EFTA01117299.pdf

1 2 IN IRE CIRCUIT COURT OP THE 1 APPEARANCES: FITTMENTI4 JUDICIAL CIRCUIT IN 2 AND FOR PAIN BEACH MINTY FLORIDA LAW OFFICES OP TCMJA KADDAD. P.A. by GENSAJW JURISDICTION DiVisiON 3 Sonja Bedded, Esq. Attorney for the Plaintiff. JEFFREY EPSTEIN, 4 Plaintiff, 5 ATTEMSURY, GOLDBERGER 6 WEISS, P.A., by No. 502009CA04000030CCOMAG Jack Goldberger, [sq. SCOTT ROTHSTEIN, individually, 6 Attorney for the Plaintiff. and BRADLEY J. SCREEDS, 7 individually, SEAECY DENNEY SCAPOLA ET AL, by Defendants. 9 Jack Scarola, Leg. Attorney for the Defendant, Bred ?Awards. 9 10 MARC NURIE, P.A., by 500 East Sioward Boulevard, Mato Nurik, Esq. Ft. Lauderdale, Florida I1 Attorney for Scott Rothstein. Thursday, June 14. 2012 (Appearing via Video Conference.) 9:14 a.m. - 12:37 p.m. 12 13 11 S. ATTORNEY'S orricz, by Req. DEPOSITION 14 Attorney for the Department of Justice. of 15 SCOTT ROTIISTED4 16 (Via Video Conference) 17 18 Taken on behalf of the Trustee 19 pursuant to a notice of taking deposition 20 21 22 23 24 25 FRIEDMAN LOMBARDI & OLSON FRIEDMAN. LOMBARDI & OISON 4 1 INDEX 1 Thereupon: 2 2 SCOTT ROTHSTEIN, WITNESS DIRECT 01039 AZDIESE? =CROSS 3 3 was called as a witness and, hawing boon duly sworn. SCOTT ROTHSTEIN 4 was examined and testified as follows: 4 5 In WITNESS: 1 do. (By Na. gadded) 5 3 (Hy Mr. Goldberger) 6 M. HADDAD: Good morning, Scott. How are 92 (By NX Sterols) 121 I you? 6 g THE WITNESS: Good morning, Sonja. How are 7 9 you? EXHIBITS 10 MS. KADOAD: Sum. thank you. It's nice to PLAINTIFF'S FOR IDENTIFICATION 21 see you. 9 12 THE WITNESS: Good to see you, too. 10 1 64 2 13 I . SCAROLE' Mr Rothstein, I don't know 69 11 3 72 14 that you end I have net. rot Jack Scarola, l'a 12 13 representing Brad Edwards end I know you know Brad 13 14 16 who's to my inmedisto left. 15 17 THE WITNESS: Hey, Brad, how are you? 16 18 Jack, good to see you. 17 19 NR. SCAPULA: Thank you. 10 19 20 MR. GOLDBERGER: Also present is another 20 21 Jack, Jack Goldberger, and I also represent Jeffrey 21 22 Epstein. To my right is Dertyn ladyke 22 23 23 TEE WITNESS: Good morning, Jack. 24 24 MR. GOLDEERGER: Bow are you today? 25 25 And to my right is Darryl Indyke, who is FRIEDMAN, LOA, BARD] & OLSON FRIEDMAN. LOMBARDI& OLSON EFTA01117299  5 6 1 Nr. Bpstein's in-house counsel. 1 different form than it ended because it started as 2 IS. INDTKE: Good morning. 2 bridge loans and things of that nature, and than 3 TEE WITNESS: Good morning, sir. 3 (oersted into the Ponta scheme. But you are looking 4 MR. NuRIA: Good morning. everyone. 4 back into the 2005 time frame for the very beginning. 5 IS. GOIDBMWAR: Ni, Marc, how are you? 5 Q. The 2005 time frame, that's when the bridge 6 NR. ADRIA: Good. You'll be seeing my 6 loans Started? 7 shoulder most of the day. 7 A. I can't be certain exactly what we were 8 WA. GOLDBERGER: Okay. 8 doing. I need to *fa all the docturents to tell you 9 Dirac? REANIMATION 9 what we were doing at what *pacific paint in time. 10 BY NS. RADDAD: 10 Q. What made you decide to start doing this? 22 Q. Well, Scott, I know you've talked about this 11 A. I started doing it out of greed and the need 12 probably more than you even care to, but I'd like to 12 to support the law fins, which was having significant 13 start a little bit asking you about the scheme at your 13 financial trouble at the time. 14 firm and how and when it started and things of that 14 Q. And in 2005 had you moved over to 401 yet or IS nature lust very briefly because I knew you've covered /5 were you still in the building where Colonial Bank 16 it many times. 16 wee? 17 NR. scAROLA: It has been covered and 17 A. I don't remoter. 18 protocol precludes asking questions that have already IS Q. Do you recall approximately how many 19 been answered and covering areas that have already 19 attorneys you had working for you when it started? 20 been covered, so we do object. 20 A. I do not. Between five and ten, Tcnja. 21 IS. coLOBERGER: Your objection is noted. 21 Q. Was it before you started acquiring 22 BY NS. HADDAD: 22 attorneys like you were acquiring cars and watches? 23 When did this first start? 23 et. SCAPOLA: Cbject to the form of the 24 It started back in '05, '06. The question 24 question, vague. 25 LS a little bit vague for me because it started in a 25 INS WITNESS: Yes. FRIEDMAN, LOMBARDI & OLSON FRIEDAIAN. LOMBARDI & OISON 8 1 BY NS. WOAD: 1 growth started," do you mean both the schwas -- do you 2 Q. Nell, who were you partners with when it 2 mean the schema and the firm or either one or both? 3 first started? 3 A. Both. 4 Stu Rosenfeldt. 4 Q. Do you recall approximately when you took 5 Q. Okay. Anyone else? 5 the space in the 401 Building? 6 A. Susan Bolin, I believe. It was definitely 6 A. 2 do net. 7 Eta Rosen/44dt, Michael Panoier, and Susan Dolin may 7 Q. At the time everything imploded, how many 8 have been partners of our* at that time, I'm not S partnere did you have at the firm, do you recall? 9 certain. 9 A. Are you saying partners and shareholders? 10 Q. Because if memory serves me correctly, you 10 Because remember, we had both, two designations. 11 went from being in the One Financial Plaza Building to 11 Q. I want to Start with just attorneys that 12 the building across the street, it was Rothstein, 12 had -- not in your firm mime but named as •partner' on 13 Rosenfeldt, Dolin and Pancier; is that correct? 13 the cards, for example. 14 A. Yes. 14 A. I'd have to see a list of all the employees. 15 Q. And it was some time later that you moved 15 NO had a bunch. 16 into the 401 Building, correct? 16 Q. Do you recall about how many attorneys you 17 A. You are skipping one step. I went fret One 17 had working there? 18 Financial Plaza to Phillips, tiainger, Ross, Rusnick, 18 A. Approximately 70. 19 Rothstein and Rosenfeldt. Then Stu Rosenfeldt and I 19 Q. In the year before, do you recall how many 20 broke off and formed Rothatein Rosenfeldt. And them 20 you had? 21 Rothstein, Rosenfeldt, Bolin. Pancier over at the 21 A. I do not. 22 Colonial Bank Building. And than we took the specs in 22 Q. So how many equity partners dad you have or 23 the 401 Building and eventually moved over there and 23 shareholders? I'm not sure of the word that we ere 24 that's when the real growth started. 24 using. 25 0. And when you say, "that's when the real IS A. Actual shareholders, equity shareholder* FTUEDMAIME & OLSON FRIEDMAN & OLSON EFTA01117300  9 10 • were two, me and Stu Aosenfeldt. • Q. When you were hiring end bringing in all 2 Q. And everyone else was just a partner for 2 these new attorneys, did everyone come in as e 3 title purposes? 3 partner? 4 There were shareholders for title purposes 4 5 and partners for title purposes. 5 Q. Bow did you decide who came in as a partner 6 Q. If someone was called a shareholder for 6 and Who ear in as an associate? 7 title purposes then, did they get to receive any of • A. Depended upon their level of expertise, B the funds? Were they shareholders receiving money or 8 practice, book of business. It was • decision Stuart 9 they were not considered shareholders in that sense? 9 and I made together on a case-by-case basis. 10 M. scAROLA: 0b3action to the fens of the 10 S. So you and Stu rata the -- were in charge 11 question. 11 of hiring? 12 Ttot WIMCCOS What kind of funds are you 12 A. Stuart and I tried to consult on every 19 talking about? 13 hiring decision, yes. 14 Br WS. HADDAD: 14 Did you guys also decide salaries? 15 Q. In general from the firm. leen you may 15 I generally decided the salary and tan let 16 equity shareholders, I understand that's you and Stu. 16 Stu know what I was going to do. And he would say if 17 What I'm saying is, if you had someone else that was 17 he thought it was okay or if he thought it was too 18 named as a shareholder, why did you call them a 18 much or too little, but I generally had free reign in 19 shareholder as opposed to a partner? 19 that regard. 20 It was a title of prestige and aehiomemat. 20 Q. Did someone's book of business directly 21 Q. so at was basically an ego thing, it had 21 correlate to the salary that you would offer? 22 nothing really to do with the finances or hierarchy of 22 That is a very broad question because it 23 the firm? 23 depends upon what other needs we had for that 24 A. They got paid more generally, but it did not • 24 individual. 25 have anything to do with distributions. 25 Q. What do you mean by 'what-other needs'? - FRIEDMAN.LOMBARDI & OLSON FRIEDMAN,LOMBARDI & OLSON 11 12 1 A. Well. I'll give you a good example. 1 WY Q. Would you need to look at someone's book of 2 lawyer, le. Kura, his salary was directly related to 2 business if they were coming in just solely -to be 3 the fact that he was a great lawyer and had a solid 3 ralneaker for the firm prior to hiring thee? • book of business. 4 A. I discussed it with them. There were not 5 Tea. s mossy people that I recall that I actually looked at 6 David Poden, on the other hand, was, as I 6 their numbers. Once David Boden was working for me I 7 previously testified, I don't know if you've had a 7 had him chaotic people's numbers, but I rarely looked. I S chance to read the testimony, but David Soden was not ▪ took most people'a words for what they were 9 only the general counsel to the law firm but he was 9 generating. 10 also -- acted as my oonsigliere in a significant 10 0. Hy recollection is, you were always looking 11 number of illegal operatioas and he was compensated 11 to bring in more people, to hire more people, same of 12 significantly for that, if that helps you understand 12 us were somehow able to ' you while others were 13 the difference. 13 not. Mow would you decide who you ware looking at to 14 It does. 24 bring into your firm? 15 So, for example, when you were hiring looser 15 A. Wa were trying to develop, on the legitimate 16 judges, let's use Met a an example, Pedro and Julio, 16 side of the law firm, we were trying to develop real 1/ clearly they don't have • book of business cuing in 17 talent, real practice groups. I moan, Brad is • 18 because they haven't had clients, but they may carry 18 perfect example, great lawyer, got a groat reputation. 19 ease sort of prestige or give sum legitimacy, if you 19 You know, it was our hope that, you know, ha was going 20 will, to the firm. Sow would you decide the salary 20 to be one of the people to actually in sane ways 21 for someone like that? 21 rescue the firm because he had a practice group that 22 A. Stu and I would discuss it. It was more • 22 could generate substantial income. You know, on the 23 market issue than anything else, how mud, are judges 23 legitimate side that's what we were trying to do, we 24 caning 022 the bench getting, how much business do we 24 were trying to find the best and the brightest. 25 think they can generate. 25 O. Okay. With respect to bringing people that FRIEDNIA & OLSON FRIED3IAIIMMI & OLSON EFTA01117301  13 14 1 you thought could bring a book of business, you 3u5t 1 Q. Okay. When you were looking at people to 2 said Brad, for example, that he had a legitimate 2 bring in to the firm to legitimise, es you said. Your 3 practice group with a good book of business. Bow did 3 firm had a vary unique area of practice and had a very 4 you know that? 4 unique environment to which to work. Bow did you know 5 A. Everyone in the tort world that I had spoke 5 or how did you came to decide what people may or may 6 to spoke extremely highly of Brad, not only people 2 6 not fit into that? 7 already had working for me but other people that know 7 A. Okay. Bang on one second. I think you just 8 him. Be was very -- came very highly recommended to accidentally misstated my testimony. B 9 9 I was not bringing the people in to 10 Q. Like who, for example? 10 legitimise the law firm. I was bringing thaw in to 11 We wanted him in there. We were trying to II the legitimate tide of the law firm. The bulk of the 12 develop a significant tort group and we thought that 12 law firm, despite the lack of financial success, was a 13 he'd be a great part of it. 13 large grow of very honest, hard working lawyers 14 Q. Who besides Russ told you that about Brad? 14 trying to do their best in difficult economic 15 A. It would have been other people in the tort 15 conditions. There were awe that were obviously not 16 group. I don't want to guess, 'Moja, as to which 16 legitimate. And the way I decided to bring people in, 17 other people told me, but it was -- well more than 17 again, it's really everything I just told you. Are 18 Ruse. 18 you looking for how I brought people into the Pouf 19 43. was it people within -- 19 scheme? 20 A. Might have boon people in politics that I 20 Q. Bo, right now I'm just asking about the firm 21 talked to that knew him because we had significant 21 because, as I said, it's a vary unique way in which to 22 input at the gubernatorial level with regard to tort 22 practice and a very unique workplace environment with 23 reform and the like, and there were people there who 23 politics and restaurants and parties at your home and 24 knew who Brad was. It was more than one person that 24 things of that nature. 2'n asking, personality wise, 25 told us that. - 25 other than the book of business, how did you decide on FRIEDMAN. % I & OLSON FlMEDMAN MBA OLSON 15 16 1 people that would be a good fit? 1 that time with Farmer and Fleece and Jaffe end 2 A. I looked for people that were outgoing, that 2 Mr. Edwards. 3 had the type of personality. CM the legitimate side 3 O. Do you know whore Mr. Edwards was working 4 of the business, people that had charisma that were -- 4 when you earned of him? 5 that could go out and hustle and try to develop a bock I don't recall whether he was working for 6 of business if they didn't have it. And as one of the 6 masons or had his own practice, I don't recall. 7 50 percent of the shareholders of the firm I was 7 Q. When did you first learn about Brad? 8 trying to hire people I wanted to work with. • A. I don't remember the time frame. 9 Q. Okay. When you would see people from whom 9 Q. Do you recall when you first met with him 10 you would offer jobs, for example, es you mentioned 10 regarding a job? 11 earlier with Brad and his practice, if somebody stated 11 A. No. The easiest way to figure that out is 12 that people told you that he was a good lawyer, did 12 to go look at his personnel file, it will have the 13 you need to see him in action, so to speak, prior to 19 notes saying when he met with me the first time. 14 your deciding to hire them or would you just take 14 Q. You don't have any recollection of your 15 people at their word for it? 15 first meeting with him? 16 A. See of people I saw in action; he wasn't 26 A. No. As you know, I was hiring people loft 17 one of them. Steve Caber is an excellent example of 17 end right and I was also unfortunately very busy doing 18 that. I hired Steve after he was beating the living 18 things I shouldn't have been doing, so I don't have a 19 daylights out of me on the other side of a case. And 29 specific recollection of when I hired him. I barely 20 I certainly would ask around about Om people. But 20 have a !pacific recollection of when I hired me. 21 the people that I trusted -- see, I can't remember. I 21 Q. But you did, in fact, meet with hie? 22 think Gary Farmer wee working for me before Brad, end 22 A. I'm certain I met with him before I hired 23 if I'm not mistaken he would have been one of the 23 him. I can't imagine -- although I did hire people 24 people that I went to with regard to Bred because we 24 without meeting them. I did hire people based on 25 ware really developing that whole tort group around 25 other people's word, if they were people within the & OLSON FRIEDMASinal & OLSON EFTA01117302  17 le 1 fine that I trusted. Because I always said, I had a 1 unfortunately, you aro taking a little tiny spot out 2 very simple, you lie or die by what you are telling 2 of a very, very busy time period in my life and in the 3 If you are telling me this guy is good and he's 3 life of the firm, so I can't tell you one way or the 4 not good, that's on you, it's going to hurt your 4 other. 5 income. So I used to tell my partner, people that S Q. I know you had a lot going on, I'm just 6 were recommending people to me, don't sell ma a bill 6 trying to see if you remember anything specific about 7 of goods just to get somebody in here because if you 7 this. 9 do that it's going to come back on you, it's going to S Do you recall what salary you had offered 9 affect your incase and your ability to grow in the 9 Brad to come join the firm? 10 firm. So with that admonishment. I might have very 10 A. I do not. You have to just try to 11 well hired salmons sight unseen based upon what 11 differentiate that what I knew thee is a lot different 12 scadmina else told ne. 12 than what I know now so .. 13 Q. But you did meet with Brad you say before he 13 Q. Meaning? 24 oar in to work? 24 A. Obviously meaning that at the point in time 15 A. Wow that I'm saying it out loud, I think I 15 that I was hiring him or maybe a year after, I would 16 did but rattly I'm guessing. I don't have a specific 16 be able to tell you what I was paying him, but new 17 recollection of meeting him. 17 it's insignificant. I don't reme•ber how much I was 10 Q. Do you recall if you know that he had worked 10 paying him. 19 as an assistant state attorney for a few year. prior 19 0. Did you learn about his book of business or 20 to doing tort litigation? 20 know what kind of oases ho was bringing in prior to 21 A. I don't recall that one way or the other. 21 hiring him? 22 Q. So you wouldn't have Maid Coward Seheinberg 22 A. I do know that he -- I discussed either with 23 or anybody about him before he came to work there? 23 Russ, well, I know with Russ, and perhaps ems other 24 A. I can't may that I wouldn't have asked 24 people, I knew about the Epstein case. 25 because, like I said, I might have asked. But 25 What did you know -shout it? FRIEDMAN.LOMBARDI & OLSON FRIEDMAN OLSON 19 20 1 I knew that it was a significant case of 1 A. Epstein vas a billionaire. 2 potentially significant value against an extremely 2 Q. Okay. Did you know anything about the 3 collectthle pedophile, for lack of a butte's word. 3 legitimacy or illegitimacy of the classes prior to 4 Q. So was that case your primary motive in 4 knowing he was a billionaire? S bringing Brad into the firm? 5 A. I knew what I was told. I didn't check it 6 A. I doubt it. I mean, I can't tell you one 6 out myself, but 1 trusted the people that told me. 7 way or the other, but I doubt that I would bring him Q. And who told you? in just for one case because what if the case foils. A. The only person I remember discussing it 9 then I'm stuck with a lawyer who can't do anything, 9 with, as I sit here today, is Russ Adler. But if 10 you know. 10 Farmer and Jaffe and those guys were with me at the 11 I'm not saying, Brad, that you couldn't do 11 time, I likely would have discussed it with them as 12 anything, I'm just saying that if I only relied on one 12 well. 13 owe, then if I bring a lawyer in for one case and one 13 Q. So were you aware of Nis ear before you 14 case only, what do I do with him when the case is 24 made an offer to Brad to join the firm? 15 Oyer. 15 A. Yes. 16 Q. Bow did you know that this case would be a 16 Q. You said you didn't -- I don't want to 17 collectible ease then? 17 misquote you. You said you heard about it from other 19 MR. SCAROLA: I'm going to object to the 19 people, but you didn't do anything to know that 19 form of the question because it misstated the prior 19 personally. Was that before you made the offer of 20 testimony. The prior testimony was not that it was a 20 employment? 21 collectible case but that it was s case against • 21 A. I made the offer of employment based upon 22 'extremely collectible pedophile..? 22 what other people had told se about Brad. 23 BY NS. ItaDDAD: 23 Q. About axed and his book of business or just 24 Q. What made you think that this case bad any 24 Brad and his legal skills? 25 financial value? 25 A. Okay. When I say Brad, I mean Brad and his FRIEDMANN/Mr OLSON FRIEDMAN. LOMBARDI & OLSON EFTA01117303  21 22 1 book of business and his legal stills. 1 Q. You didn't keep track of it? 2 Q. Okay. 2 I did not keep track of it. From time to 3 A. And his ability to generate business in the 3 tine Russ and the other guys in the tort group would 4 future. 4 tell me what was going on in certain cases, but until 5 Q. You stated that you believed that you first S I made a decision to utilise that file for an illegal 6 heard about these cases from Russ and then perhaps 6 purpose related to something illegal that I was doing 7 from Sniff. Once Brad was at the firm, did you keep up 7 along with my co-conspirators, I just assured my with these cases, these Epstein cases? 8 lawyers were going to work the case and eventually it 9 MR. SCAAOLA: itecuse me, I'm going to 9 would hopefully work out well for the law firm. 20 object to the fore of the question. It is an 10 Q. At your firm, when e-mails would go out to 21 inaccurate reflection of the prior testimony. It has 11 attorneys at RRA or all attorneys at RRA, were you 22 no predicate. There was no reference about having 12 part of that e-mail group? 13 heard about these cases free lirad. The names 13 A. you are talking about all staff? 14 mentioned were Adler, possibly Facer, possibly 14 No, all it says is attorneys at ARA. 15 Jaffe. IS It's the e-ermil group 'attorneys"? 16 BY MS. HADDAD: 16 Q. Yes. 17 Q. Once Bred started working at the firm, 27 A. yes, I'm a part of that e-mail group. 18 you've already testified you already know about these 18 Q. And I appreciate that you were very busy and 19 Epstein cases, correct? 19 may not have read all of them, but you did receive 20 yes. 20 those e-mails when they would go around? 21 Q. Bow did you keep abreast of these cases? 21 A. Yes, and I tried my best to read thee. 22 A. I didn't. 22 Q. Okay. At what point did you decide to use 23 Q. You didn't know anything about them? 23 this case to further your Paul scheme? 24 I didn't say I didn't know anything. I said 24 A. I don't remember the date, but I can give 25 I didn't keep track of it. 25 you the circumstances, if you'd like. FRIEDMAN LOMBARDI & OLSON FRIEDMAN,LOMBARDI & OLSON 23 24 1 Q. Please do. 2 interaction -- 2 A. The POnii Saida.° was running very low on 2 Sorry, Sonja, I didn't moan to speak over 3 capital. My co-conspirators and I needed to find a 3 4 now feeder fund, new Jewel:mint sources. Me had • 4 If you talk to the people in the firm, if 5 couple of very large, significantly wealthy potential 5 they ere honest with you, they'll tell you my 6 investors out there. I was looking for something that 6 interaction was far more significant with Ruse Adler, 7 would have been very attractive. We had had a lot of 7 probably more so because he was a co-conspirator of 8 inquiry during the due diligence period with these 0 mine. My interaction with Russ was far greater by 9 people that were doing due diligence on the putative many, many percents over my interaction with Brad, and 9 10 cases that we were selling. And when I thought about 10 then you go down the lino. I had sore interaction 11 the Epstein case, realising that it was a substantial 11 with Mr. Farmer than I did with Hz. Fistos, more 12 actual file in the office, I caws up with the idea 12 interaction with Jaffe than I did with Mr. Edwards, 13 that if I created a fake confidential settlement 23 and so on. 14 circling around -- lased upon this actual case, they 24 Q. Ruse was the head of your tort group, right? 15 would be able to increase the level of due diligence 25 A. Yes. 16 that I was able to offer to my potential investors. 16 Q. So these cases fell under the tort group; is 1? Q. Now did you know this was • substantial file 17 that correct? 18 in your office at that time? IS Yes, it fell under the -- fell under Russ' 19 A. Again, through the people I spoke to in the 19 purview ultimately. yes. 20 office. 20 Q. And Brad was a partner at your firm during 21 Q. Such aA who? 21 the ties these cases were there, correct? 22 A. Again, same people, Adler, Farmer, Jaffe, 22 A. I believe Out was his title. Be was either 23 'Pietas. 23 partner or shareholder. I don't think we had made him 24 Q. You newer spoke to Brad about this case? 24 a shareholder yet. 25 A. I didn't say that, but I had a lot more 25 Q. But he wasn't coming in as an associate, FRIEDMAN LOMBARDI & OLSON FRIEDMAN,LOMBARDI & OLSON EFTA01117304  25 26 I correct? I what was going on . And I may have spoke to him, I 2 To the best of my recollection, no. 2 knowispoke to Ruse, butImay have spoke to him as 3 So you stated that you learned this case 3 well within a couple of days just prior to this duo 4 woks -- I don't want to misquote you and listen to a 4 diligence because I was trying to at least get sons S long speaking objection, but what did you call this S information in my head that I could use when I was 6 case? 6 creating this story for the investors. 7 HR. scAROLA: Who wants the quote? 7 Q. Scott, what's ll-task? B THE WITNESS: it was a substantial case • A. 03-task is a web based software system that I 9 with a -- what I perceived to be a highly collectible 9 had invested $7 million in. 10 psdopbile as a defendant. 10 And what was the purpose of this internet 11 BY NS. IIACOAD: 11 Mate.? 12 Q. Right. How did you know at the tine when 12 A. To be able to rasmanitate in a secure 13 you said these investors wanted to investigate and you 13 fashion and in a unique group fashion about specific 14 said you were going to create a fake settlement, how 14 files. 15 did you know that this case was the case that you 15 Q. So forgive me, we all know I'm not good with 16 could use? 16 the computer. That was something that would be useful 17 From talking to all the people that I just 17 within a law firm, why? 28 said, Adler. ristos, Jaffe, Farmer, Nr. Edwards, to 18 A. Because it allowed you to create groups and 19 the extant that I spoke to him about it. 19 have both general and private chats, organize data in 20 Did you speak with Mr. Edwards about the 20 a very unique fashion. /het was, at least to our way 21 case? 23 of thinking, would have been were, very helpful in the 22 A. I don't have a specific recollection one way 22 law firm setting with multiple practice groups. 23 or the other. I remember speaking to him at least 23 Q. Did you belong to any groups on 0-task7 24 briefly the day or the day of or the day before the 24 A. I'm certain that I did. I don't remember 25 actual investor's due diligence was going on as to • — 25 which groups I belonged to. I -never got into the full FRIEDMAN LOMBARDI & OLSON FRIEDMAN. LCAIARDI& OLSON 2? 28 1 use of it. I tried to, but again, I was vary busy 1 and with that, with the 0-task and the a-mails, did 2 doing other things. But I know that tit. Adler's group 2 someone assist you with reviewing everything and 3 used it extensively. 3 letting you know what was going on within the groups? 4 Q. Because it was your firm and, as you said, 4 SM. SOMOZA: Mscuee me. I'm going to 5 you invested $7 million in it, did you have the 5 object to counsel's testimony. Object to the form of 6 ability to access a group if you ranted to? 6 the question es leading. 7 A. res. And if I couldn't, I could get Russ to 7 THE WITNESS: I really don't even 8 give me access. $ understand the question. 9 Q. So you didn't necessarily have to be invited 9 Can you try to rephrase it for me, Sonja? 10 into the Q-task group for you to be able to utilize or 10 Br KS. HADDAD: 11 view the communications within it? 11 Q. Of course, I would. 12 A. No, that's not true. I actually had to be 12 Did you keep abreast of everything that was 13 invited, that's what I was telling Russ to do, la to 13 going on in every practice group or was someone 14 have me invited. 14 through Q -task and e -mails, for examPle. Or was 15 Q. But I'm saying, the lawyers wouldn't have to 15 msg .te giving you information keeping you posted C. 16 personally invite you, you can get acumen° within your 16 what we going on within the practice? 17 firm to give you access maybe without the lawyers 17 Well, as part of the tort group I had a 18 knowing? 16 pretty good ides of what was going on then all the 29 A. No, I think it might have had a, quote. 19 time just because of the significant amount of 20 unquote, confidential. super secret viewing 20 interaction, both legitimate and otherwise, that I had 21 capability, but I don't recall it having that, and I'd 21 with Russ Adler, so I was probably moms up-te-date on 22 have no need to utilize that. Just invite me into the 22 that group then any group other than the labor and 23 group and lot me see what's going on. 23 employment group, again, because I had each 24 Q. Okay. I know that you are or were a very 24 significant interaction with Stu Aosenfeldt, both 25 hands-on person within certain of the practice groups 25 legitimately and illegitimately, so I knew what