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DCDOMADUBWNHROWOWDAADUBWNHEH Case 1:15-cv-07433-LAP Document 1320-29 Filed 01/03/24 Page 5 of 6 Page 130 R. Rizzo - Confidential There is a privilege of spousal privilege, so please don't disclose conversations you had with your wife. THE WITNESS: Sorry. MR. LEWIS: You can answer the question why you called, but you don't need to disclose anything about conversations with your wife. A. Iwas looking for an attorney that basically could handle this kind of situation, and I felt like, from what I had read, that Mr. Edwards was probably someone I needed to attain, if I could. Q. And so the, you referenced dissatisfaction with an attorney. I'm assuming that was the attorney that filed this 13-cv-8664 action, is that correct? A. Correct. Q. So you weren't happy with that lawyer and you were looking for a more aggressive lawyer? A. Correct, or someone that could work with my lawyer. Q._ The point being you were looking to R. Rizzo - Confidential on attorney/client privilege grounds. The conversation is privileged for the purpose of seeking legal advice. MR. PAGLIUCA: I don't understand. Mr. Edwards is the lawyer for the witness. MR. LEWIS: I am the lawyer for the witness. MR. PAGLIUCA: I know, I'm not asking about you. MR. LEWIS: He called Mr. Edwards for the purpose to determine whether Mr. Edwards could represent him in some capacity in that other lawsuit, so the conversations is privileged. MR. PAGLIUCA: I'm going to disagree, and you know we may need to revisit that issue respectfully. MR. LEWIS: Fair enough. MR. PAGLIUCA: Let me put some parameters on this that don't ask for communications. MR. LEWIS: Ask a question and I will object or not. DCDOMADUBWNHROWOWDAADUBWNHEH Page 131 R. Rizzo - Confidential recover some form of compensation, I take it, from the Dubins or Mr. Epstein? A. I was hoping -- how does Mr. Epstein -- Q. I don't know. I'm asking the question. A. That's incorrect. Q. You were seeking to get compensation from the Dubins, though? A. Correct. Q. And that was the point of you calling Mr. Edwards is that, however you learned it, you learned about the Epstein litigation and you knew Mr. Edwards was involved in the Epstein litigation? A. Correct. Q. The point of you contacting Mr. Edwards was to see if he could represent you in some litigation involving the Dubins in which you would collect money, is that right? A. Correct. Q. And so when you called Mr. Edwards, what do you recall telling him? MR. LEWIS: At this point, I object MAGNA® 34 (Pages 130 to 133) R. Rizzo - Confidential Q. I think you said you called Mr. Edwards about a year ago? A. More or less, correct. Q. I didn't print out the docket sheet, but do you recall when you settled the 13-cv-8664 case? A. To the best of my recollection, I think it was in December. Q. Of? A. I don't recall. I mean, it's last year. Q. Without telling me what you told Mr. Edwards, what was the purpose of your calling -- I think you already told me this, so I won't reask it. Never mind. Did you just speak with Mr. Edwards over the phone? A. Correct, yes. Q. And I take it Mr. Edwards did not become your lawyer in connection with any litigation against the Dubins, correct? MR. LEWIS: You may answer that. A. Correct. Q. And Mr. Edwards in some fashion LEGAL SERVICES Page 132 Page 133