IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff, VS. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendant, / NOTICE OF FILING TRANSCRIPT IN SUPPLEMENTAL SUPPORT OF BRADLEY EDWARDS' MOTION FOR SUMMARY JUDGMENT Defendant/Counterplaintiff, BRADLEY J. EDWARDS, by and through his undersigned attorneys, hereby gives notice of the filing of the transcript of the deposition of Scott Rothstein taken on June 14, 2012. Specific portions of the deposition on which Mr. Edwards’ relies in support of his motion for summary judgment are highlighted. IT HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by eq Jb U.S. Mail to all counsel on the attached list day of June, 2012. y, JACK SCAROLA Florida Bar No 169440 bss arey Denney Scarola Barnhart & Shipley, P.A. 9 Palm Beach Lakes Boulevard West Palm Beach, Florida 33409 Phone: (561) 686-6300 Fax: (561) 383-9451 Attorneys for Bradley J. Edwards HOUSE_OVERSIGHT_017488

Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG Notice of Filing Transcript In Supplemental Support of Bradley Edwards' Motion for Summary Judgment Page 2 of 2 COUNSEL LIST Bradley J. Edwards, Esquire Farmer, Jaffe, Weissing, Edwards, Fistos 425 North Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 Phone: (954) 524-2820 Fax: (954) 524-2822 Jack A. Goldberger, Esquire Atterbury, Goldberger & Weiss, P.A. 250 Australian Avenue South, Suite 1400 West Palm Beach, FL 33401 Phone: (561) 659-8300 Fax: (561) 835-8691 Marc S. Nurik, Esquire One E Broward Blvd., Suite 700 Fort Lauderdale, FL 33301 Phone: (954) 745-5849 Fax: (954) 745-3556 Tonja Haddad Coleman, Esquire Law Offices of Tonja Haddad, P.A. 524 S Andrews Avenue, Suite 200N Fort Lauderdale, FL 33301 Phone: (954) 467-1223 Fax: (954) 337-3716 Lilly Ann Sanchez, Esquire The L-S Law Firm 1441 Brickell Avenue, 15th Floor Miami, FL 33131 Phone: (305) 503-5503 Fax: (305) 503-6801 HOUSE_OVERSIGHT_017489

Page 1 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA GENERAL JURISDICTION DIVISION JEFFREY EPSTEIN, VS « Plaintiff, No. 502009CA040800XXXXMBAG SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants. 900 East Broward Boulevard, Ft. Lauderdale, Florida Thursday, June 14, 2012 9:14 a.m. - 12:37 p.m. DEPOSITION Of SCOTT ROTHSTEIN (Via Video Conference) Taken on behalf of the Trustee pursuant to a notice of taking deposition FRIEDMAN, LOMBARDI & OLSON 305-371-6677 5ed93085-0554-4477-bcdd-ca2d8fe941 df HOUSE_OVERSIGHT_017490

ATTEN APPEARANCES: Thereupon: SCOTT ROTHSTEIN, was called as a witness and, having been duly sworn, was examined and testified as follows: THE WITNESS: 1} do. MS. HADDAD: Good moming, Scott. How are you? THE WITNESS: Good morning, Tonja. How are you? MS. HADDAD: Fine, thank you. It's nice to see you. THE WITNESS: Good to see you, too. MR. SCAROLA: Mr. Rothstein, ] don't know that you and ] have met. I'm Jack Scarola, I'm representing Brad Edwards and J know you know Brad who's to my immediate left. THE WITNESS: Hey, Brad, how are you? Jack, good to see you. MR. SCAROLA: Thank you. MR. GOLDBERGER: Also present is another Jack, Jack Goldberger, and ] also represent Jeffrey Epstein. To my right is Darryn Indyke -- THE WITNESS: Good morning, Jack. MR. GOLDBERGER: How are you today? And to my right is Darryn Indyke, who is LAW OFFICES OF TONJA HADDAD, P.A. by Tonja Haddad, Esq. Attorney for the Plaintiff. ATTERBURY, GOLDBERGER & WEISS, P.A., by Jack Goldberger, Esq. Attomey for the Plaintiff. SEARCY DENNEY SCAROLA ET AL, by Jack Scarola, Esq. Attomey for the Defendant, Brad Edwards. MARC NURIK, P.A., by Mare Nurik, Esq. Attorney for Scott Rothstein. (Appearing via Video Conference.) U.S. ATTORNEY'S OFFICE, by Laurence LaVecchio, Esq. Attorney for the Department of Justice. Ore WNHOrF COMO DADO BWNHYEF OW DOwaAnonwA WH BH NNMMNMNMNHRPRPHP PP Be Yee ¢ i : & £ i & : i 4 : Ea 2 g i Page 4 ! INDEX Mr. Epstein's in-house counsel. MR. INDYKE: Good morning. THE WITNESS: Good moming, sir. MR. NURIK: Good morning, everyone. MR. GOLDBERGER: Hi, Marc, how are you? MR. NURIK: Good. You'll be seeing my shoulder most of the day. MR. GOLDBERGER: Okay. DIRECT EXAMINATION BY MS. HADDAD: Q. Well, Scott, ] know you've talked about this probably more than you even care to, but ]'d like to start a little bit asking you about the scheme at your firm and how and when it started and things of that nature just very briefly because ] know you've covered it many times. MR. SCAROLA: It has been covered and protocol precludes asking questions that have already been answered and covering areas that have already been covered, so we do object. MR. GOLDBERGER: Your objection is noted. BY MS. HADDAD: Q. When did this first start? A. It started back in '05, '06. The question is a little bit vague for me because it started in a Page 5 WITNESS DIRECT CROSS REDIRECT RECROSS SCOTT ROTHSTEIN (By Ms. Haddad) 5 (By Mr. Goldberger) 92 (By Mr. Scarola) 12] EXHIBITS PLAINTIFF'S FOR IDENTIFICATION 64 69 72 ELLA ERENT SEALS PESTER IS ENS EB TRIS DEES SEAN ESSAI SRE UIE RES SRAM GAIN RUS ERAN RNR NNO RESTS DS NIT NNNNNNHPE RPE Peep ps OBWNHE OW AWIAUBWNHE OW ANDO BWNH ERNST 2 (Pages 2 to 5) FRIEDMAN, LOMBARDI & OLSON 305-371-6677 5ed93085-0554-447f-bcdd-ca2d8fe941df HOUSE_OVERSIGHT_017491

1 different form than it ended because it started as 11 2 bridge loans and things of that nature, and then : 2 3. morphed into the Ponzi scheme. But you are looking © 3 4 back into the 2005 time frame for the very beginning. — 4 5 Q. The 2005 time frame, that's when the bridge 2 5 6 loans started? - 6 7 A. I can't be certain exactly what we were : 7 8 doing. I need to see al] the documents to tell you 2 8 9 what we were doing at what specific point in time. . 9 10 Q. What made you decide to start doing this? : 10 11 A. I started doing it out of greed and the need P11 12 to support the law firm, which was having significant 12 13 financial trouble at the time. #13 14 Q. And in 2005 had you moved over to 401] yet or (14 15. were you still in the building where Colonial Bank 215 16 was? 16 17 A. | don't remember. i 17 }18 Q. Do you recall approximately how many : 18 19 attorneys you had working for you when it started? 5 19 20 A. 1 do not. Between five and ten, Tonja. 420 Ai Q. Was it before you started acquiring 221 22 attorneys like you were acquiring cars and watches? | 22 23 MR. SCAROLA: Object to the form of the i 23 24 question, vague. . - 224 25 THE WITNESS: Yes. 625 Page 63 1 BY MS. HADDAD: 4 2 Q. Well, who were you partners with when it 2 3 first started? 3 4 A. Stu Rosenfeldt. : 4 5 Q. Okay. Anyone else? #5 6 A. Susan Dolin, I believe. It was definitely t 6 7 Stu Rosenfeldt, Michael Pancier, and Susan Dolin may 7 8 have been partners of ours at that time, I'm not i 8 9 certain. 2 9 10 Q. Because if memory serves me correctly, you 210 11. went from being in the One Financial Plaza Building to : 14 12 _ the building across the street, it was Rothstein, : 12 13. Rosenfeldt, Dolin and Pancier; is that correct? : 13 14 A. Yes. :14 15 Q. And it was some time later that you moved : iS 16 into the 401 Building, correct? 216 17 A. You are skipping one step. | went from One i 17 18 Financial Plaza to Phillips, Eisinger, Koss, Kusnick, i 18 19 Rothstein and Rosenfeldt. Then Stu Rosenfeldt and] 19 20 _ broke off and formed Rothstein Rosenfeldt. And then : 20 421 Rothstein, Rosenfeldt, Dolin, Pancier over at the #21 22 Colonial Bank Building. And then we took the space in : 22 23 the 401 Building and everitually moved over there and 423 24 that's when the real growth started. £24 25 Q. And when you say, "that's when the real i 25 i Page 7 : growth started," do you mean both the scheme -- do you mean the scheme and the firm or either one or both? A. Both. Q. Do you recall approximately when you took the space in the 401 Building? A. | do not. Q. At the time everything imploded, how many partners did you have at the firm, do you recall? A. Are you saying partners and shareholders? Because remember, we had both, two designations. Q. J] want to start with just attorneys that had -- not in your firm name but named as "partner" on the cards, for example. A. I'd have to see a list of all the employees. We had a bunch. Q. Do you recall about how many attorneys you had working there? A. Approximately 70. Q. In the year before, do you recall how many you had? A. | do not. Q. So how many equity partners did you have or shareholders? J'm not sure of the word that we are using. A. Actual shareholders, equity shareholders Page 8 were two, me and Stu Rosenfeldy. Q. And everyone else was just_a partner for title purposes? A. There were shareholders for title purposes and partners for title purposes. Q. If someone was called a shareholder for title purposes then, did they get to receive any of the funds? Were they shareholders receiving money or they were not considered shareholders in that sense? MR. SCAROLA: Objection to the form of the question. THE WITNESS: What kind of funds are you talking about? BY MS. HADDAD: Q. In genera] from the firm. When you say equity shareholders, I understand that's you and Stu. What I'm saying is, if you had someone else that was named as a shareholder, why did you call them a shareholder as opposed to a partner? A. lt was a title of prestige and achievement. Q. So it was basically an ego thing, it had nothing really to do with the finances or hierarchy of the firm? A. They got paid more generally, but it did not have anything to do with distributions. Page 9 3 (Pages 6 to 9) FRIEDMAN, LOMBARDI & OLSON 305-371-6677 5ed93085-0554-447f-bcdd-ca2d8fe941df HOUSE_OVERSIGHT_017492

ont nnd Ww DY Ne} 10 ii 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Onn Oe WM FE NNNNNNFRFP RP BRP RPP PEE mm WHF COMO WAI nD UF WDHYF OC WW} Q. When you were hiring and bringing in all these new attorneys, did everyone come in as a partner? A. No. Q. How did you decide who came in as a partner and who came in as an associate? A. Depended upon their level of expertise, practice, book of business. It was a decision Stuart and } made together on a case-by-case basis. Q. So you and Stu where the -- were in charge of hiring? A. Stuart and | tried to consult on every hiring decision, yes. Q. Did you guys also decide salaries? A. 1] generally decided the salary and then let Stu know what |] was going to do. And he would say if he thought it was okay or if he thought it was too much or too little, but ] generally had free reign in that regard. Q. Did someone's book of business directly correlate to the salary that you would offer? A. That is a very broad question because it depends upon what other needs we had for that individual. Q. What do you mean by "what other needs"? Page 10 : SE ER Aca ae A. Well, I'll give you a good example. My lawyer, Mr. Nurik, his salary was directly related to the fact that he was a great lawyer and had a solid book of business. Q. Yes. A. David Boden, on the other hand, was, as J previously testified, ] don't know if you've had a chance to read the testimony, but David Boden was not only the general counsel to the law firm but he was also -- acted as my consigliere in a significant number of illegal operations and he was compensated significantly for that, if that helps you understand the difference. Q. It does. So, for example, when you were hiring former judges, let's use that as an example, Pedro and Julio, clearly they don't have a book of business coming in because they haven't had clients, but they may carry some sort of prestige or give some legitimacy, if you will, to the firm. How would you decide the salary for someone like that? A. Stuand! would discuss it. It was more a market issue than anything else, how much are judges coming off the bench getting, how much business do we think they can generate. OoODMDAIKDY SF WNHNFr COU DANDY B WNP URLS FESS ESI NIA UIE Me iS hd RES na ig RRS IRAP NNER EE ra MRT IE RS SEIN RST BOA Rae eR ON STAEINES R Mt se meng a te Oe em) SPREE Bho Nh fh QW MF TERETE N on Q. Would you need to look at someone's book of business if they were coming in just solely to be a rainmaker for the firm prior to hiring them? A. | discussed it with them. There were not many people that ] recall that ] actually looked at their numbers. Once David Boden was working for me ] had him check people's numbers, but I rarely looked. J took most people's words for what they were generating. Q. My recollection is, you were always looking to bring in more people, to hire more people, some of us were somehow able to resist you while others were not. _How would you decide who you were looking at to bring into your firm? A. We were trying to develop, on the legitimate side of the Jaw firm, we were trying to develop real talent, rea] practice s. I mean, Brad isa perfect example, great Jawyer, got a great reputation, You know, it was our hope that, you know, he was going to be one of the people to actually in some ways rescue the firm because he had a practice group that could generate substantial income. You know, on the legitimate side that's what we were trying to do, we were trying to find the best and the brightest, Q. Okay. With respect to bringing people that Page 12 ES ee ee A ee i ee | © prt know that? A. Everyone in the tort world that J] had spoke to spoke extremely highly of Brad, not only people | already had working for me but other people that knew +him. He was very -- came very highly recommended to us. “"Q. Like who, for example? A. We wanted him in there. We were trying to develop a significant tort group and we thought that he'd be a great part of it. Q. Who besides Russ told you that about Brad? A. It would have been other people in the tort group. ] don't want to guess, Tonja, as to which other people told me, but it was -- well more than Russ. Q. Was it people within -- A. Might have been people in politics that ] talked to that knew him because we had significant input at the gubernatorial level with regard to tort reform and the like, and there were people there who knew who Brad was. It was more than one person that told us that. Page 13 4 (Pages 10 to 13) FRIEDMAN, LOMBARDI & OLSON 305-371-6677 5ed93085-0554-447f-bcdd-ca2d8fe941df HOUSE_OVERSIGHT_017493

Page 15 ey nigparanamrnaees etegiealeenn aay nishananatenenent eC RSTO ERD SGD TEP DO UE Pe aH eam EE eS TA SEY RE I A hb sop hk +f if coat ERET EAMES EE ALM NN APRESS PE CHOU IR SOAR ASN RES GANS CRS RE A PACA RARRITD E ee E ES e : NM NNN DN HR Pb ray mp 1 Q. Okay. When you were looking at people to 2 bring in to the firm to legitimize, as you said. Your 3. firm had a very unique area of practice and had a very 4 unique environment to which to work. How did you know 5° orhow did you come to decide what people may or may 6 not fit into that? 7 A, Okay. Hang on one second. J think you just 8 accidentally misstated my testimony, 9 ] was not bringing the people in to 10 legitimize the law firm. | was bringing them in to 11 the legitimate side of the Jaw firm. The bulk of the 12 Jaw firm, despite the lack of financial success, was a 13 Jarge group of very honest, hard working Jawyers 14 trying to do their best in difficult economic 15 conditions. There were some that were obviously not 16 legitimate. And the way ] decided to bring people in, 17 again, it's really everything | just told you. Are #18 you looking for how I brought people into the Ponzi f19 scheme? 20 Q. No, right now I'm just asking about the firm 21 because, as J said, it’s a very unique way in which to 22 practice and a very unique workplace environment with 23 politics and restaurants and parties at your home and 24 things of that nature. I'm asking, personality wise, 25 other than the book of business, how did you decide on Page 14 1 people that would be a good fit? 2 A. J looked for people that were outgoing, that 3 had the type of personality. On the legitimate side 4 of the business, people that had charisma that were -- 5S that could go out and hustle and try to develop a book 6 of business if they didn't have it. And as one of the 7 50 percent of the shareholders of the firm ] was 8 trying to hire people ] wanted to work with. 9 Q. Okay. When you would see people from whom §i0 you would offer jobs, for example, as you mentioned 11 — earlier with Brad and his practice, if somebody stated 12. that people told you that he was a good lawyer, did 13 you need to see him in action, so to speak, prior to 14 your deciding to hire them or would you just take 15 people at their word for it? 16 A. Some of people I saw in action; he wasn't 17 one of them. Steve Osber is an excellent example of 18 that. J hired Steve after he was beating the living 19 — daylights out of me on the other side of a case. And 20 J certainly would ask around about the people. But 21 _ the people that ] trusted -- see, J] can't remember. | 22 think Gary Farmer was working for me before Brad, and 23 if '’m not mistaken he would have been one of the 24 people that ] went to with regard to Brad because we 25 were really developing that whole tort group around MOM MMM NFR FFF FP OPW NYFF OW DAMA FWNYFPR DUH DAK BWN bP that time with Farmer and Fistos and Jaffe and Mr. Edwards. Q. Do you know where Mr. Edwards was working when you first learned of him? A. ] don't recall whether he was working for someone or had his own practice, I don't recall. Q. When did you first learn about Brad? A. ] don't remember the time frame. Q. Do you recall when you first met with him regarding a job? A. No. The easiest way to figure that out is to go look at his personnel file, it will have the notes saying when he met with me the first time. Q. You don't have any recollection of your first meeting with him? A. No. As you know, ] was hiring people left and right and ] was also unfortunately very busy doing things ] shouldn't have been doing, so ] don't have a specific recollection of when I hired him. | barely have a specific recollection of when | hired me. Q. But you did, in fact, meet with him? A. I'm certain J met with him before I hired - him. I can't imagine -- although | did hire people without meeting them. | did hire people based on other people's word, if they were people within the Page 16 firm that ] trusted. Because | always said, I had a very simple, you lie or die by what you are telling me. If you are telling me this guy is good and he's not good, that's on you, it's going to hurt your income. So J used to tell my partner, people that were recommending people to me, don't sel] me a bill of goods just to get somebody in here because if you do that it's going to come back on you, it's going to affect your income and your ability to grow in the firm. So with that admonishment, ] might have very well hired someone sight unseen based upon what someone else told me. Q. But you did meet with Brad you say before he came in to work? A. Now that I'm saying it out loud, ] think I did but really I'm guessing. I don't have a specific recollection of meeting him. Q. Do you recall if you knew that he had worked as an assistant state attorney for a few years prior to doing tort litigation? A. 1] don't recall that one way or the other. Q. So you wouldn't have asked Howard Scheinberg or anybody about him before he came to work there? A. I can't say that 1 wouldn't have asked because, like 1 said, ] might have asked. But Page 17 5 (Pages 14 to 17) FRIEDMAN, LOMBARD] & OLSON 305-371-6677 5ed93085-0554-447f-bcdd-ca2d8fe941 df HOUSE_OVERSIGHT_017494

unfortunately, you are taking a little tiny spot out of a very, very busy time period in my life and in the life of the firm, so J can't tell you one way or the other. knowing he was a billionaire? Q. |} know you had a lot going on, I'm just A. | knew what] was told. | didn't check it trying to see if you remember anything specific about; out myself, but] trusted the people that told me. this. Q. And who told you? A. The only person ] remember discussing it with, as | sit here today, is Russ Adler. But if Farmer and Jaffe and those guys were with me at the time, ] likely would have discussed it with them as ave discussed it with them as well Q. So were you aware of this case before you made an offer to Brad to join the firm? A. Yes, Q. You said you didn't -- ] don't want to misquote you. You said you heard about it from other people, but you didn't do anything to know that personally. Was that before you made the offer of A. Epstein was a billionaire, Q. Okay. Did you know anything about the legitimacy or illegitimacy of the claims prior to AUSTENITE Onan Uo B® WME Do you recal] what salary you had offered Brad to come join the firm? A. I] donot. You have to just try to differentiate that what I knew then is a Jot different than what J know now so ... Q. Meaning? A. Obviously meaning that at the point in time that ] was hiring him or maybe a year after, ] would be able to tell you what I was paying him, but now it's insignificant. J don't remember how much I was paying him. Q. Did you learn about his book of business or know what kind of cases he was bringing in prior to employment? hiring him? A. 1] made the offer of employment based upon A. I do know that he -- I discussed either with z what other people had told me about Brad. Russ, well, ] know with Russ, and perhaps some other = Q. About Brad and his book of business or just people, ] knew about the Epstein case. i Brad and his legal skills? Q. What did you know about it? : A. Okay. When ] say Brad, ] mean Brad and his Page 20 ts SONNE te tre eae Ei are Ra Oger nee RSE . Lknew that it was a significant case. book of business and his legal skills. potentially significant value against an extremely Q. Okay. A. And his ability to generate business in the future. Q. You stated that you believed that you first heard about these cases from Russ and then perhaps from Brad. Once Brad was at the firm, did you keep up with these cases, these Epstein cases? MR. SCAROLA: Excuse me, I'm going to object to the form of the question. It is an inaccurate reflection of the prior testimony. It has no predicate. There was no reference about having heard about these cases from Brad. The names mentioned were Adler, possibly Farmer, possibly Jaffe. BY MS. HADDAD: Q. Once Brad started working at the firm, you've already testified you already knew about these Epstein cases, correct? A. Yes. Q. How did you keep abreast of these cases? A. I didn't. Q. You didn't know anything about them? A. I didn't say ] didn't know anything. 1 said 1 didn't keep track of it. collectible pedophile, for lack of a better word. Q. So was that case your primary motive in bringing Brad into-the firm? A. ] doubt it, ] mean, ] can't tell you one way or the other, but I doubt that ] would bring him in just for one case because what if the case fails, then J'm stuck with a lawyer w you know. I'm not saying, Brad, that you couldn't do anything, J'm just saying that if] only relied on one case, then if] bring a lawyer in for one case and one case only, what do I do with him when the case is over. Q. How did you know that this case would be a collectible case then? MR. SCAROLA: I'm going to object to the form of the question because it misstated the prior testimony. The prior testimony was not that it was a collectible case but that it was a case against a "extremely collectible pedophile.” BY MS. HADDAD: Q. What made you think that this case had any financial value? errr ta ARAL i cre meester etn cnc oe ta zat RY TR AN Ra aera tone eat , n 4 ypu sf ry Page ia § Page 21] 6 (Pages 18 to -21) FRIEDMAN, LOMBARDI & OLSON 305-371-6677 5ed93085-0554-447f-bcdd-ca2d8fe941 df HOUSE_OVERSIGHT_017495

DrwAINO B® WNYFH OnwAnvroewwWNH-E Oo Q. You didn't keep track of it? A. J did not keep track of it. From time to time Russ and the other guys in the tort group would tell me what was going on in certain cases, but until I made a decision to utilize that file for an illegal purpose related to something illegal that ] was doing along with my co-conspirators, | just assumed my Jawyers were going to work the case and eventually it would hopefully work out well for the law firm. Q. At your firm, when e-mails would go out to attorneys at RRA or all attorneys at RRA, were you part of that e-mail group? . You are talking about all staff? . No, all it says is attorneys at RRA. It's the e-mail group "attorneys"? Yes. Yes, I'm a part of that e-mail group. And ] appreciate that you were very busy and may t not have read all of them, but you did receive those e-mails when they would go around? A. Yes, and 1 tried my best to read them. Q. Okay. At what point did you decide to use this case to further your Ponzi scheme? A. 1 don't remember the date, but I can give you the circumstances, if you'd like. Page 223 Q. Please do. A. The Ponzi scheme was running very low on capital. My co-conspirators and ] needed to find a new feeder fund, new investment sources. We had a couple of very large, significantly wealthy potential investors out there. I was looking for something that would have been very attractive. We had had a lot of inquiry during the due diligence period with these people that were doing due diligence on the putative cases that we were selling. And when | thought about the Epstein case, realizing that it was a substantial actual file in the “office, I came up with the idea that if ] created a fake confidential settlement circling around -- based upon this actual case, they would be able to increase the level of due diligence that I was able to offer to my potential investors. Q. How did you know this was a substantial file in your office at that time? A. Again, through the people J spoke to in the office. Q. Such as who? A. Again, same people, Adler, Farmer, Jaffe, Fistos. Q. You never spoke to Brad about this case? A. I didn't say that, but J had a Jot more Page 23 Serna 0 UR TNR LO OA ee eS RT RN MEER EERO eh tenor sual tease sauacetaen OerWnNor COU WHA DY fF WNYEH DO DTA DY SF WN EF PSS ERASE EP NG OR EPA IRA I Se RS A RRS SR RH SSM TE RIES RM NMONNDM NYDN HPF FE PRP PB a NNNNNRFPRP RPE PRE ER BWHrRPOW MIDE DBWNHE OW DIRDUBWNHE Ne) on) interaction -- Sorry, Tonja, | didn't mean to speak over you. If you talk to the people in the firm, if they are honest with you, they'll tell you my interaction was far more significant with Russ Adler, probably more so because he was a co- he was a co-conspirator of of mine, My interaction with Russ was | Russ was far greater b greater by many, many percents over my interaction with Brad, and then you go down the line. ] had more interaction with Mr. Farmer than I did with Mr. Fistos, more interaction with Jaffe than ] did with Mr. Edwards, and so on. Q. Russ was the head of your tort group, right? A. Yes. Q. So these cases fel] under the tort group; is that correct? A. Yes, it fell under the -- fel] under Russ’ purview ultimately, yes. Q. And Brad was a partner at your firm during the time these cases were there, correct? A. ] believe that was his title. He was either partner or shareholder. J] don't think we had made him a shareholder yet. Q. But he wasn't coming in as an associate, Page 24 correct? A. To the best of my recollection, no. Q. So you stated that you learned this case was -- ] don't want to misquote you and listen to a long speaking objection, but what did you call this case? MR. SCAROLA: Who wants the quote? THE WITNESS: It was a substantial case with a -- what | perceived to be a highly collectible pedophile as a defendant. BY MS. HADDAD: Q. Right. How did you know at the time when you said these investors wanted to investigate and you said you were going to create a fake settlement, how did you know that this case was the case that you could use? A. From talking to all the people that I just said, Adler, Fistos, Jaffe, Farmer, Mr. Edwards, to the extent that ] spoke to him about it. Q. Did you speak with Mr. Edwards about the case? a: 1 GON NSPE ac pesinocrceollection one Way or the other. ] remember speaking to him at least briefly the day or the day of or the day before the actual investor's due diligence was going on as to Page 25 7 (Pages 22 to 25) FRIEDMAN, LOMBARDI & OLSON 305-371-6677 5ed93085-0554-447f-bcdd-ca2d8fe941 df HOUSE_OVERSIGHT_017496

1 what was going on. And] may have spoke to him, ] 2 1 2 know | spoke to Russ, but ] may have spoke to him as i 2 3. well within a couple of days just prior to this due : 3 4 diligence because ] was trying to at least get some : 4 5 information in my head that ] could use when ] was : 5 6 creating this story for the investors. 2 6 7 Q. Scott, what's Q-task? : 7 8 A. Q-task is a web based software system that | : 8 9 had invested $7 million in. 1 9 10 Q. And what was the purpose of this internet £10 11. system? : 11 1.2 A. To be able to communicate in a secure #12 13 fashion and in a unique group fashion about specific ; 13 14 files. 14 15 Q. So forgive me, we all know I'm not good with ] 15 16 the computer. That was something that would be useful | 16 17 within a law firm, why? B17 #18 A. Because it allowed you to create groups and i 18 19 have both general and private chats, organize data in 119 20 avery unique fashion. That was, at least to our way : 20 21 of thinking, would have been very, very helpful in the a21 22 law firm setting with multiple practice groups. £22 23. Q. Did you belong to any groups on Q-task? : 23 24 A. I'm certain that ] did. 1 don't remember : 24 25 which groups ] belonged to. | never got into the full £25 Page 26 : 1 use of it. I tried to, but again, ] was very busy 1 2 doing other things. But ] know that Mr. Adler's group 5 2 3 used it extensively. 2 3 4 Q. Because it was your firm and, as you said, , 4 5 you invested $7 million in it, did you have the e 5 6 ability to access a group if you wanted to? 6 7 A. Yes. And if] couldn't, | could get Russ to tT 8 give me access. 1 8 9 Q. So you didn't necessarily have to be invited : 9 10 into the Q-task group for you to be able to utilize or : 10 11. view the communications within it? : 11 al: A. No, that's not true. ] actually had to be 412 13 invited, that's what } was telling Russ to do, is to : 13 14 have me invited. i 14 pis Q. But I'm saying, the lawyers wouldn't have to 1s 16 personally invite you, you can get someone within your #16 17 firm to give you access maybe without the lawyers 47 18 knowing? 218 19 A. No, ] think it might have had a, quote, 4 9 20 unquote, confidential, super secret viewing : 20 21 capability, but] don't recall it having that, and I'd ] 21 22 have no need to utilize that. Just invite me into the 22 23 group and let me see what's going on. 23 24 Q. Okay. I know that you are or were a very 24 25 hands-on person within certain of the practice groups £25 Page 27,5 and with that, with the Q-task and the e-mails, did someone assist you with reviewing everything and letting you know what was going on within the groups? MR. SCAROLA: Excuse me, I'm going to object to counsel's testimony. Object to the form of the question as leading. THE WITNESS: J really don't even understand the question. Can you try to rephrase it for me, Tonja? BY MS. HADDAD: Q. Of course, 1 would. Did you keep abreast of everything that was going on in every practice group or was someone through Q-task and e-mails, for example, or was someone giving you information keeping you posted on what was going on within the practice? A. Well, as part of the tort group | had a pretty good idea of what was going on there all the time just because of the significant amount of interaction, both legitimate and otherwise, that ] had with Russ Adler, so ] was probably more up-to-date on that group than any group other than the labor and employment group, again, because ] had such significant interaction with Stu Rosenfeldt, both legitimately and Wlegitimately, so 1] knew what was Page 28 going on in that group. ] tried, as best as ] could, given my time constraints, to stay on top of what was going on, you know, throughout the firm. But ] relied on other people like Debra Villegas and Jrene Stay and David Boden, Les Stracker to the lesser extent, to monitor what was going on in the different practice groups and keep me up to speed. Q. Was there audio and video surveillance throughout the entire firm or only within your office? A. No, through the entire office, not in the individual offices. Hang on. Not in the individual offices but throughout the general office space. Q. So in 2009 how many floors did you have? A. Three, | think. Q. And do you recall approximately how many attorneys you had working there at that time? A. Approximately 70. Q. And when you say "not the individual offices but the other areas,” do you mean -- would that include conference rooms? A. I didn't have surveillance in the conference rooms. Q. Socan you please tell me exactly where you Page 29 8 (Pages 26 to 29) FRIEDMAN, LOMBARDI & OLSON 305-371-6677 5ed93085-0554-447f-bcdd-ca2d8fe941 df HOUSE_OVERSIGHT_017497

arNInNWOS WNP had audio and/or video surveillance? We'll start with audio. A. 1 don't have a specific recollection of every place ] had video and audio, but it was in -- ] had it set up so that in all of the common areas, including our shareholder's lounge, we had -- J had audio and video capabilities. Q. When you say "capabilities," does that mean you didn't always turn it on or you just turned it on when you felt like it? A. J turned it on when J felt like it, when 1 felt like seeing what was going on. | sometimes left the screen up because | had four computer screens on my desk, I sometimes left the screen on with the video of the reception area and some other general areas. But unless ] wanted to see what was going on or listen to what was going on, ] didn't turn it on. It would have been too distracting. Q. Did the attorneys know that this surveillance existed? A. You can see it in the -- it wasn't hidden, you can see it. There were globes up in the ceiling al] over the office. Q. Did you have -- you said -- you didn't answer this, you said you didn't recall. Did you have Page 30 Oe WNrOrFOW DAI DOA WNP TOW MAINA BWNEH PEREVE REDE NOMENA PEA LUNN HS ONAN EESTI OPER HERES HIE RES EESE A AS SORTA BE OE MMONMNHNYHD FRPP BPR PE EL iN ea RI SEES IN EISNER NO eA any surveillance in the conference rooms? : A. No. Q. Other than the common areas you just went : over, in the hallways and the reception -- did you i have it in the hallways, is that a common -- do you : deem that a common area? : A. All the hallways pretty much with the : exception of a few blind spots, J can see all the : hallways. ' Q. And this was on all three floors? A. Yeah. For some reason | think we might : have taken some space on a fourth floor, but ] could : be mistaken. But yes, on the three floors that we : actively had a significant amount of space on, } tried i to have surveillance on al] the common areas of al] that space. : Q. And what floor was Mr. Edwards' office on? =| A. | don't recall. : Q. Did you have the tort group all together or | was it divided up? i A. Except for Adler, Adler was on with -- near | me, down the hall from me. The rest of the group was | all together. I think they were on -- let's see. i There were people up on 22. | was on 16. He must have been on the other floor that we were building Page 31 i Op WHF OM DMOAIAUBWNHEF TOMO DATA YAAWNHEH NONMNMNHNHNFE EP ERP PPP out, because ] remember building out space and | remember Jaffe and all those guys moving into that space. Q. If you were building up that space, do you recall when you put the surveillance in there? A. It would have been while they were building it out or shortly thereafter. Q. During 2009 it seems that you hired lots of former law enforcement people to work at the firm. Why were they people you wanted to hire? A. Severalfold. J had a significant amount of illegal activity going on with various law enforcement agencies throughout South Florida and hiring people from former law enforcement assisted me in engendering support and camaraderie with the law enforcement that } was actually utilizing in illegal activities. Q. So you are saying -- A. Secondarily, ] wanted to have a very strong investigative team, ultimately, to do both legitimate and illegitimate things for the law firm, and hiring former Jaw enforcement was the best way to do that. ] was hoping to actually ultimately create a group. Ken Jenne and I had talked about that extensively. Q. Why did you hire Ken Jenne? A. Prior to Ken going to prison, he and ] were Page 32 very friendly and he was extremely friendly with someone that was very close to me, Grant Smith. During the time that he was down in FDC Miami, I went down to visit him. And after speaking to him and after speaking to Grant, ] told him, because he was talking to me about how many people had tumed on him and abandoned him. And ] told him that when he got out of jail that he had no worries, that ] would give him a job. Q. And what -- A. And that was the primary reason -- that was my primary reason for hiring him. Q. What was it you were hiring him to do exactly? A. Ultimate the goal was to head up on investigative arm within RRA, within the RRA entities. Q. Well, while he was there, since that didn't happen, what was his obligation to the firm day-to-day? A. He handled firm security issues and he did handle overseeing certain investigative things. We had an alcohol and beverage group that was forming and he was overseeing that. He was helping me find new people to staff it, that kind of thing. Q. Did you have a lot of interaction -- Page 33 9 (Pages 30 to 33) FRIEDMAN, LOMBARDI & OLSON 305-371-6677 5ed93085-0554-447f-bcdd-ca2d8fe941df HOUSE_OVERSIGHT_017498

OnrAnD oO B® WDNR DADO HB WNH EH A. He had had significant -- as you know, he also had significant political connections and everyone who is not living under a rock knows I was doing everything | could to garner significant political power. Q. J] think many people miss your parties. But, with respect to Mr. Jenne and his politica] connections, were you hiring him to utilize him with respect to any of the police department investigations? You had stated earlier you had dealings with police departments. | don't want -- again, | don't want to put words in your mouth. You said you had dealings going on with various police agencies? A. I had -- ] mean, we had a criminal defense section in the Jaw firm, so we had legitimate dealings with law enforcement. But ] also had significant illegitimate things with law enforcement that had nothing to do with Ken Jenne. Q. And how about with respect to former FBI agents you were hiring? A. They were all people that were operating in a legitimate fashion within the law firm. Q. In what role was that? A. The investigative roles and the alcoho] beverage roles and anything else Ken or other staff could think of to have them do. Q. Let's talk about the investigative roles for a minute. What kind of investigations were these teams running? A. I] donot know. You have to speak to lawyers that were actually utilizing them. ] put it out there and Ken put it out there, that they were available to lawyers in the firm for use like in-house investigators. And what people did with them ultimately was up to them. Q. Were they on salary or were their costs and fees associated with utilizing them within a specific practice group? A. They were all on salary with me. The ultimate goal was to have it as a separate entity that could bill the Jaw firm and have the clients at least defray some of the cost. ] don't recall whether or not we ever got to that level or not. Q. With all that in-house police action, why did you have police security surrounding you all] the time? A. J guess the best answer was I was paranoid, but 1 mean -- that's the simple answer to it. You Page 355 st US RRR YP NEI ESSA ART TE TINE EI pe fete ppm a ig eet rn Seppe eet ettae aetna St HS AS RE a ep ie SRT TN SD RN SR SUE Ra NNR AT t po 4 } Otm®WNH COwWoO WAI A USF WHR DWM WAI DO B® WMH PH NNNNMONNFEPEPP RPE Pe EE know, having -- there were mixed reasons. For example, ] -- are you talking about my Fort Lauderdale police detail? Q. Yes. You had it at the office and at your home, correct? A. Yeah. There's a myriad of facts that motivated me to do that. One was that ] really wanted the security for the office. Two was, I was paranoid and this is in no particular order. Three was the Melissa Lewis murder that shook the entire law firm and shook me terribly. 1 didn't want that to ever have to happen again. And four was, I wanted -- the more law enforcement you have around, the more legitimacy it adds to you and your appearance to the community. So there were a multitude of reasons. ] mean, I hired certain Jaw enforcement to work for me that were just friends of mine that were -- that needed additional money, so 1 wanted to make sure that they had money, both guys that did the illegal stuff for me and guys that didn't do anything illegal for me. Q. Let's go back to the Epstein case and when you decided to utilize it -- to use for the investors for your Ponzi scheme. Do you recall approximately when it was that Page 36 ne ee ee t Spe pt NoF WNHrP OW Dn DO & WW NDY FP bt ~~ these investors were coming that you decided to use the files? A. My best recollection it was_in 2009, sometimes after April of 2009, but ] don't have a specific recollection beyond that. Q. What makes you think it was after April of 2009? A. Because, to the best of my recollection, the Clockwork Group came in towards the middle of 2009. When I say Clockwork, that's an umbrella term that ] use to mean the Von Allmen, AJ Discala, and other investors that came in through that feeder fund. Q. So that was around April 2009? A. No, it was after, to the best of my recollection. ] mean, you can tell because all you have to do is look and see when the first, very first Clockwork investment is. Actually, you can pinpoint it even closer. Look for the very first settlement deal that we did that was related to the Epstein case, within 60 days prior to that would have been when ] was meeting with those due diligence people, 30 to 60 days before that, Q. So when you decided to use that case, take me through exactly what you did to familiarize yourself with that case. Page 37 10 (Pages 34 to 37) FRIEDMAN, LOMBARDI & OLSON 305-371-6677 5ed93085-0554-447f-bcdd-ca2d8fe941 df HOUSE_OVERSIGHT_017499

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 cig aaNet ees ect atin eer 05 SLA ARR ELS TENA NWN HATE RE THUY STRESS UES me mR PS MSN OpmwWNFOU WAI AU PWNYNFP COU WANA HS WN LH NM NMNHNMNFPP BBE PR Pee 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 Orn oO FF WN FE OwpwWNPFP OW DOAIDUOUBPWNFP DO WMIAYNBPWNEH SSG SERENE cw ae Hee Ng I EN SAT NENA RUMEN DEE NU IE A HE PEERS S SENSIS BS SMA ALAS EO PNT TT ENR AN CSE OR NNONMNNNNEPRP REP EPH EE ll (Pages 38 to 41) FRIEDMAN, LOMBARDI & OLSON 305-371-6677 5ed93085-0554-447f-bcdd-ca2d8fe941 df HOUSE_OVERSIGHT_017500

D~ATIN OP WDE 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? Page 43 cae S009 eo a bee EE: REA SEN ETE DEN SERENE AS OE HYP EU NE RR i ARAN SCA activates ares NMNDNMNN NFP FR RP RP RPP PB HE 2 3 4 5 6 7 8 9 0 1 2 3 4 ) 6 7 8 eg) 0 1 2 3 4 5 il pl el il a al il el al pl a2 2 42 62 £2 2 Se ca er meaaata eum es O®FWNRrFP DUO MWADYU FWNHrF DO WARD O B® WHE EPEAT RRR 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 Page 45 12 (Pages 42 to 45) FRIEDMAN, LOMBARDI & OLSON 305-371-6677 5ed93085-0554-447f-bcdd-ca2d8fe941 df HOUSE_OVERSIGHT_017501

Pe Pe WhnHrF OW MAND UF WHE Beeb mn Ws anarno Ss WHY PE NNNNNNEFE PPE PPR PB OPBWNHEF OW AWHOBWNHHE OW their book of business. This being said, ] was_ bringing in legitimate lawyers to form legitimate practice groups to practice legitimate law, having nothing to do with the Ponzi scheme. Q. During the year 2009, were there any, to your knowledge, any big settlements of any cases at RRA? A. To the best of my recollection, no. We had a dismal year. Q. The year 2009 was just dismal across the board? A. Some people did better than others, but yes, overall] it was for a firm of 70 lawyers, it was dismal. Q. So there were no big wins coming into the firm as far as a financial windfall other than from your other businesses? A. The only significant capital coming into the firm was money my co-conspirators and J were stealing. Q. Was there any particular practice group that you can remember that had a particularly non-dismal year in 2009? A. Mr. Nurik had a good year. Q. Do you recall what the gross revenue was from legitimate sources in 2009? Page 46 A. It was somewhere between eight and $10 million, probably right around the nine million mark. Q. Do you know what your -- A. On its best day. Q. What was your overhead for salaries in 2009, do you recall? A. 1 don't have a clue. Q. Was it more than you brought in legitimately? A. With what I was paying in salaries, J'm -- J mean, I'd be guessing. If it wasn't more than, it was certainly close to it. Q. That's just salary, that's not talking about anything else, rent, overhead, things of that nature? A. That's correct. Q. Who was paying for the investigations of the cases that were going on in 2009, the deposition costs, the filing of complaints, and things of that nature? Where did that money come from from your firm? A. It varied from case to case. Q. For the tort group? A. It was fronted by the law firm for the most part. Page 47 RI EEE se an s ie : : 5 i Hy 2 a 4 S i a gt : 4 eS d | OW®wwWnNrP OW MONDO BWNHEH DMO DWAIUAHAYOBWNHH re erp nergy ea reg ra YUU TRS UA HG A IE TRU SE MES UE EM BR I RE OR APES SEES AS MT OS NMNNNNPPRFP PPP RP EE B Q. For the most part. What wasn't fronted by the Jaw firm? A. | recall there being a couple of agreements that various tort lawyers had with certain clients where they were going to assist in helping to pay the costs. All the other costs would have been paid by the law firm, both through legitimate and illegitimate means. Q. So when you say by "illegitimate means,” where would the illegitimate means money come from? A. It came from the Ponzi scheme, and all the tentacles of the Ponzi scheme, other illegal activity. Q. Such as? A. Things ] was doing with law enforcement, things ] was doing in politics, things that ] was doing with organized crime, things ] was doing with politicians, judges, other lawyers, bankers, business people, things of that nature, ]'m sure there's more. Q. Do you recall if any of these Epstein cases underwent significant investigation while the cases were at your firm? A. I'd be guessing. ] don't remember. Q. There was a meeting in 2009, July of 2009, and it appears from the e-mail communications that it was for everyone in the firm to attend and it was Pag e 48 oa arene reece regarding the Epstein case. In fact, there was an Epstein conference room that was reserved for it. Were you present at that meeting? A. I may have been. Q. Do you recall? A. | don't recall one way or the other. Q. You don't recall it. Do you recall anything about the Epstein case in July of 2009? A. Idonot. Do you have something that might refresh my recollection? MS. HADDAD: Can we just take a five-minute break night now? THE WITNESS: Sure. MR. GOLDBERGER: Thank you. MS. HADDAD: Thanks. {Short recess taken.] BY MS. HADDAD: Q. Scott, 1 was asking you before we took the break about a meeting with respect to the Epstein cases. There was a 159-page privilege log filed, which I'm sure you don't have and are not aware of. But in it there are many, many e-mails to both attorneys at RRA, yourself, and Mr. Nurik regarding the Epstein litigation. And all this resolved in July Page 49 13 (Pages 46 to 49) FRIEDMAN, LOMBARDI & OLSON 305-371-6677 5ed93085-0554-447f-bcdd-ca2d8fe941df HOUSE_OVERSIGHT_017502

AAD OF WNHE of 2009 about the Epstein meeting and some additional investigation into the Epstein case. Does that refresh your investigation as to when you met with the investors in the Discala/Clockwork Group? A. It does not. The best thing to refresh my recollection as to when ] met with them would be to see the dea] documents. Q. Okay. J unfortunately don't have those. Do you recal] if you took Discala and his other investors to a football game in 2009? A. Sure, ] did. Q. Okay. Would that be around the time you were trying to get them to invest in the case? A. It would have been around the time | was trying to get them to invest in general. H's may have been around the time that | was showing them the Epstein file. Q. Did you show them any files other than the Epstein file? A. I] may have. ] don't have a specific recollection one way or the other. Q. You testified earlier that you had over a dozen boxes brought to your office that were related to the Epstein case. MR. SCAROLA: Excuse me, counsel. there has been no such testimony. BY MS. HADDAD: Q. You said there were several boxes brought to your office by different people. You don't recall who that is; is that correct? A. Yes, ] had some boxes already in my office and ] had Ken Jenne and some other people bring some others. | don't remember how many boxes. . Was it more than three? Sure, it was more than three boxes, yes. . Was it more than 10? . ] don't believe so, no. You stated that you looked -- ] don't want to put words in your mouth. What did you look at specifically in that case? A. Other than looking at the flight manifest that Russ Adler told me to look at, I have no specific recollection as to what J looked at in that file. Q. Do you know if there was more than one case being prosecuted by your office against Mr. Epstein? A. To the best of my recollection there were -- it was multiple plaintiffs. Q. Okay. Do you recall if those cases were pending in state or federal court? Counsel, Page oly Op WNYeEF OUDMDAIHAU PWNHR OW DWDATIAHAYBWN HE SESSA OMEN Sia BESET CREME PNNUR EER EE AUER SU OMS BGT ER AR RIAA NEESER SNES SRE 2S ERE PRR BBS INS OOS SIRS RN SIMS RRR SUR GR RRS CRE RA YE PS Th TED SARTRE OS eter Ny MNMMNNHYNFRP EPP RP PEPPY OP WNMF ODOM DAIDOFB WNP TOW DOA DO fF WN FE MM MM NM NFP RPP PPR PPB RENEE AR UATE RTA TER TE TERRES a OUR a ER SBE RE NESE SAS SB RRR PRG BS PEAR RE RU MRR RR NR SEY CaN RES BN AN NSS BB EN SS RP A. | don't recall. Q. Did you check? A. 1] don't remember one way or the other. It was insignificant to me, Q. Well, then explain to me. You testified earlier that what was important to the investors to see is that there was a real case, correct? A. Yes. Q. What did you look at or show them -- what did you look at, first of all, to see if it was, in fact, areal case? A. | knew it was a real case. Q. How did you know? A. Because my lawyers told me it was a real case. ] believed them. Q. What Jawyers told you that? A. | already told you it was a mixture of Russ and Jaffe and Fistos and Farmer and Mr. Edwards. 1 mean, ] knew it was areal case. We had all these boxes, we had people really working on the file -- Q. How do you know -- A. -- or they were pulling a hell of a scam on me. Not that] didn't deserve it but ... Q. How did you know, you just said you knew people were working really hard on this case. Who do Page 52 you know was working on the case? A. The only people that ] knew for certain were working on the case was Brad Edwards and Russ Adier was doing his supervisory schtick, whatever that was. But other than that, ] don't know which other lawyers were assisting Mr. Edwards. | didn't get involved at that level. As far as the Ponzi scheme goes, the only thing ] cared about, Tonja, was being able to show the investors that this case that ] was utilizing to steal a significant amount of money from them was a real “case. That's all 1 cared about, Q. That case came into your office through Mr. Edwards, correct? He brought it with him when he came to RRA? A. Yes. Q. He was lead counsel on the case, correct? A. l assume he was Jead counsel. J never checked to see if he listed himself as lead counsel. Q. Do you know if any additional complaints were filed while the case was at RRA? A. I have no idea one way or the other. Q. Did you ever instruct, in furtherance of your Ponzi scheme, Mr. Edwards or anyone in that litigation group to file additional complaints? Page 53 14 (Pages 50 to 53) FRIEDMAN, LOMBARDI & OLSON 305-371-6677 5ed93085-0554-447f-bcdd-ca2d8fe94idf HOUSE_OVERSIGHT_017503

orn bp WN eE NNNNNNF RF RP RRP RRP RR WO PWNF OW DAAIMDUOBWNHEP OW 1 2 3 4 5 6 7 8 NNNNNNFRP RPP REPRE RPE OpWNOrFowvaowrAtonauwrsbs WNFH OW 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? eee Sop ps OBWNHE DODO DIDO A WHE OW DMYNHOSWNE te pes ps po sts SSS aU ai acre Sn eA i ti ESN eS US RR aR Maat atte ea atta uaaneeeme eR a 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 Page 554 OPBWNHEF OW WAAIHAKHUBWNHPFP OCW WADE BWNEHR scar car eccaecta-ece ar eNaaren iar actar asunder arr area NNMNNNOFPRPRPRP EP HP RPE EE 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) FRIEDMAN, LOMBARDI & OLSON 305-371-6677 5ed93085-0554-447f-bcdd-ca2d8fe941 df HOUSE_OVERSIGHT_017504

1 July 22nd and 23rd there were numerous e-mails sent od 2 about the meeting. It was almost an all-hands-on-deck : 2 3. type meeting where everybody needed to attend. Itwas = 3 4 labelled the Epstein meeting with an Epstein 4 5 conference room reserved. 3 5 6 A. Yes. £6 7 Okay. What's your question and I will tell i 7 8 you. i 8 9 MR. SCAROLA: First I'm going to object to 2 9 10 counsel's testimony, but let's hear the question. : 10 11 BY MS. HADDAD: Pll 12 Q. The question is, does that refresh your [ 12 13 _ recollection as to whether or not this meeting took : 13 14 place? 14 15 A. To the best of my recollection, ] actually £15 16 had introduced some of the investors to some of the 16 17 people working on the Epstein case, and that is likely i 17 f18 the meeting that you are referring to. But for the £18 19 life of me, ] don't have a specific recollection of £19 20 it. £20 f2i Q. But it could be the meeting where you 21 22 introduced the Epstein litigation team to your Ponzi £22 23 investors? £23 24 MR. SCAROLA: Excuse me, I'm going to 24 25 object to the form of the question. It misstates the £25 Page a8 a 1 prior testimony. It has no predicate. 1 2 BY MS. HADDAD: 7 2 3 Q. That couid have been the meeting in which - 3 4 you introduced the Ponzi investors to people working | 4 5 on the Epstein case? , 5 6 MR. SCAROLA: Excuse me, counsel. The | 6 7 testimony was that there may have been a meeting at | 7 8 which investors may have been introduced to some i 8 9 people working on the Epstein file. And your efforts | 9 10 continuously to mischaracterize the prior testimony 210 11° are highly improper. I object. | 11 12. BY MS. HADDAD: p12 13 Q. Scott, did you or did you not say that you p13 14 — introduced some of the investors to some of the 214 15 Jawyers on the Epstein case? £15 16 ~ A. No, J actually said, Tonja, that ] may have. £16 17 J have a recollection that | may have based upon you : 17 18 just refreshing my recollection, but] just do not ' 18 19 remember one way or the other. This was, in the : 19 20 scheme of what | was doing, insignificant. ] was 22 0 21 _ simply trying to establish to the investors that this £21 22 was areal case, with real potential, with real | 22 23 Jawyers working on it. Other than that, it was of no 23 24 interest to me. 24 25 Q. How else would you convince them? You've | 25 Page 59} mentioned letting them look through the litigation boxes, you've mentioned the meeting. What other way would Id you have convinced them that it was a real case? “A. I mentioned letting th letting them look at boxes, what they did when ] was out of the office, that's -- ] don't know because | couldn't see what they were doing. Number two, ] may have introduced them to people in the office. Number three, I'm certain that when the people brought the boxes to my office ] introduced them to whoever was carrying the boxes. And number four, the rest of it would have been all stuff] created in my imagination because, again, it was the sale of something that didn't exist. This was not settling. There was no real settlement money. There were no real settlement documents. ] even manufactured, | think, the actual plaintiff, because ] don't recall even knowing the plaintiff's real name or if 1 did it was of no significance to me. Q. How would you have manufactured a plaintiff's name, would you have created additional documents to further your Ponzi scheme using Mr. Epstein as the defendant? A. No. Q. How would you -- A. The name just would have appeared on the Page 60 confidential settlement agreement. Q. Would they have already seen the documents ai that point? A. | can't tell you one way or the other what they had seen, because | don't know what they actually looked at. Q. Forgive me, you've now confused me so I'm Just going to ask you for some clarification. You used a legitimate case and created fake settlement documents, correct, in the simplest sense? "A. If this culminated in an actual sale of a fake settlement, then the answer is yes. Q. So it was a real case with a real plaintiff and real defendant, just a fake settlement document? A. No. Let me see if] can clarify this for you. Over 90 percent of the settlements that | sold, the fake settlements, were completely fictitious? Q. Right. A. A very small percentage of them were based, at least in part, on some type of real Jitigation that ‘either had occurred or was currently occurring. | utilized the Epstein case to bolster the visual for the investors that a real case existed. Because as these were being sold to more sophisticated investors, the questions kept coming up, w re -- how do we Page 61 lo (Pages 58 to 61) FRIEDMAN, LOMBARDI & OLSON 305-371-6677 5ed93085-0554-447f-bcdd-ca2d8fe941df HOUSE_OVERSIGHT_017505

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. ‘Ud ie) Xe) oO a i) SHEDS PSK NFAT gM NESRUNa RRP Aca pragnENSTERMIU A Ls | SORTS ate RSE EI ected ia ec et ate rh epenicie tion ie Rpt RE Does NN RETRY fay s 4 y 4 fay Ss bp k dm WW t 4 On wm 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 s REET IEEE ee LIAN ST eta i 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 race ne UN ee ioe am nate aur aint ate ep tena RELATE ere ese SOA a STE A SE BE ERI 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 Page 65 17 (Pages 62 to 65) FRIEDMAN, LOMBARDI & OLSON 305-371-6677 5ed93085-0554-447f-bcdd-ca2d8fe941 df HOUSE_OVERSIGHT_017506

[13 14 15 16 17 E 1 2 3 4 5 6 7 8 9 ee Ld 12 43 14 15 address from your firm; is that correct? A. Yes. Q. And were you filing any cases back in 2009 in federal court? Do you remember how PACER works? MR. SCAROLA: Which question would like answered? THE WITNESS: |] don't remember. MR. SCAROLA: Objection, compound. BY MS. HADDAD: Q. Do you remember how PACER worked when you were filing a case, Scott? A. | actually never actually did the actual electronic filing procedure. ] had people that did that. ] knew that we could file electronically. Q. Do you know the purpose of your using your e-mail address when you were filing electronically in federal court? A. |] guess so you can get a receipt, but J have no idea. Q. Did you ever receive an e-mail] from federal court in your e-mail address that showed that a document had been filed with the stamps that you see on the top of that one? ~ MR. SCAROLA: Counsel, are you attempting -- ee | oe NEST eS NRE ENE OrAnA oO SB WN FH PLEAS IESE RS ae Wn a ee RH aN RO MR NM WM MH Om & WN FE o EN Page 66:2 a ea am ate a THE WITNESS: I don't know one way or the other. MR. SCAROLA: Are you attempting to establish that that complaint was filed in federal court by Brad Edwards? MS. HADDAD: I'm asking him if he recalls the way it's drafted and why. MR. SCAROLA: Just ask your question. MS. HADDAD: I'm asking a question. If you have any objection, please Jay it on the record. MR. SCAROLA: No, what J want to do is try to save some time. If what you are trying to establish is that Brad filed the complaint in federal court on July 24th and used the PACER system, you don't need to ask any more questions about that, it happened. MR. GOLDBERGER: We appreciate that, but when we depose you we'll ask you that question. But we are deposing Rothstein right now so Jet her ask her questions. Don't do this speaking stuff, let her ask the questions, okay? MR. SCAROLA: Maybe. MR. GOLDBERGER: Okay. Go ahead, Tonja. BY MS. HADDAD: Q. Scott, did you ever get e-mails like that re aneseam esry y S O e I RAEN PUSS ST ERE RSDP SB RTI SS APM HL from federal court? A. I'm certain] did, Tonja. 1 don't have a specific recollection of getting the one pertaining to this. I] don't even know if they sent it to me. | would imagine they'd send it back to Mr. Edwards. Q. The filing attorney? A. I suspect, unless the PACER system is registered on my name, then maybe it comes to me, but ] am completely guessing. Q. But based upon the e-mail communications of July 22nd and the meeting occurring on July 23rd, this complaint was filed the day of this meeting; is that correct? A. Okay. But here is the problem with your question, ] don't remember whether or not there actually was a meeting. | said there may have been, and J don't have an independent recollection of this being filed. ] do not have an independent recollection of whether J told someone to file this. And for the life of me, this ] am certain of, if] told Mr. Edwards to file a complaint in federa] court, if there wasn't a legitimate reason for him to do it, he wouldn't have done it. Q. Do you recall if this federal case was filed when you decided to use the case for your Ponzi scheme Page 68 and show it to your investors? A. It may have been filed around that time, because I haven't been abie to establish the exact time. It also certainly may have been utilized by me to further the Ponzi scheme. Also, 1 don't have an independent recollection of that either. Without seeing e-mail traffic, ] can't tell you one way or the other exactly what was going on at that time. Q. Well, then I'll point you to another e-mail which is marked as EP 001. MR. EDWARDS: Let me see it. MS. HADDAD: I sent a copy to your office. MR. SCAROLA: He would like to see a copy now. Thank you. {The E-mail referred to was marked for identification as Defendant's Exhibit 2.] BY MS. HADDAD: Q. Were you able to find it, Scott? A. Got it. Yes, ] have it. Q. You have it, okay. You said Cara Holmes used to be an FBI agent, correct? MR. SCAROLA: No. What he said is -- THE WITNESS: FBI or IRS. Page 69 18 (Pages 66 to 69) FRIEDMAN, LOMBARDI & OLSON 305-371-6677 5ed93085-0554-447f-bcdd-ca2d8fe941 df HOUSE_OVERSIGHT_017507

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

Onn WF WHY PH ann mnF® WDM FB A. What does it say? Say it again. Q. It says, "The first deposition occurred on July 27th,” correct? A. Yes. Q. Some three days after the federal complaint was filed, correct, that we referenced earlier? A. That's correct. Q. And Paragraph 6 clearly delineates that in August 2009 a phone call was received by the cooperating witness that explained that this Mr. Rodriguez had a list of other purported victims or contact information for people who Mr. Edwards could also potentially bring Jawsuits for -- on behalf of; is that correct? A. ] don't know one way or the other. You know, Tonja, just so this record is clear, you know, as ]'m sitting here, ] have a vague recollection of perhaps Ken Jenne coming, talking to me and telling me that someone in my office was going to cooperate with someone in this investigation. But for the life of me, } can't be certain of that. So much time has passed, but as J'm reading this, and it could be completely unrelated to this, ] just want to make sure the record is a hundred percent clear, it's possible that Ken Jenne discussed that with me, but ] don't Page 74 know who it was. Q. You are testifying that you didn't know it had anything to do with the Epstein case, as you sit here now, you don't remember? A.* No, no, | don't have a specific recollection, and ] want to just make sure so ] answer all your questions completely, is that as I'm sitting here my recollection was refreshed that ] have a vague recollection of having a conversation with Ken Jenne about the fact that someone in our office was going to cooperate as a confidential informant for some law enforcement agency, | just can't remember if it was the Epstein case or not. Q. Do you recall what you said to Mr. Jenne about that? A. No. What 1 just related to you is all 1 remember. And |'m not even sure it had anything to do with this. Q. Who's Wayne Black? A. Who? Q. Wayne Black. A. Sounds like the name of someone | hired, but 1 could be mistaken. ] don't recall. Q. Okay. You don't recall ever meeting Mr. Black? se tanta ai chage secrete | tag PN None neL tenes oom cI ere! soa SENG ar at cere ne een ara ari A pe a inne OB WNE DMO WAIA YP WNFOUW DWwAInan OB WNP MMNYMNMYNHY NYFF EPP PPE BEB sn Zz 2g Oo pWNHrF OW MAA OO HBWNHEPOUODAIHRDATAWNEHE SERSIICRITGLSGAIR NAAR ADT NS PSNR PE POT NU EE EE EN SEE LPN MESSE AE SEE MES ROE ES ITN RE ERE EAN RA EE EPR OR ES NMONNONNYNEE RPP EPP PPP A. | may have. | don't recall one way or the other. You have something that might refresh my recollection? Q. Do you know what he does for a living? A. |] do know the name. Sounds familiar to me, but | can't recall one way or the other who he was or what he did. Q. Did you instruct your office to begin investigating Mr. Epstein's pilot or his airplanes? A. J do not recal) one way or the other. Q. You did testify that the flight manifest was the one document you recall] for sure looking at in Mr. Epstein's case; is that correct? A. Yes. Q. And if it did, in fact, contain the names that you are purporting that it claimed or that you knew of, that would be something that would be juicy for the investors to further your Ponzi scheme that it was a collectible case; is that true? A. I'm sorry, you have to repeat the question, Tonja. | don't understand what you just asked me. Q. If these big names were on this list, as you seem to recal] they were, that would be most helpful to you and your Ponzi scheme investors in convincing them it was a big case, right? Page 76 A. Ifthey were on there, or if ] lied to them "and told them they were on there, or if Adler told me they were on there and | repeated, ali those things would have been helpful to the Ponzi scheme. Q. You stated earlier that you -- the only thing you looked at was the flight manifest because you were told to look at it. Is that still true? A. That's not what I testified to. J testified that I flipped through other parts of the file and that I didn’t remember what J had flipped through. | remember looking at the flight manifest because Mr. Adler told me about it. Q. You said that you met these investors in your office, but there were no cameras in your office, correct? A. I didn't have cameras specifically in my office. Q. You had these investors in your office for this particular Epstein case? A. Yes. Q. Do you recall if it was during work hours or after work hours? A. Ido not recall. Q. Typically when you were meeting with your potential Ponzi investors, did you meet them during Page 77 20 (Pages 74 to 77) FRIEDMAN, LOMBARDI & OLSON 305-371-6677 5ed93085-0554-4471-bcdd-ca2d8fe941 df HOUSE_OVERSIGHT_017509

aonrnnuowe® WN PH Ne} 10 11 12 13 14 15 16 17 Hig f19 20 21 22 23 g24 25 DAInDnU BP WNEH NNNMNHNMOHPHEHPHHE EEE EB BWwWMHMrF OW MAHA BWNHeE OC WO 25 we were establishing. work hours or after work hours? A. Both. Q. Did you always meet with them in your office or did you do it more socially down at Bova or elsewhere? A. Both. Q. But with this particular case, do you recall meeting them at least one time in your office where they could look through the files? A. Actually, that group of investors were looking at a Jot of different cases or at least multiple different cases that we were attempting to lure them into the Ponzi scheme utilizing, so ] met with them on multiple occasions, both in my office and at restaurants. Q. Who is Mike Fisten? A. Mike Fisten was a law enforcement officer of some type that ] hired. Q. Why did you hire him? A. He was a Ken Jenne suggestion. Q. And were you hiring him to start up your company with Mr. Jenne, as you indicated earlier? A. 1] don't recall] what the purpose of hiring him was. It had nothing to do with what Ken Jenne was doing for us. [ea pepe Rnareseeass Ow WHR OW MATA UBWNHEFKDWW DAAYBFWN HE MPR NM PHM NOY FRPP FP RP Re 99S A ERI USER SPS Pe EES TR SNA A NE AEE RCPS SEIS Page 78 Q. So what did he do at RRA? A. My best recollection is that he had been a former ADT officer and so it would reason that he would be working in our alcohol beverage practice that Q. Do you know if he ever did any work for your firm as an investigator? A. He may have. | don't have a specific recollection one way or the other. Q. Did you ever speak to the press about the Epstein case? A. 1] don't have a recollection one way or the other. Q. Did you ever have Kip utilize the Epstein case to put any publicity or spin out there with respect to the case? A. I don't have a specific recollection of that one way or the other. Q. Did you ever instruct Brad or Russ to talk to the press about the case? We'll start with Brad then Russ. A. 1 do not specifically recal] getting involved at the publicity level of that case. I don't have a recollection one way or the other. Q. Would that publicity have been good for your Page 79 OBWNHFOWDAATAUBWNFOWOAAIADUYAWNEH nena eer aA EAN RO Re EA NLR PEE PENN DY CCSD TERIA PE EEE ESE SRE MNOMNNMNEFP EE RP RP RPP Ee Ponzi scheme investors? A. Not really. Q. Would it have given more legitimacy to your allegation that it was a good case in which they should invest? A. Inthe way that I was selling the Ponzi settlements, it would have likely been overkill. Q. So did you ever instruct them not to speak to the press about the case? A. | don't recall that either one way or the other. Q. Ifit had gotten out there that the cases had not, in fact, settled, as you were claiming when you were selling the settlement, would that have hindered your case, your Ponzi investor's case? A. Not really because they would have no way of knowing if] had created a fake plaintiffs name. | mean, there could have been something in the news that -- and ] don't know that there was -- there could have been something in the news that says none of this settled. And] just simply would have created a fake name with my co-conspirators, created a fake set of settlement documents and handle it that way. Q. Did you know where Mr. Epstein lived? A. J] only knew that he was from Palm Beach, Page 80 other than that, no. Q. Okay. In 2009, did you ever have any firm meetings? A. Of any type? Q. Of any type, in general, firm meetings. A. I'm certain J did. Q. Do you recal] about how many? A. 1 donot recall. Q. Did you ever have any partner meetings? A. Yes. Q. Do you recall how many? A. I donot. Q. Do you recall] how many partners you had at the firm in 2009? A. I donot. Q. Do you recall how many fundraisers you had at your home in 2009? A. I donot. Q. More than 10? A. I'd be guessing, Tonja. Q. Okay. A. It's easy enough to check, there's state and federal records of all that stuff. Q. In 2009, did you still require the attorneys from your firm to attend the fundraisers you would Page 81 21 (Pages 78 to 81) FRIEDMAN, LOMBARDI & OLSON 305-371-6677 5ed93085-0554-447f-bcdd-ca2d8fe941 df HOUSE_OVERSIGHT_017510

1 have? : 1 Q. When did you hire him? 2 A. You said "still require," which would have : 2 A. 2008 or 2009. | don't have a specific 3 meant that ] testified -- / 3 recollection. 4 Q. Sorry. : 4 Q. Jf you hired Jawyers who didn't have a book 5 A. -- previously that it was requiring them. - 5 of business, what kind of practice did they do at your 6 Q. Did you require attorneys at your firm to : 6 office? 7 attend your fundraisers? 7 A. It depended upon the lawyer. 1 would have 8 A. lasked them to, ] urged them to, | tried to : 8 tried to get them to work with other lawyers in an 9 cajole them into coming, but it wasn't an absolute | 9 area that they either were proficient in or wanted to 10 requirement. -10 become proficient in. 11 Q. Do you recall between April and July of 2009 i 1 Q. Okay. You had a meeting at your office 12 how many fundraisers you would have had? il 2. during which you were asking about information 13 A. I donot. 213 _ regarding referring attorneys, attorneys who had 14 Q. Did you have fundraisers anywhere besides 14 __ referred business to the firm. Do you know what I'm 15. your home in 2009? £15 talking about? J believe it was back in December of 16 A. 1] probably did, but ] don't recall without 116 ‘08 or early 2009. 17 seeing the documents. If you have the invitation or £17 A. The way you are characterizing that meeting, 18 the e-mails, that would help me. 218 Thada lot of meetings like that. 19 Q. Did you hold fundraisers at your office in 419 Q. What was the purpose of those? 20 2009? 220 A. You are going to have to be more specific 21 A. Imay have. That wouldn't have been -21 forme, Tonija. 22 unusual, but] don't have a specific recollection. 52 2 Q. Let's start generally then. What was -- you 23 Q. Did you ever meet any of the plaintiffs in : said you had many meetings like that. Tell me what 24 _ the Epstein case? these meetings were for? 25 A. I don't have a specific recollection of A. Making sure that we were maximizing 1 that. 1 generation of business into the law form. 2 Q. Do you recall ever revving copies of e-mails gE 2 Q. What kind of business, legitimate business 3 from Mr. Jenne with respect to the plaintiffs in the i 3 or the other -- 4 case that the subject matter would say "information we i 4 A. Legitimate business. 5 need to use"? 2 9 Q. Sorry, ] couldn't hear you. 6 A. J] don't recall that one way or the other. : -6 A. Legitimate business. The genera] meetings 7 It's certainly possible. _ 7 that you are discussing, that was legitimate business. 8 Q. Do you recall ever reviewing anything that i 8 Q. So there was a meeting for all attorneys to 9 was titled "causes of action against Epstein"? = 9 attend regarding generating business, those meetings 10 A. 1 do not have a specific recollection of : 10 were for the legitimate business? 11. that one way or the other. i 11 A. If it was addressed to all attorneys, yes. 12 Q. Do you recall ever reviewing with Mr. Jenne £12 Q. Okay. And if an e-mail went out to all 13. or any other investigator in your firm any information : 13 attorneys, did paralegals and support staff get it as 14 regarding Mr. Epstein's house staff or airplane staff? 14 — well or was it just directed to the attorneys? 15 A. 1do don't recall that one way or the other. 215 A. Certain support staff probably were on that 16 I may have, J may not have. : 16 _ list, like my CFO and COO, and perhaps my IT people, 17 Q. Who is Bij] Berger? £17 but it was general for the attorneys. 18 A. A former Palm Beach judge that we hired. £18 Q. With respect to your IT people, did you have 19 Q. Okay. What was his role at your firm? : 19 the capability to review e-mails and internet activity 20 A. He was a shareholder. i 20 of all of your employees? 21 Q. What kind of practice? 2 1 A. did. 22 A. Litigating cases. #22 Q. Including attorneys? 23 Q. What kind of practice did he litigate? What £23 A. Idid. 24 _ kind of cases did he litigate? | 24 Q. Did you ever utilize that tool? 25 A. 1] don't recall specifically. : 25 A. Very infrequently. It was a pain because ] Page 83 i Page 85 22 (Pages 82 to 85) FRIEDMAN, LOMBARDI & OLSON 305-371-6677 5ed93085-0554-447f-bcdd-ca2d8fe941 cf HOUSE_OVERSIGHT_017511

OoOrArnork WNE had to have Curtis Renie or Bil! actually come into my office, set up a special icon to allow me to do that. It was a real pain, so it was rare. Q. Who else attended the meetings that you had with the Clockwork group with respect to the investors in the Epstein case? A. There were multiple meetings with what I'l] call the Clockwork investors at various points in time. A variety of people came in and out of the meetings. Some of the meetings occurred down in Bova. Other people came up to the meetings. Some of the meetings involved Michael Szafranski, our fake independent verifier. Some of the meetings may have involved bankers and the like. ] cannot tell you specifically who was at those meetings. Q. The specific meetings that we are talking about with -- where you left the boxes at your office, do you recall who else was there with you at that meeting? A. J only remember there being a handful of people from the investment group and myself. | don't recal] -- and ] remember the guys bringing the boxes the down, but they didn't stay for the meeting. There may have been other people there, ] don't recal] one me She RB where we owed 20, $30 million in Ponzi payments out and she needed to write a check for even $5,000, she probably would have checked with me on that. So substantial and whether or not she would have checked with me depended upon the circumstance at the time. Q. You stated earlier, and J think I'l] get this quote right, that 2009 was a dismal year; is that correct? A. For the legitimate law firm business, it was a dismal year. Q. Soin the months immediately preceding the dissolution of RRA, July to October of 2009, what would you consider a substantial expense that had to be approved? A. It would vary literally from day-to-day. Q. Do you have any independent recollection of how you were doing in, say, July 2009? A. The legitimate business was always doing poorly in 2009, as far as ] was concerned. Q. So would you have -- A. The Ponzi scheme had its moments of significant wealth and significant poverty, so it varied from time to time. It was a daily thing. Sometimes it was hourly. It just depended upon what OnrmwnrnrFrowwmrwntnuornesk wWwnr owmrn ars WN FH = : : g : a i : e : i : : = i a a ; Page 86 i MM NM MH NM NW FT | way or the other who it was. was coming in and what needed to go out. Ey Q. Ifthe expenditures were being made on a case that were substantial, did you have to approve them or did you have a specific practice for them? A. The head of a practice group could basically approve them but Irene, our CFO, would generally run them by me before she actually cut the check. If] wasn't around she'd run it by Stu. Q. So as the equity partners you had the authority to make the determination what funds could and could not be expended? A. As the shareholders, as the two 50 percent shareholders, we controlled the finances. Q. And if Irene was coming to you to tell you what the funding was for, to get approval rather, would she tell you specifically what the funding was for or just tell you "we need $100,000"? A. No, if it was a substantial expense -- Q. Tell me what you deem as substantial. A. That would have been -- substantial to me would have been based upon how much money we had in our coffers at the time. So, if it was one of those Q. So would you have to utilize the illegitimate funds to fund the legitimate cases at times? A. Yes. Q. And that varied daily you said? A. Well, aj] the money was commingled together, so we used whatever funds were in there to fund both the legitimate and the iJlegitimate financial requirements of the firm, the Ponzi scheme and other legitimate and illegitimate things that were going on. Q. Ifan outside agency or investigator was being utilized for a case and they needed a signed retainer agreement with your firm, would you have to approve that? A.. It would depend upon the significance of the expense. | didn't necessarily get involved in every retention of every expert in every case. Q. Okay. So it would depend on the cost or the nature of the case? A. Who the lawyer was, their level of expertise, all things of that nature. MMMM P PRP RPP BBP PB WNHNFrFPOW MAND UBWNHEH OW DANAUS WNHPH periods of time where we had 20 or $30 million floating around the law firm, Irene probably would have just written a check without even letting me know we were writing it. If it was one of those times Q. Ifit was this gentleman who you have no recollection of meeting, Mr. Black, and the attorney was Mr. Edwards, was that something you needed to look over? Page 873 Page 89 stent iBT DRAPES aN eet ae ee ao esse R RP a ER GRA NERS TES EPR ERA NE NER a hm Mm oof ia eeeienamuagiet 23 (Pages 86 to 89) FRIEDMAN, LOMBARDI & OLSON 305-371-6677 5ed93085-0554-447f-bcdd-ca2d8fe941df HOUSE_OVERSIGHT_017512

A. Did Wayne Black work for Ron Cacciatore? Q. Are you asking me -- A. I'm asking anyone in the room who wants to talk to me. Q. |] Jove to talk to you, but ] don't know the answer to that question. He might have. Brad might be able to tell you. MR. EDWARDS: No. THE WITNESS: When you said Wayne Black's name again and that J hired him to do something, ] seem to think that he may have been associated in some way with Mr. Cacciatore, but I'm not sure one way or the other. I don’t remember whether or not ] met Mr. Black, it's possible | did, it's also possible ] did not. And] don't have an independent recollection of retaining him to do anything or whether | was part and parcel of the decision if we {Short recess taken.] FURTHER DIRECT EXAMINATION BY MR. GOLDBERGER: Q. Allright. Mr. Rothstein, Jack Goldberger, I'm going to ask you some questions now. You testified that you knew Jeffrey Epstein was a billionaire. You did testify to that today, correct? A. Yes. Q. Okay. Tell me how you knew that. How did you know that Mr. Epstein was a billionaire? A. Russ Adler told me. ] looked him up on the internet. Q. What did you look on the internet about Mr. Epstein? A. 1] don't recall, but ] remember looking up an seeing that he was very wealthy, that he was a billionaire. ee a ee br +I + Me NUOUPWNHPRP DU ADAATIA OB WN ?EH ~) 4 cO did, in fact, retain him, whether ] was part and parcel of the decision to retain him. BY MS. HADDAD: Q. Traveling out of state for depositions for the particular cases, did you have to approve that? =A. Jt would depend upon who the lawyers were, the significance of the expense. It would have been case by case. |] certainly would not have been approving or disapproving Mr. Nurik's travel, Mr: Rosenfeldt's travel, Mr. Boden’s travel, Mr. Lippman's travel. That was their own thing. If a younger lawyer like a Shawn Birken came to-me and said he need to travel out of state for something, if it was just for a deposition, 1 wouldn't © have gotten involved in that unless he was telling my CFO, Ms. Stay, that he wanted to fly first class and stay in the Ritz Carlton, then ] would have gotten involved. But other than that, no. The firm was too big for me to get involved on a daily basis with all that stuff. Q. If Brad had to go out of state to take a deposition, you wouldn't be the person to approve or disapprove that? A. Russ Adler would have handled that. And if there was an issue, Russ would have come to me. And J don't know what the relationship was specifically between Brad and Russ, but it's certainly possible that Brad just was going to go do what he needed to do to properly handle the case and ] would have trusted him to do that. MS. HADDAD: Can we just take a second. We are going to take a minute, okay? THE WITNESS: Sure. Page 91 see eee agn gg egret yan ten tps nba eae tm repens eo i ran ray 4 So he ps ee pt bs 4 OP WHE OUMWU DAIHDUEUFWNPFP DMO DAHA SFWNE ps epusrene seme vere acenertmmrne cetera eta en zt TGS TU TENTS EEC EASE SEES PME PER SPER I MM NM NM NM NH Q. Okay. So as far as learning that Mr. Epstein was a billionaire, you learned via two ways, one was from Russ Adler, correct? Is that correct? A. Yes, sir. Q. And the other was through looking up Mr. Epstein on the internet, correct? A. Yes. - Page 92 Ee eS ESHER LANTUS AEE ASS IS a ee ee HRA Q. Okay. And you don't know what you reviewed on the internet in an effort to determine that Mr. Epstein was a billionaire; is that correct? A. I do not recall. Q. Do you know when you did that? A. 1 do not. Q. Was it prior to your needing to use the Epstein case to further your Ponzi scheme? A. Yes. Q. Okay. So prior to -- ] think you indicated that you needed an influx of money at some point and that's when you decided to use the Epstein case in furtherance of the Ponzi scheme; is that correct? A. Yes. Q. So prior to that time though, prior to determining that you needed to use the Epstein case for the Ponzi scheme, you Jooked up Mr. Epstein and you spoke to Mr. Adler about his work; is that correct? A. Yes. Q. Why did you do that, Mr. Rothstein, if you weren't using the Epstein case at that point in your Ponzi scheme? A. Because it was a legitimate case in the legitimate portion of RRA that ] had reason to believe Page 93 24 (Pages 90 to 93) FRIEDMAN, LOMBARD] & OLSON 305-371-6677 5ed93085-0554-447f-bcdd-ca2d8fe941df HOUSE_OVERSIGHT_017513

from speaking to Mr. Adler could bring in a significant amount of money to the firm. Q. At that time Mr. Adler was one of your co-conspirators in the Ponzi scheme; is that correct? A. By this time, yes, sir. Q. Okay. When did Mr. Adler become a co-conspirator in your Ponzi scheme? A. 1] don't recall the specific date. 9 Q. Was it before or after Mr. Adler recommended 10 that Brad Edwards be hired at your firm? 11 A. Before. 12 Q. So before Brad Edwards was hired at RRA, Russell Adler was a co-conspirator of yours in the 14 legal part of the RRA firm; is that correct? B15 A. Yes. Q. Then after that time you hired -- 17 Mr. Edwards was hired after Adler was your 18 co-conspirator? You are laughing, you are smiling, 19 — why is that, sir? A. Because when you say "RRA" that way, the 21 speaker sounds, it sounds like you are roaring. 22 ~Q. Okay. I'll just say Rothstein, how about 23 that? You know what I'm talking about if] just say 24 ‘Réthstein. 25 = A. RRA is fine. aw Wrnwp WNP Page 94 1 Q. Okay. So Adler is your co-conspirator in 2. the Ponzi scheme at the time that Brad Edwards is 3. hired, correct? 4 A. Yes. 5 “Q. Okay. Was it Adler who recommended to you 6 that Brad Edwards be hired? 7 ~ A. Yes. He was one of the people. 8 Q. Who else recommended that Edwards be hired? 9 A. | don't have a specific recollection of who 10 it was, but others did. 11 Q. Allright. But you have a recollection of 12. Adler being one of the people, so let's talk about y13 that, al] right? 14 What did Adjer tel] you about Brad Edwards 15 ~~ when you hired him? Did he tell you that he had these 16 Epstein cases or an Epstein case in the fold? 17 A. Among other things, yes. 18 Q. What else did he tel] you? 19 A. Told me he was a great lawyer and a great 20 guy. 21 Q. Did he tell you what his history was, what 22 Edwards' history was prior to coming to the Rothstein 23 firm? 24 A. I'm certain that 1] asked him, but J don't 25 have a specific recollection of that conversation. Page 95 set ee rT fp gg seine AUN FRET em Ee eR RPA NY er eREND ATL ORES ETE KS pb Fame a eee Ow DAAID OB WNP TOW DAI DUN S&S WNEP NO ee veremoenen N ey ee N N 23 : apnea NOM cn ob a OSCE GALANTE A ee a mc NPP ee Pep DoODMDIDUBWNHYEFP DOW ANA UBWNPE Ae IE ea epee ln come A ONR ESET TER see er aE 21 223 bod E & is Ea EP ER RE ES scenes Q. What did Adler tell you about the Epstein case that Edwards had at the time you were contemplating hiring him to become a member of the Rothstein firm? A. He told me that it was a huge case involving a billionaire pedophile and that it was a winner. Q. Did you, when you heard that, did you think that that was a case that could become part of your Ponzi scheme? A. No, I actually thought of it as a way to earn legitimate money to help me out of the Ponzi scheme. Q. So at the time you hired Mr. Edwards and you were talking to Adler about Edwards, you were trying to get out from under the Ponzi scheme? A. Inthe bulk of 2009 ] was praying for some sort of legitimate influx of money to get out of the Ponzi scheme. Q. Okay. So now Adler tells you about this Brad Edwards guy, did you know Brad Edwards before Adler talked to you about him? Had you run into him? A. J may have. ] don't have a specific recollection one way or the other. Q. Okay: So now hertells you that you should consider hiring Brad Edwards, this is your Page 96 co-conspirator talking to you, nght? Is that correct? A. Yes. Q. And he says, by the way, he's got this great Epstein case involving this billionaire, correct? A. Yes. Q. Presumably then-you had a meeting with Brad Edwards when you met him; is that correct? MR. SCAROLA: Presumably he had a meeting when he met him? MR. GOLDBERGER: I'm sorry, Mr. Scarola was cutting you off when you answered, so go ahead, answer again. MR. SCAROLA: | didn't understand the question. BY MR. GOLDBERGER: Q. Do you understand the question, Mr. Rothstein? A. I'm not sure ] do because you asked me if ] had a meeting when J met him and J think that meeting him is a meeting. Q. Well, there was a meeting, correct? A. I most hkely met him before I hired him. | most likely talked to him before I hired him because that was my general way of doing business. It's all Page 97 25 (Pages 94 to 97) FRIEDMAN, LOMBARDI & OLSON 305-371-6677 5ed93085-0554-447f-bcdd-ca2d8fe941df HOUSE_OVERSIGHT_017514

owt n woe Ww DN MM MMNMNFRFHFRP RPP RPRP RP OemwWwnrF OW DH RUB WNHH Ow Daan SF WN FE MONMONNNPPRP PEEP BE Bb mBWNHEFE OW DARE SB WNHE OW 25 together possible that ] gave Russ the okay to hire him before, 1] just don't have a specific recollection one way or the other. Q. At some point, | take it, you learned, whether you sat in on a meeting when Mr. Edwards was hired or whether your co-conspirator hired him, at some point you learned that Mr. Edwards, in fact, had been hired by the firm; is that correct? A. I'm certain that ] gave the final okay to hire him. Q. Okay. When you were giving the final okay io hire him, ] assume there had to be discussion of the money that he was going to be paid, correct? A. With somebody, yes. Q. Certainly with Mr. Edwards, right? I assume he wanted to know how much he was getting paid. A. Yes, but] don't have a specific recollection of whether ] discussed that with him or . whether ] authorized Adler or maybe even Rosenfeldt to discuss it with him. | don't recall. Q. Do you have the slightest idea how much money Mr. Edwards was paid when he first joined the firm, what his salary was? = A. J don't have an independent recollection. ~ Q. Generally someone like Mr. Edwards at his level of accomplishment and his age, you know what the general salary would have been at your firm? It didn't work that way. ] see. Tel] me how it worked. It's a case-by-case basis. Tel] me how it worked. Case-by-case basis. . And how did you make that determination on a case-by-case basis? A. Actual book of business, potential book of business, potentiality for growth, character, what he brought to the table, and obviously a function of how much money we had available at the time. Q. Okay. And you don't have any recollection of the machinations that occurred in determining what Mr. Edwards salary would be, correct? A. 1 do not. Q. But certainly one of the things you would consider would be the book of business, 1.e. the Epstein case, nght? A. I'm certain that ] did consider the Epstein case. Q. Do you know whether he brought any other book of business -- A. But I'm also certain it wasn't the only Q>O>ro> Page 99 Oo pBWNHOrF OW DWI DUBWNHrFP OW DAHA HBWN EH SHR GR EST ASS RE AST CL eae em EIN AR AR GE ERR ALANS WARES NM NM NHN NYFF RF RP RF RFP RPP HB factor 1 considered. Q. All right. Do you know whether he brought, in his book of business, do you know whether he brought any other cases to the firm other than the Epstein case? A. J] don't recall one way or the other. Q. Okay. Do you know whether your -- well, bad question, | won't ask that. Now, you've talked a lot about Ken Jenne here this morning. Was Ken Jenne part of your Ponzi scheme? A. No, sir. Q. Had nothing to do with it, right? A. That's correct. Q. Other than his having -- working for you as an investigator, he was not one of your co-conspirators, right? A. He didn't work for me as an investigator, he worked for me heading up our investigative division, heading up our internal security, heading up my personal security, and acting as a political advisor to me. Q. Okay. Did he serve any kind of investigative function at all, after all, he was a law enforcement officer at one point in his career? Page 100 A. I note that he assisted the other people at the firm that were doing the investigative work. ] don't know if he personally did investigative work. He may have. Q. Do you know whether Mr. Jenne, in his role as your advisor or your political consultant, do you know if he was involved in any kind of illegality, illegal wire tapping or anything like that while he was at Rothstein? MR. SCAROLA: Excuse me, ]'m going to object to the form of the question, vague and ambiguous. THE WITNESS: To my knowledge he was not. BY MR. GOLDBERGER: Q. To your knowledge, no? A. Correct. Q. Okay. You talked about having a bunch of fundraisers, I know you had a bunch of fundraisers that was kind of a deal at Rothstein. This was kind of a rock star Jaw firm, right? ] mean, you had lots of fundraisers, lots of parties, right? Was that the image you were trying to present? A. In reality that's the way we were. Q. Okay. A. A Jot of young lawyers having a good time, Page 101 26 (Pages 98 to 101) FRIEDMAN, LOMBARDI & OLSON 305-371-6677 5ed93085-0554-447f-bcdd-ca2d8fe94 1df HOUSE_OVERSIGHT_017515

trying to make money. : was a real case going on, but that within that ] would Q. And these young lawyers, would you consider : have to create some sort of fictions in order tose]. Mr. Edwards to be a young lawyer or a middle-aged : the fake product. lawyer? : Q. Okay. At the time that you decided to use A. Young lawyer. i the Epstein case as part of your illicit Ponzi scheme Q. Okay. Was he one of young lawyers that came : theme, I think you testified earlier today, when you to these fundraisers at your home? were in some dire straights, you needed an influx of A. J] don't recal] whether he was there or not. money, right? } recall] him being at some, but ] didn't know if he A. Yes. was at all of them. t Q. That's when you decided to use the Epstein Q. Okay. You do recall] him coming to some of i matters, correct? the fundraisers, though, correct? i A. Yes. A. I recall him being at my home. It may have : Q. Okay. And you knew, | assume, being the been for firm parties or other parties, it may have : Ponzi scheme mastermind here, that you needed to make been for fundraisers there. s sure that you had at least a working knowledge of the 16 Q. And that was during the time period that the i Epstein case so that you could answer questions to the Ponzi scheme was stil] going on, correct? 3 investors. I recognize that you left the room and gis A. Yes. H told them to look at it, but you had to some knowledge 19 Q. Did Adler ever the tell you about any : of the case, right? 20 discussions he had with Brad Edwards about the illegal | MR. SCAROLA: Counsel, that's a 21 __ part of the operations at Rothstein? é misrepresentation of what the earlier testimony was. 22 A. Can you reask the question, please? : ] object, no proper predicate. 23 Q. Sure. Sure. i MR. GOLDBERGER: Okay, let's g0 through the a24 Did Russell Adler ever tell you -- Russel] : whole thing again. 25 Adler is your co-conspirator, we've established that. MR. SCAROLA: No, you are not going to go Page 102, Page 104 Pek eore tee * MAUR OAR ET TARE RAM LC ee EE ha I te a Se a a AA EN aN EE ELE EEE ETRE arent ee saRerpanee sy Did Russell Adler in the furtherance of your conspiracy ever tell you he had discussed with Brad Edwards about the illegal activities at RRA? A. No. Q. Now, you testified when asked about whethei asked about whether the press -- if you were involved in asking the press asking the press to run with the Epstein story, you said something to the effect, "the way I was selling the Ponzi scheme it would be overkill.” 1 didn't understand your answer like you didn't understand some of my questions, so I'd like you to kind of tel] me what you meant by that. A. 1 was selling purportedly confidential settlements. Confidentiality was the hallmark of the Ponzi scheme, so too much publicity would have created a problem for me in the sale of what was supposed to bea completely confidential settlement. Q. J think what you are telling me, and] don't want to misstate what I think you are telling me, but is it true that you felt some publicity would be okay but too much would be counter to the purposes of the conspiracy. Js that a fair statement? A. The way J was thinking about it at the time this was going on was that some publicity would assist in establishing for the potential investors that there Page 103 through the whole thing again. Just because we have tolerated two lawyers asking questions, does not mean we are going to tolerate two lawyers asking the same questions. MR. GOLDBERGER: Your objection is noted. BY MR. GOLDBERGER: Q. Okay. So let's talk about your need to use the Epstein case to further your conspiracy. You needed an influx of money, did you not? A. Yes. Q. Okay. You decided to use the Epstein case for that purpose, right? A. Yes. Q. And in order to use the Epstein case, you were going to meet with the investors and pitch the Epstein case with the investors, correct? A. Yes. Q. And in an effort to pitch the case to the investors, you had to have some knowledge of the case, did you not? A. Some level of knowledge, yes, sir. Q. Okay. And in order to gain that knowledge, you spoke to your co-conspirator, Russell Adler; is that correct? A. That's one of the things ] did. DIDO RWNYE Peep hp 4 Oe WNHOF OW DWAIADO BF WHR DW DAAIRAU B® WYNY EE mw HM MH NH LH + canter rea eae ean eee ence at teat m8 IS EG NDE AY PATE RSA CHER UES AMEE TEE UN es 4 Page 105 27 (Pages 102 to 105) FRIEDMAN, LOMBARDI & OLSON 305-371-6677 5ed93085-0554-447f-bcdd-ca2d8fe941 df HOUSE_OVERSIGHT_017516

1 Q. Okay. And do you remember what Adler told 2 you specifically about the Epstein case that helped 3. you have a basis of information to sell it to the 4 investors? s) A. Other than him telling me that it was a 6 billionaire pedophile, other than him telling me about 7 the flight manifest, ] don't have a specific 8 recollection of what else he told me. g Q. Did you actually look at the flight manifest fl10 atsometime, Mr. Rothstein? 11 A. Yes, sir. 12 Q. And what was it about those flight manifests 13 _ that you felt would help you pitch the Epstein case to 14 the investor? 15 A. I don'tremember who specifically was on it, 16 but] remember it looking juicy. 17 Q. You don't know who was on it? #18 A. 1 don't recall. 19 Q. Did you add any names to that manifest at 20 any time? 21 A. J] had -- you mean physically write names on 22 there? 23 Q. Any way you want to interpret -- did you -- 24 not physically write any names on the manifest, but 25 did you tel] the investors that there were names on 1 the manifest that were actually not on the manifest? 2 A. | told the investors that there were other 3. people that appeared on manifests, ] don’t recall 4 whether it was that manifest or other manifests, and ! 2 got the names of those people from Russ Adler. 6 Whether or not they actually appeared on the manifest 7 or another manifest, ] do not know. 8 Q. What names did you get from Russ Adler? : A. Russ Adler told ms Bill Clinton flew on 10 Epstein's plane and that Prince Andrew flew on 11 Mr, Epstein’ s plane. 12 Q. And is it your testimony today that you fi3 never looked at the manifest to see whether Bill 14 — Clinton or Prince Andrew's name were really on the f15 manifest that you were going to use to pitch the [16 investors? 17 A. It was my understanding they didn't have all 18 the manifests. 19 Q. Okay. Did you ever ask for the manifests 20 that purportedly had the name of Bill Clinton or 21. Prince Andrew on it? Az A. 1 probably did, but I don't have a specific 23 recollection one way or the other. 24 Q. When you say you didn't have all the 25 manifests, were all the manifests in your office -- Page 107 Oe WNhNHr CUO DA nDUOBWNYPeEF OH DAA OB WN KF GAGGENAU RENO aE GENRES EY RTD ESE Ni AIC PSE OL RED RNR BE A ETM RIS OEE RMR NRG MRNAS SUT SMR AT TAM NAS SGU RAE PT RER ERE ROTRTIN OESTRONE ALARA RINT RN YI Ge ee Per NONNNNDNF PE PEP BEBE LO ALANAANNO 1 2 3 4 A 5 . 6 7 9 210 fl #12 #13 e14 & £15 £16 #19 221 122 $23 24 25 were all the manifests within the Jaw firm of RRA and you simply didn't have them in your office? A. Thave no idea one way or the other. Q. Okay. A. J] did not have them. Q. You were told by Russel] Adler that you didn't have -- that you physically didn't have all the manifests, correct? A. That's correct. Q. But you don't know whether they were in the building somewhere, these other supposed manifests? A. lThave no idea one way or the other. Q. You never asked for proof that Bill Clinton or Prince Andrew's name were on a manifest somewhere? A. ] didn't say that. 1 may very well have asked Adler or Ken Jenne to find the other manifests. Q. Were you ever shown a manifest with the name Bill Clinton or the name Prince Andrew on them? A. ] do not recall one way or the other whether ] saw that or not. ] remember Adler telling me about it and then me repeating that information to the investors based upon Mr. Adler's representations to me. Q. Now, you testified that you were told that the Epstein cases were "legitimate cases. Do you Page 108 remember that testimony you gave this morning? A. Yes. Q. And you remember your testimony that you were told they were legitimate cases by both Russ Adler and Brad Edwards, do you remember that? A. I never said that Mr. Edwards or Mr. Adler said, "Scott, these are legitimate cases." ] didn't question them as to their legitimacy. Q. You did testify that you talked to Brad Edwards about the Epstein cases; is that correct? MR. SCAROLA: No, counsel, that is a misrepresentation of the earlier testimony. MR. GOLDBERGER: No, it’s not. BY MR. GOLDBERGER: Q. Did you talk to Brad Edwards about the eps cases? I do not recall one way or the other. That_ was my prior testimony, that's stil] my ‘testimony. /. don't --1 do notrecall. Q. We'll Jet the record speak -- A. I know] spoke to Adler about it. Q. We'll let the record speak for itself. Your testimony, as ] am questioning you now, is that you do not recall whether you spoke to Brad Edwards about the Epstein cases; is that correct? i! Page 109 28 (Pages 106 to 109) FRIEDMAN, LOMBARDI & OLSON 305-371-6677 5ed93085-0554-447{-bcdd-ca2d8fe94idf HOUSE_OVERSIGHT_017517

A. If you are including within that me walking past Brad in the hall] and saying, "Hey, Brad how are you? How is the Epstein stuff going?” Then it's very likely that | talked to him about it in that manner. But I have no specific recollection one way or the other as to having any lengthy conversations with Mr. Edwards about the case. ] had a co-conspirator who was deeply involved in the Ponzi scheme that ] could go to to get any information ] wanted, Mr. Adler. ] didn't need to go to Mr. Edwards. Q. So if you had a question of your co-conspirator, Russell Adler, about the Epstein case, you would go ask Adler and would Adler always have the answer for you or would he say he would get you the answer? A. Both. Q. When he didn't have the answer, do you know who he was getting the answer from? MR. SCAROLA: Objection, predicate. THE WITNESS: J don't know who he was getting it from and ] may have contacted other people in the office who were working on the file to ask. J may have asked Mr. Jenne, ] may have asked Ms. Holmes, ] many have asked a whole myriad of people. Page 110 BY MR. GOLDBERGER: Q. So Ms. Holmes was working on the Epstein cases? A. It's my refreshed recollection from seeing one of those e-mails that she must have been. Q. Okay. And Ms. Holmes you said was a former federal law enforcement officer, was that your testimony? A. Yes. Q. You don't know whether she was FBI or IRS, correct? A. J don't remember. Q. Okay. And upon reflection, do you know whether she was hired without your say-so based on what Mr. Jenne told you or did you meet with her? A. No, | actually -- 1 remember meeting with Ms. Holmes. Q. Okay. What do you remember about that meeting? A. | remember talking about her relative who was a judge. ] remember her telling me about her time in law enforcement. J just don't remember which agency. Q. Did she tell you why she left law enforcement? see Oran oe WM HP vga og AAU EL et age eae eae gen ames cae SA aR a ep aR ea ray KI 1 1 2 3 4 5 6 7 8 9 0 1 2 3 4 5 6 4 8 ) 0 1 2 2 4 5 1 bl 1 1 pl al a1 1 pi fl 2 (2 b2 2 £2 2 ea QU DuaNN NNN mE RRS G SE FAM ARE SRE UR OS ena I se ER pet a NE EN AMER PEE EMSA GA TN PSS UTE A. She may have, | don't recal] one way or the other. Q. Did you ever ask Ms. Holmes to use any of her prior contacts in law enforcement to assist you in the Ponzi scheme to get information for you? A. The question is kind of convoluted because the way you are asking it, it seems like you are intimating that Ms. Holmes knew. I may have asked Ms. Holmes to get me information that ] was going to utilize with my co-conspirators in the Ponzi scheme, but Ms. Holmes did not know that there was a Ponzi scheme going on. Q. All right. So you may have asked Ms. Holmes to try and get some information for you from her contacts in law enforcement, but it's your testimony, and ] don't dispute it, it's your testimony that she knew nothing about the Ponzi scheme, correct? A. ] may have, ] may not have. | do not remember and she absolutely knew nothing about the Ponzi scheme. Q. Okay. Now, we talked about Brad Edwards getting paid and the multilevel ways in which you determined what a person's salary was. Do you know whether Brad Edwards got any bonuses along the way once the Epstein case was used as part of the Ponzi Page 112 scheme? A. He did not. Q. So he was -- A. If he got a bonus, it was something he eared. Q. Did you make a determination as to what that bonus would be? A. Ifhe got a bonus, ] would have been instrumental in determining it. You can determine if he got a bonus by looking at our financial records, 1 don't have an independent recollection one way or the other. Q. So you don't know whether he got a bonus at all, correct? A. That's correct. Q. Sol assume that if he got a bonus you wouldn't know whether it occurred before or after the Epstein case was used as part of the Ponzi scheme? A. 1] don't know if he got a bonus, which means ] wouldn't know the time frame. Q. But we would learn -- you are instructing us, we would learn that by looking at when the Epstein case was brought into the Ponzi scheme and we learn that by looking at these -- what was the group that it was used to pitch to? Page 113 29 (Pages 110 to 113) FRIEDMAN, LOMBARDI & OLSON 305-371-6677 5ed93085-0554-447f-bcdd-ca2d8fe941 df HOUSE_OVERSIGHT_017518

Ort nD oO SF Ww DH bP A. Clockwork. Q. So we would look at when the Clockwork group was brought into this and the Epstein case was used then and then we would look at the payroll records to see whether Mr. Edwards got a bonus after the Clockwork group was brought into the Ponzi scheme, correct? A. From a timing perspective, yes. But Mr. Edwards had nothing to do with the Ponzi scheme, nor was he rewarded even surreptitiously without his knowledge for he helping me with the Ponzi scheme. If he was rewarded it was because he deserved, ] felt he deserved a reward, having 2 nothing to do with the Ponzi scheme. The bulk of this law firm had nothing to do ‘with the Ponzi scheme, Q. 1] think you testified already, though, that money was fundable in the firm, right? ] mean, you know, illegal money was used for legitimate purposes, correct? A. Yes. Q. Okay. So, for example, investigations that were done with the Epstein case, it's very possible that legitimate Ponzi money was used to finance those investigations? A. I'd be guessing. It's certainly possible Page 114) en ee because all the money went into a whole series of pots, and if you look at, most of the pots were trust accounts. If you look back, you look to see what my CFO, who was also a co-conspirator was doing, she was pulling the money from wherever she needed to to fund whatever she needed to fund. MR. LAVECCHIO: Off the record a second. [Discussion off the record.] BY MR. GOLDBERGER: Q. Let me circle back to what you needed to learn about the Epstein cases to help make your pitch to the investors. You talked about the manifest already, correct, the flight manifest? A. Yes. Q. Okay. What else did you want to learn about the case or what else did you learn about the case so that you were conversant when you spoke to the investors about the Epstein case? A. |] recall asking someone what the causes of action were. Q. Okay. Did you understand what they were? A. J likely did at the time, ] don't remember what they were now. Q. Okay. Do you know which case we are talking Page 1156 wort nm fF WNP lO © NM PM MH NH NM FSF Ft SSE REESE ATES RO EO I GGT GE RRA MRR a EN at po pe yo i Oe WN EF O ves ~y i WF BWUNHrFOCOMHWU MATA OSPWNEF OW DWAIHADTSBWNEH eareguesannmenninern are ttaneeaanereeretee ceasaiy ieee ee we resemraman pmeR eS RRR TS ht RS MEMES MINS AGAMA RRS ASR ER RE NR ANPP PRI PR ON AEN NNONNNNEFPHPRPRP EPP PPB about? By the way, you had a number of Epstein cases in-house, do you know which case you were talking about? A. As] sit here today, no, sir, ] don't remember. Q. Was it a state case or a federal case? A. J don’t remember one way or the other. Q. All right. A. Jutilized all those boxes all together. ] don't remember which one |] sold them. Q. And the exhibits -- A. It's something completely fictitious that J made up that ] told them. Q. The exhibit that you were shown earlier, Exhibit Number 1, that's the long multi-page federal lawsuit. Do you know whether that was part of the information that you reviewed or shown to the investors when you were pitching to them? A. J] donot remember one way or the other. Q. Okay. Now, did you make any effort to learn from your co-conspirator who the plaintiffs were in this case, what kind of women they were? A, Only that they were underage. Q. Did anyone tell you that these women had -- some of these women n had a history of p a history of prostitution? Page 116] A. They may have told me that, 1] wouldn't have cared one way or the other, Q. Why would you not have cared about that, Mr. Rothstein? A. Ithad nothing to do with the sale of the Ponzi scheme settlements. Q. Okay. Were you told by anyone whether any of the women involved as plaintiffs in the case may have worked at adult clubs in the past? I mean strip clubs, let's call it what it is. A. | may have been told that one way or the other. But again, it had nothing to do with the Ponzi scheme sale of fake settlements. Q. As part of the information that you were told by you co-conspirator, Russel] Adler, were you told that some of the plaintiffs that you had in-house had travelled on Mr. Epstein’s airplane? A. I believe Russ did tel] me that. Q. You know, in fact, that that was not true, correct? A. Ihave no idea one way or the other, nor did ] care. Q. But your co-conspirator told you that, right? A. Mr. Adler did, in fact, tell me that certain Page 117 30 (Pages 114 to 117) FRIEDMAN, LOMBARD] & OLSON 305-371-6677 5ed93085-0554-447f-bedd-ca2d8fe941 df HOUSE_OVERSIGHT_017519

OAD O DWN of the underage women had travelled on Mr, Epstein's plane, Q. Did you ever meet any of the plaintiffs? MR. SCAROLA: That's question that's been asked and answered. THE WITNESS: | do not have a specific recollection of ever meeting them. MR. SCAROLA: You are exhausting my indulgence. MR. GOLDBERGER: Fair enough. MR. SCAROLA: You've exhausted my indulgence. BY MR. GOLDBERGER: Q. Do you know whether any of your investigators at the firm had any kind of high tech surveillance equipment or, you know, wire tapping equipment? A. I] believe they did. Q. Do you know whether this was legal stuff or illegal staff? A. J] did not know, nor did ] care. Q. Do you know if any of that stuff was used to elther wire tap or surveil Mr. Epstein? A. Ido not know one way or the other. Q. What sort of equipment did you know that ee nan OTTER RAR EY OB WME THU MAINA YOBWNHErR TU DAIA NB WN BH NMONMMNNMNF RPE ee PPE have any knowledge of your firm's attempt during the Ponzi scheme to depose Alan Dershowitz? A. No, sir. ] don't have a recollection of one way or the other. Q. Okay. The name Kendall Coffey was brought up before. Do you know who Kendall Coffey is? A. Yes. Q. Who do you know him to be? A. Former U.S. attorney, current criminal defense lawyer. Q. Was he a friendship of the firm's? A. Represented RRA when I fled the country. Q. So he was a friend of the firm, or a friend of yours at least, right? A. He wasn't a friend of mine. Q. A friend of the firm? A. No idea. Q. He represented them when I fled the country. l remember him coming in and doing like a show and tell in my office on TV. MR. GOLDBERGER: Patience gets rewarded. I'm done. Thank you, Mr. Rothstein. That's all the questions that ] have. THE WITNESS: You are welcome. Page 120 ILS Sh i oat aay they had, meaning your investigators? A. J had told Mr. Jenne and others involved in the investigation arm of RRA to get whatever equipment they thought they needed and to get the best stuff that they could get. What they actually did, I can't tell you. Q. You know as part of the Epstein litigation, and J'm talking about now after your using it in the Ponzi scheme, do you know whether anyone at your firm attempted to depose ex-President Bill Clinton? A. 1 don't recall that, sir. Q. Okay. How about Donald Trump, same question? A. | don't recal] that. As a matter of fact, we had represented Trump in some things, we had some pretty close ties with him, so 1] can't imagine that they would have done that with my authority. Q. Okay. A. 1 don't recall that. Q. Do you know whether Adler would have -- would Adler have the authorize to do that without getting your permission? A. The authority, no. Might he have tried, yes. Q. Okay. How about Alan Dershowitz, do you a & : : i i A i : | : Ei : i & MOF OW WAI aA UO S® WN EE a Ww he) co) NBM NR eRe NEE ST CROSS EXAMINATION BY MR. SCAROLA: @. Mr. Rothstein, again, Jack Scarola on behalf of Brad Edwards. _] want you to assume that Brad has testified under oath that you never had a substantive discussion with him regarding the Epstein case. Do you have any basis whatsoever to question the accuracy of that testimony? A. ldo not. Q. | want you to assume that Brad has or will testify under oath that while you were copied on neeting regarding the legitimate prosecution of the Epstein cases. Do you have any basis whatsoever to question the accuracy of that testimony? A. No, sir, Q. 1 want you to assume that Brad has or will testify under oath that you never directed the filing of any documents in the Epstein case, including the July federal] complaint that's been marked as an exhibit to your deposition. Do you have any reason whatsoever to question the accuracy of that testimony? A. No, sir. Q. | want you to assume that Brad has or will testify under oath that you never directed the taking Page 121 31 (Pages 118 to 121) FRIEDMAN, LOMBARD] & OLSON 305-371-6677 5ed93085-0554-447f-bcdd-ca2d8fe941 df HOUSE_OVERSIGHT_017520

ara ana ons WNP INO PE NO UE NO NOE OE NO i a Ow wnrF OW OTHE BWDHHE COW rFPoOowWwWmnA DO SB WN FE oe t Ww DR NNMNNNNNPFPFPRP EP RP RF EB Oe WrhyrPreowwmnonnrntA nan uw of a single deposition, or the propounding of any discovery in the Epstein cases. Do you have any i reason to doubt the accuracy of that testimony? A. No, sir, Q. l_want you. to assume that Brad has or will testify that you did not provide any input whatsoever into the handling of the Jegitimate Epstein cases. Do you have any reason whatsoever to doubt the accuracy of that testimony? A. No, sir. Q. |] want you to assume that Brad has or will 2 ENE YOU 10 eee at 2rd he we testify that you never met any of the legitimate plaintiffs in the Epstein cases. Do you _have a reason to doubt the accuracy of that testimony? A. No, sir. MS. HADDAD: ]'m going to object to these same questions you keep asking, because Mr. Rothstein has testified at nauseam that he doesn't recal] any of this and now you are asking him to bolster Mr. Edwards’ either already given or purported 4 testimony when he's testified he doesn't recall it. : BY MR. SCAROLA: | Q. | want you to assume that Brad has or will testify under oath that you never asked him once to report back to you on any factual matters repardi Page 122 " the Epstein case. Do you have any reason to doubt the accuracy of that testimony? A. No, sir. Q. 1] want you to assume that Brad has testified repeatedly that he had absolutely no involvement i in or ‘Knowledge of an ie il activity d any other RRA la Do you have any 1 reason to doubt the accuracy of that testimony? A. No, sir. Q. J want to talk to you briefly about your personal perceptions of the significance of the testimony that you are giving today. If Brad Edwards had, in fact, been a participant in any of the illegal ‘activities that you have been questioned about at any stage of this very lengthy deposition. and you knowingly concealed Brad Edwards’ participation, what do you understand the personal consequences to be as a conset q uence of your having knowingly concealed Brad Edwards participation? A. I'l] be violating my agreement with the United States government and ] would run the risk of dying in prison, Q. If Brad Edwards, contrary to what you have testified under oath and what Brad himself has repeatedly said, knew about anything having to do with Page 123 santero rast ES PRR cE TT GEN AN USOT SEN SASS SRA U HG SHAE ORR ARR OB PEND Ea seater emcee conseUenees of that false testimony to be to be? A. J'll be violating my agreement with the United States government and ] would run the risk of. dying in prison, MR. SCAROLA: Thank you. | don't have any further questions. THE WITNESS: Thank you, sir. MR. NURIK: Mark, 1 don't know what your time frame is on your hitigation, but the ability to receive the transcript, review it and prepare an errata sheet within what is normally the time allotted under the court rules cannot be accomplished in this case. MR. GOLDBERGER: How much time are you generally -- MR. NURIK: | don't know. Actually, the first set of errata sheets have just been prepared and finalized for the first deposition in December. I'm not suggesting it will take that long this time, but if you can give me an idea of what your time responsibilities are with the court, what the time limits are -- Page 124 moreno MR. GOLDBERGER: Do you think it will be less than a month, two months? MR. NURIK: J don't think it will be jess than a month. First of all, a lot depends on the ability to get the transcript to him to review. MR. GOLDBERGER: Right. MR. NURIK: And that's a whole procedure, it's not normal circumstances that we are dealing with. MR. GOLDBERGER: If time becomes an issue, we'll approach you and ask you to expedite. MR. SCAROLA: Mark, ] will tell that from our perspective time is an issue. MR. NURIK: Have at it then, Jack. Do what you need to do to get it done. MR. SCAROLA: There is a long pending motion for summary judgment on Brad’s behalf that has been delayed for purposes of taking this deposition. We are very anxious to be able to call that motion for summary judgment up for hearing, so whatever can be done reasonably to expedite the preparation of this portion of this transcript would be appreciated. We understand there are limitations beyond your control, but to the extent you can do it, that would be helpful. Thank you. Page 125 32 (Pages 122 to 125) FRIEDMAN, LOMBARDI & OLSON 305-371-6677 5ed93085-0554-447f-bcdd-ca2d8fe941 df HOUSE_OVERSIGHT_017521

ODO WDMDATAHAYBWNHEH hb 10° 11 42 MS. HADDAD: It's scheduled in a month, Mark. MR. NURIK: We'll cooperate. MR. SCAROLA: Thank you very much. [Thereupon, the taking of the deposition was concluded at 12:37 p.m.] SCOTT ROTHSTEIN Sworn to and subscribed before me this day of , 2012. Notary Public, State of Florida at Large. Page Sa epee EID RE A NT CERTIFICATE STATE OF FLORIDA _) COUNTY OF MIAMI-DADE) J, Pearlyck Martin, a Notary Public in and for the State of Florida at Large, do hereby certify that, pursuant to a Notice of Taking Deposition in the above-entitled cause, SCOTT ROTHSTEIN was by me first duly cautioned and sworn to testify the whole truth, and upon being carefully examined testified as is hereinabove shown, and the testimony of said witness was reduced to typewriting under my personal supervision and that the said Video Conference deposition constitutes a true record of the testimony given by the witness. ] further certify that the said Video Conference deposition was taken at the time and place specified hereinabove and that ] am neither of counsel nor solicitor to either of the parties in said suit nor interested in the event of the cause. WITNESS my hand and official seal in the City of Miami, County of Dade, State of Florida, this day of June 19, 2012. Pearlyck Martin FRIEDMAN, LOMBARD] & OLSON 2 Suite 924, Biscayne Building 19 West Flagler Street 3 Miamu, Florida 33130 Telephone (305) 371-6677 June 21, 2012 IN RE: EPSTEIN VS EDWARDS SCOTT ROTHSTEIN C/O MARC NURIK a One East Broward Boulevard, Seventh Floor Ft. Lauderdale, Florida 33301 Dear SCOTT ROTHSTEIN: With reference to the deposition of 10 yourself taken on June 14, 2012. in connection with the above-captioned case, please be advised that the 11 isanscript of the deposition has been completed and is awaiting signature. Please arrange ta stop by our office for 13 the purpose of reading and signing the deposition. Our office hours are 9:00 a.m, to 4:00 p.m., Monday 14 through Friday. Please telephone in advance 5 You may. however, read a copy of the transcript, provided by any of the attorneys 16 connected with the case, denoting any corrections by page and line number on a separate sheet of paper. 17 This correction page must be signed by you and notarized and returned to us for filing with the Es EP 5 S L 18 original 19 If this has not been taken care of, however, within the next 30 days, or by the time of 20 trial, whichever comes first, I shall then conclude that the reading, subscribing and notice of filing 21 have been waived and shall then proceed 10 deliver the original of the transcript to ordering attorney 22 without further notice. 25 Pearlyck Martin Page 128 | 33 (Pages 126 to 128) FRIEDMAN, LOMBARDI & OLSON 305-371-6677 5ed93 085-0554-447{-bcdd-ca2d8fe941df HOUSE_OVERSIGHT_017522