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On D WF WHY PH anton nF WDM BF A. What does it say? Say it again. Q. It says, "The first deposition occurred on July 27th,” correct? A. Yes. Q. Some three days after the federal complaint was filed, correct, that we referenced earlier? A. That's correct. Q. And Paragraph 6 clearly delineates that in August 2009 a phone call was received by the cooperating witness that explained that this Mr. Rodriguez had a list of other purported victims or contact information for people who Mr. Edwards could also potentially bring Jawsuits for -- on behalf of; is that correct? A. ] don't know one way or the other. You know, Tonja, just so this record is clear, you know, as ]'m sitting here, ] have a vague recollection of perhaps Ken Jenne coming, talking to me and telling me that someone in my office was going to cooperate with someone in this investigation. But for the life of me, } can't be certain of that. So much time has passed, but as J'm reading this, and it could be completely unrelated to this, ] just want to make sure the record is a hundred percent clear, it's possible that Ken Jenne discussed that with me, but ] don't Page 74 sere se eat ant he aitetchag know who it was. Q. You are testifying that you didn't know it had anything to do with the Epstein case, as you sit here now, you don't remember? A.* No, no, | don't have a specific recollection, and ] want to just make sure so ] answer all your questions completely, is that as I'm sitting here my recollection was refreshed that ] have a vague recollection of having a conversation with Ken Jenne about the fact that someone in our office was going to cooperate as a confidential informant for some law enforcement agency, | just can't remember if it was the Epstein case or not. Q. Do you recall what you said to Mr. Jenne about that? A. No. What 1 just related to you is all 1 remember. And |'m not even sure it had anything to do with this. Q. Who's Wayne Black? A. Who? Q. Wayne Black. A. Sounds like the name of someone | hired, but 1 could be mistaken. ] don't recall. Q. Okay. You don't recall ever meeting Mr. Black? | tae RSPR PR Nea oReL nes emcee ere yas ga a eet cere ee ern ara ari Ip ae ain nS OB WNEHFE DMO WAIA OY BPWNEFP TH DWDAIHA OB WN bP MMMM NHY YF EEE PP Pe EB i fa Ey OpWNrFOWU MAA OT BWNHEPOUWODAIHDYTAWNEH SERSSICRITRLAGIIR NAAR NT I NE PRN STRAY PF PTE RE A EN SE EMT MELEE EAE SEE MES ROSE REPRE ITN ERE Ea RO EY EPR OR EY NONNNNYONEFE RPP EP Pe PP A. | may have. | don't recall one way or the other. You have something that might refresh my recollection? Q. Do you know what he does for a living? A. 1] do know the name. Sounds familiar to me, but | can't recall one way or the other who he was or what he did. Q. Did you instruct your office to begin investigating Mr. Epstein's pilot or his airplanes? A. J do not recalJ one way or the other. Q. You did testify that the flight manifest was the one document you recall] for sure looking at in Mr. Epstein's case; is that correct? A. Yes. Q. And if it did, in fact, contain the names that you are purporting that it claimed or that you knew of, that would be something that would be juicy for the investors to further your Ponzi scheme that it was a collectible case; is that true? A. I'm sorry, you have to repeat the question, Tonja. | don't understand what you just asked me. Q. If these big names were on this list, as you seem to recal] they were, that would be most helpful to you and your Ponzi scheme investors in convincing them it was a big case, right? Page 76 A. Ifthey were on there, or if ] lied to them "and told them they were on there, or if Adler told me they were on there and | repeated, ali those things would have been helpful to the Ponzi scheme. Q. You stated earlier that you -- the only thing you looked at was the flight manifest because you were told to look at it. Is that still true? A. That's not what I testified to. J testified that I flipped through other parts of the file and that I didn’t remember what J had flipped through. | remember looking at the flight manifest because Mr. Adler told me about it. Q. You said that you met these investors in your office, but there were no cameras in your office, correct? A. I didn't have cameras specifically in my office. Q. You had these investors in your office for this particular Epstein case? A. Yes. Q. Do you recall if it was during work hours or after work hours? A. Ido not recall. Q. Typically when you were meeting with your potential Ponzi investors, did you meet them during 20 (Pages 74 to 77 FRIEDMAN, LOMBARDI & OLSON Page 77 ) 305-371-6677 5ed93085-0554-447f-bedd-ca2d8fe941 df HOUSE_OVERSIGHT_017509