Text extracted via OCR from the original document. May contain errors from the scanning process.
A. If you are including within that me walking
past Brad in the hall] and saying, "Hey, Brad how are
you? How is the Epstein stuff going?” Then it's very
likely that | talked to him about it in that manner.
But I have no specific recollection one way or the
other as to having any lengthy conversations with
Mr. Edwards about the case.
] had a co-conspirator who was deeply
involved in the Ponzi scheme that ] could go to to get
any information ] wanted, Mr. Adler. ] didn't need to
go to Mr. Edwards.
Q. So if you had a question of your
co-conspirator, Russell Adler, about the Epstein case,
you would go ask Adler and would Adler always have the
answer for you or would he say he would get you the
answer?
A. Both.
Q. When he didn't have the answer, do you know
who he was getting the answer from?
MR. SCAROLA: Objection, predicate.
THE WITNESS: J don't know who he was
getting it from and ] may have contacted other people
in the office who were working on the file to ask. J
may have asked Mr. Jenne, ] may have asked Ms.
Holmes, ] many have asked a whole myriad of people.
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Q. So Ms. Holmes was working on the Epstein
cases?
A. It's my refreshed recollection from seeing
one of those e-mails that she must have been.
Q. Okay. And Ms. Holmes you said was a former
federal law enforcement officer, was that your
testimony?
A. Yes.
Q. You don't know whether she was FBI or IRS,
correct?
A. J don't remember.
Q. Okay. And upon reflection, do you know
whether she was hired without your say-so based on
what Mr. Jenne told you or did you meet with her?
A. No, | actually -- 1 remember meeting with
Ms. Holmes.
Q. Okay. What do you remember about that
meeting?
A. | remember talking about her relative who
was a judge. ] remember her telling me about her time
in law enforcement. J just don't remember which
agency.
Q. Did she tell you why she left law
enforcement?
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A. She may have, | don't recal] one way or the
other.
Q. Did you ever ask Ms. Holmes to use any of
her prior contacts in law enforcement to assist you in
the Ponzi scheme to get information for you?
A. The question is kind of convoluted because
the way you are asking it, it seems like you are
intimating that Ms. Holmes knew. I may have asked
Ms. Holmes to get me information that ] was going to
utilize with my co-conspirators in the Ponzi scheme,
but Ms. Holmes did not know that there was a Ponzi
scheme going on.
Q. All right. So you may have asked Ms. Holmes
to try and get some information for you from her
contacts in law enforcement, but it's your testimony,
and ] don't dispute it, it's your testimony that she
knew nothing about the Ponzi scheme, correct?
A. ] may have, ] may not have. | do not
remember and she absolutely knew nothing about the
Ponzi scheme.
Q. Okay. Now, we talked about Brad Edwards
getting paid and the multilevel ways in which you
determined what a person's salary was. Do you know
whether Brad Edwards got any bonuses along the way
once the Epstein case was used as part of the Ponzi
Page 112
scheme?
A. He did not.
Q. So he was --
A. If he got a bonus, it was something he
eared.
Q. Did you make a determination as to what that
bonus would be?
A. Ifhe got a bonus, ] would have been
instrumental in determining it. You can determine if
he got a bonus by looking at our financial records, 1
don't have an independent recollection one way or the
other.
Q. So you don't know whether he got a bonus at
all, correct?
A. That's correct.
Q. Sol assume that if he got a bonus you
wouldn't know whether it occurred before or after the
Epstein case was used as part of the Ponzi scheme?
A. 1] don't know if he got a bonus, which means
] wouldn't know the time frame.
Q. But we would learn -- you are instructing
us, we would learn that by looking at when the Epstein
case was brought into the Ponzi scheme and we learn
that by looking at these -- what was the group that it
was used to pitch to?
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