17 Q. Okay. Have you ever heard the term
18 "Gematria"?
19 A. Gematria?
20 Q. Yes.
21 A. Yes.
22 Q. Okay. Where did you hear that?
23 A. Uh, from Nate, actually I did, uh, and
24 some websites.
25 Q. What did you understand Gematria to be?

1 A. Well, I think I understand the, uh,
2 question. Uh, numerical, uh, application to, uh,
3 a name or word.
4 Q. Okay. Do you know what Gematria is in
5 the context of Shift4?
6 A. Yes, I do.
7 Q. What is that?
8 A. The number 1644.
9 Q. How did you hear about that?
10 A. From Nate.
11 Q. Okay. So, other than that, what else did
12 you understand Gematria to be? You said somebody told
13 you and websites.
14 A. Yes, yes.
15 Q. Okay. What else did you learn?
16 A. Uh, primarily what I learned is that, uh,
17 that the numbers have a meaning.
18 Q. Okay.
19 A. Based on, uh, biblical references.
20 Q. Okay. Do you happen to know what any
21 numbers mean?
22 A. Specifically?
23 Q. Sure.
24 A. Yeah, uh --
25 Q. Okay.

   1 A. -- yeah, the number 8, which is very
   2 important.
   3 Q. Okay. Why is that important?
   4 A. Well, Nate told me, number one. Number
   5 two, it, uh, represents new beginnings.
   6 Q. Okay. Did Nate indicate to you why the
   7 number 8 was important to Shift4?
   8 A. I'm sorry. Could you repeat it.
   9 Q. Did Nate tell you why the number 8 was
  10 important to Shift4?
  11 A. Yes.
  12 Q. What did he tell you?
  13 A. That it was, uh, the, uh -- God.
  14 Q. That what was God?
  15 A. The number 8.
  16 Q. Okay. The number 8 was God?
  17 A. Uh-hum.
  18 Q. Okay. Any other numbers that Nate ever
  19 talked about?
  20 A. Uh, yeah, 88.
  21 Q. What did he say about 88?
  22 A. Uh, Jesus Christ.
  23 Q. Okay. Any other numbers?
  24 A. 44 or 444.
  25 Q. What did Nate say about that?

   1   A.  Uh, that represents, the best that I
   2  could understand, uh, moving from one realm to
   3  another.
   4   Q.  Okay.
   5   A.  Salvation.
   6   Q.  Okay.  Did he talk to you about -- and I
   7  think we mentioned this number already -- 1644? Did he
   8  talk to you about what that meant?
   9   A.  Um, just in in, uh, that's the name of,
10  uh, what they use to represent Shift4.
11   Q.  Okay.  Did he ever talk to you about
12  what -- what Gematria meant in the context of Shift4,
13  like, why are we doing this?
14   A.  Yeah, he talked about, uh -- I'll
15  probably butcher the name, but, uh, Kabbalah, uh, when
16  Nate and I had conversations.
17   Q.  Okay.  What did he say about that?
18   A.  That it was important that he studied.
19   Q.  Okay.  Did he tell you what he learned
20  from his studies?
21   A.  Uh, some of the numbers, yeah, and how to
22  apply them.
23   Q.  Okay.  How did he apply them?
24   A.  Just, uh, in a general sense, to let us
25  know that there was a meeting -- a meaning behind

   1  the -- the letters and numbers and Shift4.
   2   Q.  Okay.  And he obviously believed in
   3  Gematria, correct?
   4   A.  Yes.
   5   Q.  Did he tell you he believed in Gematria?
   6   A.  Yes.
   7   Q.  Okay.  Do you -- well, let me -- did you
   8  ever question him about like -- like, that seems kind
   9  of a little nutty, right, like, assigning meaning to
10  numbers and names of your company?  Did you ever -- did
11  you ever just question him why are you doing that?
12   A.  You know, I probably did.
13   Q.  Okay.  What did --
14   A.  And what did he --
15   Q.  -- what did he tell you?
16   A.  -- uh, he, you know, really believed in
17  it.
18   Q.  Okay.
19   A.  And, you know, Nate's a persuasive guy.
20   Q.  Okay.

6 Q. I'm showing you what's been marked as
7 Exhibit Number 15.
8 (Exhibit No. 15 was
9 marked for identification.)
10 Q. Do you see that, sir?
11 A. Uh-hum.
12 Q. Do you recognize this?
13 A. Uh-hum.
14 Q. What is this?
15 A. It's a, uh, a text.
16 Q. Okay. And is that a conversation that
17 you had?
18 A. Yes.
19 Q. Okay. And who were you chatting with?
20 A. Nate.
21 Q. All right. And at this time, what was
22 your position at the company?
23 A. I think I was still national sales
24 manager.
25 Q. Okay. And remind me, when did you have

1 that role until?
2 A. 2017.
3 Q. Like, all -- was it all the way through
4 the end of 2017?
5 A. I believe so.
6 MR. EGBERT: Objection to form.
7 Q. (BY MR. PARLATO) Okay. So, do you
8 remember having this conversation with Nate?
9 A. I don't remember it, but I did have the
10 conversation.
11 Q. You did have it. Okay.
12 All right. Can we blow up the first
13 message that says, "I'm very close."
14 A. Uh-hum.
15 Q. Okay. And it says, "I'm very close on
16 something major"?
17 A. Uh-hum.
18 Q. All right. Do you know what he was
19 referring to?
20 A. I do.
21 Q. What?
22 A. Uh, settlement.
23 Q. Okay. And you say, "Really? That sounds
24 good. Let me know. Are you still at home?"
25 He says: "I -- I'm working from home

1 today."
2 What did -- did you understand that to
3 mean that he was working on a settlement from his home?
4 MR. EGBERT: Objection to form.
5 A. Yes.
6 Q. (BY MR. PARLATO) And who was the
7 settlement with?
8 A. Uh, First Data.
9 Q. And you understood this to mean that
10 you're very close to settling the First Data case?
11 MR. EGBERT: Objection to form.
12 THE WITNESS: The answer's yes.
13 Q. (BY MR. PARLATO) Okay.
14 Next text message is on 12 -- from
15 December 12th, 2017.
16 You say, "Hi, Nate. Just checking in.
17 Any additional updates you can share?"
18 And what were you asking about, do you
19 recall?
20 A. Uh, just, uh, the case.
21 Q. The First Data case?
22 A. Yes.
23 Q. And do you remember -- and, I'm sorry, he
24 responded:
25 "Yes, my attorney --"

1 And there's a -- blank space -- "has
2 had" -- blank space -- "numerous conversations."
3 Do you see what I'm reading here?
4 A. I see.
5 Q. Okay. It says:
6 "Yes, my attorney" -- blank -- "has had"
7 -- blank -- "numerous conversations with counsel
8 and First Data."
9 Do you see that, sir?
10 A. Uh-hum.
11 Q. What do you think those redacted portions
12 are?
13 MR. EGBERT: Objection to form.
14 THE WITNESS: I --
15 MR. PARLATO: Well, hold on.
16 Let me object to this.
17 How can this witness testify as to
18 what -- what appears to be redacted, and I would
19 object as this calls -- obviously, this calls for
20 speculation, and that's a confidential settlement
21 agreement between First Data and you guys.
22 MR. EGBERT: I didn't tender him as a
23 witness on that topic.
24 MR. PARLATO: I'm just making an
25 objection.

1 Q. (BY MR. PARLATO) Okay. We're -- we're
2 just talking -- we're just talking about these two
3 redacted words.
4 A. I have no ideas.
5 Q. You have no idea?
6 A. I have no clue.
7 Q. Okay. And he goes on to say:
8 "They are close on the payment term
9 sheet."
10 Do you see that?
11 A. Uh-hum.
12 Q. Okay. And --
13 MR. PARLATO: I'm going to move to strike
14 that last answer as speculation.
15 Q. (BY MR. PARLATO) So, it's fair to say
16 that Nate was updating you on the status of the First
17 Data litigation in this text message?
18 MR. EGBERT: Objection to form.
19 THE WITNESS: Yes.
20 Q. (BY MR. PARLATO) Okay. Let's look at,
21 on December 14th, you then say:
22 "Hi, Nate. I was just wondering if
23 there's any additional updates that you might be able
24 to share. I've been asked by a number of people."
25 Who were -- who were the people at the

1 company that were asking you --
2 A. Uh, uh --
3 Q. -- about the status of things?
4 A. The sales team.
5 Q. Sales team?
6 A. Uh-hum.
7 Q. Were you still manager at this point?
8 A. I --
9 Q. Okay.
10 A. I believe so.
11 Q. And so they had -- they had known that a
12 settlement had been brewing, and so they -- they were
13 coming to you to ask you --
14 A. Yes.
15 Q. Okay. So, what did you understand that
16 to mean?
17 MR. EGBERT: Objection to form.
18 Q. (BY MR. PARLATO) Like, when you say
19 you've been -- you've been asked by a number of people.
20 What -- what did you understand that to mean? What was
21 the question people asking to you?
22 A. Uh, updates on the, uh, the litigation.
23 Q. Okay. And he says:
24 "There is major progress. Documents are
25 under review, but it's going to take a little more

1 time because of my upcoming mission trip."
2 Okay. Do you see that, sir?
3 A. Uh-hum. Yes.
4 Q. What did you understand his mission trip
5 to be?
6 A. Going to Haiti and the Bahamas.
7 Q. Did he -- did you ever learn what he did
8 on those mission trips?
9 A. Just gave, uh, aid to, uh, people.
10 Q. Okay. And on the -- the next
11 communication is on, uh, January 1st, 2018.
12 He says:
13 "You're -- it's been great working with
14 you this past year."
15 And you respond:
16 "Happy New Year, Nate. I'm sorry. I
17 didn't see this text earlier. I was flying to
18 Birmingham."
19 And on 1-12 -- or, I'm sorry. January
20 12th, 2108, you say:
21 "Hi, Nate. Long time. I was just
22 curious if you had any updates that I can pass along
23 to the team."
24 And he says:
25 "Yes, tell them that the attorneys are

   1  finalizing everything.  It could be any day
   2  now.  I think that the payment may get delayed
   3  because I may need to use the funding to help my
   4  friends at Sound --"
   5  And is that "Sound Ford"?  Is that what
   6  that is?
   7   A.  That's what it looks like.
   8   Q.  Okay.
   9   " -- but will have definitive answer this
10  week.  This week, I hope."
11   Okay.  So, are you familiar with
12  Sound Ford?
13   A.  Very.
14   Q.  Okay.  Was that a -- a merchant of
15  Shift4's?
16   A.  Yes.
17   Q.  Okay.  You say:
18   "Okay.  Understood.  Thanks for the
19  update."
20   On 1-18-2018, you say:
21   "Hi, Nate.  I just wanted to check in
22  and see if you had any updates."
23   And he says:
24   "Yes, still waiting."
25   And you say:

   1 "Okay. I'll be patient."
   2 And then, on "1-23-2018," you say:
   3 "Morning. Any updates?"
   4 And he says:
   5 "No, very frustrating."
   6 You say:
   7 "I bet."
   8 And then, on the 29th, "1-29," you say:
   9 "Anything new?"
  10 And he says:
  11 "Yes, they agreed to my request. I'll
  12 explain wed of next week. I told Shift4 management
  13 team this afternoon."
  14 Okay. Do you recall this conversation?
  15 A. Uh-hum. I remember the text.
  16 Q. Okay. The -- did you learn, did you get
  17 an explanation of what the request was?
  18 A. I don't recall.
  19 Q. Okay. Do you know if he conveyed any
  20 type of resolution on the First Data case to the
  21 management team around this time?
  22 MR. EGBERT: Objection to form.
  23 THE WITNESS: I -- I don't recall.
  24 Q. (BY MR. PARLATO) Okay. And, finally, on
  25 2-1 -- this is February 6th, 2018, you say:

1 "Good morning, Nate. Any updates?"
2 And he says:
3 "Paperwork is finalized and going out
4 today. Once everything is in, they will release the
5 payment."
6 Okay. So that also sounds like he's
7 talking about settlement, correct?
8 MR. EGBERT: Objection to form.
9 THE WITNESS: Yes.
10 Q. (BY MR. PARLATO) Okay.
11 And then the last text message, on
12 2-22-2018, he says:
13 "They said they are close, again."
14 You say:
15 "Okay."
16 And he says:
17 "Could be any day. We will all just have
18 to hang tight."
19 Okay. So did it seem that he kept
20 updating you about the status of the First Data
21 settlement?
22 MR. EGBERT: Objection to form.
23 THE WITNESS: Yes.