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Q. You didn't keep track of it?
A. J did not keep track of it. From time to
time Russ and the other guys in the tort group would
tell me what was going on in certain cases, but until
I made a decision to utilize that file for an illegal
purpose related to something illegal that ] was doing
along with my co-conspirators, | just assumed my
Jawyers were going to work the case and eventually it
would hopefully work out well for the law firm.
Q. At your firm, when e-mails would go out to
attorneys at RRA or all attorneys at RRA, were you
part of that e-mail group?
. You are talking about all staff?
. No, all it says is attorneys at RRA.
It's the e-mail group "attorneys"?
Yes.
Yes, I'm a part of that e-mail group.
And ] appreciate that you were very busy and
may t not have read all of them, but you did receive
those e-mails when they would go around?
A. Yes, and 1 tried my best to read them.
Q. Okay. At what point did you decide to use
this case to further your Ponzi scheme?
A. 1 don't remember the date, but I can give
you the circumstances, if you'd like.
Page 223
Q. Please do.
A. The Ponzi scheme was running very low on
capital. My co-conspirators and ] needed to find a
new feeder fund, new investment sources. We had a
couple of very large, significantly wealthy potential
investors out there. I was looking for something that
would have been very attractive. We had had a lot of
inquiry during the due diligence period with these
people that were doing due diligence on the putative
cases that we were selling. And when | thought about
the Epstein case, realizing that it was a substantial
actual file in the “office, I came up with the idea
that if ] created a fake confidential settlement
circling around -- based upon this actual case, they
would be able to increase the level of due diligence
that I was able to offer to my potential investors.
Q. How did you know this was a substantial file
in your office at that time?
A. Again, through the people J spoke to in the
office.
Q. Such as who?
A. Again, same people, Adler, Farmer, Jaffe,
Fistos.
Q. You never spoke to Brad about this case?
A. I didn't say that, but J had a Jot more
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interaction --
Sorry, Tonja, | didn't mean to speak over
you.
If you talk to the people in the firm, if
they are honest with you, they'll tell you my
interaction was far more significant with Russ Adler,
probably more so because he was a co- he was a co-conspirator of of
mine, My interaction with Russ was | Russ was far greater b greater by
many, many percents over my interaction with Brad, and
then you go down the line. ] had more interaction
with Mr. Farmer than I did with Mr. Fistos, more
interaction with Jaffe than ] did with Mr. Edwards,
and so on.
Q. Russ was the head of your tort group, right?
A. Yes.
Q. So these cases fel] under the tort group; is
that correct?
A. Yes, it fell under the -- fel] under Russ’
purview ultimately, yes.
Q. And Brad was a partner at your firm during
the time these cases were there, correct?
A. ] believe that was his title. He was either
partner or shareholder. J] don't think we had made him
a shareholder yet.
Q. But he wasn't coming in as an associate,
Page 24
correct?
A. To the best of my recollection, no.
Q. So you stated that you learned this case
was -- ] don't want to misquote you and listen to a
long speaking objection, but what did you call this
case?
MR. SCAROLA: Who wants the quote?
THE WITNESS: It was a substantial case
with a -- what | perceived to be a highly collectible
pedophile as a defendant.
BY MS. HADDAD:
Q. Right. How did you know at the time when
you said these investors wanted to investigate and you
said you were going to create a fake settlement, how
did you know that this case was the case that you
could use?
A. From talking to all the people that I just
said, Adler, Fistos, Jaffe, Farmer, Mr. Edwards, to
the extent that ] spoke to him about it.
Q. Did you speak with Mr. Edwards about the
case?
a: 1 GON NSPE ac pesinocrceollection one Way
or the other. ] remember speaking to him at least
briefly the day or the day of or the day before the
actual investor's due diligence was going on as to
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