unrelated to this case, documents related to the
settlements. Other than proving the existence of the
. ; : case, there's very little an investor, at least from my end, investigates into the actual case. It was
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.
Q. 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. 1 did two main things. One, | put the boxes
in my office while they were there. ] told them to specifically look at a couple of sheets of a flight
manifest that was in the file that Russ had shown me. And ] told them that it would be a breach of
attorney/client privilege 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
that's what I did. I stepped out, ] let them look at whatever they wanted to Jook at. 1 came back in, they were satisfied that it was areal case and ] was off
and running,
Q. And these were the real legitimate files for Page 40
eA Ea
A. | talked to Russ Adler. ] may have talked to some of the other Jawyers._] flipped through certain boxes in the file.
Q. How did you get the boxes?
A. lj asked someone to bring them to me.
Q. Do you know where those files were stored?
A. | do not.
Q. So you flipped -- sorry, please continue. Flipped through some files?
A. 1 flipped through some files. 1] had the
files in my office. The day that the investor group came in, 1 actually had Ken Jenne and some others actually bring me some more of the boxes actually into my office while the investors were there. J already
had some of the boxes with me.
Q. You say "Ken Jenne and others,” who were the others to whom you are referencing?
A. | don't specifically recall who carried them in. 1 was very focused on my investors at that time.
Q. Were any of the lawyers present with you
when you were meeting with these investors? A. During the actual meeting with them, no. |]
recall that some of the Jawyers may have met some of the investors, but ] don't recal] who. Q. Do you recall approximately when that
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Page 38:
happened?
A. No, it's the same dates that ] was giving you before.
Q. 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 ] told the investors was all things that ] was creating as ] went.
Q. 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 --
Q. Please tell me then.
A. ]'m telling you -- hang on. From an investor's standpoint, the investor is simply lookin for is the case believable. And once they get past that, is it of such case -- excuse me, is it of sucha nature 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 settlements. money, that the documents pass -- the documents Q. Why was the flight manifest so interesting Page 39 : Page 41
this case; is that correct?
A. These were the legitimate files, yes.
Q. Nothing had been created at this time for them to look through?
A. |] didn't add anything to the case files. The case files were significant enough by themselves.
Q. Do you know how long they were in your office; days, weeks?
A. The people or the boxes?
Q. The boxes.
A. The boxes were in there probably a little more than a week. | don't have a specific recollection.
Q. Okay. Did you ever go through them?
A. Yes, ! flipped through them at some point in time.
Q. And what do you recall about what you saw in the cases? Do you remember anything?
A. J remember seeing the flight manifest. ] don't recall seeing anything else. I'm sure ] looked
at other things, but again, for my purposes it was insignificant to me because the actual content of the
boxes was not necessary in the sale of the fake
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