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know this is a real case? So] was finally able to say this is how you know, here is a case file. |!may Okay. What number am I looking at? have, ] don't remember specifically one way or the : Q. It's a very large document. It's begins other, but ] may have utilized actual plaintiffnames with Bates Stamp Number 081 and ends with 264. from the cases filed, but ] may have made them up. | | A. It's in the computer, hold on a second. have no specific recollection one way or the other, ] ] have that in front of me. was totally geared toward simply getting the investor A. Hold on one second. TRCN Onno BWNY PR money into the Ponzi scheme. Q. Were you aware that the day after this meeting took place on July 24th, 2009, a new federal complaint was filed against Epstein with one of the same plaintiffs that was already pending in state court? A. ] don't know that | was aware of that or not. If they were filing it, someone may have told me. | don't recall one way or the other. Q. Did you ask anyone to file it to further your Ponzi scheme? A. No, 1 don't remember doing that, Q. Do you recall any situation where you -- A. You do realize -- Tonja, hang on__] just want to make sure this record is clear. Other than Russ Adler, the people that were involved in the Epstein case had absolutely nothing to do with the Ponzi scheme. ‘Ud ie) Ke} oO op) N | SORTER ate SE TEI se ctceeat eo ne asian int ecg et ate rh epen icie atone Ret PR RE Deeb NEES fay > 4 s 4 vay een k md Wo t 4 Om Q. Do you see the date on that complaint stamped? A. Ido. Q. And there's -- give me one second, Scott, sorry. What was the date that complaint was filed? A. What's the last page of the complaint, what's the Bates number? Q. The last page is 234. I'm sorry, 263 would be the last page of the complaint. [The Complaint referred to was marked for identification as Defendant's Exhibit 1.] MR. SCAROLA: You may want to call his attention to the filing stamp on the first page. MS. HADDAD: | did. 1 guess he didn't hear me. THE WITNESS: I'm sorry. MS. HADDAD: It's stamped on the first page. Page 64 5 ERE ERE TSU IEEE eee SE LEIA NST eta ei Q. Directly? A. _Orindirectly. They had nothing to do with it. “OQ. Yet the file was used for you to further your Ponzi scheme. ]'m not saying that they gave it to you to use for the Ponzi scheme, I'm asking, you used their case. I'm not -- the question is you used the case? A. ltook advantage of some good, innecent people for my own and my ¢o- copspuator's yeah purposes. Mr. Edwards is one of them, and for that ] sorry, Brad, Q. Did you ask anyone involved in the Epstein case to file a federal complaint? MR. SCAROLA: Objection, repetitious. THE WITNESS: Without seeing a document, Tonja, I can't tell you one way or the other. ] don't want to -- ] do not want to guess. If you have an e-mail where I'm saying to someone, file a federal case, then obviously I did. But I have no specific recollection of that. BY MS. HADDAD: Q. You do have a document with you, it's marked for you, it's Bates stamped. It begins at EP 081 and goes through through 264. Page 63 ra aE ND UN ec ei oem rate au arnt Nate tp tua REL Eo eran eee SOAS STE STE AE ERI 24 THE WITNESS: Hang on, the complaint is dated July 24th, 2009. It was entered onto the docket on July 27th, 2009. MR. SCAROLA: Do you have another question? MS. HADDAD: ] thought he was still looking. Scott, are you done looking? THE WITNESS: Yes, one second. MS. HADDAD: That's what J thought. THE WITNESS: No, hang on one second. It shows the stamp on the first page says July 24th, 2009. The filing say electronically filed July 24th, 2009. There's an entry onto the docket on July 27, 2009, and the complaint is signed July 24th, 2009. That's all the dates ] have. BY MS. HADDAD: Q. Okay. And back on Bates Stamp Page Number 263, who's the attorney that filed this complaint? A. | don't know if that's his signature, but the name is Brad Edwards. Q. Okay. And does that e-mail -- A. With the squiggle on top of it. Q. And does that e-mail address Jook like the correct e-mail address for RRA? A. Itis. Q. So that is, in fact, a legitimate e-mail Page 65 17 (Pages 62 to 65) FRIEDMAN, LOMBARDI & OLSON 305-371-6677 5ed93085-0554-447f-bcdd-ca2d8fe941 df HOUSE_OVERSIGHT_017506