Q. You didn't keep track of it?

DrwAINO B® WNYFH OnwAnvroewwWNH-E Oo Q. You didn't keep track of it? A. J did not keep track of it. From time to time Russ and the other guys in the tort group would tell me what was going on in certain cases, but until I made a decision to utilize that file for an illegal purpose related to something illegal that ] was doing along with my co-conspirators, | just assumed my Jawyers were going to work the case and eventually it would hopefully work out well for the law firm. Q. At your firm, when e-mails would go out to attorneys at RRA or all attorneys at RRA, were you part of that e-mail group? . You are talking about all staff? . No, all it says is attorneys at RRA. It's the e-mail group "attorneys"? Yes. Yes, I'm a part of that e-mail group. And ] appreciate that you were very busy and may t not have read all of them, but you did receive those e-mails when they would go around? A. Yes, and 1 tried my best to read them. Q. Okay. At what point did you decide to use this case to further your Ponzi scheme? A. 1 don't remember the date, but I can give you the circumstances, if you'd like. Page 223 Q. Please do. A. The Ponzi scheme was running very low on capital. My co-conspirators and ] needed to find a new feeder fund, new investment sources. We had a couple of very large, significantly wealthy potential investors out there. I was looking for something that would have been very attractive. We had had a lot of inquiry during the due diligence period with these people that were doing due diligence on the putative cases that we were selling. And when | thought about the Epstein case, realizing that it was a substantial actual file in the “office, I came up with the idea that if ] created a fake confidential settlement circling around -- based upon this actual case, they would be able to increase the level of due diligence that I was able to offer to my potential investors. Q. How did you know this was a substantial file in your office at that time? A. Again, through the people J spoke to in the office. Q. Such as who? A. Again, same people, Adler, Farmer, Jaffe, Fistos. Q. You never spoke to Brad about this case? A. I didn't say that, but J had a Jot more Page 23 Serna 0 UR TNR LO OA ee eS RT RN MEER EERO eh tenor sual tease sauacetaen OerWnNor COU WHA DY fF WNYEH DO DTA DY SF WN EF PSS ERASE EP NG OR EPA IRA I Se RS A RRS SR RH SSM TE RIES RM NMONNDM NYDN HPF FE PRP PB a NNNNNRFPRP RPE PRE ER BWHrRPOW MIDE DBWNHE OW DIRDUBWNHE Ne) on) interaction -- Sorry, Tonja, | didn't mean to speak over you. If you talk to the people in the firm, if they are honest with you, they'll tell you my interaction was far more significant with Russ Adler, probably more so because he was a co- he was a co-conspirator of of mine, My interaction with Russ was | Russ was far greater b greater by many, many percents over my interaction with Brad, and then you go down the line. ] had more interaction with Mr. Farmer than I did with Mr. Fistos, more interaction with Jaffe than ] did with Mr. Edwards, and so on. Q. Russ was the head of your tort group, right? A. Yes. Q. So these cases fel] under the tort group; is that correct? A. Yes, it fell under the -- fel] under Russ’ purview ultimately, yes. Q. And Brad was a partner at your firm during the time these cases were there, correct? A. ] believe that was his title. He was either partner or shareholder. J] don't think we had made him a shareholder yet. Q. But he wasn't coming in as an associate, Page 24 correct? A. To the best of my recollection, no. Q. So you stated that you learned this case was -- ] don't want to misquote you and listen to a long speaking objection, but what did you call this case? MR. SCAROLA: Who wants the quote? THE WITNESS: It was a substantial case with a -- what | perceived to be a highly collectible pedophile as a defendant. BY MS. HADDAD: Q. Right. How did you know at the time when you said these investors wanted to investigate and you said you were going to create a fake settlement, how did you know that this case was the case that you could use? A. From talking to all the people that I just said, Adler, Fistos, Jaffe, Farmer, Mr. Edwards, to the extent that ] spoke to him about it. Q. Did you speak with Mr. Edwards about the case? a: 1 GON NSPE ac pesinocrceollection one Way or the other. ] remember speaking to him at least briefly the day or the day of or the day before the actual investor's due diligence was going on as to Page 25 7 (Pages 22 to 25) FRIEDMAN, LOMBARDI & OLSON 305-371-6677 5ed93085-0554-447f-bcdd-ca2d8fe941 df HOUSE_OVERSIGHT_017496