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boxes with real pleadings in it and a Jot of other information in it. The fact that there was real money
to you? A. Because of who was on it. Q. Who was on it? A. J] don't recall, but ] do recall saying to the investors -- ] 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. And ] don't remember whether that was on any of the flight
manifests or not, but ] 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 Jet them Jook at the file.
You have to understand from an investor's perspective -- hang on. From an investor's
perspective the only thing that matters to the
investor is that it's a real case and that they can
verify that real dollars are being paid. The fact
that it was a real case was evident, I had a lot of
being paid was a fiction that was created by me and my
co-conspirators, everyone from bankers, to computer people. So the actual role of the case, and ] want to
Page 423
ee ee eee
make sure you understand this, the actual role of the
actual physical case in the Ponzi scheme is, from my perspective, minimal. It was just another vehicle for
me, “OQ. 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. I'm going to object to the form of the question, it assumes facts not in evidence. There's 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:
Q. Was your video surveillance on when you left the investors alone in your office?
A. No, no, ] didn't have cameras in my office. I didn't let people look in my office when I] was in there, that would have been bad.
Q. So you Jeft them alone in there?
A. Yes.
Q. Do you recall for approximately how long?
A. No more than 20, 30 minutes. It was a short
period of time, Q. When you went back in what happened?
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A. I went back to selling the Ponzi deal. Q. And did you sell it?
A. | believe] did. You'd have to look at the actual settlement documents to see if ] put one together for that, but J'm pretty sure we did.
Q. Do you recall if the investors asked you for any additional information or any additional documentation?
A. | don't recall one way or the other.
Q. After this initial meeting with the investors, did you give any direction regarding this
particular case?
A. To whom?
Q. To any of the attorneys working on the Epstein case.
A. No. | didn't interfere in how they were running their cases. They were far more experienced
than J was in that type -- in handling that type of fase, As a matter of fact, ] was practicing very little real Jaw at this point in time. ] wouldn't have had time to tell them or to get involved. ~~ Q. Did you ever keep up with this case ; Pp up with this case after this initial meeting with the investors?
A. I'm certain that IJ talked to Russ im certain that J talked to Russ Adler
about it from time to time, but my main focu time, but my main focus by this page 44 point in time in 2009 was the Ponzi scheme, Q. Did you try to sell this particular settlement to any other investors? A. 1 don't recall one way or the other.
Q. Okay. Did you ever have any conversations with any of your investors about this Epstein case? A. 1 don't recall one way or the other.
Q. I notice there's been a privilege Jog 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 don't. As] sit here today, ] don't have a specific recollection of having significant e-mail contact with Ken Jenne about the case. But if you are telling me I did, I'l] accept that, but ] don't recall what it was.
Q. Earlier you had stated that when you were hiring good attorneys such as Mr. Edwards, looking at their book of business was --] don't want to pul.
words in your mouth -- it was the legitimacy of the
practice, it would bring in legitimate money to the Practice, is that what you were hoping to do? A. Earlier when I testified | specifically
testified that J personally did not look at most of
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