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EEE I TERE A EEE SE EUS Page 27,4 1 what was going on. And 1 may have spoke to him, ] = 1 and with that, with the Q-task and the e-mails, did 2 know | spoke to Russ, but ] may have spoke to him as i 2 someone assist you with reviewing everything and 3 well within a couple of days just prior to this due : 3 letting you know what was going on within the groups? 4 diligence because ] was trying to at least get some : 4 MR. SCAROLA: Excuse me, I'm going to 5 information in my head that ] could use when ] was : 5 object to counsel’s testimony. Object to the form of 6 creating this story for the investors. _ 6 the question as leading. f) Q. Scott, what's Q-task? : 7 THE WITNESS: J really don't even 8 A. Q-task is a web based software system that | : 8 understand the question. 9 had invested $7 million in. 1 9 Can you try to rephrase it for me, Tonja? 10 Q. And what was the purpose of this internet 210 BY MS. HADDAD: 11 system? : 11 Q. Of course, | would. 12 A. To be able to communicate in a secure £12 Did you keep abreast of everything that was 13. fashion and in a unique group fashion about specific ; 13. going on in every practice group or was someone 14 ~ files. 214 through Q-task and e-mails, for example, or was 15 Q. So forgive me, we all know I'm not good with | 15 someone giving you information keeping you posted on 16 the computer. That was something that would be useful | 16 what was going on within the practice? 17 within a Jaw firm, why? a17 A. Well, as part of the tort group | had a #18 A. Because it allowed you to create groups and ] 18 pretty good idea of what was going on there all the 19 have both general and private chats, organize data in .19 time just because of the significant amount of 20 avery unique fashion. That was, at least to our way : 20 interaction, both legitimate and otherwise, that ] had 21 of thinking, would have been very, very helpful in the 221 with Russ Adler, so] was probably more up-to-date on 22 — law firm setting with multiple practice groups. : 22 that group than any group other than the labor and 23 Q. Did you belong to any groups on Q-task? : 23 employment group, again, because ] had such 24 A. |'m certain that ] did. ] don't remember ] 24 — significant interaction with Stu Rosenfeldt, both 25 which groups ] belonged to. | never got into the full i: 25 legitimately and illegitimately, so 1 knew what was Page 265 Page 28 1 use of it. I tried to, but again, ] was very busy 1 going on in that group. 2 doing other things. But I know that Mr. Adler's group =; 2 ] tried, as best as ] could, given my time 3. used it extensively. : 3 constraints, to stay on top of what was going on, you 4 Q. Because it was your firm and, as you said, i 4 know, throughout the firm. But ] relied on other 5 you invested $7 million in it, did you have the * 5 people like Debra Villegas and Jrene Stay and David 6 ability to access a group if you wanted to? 6 Boden, Les Stracker to the lesser extent, to monitor 7 A. Yes. Andif I couldn't, | could get Russ to i 7 what was going on in the different practice groups and 8 give me access. 1 8 keep me up to speed. 9 Q. So you didn't necessarily have to be invited » 9 Q. Was there audio and video surveillance 10 into the Q-task group for you to be able to utilize or : 10 throughout the entire firm or only within your office? 11. view the communications within it? : 11 A. No, through the entire office, not in the 12 A. No, that's not true. | actually had to be 212 _ individual offices. 13 invited, that's what ] was telling Russ to do, is to : 13 Hang on. Not in the individual offices but 14 have me invited. ;14 throughout the general office space. ps Q. But I'm saying, the lawyers wouldn't have to pls Q. So in 2009 how many floors did you have? 16 personally invite you, you can get someone within your #16 A. Three, ] think. 17 firm to give you access maybe without the lawyers 47 Q. And do you recall approximately how many 18 knowing? 218 attorneys you had working there at that time? 19 A. No, ] think it might have had a, quote, hy 9 A. Approximately 70. 20 unquote, confidential, super secret viewing i2 0 Q. And when you say "not the individual offices 21 capability, but ] don't recall it having that, and I'd 1 21 but the other areas,” do you mean -- would that 22 have no need to utilize that. Just invite me into the 22 include conference rooms? 23 group and let me see what's going on. 23 A. 1 didn't have surveillance in the conference 24 Q. Okay. I know that you are or were a very 24 rooms. 25 hands-on person within certain of the practice groups 225 Q. Socan you please tell me exactly where you Page 29 8 (Pages 26 to 29) FRIEDMAN, LOMBARDI & OLSON 305-371-6677 5ed93085-0554-447f-bcdd-ca2d8fe941 df HOUSE_OVERSIGHT_017497