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¤ Paul
Janszen's testimony is corroborated by the voluntary
sworn testimony of Danita Marcum, Ron Peters, Jim
Procter, David Bernstein, the unguarded statements of
Steve Chevashore on the tape of December 27, 1988,
the unguarded statements of Mike Bertolini on =he
=ape of April 4, 1988, and the statements of Mike
Fry.
¤ Paul
Janszen's testimony is corroborated by the betting
sheets he obtained from the home of Pete Rose, Which
record the results of the Reds and other baseball
games. The handwriting expert has established from
the handwriting exemplars of Rose and the 1987
handwriting samples of Rose that the three sheets are
in the handwriting of Pete Rose. Another handwriting
expert has established that the three sheets are not
in the handwriting of Paul Janszen or Danita Marcum.
¤ Paul
Janszen's testimony is corroborated by his own
notebook in which he recorded the betting results of
Reds games. The bets in Janszen's notebook match =he
games and results of the three sheets in Rose's
handwriting. The handwriting expert has established
that the writing in the notebook is that of Janszen
and Marcum.
¤ Paul
Janszen's testimony is corroborated by the betting
records of Ron Peters. Peters betting records show
betting on the Reds and other baseball teams by one
cd6tomJr in 1987. These records bear the names of
Janszen and "Pete."
¤ Paul
Janszen's testimony is corroborated by the gambling
expert who has found all of the betting records to be
authentic and correct based upon a comparison with
the schedules, betting lines and results of Major
League Baseball in 1987.
¤ Paul
Janszen's testimony is corroborated by the collective
telephone traffic which shows continuous contact
between Janszen and Rose and (1) between Janszen and
Chevashore from April 8 to 17; (2) between Janszen :
and Val from April 17 to May 13; and (3) between
Janszen and Peters from May 17 to July 5, 1987 --
just before game time for the Reds -- home or away --
night or day.
¤ Paul
Janszen's testimony is corroborated by the taped
conversation with Steve Chevashore in which
Chevashore acknowledged that Janszen was betting for
Rose with Val; that Rose was delinquent in paying his
gambling losses; that Danita Marcum placed bets on
the Cincinnati-Montreal game for Rose; that
Chevashore called Rose to collect Rose's debts; that
Rose denied betting after the Reds-Mets series and
that Rose said Janszen was betting in Rose's name;
that "the bosses" in New York held Rose
responsible; that Janszen could not afford to bet
$2,000 per game; and that Bertolini was in trouble
with people in New York.
¤ Paul
Janszen's testimony concerning the debt owed to him
by Rose is corroborated by Bertolini's remark in the
April 4, 1988 conversation with Janszen, when after
Janszen told Bertolini that Rose owed him $12,000,
Bertolini asked whether Rose had paid Janszen
$38,000; by the testimony of Ron Peters that Janszen
tried to collect the debt from Rose's winnings; by
Peters' testimony that he paid Janszen the difference
between what Peters owed Rose and what Rose owed
Peters; by the $10,000 check -''for loan" --
given to Janszen by Rose's counsel in March 1988 to
pay Janszen's attorney's fees for Janszen's criminal
case for which neither Katz nor Rose has ever sought
repayment; by the correspondence between Janszen, his
attorney and Rose's counsel in which Janszen asserted
his claim for monies due, which Rose's counsel did
not dispute; and by the statement of Mark Stowe, the
Assistant Clubhouse Manager of the Cincinnati Reds,
who asked Rose, in the spring of 1989, why he had a
falling out with Paul Janszen and Rose told him it
was over betting losses owed to Janszen which Rose
told Janszen to collect from someone else who owed
money to Rose.
¤ Paul
Janszen's testimony that Pete Rose bet on the Reds
and baseball with another bookmaker in New York,
through Mike Bertolini, and that Pete Rose used the
cash from card shows, memorabilia sales, and loans
arranged for Bertolini and Bertolini's company, Hit
King Marketing, Inc., to pay gambling losses is
corroborated by the unguarded taped conversation of
April 4, 1988 in which Bertolini acknowledged the
following: the indebtedness to the New York
bookmakers by Rose; Rose's conversations with the
bookmakers; the enormous indebtedness of Rose for
gambling losses; the payment of $150-$200,000 in
betting losses; the outstanding debt of $200,000; the
indebtedness of Rose to Bertolini; and the gambling
habit of Pete Rose. During the conversation,
Bertolini said that he was the only proof of Rose's
betting and he would "die" before he told
on Pete Rose.
¤ Paul
Janszen's testimony that Bertolini was betting on
baseball for Pete Rose is corroborated by Rose's bank
records for an account at Oak Mills Savings and Loan
in Cincinnati. The account was used to funnel checks
in the fail of 1986, after the baseball season ended,
to Bertolini in amounts under $10,000 and made
payable to fictitious payees. The checks were cashed
by Bertolini at a check cashing service in New York
to pay the bookmaker in New York.
¤ Paul
Janszen's testimony concerning the placing of bets on
the Reds for Pete Rose is corroborated by the
voluntary, sworn testimony of Danita Marcum, who
verified all of Janszen's testimony concerning his
relationship with Rose; the events at Spring training
in Florida; the betting sheets in Rose's handwriting;
the notebook in her and Janszen's handwriting; and
placing the bets with : Chevashore, Val and Peters.
More significantly, Danita Marcum testified that she
took bets directly from Pete Rose on the Reds and
other baseball games and placed those bets for Rose
with Val and Peters. Her recollection is corroborated
by Peters' testimony that he took bets from Marcum
for Pete Rose on Reds game, and by Chevashore's
statements recounting Marcum's betting on the
Cincinnati-Montreal game in May 1987.
¤ Paul
Janszen's testimony is further corroborated by the
voluntary sworn testimony of Ron Peters, who admitted
taking bets from Rose and Janszen on the Reds.
It is quite significant that
Peters and Janszen were not friends or close
associates. At the time of their testimony, Peters
possessed a bitter animosity towards Janszen because
Janszen assisted the government in catching Peters
engaging in activity which led to Peters' arrest,
indictment and conviction.
Notwithstanding this animosity,
Peters corroborates Janszen. Peters testified that he
began taking bets from Janszen on behalf of Rose in
mid-May 1987 after Janszen gave him a copy of the
$34,000 check of March 12, 1987 signed by Katz He
testified that Rose won $27,000 the first week, which
he paid to Janszen for Rose; lost $24,000 the second
week, which Janszen paid him in cash for Rose; and
won $40,000 in June and early July which he refused
to pay Rose because Rose still owed him $34,000 from
earlier betting. Peters testified that he took bets
for Pete Rose from Danita Marcum during May, June and
early July 1987. Peters also received tickets to Reds
games from Pete Rose through Paul Janszen.
¤ Paul
Janszen's testimony is corroborated by the sworn
testimony of David Bernstein and Jim Procter.
Bernstein and Procter observed and heard Janszen
taking bets on baseball games from Pete Rose during
the 1987 season. Bernstein and Procter were also told
by Janszen that Rose bet on the Reds. Bernstein also
witnessed Janszen giving the status of bets to Pete
Rose with hand signals at Riverfront Stadium when the
Reds scoreboard, reporting the scores of other
baseball games, was not working.