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1 A. He had had significant -- as you know, he
2 also had significant political connections and
3 everyone who is not living under a rock knows I was
4 doing everything I could to garner significant
5 political power.
6 Q. I think many people miss your parties.
7 But, with respect to Mr. Jenne and his
8 political connections, were you hiring him to utilize
9 him with respect to any of the police department
10 investigations? You had stated earlier you had
11 dealings with police departments. I don't want --
12 again, I don't want to put words in your mouth. You
13 said you had dealings going on with various police
14 agencies?
15 A. I had -- I mean, we had a criminal defense
16 section in the law firm, so we had legitimate dealings
17 with law enforcement. But I also had significant
18 illegitimate things with law enforcement that had
19 nothing to do with Ken Jenne.
20 Q. And how about with respect to former FBI
21 agents you were hiring?
22 A. They were all people that were operating in
23 a legitimate fashion within the law firm.
24 Q. In what role was that?
25 A. The investigative roles and the alcohol
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1 beverage roles and anything else Ken or other staff
2 could think of to have them do.
3 Q. Let's talk about the investigative roles for
4 a minute.
5 What kind of investigations were these teams
6 running?
7 A. I do not know. You have to speak to lawyers
8 that were actually utilizing them. I put it out there
9 and Ken put it out there, that they were available to
10 lawyers in the firm for use like in-house
11 investigators. And what people did with them
12 ultimately was up to them.
13 Q. Were they on salary or were their costs and
14 fees associated with utilizing them within a specific
15 practice group?
16 A. They were all on salary with me. The
17 ultimate goal was to have it as a separate entity that
18 could bill the law firm and have the clients at least
19 defray some of the cost. I don't recall whether or
20 not we ever got to that level or not.
21 Q. With all that in-house police action, why
22 did you have police security surrounding you all the
23 time?
24 A. I guess the best answer was I was paranoid,
25 but I mean -- that's the simple answer to it. You
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1 know, having -- there were mixed reasons. For
2 example, I -- are you talking about my Fort Lauderdale
3 police detail?
4 Q. Yes. You had it at the office and at your
5 home, correct?
6 A. Yeah. There's a myriad of facts that
7 motivated me to do that. One was that I really wanted
8 the security for the office. Two was, I was paranoid
9 and this is in no particular order. Three was the
10 Melissa Lewis murder that shook the entire law firm
11 and shook me terribly. I didn't want that to ever
12 have to happen again. And four was, I wanted -- the
13 more law enforcement you have around, the
14 more legitimacy it adds to you and your appearance to
15 the community. So there were a multitude of reasons.
16 I mean, I hired certain law enforcement to
17 work for me that were just friends of mine that
18 were -- that needed additional money, so I wanted to
19 make sure that they had money, both guys that did the
20 illegal stuff for me and guys that didn't do anything
21 illegal for me.
22 Q. Let's go back to the Epstein case and when
23 you decided to utilize it -- to use for the investors
24 for your Ponzi scheme.
25 Do you recall approximately when it was that
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1 these investors were coming that you decided to use
2 the files?
3 A. My best recollection it was in 2009,
4 sometimes after April of 2009, but I don't have a
5 specific recollection beyond that.
6 Q. What makes you think it was after April of
7 2009?
8 A. Because, to the best of my recollection, the
9 Clockwork Group came in towards the middle of 2009.
10 When I say Clockwork, that's an umbrella term that I
11 use to mean the Von Allmen, AJ Discala, and other
12 investors that came in through that feeder fund.
13 Q. So that was around April 2009?
14 A. No, it was after, to the best of my
15 recollection. I mean, you can tell because all you
16 have to do is look and see when the first, very first
17 Clockwork investment is. Actually, you can pinpoint
18 it even closer. Look for the very first settlement
19 deal that we did that was related to the Epstein case,
20 within 60 days prior to that would have been when I
21 was meeting with those due diligence people, 30 to
22 60 days before that.
23 Q. So when you decided to use that case, take
24 me through exactly what you did to familiarize
25 yourself with that case.
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