HOUSE_OVERSIGHT_017505.jpg

1 July 22nd and 23rd there were numerous e-mails sent 7 od 2 about the meeting. It was almost an all-hands-on-deck : 2 3. type meeting where everybody needed to attend. Itwas = 3 4 labelled the Epstein meeting with an Epstein 4 5 conference room reserved. 5 6 A. Yes. : 6 7 Okay. What's your question and I will tell i 7 8 you. i 8 9 MR. SCAROLA: First I'm going to object to 2 9 19 counsel's testimony, but let's hear the question. | 10 11 BY MS. HADDAD: Pll 12 Q. The question is, does that refresh your i 12 13 _ recollection as to whether or not this meeting took : 13 14 place? 14 15 A. To the best of my recollection, ] actually £15 16 _ had introduced some of the investors to some of the 16 17 people working on the Epstein case, and that is likely i 17 f18 the meeting that you are referring to. But for the £18 19 life of me, ] don't have a specific recollection of £19 20 it. £20 f2i Q. But it could be the meeting where you ,21 22 introduced the Epstein litigation team to your Ponzi £22 23. investors? £23 24 MR. SCAROLA: Excuse me, I'm going to 24 25 object to the form of the question. It misstates the £25 Page a8 a 1 prior testimony. It has no predicate. 1 2 BY MS. HADDAD: iz 3 Q. That couid have been the meeting in which E 3 4 you introduced the Ponzi investors to people working | 4 5 on the Epstein case? , 5 6 MR. SCAROLA: Excuse me, counsel. The 6 7 testimony was that there may have been a meeting at | 7 8 which investors may have been introduced to some i 8 9 people working on the Epstein file. And your efforts | 9 10 continuously to mischaracterize the prior testimony 210 11° are highly improper. I object. | 11 12. BY MS. HADDAD: p12 13 Q. Scott, did you or did you not say that you p13 14 — introduced some of the investors to some of the 214 15 Jawyers on the Epstein case? f15 16 ~ A. No, actually said, Tonja, that ] may have. £16 17 J have a recollection that | may have based upon you : 17 18 just refreshing my recollection, but] just do not ' 18 19 remember one way or the other. This was, in the : 19 20 scheme of what 1 was doing, insignificant. ] was 22 0 21 _ simply trying to establish to the investors that this £21 22 was areal case, with real potential, with real | 22 23 Jawyers working on it. Other than that, it was of no 23 24 interest to me. 24 25 Q. How else would you convince them? You've | 25 Page 59} mentioned letting them look through the litigation boxes, you've mentioned the meeting. What other way would Id you have convinced them that it was a real case? “A. | mentioned letting th letting them look at boxes, what they did when ] was out of the office, that's -- ] don't know because | couldn't see what they were doing. Number two, ] may have introduced them to people in the office. Number three, I'm certain that when the people brought the boxes to my office ] introduced them to whoever was carrying the boxes. And number four, the rest of it would have been all stuff] created in my imagination because, again, it was the sale of something that didn't exist. This was not settling. There was no real settlement money. There were no real settlement documents. ] even manufactured, | think, the actual plaintiff, because ] don't recall even knowing the plaintiff's real name or if ] did it was of no significance to me. Q. How would you have manufactured a plaintiffs name, would you have created additional documents to further your Ponzi scheme using Mr. Epstein as the defendant? A. No. Q. How would you -- A. The name just would have appeared on the Page 60 confidential settlement agreement. Q. Would they have already seen the documents ai that point? A. | can't tell you one way or the other what they had seen, because | don’t know what they actually looked at. Q. Forgive me, you've now confused me so I'm Just going to ask you for some clarification. You used a legitimate case and created fake settlement documents, correct, in the simplest sense? "A. _If this culminated in an actual sale of a fake settlement, then the answer is yes. Q. So it was a real case with a real plaintiff and real defendant, just a fake settlement document? A. No. Let me see if] can clarify this for you. Over 90 percent of the settlements that | sold, the fake settlements, were completely fictitious? Q. Right. A. A very small percentage of them were based, at least in part, on some type of real litigation that ‘either had occurred or was currently occurring. | utilized the Epstein case to bolster the visual for the investors that a real case existed. Because as these were being sold to more sophisticated investors, the questions kept coming up, w. re -- how do we Page 61 lo (Pages 58 to 61) FRIEDMAN, LOMBARDI & OLSON 305-371-6677 5ed93085-0554-447f-bcdd-ca2d8fe941 df HOUSE_OVERSIGHT_017505