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1 A. I talked to Russ Adler. I may have talked
2 to some of the other lawyers. I flipped through
3 certain boxes in the file.
4 Q. How did you get the boxes?
5 A. I asked someone to bring them to me.
6 Q. Do you know where those files were stored?
7 A. I do not.
8 Q. So you flipped -- sorry, please continue.
9 Flipped through some files?
10 A. I flipped through some files. I had the
11 files in my office. The day that the investor group
12 came in, I actually had Ken Jenne and some others
13 actually bring me some more of the boxes actually into
14 my office while the investors were there. I already
15 had some of the boxes with me.
16 Q. You say "Ken Jenne and others," who were the
17 others to whom you are referencing?
18 A. I don't specifically recall who carried them
19 in. I was very focused on my investors at that time.
20 Q. Were any of the lawyers present with you
21 when you were meeting with these investors?
22 A. During the actual meeting with them, no. I
23 recall that some of the lawyers may have met some of
24 the investors, but I don't recall who.
25 Q. Do you recall approximately when that

Page 39
1 happened?
2 A. No, it's the same dates that I was giving
3 you before.
4 Q. Okay. So you had, to further your Ponzi
5 scheme, you had to familiarize yourself with this case
6 so that you could speak intelligently with the
7 investors; is that correct?
8 A. Well, sort of because most of what I told
9 the investors was all things that I was creating as I
10 went.
11 Q. About this particular case, the Epstein
12 case?
13 A. Yes, from an investor -- you have to
14 understand how the inner working of the Ponzi scheme
15 were crafted but --
16 Q. Please tell me then.
17 A. I'm telling you -- hang on. From an
18 investor's standpoint, the investor is simply looking
19 for is the case believable. And once they get past
20 that, is it of such case -- excuse me, is it of such a
21 nature that it is possible to be generating a
22 significant amount of settlement dollars. And then
23 after that, their concern is simply on the due
24 diligence side of making sure we actually have the
25 money, that the documents pass -- the documents

Page 40
1 unrelated to this case, documents related to the
2 settlements. Other than proving the existence of the
3 case, there's very little an investor, at least from
4 my end, investigates into the actual case. It was
5 more after having the case exist and not caring about
6 really what was going on in the case other than a lot
7 of money was going to be collected.
8 Q. Well, with respect to showing them that the
9 case existed and that there was a likelihood of a
10 possibility of a payday at the end, how did you
11 convince them of that? What did you use to convince
12 them of that?
13 A. I did two main things. One, I put the boxes
14 in my office while they were there. I told them to
15 specifically look at a couple of sheets of a flight
16 manifest that was in the file that Russ had shown me.
17 And I told them that it would be a breach of
18 attorney/client privilege for them to look at the
19 file, but that I was going to step out for a while and
20 leave them there with the boxes, wink, wink, and
21 that's what I did. I stepped out, I let them look at
22 whatever they wanted to look at. I came back in, they
23 were satisfied that it was a real case and I was off
24 and running.
25 Q. And these were the real legitimate files for

Page 41
1 this case; is that correct?
2 A. These were the legitimate files, yes.
3 Q. Nothing had been created at this time for
4 them to look through?
5 A. I didn't add anything to the case files.
6 The case files were significant enough by themselves.
7 Q. Do you know how long they were in your
8 office; days, weeks?
9 A. The people or the boxes?
10 Q. The boxes.
11 A. The boxes were in there probably a little
12 more than a week. I don't have a specific
13 recollection.
14 Q. Okay. Did you ever go through them?
15 A. Yes, I flipped through them at some point in
16 time.
17 Q. And what do you recall about what you saw in
18 the cases? Do you remember anything?
19 A. I remember seeing the flight manifest. I
20 don't recall seeing anything else. I'm sure I looked
21 at other things, but again, for my purposes it was
22 insignificant to me because the actual content of the
23 boxes was not necessary in the sale of the fake
24 settlements.
25 Q. Why was the flight manifest so interesting

11 (Pages 38 to 41)
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