting 4 Q. Between the time that you introduced the
15 with David Webster, and they wert and met with David 45 partners to David Webster or setup a meeting where
14 Webster. 46 they met David Webster, and the time that the loan was
Ww Q, Okay. Whal was your title with the bank at 17 approved, did you have any involvement in the financing
1a the fime that that happened? 18 at ali?
19 A. Same title I've always had, chairman of the 419 A New
20 executive committes, 20 @. Did you have any communications with David
2 Q. So David Webster, in effect, works for you? 21 Webster about the partners’ interest in obtaining
2 A. Well, chaieman of the executive commitiee 22 financing?
23 really doesn’t have anything to do with running the 23 A. Maybe in passing, but ~
24 bank. a Q. Thatwas it, What about communications with
25 Sol, you know, | mean | ~ if he works for 25 any of the partners?
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Page 7 (Pages 25-28)
CHARLES W. IENNESS - March 03, 2016
Page 25 Pago 27
1 A IF saw them socially, "How are you doing?” 1 Q. Se you were interested In seeing how the
2 Q. You didn't make any effart to monitor what was 2 construction was going?
8 going on? 3 A i was interested from the standpoint of they
4 A. No. 4 were going over and back. I wasn't so interested where
5 Q. Gkay. At some point in tme after the loan 5 I would fly over, personally, and so on and so forth.
6 was approved, did you become involvad in soma way, 6