arnvrnauw & WN eH
NNONNNNE EEE eee eee OP WHR TOwO WMWAIHD UU BWNHEFR OW
Anr7AnDU BP WNE
NNNNNPRPEPRPEP EHP EB DBWONF OW MAID UO BWHP OW
25
BY MS. HADDAD: Q. OrIRS. We'll use the blanket term federal agent. Is that a fair assessment?
A. Yes. Q. Thank you. Do you recall when you hired her to work for you? A. 1] do not.
Q. Was it in 2009?
A. I don't have a recollection one way or the other.
Q. Okay. Have you ever seen this e-mail before?
A. I saw it when] was reviewing your exhibits. Before that ] have no independent recollection of having seen it. I'm not copied on it so ...
Q. Did you ever have any communications with Ms. Holmes about people that were close to Mr. Epstein?
A. J do not remember.
Q. You stated earlier that you knew that Mr. Epstein was a wealthy man. |s that a fair statement? You called him "collectible," was that because he had money?
‘MR. SCAROLA: He called him a billionaire Page 70
too.
MS. HADDAD: Billionaire. THE WITNESS: I knew he was a billionaire. BY MS. HADDAD:
Q. Do you have any independent recollection in the month of July 2009 of this case being intensified in any way such as going after those close to Mr. Epstein?
A. J don't remember that one way or the other.
Q. If you knew that Mr. Epstein was a billionaire, do you have any recollection of asking someone to investigate those close to Mr. Epstein to further your Ponzi scheme?
A. I don't have an independent recollection of that one way or the other.
Q. Do you recall if you ever directed the depositions to be taken of the people who were listed on the flight manifest that you saw?
A. I don't recall one way or the other. ] may have told the investors that I was going to take the depositions without ever intending to take them, but | don't recall one way or the other.
Q. Are you familiar with a gentleman by the name of Mr. Rodriguez, Alfredo Rodriguez?
A. No.
Page 71
ea eng ROLES US SCN EN PND ae MPT A TN SA STEER
MM NYONMNYNHHPKBE FRPP HE RB eH
SE car Car carat Car coriarmareamne satire anys eae tal NMNNNMDNMNDNYF RPE PRE BRP
Own WnrOrF Oo MAID UB WNP OW DAHA U Ss WH E-H
Scipio sautiamasanatate nate
OBWNHF OW MIRHAUDBDWNHRFP OU WAHAB WNH
Never heard that name before?
Alfredo Rodriguez?
Yes.
It's not ringing any bells to me.
Do you remember hearing at your office with respect to Mr. Epstein’s case that one of his former employees was willing to come forward with a big book of names?
A. ] don't remember that one way or the other.
Q. You have no recollection of that.
Do you recall anyone approaching to ask if the office can purchase this book?
A. | don't recall that.
Q. Do you recal) mstructing any of the attorneys in your office to get an opinion from Kendall Coffey whether or not they can legally and legitimately purchase this book?
A. J don't recall that one way or the other.
[The Complaint referred to was marked for identification as Defendant's Exhibit 3.]
BY MS. HADDAD:
Q. Okay. I'm going to direct your attention to what's now Bates stamped as EP 002, which I'm sure you haven't seen before since you just said you didn't know who he was, but I'l] give you a minute to look Page 72
OPOPD
over it.
A. This is rather long. Do you want to direct me to a specific portion of it?
Q. Sure. If you look at the Page Bates Stamp EP 004, Paragraph 5 and 6.
A. Okay. ] read number five.
Q. Would you please read number six as wel]?
A. Okay.
Q. Does this refresh your memory as to whether or not anyone ever asked you in your office about purchasing a book?
A. It does not.
Q. Do you know that the cooperating witness was an attorney who worked for you at your firm?
A. I] did not know that until you just said it right now.
Q. According to Paragraph Number 5, "The deposition of this Mr. Rodriguez occurred on July 27th, 2009;" is that correct?
MR. SCAROLA: |s it correct that that's what it says? I'm going to object to the form of the question, it's vague and ambiguous.
BY MS. HADDAD:
Q. That's what's listed in the federal complaint, correct?
Page 73
19 (Pages 70 to 73)
FRIEDMAN, LOMBARDI & OLSON
305-371-6677
5ed93085-0554-447f-bcdd-ca2d8fe941df
HOUSE_OVERSIGHT_017508