A A 4A E0 A4 DE a qr?q rq qrCX HhL Kg lg d?a d6U a M3 flW y??S m/y t0 I F/Z V/j 1a qC KS u?v vZ O5 a qr rCX qC 0V I I dc rM?M rM 10Cy n??m?n k?o?h I A I w?!ac qr MCX 10Cy ITy qr M3 Ґ??1rA5R h?H?T3P K?z X?K H?o I Idc rM?M rM 10Cy f헊?f?Tz e?e:Aa I v"x i X5 EO5 5a r?q CX 9r Cy rq rqC M3 ş?:c p/p0 5H V)V 6T Y2 G5 qrM?r?qr?r9 q?10Cy rCX qr l1 X?l 3K fm?Q Z2f CX CX gT L??T 2E Cy 3P EM3 J4T L?h??M q?ᡚ?Y r??O?rJt CTX i P!e i I CTX rC YY I 1e 2j CTX X0T1i k3v Jh/e0h1 H(K W/Q0 CTX j?!k 5B r2 CTX A A A 4v z"p A A A0A?A AK CTX A A?!k CX qCX YCX i!d A fi8 l8 yuZ 6L pH m?c sP;0 6ZR Ni P0 0Q X(P0s s(s p0 Pp CTX qq dR B/J Va A N?q qr NEeD K?i N?M?qr EeD k??O d6 I I i i CTX GH FT I CTX U3 U3 U3 U3 S6 E"L I I I5K7C:I 9O U3 Cn qrr qr q??r?q 9qr CTX G5 qr CX rC l0 WS zN pf1 ODV8L?m jC1DxV CTX CTX A qr 10Cy rYY Ң??P?V CTX C"C rqM?rq?q?qr qr CTX YY Jb?C.y CTX CTX GG4 A A G5 C.C M??r 10Cy rq YY C?J?yO c/XE?lgF GM??H p?ݡG Dp9Oh CTX CTX CJ4 I J6 CJ4 CK qrrM?q qq 9/CX?o CX qYqr rC dd?Z c6S ttcx A CTX CTX 10Cy rq rqYY X?qiX:4 3J Db ZH uD-8 1g?BH I vS 7Oo7u E?K?O J6 UJP U0 UT??ʴ UT UT UT O(p U(u UF1 iZ qr?r CX CX Yr zKW:E A K5M P-M UW VW L1J KJ56 N/Q SQ rC 6J ߵl ߵl 5TZ w8ĥDG oj?K _4 N)?Y Hp pRqc?W26 vz?WBrz?ZB??3X H4 CTX A CTX X4 U5 P8 5D qr qr 10Cy qr YY Mo?ANp D01jJ 9F bzEV 4O 8V CTX O!o CTX KK AA qr A C5 qr rYY 1A?CC V9 a c?F CTX A G5 qr EeD?M CTX 9?rY 10Cy rq qY ȠX1 a f??B CTX 9F I CTX 6D N?qr rrqq qC O?J RmA??b"0 M?.F q?D B?G CTX CTX F4 d6P A F4 qr rYY 4G AV8 CTX UY UL0 U0 U0 U0 UF UF UFAGA UA UA UAL UL UL UL UL UL UL U7 U7 U7 U7 U7 U7 U7 2EH GTU U/U OUoU UV G1 CTX TUV 1G 7A UA UAL X7 U7 U7 U77XL UL UL ULLYX KTX 8Y GJ A UMAT UD 7M GVW GF10 MWA LL MPM M?M 4M XY qr qr qr NEeD 10Cy qYY E2 GH l1 Pd h3V g?KIq V5kL O65S d_xKKU vV 5H p1 Z6 CTX U0 U1 CTX U0 U1 A0 1D qr qr 10Cy YY K??Kl 1B AMwv 1K F1 KV yW Gd T?H CTX CTX I CK M?qr K?SK?PQZ I IRZX 8YCX 10Cy qr CX kv zg S5kB??a iG wA CTX U2 6Y CTX U2 6Y I K,,j j,s 6Y P!p qr 10Cy qr YY G?O 9K mSd X0 9r?yal 1d bY0 XNf??qN D?J CTX P!Z b!o C,C qrM 10Cy qr8 I fX2 9R lO KV CTX Oo CTX A qr r?qr rq YY Lsy7H4 C,6E IL CTX U3 CTX J,O3_3xx qrM?r q?CX Y9/C 9CX CTX Y10Cy CX CX CX YC YY FV uTl bEWa ȓjJ-8 Gc G??Q9E 9Wq CTX CTX Up i I A 9_ qr qr YY D.X 7s F??Y bc3_c iH CTX CTX A qr 10Cy YY EMq 7H AY mK9Z BY A2 P6L N7 CTX CTX a I I i qr rC CTX CTX 7O I FMM qr qr i I I3 CTX Z6 I L(K4 P:u Z6P CTX y8 Edwards adv Epstein Case No Notice of Filing Transcript In Supplemental Support of Bradley Edwards Motion for Summary Judgment Page of2 COUNSEL LIST Brqdley Edwards Esquire Farmer Jaffe Weissing Edwards Fistos North Andrews Avenue Suite Fort Lauderdale FL Phone Fax Jack A Goldberger Esquire Atterbury Goldberger Weiss P.A Australian Avenue South Suite West Palm Beach FL Phone Fa Marc Nurik Esquire One Broward Blvd Suite Fort Lauderdale FL Phone Fax Tonja Haddad Coleman Esquire Law Offices of Tonja Haddad P.A Andrews A venue Suite Fort Lauderdale FL Phone Fax Lilly Ann Sanchez Esquire The L-S Law Firm Brickell A venue 15th Floor Miami FL Phone Fax Page IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA GENERAL JURISDICTION DIVISION JEFFREY EPSTEIN Plaintiff vs No SCOTT ROTHSTEIN individually and BRADLEY EDWARDS individually Defendants I East Broward Boulevard Ft Lauderdale Florida Thursday June a.rn p.rn I I Of SCOTT ROTHSTEIN Via Video Conference Taken on behalf of the Trustee pursuant to a notice of taking deposition FRIEDMAN LOMBARDI OLSON 7f-bcdd-ca2d8fe941 df APPEARANCES LAW OFFICES OF TONJA HADDAD P.A by Tonja Haddad Esq Attorney for the Plaintiff ATTERBURY GOLDBERGER WEISS P.A by Jack Goldberger Esq Attorney for the Plaintiff SEARCY DENNEY SCAROLA different form than it ended because it started as bridge loans and things of that nature and then morphed into the Ponzi scheme But you are looking back into the time frame for the very beginning The time frame thats when the bridge loans started A I cant be certain exactly what we were doing I need to see all the documents to tell you what we were doing at what specific point in time What made you decide to start doing this A I started doing it out of greed and the need to support the law firm which was having significant financial trouble at the time And in had you moved over to yet or were you still in the building where Colonial Bank was A I dont remember Do you recall approximately how many attorneys you had working for you when it started A I do not Between five and ten Tonja Was it before you started acquiring attorneys like you were acquiring cars and watches MR SCAROLA Object to the form of the question vague THE WITNESS Yes Page BY MS HADDAD Well who were you partners with when it first started A Stu Rosenfeldt Okay Anyone else A Susan Dolin I believe lt was definitely Stu Rosenfeldt Michael Pancier and Susan Dolin may have been partners of ours at that time Im not certain Because if memory serves me correctly you went from being in the One Financial Plaza Building to the building across the street it was Rothstein Rosenfeldt Dolin and Pancier is that correct A Yes And it was some time later that you moved into the I Building correct A You are skipping one step I went from One Financial Plaza to Phillips Eisinger Koss Kusnick Rothstein and Rosenfeldt Then Stu Rosenfeldt and I broke off and fonned Rothstein Rosenfeldt And then Rothstein Rosenfeldt Dolin Pancier over at the Colonial Bank Building And then we took the space in the I Building and eventually moved over there and thats when the real growth started And when you say thats when the real I I II i I ii15 I I I I I I I ha I Ii Page Ii growth started do you mean both the scheme do you mean the scheme and the finn or either one or both A Both Do you recall approximately when you took the space in the I Building A I do not At the time everything imploded how many partners did you have at the finn do you recall A Are you saying partners and shareholders Because remember we had both two designations I want to start with just attorneys that had not in your firm name but named as partner on the cards for example A Id have to see a list of all the employees We had a bunch Do you recall about how many attorneys you had working there A Approximately In the year before do you recall how many you had A I do not So how many equity partners did you have or shareholders Im not sure of the word that we are usmg A Actual shareholders equity shareholders were two me and Stu Rosenfeldt And everyone else was just a partner for title purposes Page A There were shareholders for title purposes and partners for title purpose_s If someone was called a shareholder for title purposes then did they get to receive any of the funds Were they shareholders receiving money or they were not considered shareholders in that sense MR SCAROLA Objection to the form of the question THE WITNESS What kind of funds are you talking about BY MS HADDAD In general from the firm When you say equity shareholders I understand thats you and Stu What Im saying is if you had someone else that was named as a shareholder why did you call them a shareholder as opposed to a partner A It was a title of prestige and achievement So it was basically an ego thing it had nothing really to do with the finances or hierarchy of the firm A They got paid more generally but it did not have arrything to do with distributions Page Pages to FRIEDMAN LOMBARDI OLSON 7f-bcdd-ca2d8fe941 df Z?K M?;TX 1ᘯm Dzp?wJ Fs!b v?DZ?Y??t?h OD m?k jB?N MA DH FimןT o?n oD_da WȦz ɦNߡ 0Cċ?F kR?N 3d cB?Bb?ƜL ՄV??Ϙ i p??R3f MHh?ʛM??6 TШ Zק F?V 럳?x 6eEc ML腥 q첌 yB aK2 uE M?gϘ 4qq㙯 Z?X Gщ?5 M??X N?w D匋 s?TM u?а r?(Igu?mKnN霷 ϓ?Q C?O CYm V?X en 3Sױ?J u8?l B?:b EO O?z F?ݷm?ʘ k?ݜ??Ը I k?h Mmܩ?4TU _?eDA!Z?L O?XA?e?6HC Hm f?tr ekyfM J8 vf?NY:I RvZ?7 Cv??V tm?n W??C yO xμ y9 PI?ۏ??u??r ɮI??M?Vg?f?tf??H?_ c0 M?v?2o I?G 9?Uu Ӌzr D??O W7v K?f aKlg o?i cQ HO?X a?/o i?c?5w Xcn?p C?X DGTw?p I?s?ǻ a _?FJ k??Lb Fm sdo G??V h?ɘ ܜg z?x?b?ބI A??f?Ct??ӡ?E?O og A jQ5 I I??f k?T?o 7u:ܩ 4Ly?TzY m?p X?D?C yB6 hp?IEފ?-?7q TK mx k?G mc ir m?H8 dr f?A E?;Y PcP ы?w Ff a sO?EQ f?Au Gi CWU?7 o?k N?y О?"Q A?xl 0b aLC ץU 0H??IE Dad PI j?ѨY ǚw?O T6 a G?Ɓ mi?T g??K 7w v??B A?ke AN kw??o Tڇ?E eCZ Ӛe o?߇d eht1Q炗?_?ᒡ Ro n?h S?S?k ImK T9 b?Z?JV ԮJ?v 0L Hx!?m 9l?Ҭ C?r ĵ?Fl?e sШi O?H s?f 0n?_JG a?Q?ӀQE Av?s?L ox nމ Uת Zv n9??qBdSf Nӳi IkKD n?O?N?ؠ oר Ho IjT.X ګm4W?A r??y V??UE,r 7k V?x iO p?YZ 8?_U6crKc J?i 3?OyuJ?d Z?ɢ??w u?x Y?w Ot?g m.:?LE?mm 4??Djҋo!g oQ?7 a!Z?p k??Ŏ Y??ъOr?"?O eN riQk Z?d(LnC A?PJk Pem U?ed?ahZ e?n?c?"o U?Fa4 j?j?Q.?B ip MAd?k Yu e?G ALO?W!3 sD S8 Qb gō c?D mGJ xPU 3v Gi M5 Cb S;-P b?SD??Y5 I ep V?Տ?p?Ͼ2 k?:?Ai a?GϝZx?5?ON 3P 4bA V?-BJ K7 j?a??b q?q c??LLk TB m?J V?ټ??J ҍp dC?S tn dO??X a ZP A O5 Ou?P G??D _V Kno??P?WY U_ j?z I Y?H mL?Ӆ c1 A wJ?P EQ oU oYg S?Q ˈY?kP M??Y s?T g??a ObU ՍZ?K wF GV R??K?o a Ԫ?X?G?g C?oL uc??BGڲ o?r yu d?s8 Q?T o?b nԡPH-Q 8bd 2tu2u?l?C Ѷ??sSM KG?w y?Sǩ wU OV E??Ҟ g:?S,Z?d?H i J?:K 3PyQ Gk?P8 o?G o?G a f96e?j?hA Ulģg1 w0U 6?븛c?!玸?JZ WP?bd b?a Q?s x?yM c??F SVZ?G v4 f?O Rj?սI k߀P??Q At??ۋ w?E 뙾?Z ļ?Y??ч G?k KOt6 w?"D(S ν7 HN?R?oS C?In??Y?fxV?6 AK/?0c DW?j?gz ȅ?t??v J?Z蜎 ė?J?j W?JC OvK?QM?v A c?t?Ӭ??Ej L?P 9??ȉfΚ H?a?b ZwG5?A Ѝ?Xy?h?r L?T?wD ݻ??U RuUj/?ž t?J??V?h v?o?f?x Bߚ r)?D k?X?)L C?S3 m?b?a O?Lr?ٻ I em xJ Q"DT?䰡 G?ت M?ڹ _?uA 8yI xa AWwb6?U H?z H?p v?!uk byOŅ ˁV 6j?jöĆFx yk?ϒ T?I?bz??g ҤiL??h 詎?nY e9g Q?L zy w?pF e2 β6 h?x?j?L?N?d o?ۍ C?8E?r?um næ i a L?P2S37RƎI yq 3P JL?wi H2O M??G 5??l?kհQ nt??R R?o JY??sr ߐ?e mqSy?v?q k?f?3kX L1 ɫTm T?vV 2?!?RiWZ B:6?ʵl _?F?p?Un fPRZ,C Z?/Sa kV IN??ᒖI x?gTH 3y?Z G??i?d 8mT R?ZS?Y?V Pba?1 1?ΤI u5 A TfP_ D?οCy?E O?l c??a??jF tD?㚭 LK l?B Bt3C?ߊRo mq j?An f?d i??سnZ p?NCj 2ٿ Q:??HI??زU?oy?e?W??òv aA 9U Sx_?B狿LK ZO DR A?y?ͺ Ѕ?g??I SCk hH?G Lt i?J x?ɞyi?F/M n??C??ylB_S g?h_ql Mn?F w?YJ T?a M?Y wd5?"H c?vҮ?D PtW d?RL Lj1 vFD?H Hv?XG PQ aRǯ pS K?2I?h i l?A?QulZ?z0 T?.yjY nF xc?T6??O?ҵ?lDz r?γ??y gH 4g C?m l?-a N?v h?j x??o?FFl Ne?2N;?O u?7?XXY cJD yX NJ 7ѵ e??I i?W LG E?udž??R?D Q?Mȿu dG?M P?8ȌH?p E?s kMD?q Z??q?FE Or?n5?N7 ѶXu u2 A Y?VU Ԭ)ޔP O??oGݽ?8P?q?kX?o C?E Tg-?s R??F 3?sqΈ k??K Sp?p F?l kJ?R?"WK X?qk?F A 8:SU Đb j?K B?ץ U??L xz P?U?R6 z?/S JZ??E A xuN KВ Ru wԥH?c T?M鯘?g?C?nI T?T tU?Y n??J Æ??7b?Du P?c s4 żDnG?T?nJPωEUN Ip K??A D??D??vh?hx n?s x??SM?h _??ˈb?FW 6B I?Y?r1 MR 0B 1L U?;쌮Z3 J?A9?Bi oP fT g?F??P Fr j6 my I O??ʊ 7T H??ǙH Ly??U 신cUL;?Ҿ ڝ?Ղ X?P u?j?r ɞz?4 U?r Z?č?8x-c Il?:Y??p wG?m?a?d n??s a 5Aj?tl 湤6?0gw qA OE Ga?g?t?elde ҍ?e q5j SQ q2sp?e W?J3 1?jN nUw??0?Ġ ظ??vZ n?w?l Čҍ r?N MF?NI C?I as?K t2vŜC I ȍaXU IibF?N?𰗊 6M1i h?Mo?ӯ?i9 X?o GQ l5 uP a R?y iԋu?0?bo i 7nخ?Qd?osvJl??rE?1 h?OG Od?o7 xG Iz c3?ZĀq q?ī C?X e53uļg Qd iU-?MP jQ?kt?A㿐 H?i ҳj m4 jvn wF ۑM??k eG MC d??g I c?-?sK kj m9?t f?O e??k w-?V ӻL)0 Xn DI?Ó l??F uE S?j Dj Į1 yXn??o G3??U?ܓʓZR?w?A Vż?dM2 B?A?E ћ?l?G Mj?Xga??v 7y z5 P?UX YC U?nv??S պI 9k I?WH?s ҲG T??Ͻ V?k ͿpR a?eo i퀶?-D փId?/1?w Nku??v T_ BY 4gqB?n te N?vN??k XG D3?gFS ph??dV NV I b?R UB _?Ag?n?lf aU?Ѻ Ir?W??b W??t L??iu y?V I a E?Bje I?j a Q?Bp R?M?ycO?Q Mb X?P??t b?uW ҖAU?4C?l ǧ?G?w cG F?I Z?F E?!d Ylao Gg??ìغ ɹt e?y?i??A ջ3 Jy l5 wBo ګ?d k?o AQ U??OGF4PEa F??b l髋 S?FS I ӯO պA ľ?Ǟ FıS ȸ?V hx Fb r0F??;qE e?E dǸ?x 6ee,b J?IU(?l 3Q XEj??:?Ƨlϖq wO m??M MF0 Pm ʼɜ X?_ȩnZZ 4nZ E?Ny?F Mk P?t fE ʔ?kBu?A?_U Cڑ ViX i W?J?,P?p?M䜠 E2m??s p?P?N Wf?J?J ˮYΩ g-?HΑ fơ A?i dD?E GM Ex cD 7P C??N hP1w??J??l?y z?Sąդ zp c?j u7?B z9 jP Ud?w IP?b??P.??i?z?LH lE X?m?k yo qu f?p 3YQ P?nn 糱??ȉ?M 颠A p??YS!2h C߆ PrĦ W?X0 z5U v?p?ز iW wn u4 C?ь?L3钫0 i W??T 3Pm vO n?m wtd G0N??8QҺٿ?k?D H?Yh g?ȠE 2?dߌ Dt/j?Gz E?ĵ T?o bKl7r m??ȩ x?k?R?S??J p??V q?C g??ʲ?n eT e9 i?ט L??މU roN eЎ Z5 S1?PشΌ 4J2V g?z 3W?M p?H??oL E?s 衵S DgI?e?T2w Z?u?p z??v N?u w?U Rs??n?O I B??PC q??Ba)GD Yȯ IJy??f?k G?xvx?PO _?l?Il?G?q pObS A w8 ΌY v?a3 q?V X?y zu䭳?z I VC Nu 0n 7Mmn np đJac?zE?u??ޒf jyq CD?b T??w j?sϟ s?R Q?U fˤ r9F GV?Q G?ʙ2 h5 U??nUf mP p?xk ZE4C JvGvE?s?C?2 л??G A僸 B??l ck??h nޢi fg0 Z?cˡ 0F d?i fO٧ zB?d i?P rV jц?O?e?ї?_ V?H yX q?Tamu?V??6 R?A?H i O?u A tP_ t?oU bq a?M xq j?/n xBĬ t?ki 5F e1z pJss fa rQ Md??硸C?s?K dd KT?g?쒷 K?I??h S?p??X?ڱ?Q qo??rv N)_c Pg4??EH c??e Kh UU8??Y Ő?T kmn?Kfo??sKxf qI?ԝ A VG??Mx LP?A?7 BR ߪ3 pq H?x ObI?Fb T?R?c!P When you were hiring and bringing in all these new attorneys did everyone come in as a partner A No How did you decide who came in as a partner and who came in as an associate A Depended upon their level of expertise practice book of business It was a decision Stuart and I made together on a case-by-case basis So you and Stu where the were in charge of hiring A Stuart and I tried to consult on every hiring decision yes Did you guys also decide salaries A I generally decided the salary and then let Stu know what I was going to do And he would say if he thought it was okay or if he thought it was too much or too little but I generally had free reign in that regard Did someones book of business directly correlate to the salary that you would offer I ll I I I I i Would you need to look at someones book of business if they were coming in just solely to be a rainmaker for the firm prior to hiring them A I discussed it with them There were not many people that I recall that I actually looked at their numbers Once David Boden was working for me I had him check peoples numbers but I rarely looked I took most peoples words for what they were generating My recollection is you were always looking to bring in more people to hire more people some of us were somehow able to resist you while others were not How would you decide who you were looking at to bring into your firm A We were trying to develop on the legitimate side of the law firm we were trying to develop real talent real practice groups I mean Brad is a _perfect example great lawyer got a great reputatiol You know it was our hope that you know he was goin to be one of the people to actually in some ways rescue the firm because he had a practice group that A That is a very broad question because it could generate substantial income You know on the depends upon what other needs we had for that legitimate side thats what we were trying to do we individual were trying to find the best and the brightest What do you mean by what other needs Okay With respect to bringing people that Page Page _cc _cl __ A Well Ill give you a good example My lawyer Mr Nurik his salary was directly related to the fact that he was a great lawyer and had a solid book of business Yes A David Boden on the other hand was as I previously testified I dont know if youve had a chance to read the testimony but David Boden was not only the general counsel to the law firm but he was also acted as my consigliere in a significant number of illegal operations and he was compensated significantly for that if that helps you understand the difference It does So for example when you were hiring former judges lets use that as an example Pedro and Julio clearly they dont have a book of business coming in because they havent had clients but they may carry some sort of prestige or give some legitimacy if you will to the firm How would you decide the salary for someone like that A Stu and I would discuss it It was more a market issue than anything else how much are judges coming off the bench getting how much business do we think they can generate I you thought could bring a book of business you just I said Brad for example that he had a legitimate practice group with a good book of business How did you know that I I I I I I I ii20 ii A Everyone in the tort world that I had spoke to spoke extremely highly of Brad not only people I already had working for me but other people that knew hi He was very came very highly recommended to us Like who for example A We wanted him in there We were trying to develop a significant tort group and we thought that hed be a great part of it Who besides Russ told you that about Brad A It would have been other people in the tort group I dont want to guess Tonja as to which other people told me but it was well more than Russ Was it people within A Might have been people in politics that I talked to that knew him because we had significant input at the gubernatorial level with regard to tort reform and the like and there were people there who knew who Brad was It was more than one person that told us that Page Page FRIEDMAN LOMBARDI OLSON Pages to df Okay When ou were looking at 11eo11le tci bring in to the finn to legitimize as ou said Your finn had a very unique area of practice and had a very unique environment to which to work _How did you know or how did i,:ou come to decide what 12eo12le may or may ot fit into that A Okay Hang on one second I think you just accidentall misstated mi testimon:r:._ I was not bringing the peoele in to legitimize the law finn I was brin ing them in to the legitimate side of the law finn The bulk of the law finn des12ite the lack of financial success was a large group of very honest hard working lawyers trying to do their best in difficult economic conditions There were some that were obviously not legitimate And the way I decided to bring people in again its really everything I just told you Are you looking for how I brought people into the Ponzi scheme No right now Im just asking about the finn because as I said its a very unique way in which to practice and a very unique workplace environment with politics and restaurants and parties at your home and things of that nature Im asking personality wise other than the book of business how did you decide on Page people that would be a good fit A I looked for people that were outgoing that had the type of personality On the legitimate side of the business people that had charisma that were that could go out and hustle and try to develop a book of business if they didnt have it And as one of the percent of the shareholders of the firm I was trying to hire people I wanted to work with Okay When you would see people from whom you would offer jobs for example as you mentioned earlier with Brad and his practice if somebody stated that people told you that he was a good lawyer did you need to see him in action so to speak prior to your deciding to hire them or would you just take people at their word for it A Some of people I saw in action he wasnt one of them Steve Osber is an excellent example of that I hired Steve after he was beating the living daylights out of me on the other side of a case And I certainly would ask around about the people But the people that I trusted see I cant remember I think Gary Farmer was working for me before Brad and iflm not mistaken he would have been one of the I I I II I i I I I I I I I I I I I I I i i I people that went to with regard to Brad because we were really developing that whole tort group around Page i that time with Farmer and Fistos and Jaffe and Mr Edwards Do you know where Mr Edwards was working when you first learned of him A I dont recall whether he was working for someone or had his own practice I dont recall When did you first learn about Brad A I dont remember the time frame Do you recall when you first met with him regarding a job A No The easiest way to figure that out is to go look at his personnel file it will have the notes saying when he met with me the first time You dont have any recollection of your first meeting with him A No As you know I was hiring people left and right and I was also unfortunately very busy doing things I shouldnt have been doing so I dont have a specific recollection of when I hired him I barely have a specific recollection of when hired me But you did in fact meet with him A Im certain I met with him before hired him I cant imagine although I did hire people without meeting them I did hire people based on other peoples word if they were people within the Page firm that I trusted Because always said had a very simple you lie or die by what you are telling me lfyou are telling me this guy is good and hes not good thats on you its going to hurt your income So used to tell my partner people that were recommending people to me dont sell me a bill of goods just to get somebody in here because if you do that its going to come back on you its going to affect your income and your ability to grow in the firm So with that admonishment I might have very well hired someone sight unseen based upon what someone else told me But you did meet with Brad you say before he came in to work A Now that Im saying it out loud I think I did but really lm guessing I dont have a specific recollection of meeting him Do you recall if you knew that he had worked as an assistant state attorney for a few years prior to doing tort litigation A I dont recall that one way or the other So you wouldnt have asked Howard Scheinberg or anybody about him before he came to work there A I cant say that I wouldnt have asked because like I said might have asked But Page Pages to FRIEDMAN LOMBARD OLSON 7f-bcdd-ca2d8fe941 df unfortunately you are taking a little tiny spot out ii of a very very busy time period in my life and in the life of the finn so I cant tell you one way or the other I I know you had a lot going on Jm just i trying to see if you remember anything specific about i this Do you recall what salary you had offered Brad to come join the finn A I do not You have to just try to ir differentiate that what I knew then is a lot different ll than what I know now so 1P Meaning ljl3 A Obviously meaning that at the point in time that I was hiring him or maybe a year after I would be able to tell you what I was paying him but now its insignificant dont remember how much I was paying him fl Did you learn about his book of business or know what kind of cases he was bringing in erior to hiring him A I do know that he I discussed either with Russ well I know with Russ and perhaps some other i people I knew about the E12stein case i What did you know about it Page A I knew that it was a significant case of 12otentially significant value against an extremely 3ollectible pedophile fqr lack of a better word So was that case your erimary motive in bringing Brad into the firm A I doubt it I mean I cant tell you one way or the other but I doubt that I would bring him in just for one case because what if the case fails _!ben Im stuck with a lawyer who cant do anything you know Im not saying Brad that you couldnt do anything Im just saying that if I only relied on one case then if I bring a lawyer in for one case and one case only what do I do with him when the case is over How did you know that this case would be a collectible case then MR SCAROLA Im going to object to the form of the question because it misstated the prior testimony The prior testimony was not that it was a collectible case but that it was a case against a extremely collectible pedophile BY MS HADDAD What made you think that this case had any financial value I I i Ir I i A Epstein was a billionaire Okay Did you know anything about the legitimacy or illegitimacy of the claims prior to knowing he was a billionaire A I knew what I was told I didnt check it out myself but I trusted the 12eo12Ie that told me And who told you A The only person I remember discussing it with as I sit here today is Russ Adler.J!ill.i Fanner and Jaffe and those guys were with me at the time,_ likely would have discussed it with them as well So were you aware of this case before you made an offer to Brad to join the finu A You said you didnt I dont want to misquote you You said you heard about it from other people but you didnt do anything to know that personally Was that before you made the offer of employment A I made the offer of employment based upon what other people had told me about Brad About Brad and his book of business or just Brad and his legal skills A Okay When I say Brad I mean Brad and his Page book of business and his legal skills Okay A And his ability to generate business in the future You stated that you believed that you first heard about these cases from Russ and then perhaps from Brad Once Brad was at the firm did you keep up with these cases these Epstein cases MR SCAROLA Excuse me Im going to object to the form of the question It is an inaccurate reflection of the prior testimony It has no predicate There was no reference about having heard about these cases from Brad The names mentioned were Adler possibly Farmer possibly Jaffe BY MS HADDAD Once Brad started working at the firm youve already testified you already knew about these Epstein cases correct A Yes How did you keep abreast of these cases A I didnt You didnt know anything about them A I didnt say I didnt know anything I said I didnt keep track of it Page Page FRJEDMAN LOMBARDI OLSON Pages to df You didnt keep track of it I A I 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 I was doins along with my co-cons12irators I just assumed lawyers were going to work the case and eventually it ould hoEefully work out well for the law firm At your firm when e-mails would go out to attorneys at RRA or all attorneys at RRA were you I part of that e-mail group A You are talking about all staff No all it says is attorneys at RRA A Its the e-mail group attorneys Yes A Yes Im a part of that e-mail group I I And I appreciate that you were very busy and may not have read all of them but you did receive i those e-mails when they would go around i A Yes and I tried my best to read them i Okay At what point did you decide to use this case to further your Ponzi scheme A dont remember the date but I can give you the circumstances if youd like Page I Please do A The Ponzi scheme was running very low on caEital My co-conspirators and I needed to find__11 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 I thought about the EEstein case realizing that it was a substantial actual file in the office I came UE with the idea that if I created a fake confidential settlement circling around based upon this actual case they would be able to increase the eye of due djgence that I was able to offer to my potential investors How did you know this was a substantial file in your office at that time A Again through the people I spoke to in the office Such as who A Again same people Adler Farmer Jaffe Fistos You never sEoke to Brad about this case I I i I ii22 A didnt say that but I had a lot morir Page interaction Sorry Tonja I didnt mean to speak over you If you talk to the people in the firm if they are honest with you theyll tell you my _interaction was far more significant with Russ Adle_r probably more so because he was a co-conspirator of My interaction with Russ was far greater b_y many many percents over my interaction with Brad and then you go down the line I had more interaction with Mr Farmer than I did with Mr Fistos more interaction with Jaffe than I did with Mr Edwards and so on Russ was the head of your tort group right A Yes So these cases fell under the tort group is that correct A Yes it fell under the fell under Russ purview ultimately yes And Brad was a partner at your firm during the time these cases were there correct A I believe that was his title He was either partner or shareholder I dont think we had made him a shareholder yet But he wasnt coming in as an associate Page correct A To the best of my recollection no So you stated that you learned this case was I dont 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 I perceived to be a highly collectible pedophile as a defendant BY MS HADDAD 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 I spoke to him about it Did you speak with Mr Edwards about the case A I dont have a specific recollection one way or the other I remember speaking to him at least briefly the day or the day of or the day before the actual investors due diligence was going on as to Page Pages to FRIEDMAN LOMBARDI OLSON 7f-bcdd-ca2d8fe941 df ȏ?N?w,?xl?T쵙?j 2r E??I9t L?e y?W ϐ?ڴ?X?U??o?qk i9 e?N H恊 E5?C P;?-?FwI u?g OP aI K?P lR ɚ??q OT 9?ah u?z LH7D unNg r0 j?J a i tA?w??A xG w?J E?Lx??;ٮ f??r e?DUr k??Γ:F L?b??Y?n Iz qV?M0??t 9j??gI ha?C I??S M?x M?h z?ő??(?n?Qڿ?Č?9Jӹv E1 G??ѱ?z eN R?1?UC X?T rH k?,?Z?uĜ l?A?LKf Љ?7C h?vbk Sթ m?aG?O Fe O?k L_ QTX?ʤ?wr?6 yt?N F9 aƶ 4la??nh?Xٲ Q?ɾ DΡ?q??M aK J?yjɁ 櫒??E áp:?G 漲Lٱd Vef P?tSt?F mW?g??I B?J YO?G ix n?sz hY um??N?wd Y?I m??i?uJӻ?r wb?AQш?r mX ȹN JN?r 7Bx bB?T?mw s?F 3H?ux_ ӥӔ?8 zH OΣ a??z p?Lq Qb NP?.U2 p?c?P iU k?彾?ZH?z Q?h??R t?Ѐ w;f 턋?_s?U ƌq w?R?p i huBk k??Bѡ oh?l ߤ?FXp ɥߋ 8?b?Iٸ?fdM 0ZЎ U?u Gu AW In?w Ӏ?P B?p I?g-?Ն p??Zu h?L?pIK h?ǘ3 G?.gIn ی?i䮰裠 zUø nȋ eh??Z PN v?z j??a X?Y Dt n?R?pg UѼ?PX U??z լsl??X T?c H??J P?J W?S?W??RŚ yCi汾 f?P BH?P??Q gj F䉻?p?SA WL?0 n?B xL?y jw??z)M?2cM ŗ:L?H mHڲ?ײ?M a i 7L.y?a?o 顆B s?xy UVaI 虗?A Cu R?h f??f4s h?k D?a??Z?8Iﾋ ƀ?F H4H uiP K??HR IMw rR??N sQh?D u?W??p4w?R?FK hLY m?Z?nW?c?f OF ugw cz z?A rpc?ty7C??9?i k?ɲ v?C?p M?B??a q?H?Ւ?s?R dw0 C?d A Ob?O L?F A2 y?b?n9 t?a?E?Q k?OC 5Ҷ jQ EC 4t XI M?F BVdq?q/?(??I 0p j??g H?i C?L i E?"dRk I j?P x?d ݷ??ZF?S??M?nQ d?tW Ǻ?q?sq t㛱7 f??D v?T Sd?:l T?e W"/??rXer fB Wm A tN ct U6 k?(uW6w AG 7ծTz e?P Zh?晄 Z1?n?b 3D"c p?g XS i 6A??A?FSX s4Spv x?L??مq?P jf Ts A yj Tdӛ?N L5ҳ?N?QA Yւe 0?pܥ H??g S?Y?Y B2y oD j?Nlv?.?x _X i ji jа??P I DP65?ޤJ T?R jN Ғ?6K xK I ij k"?iL N?f zx L?Z ìt ro2?ܡB N??p?Y Wm z?o?u Va ſ?A ecw Jw 忓?ho O3 Nˣ ey GD2 t?uT m?c O1u3?O?X?.ih pU L?.?ZGS?tS sZf pA?m?d FsΠ QױN 0J?Ը We B/?ݕ UѶ R?Q?by eT5 x?X Cq 3D?Ta w??7o?tۯ gT bF ijі a?p FV Lh m?Ǹ H?1T OV-??SA Pw H?M??կ?W A zEE6!G 0?mȥ I s,s d??O R?Hi UD PC ѼOm?Sf s?J V??o S?F Njl ZeM?.?z?d??D q4R s?c Ѭ??q l?Y?sP N?E嵈?a t?y F1k U?D q?q ǎ?P??z?4hO gD?aaO G1 ڼ?j?ጹ??M C?IB?a?r lU i?U?u Ȇd?v V?RC1?x l?I WL?qb d?u a W?r?o:h Bj cތM E?XcO ZI ub aв??e bbҲa 橌0ksҘy f?b A r?G JnLK??K?P q?D yY M,?j?oO W??o Eϭ yiN?I?3 F8Z??uݹk?r sϯKMC р?wڝ nqa?e?z?8u/u?Yt lbϰ?p V8?G S??s Eq ؤ1 v5N x?F?l KI W?U r?A i xv WQA a Eaҕ?nM?H 扎?I A x?rJG?Nb _s Pc??ϡ F??sn d?V A??wݔ 4V?m?v 6lp?l Ic2p LPek ڹx ۑd L?b j??Ys d?u i JD Wf ȱ?yh a EM Waz ػ?h yQ3??SX y?v?v yVE?LӔ Ȇ?s I?e PCBj?Z t)L uk?KH?j4 z5 fN wE D?jh9 m?T aD?5 B?c?N fx??w?Q?D.O?O?jW n?b kr r?Lm u4?x G?X CX a?E n?n ȘגuQ?Qr?o?W.?q q??U Rh 8Ts ʿ??G t?Q Ts h??nC g?dww?O P?vWԯ??;?soZ Hh t?L?VE)?U 8S eX A rP ԑ?MW Z7 j?z??EX x?pw??Ċ c?y??Ǒ e5RU B??W Ngsѵk m2 RM2??Z V?ӡ?Hr 6Z DŽw M?f0?p?z l?Wܙ?a SW Ɂt P?s k?l-τf??Q nI24 ½n 3Lk p?p G??q?g??p?TA r4 T??kKc?JR A ʝnA Y"r _fcW iN?3?E?W W?j VS a ED yp?ns??pK k?iJ5YX?rИ?o j?s xpȿ??sh?iZ?Ռ?Vx Q?w nT q?MNY gn?X Y"k gs_ i?T??Udb j?g1 9K?e yu a 7g?Hʛ r퉑?F??x t?ڑ iOO?G W?k ot?h ޅyp?q A f??di E?2W FgY??Cu?I SU OX 2tF?X?B gE4r?f?B 逶?T J5j ǽ3n 9d L?N?f Ռ?W?f X?4CB?Z5Fcxmgr μ0 I?e J??i a ƴ?sy?m R??d?S Β?pQ eS Ai?A??ꢈ??Q?k GKKҞ rQ?-q?T La?eK 0R fv?䙎G??m?o S?R iU8n xnM ڤh n7cSЃiuz ϼ??y cILPT NH tg oH?U PL q?Xvc mk?S u?l A _F LW y??دH??þWկK??8HK p?Л)y?u FE L?4Z?e e9 Z3 A A7aC??b 9پ n?S?E??R?X aӷ?q F??lЎ H??x ZH Hy I PX r?O?KX 6t I βۅ 8?tw O9 L?I KK 3Tv b??I չ2 ʑG NP o?U kxU??_ m?c x?X I H??.M싨 Iej?G?D?c??v ףՖJ 젮RS Ԓ?2?c3ghgL1 xX b?U??늖 I1Y??N TH?TY Y?,A A q?J A?i xFyr B0 yF F?b fi??I xN3B Yr Zow:?R SF rry H/s ȘƮ?v 5y OSrx?b?m e??Q??ze i??O O?b?I?W vt Gk0 AN?M ԍo 8?Sp f??Sij??Hg آZr?1ɑz E?K WB ii ζ?S۱?AV i R??oUB?GU?i R1 E??M Yl p?c J?Tz g?A?U"n ݓC yR S?ʠ pwC??f p?ç q?Obj??9?i??xdĈ O??kb mjf D?Q I Ư?ck n?R i??l H?X y?Z QQ Fd 1x??O?I5Qwvq P?J O?N G??j?w j?f ϱh?D?U ю?겱?n?P ۇCx _e EI Sl BM8 RZؠ??s9ߟ ϼ塉??b5aԮ?p/o R,ø I i?r??z BR??c T?i?t nS??C??s i kh S??i A I Cd bT5 L??X a?v9n?t a y?v S?G?e yB?O?S?""N TP?c 6η a ɞ??!ίpȆT?c A?F?lXwՕ??g oI JҚY ܔE?ѳ?W?R C?t i ǔi d?ǵ/r ui?ÐR 6t x?"vw j?YjI yP?K ϖΆ n?Ly??w p?d i ǯ??G 萓U??n?U?I T?xŧ c?3b F?2?bK?cЊ Rx pc 0?Ql c?W?p BP s?L dN"jz SNg Jy s?a r7BE??ȦJ q??M?tz ln98 L0 FM혅 Vy?7?c?Wc ؤ?v ҧ?b E?W?H s姯?w?;?D y2?H pr ޠ:?ʱ z?U?ô N?X 77?VgxY ߐJH 탍?k Y??Wu??l 5?ГV?V u?K DMD W?h xAA?U S??v dž?ʼZ?1 l4 uV w??v i ÌA X?Ծ щQA A KD TǼ DS?H?kj G?Qf ġ?B v?T9D a(ƤH?l KX VI H0?K Ta B0?㲼 w?n I-?ڀ1d k9 4UVֆ?G?4?B o?e A?a?n fRX?k RVĢ l??X k?pT eǏ?7?fa,?AAH??r??J?ox B2E w?ae ļ?Bs IJ LY g??jΰ I ɾWUB?aƌ??x pL Y0w Ý1 d?C?b V9 Na yǑ?Ջ f?W??kkd?QrZ l?M ao g?n pzn ȆƩ يn?V D4 n?,?AOÙ vE nq/O?ڠEc JM ZħC d??x dF1?ڊ Yru?2s VIv?UZ I?J i K0 I w)K M5p SࡪmeY?fāݴ Zn uٵ 3t PKg?czR k_ϯ 7EH v??odn6GlY M?2p?K?g Ǵp n?,V?l C?t Ǒw a z?Q oO PoW uV?E KN XcS?!??T?m Yv I?gm ߵ?KR AR tI o?m6 4i E?V rzI 1hSk?C NB ڹ??Ù x?l E?d?O oI?p?8 _y ר??bs/u?Bu C?5Wt I vGj X?-I xh 9z ea6?gšs n??mץ?m4Ɛ I P3 n?I껿?1?l VD u?k v?U Jj m?:J l?Z 6f A?e?!E Tw T?N mB??J OY C2 r?f 1b?e yȝ z??n V?Ҵ?C ݏt G3 Mh 4ȸ 6x I?nKBt?4?c cNe oA a??V D?Y?e4f??Kv 7J җīi?g?_ s_R q?zd Vu i z?k e??f.?xcE ޕqJ?E?Sb caC U?M9 a?O?³t?r Q??OgO?wan??g nrb F?i Q?m K?h N?b??e??u?nn zp??a cxU p?Sc?j KJM G?j i Ah?Y O?Sd8Ez LG D?P Ĩ??QZ?P N?r A?I Ӗ?r WKq kL?qF??N!K yy Dv ة?A?Kyn fG?U l?6??ԩyY?U i zA Q:Y OLP??v ɢ??4ls h??VG5 ʪi??c3 EGe?6 q?7o 2hĔ Q?o v?k oBF V?J?u pŒ Sh yz?MioHj w?W5?Y z?ke bc B7 d?v??i c?"dj?P?N B?z FPh5 A y?ZЖ jk Tɦ Z_ Hl V6 MZ f?f??tMI2 pȯu??A t?Q ɋ?C?BGJ??TU a V?M?ɳ w7?z Ix 9OmC 6x à??P䊠 t;ïV YkF a?d Ӗ?6F e?Zı f?L6 JS?t?8z XX?i Sk ef h2 lM ԓe?z F?"?JM z?so _??F4?pZfh?w _kD??t E?s Ja ezd?d?8 z0K ƿ1捛J??w8?JE n??P l?.Ι D?HQ ͲC r7 a H??ߙ 0.Tӯ ct aW H??כ?ݨ mc ɑԜ?2Ծ?Q?X SbV Zy what was going on And I may have spoke to him I know I spoke to Russ but I may have spoke to him as well within a couple of days just prior to this due diligence because I was trying to at least get some information in my head that I could use when I was creating this story for the investors Scott whats Q-task A Q-task is a web based software system that I had invested million in And what was the purpose of this internet system A To be able to communicate in a secure fashion and in a unique group fashion about specific files So forgive me we all know Im not good with the computer That was something that would be useful within a law firm why A Because it allowed you to create groups and have both general and private chats organize data in a very unique fashion That was at least to our way of thinking would have been very very helpful in the law firm setting with multiple practice groups Did you belong to any groups on Q-task A Im certain that I did I dont remember I I I I p7 which groups I belonged to I never got into the full Page 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 Im going to object to counsels testimony Object to the form of the question as leading THE WITNESS I really dont even understand the question Can you try to rephrase it for me Tonja BY MS HADDAD Of course I 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 I 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 I had with Russ Adler so I was probably more up-to-date on that group than any group other than the labor and employment group again because I had such significant interaction with Stu Rosenfeldt both legitimately and illegitimately so I knew what was Page I __ use of it I tried to but again I was very busy doing other things But I know that Mr Adlers group used it extensively Because it was your firm and as you said you invested million in it did you have the ability to access a group if you wanted to I i I I II i A Yes And if I couldnt I could get Russ to give me access So you didnt necessarily have to be invited into the Q-task group for you to be able to utilize or view the communications within it I A No thats not true I actually had to be I invited thats what I was telling Russ to do is to I have me invited But Im saying the lawyers wouldnt have to personally invite you you can get someone within your finn to give you access maybe without the lawyers knowing A No I think it might have had a quote unquote confidential super secret viewing capability but I dont recall it having that and Id have no need to utilize that Just invite me into the group and let me see whats going on Okay I know that you are or were a very hands-on person within certain of the practice groups i I Page I going on in that group I tried as best as I could given my time constraints to stay on top of what was going on you know throughout the finn But I relied on other people like Debra Villegas and Irene 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 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 So in how many floors did you have A Three I think And do you recall approximately how many attorneys you had working there at that time A Approximately And when you say not the individual offices but the other areas do you mean would that include conference rooms A I didnt have surveillance in the conference rooms So can you please tell me exactly where you Page Pages to FRIEDMAN LOMBARDI OLSON df had audio and/or video surveillance Well start with audio A dont have a specific recollection of every place I had video and audio but it was in had it set up so that in all of the common areas including our shareholders lounge we had I had audio and video capabilities When you say capabilities does that mean you didnt always tum it on or you just turned it on when you felt like it I I A I turned it on when I felt like it when felt like seeing what was going on I sometimes left i the screen up because I had four computer screens on I my desk I sometimes left the screen on with the video i of the reception area and some other general areas But unless I wanted to see what was going on or listen to what was going on I didnt tum it on 1t would have been too distracting Did the attorneys know that this surveillance existed A You can see it in the it wasnt hidden you can see it There were globes up in the ceiling all over the office I Did you have you said you didnt answer this you said you didnt recall Did you have Page I any surveillance in the conference rooms A No Other than the common areas you just went over in the hallways and the reception did you have it in the hallways is that a common do you deem that a common area I A All the hallways pretty much with the exception of a few blind spots can see all the hallways i And this was on all three floors I A Yeah For some reason I think we might I have taken some space on a fourth floor but I could I be mistaken But yes on the three floors that we actively had a significant amount of space on tried to have surveillance on all the common areas of all I that space And what floor was Mr Edwards office on A I dont recall I i Did you have the tort group all together or I was it divided up A Except for Adler Adler was on with near me down the hall from me The rest of the group was I all together I think they were on lets see I There were people up on I was on He must have been on the other floor that we were building Page out because I remember building out space and I remember Jaffe and all those guys moving into that space If you were building up that space do you recall when you put the surveillance in there A It would have been while they were building it out or shortly thereafter During it seems that you hired lots of former law enforcement people to work at the firm Why were they people you wanted to hire A Severalfold I had a significant amount of illegal activity going on with various law enforcement agencies throughout South Florida and hiring people from former law enforcement assisted me in engendering support and camaraderie with the law enforcement that was actually utilizing in illegal activities So you are saying A Secondarily I wanted to have a very strong investigative team ultimately to do both legitimate and illegitimate things for the law firm and hiring former law enforcement was the best way to do that was hoping to actually ultimately create a group Ken Jenne and I had talked about that extensively Why did you hire Ken Jenne A Prior to Ken going to prison he and I were Page very friendly and he was extremely friendly with someone that was very close to me Grant Smith During the time that he was down in FDC Miami I went down to visit him And after speaking to him and after speaking to Grant I told him because he was talking to me about how many people had turned on him and abandoned him And I told him that when he got out of jail that he had no worries that I would give him ajob And what A And that was the primary reason that was my primary reason for hiring him What was it you were hiring him to do exactly A Ultimate the goal was to head up on investigative arm within RRA within the RRA entities Well while he was there since that didnt happen what was his obligation to the firm day-to-day A He handled firm security issues and he did handle overseeing certain investigative things We had an alcohol and beverage group that was forming and he was overseeing that He was helping me find new people to staff it that kind of thing Did you have a lot of interaction Page Pages to FRJEDMAN LOMBARDI OLSON 7f-bcdd-ca2d8fe941 df A He had had significant as you know he also had significant political connections and everyone who is not living under a rock knows I was doing everything I could to gamer significant political power I think many people miss your parties But with respect to Mr Jenne and his political connections were you hiring him to utilize him with respect to any of the police department investigations You had stated earlier you had dealings with police departments I dont want again I dont want to put words in your mouth You said you had dealings going on with various police agencies A I had I mean we had a criminal defense section in the law finn so we had legitimate dealings with law enforcement But I also had significant illegitimate things with law enforcement that had nothing to do with Ken Jenne And how about with respect to former FBI agents you were hiring A They were all people that were operating in a legitimate fashion within the law finn ln what role was that A The investigative roles and the alcohol Page beverage roles and anything else Ken or other staff could think ofto have them do Lets talk about the investigative roles for a minute What kind of investigations were these teams running A I do not know You have to speak to lawyers that were actually utilizing them I put it out there and Ken put it out there that they were available to lawyers in the firm for use like in-house investigators And what people did with them ultimately was up to them Were they on salary or were their costs and fees associated with utilizing them within a specific practice group A They were all on salary-with me The ultimate goal was to have it as a separate entity that could bill the law firm and have the clients at least defray some of the cost I dont recall whether or not we ever got to that level or not With all that in-house police action why did you have police security surrounding you all the time A I guess the best answer was I was paranoid but I mean thats the simple answer to it You Page I I I i I i I I I I i I i I know having there were mixed reasons For example I are you talking about my Fort Lauderdale police detail Yes You had it at the office and at your home correct A Yeah Theres a myriad of facts that motivated me to do that One was that I really wanted the security for the office Two was I was paranoid and this is in no particular order Three was the Melissa Lewis murder that shook the entire law finn and shook me terribly I didnt want that to ever have to happen again And four was I wanted the more law enforcement you have around the more legitimacy it adds to you and your appearance to the community So there were a multitude ofreasons mean I hired certain law enforcement to work for me that were just friends of mine that were that needed additional money so I wanted to make sure that they had money both guys that did the illegal stuff for me and guys that didnt do anything illegal for me Lets go back to the Epstein case and when you decided to utilize it to use for the investors for your Ponzi scheme Do you recall approximately when it was that Page these investors were coming that you decided to use the files A My best recollection it was in sometimes after April of but I dont have a specific recollection beyond that What makes you think it was after April of A Because to the best of my recollection the Clockwork Group came in towards the middle of When I say Clockwork thats an umbrella tenn that I use to mean the Yon Allmen AJ Discala and other investors that came in through that feeder fund So that was around April A No it was after to the best of my recollection I mean you can tell because all you have to do is look and see when the first very first Clockwork investment is Actually you can pinpoint it even closer Look for the very first settlement deal that we did that was related to the Epstein case within days prior to that would have been when I Vas meeting with those due diligence people to days before that So when you decided to use that case take me through exactly what you did to familiarize yourself with that case Page Pages to FRIEDMAN LOMBARDI OLSON 7f-bcdd-ca2d8fe941 df A I talked to Russ Adler I may have talked to some of the other la ers I fli1212ed througp certain boxes in the file How did you get the boxes A I asked someone to bring them to me Do you know where those files were stored A I do not So you flipped sorry please continue Flipped through some files A I flipped through some files I had the files in my office The day that the investor group h1 came in I actually had Ken Jenne and some others actually bring me some more of the boxes actually into my office while the investors were there I already II had some of the boxes with me You say Ken Jenne and others who were the others to whom you are referencing A dont specifically recall who carried them in I was very focused on my investors at that time Were any of the lawyers 12resent with you when you were meeting with these investor A During the actual meeting with them no I recall that some of the lawyers may have met some of the investors but I dont recall who Do you recall approximately when that Page happened A No its the same dates that I was giving you before Okay So you had to further your Ponzi scheme you had to familiarize yourself with this case so that you could speak intelligently with the investors is that correct A Well sort of because most of what I told the investors was all things that I was creating as I About this particular case the Epstein case A Yes from an investor you have to understand how the inner working of the Ponzi scheme were crafted but Please tell me then A Im telling you hang on From an investors stand12oint the investor is simQIY looking for is the case believable And once they get past that is it of such case excuse me is it of such a that it is possible to be generating a significant amount of settlement dollars And then after that their concern is simply on the due diligence side of making sure we actually have the money that the documents pass the documents Page no Ill I Ii In I unrelated to this case documents related to the settlements Other than 12roving the existence of the case theres ven little an investor at least from my end investigates into the actual case more after having the case exist and not caring about really what was going on in the case other than a lot of money was going to be collected Well with respect to showing them that the case existed and that there was a likelihood of a possibility of a payday at the end how did you convince them of that What did you use to convince them of that A I did two main things One I QUt the boxes in my office while they were there I told them to 12ecifically look at a cou12le of sheets of a flight manifest that was in the file that Russ had shown me And I told them that it would be a breach of attomeiclient erivilege for them to look at the file but that was going to step out for a while and leave them there with the boxes wink wink and thats what I did I ste1212ed oul I let them look jjt whatever they wanted to look at I came back in they were satisfied that it was a real case and I was and running And these were the real legitimate files for Page this case is that correct A These were the legitimate files yes Nothing had been created at this time for them to look through A didnt add anything to the case files The case files were significant enough by themselves Do you know how long they were in your office days weeks A The people or the boxes The boxes A The boxes were in there probably a little more than a week I dont have a specific recollection Okay Did you ever go through them A Yes I flipped through them at some point in time And what do you recall about what you saw in the cases Do you remember anything A I remember seeing the flight manifest._L dont recall seeing anything else Im sure I looked at other things but again for my purposes it was insignificant to me because the actual content of the boxes was not necessan in the sale of the fake settlements Why was the flight manifest so interesting Page Pages to FRIEDMAN LOMBARDI OLSON 7f-bcdd-ca2d8fe941 df I I I I to you A Because of who was on it Who was on it A dont recall but I do recall saying to the investors I recall having a conversation prior to the investors coming in with Russ Adler and Russ had told me that Epstein had flown Bill Clinton on his plane had flown Prince Andrew on his plane dont remember whether that was on any of the flight manifests or not but I left that to the investors imagination as to what they were being told about Mr Epstein and these other famous people that were cavorting with Mr Epstein and let them look at the file You have to understand from an investors perspective hang on From an investors perspective the only thing that matters to the investor is that its a real case and that they can verify that real dollars are being paid The fact that it was a real case was evident had a lot of boxes with real pleadings in it and a lot of ot.bs:r information in it The fact that there was real money being paid was a fiction that was created by me and my co-conspirators everyone from bankers to computer people So the a tual role of the case and I want to Page I I I ii12 1lu I I I I i2 A I went back to selling the Ponzi deal And did you sell it A I be ieve I did Youd have to look at the actual settlement documents to see if I put one together for that but Im pretty sure we did Do you recall if the investors asked you for any additional information or any additional documentation A I dont recall one way or the other After this initial meeting with the investors did you give any direction regarding this particular case A To whom To any of the attorneys working on the Epstein case A No I didnt interfere in how they were running their cases They were far more experienced than I was in that type in handling that type of As a matter of fact I was practicing very little real law at this point in time I wouldnt have had time to tell them or to get involved Did you ever keep up with this case after this initial meeting with the investors A Im certain that I talked to Russ Adler about it from time to time but my main focus by this Page __ c_ make sure you understand this the actual role of the actual physical case in the Ponzi scheme is from m1 12erspective minimal It was just another vehicle for After that initial meeting with the investors where they looked at the file what happened with respect to their desire or lack of desire to invest MR SCAROLA Excuse me Im going to object to the form of the question it assumes facts not in evidence Theres been no testimony that the investors actually looked at the files only that they were given the opportunity to look at the files BY MS HADDAD Was your video surveillance on when you left the investors alone in your office A No no I didnt have cameras in my office I didnt let people look in my office when I was in there that would have been bad So left them alone in there A Yes Do you recall for ap12roximately how lon,g A No more than minutes It was a short _period of time When you went back in what happened Page I i I I I i point in time in was the Ponzi scheme Did you try to sell this particular settlement to any other investors A I dont recall one way or the other Okay Did you ever have any conversations with any of your investors about this Epstein A I dont recall one way or the other I notice theres been a privilege log produced with respect to e-mails There seems to be quite a bit of communication between you and Ken Jenne with the topic being the Epstein case Do you have any recollection what that would be about A I dont As I sit here today I dont have a specific recollection of having significant e-mail contact with Ken Jenne about the case But if you are telling me I did Ill accept that but I dont recall what it was Earlier you had stated that when you were hiring good attorneys such as Mr Edwards looking at their book of business was I dont want to put words in your mouth it was the legitimacy of the practice it would bring in legitimate money to the practice 1s that what you were hoping to do A Earlier when testified specifically testified that I personally did not look at most of Page Pages to FRIEDMAN LOMBARDI OLSON 7f-bcdd-ca2d8fe941 df I It I I I I their book of business This being said I was I I bringing in legitimate law ers to form legitimate 243ractice grQUQS to Qractice legitimate lawi having nothing to do with the Ponzi scheme During the year were there any to your knowledge any big settlements of any cases at i RRA I A To the best ofmy recollection no We had a dismal year The year was just dismal across the board A Some people did better than others but yes overall it was for a firm of lawyers it was I dismal So there were no big wins coming into the firm as far as a financial windfall other than from i your other businesses ld7 A The only significant capital coming into the I firm was money my co-conspirators and I were stealing Was there any particular practice group that you can remember that had a particularly non-dismal year in jl A Mr Nurik had a good year Do you recall what the gross revenue was I from legitimate sources in Page A It was somewhere between eight and million probably right around the nine million i mark Do you know what your I A On its best day What was your overhead for salaries in i do you recall A I dont have a clue Was it more than you brought in legitimately A With what I was paying in salaries Im I mean Id be guessing If it wasnt more than it was certainly close to it Thats just salary thats not talking about anything else rent overhead things of that nature A Thats correct Who was paying for the investigations of the cases that were going on in the deposition costs the filing of complaints and things of that nature Where did that money come from from your firm A It varied from case to case For the tort group A It was fronted by the law firm for the most part Page For the most part What wasnt fronted by the law firm A I recall there being a couple of agreements that various tort lawyers had with certain clients where they were going to assist in helping to pay the costs All the other costs would have been paid by the law firm both through legitimate and illegitimate means So when you say by illegitimate means where would the illegitimate means money come from A It came from the Ponzi scheme and all the tentacles of the Ponzi scheme other illegal activity Such as A Things I was doing with law enforcement things I was doing in politics things that I was doing with organized crime things I was doing with politicians judges other lawyers bankers business people things of that nature Im sure theres more Do you recall if any of these Epstein cases underwent significant investigation while the cases were at your firm A Id be guessing I dont remember There was a meeting in July of and it appears from the e-mail communications that it was for everyone in the firm to attend and it was Page regarding the Epstein case In fact there was an Epstein conference room that was reserved for it Were you present at that meeting A I may have been Do you recall A I dont recall one way or the other You dont recall it Do you recall anything about the Epstein case in July of A I do not Do you have something that might refresh my recollection MS HADDAD Can we just take a five-minute break right now THE WITNESS Sure MR GOLDBERGER Thank you MS HADDAD Thanks Short recess taken BY MS HADDAD Scott I was asking you before we took the break about a meeting with respect to the Epstein cases There was a 159-page privilege log filed which Im sure you dont have and are not aware of But in it there are many many e-mails to both attorneys at RRA yourself and Mr Nurik regarding the Epstein litigation And all this resolved in July Page Pages to FRIEDMAN LOMBARDI OLSON 7f-bcdd-ca2d8fe941 df of about the Epstein meeting and some additional investigation into the Epstein case Does that refresh your investigation as to when you met with the investors in the Discala/Clockwork Group A It does not The best thing to refresh my recollection as to when I met with them would be to see the deal documents Okay I unfortunately dont have those Do you recall if you took Discala and his other investors to a football game in A Sure I did Okay Would that be around the time you were trying to get them to invest in the case A It would have been around the time I was trying to get them to invest in general Its may have been around the time that I was showing them the Epstein file Did you show them any files other than the Epstein file A I may have I dont have a specific recollection one way or the other You testified earlier that you had over a dozen boxes brought to your office that were related to the Epstein case Page II i I i I li9 MR SCAROLA Excuse me counsel Counsel there has been no such testimony BY MS HADDAD You said there were several boxes brought to your office by different people You dont recall who that is is that correct A Yes had some boxes already in my office and I had Ken Jenne and some other people bring some others I dont remember how many boxes Was it more than three A Sure it was more than three boxes yes Was it more than A I dont believe so no You stated that you looked I dont want to put words in your mouth What did you look at specifically in that case A Other than looking at the flight manifest that Russ Adler told me to look at I have no specific recollection as to what I looked at in that file I Do you know if there was more than one case being prosecuted by your office against Mr Epstein i A To the best of my recollection there were it was multiple plaintiffs Okay Do you recall if those cases were pending in state or federal court A I dont recall Did you check A I dont remember one way or the other It was insignificant to me Well then explain to me You testified earlier that what was important to the investors to see is that there was a real case correct A Yes What did you look at or show them what did you look at first of all to see if it was in fact a real case A I knew it was a real case How did you know A Because my lawyers told me it was a real case I believed them What lawyers told you that A I already told you it was a mixture of Russ and Jaffe and Fistos and Farmer and Mr Edwards mean I knew it was a real case We had all these boxes we had people really working on the file How do you know A or they were pulling a hell of a scam on me Not that I didnt deserve it but How did you know you just said you knew people were working really hard on this case Who do Page you know was working on the case A The only people that I knew for certain were working on the case was Brad Edwards and Russ Adler doing his supervisory schtick whatever that was But other than that I dont know which other lawyers were assisting Mr Edwards I didnt get involved at that level As far as the Ponzi scheme goes the only thing I cared about Tonja was being able to show the investors that this case that I was utilizing to steal a significant amount of money from them was area ase Thats all I cared about That case came into your office through Mr Edwards correct He brought it with him when he came to RRA A Yes He was lead counsel on the case correct A I assume he was lead counsel never checked to see if he listed himself as lead counsel Do you know if any additional complaints were filed while the case was at RRA A I have no idea one way or the other Did you ever instruct in furtherance of 1our Ponzi scheme Mr Edwards or anyone in th litigation group to file additional complaints Page Page FRIEDMAN LOMBARDI OLSON Pages to df A l:iQ Who is Cara Holmes A Who is who Cara or Cara C-a-r-a Holmes A To the best of my recollection she was a former FBI agent or maybe IRS agent I dont know She was a former federal agent Did you hire her to work for you A It was either IRS or FBI Did you hire her to work for you A Yes I hired her at the suggestion of Ken Jenne For what purpose A To work in the group that he was overseeing So what did she do for RRA while she was there A I dont remember Did you ever mention her to your potential investors from the Clockwork group A Its a possibility because as I was I lil5 building the Ponzi scheme I frequently referred to the fact that we had fonner state and federal law i enforcement working for us and on our investigative teams It added legitimacy to the Ponzi scheme Didnt you tell investors that she could I Page hack into a computer as part of her skills A I certainly may have told the investors a whole host of lies about what was going on about with case and what people could do and did do Did you ever personally utilize Cara Holmes skills in any of your cases A I dont remember Were you handling any cases during the A I was overseeing cases in but my involvement was mostly supervisory I was handling very little that was legitimate at that point in time Were you legitimately when say legitimately were you invited into Q-task on any particular cases that you can recall A lm certain was I dont recall one way or the other Do you recall if you were involved in Mr Epsteins case on Q-task A I may very well have been but I dont have a specific recollection one way or the other Do you know who invited you in A I have no idea ifl was invited in And if I was invited in I have no idea who invited me Once you decided to use this case in your Ponzi scheme did you go into Q-task to look at the Page i I I I case or any communications A I may have Do you recall when that A I may have Do you recall when that may have happened A I do not Do you recall the first time you looked at the flight manifest to which you referenced earlier A Prior to the investors coming in I dont remember the date Did you instruct anybody to further your Ponzi cheme to investigate or check into anyon whose name was listed on the flight manifest A I may have but with this clarification If I instructed someone to look into something I did it without that person knowing that I was involved in a Ponzi scheme or that what they were doing was illegal and it was just to get me additional information to help with my sale of the fake settlements So it was to further your A So I may have asked someone I may have asked someone to get me some additional information but as I sit here today I dont recall ever asking anyone to do anything on the file that was for the purpose of furthering the Ponzi scheme other than Page perhaps getting me a piece of information that I needed Im going to try to refresh your recollection as to whether or not you attended those meeting in July of And it appears that in between the dates of July 22nd and July 24th there was a number of communications through e-mail by and between yourself Mr Adler Brad Edwards and Ken Jenne regarding an Epstein meeting that was going to be taking place Do you remember that at all A I think what you are referring to and Im not certain but I think that what you are referring to is me making sure that the file was in the condition in which I wanted it at the time the investors were coming in I dont think it had anything to do with the actual functioning of the Epstein case I think it had to do with my illegitimate purpose Thats the best of my recollection but if you have documents or something that you can show me that would be helpful We are not privy to all of the e-mails because theyve been alleged as privileged or work product so I unfortunately cant show them to you But according to the privilege log between Page Pages to FRIEDMAN LOMBARDI OLSON df July 22nd and 23rd there were numerous e-mails sent about the meeting It was almost an all-hands-on-deck type meeting where everybody needed to attend It was labelled the Epstein meeting with an Epstein i conference room reserved A Yes Okay Whats your question and will tell you i MR SCAROLA First Im going to object to counsels testimony but lets hear the question BY MS HADDAD i The question is does that refresh your recollection as to whether or not this meeting took i place A To the best of my recollection I actually I I had introduced some of the investors to some of the i people working on the Epstein case and that is likely the meeting that you are referring to But for the life of me I dont have a specific recollection of it But it could be the meeting where you introduced the Epstein litigation team to your Ponzi investors MR SCAROLA Excuse me Im going to I object to the form of the question It misstates the Page prior testimony It has no predicate BY MS HADDAD That could have been the meeting in which you introduced the Ponzi investors to people working on the Epstein case MR SCAROLA Excuse me counsel The testimony was that there may have been a meeting at which investors may have been introduced to some people working on the Epstein file And your efforts continuously to mischaracterize the prior testimony are highly improper I object BY MS HADDAD I Scott did you or did you not say that you introduced some of the investors to some of the lawyers on the Epstein case A No I actually said Tonja that I may have I have a recollection that I may have based upon you just refreshing my recollection but I just do not remember one way or the other This was in the scheme of what I was doing insignificant I was simply trying to establish to the investors thaitlus was a real case with real potential with real Jawyers working on it Other than that it was of no interest to me il4 i I i i I I I How else would you convince them Youve Page mentioned letting them look through the litigation boxes youve mentioned the meeting What other way would you have convinced them that it was a real case A I mentioned letting them look at boxes what they did when I was out of the office thats I dont know because I couldnt see what they were doing Number two I may have introduced them to people in the office Number three Im certain that when the people brought the boxes to my office I ntroduced them to whoever was canying the boxes And number four the rest of it would have been all tuff I created in my imagination because again it was the sale of something that didnt exist This was not settling There was no real settlement money There were no real settlement documents I even manufactured I think the actual plaintiff because I dont recall even knowing the plaintiffs real name or if I did it was of no significance to me How would you have manufactured a plaintiffs name would you have created additional documents to further your Ponzi scheme using Mr Epstein as the defendant A No How would you A The name just would have appeared on the Page confidential settlement agreement Would they have already seen the documents at that point A I cant tell you one way or the other what they had seen because I dont know what they actually looked at Forgive me youve now confused me so Im just going to ask you for some clarification You used a legitimate case and created fake settlement documents correct in the simplest sense A If this culminated in an actual sale of a fake settlement then the answer is yes So it was a real case with a real plaintiff and real defendant just a fake settlement document A No Let me see if I can clarify this for you Over percent of the settlements that I sold the fake settlements were completely fictitious Right A A very small percentage of them were based at least in part on some type of real litigation that either had occurred or was currently occurring I utilized the Epstein case to bolster the visual for the investors that a real case existed Because as these were being sold to more sophisticated investors the questions kept coming up was there how do we Page Pages to FRIEDMAN LOMBARDI OLSON 7f-bcdd-ca2d8fe941 df know this is a real case So I was finally able to say this is how you know here is a case file I may have I dont remember specifically one way or the other but I may have utilized actual 12laintiff names from the cases filed but I may have made them UJ2 I have no s12ecific recollection one way or the oth as total geared toward simel getting the investor mone into the Ponzi schem W..ere you aware thal the da after this meeting took 12lace on Jul 24th a new federal comelaint was filed against E12stein with one of the same plaintiffs that was already pending in state court A I dont know that I was aware of that or not If they were filing it someone may have told me I dont recall one way or the other Did OU ask an One to file it to further your Ponzi schemeJ A No I dont remember doing that Do you recall any situation where you A You do realize Tonja hang want to make sure this record is clear Other than Russ Adler the 12eogle that were involved in the E12stein case had absolute nothing to do with the Ponzi scheme Page Directl:C A Or indirect They had nothing to do with JL Yet the file was used for you to further your Ponzi scheme Im not saying that they gave it to you to use for the Ponzi scheme Im asking you used their case Im not the question is you used the case A I took advantage of some good innocent people for my own and my co-cons12irators illegal purposes Mr Edwards is one of them and for that I am sorry Brad Did you ask anyone involved in the Epstein case to file a federal complaint MR SCAROLA Objection repetitious THE WJTNESS Without seeing a document Tonja I cant tell you one way or the other I dont want to I do not want to guess If you have an e-mail where Im saying to someone file a federal case then obviously I did But I have no specific recollection of that BY MS HADDAD You do have a document with you its marked for you its Bates stamped It begins at EP and I goes through through I Page A Hold on one second Okay What number am I looking at Its a very large document Its begins with Bates Stamp Number and ends with A Its in the computer hold on a second I have that in front of me Do you see the date on that complaint stamped A I do And theres give me one second Scott sorry What was the date that complaint was filed A Whats the last page of the complaint whats the Bates number The last page is Im sorry would be the last page of the complaint The Complaint referred to was marked for identification as Defendants Exhibit I MR SCAROLA You may want to call his attention to the filing stamp on the first page MS HADDAD I did I guess he didnt hear me THE WJTNESS Im sorry MS HADDAD Its stamped on the first page Page THE WITNESS Hang on the complaint is dated July 24th It was entered onto the docket on July 27th MR SCAROLA Do you have another question MS HADDAD I thought he was still looking Scott are you done looking THE WITNESS Yes one second MS HADDAD Thats what I thought THE WITNESS No hang on one second It shows the stamp on the first page says July 24th The filing say electronically filed July 24th Theres an entry onto the docket on July and the complaint is signed July 24th Thats all the dates I have BY MS HADDAD Okay And back on Bates Stamp Page Number whos the attorney that filed this complaint A I dont know if thats his signature but the name is Brad Edwards Okay And does that e-mail A With the squiggle on top of it And does that e-mail address look like the correct e-mail address for RRA A It is So that is in fact a legitimate e-mail Page Pages to FRIEDMAN LOMBARDI OLSON 7f-bcdd-ca2d8fe941 df address from your firm is that correct A Yes And were you filing any cases back in in federal court Do you remember how PACER works MR SCAROLA Which question would like answered THE WITNESS I dont remember MR SCAROLA Objection compound BY MS HADDAD Do you remember how PACER worked when you were filing a case Scott A actually never actually did the actual electronic filing procedure I had people that did that I knew that we could file electronically Do you know the purpose of your using your e-mail address when you were filing electronically in federal court A guess so you can get a receipt but I have no idea Did you ever receive an e-mail from federal court in your e-mail address that showed that a document had been filed with the stamps that you see on the top of that one MR SCAROLA Counsel are you attempting i I from federal court A Im certain I did Tonja dont have a specific recollection of getting the one pertaining to this dont even know if they sent it to me I would imagine theyd send it back to Mr Edwards The filing attorney A suspect unless the PACER system is registered on my name then maybe it comes to me but I am completely guessing But based upon the e-mail communications of July 22nd and the meeting occurring on July 23rd this complaint was filed the day of this meeting is that correct A Okay But here is the problem with your question I dont remember whether or not there actually was a meeting said there may have been and I dont have an independent recollection of this being filed do not have an independent recollection of whether I told someone to file this And for the life of me this I am certain of if I told Mr Edwards to file a complaint in federal court if there wasnt a legitimate reason for him to do it he wouldnt have done it Do you recall if this federal case was filed when you decided to use the case for your Ponzi scheme Page Page THE WJTNESS dont know one way or the other MR SCAROLA Are you attempting to establish that that complaint was filed in federal court by Brad Edwards MS HADDAD Im asking him if he recalls the way its drafted and why MR SCAROLA Just ask your question MS HADDAD Im asking a question If you have any objection please lay it on the record MR SCAROLA No what I want to do is try to save some time If what you are trying to establish is that Brad filed the complaint in federal court on July 24th and used the PACER system you dont need to ask any more questions about that it happened MR GOLDBERGER We appreciate that but when we depose you well ask you that question But we are deposing Rothstein right now so let her ask her questions Dont do this speaking stuff let her ask the questions okay MR SCAROLA Maybe MR GOLDBERGER Okay Go ahead Tonja BY MS HADDAD Scott did you ever get e-mails like that Page I I i and show it to your investors A It may have been filed around that time because I havent been able to establish the exact time It also certainly may have been utilized by me to further the Ponzi scheme Also I dont have an independent recollection of that either Without seeing e-mail traffic I cant tell you one way or the other exactly what was going on at that time Well then Ill point you to another e-mail which is marked as EP MR EDWARDS Let me see it MS HADDAD I sent a copy to your office MR SCAROLA He would like to see a copy now Thank you The E-mail referred to was marked for identification as Defendants Exhibit BY MS HADDAD Were you able to find it Scott A Got it Yes I have it You have it okay You said Cara Holmes used to be an FBI agent correct MR SCAROLA No What he said is THE WllNESS FBI or IRS Page Pages to FRIEDMAN LOMBARD OLSON 7f-bcdd-ca2d8fe941 df i i i I i l1 I I I I I BY MS HADDAD Or IRS Well use the blanket tenn federal agent ls that a fair assessment A Yes Thank you Do you recall when you hired her to work for you A I do not Was it in A I dont have a recollection one way or the other Okay Have you ever seen this e-mail I before A saw it when I was reviewing your exhibits Before that I have no independent recollection of ii having seen it Im not copied on it so I Did you ever have any communications with Ms Holmes about people that were close to Mr Epstein A I do not remember I You stated earlier that you knew that Mr Epstein was a wealthy man ls that a fair I I statement You called him collectible was that because he had money MR SCAROLA He called him a billionaire Page too MS HADDAD Billionaire THE WITNESS I knew he was a billionaire I BY MS HADDAD Do you have any independent recollection in the month of July of this case being intensified I in any way such as going after those close to Mr Epstein A I dont remember that one way or the other If you knew that Mr Epstein was a billionaire do you have any recollection of asking I someone to investigate those close to Mr Epstein to ii further your Ponzi scheme I A dont have an independent recollection of I that one way or the other i Do you recall if you ever directed the I depositions to be taken of the people who were listed on the flight manifest that you saw A dont recall one way or the other I may have told the investors that I was going to take the depositions without ever intending to take them but dont recall one way or the other Are you familiar with a gentleman by the name of Mr Rodriguez Alfredo Rodriguez A No Page i Never heard that name before A Alfredo Rodriguez Yes A Its not ringing any bells to me Do you remember hearing at your office with respect to Mr Epsteins case that one of his former employees was willing to come forward with a big book of names A I dont remember that one way or the other You have no recollection of that Do you recall anyone approaching to ask if the office can purchase this book A I dont recall that Do you recall instructing any of the attorneys in your office to get an opinion from Kendall Coffey whether or not they can legally and legitimately purchase this book A I dont recall that one way or the other The Complaint referred to was marked for identification as Defendants Exhibit BY MS HADDAD Okay Im going to direct your attention to whats now Bates stamped as EP which Im sure you havent seen before since you just said you didnt know who he was but Ill give you a minute to look Page over it A This is rather long Do you want to direct me to a specific portion of it Sure If you look at the Page Bates Stamp EP Paragraph and A Okay I read number five Would you please read number six as well A Okay Does this refresh your memory as to whether or not anyone ever asked you in your office about purchasing a book A It does not Do you know that the cooperating witness was an attorney who worked for you at your firm A I did not know that until you just said it right now According to Paragraph Number The deposition of this Mr Rodriguez occurred on July 27th is that correct MR SCAROLA ls it correct that thats what it says Im going to object to the form of the question its vague and ambiguous BY MS HADDAD Thats whats listed in the federal complaint correct Page Pages to FRJEDMAN LOMBARDI OLSON 7f-bcdd-ca2d8fe941 df I I I I A What does it say Say it again It says The first deposition occurred on July 27th correct A Yes Some three days after the federal complaint was filed correct that we referenced earlier A Thats correct And Paragraph clearly delineates that in August a phone call was received by the cooperating witness that explained that this Mr Rodriguez had a list of other purported victims or contact information for people who Mr Edwards could also potentially bring lawsuits for on behalf of is that correct A dont know one way or the other You know Tonja just so this record is clear you know i as Im sitting here have a vague recollection of i perhaps Ken Jenne coining talking to me and telling me that someone in my office was going to cooperate with someone in this investigation But for the life of me cant be certain of that So much time has passed but as Im reading this and it could be completely unrelated to this I just want to make sure the record is a hundred percent clear its possible I that Ken Jenne discussed that with me but I dont Page know who it was You are testifying that you didnt know it had anything to do with the Epstein case as you sit here now you dont remember A No no dont have a specific recoHection and I want to just make sure so I answer all your questions completely is that as Im sitting here my recollection was refreshed that I have a vague recollection of having a conversation with Ken Jenne about the fact that someone in our office was going to cooperate as a confidential informant for some law enforcement agency I just cant remember ifit was the Epstein case or not Do you recall what you said to Mr Jenne about that A No What I just related to you is all I remember And Im not even sure it had anything to do with this Whos Wayne Black A Who Wayne Black A Sounds like the name of someone hired but I could be mistaken I dont recall Okay You dont recall ever meeting Mr Black i I I I I I I Page ii A may have I dont recall one way or the other You have something that might refresh my recollection Do you know what he does for a living A do know the name Sounds familiar to me but cant recall one way or the other who he was or what he did Did you instruct your office to begin investigating Mr Epsteins pilot or his airplanes A I do not recall one way or the other You did testify that the flight manifest was the one document you recall for sure looking at in Mr Epsteins case is that correct A Yes And if it did in fact contain the names that you are purporting that it claimed or that you knew of that would be something that would be juicy for the investors to further your Ponzi scheme that it was a collectible case is that true A Im sorry you have to repeat the question Tonja I dont understand what you just asked me If these big names were on this list as you seem to recall they were that would be most helpful to you and your Ponzi scheme investors in convincing them it was a big case right Page A If they were on there or if lied to them and told them they were on there or if Adler told me they were on there and I repeated all those things would have been helpful to the Ponzi scheme You stated earlier that you the only thing you looked at was the flight manifest because you were told to look at it ls that still true A Thats not what I testified to I testified that I flipped through other parts of the file and that I didnt remember what I had flipped through remember looking at the flight manifest because Mr Adler told me about it You said that you met these investors in your office but there were no cameras in your office correct A I didnt have cameras specifically in my office You had these investors in your office for this particular Epstein case A Yes Do you recall if it was during work hours or after work hours A I do not recall Typically when you were meeting with your potential Ponzi investors did you meet them during Page Pages to FRJEDMAN LOMBARDI OLSON 7f-bcdd-ca2d8fe941 df work hours or after work hours A Both Did you always meet with them in your office or did you do it more socially down at Bova or elsewhere A Both But with this particular case do you recall meeting them at least one time in your office where they could look through the files A Actually that group of investors were looking at a lot of different cases or at least multiple different cases that we were attempting to lure them into the Ponzi scheme utilizing so I met with them on multiple occasions both in my office and at restaurants Who is Mike Fisten A Mike Fisten was a law enforcement officer of some type that I hired Why did you hire him A He was a Ken Jenne suggestion And were you hiring him to start up your company with Mr Jenne as you indicated earlier A I dont recall what the purpose of hiring him was It had nothing to do with what Ken Jenne was doing for us I I I i h1 i I I I Page i So what did he do at RRA I A My best recollection is that he had been a former ADT officer and so it would reason that he would be working in our alcohol beverage practice that we were establishing I I Do you know if he ever did any work for your I I i firm as an investigator A He may have I dont have a specific recollection one way or the other Did you ever speak to the press about the Epstein case A dont have a recollection one way or the other Did you ever have Kip utilize the Epstein case to put any publicity or spin out there with respect to the case A I dont have a specific recollection of that one way or the other i1s I Did you ever instruct Brad or Russ to talk to the press about the case Well start with Brad then Russ A I do not specifically recall getting I involved at the publicity level of that case dont have a recollection one way or the other Would that publicity have been good for your Page I Ponzi scheme investors A Not really Would it have given more legitimacy to your allegation that it was a good case in which they should invest A In the way that I was selling the Ponzi settlements it would have likely been overkill So did you ever instruct them not to speak to the press about the case A I dont recall that either one way or the other If it had gotten out there that the cases had not in fact settled as you were claiming when you were selling the settlement would that have hindered your case your Ponzi investors case A Not really because they would have no way of knowing ifI had created a fake plaintiffs name I mean there could have been something in the news that and I dont know that there was there could have been something in the news that says none of this settled And I just simply would have created a fake name with my co-conspirators created a fake set of settlement documents and handle it that way Did you know where Mr Epstein lived A I only knew that he was from Palm Beach Page other than that no Okay In did you ever have any firm meetings A Of any type Of any type in general firm meetings A Im certain I did Do you recall about how many A I do not recall Did you ever have any partner meetings A Yes Do you recall how many A I do not Do you recall how many partners you had at the firm in A I do not Do you recall how many fundraisers you had at your home in A I do not More than A Id be guessing Tonja Okay A lts easy enough to check theres state and federal records of all that stuff In did you still require the attorneys from your firm to attend the fundraisers you would Page Pages to FRIEDMAN LOMBARDI OLSON 7f-bcdd-ca2d8fe941 df have A You said still require which would have meant that testified Sorry A previously that it was requiring them Did you require attorneys at your firm to attend your fundraisers A I asked them to I urged them to I tried to cajole them into coming but it wasnt an absolute requirement Do you recall between April and July how many fundraisers you would have had A I do not Did you have fundraisers anywhere besides your home in A I probably did but I dont recall without seeing the documents If you have the invitation or the e-mails that would help me Did you hold fundraisers at your office in A I may have That wouldnt have been unusual but I dont have a specific recollection Did you ever meet any of the plaintiffs in the Epstein case A I dont have a specific recollection of Page Jc that Do you recall ever revving copies of e-mails from Mr Jenne with respect to the plaintiffs in the case that the subject matter would say information we need to use A I dont recall that one way or the other I Its certainly possible Do you recall ever reviewing anything that i was titled causes of action against Epstein i A I do not have a specific recollection of that one way or the other Do you recall ever reviewing with Mr Jenne ii or any other investigator in your firm any information regarding Mr Epsteins house staff or airplane staff Ii A I do dont recall that one way or the other I may have I may not have Who is Bill Berger A A former Palm Beach judge that we hired Okay What was his role at your firm I I A He was a shareholder What kind of practice A Litigating cases What kind of practice did he litigate What I kind of cases did he litigate I A I dont recall specifically 2s Page I When did you hire him A or I dont have a specific reco II ecti on If you hired lawyers who didnt have a book of business what kind of practice did they do at your office A It depended upon the lawyer I would have tried to get them to work with other lawyers in an area that they either were proficient in or wanted to become proficient in Okay You had a meeting at your office during which you were asking about information regarding referring attorneys attorneys who had referred business to the firm Do you know what Im talking about I believe it was back in December of or early A The way you are characterizing that meeting I had a lot of meetings like that What was the purpose of those A You are going to have to be more specific for me Tonja Lets start generally then What was you said you had many meetings like that Tell me what these meetings were for A Making sure that we were maximizing Page generation of business into the law form What kind of business legitimate business or the other A Legitimate business Sorry I couldnt hear you A Legitimate business The general meetings that you are discussing that was legitimate business So there was a meeting for all attorneys to attend regarding generating business those meetings were for the legitimate business A If it was addressed to all attorneys yes Okay And if an e-mail went out to all attorneys did paralegals and support staff get it as well or was it just directed to the attorneys A Certain support staff probably were on that list like my CFO and COO and perhaps my IT people but it was general for the attorneys With respect to your IT people did you have the capability to review e-mails and internet activity of all of your employees A I did Including attorneys A did Did you ever utilize that tool A Very infrequently It was a pain because I Page Pages to FRJEDMAN LOMBARDI OLSON df had to have Curtis Renie or Bill actually come into my office set up a special icon to allow me to do that It was a real pain so it was rare Who else attended the meetings that you had with the Clockwork group with respect to the investors in the Epstein case A There were multiple meetings with what Ill call the Clockwork investors at various points in time A variety of people came in and out of the meetings Some of the meetings occurred down in Bova Other people came up to the meetings Some of the meetings involved Michael Szafranski our fake independent verifier Some of the meetings may have involved bankers and the like I cannot tell you specifically who was at those meetings The specific meetings that we are talking about with where you left the boxes at your office do you recall who else was there with you at that meeting A I only remember there being a handful of people from the investment group and myself I dont recall and I remember the guys bringing the boxes the down but they didnt stay for the meeting There may have been other people there I dont recall one way or the other who it was I Ii I I I i I I Page If the expenditures were being made on a case that were substantial did you have to approve them or did you have a specific practice for them A The head of a practice group could basically approve them but Irene our CFO would generally run them by me before she actually cut the check If I wasnt around shed run it by Stu So as the equity partners you had the authority to make the determination what funds could and could not be expended A As the shareholders as the two percent shareholders we controlled the finances And if Irene was coming to you to tell you what the funding was for to get approval rather would she tell you specifically what the funding was for or just tell you we need A No ifit was a substantial expense Tell me what you deem as substantial A That would have been substantial to me would have been based upon how much money we had in our coffers at the time So ifit was one of those periods of time where we had or million floating around the law firm Irene probably would have just written a check without even letting me know we were writing it If it was one of those times I I I Ii i i I I I I I I I I Page I I 2s where we owed million in Ponzi payments out and she needed to write a check for even she probably would have checked with me on that So substantial and whether or not she would have checked with me depended upon the circumstance at the time You stated earlier and I think Ill get this quote right that was a dismal year is that correct A For the legitimate law firm business it was a dismal year So in the months immediately preceding the dissolution ofRRA July to October of what would you consider a substantial expense that had to be approved A It would vary literally from day-to-day Do you have any independent recollection of how you were doing in say July A The legitimate business was always doing poorly in as far as I was concerned So would you have A The Ponzi scheme had its moments of significant wealth and significant poverty so it varied from time to time It was a daily thing Sometimes it was hourly It just depended upon what was coming in and what needed to go out So would you have to utilize the illegitimate funds to fund the legitimate cases at times A Yes And that varied daily you said Page A Well all the money was commingled together so we used whatever funds were in there to fund both the legitimate and the illegitimate financial requirements of the firm the Ponzi scheme and other legitimate and illegitimate things that were going on If an outside agency or investigator was being utilized for a case and they needed a signed retainer agreement with your firm would you have to approve that A It would depend upon the significance of the expense I didnt necessarily get involved in every retention of every expert in every case Okay So it would depend on the cost or the nature of the case A Who the lawyer was their level of expertise all things of that nature fit was this gentleman who you have no recollection of meeting Mr Black and the attorney was Mr Edwards was that something you needed to look over Page Pages to FRIEDMAN LOMBARDI OLSON 7f-bcdd-ca2d8fe941 df A Did Wayne Black work for Ron Cacciatore Are you asking me A Im asking anyone in the room who wants to talk to me I love to talk to you but I dont know the answer to that question He might have Brad might be able to tell you MR EDWARDS No THE WITNESS When you said Wayne Blacks name again and that I hired him to do something I seem to think that he may have been associated in some way with Mr Cacciatore but Im not sure one way or the other I dont remember whether or not I met Mr Black its possible did its also possible I did not And I dont have an independent recollection of retaining him to do anything or whether I was part and parcel of the decision ifwe did in fact retain him whether I was part and parcel of the decision to retain him BY MS HADDAD Traveling out of state for depositions for the particular cases did you have to approve that A It would depend upon who the lawyers were the significance of the expense It would have been case by case I certainly would not have been Page I i approving or disapproving Mr Nuriks travel Mr Rosenfeldts travel Mr Badens travel Mr Lippmans travel That was their own thing fa younger lawyer like a Shawn Birken came to me and said he need to travel out of state for something if it was just for a deposition wouldnt have gotten involved in that unless he was telling my CFO Ms Stay that he wanted to fly first class and stay in the Ritz Carlton then I would have gotten involved But other than that no The firm was too big for me to get involved on a daily basis with all that stuff If Brad had to go out of state to take a deposition you wouldnt be the person to approve or disapprove that A Russ Adler would have handled that And if there was an issue Russ would have come to me And I dont know what the relationship was specifically between Brad and Russ but its certainly possible that Brad just was going to go do what he needed to do to properly handle the case and I would have trusted him to do that I MS HADDAD Can we just take a second We are going to take a minute okay Page Ii THE WJTNESS Sure Short recess taken FURTHER DIRECT EXAMINATION BY MR GOLDBERGER All right Mr Rothstein Jack Goldberger Im going to ask you some questions now You testified that you knew Jeffrey Epstein was a billionaire You did testify to that today correct A Yes Okay Tell me how you knew that How did you know that Mr Epstein was a billionaire A Russ Adler told me I looked him up on the internet What did you look on the internet about Mr Epstein A I dont recall but remember looking up an seeing that he was very wealthy that he was a billionaire Okay So as far as learning that Mr Epstein was a billionaire you learned via two ways one was from Russ Adler correct Is that correct A Yes sir And the other was through looking up Mr Epstein on the internet correct A Yes Page Okay And you dont know what you reviewed on the internet in an effort to determine that Mr Epstein was a billionaire is that correct A do not recall Do you know when you did that A do not Was it prior to your needing to use the Epstein case to further your Ponzi scheme A Yes Okay So prior to I think you indicated that you needed an influx of money at some point and thats when you decided to use the Epstein case in furtherance of the Ponzi scheme is that correct A Yes So prior to that time though prior to determining that you needed to use the Epstein case for the Ponzi scheme you looked up Mr Epstein and you spoke to Mr Adler about his work is that correct A Yes Why did you do that Mr Rothstein if you werent using the Epstein case at that point in your Ponzi scheme A Because it was a legitimate case in the legitimate portion ofRRA that I had reason to believe Page Pages to FRIEDMAN LOMBARDI OLSON 7f-bcdd-ca2d8fe941 df from speaking to Mr Adler could bring in a significant amount of money to the firm At that time Mr Adler was one of your co-conspirators in the Ponzi scheme is that correct A By this time yes sir Okay When did Mr Adler become a co-conspirator in your Ponzi scheme A I dont recall the specific date Was it before or after Mr Adler recommended that Brad Edwards be hired at your firm A Before So before Brad Edwards was hired at RRA Russell Adler was a co-conspirator of yours in the illegal part of the RRA firm is that correct A Yes Then after that time you hired Mr Edwards was hired after Adler was your co-conspirator You are laughing you are smiling why is that sir A Because when you say RRA that way the speaker sounds it sounds like you are roaring Okay Ill just say Rothstein how about that You know what Im talking about if I just say Rothstein A RRA is fine Page Okay So Adler is your co-conspirator in the Ponzi scheme at the time that Brad Edwards is hired correct A Yes Okay Was it Adler who recommended to you that Brad Edwards be hired A Yes He was one of the people Who else recommended that Edwards be hired A I dont have a specific recollection of who it was but others did All right But you have a recollection of Adler being one of the people so lets talk about that all right What did Adler tell you about Brad Edwards when you hired him Did he tell you that he had these Epstein cases or an Epstein case in the fold A Among other things yes I What else did he tell you A Told me he was a great lawyer and a great I guy i Did he tell you what his history was what I I Edwards history was prior to coming to the Rothstein firm I A Im certain that I asked him but I dont have a specific recollection of that conversation ii Page What did Adler tell you about the Epstein case that Edwards had at the time you were contemplating hiring him to become a member of the Rothstein firm A He told me that it was a huge case involving a billionaire pedophile and that it was a winner Did you when you heard that did you think that that was a case that could become part of your Ponzi scheme A No I actually thought of it as a way to earn legitimate money to help me out of the Ponzi scheme So at the time you hired Mr Edwards and you were talking to Adler about Edwards you were trying to get out from under the Ponzi scheme A In the bulk I was praying for some sort of legitimate influx of money to get out of the Ponzi scheme Okay So now Adler tells you about this Brad Edwards guy did you know Brad Edwards before Adler talked to you about him Had you run into him A I may have I dont have a specific recollection one way or the other Okay So now he tells you that you should consider hiring Brad Edwards this is your co-conspirator talking to you right ls that correct A Yes Page And he says by the way hes got this great Epstein case involving this billionaire correct A Yes Presumably then you had a meeting with Brad Edwards when you met him is that correct MR SCAROLA Presumably he had a meeting when he met him MR GOLDBERGER Im sorry Mr Scarola was cutting you off when you answered so go ahead answer again MR SCAROLA I didnt understand the question BY MR GOLDBERGER Do you understand the question Mr Rothstein A Im not sure I do because you asked me if I had a meeting when I met him and I think that meeting him is a meeting Well there was a meeting correct A I most likely met him before I hired him most likely talked to him before I hired him because that was my general way of doing business Its all Page Pages to FRJEDMAN LOMBARDI OLSON df together possible that I gave Russ the okay to hire him before I just dont have a specific recollection one way or the other At some point I take it you learned whether you sat in on a meeting when Mr Edwards was I hired or whether your co-conspirator hired him at i some point you learned that Mr Edwards in fact had been hired by the firm is that correct A lm certain that I gave the final okay to hire him Okay When you were giving the final okay to hire him I assume there had to be discussion of the money that he was going to be paid correct A With somebody yes Certainly with Mr Edwards right I assume he wanted to know how much he was getting paid A Yes but I dont have a specific recollection of whether I discussed that with him or whether I authorized Adler or maybe even Rosenfeldt to discuss it with him I dont recall Do you have the slightest idea how much money Mr Edwards was paid when he first joined the firm what his salary was A I dont have an independent recollection Generally someone like Mr Edwards at his Page level of accomplishment and his age you know what the general salary would have been at your firm A It didnt work that way I see Tell me how it worked I A Its a case-by-case basis I Tell me how it worked A Case-by-case basis And how did you make that determination on a case-by-case basis I A Actual book of business potential book of business potentiality for growth character what he brought to the table and obviously a function of how I much money we had available at the time Okay And you dont have any recollection of the machinations that occurred in determining what Mr Edwards salary would be correct A I do not i But certainly one of the things you would consider would be the book of business i.e the I Epstein case right I A Im certain that I did consider the Epstein case I Do you know whether he brought any other i book of business A But Im also certain it wasnt the only Page Ii factor I considered All right Do you know whether he brought in his book of business do you know whether he brought any other cases to the firm other than the Epstein case A I dont recall one way or the other Okay Do you know whether your well bad question I wont ask that Now youve talked a lot about Ken Jenne here this morning Was Ken Jenne part of your Ponzi scheme A No sir Had nothing to do with it right A Thats correct Other than his having working for you as an investigator he was not one of your co-conspirators right A He didnt work for me as an investigator he worked for me heading up our investigative division heading up our internal security heading up my personal security and acting as a political advisor tome Okay Did he serve any kind of investigative function at all after all he was a law enforcement officer at one point in his career Page A I note that he assisted the other people at the firm that were doing the investigative work I dont know if he personally did investigative work He may have Do you know whether Mr Jenne in his role as your advisor or your political consultant do you know ifhe was involved in any kind of illegality illegal wire tapping or anything like that while he was at Rothstein MR SCAROLA Excuse me Im going to object to the form of the question vague and ambiguous THE WITNESS To my knowledge he was not BY MR GOLDBERGER To your knowledge no A Correct Okay You talked about having a bunch of fundraisers I know you had a bunch of fundraisers that was kind of a deal at Rothstein This was kind of a rock star law firm right I mean you had lots offundraisers lots of parties right Was that the image you were trying to present A In reality thats the way we were Okay A A lot of young lawyers having a good time Page Pages to FRIEDMAN LOMBARDI OLSON 7f-bcdd-ca2d8fe941 df trying to make money And these young lawyers would you consider Mr Edwards to be a young lawyer or a middle-aged lawyer A Young lawyer Okay Was he one of young lawyers that came to these fundraisers at your home A I dont recall whether he was there or not I recall him being atsome but I didnt know if he was at all of them Okay You do recall him coming to some of I the fundraisers though correct A I recall him being at my home It may have been for firm parties or other parties it may have been for fundraisers there And that was during the time period that the Ponzi scheme was still going on correct I A Yes Did Adler ever the tell you about any discussions he had with Brad Edwards about the illegal part of the operations at Rothstein A Can you reask the question please Sure Sure Did Russell Adler ever tell you Russell i Adler is your co-conspirator weve established that Page Did Russell Adler in the furtherance of your conspiracy ever tell you he had discussed with Brad Edwards about the illegal activities at RRA A No Now,1:ou testified when asked about whether he press if OU were involved in asking the eress to run with the Egstein ston::i ou said something to the effect the wal was selling the Ponzi scheme it 1i would be overkill I I didnt understand your answer like you didnt understand some of my questions so Id like you to kind of tell me what you meant by that A I was selling purported confidential settlements Confidentia ify was the hallmark of the Ponzi scheme so too much publicity would have created a problem for me in the sale of what was supposed to be a com12letel;r confidential settlement I I think what you are telling me and I dont want to misstate what I think you are telling me but is it true that you felt some publicity would be okay but too much would be counter to the purposes of the I conspiracy Is that a fair statement i A The way I was thinking about it at the time this was going on was that some QUblicify would assist in establishing for the 12otential investors that there Page II was a real case going on but that within that I would ha;e to create some sort of fictions in order to sel the fake product Okay At the time that you decided to use the Epstein case as part of your illicit Ponzi scheme theme I think you testified earlier today when you were in some dire straights you needed an influx of money right A Yes Thats when you decided to use the Epstein matters correct A Yes Okay And you knew I assume being the Ponzi scheme mastermind here that you needed to make sure that you had at least a working knowledge of the Epstein case so that you could answer questions to the investors I recognize that you left the room and told them to look at it but you had to some knowledge of the case right MR SCAROLA Counsel thats a misrepresentation of what the earlier testimony was I object no proper predicate MR GOLDBERGER Okay lets go through the whole thing again MR SCAROLA No you are not going to go Page through the whole thing again Just because we have tolerated two lawyers asking questions does not mean we are going to tolerate two lawyers asking the same questions MR GOLDBERGER Your objection is noted BY MR GOLDBERGER Okay So lets talk about your need to use the Epstein case to further your conspiracy You needed an influx of money did you not A Yes Okay You decided to use the Epstein case for that purpose right A Yes And in order to use the Epstein case you were going to meet with the investors and pitch the Epstein case with the investors correct A Yes And in an effort to pitch the case to the investors you had to have some knowledge of the case did you not A Some level of knowledge yes sir Okay And in order to gain that knowledge you spoke to your co-conspirator Russell Adler is that correct A Thats one of the things I did Page Pages to FRIEDMAN LOMBARDI OLSON 7f-bcdd-ca2d8fe941 df Okay And do you remember what Adler told you specifically about the Epstein case that helped i you have a basis of information to sell it to the investors A Other than him telling me that it was a billionaire pedophile other than him telling me about the flight manifest I dont have a specific recollection of what else he told me Did you actually look at the flight manifest at sometime Mr Rothstein A Yes sir And what was it about those flight manifests that you felt would help you pitch the Epstein case to I the investor A dont remember who specifically was on it but I remember it looking juicy ii You dont know who was on it A I dont recall Did you add any names to that manifest at any time A I had you mean physically write names on there I Any way you want to interpret did you not physically write any names on the manifest but did you tell the investors that there were names on Page the manifest that were actually not on the manifest I A I told the investors that there were other people that appeared on manifests I dont recall whether it was that manifest or other manifests and I got the names of those people from Russ Adler Whether or not they actually appeared on the manifest or another manifest I do not know I What names did you get from Russ Adler A Russ Adler told rue that Bjll Clinton flew on I I Mr E12steins 12lane and that Prince Andrew flew on Mr E12steins plane And is it your testimony today that you never looked at the manifest to see whether Bill i Clinton or Prince Andrews name were really on the manifest that you were going to use to pitch the i investors I A It was my understanding they didnt have all i the manifests Okay Did you ever ask for the manifests that purportedly had the name of Bill Clinton or Prince Andrew on it A I probably did but I dont have a specific i recollection one way or the other When you say you didnt have all the manifests were all the manifests in your office Page were all the manifests within the law finn of RRA and you simply didnt have them in your office A I have no idea one way or the other Okay A I did not have them You were told by Russell Adler that you didnt have that you physically didnt have all the manifests correct A Thats correct But you dont know whether they were in the building somewhere these other supposed manifests A I have no idea one way or the other You never asked for proof that Bill Clinton or Prince Andrews name were on a manifest somewhere A I didnt say that I may very well have asked Adler or Ken Jenne to find the other manifests Were you ever shown a manifest with the name Bill Clinton or the name Prince Andrew on them A I do not recall one way or the other whether I saw that or not I remember Adler telling me about it and then me repeating that infonnation to the investors based upon Mr Adlers representations to me Now you testified that you were told that the Epstein cases were legitimate cases Do you Page remember that testimony you gave this morning A Yes And you remember your testimony that you were told they were legitimate cases by both Russ Adler and Brad Edwards do you remember that A never said that Mr Edwards or Mr Adler said Scott these are legitimate cases I didnt question them as to their legitimacy You did testify that you talked to Brad Edwards about the Epstein cases is that correct MR SCAROLA No counsel that is a misrepresentation of the earlier testimony MR GOLDBERGER No its not BY MR GOLDBERGER Did you talk to Brad Edwards about the Epstein cases A I do not recall one way or the other was my prior testimony thats still my testimony I dont I do not recall Well let the record speak A I know I spoke to Adler about it Well let the record speak for itself Your testimony as I am questioning you now is that you do not recall whether you spoke to Brad Edwards about the Epstein cases is that correct Page Pages to FRIEDMAN LOMBARDI OLSON 7f-bcdd-ca2d8fe941 df A If you are including within that me walking past Brad in the hall and saying Hey Brad how are you How is the Epstein stuff going Then its very likely that I talked to him about it in that manner But I have no specific recollection one way or the other as to having any lengthy conversations with Mr Edwards about the case I had a co-conspirator who was deeply involved in the Ponzi scheme that I could go to to get any information I wanted Mr Adler I didnt need to go to Mr Edwards So if you had a question of your co-conspirator Russell Adler about the Epstein case you would go ask Adler and would Adler always have the answer for you or would he say he would get you the I answer ii A Both When he didnt have the answer do you know I who he was getting the answer from MR SCAROLA Objection predicate i THE WITNESS I dont know who he was getting it from and I may have contacted other people in the office who were working on the file to ask I may have asked Mr Jenne I may have asked Ms Holmes I many have asked a whole myriad of people Page A She may have I dont recall one way or the other Did you ever ask Ms Holmes to use any of her prior contacts in law enforcement to assist you in the Ponzi scheme to get information for you A The question is kind of convoluted because the way you are asking it it seems like you are intimating that Ms Holmes knew I may have asked Ms Holmes to get me information that I was going to utilize with my co-conspirators in the Ponzi scheme but Ms Holmes did not know that there was a Ponzi scheme going on All right So you may have asked Ms Holmes to try and get some information for you from her contacts in law enforcement but its your testimony and I dont dispute it its your testimony that she knew nothing about the Ponzi scheme correct A I may have I may not have I do not remember and she absolutely knew nothing about the Ponzi scheme Okay Now we talked about Brad Edwards getting paid and the multilevel ways in which you determined what a persons salary was Do you know whether Brad Edwards got any bonuses along the way once the Epstein case was used as part of the Ponzi Page BY MR GOLDBERGER So Ms Holmes was working on the Epstein cases A Its my refreshed recollection from seeing one of those e-mails that she must have been Okay And Ms Holmes you said was a former federal law enforcement officer was that your testimony A Yes You dont know whether she was FBI or IRS correct A I dont remember Okay And upon reflection do you know whether she was hired without your say-so based on what Mr Jenne told you or did you meet with her A No I actually I remember meeting with Ms Holmes Okay What do you remember about that meeting A I remember talking about her relative who was a judge I remember her telling me about her time in law enforcement I just dont remember which agency Did she tell you why she left law enforcement I i I I i2s scheme A He did not So he was A If he got a bonus it was something he earned Did you make a determination as to what that bonus would be A lfhe got a bonus I would have been instrumental in determining it You can determine if he got a bonus by looking at our financial records I dont have an independent recollection one way or the other So you dont know whether he got a bonus at all correct A Thats correct So I assume that if he got a bonus you wouldnt know whether it occurred before or after the Epstein case was used as part of the Ponzi scheme A I dont know if he got a bonus which means I wouldnt know the time frame But we would learn you are instructing us we would learn that by looking at when the Epstein case was brought into the Ponzi scheme and we learn that by looking at these what was the group that it was used to pitch to Page Page FRIEDMAN LOMBARDI OLSON Pages to I A Clockwork about By the way you had a number of Epstein cases So we would look at when the Clockwork group in-house do you know which case you were talking was brought into this and the Epstein case was used about then and then we would look at the payroll records to A As I sit here today no sir I dont see whether Mr Edwards got a bonus after the remember Clockwork group was brought into the Ponzi scheme Was it a state case or a federal case correct A From a timing perspective yes But Mr Edwards had nothing to do with the Ponzi scheme nor was he rewarded even surreptitiously without his knowledge for helping me with the Ponzi scheme was rewarded it was because he deserved I felt he deserved a reward having nothing to do with the Ponzi scheme The bulk of this law firm had nothing to do with the Ponzi scheme think you testified already though that money was fundable in the firm right I mean you know illegal money was used for legitimate purposes correct A Yes Okay So for example investigations that were done with the Epstein case its very possible that legitimate Ponzi money was used to finance those i i i A I dont remember one way or the other All right A I utilized all those boxes al together dont remember which one I sold them And the exhibits A Its something completely fictitious that I made up that I told them The exhibit that you were shown earlier Exhibit Number I thats the long multi-page federal lawsuit Do you know whether that was part of the information that you reviewed or shown to the investors when you were pitching to them A I do not remember one way or the other Okay Now did you make any effort to learn from your co-conspirator who the plaintiffs were in this case what kind of women they were A Only that they were underage Did anyone tell you that these women had Its certainly possible I some of these women had a history of prostitution investigations A Id be guessing Page i Page _-cc __ c""nz because all the money went into a whole series of pots and if you look at most of the pots were trust accounts If you look back you look to see what my CFO who was also a co-conspirator was doing she was pulling the money from wherever she needed to to fund whatever she needed to fund MR LA VECCHIO Off the record a second Discussion off the record BY MR GOLDBERGER Let me circle back to what you needed to learn about the Epstein cases to help make your pitch to the investors You talked about the manifest already correct the flight manifest A Yes Okay What else did you want to learn about the case or what else did you learn about the case so that you were conversant when you spoke to the investors about the Epstein case A I recall asking someone what the causes of action were I I I i I I Lu I I il Okay Did you understand what they were i A I likely did at the time I dont remember i what they were now Okay Do you know which case we are talking i2 Page A They may have told me that.I I wouldnt have cared one way or the other Why would you not have cared about that Mr Rothstein A It had nothing to do with the sale of the Ponzi scheme settlements Okay Were you told by anyone whether any of the women involved as plaintiffs in the case may have worked at adult clubs in the past I mean strip clubs lets call it what it is A I may have been told that one way or the other But again it had nothing to do with the Ponzi scheme sale of fake settlements As part of the information that you were told by you co-conspirator Russell Adler were you told that some of the plaintiffs that you had in-house had travelled on Mr Epsteins airplane A I believe Russ did tell me that You know in fact that that was not true correct A I have no idea one way or the other nor did I care But your co-conspirator told you that right A Mr Adler did in fact tell me that certain Page Pages to FRIEDMAN LOMBARDI OLSON 7f-bcdd-ca2d8fe941 df I of the underage women had travelled on Mr E12steins i plane I Did you ever meet any of the plaintiffs MR SCAROLA Thats question thats been asked and answered I THE W1TNESS do not have a specific recollection of ever meeting them MR SCAROLA You are exhausting my indulgence i MR GOLDBERGER Fair enough I MR SCAROLA Youve exhausted my indulgence BY MR GOLDBERGER Do you know whether any of your investigators at the firm had any kind of high tech surveillance equipment or you know wire tapping equipment A believe they did Do you know whether this was legal stuff or illegal staff A I did not know nor did I care Do you know if any of that stuff was used to either wire tap or surveil Mr Epstein A I do not know one way or the other What sort of equipment did you know that Page i they had meaning your investigators A I had told Mr Jenne and others involved in the investigation arm of RRA to get whatever equipment they thought they needed and to get the best stuff that they could get What they actually did I cant tell you You know as part of the Epstein litigation and Im talking about now after your using it in the Ponzi scheme do you know whether anyone at your firm attempted to depose ex-President Bill Clinton A I dont recall that sir Okay How about Donald Trump same question A I dont recall that As a matter of fact we had represented Trump in some things we had some pretty close ties with him so I cant imagine that they would have done that with my authority Okay A I dont recall that Do you know whether Adler would have would Adler have the authorize to do that without getting your permission A The authority no Might he have tried I I I I i I yes Okay How about Alan Dershowitz do you Page have any knowledge of your firms attempt during the Ponzi scheme to depose Alan Dershowitz A No sir I dont have a recollection of one way or the other Okay The name Kendall Coffey was brought up before Do you know who Kendall Coffey is A Yes Who do you know him to be A Former U.S attorney current criminal defense lawyer Was he a friendship of the firms A Represented RRA when I fled the country So he was a friend of the firm or a friend of yours at least right A He wasnt a friend of mine A friend of the firm A No idea He represented them when I fled the country I remember him coming in and doing like a show and tell in my office on TY MR GOLDBERGER Patience gets rewarded Im done Thank you Mr Rothstein Thats all the questions that I have THE WlTNESS You are welcome CROSS EXAMINATION BY MR SCAROLA Page Mr Rothstein again Jack Scarola on behalf of Brad Edwards I want you to assume that Brad has testified under oath that you never had a substantive discussion with him regarding the Epstein case Do you have any basis whatsoever to question the accuracy of that testimon;f A I do not I want you to assume that Brad has or will testify under oath that while you were co12ied on e-mails you never attended a single legitimate meeting regarding the legitimate prosecution oft Epstein cases Do you have any basis whatsoever to question the accuracy of that testimonz A No sir I want you to assume that Brad has or will testify under oath that you never directed the hling of any documents in the Epstein case including the July federal complaint thats been marked as an exhibit to your deposition Do you have any reason whatsoever to question the accuracy of that testimony A No sir I want you to assume that Brad has or will testify nder oath that you never directed the taking Page Pages to FRlEDMAN LOMBARDI OLSON 7f-bcdd-ca2d8fe941 df of a single deposition or the propounding of an discovery in the Epstein cases Do you have an reason to doubt the accuracy of that testirnon A No sir I want you to assume that Brad has or will testify that you did not provide any input whatsoever into the handling of the legitimate Epstein cases Do you have any reason whatsoever to doubt the accuracy of that testimony A sir I want you to assume that Brad has or will testify that you never met any of the legitimate plaintiffs in the Epstein cases Do you have an reason to doubt the accuracy of that testimoey A MS HADDAD Im going to object to these same questions you keep asking because Mr Rothstein has testified at nauseam that he doesnt recall any of this and now you are asking him to bolster Mr Edwards either already given or purported testimony when hes testified he doesnt recall it BY MR SCAROLA I want you to assume that Brad has or will i testify under oath that you never asked him once to report back to you on any factual matters regardin,g_ Page the Epstein case Qo you have any reason to doubt the accuracy of that testimony A I want you to assume that Brad has testified repeatedly that he had absolutely no involvement in or knowledge of any illegal activi!Y engaged in by you or any other RRA la er Do you have any reason to doubt the accuracy of that testimony A sir I want to talk to you briefly about your personal perce12tions of the si!!ificance of the testimony that you are giving today If Brad Edwards had in fact been a participant in any of the illegal i activities that you have been questioned about at any stage of this ve!:Y leng!hY deuo ition and you knowingly concealed Brad Edwards m1rtjs;jgation what do you understand the gersonal consequences to be as a conseguence of your having knowingly concealed Brad Edwards participation A Ill be violating my aB!:eement with the United States government and I would run the risk of dying in prison I If Brad Edwards contrary to what you have II testified under oath and what Brad himself has repeatedly said knew about anY!hing having to do with i Page li jllegal activities at the RRA firm and you concealed your knowledge of Brad Edwards knowledge of that illegal activity what do you understand the consequences of that false testimony to be A Ill be violating my agreement with the United States government and I would run the rjsk of dying in prison MR SCAROLA Thank you I dont have any further questions THE WITNESS Thank you sir MR NURIK Mark I dont know what your time frame is on your litigation but the ability to receive the transcript review it and prepare an errata sheet within what is normally the time allotted under the court rules cannot be accomplished in this case MR GOLDBERGER How much time are you generally MR NURIK dont know Actually the first set of errata sheets have just been prepared and finalized for the first deposition in December Im not suggesting it will take that long this time but if you can give me an idea of what your time responsibilities are with the court what the time limits are Page MR GOLDBERGER Do you think it will be less than a month two months MR NURIK I dont think it will be less than a month First of all a lot depends on the ability to get the transcript to him to review MR GOLDBERGER Right MR NURJK And thats a whole procedure its not normal circumstances that we are dealing with MR GOLDBERGER If time becomes an issue well approach you and ask you to expedite MR SCAROLA Mark I will tell that from our perspective time is an issue MR NURJK Have at it then Jack Do what you need to do to get it done MR SCAROLA There is a long pending motion for summary judgment on Brads behalf that has been delayed for purposes of taking this deposition We are very anxious to be able to call that motion for summary judgment up for hearing so whatever can be done reasonably to expedite the preparation of this portion of this transcript would be appreciated We understand there are limitations beyond your control but to the extent you can do it that would be helpful Thank you Page Pages to FRIEDMAN LOMBARDI OLSON 7f-bcdd-ca2d8fe941 df MS HADDAD Its scheduled in a month Mark MR NURIK Well cooperate MR SCAROLA Thank you very much Thereupon the taking of the deposition was concluded at p.m SCOTT ROTHSTEIN Sworn to and subscribed before me this day of Notary Public State of Florida at Large FRIEDMAN LOMBARDI OLSON Suite Biscayne Building West Flagler Street Miami Florida Telephone June IN RE EPSTEIN VS EDWARDS SCOTT C/O MARC NURIK One East Broward Boulevard Seventh Floor Fl Lauderdale Florida Dear SCOTT ROTHSTEIN With reference to the deposition of yourself taken on June in connection 1th the above-captioned case please be advised that the transcript of the deposition has been completed and is awaiting signature Please arrange stop by our office for the purpose of reading and signing the deposition Our office hours are a.m to pm Monday through Friday Please telephone in advance You may however read a copy of the transcript provided by any of the attorneys connected with the case denoting any corrections by page and line number on a separate sheet of paper This correc1ion page must be signed by you and no1arized and relumed lo us for filing with the original If this has not been taken care of however within the next days or by the time of lnal whichever comes first I shall then conclude that the reading subscribing and notice of filing have been waived and shall then proceed to deliver lhe original of the lranscript lo ordering attorney v.i1hou1 fur1her notice Pearlyck Manin Page Page Jr CERTIFICATE ST A TE OF FLORIDA COUNTY OF MIAMI-DADE I Pearlyck Manin a Notary Public in and for the Stale ofFlorida at Large do hereby cenify that pursuant lo a Notice of Taking Deposition in the above-entitled cause SCOTT ROTHSTEIN was by me first duly cautioned and sworn to testify the whole truth and upon being carefully examined testified as is hereinabove shown and the testimony of said witness was reduced to typewriting under my personal supervision and thal the said Video Conference deposition constitutes a true record of the 1es1imony given by the witness I funher cenifv that the said Video Conference depositi was 1aken al the time and place specified hereinabove and that I am neither of counsel nor solicitor to either of the panies in said suit nor interested in the event of the cause WITNESS mv hand and official seal in the City of Miami Co ty of Dade State of Florida this day of June Pearlyck Manin Page FRIEDMAN LOMBARDI OLSON Pages to df
