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INO, Who is Cara Holmes? Who is who? Cara or Cara, C-a-r-a, Holmes? To the best of my recollection, she was a former FB] agent or maybe IRS agent. 1 don't know. She was a former federal agent. Q. Did you hire her to work for you? A. It was either IRS or FBI. Q. Did you hire her to work for you? A. Yes, ] hired her at the suggestion of Ken
POPO >
Q. For what purpose?
A. To work in the group that he was overseeing.
Q. So what did she do for RRA while she was there?
A. 1 don't remember.
Q. Did you ever mention her to your potential investors from the Clockwork group?
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case or any communications --
] may have.
Do you recall when that --
] may have.
Do you recal] when that may have happened?
] do not.
Do you recall the first time you looked at
the flight manifest to which you referenced earlier? A. Prior to the investors coming in. ] don't
remember the date.
Q. Did you instruct anybody, to further your Ponzi scheme, to investigate or check into anyone whose name was listed on the flight manifest?
A. I may have, but with this clarification. If
| instructed someone to look into something, } did it without that person knowing that J was involved in a Ponzi scheme or that what they were doing was illegal and it was just to get me additional information to _ help with my sale of the fake settlements.
20 POPOS
A. It's a possibility because, as ] was 2 Q. So it was to further your -- building the Ponzi scheme, | frequently referred to 2 A. So] may have asked someone -- ] may have the fact that we had former state and federal law 2 asked someone to get me some additional information, enforcement working for us and on our investigative | 2 but as ] sit here today, ] don't recall ever asking teams. It added legitimacy to-the Ponzi scheme. 2 anyone to do anything on the file that was for the Q. Didn't you tell investors that she could 2 purpose of furthering the Ponzi scheme, other than Pa gs = 4 Page 56
hack into a computer as part of her skills?
A. I certainly may have. | told the investors a whole host of lies about what was going on about with case and what people could do and did do.
Q. Did you ever personally utilize Cara Holmes' skills in any of your cases?
A. | don’t remember.
Q. Were you handling any cases during the 2009?
A. 1 was overseeing cases in 2009, but my involvement was mostly supervisory. | was handling very little that was legitimate at that point in time.
Q. Were you legitimately, when I say "legitimately," were you invited into Q-task on any particular cases that you can recall?
A. |'mcertain ] was. | don't recall one way or the other.
Q. Do you recall if you were involved in Mr. Epstein's case on Q-task?
A. I may very well have been, but } don't have a specific recollection one way or the other.
Q. Do you know who invited you in?
A. J have no idea if 1] was invited in. And if I was invited in, ] have no idea who invited me.
Q. Once you decided to use this case in your Ponzi scheme, did you go into Q-task to look at the
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perhaps getting me a piece of information that ] needed. Q. I'm going to try to refresh your recollection as to whether or not you attended those meeting in July of 2009. And it appears that in between the dates of July 22nd, 2009 and July 24th, 2009, there was a number of communications through e-mail] by and between yourself, Mr. Adler, Brad Edwards and Ken Jenne regarding an Epstein meeting that was going to be taking place. Do you remember that at all?
A. | think what you are referring to, and I'm not certain, but | think that what you are referring to is me making sure that the file was in the condition in which | wanted it at the time the investors were coming in. | don't think it had anything to do with the actual functioning of the Epstein case. | think it had to do with my illegitimate purpose. That's the best of my reco]lection, but if you have documents or something that you can show me, that would be helpful.
Q. We are not privy to all of the e-mails because they've been alleged as privileged or work product, so ] unfortunately can't show them to you.
But according to the privilege log between Page 57
15 (Pages 54 to 57)
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