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[Page 18]
1 unfortunately, you are taking a little tiny spot out
2 of a very, very busy time period in my life and in the
3 life of the firm, so I can't tell you one way or the
4 other.
5 Q. I know you had a lot going on, I'm just
6 trying to see if you remember anything specific about
7 this.
8 Do you recall what salary you had offered
9 Brad to join the firm?
10 A. I do not. You have to just try to
11 differentiate that what I knew then is a lot different
12 than what I know now so ...
13 Q. Meaning?
14 A. Obviously meaning that at the point in time
15 that I was hiring him or maybe a year after, I would
16 be able to tell you what I was paying him, but now
17 it's insignificant. I don't remember how much I was
18 paying him.
19 Q. Did you learn about his book of business or
20 know what kind of cases he was bringing in prior to
21 hiring him?
22 A. I do know that he -- I discussed either with
23 Russ, well, I know with Russ, and perhaps some other
24 people, I knew about the Epstein case.
25 Q. What did you know about it?

[Page 19]
1 A. I knew that it was a significant case of
2 potentially significant value against an extremely
3 collectible pedophile, for lack of a better word.
4 Q. So was that case your primary motive in
5 bringing Brad into the firm?
6 A. I doubt it. I mean, I can't tell you one
7 way or the other, but I doubt that I would bring him
8 in just for one case because what if the case fails,
9 then I'm stuck with a lawyer who can't do anything,
10 you know.
11 I'm not saying, Brad, that you couldn't do
12 anything, I'm just saying that if I only relied on one
13 case, then if I bring a lawyer in for one case and one
14 case only, what do I do with him when the case is
15 over.
16 Q. How did you know that this case would be a
17 collectible case then?
18 MR. SCAROLA: I'm going to object to the
19 form of the question because it misstated the prior
20 testimony. The prior testimony was not that it was a
21 collectible case but that it was a case against a
22 "extremely collectible pedophile."
23 BY MS. HADDAD:
24 Q. What made you think that this case had any
25 financial value?

[Page 20]
1 A. Epstein was a billionaire.
2 Q. Okay. Did you know anything about the
3 legitimacy or illegitimacy of the claims prior to
4 knowing he was a billionaire?
5 A. I knew what I was told. I didn't check it
6 out myself, but I trusted the people that told me.
7 Q. And who told you?
8 A. The only person I remember discussing it
9 with, as I sit here today, is Russ Adler. But if
10 Farmer and Jaffe and those guys were with me at the
11 time, I likely would have discussed it with them as
12 well.
13 Q. So were you aware of this case before you
14 made an offer to Brad to join the firm?
15 A. Yes.
16 Q. You said you didn't -- I don't want to
17 misquote you. You said you heard about it from other
18 people, but you didn't do anything to know that
19 personally. Was that before you made the offer of
20 employment?
21 A. I made the offer of employment based upon
22 what other people had told me about Brad.
23 Q. About Brad and his book of business or just
24 Brad and his legal skills?
25 A. Okay. When I say Brad, I mean Brad and his

[Page 21]
1 book of business and his legal skills.
2 Q. Okay.
3 A. And his ability to generate business in the
4 future.
5 Q. You stated that you believed that you first
6 heard about these cases from Russ and then perhaps
7 from Brad. Once Brad was at the firm, did you keep up
8 with these cases, these Epstein cases?
9 MR. SCAROLA: Excuse me, I'm going to
10 object to the form of the question. It is an
11 inaccurate reflection of the prior testimony. It has
12 no predicate. There was no reference about having
13 heard about these cases from Brad. The names
14 mentioned were Adler, possibly Farmer, possibly
15 Jaffe.
16 BY MS. HADDAD:
17 Q. Once Brad started working at the firm,
18 you've already testified you already knew about these
19 Epstein cases, correct?
20 A. Yes.
21 Q. How did you keep abreast of these cases?
22 A. I didn't.
23 Q. You didn't know anything about them?
24 A. I didn't say I didn't know anything. I said
25 I didn't keep track of it.

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6 (Pages 18 to 21)
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