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Own oO fF WHY bP A. Clockwork. Q. So we would look at when the Clockwork group was brought into this and the Epstein case was used then and then we would look at the payroll records to see whether Mr. Edwards got a bonus after the Clockwork group was brought into the Ponzi scheme, correct? A. From a timing perspective, yes. But Mr. Edwards had nothing to do with the Ponzi scheme, nor was he rewarded even surreptitiously without his knowledge for he helping me with the Ponzi scheme. If he was rewarded it was because he deserved, ] felt he deserved a reward, having g nothing to do with the Ponzi scheme. The bulk of this law firm had nothing to do ‘with the Ponzi scheme, Q. 1 think you testified already, though, that money was fundable in the firm, right? 1 mean, you know, illegal money was used for legitimate purposes, correct? A. Yes. Q. Okay. So, for example, investigations that were done with the Epstein case, it's very possible that legitimate Ponzi money was used to finance those investigations? A. I'd be guessing. It's certainly possible Page 114) ne ee because all the money went into a whole series of pots, and if you look at, most of the pots were trust accounts. If you look back, you look to see what my CFO, who was also a co-conspirator was doing, she was pulling the money from wherever she needed to to fund whatever she needed to fund. MR. LAVECCHIO: Off the record a second. [Discussion off the record.] BY MR. GOLDBERGER: Q. Let me circle back to what you needed to learn about the Epstein cases to help make your pitch to the investors. You talked about the manifest already, correct, the flight manifest? A. Yes. Q. Okay. What else did you want to learn about the case or what else did you learn about the case so that you were conversant when you spoke to the investors about the Epstein case? A. |] recall] asking someone what the causes of action were. Q. Okay. Did you understand what they were? A. J likely did at the time, ] don't remember what they were now. Q. Okay. Do you know which case we are talking Page 1156 worst nn fF WNP LO © MR PM MH NH NM FF +t SSE HEEB APES RO EO PR GG eI GT RIA MRR ENR at any po yo i Of WN EF O | a “y i WF BWNHrF CHU MANA USPWNEF OW DATA TSBWNEH eareguesannnpnineraare tana eannerceremee essai ler ee resemraman nme SRR N GSS! hE RS MEMES MIEN AGATA RS AISA ER REN ANTRAL ARIE ROA ARENAS NNONNNDNOEFPPRPEP EP RP PPB about? By the way, you had a number of Epstein cases in-house, do you know which case you were talking about? A. As) sit here today, no, sir, ] don't remember. Q. Was it a state case or a federal case? A. J don’t remember one way or the other. Q. All right. A. Jutilized all those boxes all together. ] don't remember which one ] sold them. Q. And the exhibits -- A. It's something completely fictitious that J made up that ] told them. Q. The exhibit that you were shown earlier, Exhibit Number 1, that's the long multi-page federal lawsuit. Do you know whether that was part of the information that you reviewed or shown to the investors when you were pitching to them? A. J] donot remember one way or the other. Q. Okay. Now, did you make any effort to learn from your co-conspirator who the plaintiffs were in this case, what kind of women they were? A, Only that they were underage. Q. Did anyone tell you that these women had -- some of these women n had a history of p a history of prostitution? Page 116] A. They may have told me that, 1] wouldn't have cared one way or the other, Q. Why would you not have cared about that, Mr. Rothstein? A. Ithad nothing to do with the sale of the Ponzi scheme settlements. Q. Okay. Were you told by anyone whether any of the women involved as plaintiffs in the case may have worked at adult clubs in the past? I mean strip clubs, let's call it what it is. A. | may have been told that one way or the other. But again, it had nothing to do with the Ponzi scheme sale of fake settlements. Q. As part of the information that you were told by you co-conspirator, Russell Adler, were you told that some of the plaintiffs that you had in-house had travelled on Mr. Epstein’s airplane? A. I believe Russ did tel] me that. Q. You know, in fact, that that was not true, correct? A. J have no idea one way or the other, nor did I care. Q. But your co-conspirator told you that, right? A. Mr. Adler did, in fact, tell me that certain Page 117 30 (Pages 114 to 117) FRIEDMAN, LOMBARDI & OLSON 305-371-6677 5ed93085-0554-447f-bedd-ca2d8fe941 df HOUSE_OVERSIGHT_017519