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1 A. If you are including within that me walking
2 past Brad in the hall and saying, "Hey, Brad how are
3 you? How is the Epstein stuff going?" Then it's very
4 likely that I talked to him about it in that manner.
5 But I have no specific recollection one way or the
6 other as to having any lengthy conversations with
7 Mr. Edwards about the case.
8 I had a co-conspirator who was deeply
9 involved in the Ponzi scheme that I could go to to get
10 any information I wanted, Mr. Adler. I didn't need to
11 go to Mr. Edwards.
12 Q. So if you had a question of your
13 co-conspirator, Russell Adler, about the Epstein case,
14 you would go ask Adler and would Adler always have the
15 answer for you or would he say he would get you the
16 answer?
17 A. Both.
18 Q. When he didn't have the answer, do you know
19 who he was getting the answer from?
20 MR. SCAROLA: Objection, predicate.
21 THE WITNESS: I don't know who he was
22 getting it from and I may have contacted other people
23 in the office who were working on the file to ask. I
24 may have asked Mr. Jenne, I may have asked Ms.
25 Holmes, I many have asked a whole myriad of people.
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1 BY MR. GOLDBERGER:
2 Q. So Ms. Holmes was working on the Epstein
3 cases?
4 A. It's my refreshed recollection from seeing
5 one of those e-mails that she must have been.
6 Q. Okay. And Ms. Holmes you said was a former
7 federal law enforcement officer, was that your
8 testimony?
9 A. Yes.
10 Q. You don't know whether she was FBI or IRS,
11 correct?
12 A. I don't remember.
13 Q. Okay. And upon reflection, do you know
14 whether she was hired without your say-so based on
15 what Mr. Jenne told you or did you meet with her?
16 A. No, I actually -- I remember meeting with
17 Ms. Holmes.
18 Q. Okay. What do you remember about that
19 meeting?
20 A. I remember talking about her relative who
21 was a judge. I remember her telling me about her time
22 in law enforcement. I just don't remember which
23 agency.
24 Q. Did she tell you why she left law
25 enforcement?
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1 A. She may have, I don't recall one way or the
2 other.
3 Q. Did you ever ask Ms. Holmes to use any of
4 her prior contacts in law enforcement to assist you in
5 the Ponzi scheme to get information for you?
6 A. The question is kind of convoluted because
7 the way you are asking it, it seems like you are
8 intimating that Ms. Holmes knew. I may have asked
9 Ms. Holmes to get me information that I was going to
10 utilize with my co-conspirators in the Ponzi scheme,
11 but Ms. Holmes did not know that there was a Ponzi
12 scheme going on.
13 Q. All right. So you may have asked Ms. Holmes
14 to try and get some information for you from her
15 contacts in law enforcement, but it's your testimony,
16 and I don't dispute it, it's your testimony that she
17 knew nothing about the Ponzi scheme, correct?
18 A. I may have, I may not have. I do not
19 remember and she absolutely knew nothing about the
20 Ponzi scheme.
21 Q. Okay. Now, we talked about Brad Edwards
22 getting paid and the multilevel ways in which you
23 determined what a person's salary was. Do you know
24 whether Brad Edwards got any bonuses along the way
25 once the Epstein case was used as part of the Ponzi
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1 scheme?
2 A. He did not.
3 Q. So he was --
4 A. If he got a bonus, it was something he
5 earned.
6 Q. Did you make a determination as to what that
7 bonus would be?
8 A. If he got a bonus, I would have been
9 instrumental in determining it. You can determine if
10 he got a bonus by looking at our financial records, I
11 don't have an independent recollection one way or the
12 other.
13 Q. So you don't know whether he got a bonus at
14 all, correct?
15 A. That's correct.
16 Q. So I assume that if he got a bonus you
17 wouldn't know whether it occurred before or after the
18 Epstein case was used as part of the Ponzi scheme?
19 A. I don't know if he got a bonus, which means
20 I wouldn't know the time frame.
21 Q. But we would learn -- you are instructing
22 us, we would learn that by looking at when the Epstein
23 case was brought into the Ponzi scheme and we learn
24 that by looking at these -- what was the group that it
25 was used to pitch to?
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29 (Pages 110 to 113)
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