HOUSE_OVERSIGHT_017505.jpg

Page 58
1 July 22nd and 23rd there were numerous e-mails sent
2 about the meeting. It was almost an all-hands-on-deck
3 type meeting where everybody needed to attend. It was
4 labelled the Epstein meeting with an Epstein
5 conference room reserved.
6 A. Yes.
7 Okay. What's your question and I will tell
8 you.
9 MR. SCAROLA: First I'm going to object to
10 counsel's testimony, but let's hear the question.
11 BY MS. HADDAD:
12 Q. The question is, does that refresh your
13 recollection as to whether or not this meeting took
14 place?
15 A. To the best of my recollection, I actually
16 had introduced some of the investors to some of the
17 people working on the Epstein case, and that is likely
18 the meeting that you are referring to. But for the
19 life of me, I don't have a specific recollection of
20 it.
21 Q. But it could be the meeting where you
22 introduced the Epstein litigation team to your Ponzi
23 investors?
24 MR. SCAROLA: Excuse me, I'm going to
25 object to the form of the question. It misstates the

Page 59
1 prior testimony. It has no predicate.
2 BY MS. HADDAD:
3 Q. That could have been the meeting in which
4 you introduced the Ponzi investors to people working
5 on the Epstein case?
6 MR. SCAROLA: Excuse me, counsel. The
7 testimony was that there may have been a meeting at
8 which investors may have been introduced to some
9 people working on the Epstein file. And your efforts
10 continuously to mischaracterize the prior testimony
11 are highly improper. I object.
12 BY MS. HADDAD:
13 Q. Scott, did you or did you not say that you
14 introduced some of the investors to some of the
15 lawyers on the Epstein case?
16 A. No, I actually said, Tonja, that I may have.
17 I have a recollection that I may have based upon you
18 just refreshing my recollection, but I just do not
19 remember one way or the other. This was, in the
20 scheme of what I was doing, insignificant. I was
21 simply trying to establish to the investors that this
22 was a real case, with real potential, with real
23 lawyers working on it. Other than that, it was of no
24 interest to me.
25 Q. How else would you convince them? You've

Page 60
1 mentioned letting them look through the litigation
2 boxes, you've mentioned the meeting. What other way
3 would you have convinced them that it was a real case?
4 A. I mentioned letting them look at boxes, what
5 they did when I was out of the office, that's -- I
6 don't know because I couldn't see what they were
7 doing. Number two, I may have introduced them to
8 people in the office. Number three, I'm certain that
9 when the people brought the boxes to my office I
10 introduced them to whoever was carrying the boxes.
11 And number four, the rest of it would have been all
12 stuff I created in my imagination because, again, it
13 was the sale of something that didn't exist. This was
14 not settling. There was no real settlement money.
15 There were no real settlement documents. I even
16 manufactured, I think, the actual plaintiff, because I
17 don't recall even knowing the plaintiff's real name or
18 if I did it was of no significance to me.
19 Q. How would you have manufactured a
20 plaintiff's name, would you have created additional
21 documents to further your Ponzi scheme using
22 Mr. Epstein as the defendant?
23 A. No.
24 Q. How would you --
25 A. The name just would have appeared on the

Page 61
1 confidential settlement agreement.
2 Q. Would they have already seen the documents
3 at that point?
4 A. I can't tell you one way or the other what
5 they had seen, because I don't know what they actually
6 looked at.
7 Q. Forgive me, you've now confused me so I'm
8 just going to ask you for some clarification.
9 You used a legitimate case and created fake
10 settlement documents, correct, in the simplest sense?
11 A. If this culminated in an actual sale of a
12 fake settlement, then the answer is yes.
13 Q. So it was a real case with a real plaintiff
14 and real defendant, just a fake settlement document?
15 A. No. Let me see if I can clarify this for
16 you. Over 90 percent of the settlements that I sold,
17 the fake settlements, were completely fictitious?
18 Q. Right.
19 A. A very small percentage of them were based,
20 at least in part, on some type of real litigation that
21 either had occurred or was currently occurring. I
22 utilized the Epstein case to bolster the visual for
23 the investors that a real case existed. Because as
24 these were being sold to more sophisticated investors,
25 the questions kept coming up, was there -- how do we

16 (Pages 58 to 61)
FRIEDMAN, LOMBARDI & OLSON
305-371-6677
5ed93085-0554-447f-bcdd-ca2d8fe941df
HOUSE_OVERSIGHT_017505