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1 have? : 1 Q. When did you hire him? 2 A. You said "still require," which would have : 2 A. 2008 or 2009. J don't have a specific 3 meant that ] testified -- / 3 recollection. 4 Q. Sorry. : 4 Q. Jf you hired Jawyers who didn't have a book 5 A. -- previously that it was requiring them. - 5 of business, what kind of practice did they do at your 6 Q. Did you require attorneys at your firm to : 6 office? 7 attend your fundraisers? 7 A. It depended upon the lawyer. 1 would have 8 A. lasked them to, ] urged them to, | tried to : 8 tried to get them to work with other lawyers in an 9 cajole them into coming, but it wasn't an absolute | 9 area that they either were proficient in or wanted to 10 requirement. 210 become proficient in. 11 Q. Do you recall between April and July of 2009 i 1 Q. Okay. You had a meeting at your office 12 how many fundraisers you would have had? il 2. during which you were asking about information 13 A. I donot. 213 _ regarding referring attorneys, attorneys who had 14 Q. Did you have fundraisers anywhere besides 14 __ referred business to the firm. Do you know what I'm 15. your home in 2009? #15 talking about? J believe it was back in December of 16 A. | probably did, but ] don't recall] without 116 ‘08 or early 2009. 17 seeing the documents. If you have the invitation or = £17 A. The way you are characterizing that meeting, 18 the e-mails, that would help me. 218 Thad a lot of meetings like that. 19 Q. Did you hold fundraisers at your office in 419 Q. What was the purpose of those? 20 2009? 220 A. You are going to have to be more specific 21 A. Imay have. That wouldn't have been -21 forme, Tonja. 22 unusual, but] don't have a specific recollection. 2 2 Q. Let's start generally then. What was -- you 23 Q. Did you ever meet any of the plaintiffs in : said you had many meetings like that. Tell me what 24 — the Epstein case? these meetings were for? 25 A. I don't have a specific recollection of A. Making sure that we were maximizing 1 that. 1 generation of business into the Jaw form. 2 Q. Do you recall ever revving copies of e-mails g 2 Q. What kind of business, legitimate business 3. from Mr. Jenne with respect to the plaintiffs in the i 3 or the other -- 4 case that the subject matter would say "information we i 4 A. Legitimate business. 5 need to use"? 2 3 Q. Sorry, ] couldn't hear you. 6 A. J] don't recall that one way or the other. : - 6 A. Legitimate business. The genera] meetings 7 It's certainly possible. = 7 that you are discussing, that was legitimate business. 8 Q. Do you recall ever reviewing anything that i 8 Q. So there was a meeting for all attorneys to 9 was titled "causes of action against Epstein"? = 9 attend regarding generating business, those meetings 10 A. 1 do not have a specific recollection of : 10 were for the legitimate business? 11. that one way or the other. i 11 A. If it was addressed to all attorneys, yes. 12 Q. Do you recall ever reviewing with Mr. Jenne £12 Q. Okay. And if an e-mail went out to all 13. or any other investigator in your firm any information : 13 attorneys, did paralegals and support staff get it as 14 regarding Mr. Epstein's house staff or airplane staff? 14 — well or was it just directed to the attorneys? 15 A. 1do don't recall that one way or the other. 215 A. Certain support staff probably were on that 16 I may have, J may not have. ; 16 list, like my CFO and COO, and perhaps my IT people, 17 Q. Who is Bill Berger? 117 but it was general for the attorneys. 18 A. A former Palm Beach judge that we hired. f18 Q. With respect to your IT people, did you have 19 Q. Okay. What was his role at your firm? : 19 the capability to review e-mails and internet activity 20 A. He was a shareholder. i 20 of all of your employees? 21 Q. What kind of practice? 2 1 A. did. 22 A. Litigating cases. 422 Q. Including attomeys? 23 Q. What kind of practice did he litigate? What £23 A. Idid. 24 kind of cases did he litigate? | 24 Q. Did you ever utilize that tool? 25 A. 1] don't recall specifically. : 25 A. Very infrequently. It was a pain because ] Page 83 i Page 85 22 (Pages 82 to 85) FRIEDMAN, LOMBARDI & OLSON 305-371-6677 5ed93085-0554-447f-bcdd-ca2d8fe941 cf HOUSE_OVERSIGHT_017511