1 what was going on. And] may have spoke to him, ] 2 1

1 what was going on. And] may have spoke to him, ] 2 1 2 know | spoke to Russ, but ] may have spoke to him as i 2 3. well within a couple of days just prior to this due : 3 4 diligence because ] was trying to at least get some : 4 5 information in my head that ] could use when ] was : 5 6 creating this story for the investors. 2 6 7 Q. Scott, what's Q-task? : 7 8 A. Q-task is a web based software system that | : 8 9 had invested $7 million in. 1 9 10 Q. And what was the purpose of this internet £10 11. system? : 11 1.2 A. To be able to communicate in a secure #12 13 fashion and in a unique group fashion about specific ; 13 14 files. 14 15 Q. So forgive me, we all know I'm not good with ] 15 16 the computer. That was something that would be useful | 16 17 within a law firm, why? B17 #18 A. Because it allowed you to create groups and i 18 19 have both general and private chats, organize data in 119 20 avery unique fashion. That was, at least to our way : 20 21 of thinking, would have been very, very helpful in the a21 22 law firm setting with multiple practice groups. £22 23. Q. Did you belong to any groups on Q-task? : 23 24 A. I'm certain that ] did. 1 don't remember : 24 25 which groups ] belonged to. | never got into the full £25 Page 26 : 1 use of it. I tried to, but again, ] was very busy 1 2 doing other things. But ] know that Mr. Adler's group 5 2 3 used it extensively. 2 3 4 Q. Because it was your firm and, as you said, , 4 5 you invested $7 million in it, did you have the e 5 6 ability to access a group if you wanted to? 6 7 A. Yes. And if] couldn't, | could get Russ to tT 8 give me access. 1 8 9 Q. So you didn't necessarily have to be invited : 9 10 into the Q-task group for you to be able to utilize or : 10 11. view the communications within it? : 11 al: A. No, that's not true. ] actually had to be 412 13 invited, that's what } was telling Russ to do, is to : 13 14 have me invited. i 14 pis Q. But I'm saying, the lawyers wouldn't have to 1s 16 personally invite you, you can get someone within your #16 17 firm to give you access maybe without the lawyers 47 18 knowing? 218 19 A. No, ] think it might have had a, quote, 4 9 20 unquote, confidential, super secret viewing : 20 21 capability, but] don't recall it having that, and I'd ] 21 22 have no need to utilize that. Just invite me into the 22 23 group and let me see what's going on. 23 24 Q. Okay. I know that you are or were a very 24 25 hands-on person within certain of the practice groups £25 Page 27,5 and with that, with the Q-task and the e-mails, did someone assist you with reviewing everything and letting you know what was going on within the groups? MR. SCAROLA: Excuse me, I'm going to object to counsel's testimony. Object to the form of the question as leading. THE WITNESS: J really don't even understand the question. Can you try to rephrase it for me, Tonja? BY MS. HADDAD: Q. Of course, 1 would. Did you keep abreast of everything that was going on in every practice group or was someone through Q-task and e-mails, for example, or was someone giving you information keeping you posted on what was going on within the practice? A. Well, as part of the tort group | had a pretty good idea of what was going on there all the time just because of the significant amount of interaction, both legitimate and otherwise, that ] had with Russ Adler, so ] was probably more up-to-date on that group than any group other than the labor and employment group, again, because ] had such significant interaction with Stu Rosenfeldt, both legitimately and Wlegitimately, so 1] knew what was Page 28 going on in that group. ] tried, as best as ] could, given my time constraints, to stay on top of what was going on, you know, throughout the firm. But ] relied on other people like Debra Villegas and Jrene Stay and David Boden, Les Stracker to the lesser extent, to monitor what was going on in the different practice groups and keep me up to speed. Q. Was there audio and video surveillance throughout the entire firm or only within your office? A. No, through the entire office, not in the individual offices. Hang on. Not in the individual offices but throughout the general office space. Q. So in 2009 how many floors did you have? A. Three, | think. Q. And do you recall approximately how many attorneys you had working there at that time? A. Approximately 70. Q. And when you say "not the individual offices but the other areas,” do you mean -- would that include conference rooms? A. I didn't have surveillance in the conference rooms. Q. Socan you please tell me exactly where you Page 29 8 (Pages 26 to 29) FRIEDMAN, LOMBARDI & OLSON 305-371-6677 5ed93085-0554-447f-bcdd-ca2d8fe941 df HOUSE_OVERSIGHT_017497