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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 | could to garner significant political power.
Q. J] think many people miss your parties.
But, with respect to Mr. Jenne and his politica] 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. | don't want -- again, | don't want to put words in your mouth. You said you had dealings going on with various police agencies?
A. I had -- ] mean, we had a criminal defense section in the Jaw firm, so we had legitimate dealings with law enforcement. But ] also had significant illegitimate things with law enforcement that had nothing to do with Ken Jenne.
Q. 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 firm.
Q. In what role was that?
A. The investigative roles and the alcoho]
beverage roles and anything else Ken or other staff could think of to have them do.
Q. Let's talk about the investigative roles for a minute.
What kind of investigations were these teams running?
A. I] donot know. You have to speak to lawyers that were actually utilizing them. ] 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.
Q. 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 Jaw firm and have the clients at least defray some of the cost. ] don't recall whether or not we ever got to that level or not.
Q. With all that in-house police action, why did you have police security surrounding you all] the time?
A. J guess the best answer was I was paranoid, but 1 mean -- that's the simple answer to it. You
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know, having -- there were mixed reasons. For example, ] -- are you talking about my Fort Lauderdale police detail?
Q. Yes. You had it at the office and at your home, correct?
A. Yeah. There's a myriad of facts that motivated me to do that. One was that ] 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 firm and shook me terribly. 1 didn't 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 of reasons.
] mean, I hired certain Jaw enforcement to work for me that were just friends of mine that were -- that needed additional money, so 1 wanted to make sure that they had money, both guys that did the illegal stuff for me and guys that didn't do anything illegal for me.
Q. Let's 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 36
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these investors were coming that you decided to use the files?
A. My best recollection it was_in 2009, sometimes after April of 2009, but ] don't have a specific recollection beyond that.
Q. What makes you think it was after April of 2009?
A. Because, to the best of my recollection, the Clockwork Group came in towards the middle of 2009. When I say Clockwork, that's an umbrella term that ] use to mean the Von Allmen, AJ Discala, and other investors that came in through that feeder fund.
Q. So that was around April 2009?
A. No, it was after, to the best of my recollection. ] 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 60 days prior to that would have been when ] was meeting with those due diligence people, 30 to 60 days before that,
Q. So when you decided to use that case, take me through exactly what you did to familiarize
yourself with that case. Page 37
10 (Pages 34 to 37)
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