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Page 74
1 A. What does it say? Say it again.
2 Q. It says, "The first deposition occurred on
3 July 27th," correct?
4 A. Yes.
5 Q. Some three days after the federal complaint
6 was filed, correct, that we referenced earlier?
7 A. That's correct.
8 Q. And Paragraph 6 clearly delineates that in
9 August 2009 a phone call was received by the
10 cooperating witness that explained that this
11 Mr. Rodriguez had a list of other purported victims or
12 contact information for people who Mr. Edwards could
13 also potentially bring lawsuits for -- on behalf of;
14 is that correct?
15 A. I don't know one way or the other. You
16 know, Tonja, just so this record is clear, you know,
17 as I'm sitting here, I have a vague recollection of
18 perhaps Ken Jenne coming, talking to me and telling me
19 that someone in my office was going to cooperate with
20 someone in this investigation. But for the life of
21 me, I can't be certain of that. So much time has
22 passed, but as I'm reading this, and it could be
23 completely unrelated to this, I just want to make sure
24 the record is a hundred percent clear, it's possible
25 that Ken Jenne discussed that with me, but I don't

Page 75
1 know who it was.
2 Q. You are testifying that you didn't know it
3 had anything to do with the Epstein case, as you sit
4 here now, you don't remember?
5 A. No, no, I don't have a specific
6 recollection, and I want to just make sure so I answer
7 all your questions completely, is that as I'm sitting
8 here my recollection was refreshed that I have a vague
9 recollection of having a conversation with Ken Jenne
10 about the fact that someone in our office was going to
11 cooperate as a confidential informant for some law
12 enforcement agency, I just can't remember if it was
13 the Epstein case or not.
14 Q. Do you recall what you said to Mr. Jenne
15 about that?
16 A. No. What I just related to you is all I
17 remember. And I'm not even sure it had anything to do
18 with this.
19 Q. Who's Wayne Black?
20 A. Who?
21 Q. Wayne Black.
22 A. Sounds like the name of someone I hired, but
23 I could be mistaken. I don't recall.
24 Q. Okay. You don't recall ever meeting
25 Mr. Black?

Page 76
1 A. I may have. I don't recall one way or the
2 other. You have something that might refresh my
3 recollection?
4 Q. Do you know what he does for a living?
5 A. I do know the name. Sounds familiar to me,
6 but I can't recall one way or the other who he was or
7 what he did.
8 Q. Did you instruct your office to begin
9 investigating Mr. Epstein's pilot or his airplanes?
10 A. I do not recall one way or the other.
11 Q. You did testify that the flight manifest was
12 the one document you recall for sure looking at in
13 Mr. Epstein's case; is that correct?
14 A. Yes.
15 Q. And if it did, in fact, contain the names
16 that you are purporting that it claimed or that you
17 knew of, that would be something that would be juicy
18 for the investors to further your Ponzi scheme that it
19 was a collectible case; is that true?
20 A. I'm sorry, you have to repeat the question,
21 Tonja. I don't understand what you just asked me.
22 Q. If these big names were on this list, as you
23 seem to recall they were, that would be most helpful
24 to you and your Ponzi scheme investors in convincing
25 them it was a big case, right?

Page 77
1 A. If they were on there, or if I lied to them
2 and told them they were on there, or if Adler told me
3 they were on there and I repeated, all those things
4 would have been helpful to the Ponzi scheme.
5 Q. You stated earlier that you -- the only
6 thing you looked at was the flight manifest because
7 you were told to look at it. Is that still true?
8 A. That's not what I testified to. I testified
9 that I flipped through other parts of the file and
10 that I didn't remember what I had flipped through. I
11 remember looking at the flight manifest because
12 Mr. Adler told me about it.
13 Q. You said that you met these investors in
14 your office, but there were no cameras in your office,
15 correct?
16 A. I didn't have cameras specifically in my
17 office.
18 Q. You had these investors in your office for
19 this particular Epstein case?
20 A. Yes.
21 Q. Do you recall if it was during work hours or
22 after work hours?
23 A. I do not recall.
24 Q. Typically when you were meeting with your
25 potential Ponzi investors, did you meet them during

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