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1 A. No.
2 Q. Who is Cara Holmes?
3 A. Who is who?
4 Q. Cara or Cara, C-a-r-a, Holmes?
5 A. To the best of my recollection, she was a
6 former FBI agent or maybe IRS agent. I don't know.
7 She was a former federal agent.
8 Q. Did you hire her to work for you?
9 A. It was either IRS or FBI.
10 Q. Did you hire her to work for you?
11 A. Yes, I hired her at the suggestion of Ken
12 Jenne.
13 Q. For what purpose?
14 A. To work in the group that he was overseeing.
15 Q. So what did she do for RRA while she was
16 there?
17 A. I don't remember.
18 Q. Did you ever mention her to your potential
19 investors from the Clockwork group?
20 A. It's a possibility because, as I was
21 building the Ponzi scheme, I frequently referred to
22 the fact that we had former state and federal law
23 enforcement working for us and on our investigative
24 teams. It added legitimacy to the Ponzi scheme.
25 Q. Didn't you tell investors that she could
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1 hack into a computer as part of her skills?
2 A. I certainly may have. I told the investors
3 a whole host of lies about what was going on about
4 with case and what people could do and did do.
5 Q. Did you ever personally utilize Cara Holmes'
6 skills in any of your cases?
7 A. I don't remember.
8 Q. Were you handling any cases during the 2009?
9 A. I was overseeing cases in 2009, but my
10 involvement was mostly supervisory. I was handling
11 very little that was legitimate at that point in time.
12 Q. Were you legitimately, when I say
13 "legitimately," were you invited into Q-task on any
14 particular cases that you can recall?
15 A. I'm certain I was. I don't recall one way
16 or the other.
17 Q. Do you recall if you were involved in
18 Mr. Epstein's case on Q-task?
19 A. I may very well have been, but I don't have
20 a specific recollection one way or the other.
21 Q. Do you know who invited you in?
22 A. I have no idea if I was invited in. And if
23 I was invited in, I have no idea who invited me.
24 Q. Once you decided to use this case in your
25 Ponzi scheme, did you go into Q-task to look at the
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1 case or any communications --
2 A. I may have.
3 Q. Do you recall when that --
4 A. I may have.
5 Q. Do you recall when that may have happened?
6 A. I do not.
7 Q. Do you recall the first time you looked at
8 the flight manifest to which you referenced earlier?
9 A. Prior to the investors coming in. I don't
10 remember the date.
11 Q. Did you instruct anybody, to further your
12 Ponzi scheme, to investigate or check into anyone
13 whose name was listed on the flight manifest?
14 A. I may have, but with this clarification. If
15 I instructed someone to look into something, I did it
16 without that person knowing that I was involved in a
17 Ponzi scheme or that what they were doing was illegal
18 and it was just to get me additional information to
19 help with my sale of the fake settlements.
20 Q. So it was to further your --
21 A. So I may have asked someone -- I may have
22 asked someone to get me some additional information,
23 but as I sit here today, I don't recall ever asking
24 anyone to do anything on the file that was for the
25 purpose of furthering the Ponzi scheme, other than
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1 perhaps getting me a piece of information that I
2 needed.
3 Q. I'm going to try to refresh your
4 recollection as to whether or not you attended those
5 meeting in July of 2009. And it appears that in
6 between the dates of July 22nd, 2009 and July 24th,
7 2009, there was a number of communications through
8 e-mail by and between yourself, Mr. Adler, Brad
9 Edwards and Ken Jenne regarding an Epstein meeting
10 that was going to be taking place. Do you remember
11 that at all?
12 A. I think what you are referring to, and I'm
13 not certain, but I think that what you are referring
14 to is me making sure that the file was in the
15 condition in which I wanted it at the time the
16 investors were coming in. I don't think it had
17 anything to do with the actual functioning of the
18 Epstein case. I think it had to do with my
19 illegitimate purpose. That's the best of my
20 recollection, but if you have documents or something
21 that you can show me, that would be helpful.
22 Q. We are not privy to all of the e-mails
23 because they've been alleged as privileged or work
24 product, so I unfortunately can't show them to you.
25 But according to the privilege log between
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FRIEDMAN, LOMBARDI & OLSON
305-371-6677
5ed93085-0554-447f-bcdd-ca2d8fe941df
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