Onn BWP
know this is a real case? So] was finally able to
say this is how you know, here is a case file. ] may have, ] don't remember specifically one way or the
other, but ] may have utilized actual plaintiff names
from the cases filed, but ] may have made them up. ] have no specific recollection one way or the other, ] was totally geared toward simply getting the investor
money into the Ponzi scheme.
Q. Were you aware that the day after this meeting took place on July 24th, 2009, a new federal complaint was filed against Epstein with one of the
same plaintiffs that was already pending in state court?
A. ] don't know that | was aware of that or not. If they were filing it, someone may have told me. | don't recall one way or the other.
Q. Did you ask anyone to file it to further your Ponzi scheme?
A. No, 1 don't remember doing that,
Q. Do you recall any situation where you --
A. You do realize -- Tonja, hang on] just want to make sure this record is clear. Other than
Russ Adler, the people that were involved in the Epstein case had absolutely nothing to do with the
Ponzi scheme.
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A. Hold on one second. Okay. What number am I looking at? Q. It's a very large document. It's begins with Bates Stamp Number 081 and ends with 264. A. It's in the computer, hold on a second. ] have that in front of me. Q. Do you see the date on that complaint stamped? A. Ido. Q. And there's -- give me one second, Scott, sorry. What was the date that complaint was filed? A. What's the last page of the complaint, what's the Bates number? Q. The last page is 234. I'm sorry, 263 would be the last page of the complaint. [The Complaint referred to was marked for identification as Defendant's Exhibit 1.] MR. SCAROLA: You may want to call his attention to the filing stamp on the first page. MS. HADDAD: | did. 1 guess he didn't hear me. THE WITNESS: I'm sorry. MS. HADDAD: It's stamped on the first page. Page 64
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Q. Directly?
A. _Orindirectly. They had nothing to do with
it.
“OQ, Yet the file was used for you to further your Ponzi scheme. ]'m not saying that they gave it to you to use for the Ponzi scheme, I'm asking, you used their case. I'm not -- the question is you used
the case?
A. took advantage of some good, innecent
people for my own and my ¢o- conspirators yeah purposes. Mr. Edwards is one of them, and for that ]
sorry, Brad, Q. Did you ask anyone involved in the Epstein case to file a federal complaint? MR. SCAROLA: Objection, repetitious. THE WITNESS: Without seeing a document, Tonja, I can't tell you one way or the other. ] don't want to -- ] do not want to guess. If you have an e-mail where I'm saying to someone, file a federal case, then obviously I did. But I have no specific recollection of that. BY MS. HADDAD: Q. You do have a document with you, it's marked for you, it's Bates stamped. It begins at EP 081 and goes through through 264.
Page 63
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24
THE WITNESS: Hang on, the complaint is dated July 24th, 2009. It was entered onto the docket on July 27th, 2009.
MR. SCAROLA: Do you have another question?
MS. HADDAD: ] thought he was still looking.
Scott, are you done looking?
THE WITNESS: Yes, one second.
MS. HADDAD: That's what J thought.
THE WITNESS: No, hang on one second. It shows the stamp on the first page says July 24th, 2009. The filing say electronically filed July 24th, 2009. There's an entry onto the docket on July 27, 2009, and the complaint is signed July 24th, 2009. That's all the dates ] have.
BY MS. HADDAD:
Q. Okay. And back on Bates Stamp Page Number 263, who's the attorney that filed this complaint?
A. | don't know if that's his signature, but the name is Brad Edwards.
Q. Okay. And does that e-mail --
A. With the squiggle on top of it.
Q. And does that e-mail address Jook like the correct e-mail address for RRA?
A. Itis.
Q. So that is, in fact, a legitimate e-mail
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17 (Pages 62 to 65)
FRIEDMAN, LOMBARDI & OLSON
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