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1 of 2009 about the Epstein meeting and some additional
2 investigation into the Epstein case.
3 Does that refresh your investigation as to
4 when you met with the investors in the
5 Discala/Clockwork Group?
6 A. It does not. The best thing to refresh my
7 recollection as to when I met with them would be to
8 see the deal documents.
9 Q. Okay. I unfortunately don't have those.
10 Do you recall if you took Discala and his
11 other investors to a football game in 2009?
12 A. Sure, I did.
13 Q. Okay. Would that be around the time you
14 were trying to get them to invest in the case?
15 A. It would have been around the time I was
16 trying to get them to invest in general. It's may
17 have been around the time that I was showing them the
18 Epstein file.
19 Q. Did you show them any files other than the
20 Epstein file?
21 A. I may have. I don't have a specific
22 recollection one way or the other.
23 Q. You testified earlier that you had over a
24 dozen boxes brought to your office that were related
25 to the Epstein case.
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1 MR. SCAROLA: Excuse me, counsel. Counsel,
2 there has been no such testimony.
3 BY MS. HADDAD:
4 Q. You said there were several boxes brought to
5 your office by different people. You don't recall who
6 that is; is that correct?
7 A. Yes, I had some boxes already in my office
8 and I had Ken Jenne and some other people bring some
9 others. I don't remember how many boxes.
10 Q. Was it more than three?
11 A. Sure, it was more than three boxes, yes.
12 Q. Was it more than 10?
13 A. I don't believe so, no.
14 Q. You stated that you looked -- I don't want
15 to put words in your mouth. What did you look at
16 specifically in that case?
17 A. Other than looking at the flight manifest
18 that Russ Adler told me to look at, I have no specific
19 recollection as to what I looked at in that file.
20 Q. Do you know if there was more than one case
21 being prosecuted by your office against Mr. Epstein?
22 A. To the best of my recollection there were --
23 it was multiple plaintiffs.
24 Q. Okay. Do you recall if those cases were
25 pending in state or federal court?
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1 A. I don't recall.
2 Q. Did you check?
3 A. I don't remember one way or the other. It
4 was insignificant to me.
5 Q. Well, then explain to me. You testified
6 earlier that what was important to the investors to
7 see is that there was a real case, correct?
8 A. Yes.
9 Q. What did you look at or show them -- what
10 did you look at, first of all, to see if it was, in
11 fact, a real case?
12 A. I knew it was a real case.
13 Q. How did you know?
14 A. Because my lawyers told me it was a real
15 case. I believed them.
16 Q. What lawyers told you that?
17 A. I already told you it was a mixture of Russ
18 and Jaffe and Fistos and Farmer and Mr. Edwards. I
19 mean, I knew it was a real case. We had all these
20 boxes, we had people really working on the file --
21 Q. How do you know --
22 A. -- or they were pulling a hell of a scam on
23 me. Not that I didn't deserve it but ...
24 Q. How did you know, you just said you knew
25 people were working really hard on this case. Who do
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1 you know was working on the case?
2 A. The only people that I knew for certain were
3 working on the case was Brad Edwards and Russ Adler
4 was doing his supervisory schtick, whatever that was.
5 But other than that, I don't know which other lawyers
6 were assisting Mr. Edwards. I didn't get involved at
7 that level.
8 As far as the Ponzi scheme goes, the only
9 thing I cared about, Tonja, was being able to show the
10 investors that this case that I was utilizing to steal
11 a significant amount of money from them was a real
12 case. That's all I cared about.
13 Q. That case came into your office through
14 Mr. Edwards, correct? He brought it with him when he
15 came to RRA?
16 A. Yes.
17 Q. He was lead counsel on the case, correct?
18 A. I assume he was lead counsel. I never
19 checked to see if he listed himself as lead counsel.
20 Q. Do you know if any additional complaints
21 were filed while the case was at RRA?
22 A. I have no idea one way or the other.
23 Q. Did you ever instruct, in furtherance of
24 your Ponzi scheme, Mr. Edwards or anyone in that
25 litigation group to file additional complaints?
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