EFTA01100749

Page 1 Page 2 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL APPEARANCES: CIRCUIT IN AND FOR PALM BEACH COUNTY. FLORIDA CASE NO. 50 2009CA040800XXXX/45 AG 2 On behalf of the Plaintiff: Complex Litigation. Fla.R.Civ.Pro. 1201 3 ROBERT D. CRITTER, JR., ESQUIRE BURMAN, CRII1XNI, LAPITIER 4 COLEMAN. LLP 4 303 Banyan Boulevard Suite 400 JEFFREY EPSTEIN, 5 Nest im 33401 Phone: Plaintiff, 6 VOLUME I OF II 7 and JACK AWt GOLEBERGER. ESQUIRE SCOTT ROTHSTEIN, individually. ATTERBURY, GOLEBERGER 4 WEISS. BRADLEY J. EDWARDS. 9 250 Australian Avenue South Individually, and L.N. individually. Suite 1400 10 West Palm Raze rl ride 33401-5012 Defendants. Phone: 11 12 and VIDEOTAPED DEPOSITION OF BRADLEY J. EOSARDS, ESQUIRE 13 On behalf of the Plaintiff: 14 ALAN M. ECASHOWIT2, ESQUIRE Tuesday. March 23. 20010 HARVARD IA/I SCHOOL 10:00 - 5:01 p.m. 15 Hauser 520 Cashridiass iatts 02138 16 Phone: 2139 Palm Beach Lakes, Boulevard West Palm Beach, Florida 33401 17 On behalf of the Defendant: 18 JACK SCAROLA, ESQUIRE SEARCY, DENNEY, SCAROLA, 19 BARNHART a SHIPLEY, P.A. 2139 Palm Beach Lakes Boulevard Reported By: 20 West Pa de 33409 Cynthia Hopkins, RPR, PPR Phone: Notary Public, State of Florida 2) Prose Court Reporting Job No.: 1333 22 ALSO PRESENT: Jeffrey Epstein 24 Joseph Kozak. Videographer Prose Reporting Services 25 PROSE COURT REPORTING AGENCY.INC. PROSE COURT REPORTING AGENCY, INC. Page 3 Page 4 PROCEEDINGS 2 INDEX 3 3 Deposition taken before Cynthia Hopkins. 4 4 Registered Professional Reporter and Florida 5 EXAMINATIOR DIRECT CROSS REDIRECT 5 Professional Reporter, and Notary Public in and for 6 6 the State of Florida at Large, In the above cauee. BRADLEY J. EDWARDS, ESQUIRE 7 7 - - - BY MR. CRITTER 5 8 B THE VIDEOGRAPHER: We are now on video 9 9 record. This is Media Nusber One in the 10 10 videotaped deposition of Bradley Edwards in the 11 EXHIBITS 11 matter of Jeffrey Epstein versus Scott 12 12 Rothstein, Bradley J. Edwards, and L.M. 13 13 Today is Tuesday, March 23rd. 2010 et 14 EXHIBIT DESCRIPTICei PAGE 14 10:00 a.m. We're here in the law offices 15 15 Of Searcy, Denney, scarola, Barnhart 4 PLAINTIFF'S EX. 1 /JARED° RODRIGUEZ 211 16 CRINIIL11.02MPLAIM 16 Shipley, 2139 Palm Beach Lakes Boulevard, PLAINTIFF'S EX. 2 COMPLAINT 239 11 PLAINTIFF'S EX. 3 JULY 22. 2009 276 17 West Palm Beach, Florida. FRCS/OLE 18 18 Hy name is Joe Kozak. I am the 19 19 videographer. The court reporter is Cindy 20 20 Hopkins from Prose. Prose Court Reporting 21 21 Agency. 22 22 Will counsel please introduce 23 23 yourselves, and then the court reporter 24 24 will swear in the witnesses. 25 25 KR. CRITTER: Bob Critton on behelf of the PROSE COURT REPORTING AGENCY. INC. PROSE COURT REPORTING AGENCY, INC. EFTA01100749 Page 5 Page 6 1 Plaintiff, Jeffrey Epstein. 1 A. No. 2 I . GOLDBERG: Jack. Goldberger on behalf 2 O. okay. But you've counseled, you've 3 of the Plaintiff. Jeffrey Epstein. 3 obviously taken a number of depositions both as a MR. DERSHOWITZ: Alan Dershowits on behalf 4 Plaintiff and as a Defendant. You're familiar with S Of the Plaintiff, Jeffrey Epstein, of counsel. 5 all the rules? 6 MR. SCAROLA: The record should reflect 6 A. I know the rules. 7 that Mr. Epstein is also personally present. O. All right. Again if I ask you a question My name is Jack Sterol.. I am counsel on 8 you don't understand, if you would ask me or if yOu 9 behalf of the Defendant/Counter-Plaintiff, Brad 9 want me to rephrase it, I will be happy to do that. 10 Edwards. 10 A. Yes. 11 Thereupon, 11 NR. SCABOLA: Mr. Edwards, Mt. Edwards, 12 'BRADLEY J. E0WMDS, ESQUIRE' 12 knows the rules. You can skip the 13 having been first duly sworn or affirmed, was 13 preliminaries. 14 examined and testified as follows: 14 MR. CRITTCN: Is that a form objection? 15 THE WITNESS: Yes. IS MA. SCAROLA: No. 16 DIRECT E)U1IIINATICII 16 MR. CRITTON: Just a talk. 17 BY MR. CRITTON: 17 red. SCAROLA: It's a. it's a request that 18 O. Would you please tell us your full nave 18 you not waste our time. 19 and ix" your home address. 19 HR. CRIT70N: I am not wasting your tine. 20 A. Bradley James Edwards, 20 And if we hadn't gone through that, we would 21 21 have been done with them. Jack. 22 O. Bete of birth, please. 22 BY M. CRITTON: 23 A. 23 O. Mr. Edwards, are you currently employed? 24 O. Mr. Edwards, have you ever had your 24 A. Yes. 25 deposition taken before? 25 O. Md by whom are you currently employed? PROSE COURT REPEOTING AGENCY. INC. PROSE COURT REPORTING AGING,, INC. Page/ Page 8 1 A. I—don't understand the question. 1 Correct. 2 O. For whom do you work at the current time? 2 And do you hold yourself out to the public 3 Are you an employee? 3 as being a partner of that fire; that Is you 4 I as a partner In the law firm of Farmer, 4 individually? 5 Jaffe, Weissing, Edwards, Fistfni I Lehrman. 5 A. What do you mean by hold myself out to the 6 O. Is that a professional association? 6 public? 1 A. Yes. 7 O. If I got your letter would your letter 8 O. Md you said you're a partner. DO you say. if I received a letter from you would It say 9 have your own P.A. or Is the only the Farmer -- what 9 Brad Edwards. partner, or something to that effect? 10 was the second name. Jaffe? 10 A. I don't think so. II A. Correct. 11 Okay. What does your card say? DO you 12 O. And I will refer to it as Former, Jaffe. 12 have a business card? 13 if that's all right with you. Is Farmer, Jaffe 13 1 do. 14 itself a P.A.; that is, are you a partnership of 14 Okay. O. Mar doss your business card-- 15 P.A.'s? 15 A. Attorney. 16 A. Yes. 16 O. -- reflect? And when you introduce 1? Q. Do you have your own professional 17 yourself to clients or other attorneys for the first 18 association? 18 occasion, do you Introduce yourself as a partner of 19 A. Yes. 19 that firm if asked? 20 O. Okay. What's it called? 20 A. If asked are you a partner; is that your 21 A. Law Office of Brad Edwards, LLC. 21 question? 22 O. You are the sole member of that LW? 22 O. Correct. 23 A. Yes. 23 A. Mould 1 say yes? The answer is yes. 24 O. Md then your LLC is a partner of the 24 When did you Start -- I want to strike Q. 25 Former. Jaffe firm? 25 that. DO you consider yourself an employee of the PROSE COURT REPORTING AGENCY, INC. PROSE COURT REPORTING Aar', INC. EFTA01100750 Page 9 Page 10 1 partnership? 1 paralegals that are Currently employed by Farmer, 2 A. What do you mean by that? 2 Jaffe in any capacity whether they are independent 3 Q. Do you understand what an employee Is? 3 contractors -- well. let me strike that. 4 A. I work for the firm. 4 As employee's, 1 probably should ask 5 O. You are certainly not -- this question: Does the firm. Farmer, Jaffe have 6 I am employed there, to. yes. 6 employees -- 7 0. When did you start your esaociation with 7 A. Yea. the farmer. Jaffe firm? O. -- separate and apart from the partners? 9 A. Sometime during the month of November, 2009. 9 A. Yea. 10 O. And IS that when the firm was incorporated 10 O. And they are actually employed by the 11 as a professional association? 11 P.A., correct? 12 A. I believe so. 12 A. Correct. 11 Q. The attorneys who are In the current firm, 13 Q. Does the firm have any paralegals that 14 are they all former Rothstein Rosenfeld[ Adler 14 came over from the BAA firm, RM? 15 attorneys: that 1s, the professional staff? 15 A. Yes. 16 A. Yes. 16 Q. WhO are they? 17 Q. Is there anyone -- Let me strike that. 17 Marla and Seth. 18 Do you have paralegals as well that 18 O. Does Maria have a last name? 19 work there? 19 A. Yes. 20 A. Yes. 20 O. What is it. Please? 21 Are any of the paralegals former, and if 1 21 A. I believe it's pronounced Kelljian. 22 refer to Rothstein Roaenfeldt Adler as AM. or PRA, 22 Q. Can you spell it? 23 is that all right with yov? 23 I can give it my best shot. 24 . A. I understand what you mean. 24 Q. And Beth's last name is what, please? 25 Q. Are there any other, are any of the 25 A. Willlamson. PROSt cOURT IMPORTING AGENCY. INC. MOLE COURT REPORTING AGENCY, INC. Page 11 Page 12 1 O. She's your current eecretery/paralegal, or 1 for or with. 2 do you have a secretary as well? 2 Did she work with you at all at BRA? 3 A. I don't understand your question. 3 A. In some limited capacity. maybe. 4 O. Do you have -- is Beth Williamson your 4 Q. Did she ever work on any of the -- you 5 paralegal? 5 have three cases that you ever filed -- or let me 6 A. She's a paralegal at the law firm of garner. 6 strike that. 1 Jaffe, weissing, Edwards, ?limos a Lehrman. 7 There are three cans that are in 8 Q. Does she primarily work for you? 8 existence at the current time. One is Jane 00* 9 A. No. 9 versus Mr. Epstein which is, is a federal court case 10 Do you have a Secretary as well? 10 and the Plaintiff's name is Jane Doe. That is one 11 The law firm? Yes. 11 of your cases, correct? 12 The secretary who works primarily for 12 A. Correct. 13 13 Q. Or one of the firm's cases at the Current II 14 time? 15 O. You jest use whoever is available from a 15 Correct. 16 secretary standpoint? 16 There le another case versus L.M. Versus 11 A. No. )7 Jeffrey Epstein and a third called C.M. versus 18 Q. Who do you primarily use for secretary IS Jeffrey Epstein. correct? 19 services? 19 A. Yes. 20 A. There is nobody who could fall into the 20 0. And as a result all three of those cases 21 category of who I primarily use. 21 currently now are firm , the farmer, Jaffe firm 22 Q. Ma. Williamson. who, by whom, who, who was 22 cases? 23 the attorney at AAA with wham she primarily worked? 23 A. Yes. 20 A. I believe it was several attorneys, and 24 Q. Did Mrs. Williamson work on any of those 25 can't tell you who the attorneys were that she worked 25 cases? PROSE COURT ILEICItTING AGCMCY, INC. PROSE COURT ItUVRTING AGENCY, INC. EFTA01100751 Page 13 Page 14 1 A. In what time period? What's your question? notice of appearance or something by RIM would 2 Q. I'm sorry. During the time that you were 2 that. in any way, If I asked you to assume that 3 associated with KM. did Mrs. Williamson work on 3 that's correct, would that refresh your recollection 4 those cases? 4 that it may have been at the end of March? S A. Without you needing to ask 20 different 5 A. I don't understand that question at all. 6 question to pet to your answer, I will tell you her 6 Q. I paw a pleading that was filed or -- involvement was that after federal motions were drafted, 7 Yesterday you said. 0 she was the person to literally file the motion. That -- a paper that was filed. 1 was looking 9 is her only involvement with the cases while at RIM 9 at a pleading filed in either E.M. or L.M., and 1 10 She basically filed them through the Pacer 10 saw a paper that was basically a notice of 11 system? 11 appearance on behalf of RM And it looked like it 12 A. Exactly. 12 was dated around march 30 of 2009. 13 0. Prior to you working at Farmer, Wee by 13 A. Okay. 14 whoa were you employed? And by employed I mean In. 14 Q. Is it possible that you started your 15 in a broad sense. You could have been an 15 association with BRA at an earlier date than April 16 independent contractor. You could have been a 16 of '09? 17 partner. You could have been an employee. IT A. Misusing that what you said is true, if that 10 A. The law firm of Rothstein Rosenfeldt Adler. 18 document says that, then it's possible that is an 19 0. When did you start working for RM? 19 accurate reflection of when I beam. 20 A. 1 believe April of 2009. 20 Did you start working with RM before you O. 21 O. Beginning of April? 21 filed any documents representing that RRA or that 22 A. Yes. 22 you had now an affiliation with RRA? 23 O. 1 saw a pleading that was filed yesterday 23 No. 24 and it was either E.N., I am sorry, L.M. or E.N. 24 Q. where the -- again, I don't remember. . 25 that looked like there was a change of -- I'm sorry, 25 whether there was a notice of additional counsel or PROSE COM' REPoRTING AGENCY. INC. MEM COuRT ItteoliTim AGENCY, INC. Page 15 Page 16 1 substitution of counsel. Did you, were the 1 was a meeting that was held informing all the employees 2 substitution of counsel's filed the exact date that 2 including myself that the firm no longer was financially 3 you started with RRA? 3 able to survive and therefore would be immediettly 4 A. I don't remember. 4 doming down. 5 O. When did your association with MA 5 Q. Mho was the spokesperson at the meeting, 6 terminate or end? 6 the min individual who advised those assembled in 7 A. The end of October 2009 or the beginning of the room that that's what was going to occur? 8 November 2009. 8 A. I don't remember. 9 O. And Now did it terminate? Now did your 9 O. Was it -- did Rosenfeldt speak at all at 10 relationship with RM terminate? 10 that meeting? 11 The fine closed. 11 I, I can't remember. 12 Q. Did you get, notification -- when you say 12 0. Do you remember the date Of the meeting? 13 closed. meaning what? 13 A. I remember that it was a Monday. 71 A. Meaning what everybody in this entire roan 14 O. Do you temealier it being in October or 15 knows Is that the firm went from operating to no longer 15 November? 16 operating. 16 Either the very end of October or the very 17 Q. And how did you receive notice: that is. 17 beginning of November. le did you receive some sort of notice that told you 18 Did anyone -- well, let me strike that. Q. 19 that MA now is a defunct firm? Did you receive 19 Do you remember whether the person -- let me strike 20 notification that was in bankruptcy? What, if 20 that. 21 anything, did you receive? 21 At the meeting who was present, and I 22 1 didn't receive anything. 22 don't mean individual names. Who did it, by groups, 23 And then how did your relationship with 23 who did it include? 24 RM end? 24 A. The meeting was held in a cafeteria type room 25 A. Came to work on a Monday morning, and there 25 in the building where RRA maintained its offices. And PROSE COURT REPORTING AGENCY, INC. PROSE COURT REPORTING AGENCY. INC. EFTA01100752 Page 11 Page 16 1 the room was completely full to capacity with as many 1 what I heard was, tins is closing down. That's all I 2 employees of the Rothstein. Ronnfeldt Adler firm as 2 needed to hear and I left. 3 were in attendance at work that day. 3 O. Did you subsequent -- well, let me strike Q. And included lawyer.. paralegals, support 4 that. Did you, were you able to gain. pain access 5 staff. investigators? 5 to the building that day? 1 am sorry, access to 6 A. Literally -- 6 your, to the offices of the Rothstein firm that day? 1 O. everyone, 1 mean everyone who obviously 7 A. Yes. showed up at the meeting? 6 Q. And were you able to access any of your 9 A. I don't know. 9 files or your e-mail at that time? 10 Q. Did you see other lawyers there? 10 What time? 11 A. Yes. 11 That same day, that Monday that you were 12 Q. Did you see staff there? 12 advised that the fine was shutting down. 13 Yes. 13 A. Yes. 14 Did you see paralegals there/ 14 O. And were you able to print documents? 15 Yes. 15 Well, let me strike that. Were you able to take 16 O. Did you see investigators there? 16 documents relating to matters on which you worked 1? A. 1 Can't necessarily remember whether or not I 17 from the firm? IS saw investor -- investigators there. 16 A. What do you mean by was I able to/ 19 O. And did more then one person speak et the 19 Were you able to access and take with you 20 meeting? 20 documents that related to files on which you were 21 A. I don't remember. 21 working the preceding Friday when you were at RRA? 22 Q. Okay. what else were you advised at the 22 A. I believe so. 23 meeting. If anything? 23 Did you take, did you actually remove Q. 24 It was -- I stayed for very little of that 24 documents, papers that were related to tiles that 25 meeting. I don't know what was advised to others, but 25 you had on which you were working from PRA that day? PROSE COURT REPoitnIC AGOICY. INC. PROSE COURT REPORTING AGENCY. INC. Page 19 Page 20 2 A. I don't believe so. • 1 behalf: that is, who purpOrte to represent 2 O. Okay. Mae anyone preventing you from 2 Mr. Rothstein since you left the firm that day? 3 taking anything? 3 A. No. 4 A. No. 4 O. DO you know Mr. Malt? 0• Okay. Did you print Out any documentation Yes. 6 from your server or from the flrn's server that day 6 O. Do you recog -- are you aware that he to take with you? 7 represents Mr. Rothstein? 0 A. Not that I recall. 0 A. Yea. 9 O. Do you recall taking anything free 9 Okay. have you spoken with him since that 10 RM•offin that day, that day being that same 10 Monday? 11 Monday? 11 Me called me on a morning before a hearing to 12 A. No. 12 ask me where Judge Crow's courtroom was. And I told 13 Q. Obviously Scott Rothstein was not there? 13 him, and that was the extent of that conversation. 14 A. Correct. 24 Otherwise. I have had tero communication with Marc 15 Rave you ever spoken, excuse me, have you 15 Pura. 16 ever seen Mr. Rothstein since that Monday at the 16 With regard to the firm being advised that Q. 1? meeting? 11 the firm was shutting down on that Monday. did you 10 A. What do you mean have I seen him? IS subsequently return to the firm's offices? Let me 19 Seen him in person, I'm sorry. 19 Stalks that. Now long did you stay at the fine that 20 A. No. 20 day? 21 Q. Okay, have you spoken with him at any time 21 A. 1 don't remember. 22 since the Monday meeting at which time you were 22 Did you stay all day? 0. 23 advised that the firm was shutting down? 23 I believe so. 24 24 Were you able to work on your files? 25 0. Have you spoken on any. with anyone on his 25 I don't understand the question. PROSE COAST Unwell.; AGENCY. INC. PROSE Ord REPORTING AGENCY, INC. EFTA01100753 Page 21 Page 22 1 0. Were you able to do legal work on the 1 O. Was there a point in time that you were 2 matters that wherein you represent individuals? 2 prevented from entering your office or the offices 3 Was 1 able to? Yes. I was physically able to 3 of AAA? do that. 4 yea. 5 Did you work on legal matters that day? 5 At what point in time were you prevented 6 A. No. 6 from going into the offices? 7 Did you subsequently. after that date, did 7 A. I don't remember. you return to the PRA offices? B O. Mow many days were you able to access the 9 A. Yes. 9 officer before you were prevented? 10 O. And where are those offices or where were 10 A. I don't remember. 11 those offices located? 11 O. YOu don't know whether it was a day or 12 Las Olas. 12 three days or five days that you were allowed to go 13 Q. The address, please? 13 into the office? 14 A. I don't remember. 14 A. The period of time that I was able to go into 15 O. With regard to the -- 15 the office encompasses all of them things that you just 16 A. 401. 16 did. one day, three days, five days, yes. I can 17 O. Las Oles? 17 definitely say with certainty 1 was able to do that. 10 A. Oneness nods head.1 16 O. During the month Of October were you 19 O. Did you, did you after that Monday did you 19 allowed to go into the office more than ten days? 20 return to the offices at 401 Las Dlas. the RPA 20 A. Yes. 21 offices? 21 O. Did they put -- well, let me strike that. 22 Yes. 22 Did someone put restrictions on what your access was 23 And did you return every day thereafter 23 to the office, the MA office? 24 for a period of time? 24 A. Yes. 25 A. No. 25 0. Okay. Who put the restrictions on the PROSE COURT RESORTING AGENCY, INC. PAOSt COURT REPCeTne AGEACT. INC. Page 23 Page 24 1 entry to the office? 1 Police, U.S. Marshals. 1 don't know. 2 A. From my recollection there were at some point O. Well, who would, who would monitor whether 3 in time, there were people In the office monitoring 4 you came In or couldn't go into the office? 4 activity in the office. 5 I don't know. 5 O. Was that the first week after the Monday? 6 Q. Was there someone there? 6 A. I don't recall. 7 A. Was there someone where? 7 Did you ever, did you receive any O. O. The Ispression I got Is that there was guidelines either at the Monday meeting or 9 some limitation on your ability to access the PM 9 thereafter es to what you could or could not remove 10 offices after the Monday at which time you were 10 from the file, from the, I'm sorry from the Pith 11 advised that the firm was shutting down. Did 1 11 offices? 12 misunderstand you? 12 A. I believe so. 13 No, that's correct. 13 And who put those guidelines out, do you Q. 14 Okay. Wh0 then, if you know, Or whet, if 14 recall? 15 it was an entity, placed any restrictions On your IS A. No. 16 access to AAA offices? 16 O. Were they in a written form? 17 A. I don't know. 1? IS O. When you would go to the office -- well. 16 Okay. Was given in what fora. how did you 19 let as strike that. After how many days -- well. 19 learn what you could and could not take from the 20 let ne strike that. 20 office? 21 The very day, the same day that you 21 A. More rumor than anything else is what I 22 were advised that the office was closing down, were 22 remember. 23 there any individuals that were monitoring whit, if 23 O. Old you discuss that with other 24 anything, was to be removed or not removed from the 24 individuals or other attorneys who were working et 25 office, like a security force. Steward County 25 RIM? PROSE COURT REPORTING Meier. INC. PROSE COM/ REPORTING AGENCY. INC. EFTA01100754 Page 25 Page 26 1 A. Possibly. 1 electronic date at the RR. firm. in addition to, 2 Q. Did you ever attempt to remove something 2 excuse mom. the 6-mall server was and Octet. wee 3 from the office of the /MA offices and someone 3 there anything else from an electronic storage or 4 prevented you? 4 communication means through AM? 5 A. NO. 5 A. Yes. 6 Q. Old you ever -- and when 1 say remove I 6 O. What else was there? 7 mean an the sense of physically remove: that Is. 7 A. That stored electronic materials? I tate Oct boxes or take out files or something of 0. Pint. or that you could communicate with 9 that nature. 9 someone elm either Inside or out of the firm. YOu 10 A. 1 understand the definition of remove. 10 heel the server, e-mail server. You had Qtask. What 11 O. With regard tou there were also, 1 11 else did you have? 12 understand you had an e-mail server at the office? 12 A. To communicate with others, e-mail and Otask. 13 A. Okay. 13 O. And how about within the Confines of the 34 O. Is that correct? 14 firm, was there another electronic mail system Or 16 A. Yes. 15 electronic system either for storage or for 16 0. And I have seen something, there is 16 coamunication? 17 something that's called Otask. Ate you familiar 17 A. To the best of my recollection, none for Is with Qtask? la communicetion. Storage, yes. There were electronic 19 A. Yes. 19 paperless storage case management systems in place. 20 O. And what do you understand Otask or what 20 And with regard to the electronic case 21 did you understand that Otask did: that Is, as an 21 management system, were yOur files, including the 22 electronic service? 22 three cases involving Kr. Epstein, were those cases 23 A web based network to Stott files and other 23 on the electronic case management system? 24 matOOOOOO 24 A. Yes. 25 Q. In terms of electronic storage, or 25 Q. And could you access the electronic case PRIME Cain mmaTING AGENCY. INC. PROSE COURT RETORTING AGENCY. INC. Page 27 Page 28 1 wanegenent system: that is, did you utilize the there a password required to use or access each one? 2 software that was available? 2 A. No. 3 A. yes. 3 Q. Was there a password required to use any 4 O. And had you ever used a system like that 4 of the three? 5 before you came to the PM firm, PM? 5 A. I don't believe so. 6 A. I don't understand. 6 0. As 1 saw in an order that with the Otask 7 O. Okay. Mad you ever used an electronic system that there was some sort of access code that 8 case management software system before you cane to o was required co get into Qtask. 9 PM? 9 A. I saw that too. 10 A. Yes. 10 Q. Did you ever have, did you Over have such 11 O. Was yours the system that you had used 11 a code or a password with regard to Qtask? 12 before was that were you able to integrate that with 12 A. I don't remember. 13 ARA, with the BRA file or system when you got there, 13 O. Was the receiver and/or it's, Ns. Seton or 14 or did your files have to be put on the new AAA 14 hie attorneys asked for you to provide any passwords 15 system? 15 or information to access any of your filet? 16 A. The latter. 16 A. I don't think so. 17 O. In addition, so we had the e-mall server, 17 Q. DO you understand that you have a 18 Otask, and electronic case management system. Was 18 requirement or you're required to give the password 19 there any other type of electronic storage or system 19 If requested by Mr. Secon? 20 that was available for communication or 'torso, at 20 A. I don't know the password to elm to anybody. 21 ARA? 21 I never know there was a password. 22 A. Not that I recall. 22 O. Did you -- 23 O. With regard to the s-mall States. well, 23 A. I don't believe. 24 with regard to the e-mail system, Quist. and 24 O. Did you use Qtask? 25 electronic case management. did you require. was 25 A. I have used otaek. PROSE COURT REPORTING AGENCY, INC. PROSE COURT REPORTING AGENCY, INC. EFTA01100755 Page 29 Page 30 1 Q. With regard to your, the tiles 1 firm but you just didn't sign them up before you 2 specifically, specifically the -- well, let me 2 left? 3 strike that. During she time you were at RRA, of 3 MR. SCAROLA: Objection, calls for 4 the three files. Jane Doe, and C.Y. or in 4 speculation. 5 addition to those throe files, did yOu represent any 5 THE WITNESS: Yes. 6 other individuals who were potential claimants 6 AY MR. CIOTTON: 7 against Mr. Epstein? 7 O. la there a reason that you would not have 0 1 don't believe to. 8 signed them up during the time you were with -- or 9 All right. I received notification from 9 let me strike that. Prior to the implosion, prier. 10 you as to a Ma. N.R.? 10 prior to that Monday when you were advised that the 11 A. N.A. 11 PM first was closing down, had you made any plans to 12 O. N.R. and Na. D.F. I believe is her name? 12 leave that firm, that is the ARA firm? 13 A. Correct. 13 A. NO. 14 O. Were either of those individuals, had 14 0. okay. Had you discussed with any other 15 either of those individuals contacted you Prier to 15 attorneys in RPA departing from PRA or the RPA firm 16 leaving the MA firm? 16 prior to that Monday meeting at which time you were 17 I don't believe so. 17 advised that the firm was shutting down? IS Is it your testimony then that none. 10 A. NO. 19 neither Ma. N.P. nor Ma. D.F. would have had a fee 19 You indicated it's possible that Na. N.P. O. 20 agreement or representation agreement with the RRA 20 or Ms. D.F. may have contacted you prior to your 21 firm because they hadn't contacted you prior to your 21 departure or prior to that Monday meeting. what 22 departure from that firm; is that correct? 22 makes you believe that? 23 A. I'm not sure. 23 A. I don't remember exactly the timing of any 24 O. Is it possible that Ms., either Ns. N.A. 24 communications between myself and Ms. O.F. Or Pls. N.R. 25 or Ns. D.F. contacted you before you left the RAA 25 And it seems to me that it was around the time period PROSE COURT REPORTING AGENCY, INC. PROSE COURT REPORTING AGENCY, INC. Page 31 Page 37 1 either just before or just after I do believe 1 spoke I don't remember. 2 with one or maybe both of them on at least one occasion 2 Okay. 3 before the disbandment of AM 3 A. I am now. And I know for a fact I signed each 4 0. Nell, with the program that you did have, 5 One of the clients up after the disbandment of AAA 5 could you delete it and then you would have to go 6 I can't tell you with any degree of certainty 6 into the delete It and further delete it to Clean It whether they signed a fee agreement with RRA prior out? 8 to the disband•ent. B A. I don't remember. 9 O. Have you been able to do any transfers of 9 Q. You don't remember back to October or 10 your, of -- let me strike that. Mich regard to the 10 September of '09 et this point? 11 e-mail server at ARA. have you had occasion to 11 A. That's just not what I do. I mean, 1 don't 12 access that since that Monday: that Is, the Monday 12 just delete ♦-ails. So I don't know what you had to 13 meeting that you referred to in either late October 13 do. You take me for somebody more e-mail savvy than 14 or early November of '09? 14 am about that. 15 A. Yes. 15 O. DO you basically save all your e-malls or 16 O. All right. And have you had full access, 16 had you in the past when you were at PRA/ 17 at some point did you get full access to all of your 17 A. I don't intentionally save or delete. They 16 e-mail that, that existed at least, that you had not 10 are just there. 19 removed -- let me start again. 19 O. And when you, when you, at some point 20 Under an e-mail server you, you have 20 after the Monday meeting, were you able to transfer 21 the ability, obviously, to delete whet you, what you 21 whatever e-malls you had from RRA to your current 22 choose, correct? 22 program? 23 A. As do you. 23 At Farmer. Jaffe, Weissing? 24 Q. As do I, right. And were you using like • 24 Correct. Q. 25 Microsoft Outlook program? 25 A. No. PROSE COURT REPORTING AGENCY. INC. PROSE COUNT REPORTING AGENCY, INC. EFTA01100756 Page 33 Page 34 1 O. Were you at some point given access to all 1 A. I don't remember. 7 your e-malls so it could be downloaded either on a 2 0- You say yOu don't remember. Would there disk, hard disc, floppy disk, or some other storage 3 have been a reason that you either requested or medium so that you had access to all your prior 4 didn't request access to your prior e-mail? When 5 e-mails when you were at ERA? 5 say prior 1 mean at ERA 6 A. 1 don't know. 6 A. Usually you read all of your e-nails and there 7 Q. Did you ever make that request to someone, 7 shouldn't be anything that I had not read. However, either the receiver or anyone else associated with 6 there are some 4-nalla that you would like to keep 9 MA? 9 around. So there may have been reason for me to have 10 1 don't remember if I made that request. 10 requested. However. I don't believe I was ever granted 11 0. I thought you indicated earlier, 11 access to those e-mails, and I can't specifically 12 Hz. Edwards, that you had access to some of your 12 remember requesting the a-malls. 13 e-mails. 13 Q. Within, within the e-mails you would have 14 A. I had access to all of my e-malls on that 14 corresponded with or communicated with people 15 Monday of the meeting, on the neat day, on that Tuesday, 15 outside of the firm and as well as people within the IA right, the immediately following the meeting. 32:46 at 16 firm, true? 17 soma point In time it was cutoff and since that time, 17 A. Ever, yes. 16 when it was cutoff. I don't believe I have ever had le Q. During the time you were ERA 19 access back to my entire e-mall System. 19 A. Did I ever communicate with somebody outside? 20 Q. Okay. Nave you had scout to portions of 20 I connunicated with you. 21 your e-mail system? 21 0. Correct. 22 Not that I remember. 22 A. So you know that to be true. Yeah, of course. 23 Nave you attempted to obtain access or 23 I know that to be true. And my question 24 requested that you obtain.access or information from 24 is as well within the server or e-mail system with 25 your e-mail, Ire the AAA e-mail 25 . ARA, did you ever also communicate with other PROSE COURT REPORTING AGENCY. INC. PROSE COURT REPORTING AGENCY, INC. Page 35 Page 36 1 'paralegals, other Staff et PM? Since the meeting that occurred on 2 Yes. 2 that Monday et which time you were advised the firm 3 0. And would you see, receive, if it was 3 was shutting down, have you accessed Otask for any something from one of the other partners at ERA reason? 5 would you receive: that Is, did you get fire-wide 5 A. 1 don't believe so. 6 e-mails from time to time about Specific topics? 6 0. What kind of -- you said, you described 7 A. Yes. 7 earlier that (Malik was a web based network of files Q. All right. When you, during the time that A for files and other materials. And in what fashion 9 you want back to AAA, did you printout, and up until 9 did you use Otask during the time you were with AM, 10 the time you were denied access to the e-mail 10 AM? 11 server, did you ever print, printout any e-malls or 11 A. Qtask is a project centric web-based Program. 12 transfer any a-mails that you can recall? 12 So projects could be created. The project would 13 A. Not that I can recall. 13 normally be a case, and that use discussed with lawyers 14 Q. All right. With regard to the Otask 14 the way that you may gather around a table end discuss 15 system, have you been, since that Monday have you IS And at times I was invited to projects on various it. 16 been able to use that system in any fashion? 16 Cases and utilized that system. 11 What do you mean by that? 17 IS that the only fashion that you would 16 Have you been able to access Otask either 16 have used Otask during the time you were with ARA? 19 to look to see whet was there or in the alternative 19 Yes. 20 pull information from so that you could printout 20 And when you say a project, as an example. 21 information from Otask? 21 Jane Doe versus Jeffrey Epstein, if that had been 22 I don't know. Probably. 22 put, just this is hypothetically end then I will ask 23 Okay. Have you attempted since that 23 you later whether that was in the system but if you 21 Monday -- well, after that Monday meeting -- let me 24 wanted or let me strike that. 25 strike that. 75 Could Jane Doe versus Jeffrey Epstein PROBE COURT REPORTING AGENCY, INC. PROSE COURT REPORTING =ACT. INC. EFTA01100757 Page 37 Page 31 1 been put in the Otask program for, for purposes of 1 Q. When you say a specific project, sf 1 2 creating a project? 2 understand you correctly, Mr. Edwards. that would 3 Repeat it again. 3 hive been, as an example. it could be any case. It 4 Okay. Could a case like Jane Doe versus • could be a real estate case, it Could be a labor 5 Jeffrey Epstein been put in the Qtask system as a 5 case. it could be Jane Doe versus Jeffrey Epstein. 6 project so that you and others <Quid look at It7 6 but someone could, someone whether it was you or 1 A. You mean is. 1s, is the project capable of 7 someone else could put In facts and information 0 holding such a project? • about the case? 9 Ye.. just generically. 9 Similar to any case management system that's. 10 A. Yee, yes. 10 it just happens to be web based, but you have the right 11 0. And in terms of the RRA system, did the 11 concept. 12 PRA system ever nave as. as a project Jane Doe 12 O. Is the concept the same concept for en 13 versus Jeffrey Epstein? 13 electronic, for the third electronic system, you had 14 A. 1 don't believe so. 14 the electronic case management system? 15 Q. Dld you ever look fn the Qtask, Qtask 15 A. 1 suppose at full capacity it. It may. 1 Jost 16 system to determine whether you or anyone on your 16 wasn't that adept at °task to know all of the 17 behalf or any other person In the firm had ever put 17 capabilities of Qtask. 10 Jane Doe versus Jeffrey Epstein Into the Otask le 0. With regard to the third item which I am 19 system? 19 going to COM back to (Mask In lust a minute, the 20 A. Yes. 20 electronic case management software, what was the 21 O. Okay. And what did you find or not find? 21 name of that software? 22 I, I don't remember if that was the name of 22 I believe ft's called Fortin. 23 any project in the system. It could have been, but it 23 Q. F-o-r-t-1-$7 24 may not have been. 1 don't remember that as a specific 24 A. I think so. 25 project in the. system. 25 O. 1 may have asked you, have you ever used a MISS COURT REPORTING AGENCY. INC. PROSE COURT REPORTING AGENCY. INC. Page 39 Pager 40 1 Fortis spites before you cam* to Rothstein -- THE WITNESS: 1 don't'understend. 2 A. Had 1 ever used Fortis before I came to ABA? 2 MR. SCAROLA: Are you asking whether that. 3 0. Yes. 3 that capability existed? 4 A. Mo. 4 MR. CR1TTON: Sure. 5 0. Mow, back to Otask. Did you, do you have THE WITNESS: Did the capability exist? 6 a recollection -- let a strike that. Did you ever 6 MR. CRITTON: Right. Again Mr. SCarOle 7 personally ever put any information into the Qtask 7 didn't want to let me go through the e system for a project -- 8 explanation because he thought you understand 9 A. Yes. 9 it and I know you did, Brad. I know you 10 Q. -- on your cases? 10 understand. 11 A. Yes. 11 THE WITNESS: 1 don't know that 12 Q. Did you ever put, and 1 think you just 12 understand that question. I want to make sure 13 testified as to the best of your recollection, Jane 13 that 1 answer your question accurately. 14 Doe versus Jeffrey Epstein was never put into the 14 MR. CR1TTON: See, cut me off too early, 15 Otask system, correct? 15 earlier. 16 A. As the name of a project? 16 MR. SCAROLA: No, too late. 17 Q. Yes, sir. 17 BY MR. CRISTO*: NO. I don't believe so. le Hz. Edwards. what 1 am trying to get is 19 Well, was, when you say the name of • 19 you described the Qtask as being project centric. 20 project, could, could information about Jane Doe 20 And as 1 understoOd St. the project may be given s 21 versus Jeffrey Epstein have gotten into the system 21 label or a title? 22 but not identified as a, quote. unquote, Project? 22 A. Correct. 23 MA. SCARO/A: Calls for speculation. 23 Q. So, it could be Jane Doe versus Epstein: 24 MR. CAITTOM: Do you understand the 24 It could be Jane Doe; it could just be assault case: 25 question, sir? 25 is that correct, whatever you wanted to cell or NOSE COURT REPORTING AGONY, INC. PROSE COURT REPORTING AGMs. INC. EFTA01100758 Page 41 Page 42 1 someone wanted to call the project? 1 A. let's say 1 an the lead on a project: I 2 A. You have the right idea. 2 believe that is what It was called the. I believe that 3 O. And if I understand it correctly Is In 3 was the title given to the person that initiates the 4 terms of the project, is if it was, If it was as an 4 project, If I want to then Invite one or two or three or 5 example the Jane Doe case, you could, you or anyone 5 100 other attorneys to that project to help work on 6 else could put Information in about Jane Doe. might 6 various aspects. I could do that. 7 not call it Jane Doe, but whatever amount of 7 And if I didn't choose to add 8 information you or anyone else wanted to put in, somebody, and another attorney said make me a lead 9 could put it into the Qtask so that other attorneys. 9 so that I can add somebody, that's another way that 10 staff, investigators, paralegals, anyone whO could 10 that other lead could have invited somebody else co 11 access the (Mask system, could see that project• is 11 the project. 12 that correct? 12 And when you open up the interphsse 13 A. So that the people that were invited to the 13 of (Mast, you're Immediately shown a portfolio of or 14 project could see the project and those people only. 14 a photograph of the people that are invited CO the 15 Q. And when you say invited to the project. 15 specific project and those people can access It. 16 is. would, would, assuming you're the person who )6 Q. So, if it was, as an example. If It was. 17 created the project -- 11 if you were the lead person and you invited 18 A. Okay. 18 Kr. Adler and you invited Mr. Seeger in and 19 -- would you then set the parameters as 19 Kr. Rothstein in, there, when you punched up the 20 to, or the guidelines as to who could come into the 20 Otask on the screen, 1 would see Mr. Rothstein's 21 project? 21 picture. I would see yours. I would see 22 A. Maybe. 22 Mr. Berger's and Mr. Adler's? 23 Okay. If. again. If It wasn't you, who 23 Correct. 24 else could have set the parameters: that is. who 24 Q. As an example. 25 else can access the file? 25 A. Yes. PROSE CCORT REPORTING AGENCY. PROSE COURT REPORTING AGENCY, INC. Page 43 Page 44 1 O. Would I only aim pictures or would I see • 1 A. That's correct. 2 names as well? 2 O. And during the time that you did, you, 3 A. 1 don't remember that. 3 when you were the lead. sae you the one who chose 1 Q. Would it be a correct statement that 4 what went into the file, to the (Mask file? 5 during the time you were at R . you did use ;Mask? 5 6 A. Yes. 6 O. Who would have mSde that decision? 7 0. And did you ever put projects; that is, 7 A. Everybody in the, anybody that's invited can B did you ever es the lead create projects through the 8 add. I'm not the one that does It. Nobody has to roan 9 Otask system? 9 to me to insert anything in the (Mask. You can add if 10 A. Yes. 10 you're Invited. 11 O. Would someone else, would, assuming that 11 O. Well, let's assume that you are, you're 12 you were the lead and you created the project, would 12 the lead but you don't invite anyone: that is, you 13 only you be able to add information to Qtask? 13 create the 45:01 time project. You're the person 14 A. No. 14 doing the adding, not scant/Ise but you're the 15 0. Okay. Wee, was any invitee Or person 15 person that puts the information in. 16 allowed access. was he or she allowed to add to 16 A. 1 understood the question until you added the 1? (Mesa? 17 segment about maybe some Staff member helps you add the 16 A. Correct. 18 (mask. That just doesn't make sense with the program. 19 Q. Okay. Would he or she also be able to 19 Q. Nell. with (Mask, If you're the lead and 20 delete from (mask If they were an Invitee? 20 you don't Invite anyone in because you're creating 2) A. I don't know that. 21 the project itself, are you the person who chooses 22 O. Were you ever, did you ever -- In any -- 1 22 exactly what goes in? 23 assume that you were not only the lead but from time 23 A. I am the person who puts in what gees in. 24 to time you were invited into (Mask: Is that 24 Q. All right. Are you, are you responding to 25 correct? 25 questions within Otesk where you put, you describe PROSE COURT REPORTING AGENCY, INC. most Com REPORTING roomy, INC. EFTA01100759 Page 45 Page 46 1 the case. You describe the facts. You describe the -- or suggestions. Let me strike that. 2 witnesses, thing, Of that nature. or are you 2 With regard to the Otask, once, 3 actually, can you -- well, first of all can you do 3 once -- assuming that You're the lead, you Create 4 that? 1 the project and then you. you say. okay, now it's in 5 A. Can you describe the case and describe the 5 a form that I want to get SOM. Invitees involved. 6 facts? Yes, you can. 6 Do you then fend that project; that is. you then on 7 Q. And is that, when you say project centric. 1 Otask you list the invitees end those people would B Is that what you're doing very much like the 8 be. get some sort of cue that they had been invited electronic, much like the Portia program? 9 to the project up to the Qtask system? 10 A. It's not very much like the fortis program in 10 A. I don't remember the exact process for 11 my mind, but it's, It is whit you are doing, you're 11 inviting, but there is a way to invite. And to the test 12 inputting information about a specific project. 12 of my recollection, they do receive a notification that 13 O. Can you put in the facts about a case, 13 they have been invited so that they con accept. 14 again lust generically, can you put in facts about a 14 Q. Okay. Can, can someone who has not been IS particular case and then ask someone In your 15 Invited also access the system) )6 invitees to comment on what they think, might think 16 A. No. I7 the value of the case is or is not and give 17 0. Okay. And how do you know that? 18 suggestions as to OleCOVery and things of that )8 A. That's Just not how the system works. 19 nature? Is that all true? 19 0. Nell, ix may not be how the system works, 20 A. Yea. 20 but say if Hr. Rothstein wanted to access when he 21 O. And with regard to -- and once those 21 was the heed person at the KRA firm, he wanted to 22 invitees show up and they're photographed, then each 22 access the Q. Otask system, do you believe that he 23 of those Individuals can have access to the file and 23 would have been able to access the system whether 21 add their thoughts or opinions -- - 24 you Invited him or not? 25 A. Repeat lt. 25 PROSE COURT REPORTING AGENCY, INC. PROSE COURT REPORTING AGENCY, INC. Page 47 Page 48 1 Q. And why do you believe that to be true? 1 post documents like an attachment? 2 A. It's not how the system works. 2 I believe it has that capability. I think the 3 O. Well, at least as you understand the 3 answer is yea. 4 system? 4 O. Now, with regard to the three cases that 5 A. Well, if you want to tell me that it works a 5 you -- well, with regard to Jane Doe versus Jeffrey 6 different way, then maybe you can persuade :re but that's 6 Epstein. 1 think you already told me you don't how I understand the system. 7 recall whether you put that in Mask: 1$ that B I am not, I'm not arguing with you. 8 correct? PEA. SCAROLR: Actually you are. 9 I didn't tell you that. 10 THE WITNESS: Assuming you had boon on 10 Okay. Let Me ask you then: Did you ever 11 Qtask, it would help to get past all of these 11 use °task, you personally create a project as it 12 questions. If you had been on Qtask it would 12 related to Jane Doe's case against Mr. Epstein? 13 help to get past all of this and you would see 13 A. No. 14 exactly what I am trying to describe to you. 14 Q. To your knowledge did you direct anyone -- 15 MR. cRITTCH: I would like to get on 15 well, let me strike that. Did you direct anyone to 16 Otask. /6 crease a project on Ocala for the Jane Doe case 11 TUE WITNESS; Qtask.com. 17 against Hr. Epstein? 18 BY NR. CRITTON: IS A. No. 19 Q. Okay. I'll remember that. With regard 19 O. Okay. Do you know have you ever have 20 to, so as to whether or not Mr. Rothstein could have 20 looked at the °Can system -- let me strike that. 21 accessed It or Hr. Rosenfeldt or anyone else who was 21 Prom what you were able to access Of 22 not an invitee at least from your knowledge, you 22 the Quist system, did you ever go online on the 23 believe they cannot access it? 23 Qtask system to determine whether anyone else had 24 A. Correct. 24 ever put the Jane Doe case against Hr. Epstein OA 25 O. Can you as wall on (Mask, can you as well 25 Otask? PROSE COURT REPORTING AGENcY, INC. PROSE COURT REPORTING AGENCY, INC. EFTA01100760 Page 49 Page 50 1 1 Q. Okay. And so it's your testimony as In 2 O. And therefore as you sit here today. you 2 as you know the L.N. versus Jeffrey Epstein case was 3 don't know whether someone else, whether it was 3 not ever on the Otask system: is that correct? another attorney, whether it was an investigator or 4 A. To the best of my recollection today. 5 a staff person ever put the Jane Doe versus Epstein 5 0. When 1 describe both the Jane Doe versus 6 case on Qtask] 6 Jeffrey Epstein case and the L.M. versus Jeffrey Or whether it was you, right. 7 Epstein case being on Otask. I don't necessarily 6 Q. Right. As to L.M., did you ever put mean just the pleadings. I mean any aspect of it, 9 L.M.'s case or direct -- well, let me strike that. 9 not necessarily the pleadings or the fact that the 10 Did you ever create a project for L.M. on (Mask? ID case was there but the factual circumstances 11 No. 11 surrounding either case. 12 Q. Did you ever direct that someone else 12 A. I em not going to get into what my 13 create a project in °task for the L.M. case, L.N. 13 work-product privilege, I am not going to allow you to 14 versus Jeffrey Epstein case? 14 pierce that privilege. I am not going to tell you what. 15 A. No. 15 regarding those cases, was or was not on Otask. 16 Do you have any knowledge as to whether -- 16 O. Well, let me ask a specific question. So 17 let me strike that. Did you eve: goon Otask or 17 if you want to claim some sort of privilege so the IS have you been able to determine whether anyone else le record is clear. 19 within the RM firm put the L.M. versus Jeffrey 19 A. Sure. 20 Epstein Cale or any aspects of it on °test? Nave 20 Q. With regard to. and let me go first to 21 you looted or do you know? 21 the. finally to the E.Y. case. With regard to the 22 A. I don't know. 22 E.M. versus Jeffrey Epstein case or any aspect of 23 Q. Nos anyone told you that the L.N. case 23 it, did you ever put E.M. into the Qtask system? 24 against Jeffrey Epstein was on °task/ 24. MR. SCAM:ILA: Let us save you scale time. 25 25 Why don't you ask whether the answers with PROSE COURT REPORT/NG AGENCY. INC. PROSE coURT anCeTING AGIUKY, INC. Page 51 Page 52 1 regard to E.N. would be- any different than the 1 create a project? 2 answers given with respect to the other two 2 KR. SCARO1A: You nay answer. 3 cases. 3 THE WITNESS: There was never a project HR. CRITTON: I would have rather have it 4 entitled to my recollection E.M. versus Jeffrey 5 specific. Oftentimes judge want to see that. 5 Epstein, L.M. versus Jeffrey Epetein, Jane Doe 6 SO I understand that if I want something broad 6 versus Jeffrey Epstein. And you're asking was 1 later on, 1 would be glad to accept that, but any information about those cases ever put onto 8 thank you. Do you remember my question. sir. a Otask? 9 THE WITNESS: No. 9 . CRITTON: I didn't ask that question. 10 BY M. CRITTON: 10 THE WITNESS: Okay. 11 Okay. With regard -- 11 HP. CRITTON: But i will in just a minute. 12 HR. SCMOIA: For the record let me 12 THE WITNESS: And my answer Is no, those 13 observe I believe that your Insistence upon 13 titles are not, I don't believe were ever on 14 asking the individual questions that 20o have 14 Ot 15 now asked twice with regard to the, other 15 BY HR. CRITTON: 16 claims, and your refusal to ask the blanket 16 Q. Now, separate and apart from -- let me 17 question in the way in which I have suggested 11 strike that. Let me just stay with E.W. with regard 18 is an annoyance and embarrassment and a 18 rola Old anyone else at your direction put any 19 harassment of this witness which does nothing 19 information regarding C.Y. into the Otask system, en 20 but unnecessarily consume his time. 20 attorney, staff person, or secretary or another 21 BY M. CRITTOW: 21 lawyer? 22 Q. Mr. Edwards, with regard to C.R., did you 22 what do you moan by information? 23 ever put any aspects of that case/ that is, not just 23 O. My information about E.Y. into the Otask 24 the pleadings but any aspeCta of the E.Y. 24 system? 25 Jeffrey Epstein case onto (Mask? Did you ever 25 A. I don't remember. PROSE COURT REPORTING AGENCY. INC. PROSE COURT REPORTIM Aral. INC. EFTA01100761 Page 53 Page 54 1 0. Okay. Sow* don't -- you gave a broader 1 least at your direction regarding these three 2 response to a question or that is you rephrased the 2 individuals' claims against Mr. Epstein? 3 question. So, let me ask it in a brooder sense. 3 A. Information that I put into Otask le 4 was any information about the. your I Information that was inputted into Otask by me. 5 three clients put into the Otask, about your three O. Did you ever direct anyone else to put any 6 clients, Jane Doe, E.N., and L.M. versus Jeffrey 6 additional information in with regard to those three Epstein, or against Jeffrey Epstein, was any 7 claims against Mr. Epstein? information ever put into the Otask system? I don't 6 A. 1 don't believe so. 9 want to know the information, just whether you put 9 O. And what type of information Old you put 10 Information Into the Otask system. 10 into Otask regarding the claims against Mr. Epstein? 11 Yes. 11 MR. SCAROLA: Read that back, please. 12 0. Did you do it yourself or did you do it in 12 Mu requested portion Of the record was 13 conjunction with someone else? 13 reed by the reporter.' 24 A. Explain to me what you mean by did 1 do it in 14 MR. SCARDLA: we're going to Object and 15 conjunction with somebody else. 15 that I will Instruct you not to answer on the 16 0. Noll, is, you ma y have typed in the 16 basis Of both ettorney-client and work-product 11 information yourself. 11 privileges. 10 A. 1 strike one key; somebody else strikes 28 MR. CRITTON: I new.* if Mr. Scarola 19 another? 19 aaaaa ts an objection, you're adopting that end 20 O. No. you may have input all the information 20 you would assert it. So. we don't have to do 21 you want, whatever Information you want to put into 21 that as A repetitious project here? 22 Otask, you may have made the decision to do that. 22 MR. SCAROLA: Correct. 23 All right. My question is someone else, a 23 MR. CRITTC44: And that's Correct. 24 secretary, or a paralegal may have helped you, an 21 MR. SCAROLA: You can, you can assume that 25 investigator may have put some information in. at 25 my instructions to Mr. Edwards will be followed PROSE COURT REPORTING AGENCY, INC. PROSE COURT REPORTING AGENCY. INC. Page 55 Page 56 • by Kr. Edwards unless we expressly tell you 1 Would it, would it be a correct 2 Otherwise. 2 statement during the time that you with PRA that the 3 MR. CRITTON: All right. 3 only claims that you had against Mr. Epstein were 4 MR. SCAROLA: So, when 1 instruct him not Jane Doe, E.M. end L.M.? to answer, he will follow that instruction. 5 The only clients I represented, yes. 6 MR. CRITTON: And you will do that, 6 Q. And not necessarily In a lawsuit but those correct/ 7 ate the only people that, that you and RRA 6 THE WITNESS: That's correct. 8 represented In any. in any existing or potential 9 BY KR. CRITTON: 9 claims against Mr. Epstein during the time you were 10 O. With regard to the, the generic, and If 10 with war? 11 understood you correctly that there was generic or 11 I believe so. 12 there was information put in on one, two, or three 12 Q. By the way. could. could an outside 13 of your clients' claims again Mr. Epstein, did you 13 person, that is a person outside the firm access 11 have or identity individuals who were invitees to 14 Otask as well? 15 that Otask filo? 15 A. YOu can access it right now. 16 A. I'm sorry, what's your question? 16 O. Can -- did you ever allow someone who was 11 O. Did you designate individuals who could be 11 not associated with RM to access the 0teak file 18 invitees to that file? 18 relating to Mr. Epstein? 19 A. Did I Invite anybody Into the project? 19 A. No. 20 Sure. 20 O. Okay. Was there more then one file that 21 A. Yes. 21 was created associated with the claims against 22 O. Okay. Who did you invite Into the Otask? 22 Mr. Epstein? 23 And let me ask you this first. Ms. Edwards: With 23 I don't remember. 24 regard to the claims against Mr. Epstein, the only 24 Did anyone to your knowledge -- well, let 25 three -- well, and I probably need to step back. 25 me strike that. Did anyone other than you create a PROSE COtreT REPORTING AGENCY, INC. MSC EctrAT REPORTING AGENCY. INC. EFTA01100762 Page 5? Page 58 1 Qtask file relating to claims again Mr. Epstein? 1 O. Separate and apart from whether -- 2 A. To the best of my knowledge, no. 1 take that 2 let me strike that. If you didn't create the 3 back. I don't know who treated the project. but 1 am 3 project, who would have? 4 Only aware Of the project that I participated In related 4 A. I don't know. 5 to Mr. Epstein and has molestation of many children. 5 Q. Well, do you remember -- let me strike 6 period. 6 that. Do you know whether with regard to the 1 Q. And what Old you call the project: that is project, and for purposes of st least this question. how it was identified on the Otask system? 8 let me Just call it the Epstein project, are you 9 A. I don't remember. 9 okay with that designation? 10 Q. Do you recall when it was created? 20 A. Yes. 11 A. No. 11 O. Okay. With regard t0 the Epstein project 12 Q. Do you recall whether it was created 12 that was created In the Otask system, if I am 13 within a month of your coming to RNA? 13 understanding correctly, you don't remember whether 14 A. I don't remember. 14 you created It or someone else did, correct? 15 O. Do you recall whether it was, 1 think you 15 A. Correct. 16 said approximately the beginning of April of '09 yOu 16 O. Who would have had access to your files 11 Came to PM. Correct? 17 that could have created the Epstein project other 18 A. Correct. 18 than you? 19 0. All right. And Is it, just so the record 19 A. That question makes no 20 is clear it's, your testimony is you don't recall 20 Okay. 21 whether you created the project in April. May, June. 21 MR. SCAROLA: And it also assures facts 22 July, August, September or October relating to the 22 not in evidence and does not have a prior 23 claims against Hr. Epatain? 23 proper predicate. 24 A. I don't remember if 1 created the project.. - 24 THE WITNESS: That's why it doesn't make 25 PeriOd. 25 sense. PROSE COURT REPORTING AGENCY. INC. PROSE COURT REPORTING AGENCY, INC. Page 59 Page 60 1 SY NA. CRITTON: 1 A. That's good. 2 O. During the time that you were at ARA did 2 0. E.W. and L.M., correct? 3 a number of people have access to the Epstein files 3 A. Correct. 4 either, either in a paper form or in an electronic 4 Q. Were all materials relating to Jeffrey S form? S Epstein kept. kept under, at least for filing, for 6 A. Either/or, yes. 6 filing purposes at RRA, were they kept under the 1 O. And maybe I should get a definition of, 7 Epstein designation or, or sane other designation? 8 with regard to the Epstein files, you had three 0 A. Yee. 9 Cases, Jane Doe, C.X., and L.M., correct? 9 O. Okay. And what wile the designation? 10 NR. SCAROLA: Excuse me. You used Epstein 10 A. 1 don't remitter but It was either under 11 file as a defined copra earlier. Aro you now 11 Epstein or some other designation. 12 using it generically? 12 O. And at AM, were there both paper files or 13 MR. CRIMP: I am going to use it 13 paper information as well as electronic information 14 genitally and when I come back to Mask. I am 14 that was stored or kept regarding the Epstein files? I! Off Qtaek (Or just a minute. So that I have an 15 A. Correct. 16 understanding of how your filing was kept. And 16 0. Was RDA supposed to be or at least 11 I will come back to Otask. So, right now I am 1? designed to be a paperless office? 18 using the Epstein files an a generic form. Not 18 A. YeS. 19 using Otask. Okay. 19 And would every document that Case that 20 MR. SCAROLA: Okay. 20 was associated with the Epstein files, again in the 21 SY MR. GRISSOM: 21 generic sense, was that scanned in or put into the 22 Q. With regard to the Epstein files or 22 ilystem in some fashion at AAA? 23 matters. I know you had -- we know you have three 23 A. To the best of my knowledge. 24 cases that were filed that we have already 24 MR. CR1TTON: Just two minutes. 25 identified, Jane Doe? 2$ PROSE COURT REPORTINC AGENCY. INC. PROSE COURT REPORTING AGENCY, INC. EFTA01100763 Page 61 Page 62 1 BY HP. CRITTON: 1 both in a paper and a papules, manner? 2 O. With regard to the scanned system: that 2 A. No. 3 Is, co store the electronic records, was that put in 3 O. Did you operate only in a -- well, in what 4 through the, through the Fortis program? 4 way did you operate? 5 Yee, I believe so. S A. Paperless. 6 0. And did you as well -- let me strike that. 6 O. Okay. So if, if as an example I sent you 7 Prior to coming to RRA had you ever worked in • 7 correspondence or answers to Interrogatories or a 8 paperless file or in a paperless office? 8 response to a pleading and it cane in the mail. 9 A. 7 don't understand. 9 would that document be scanned and then you would 10 O. Had you ever been working in an office 10 toss away the paper? 11 prior to casing to AM that was designed to be II A. I don't know. 12 paperless? 12 Q. So, you may well have had paper in 13 A. No, but as I mentioned earlier. I have worked 13 addition to -- well, let me strike that. Do you 14 with case management software that stores electronic 14 even know whether the document was scanned? 15 OM of tiles. SO therefore there is a paperlees 15 A. If you're telling me you sent correspondence 16 system. 16 in the mail and I would later see that correspondence In 17 Q. Did you as wall when you came to BRA with I? my virtual mailbox, 1 make the logical assumption that 18 regard to the Epstein related matters or the content 18 it was scanned. I never observed anything being 19 of your Epstein investigation and tiles, had you 19 scanned. 20 placed any Of that on a prior, a previous peperless 20 O. Okay. And do you, if something came to 21 system or did you have the paper itself or both? 21 you by mail, whether it was some form of discovery 22 Both. 22 or request, and I will be In the State Case.. where, 23 And during the time that you operated at 23 which is not a paperless system and you don't file 24 AAA, did yOu operate both with a, you individually 24 through Pacer, would you ever see the paper that 25 with regard to the Epstein files. did you operate 25 actually came to your office or would you only see PROSE COURT REPORTING MAINC1. IRC. PROSE COOT REPORTING AGENCY, INC. Page 63 Page 64 1 it electronically? 1 Marti, system where you, if I understand you 2 A. For the most part I would see it 2 correctly, you input various information into that 3 electronically, but I can't say that I hove never seen a 3 Epstein regarding Epstein files: is that correct? 4 piece of paper come in. 4 A. No. 5 MR. CN1TTON: Okay. Let me take a few 5 You never used those system, with regard 6 minute break. 6 to Epstein files? 7 MR. SCAROLA: Well, wait a second. Do you 7 A. I used the systems. 1 never input anything R want to break at this point? 8 into the System. I think it gets 'Canned in. 9 THE WITNESS: Not really. 9 O. And could anyone in the firs access the 10 MR. SCAROLA: Okay. We would like to keep 10 Fortis system? 11 going. 11 I don't know. 12 MR. CRITTOR: Can I just go to the rest 12 Could you access other tiles that weren't 13 room for two minutes? 13 necessarily yours within the Fortis system it you 14 MR. SCAROLA: Yes. 14 wanted to? 15 THE VIECEGI4APRER: we're now off video 15 A. I don't know. 16 record. The time is 11:21 a.m. 16 0. Hr. Edwards, with regard to your 17 (A brief recess was held./ 17 employment with ARA, did you know any of the BRA IS THE VIDEOGRAPRER: We're now cm video 10 pertnere prior to coming to that firm in 19 record. The time is 11:28 a.m. 19 approximately April of '09? 20 ST MR. CAITTON: 20 A. What do you mean by knew them? 21 O. Couple, few more questions in ()task. Old 21 Did you know them? 22 you ever allow Hr. Rothstein, was he an invitee on 22 Yes. 23 the Epstein-related projects? 23 O. As either an acquaintance or a friend? 24 A. I don't believe 40. 24 A. Yes. 25 O. With regard to the third electronic, the 25 O. Did you have any friends at the RNA firm PROSE COURT REPORTING AGENCY. INC. PROSE COURT REPORTING AdOCY, INC. EFTA01100764 Poise! Page 66 before joining them? 1 A. Right. 2 People that I would consider to be my friend, 2 Q. Did you ever have an Investigator work for 3 yes. 3 you? 4 Q. Who. 4 A. Yes. 5 A. Russell Adler. 5 Okay. Do you know an Individual by the 0. 6 Q. And how did you know Hr. Adler? 6 name of risten, P-1-s-t-e-n? 7 A. We worked out at the sage gym for about, I know an Individual whose last name is approximately four Or flee yfars. 8 Platen. 9 Q. What were you doing, prior to your 9 0. All sight. What's his first name, the one 10 association with AM, what was your employment? 10 you know? 11 What? 11 Mike. 12 Were you working as a solo practitioner? 12 Q. Michael Platte? 13 Were you working with another firm prior to coming 13 A. Yes. 14 to ARA in April of 09? 14 Q. Mike Piston ever do any work for you when 15 A. Solo practitioner. 15 you worked as a solo practitioner at any time prior 16 Q. How long had you been a solo practitioner? 16 to you joining PM? 11 A. Approximately two years. 1? No. 18 Q. During the time you were a solo 15 Q. Did you know of Michael Platen or Mike 19 practitioner, did you ever have any associates 19 Piston prior to joining AM? 20 working for you. solo imply that you're the only 20 A. Mo. 21 one, is that true, or did you have associates that 21 Q. With regard to the investigators that you 22 actually worked for you? 22 used prior to joining AM, did you use, or were any 23 A. Various times I had clerks, law school clerks. 23 of those Individuals over employed by ARA during the 24 but that was it. 24 time you were there? 25 Q. Out no other lawyers? 25 PROSE COURT REPORTING AGENCY. INC. PROSE COURT UPDATING AGENCY, INC. Page 6? Page 66 1 Q. How did it, how did it happen that you 1 joining the firm. 2 came to be employed by AM? 2 Okay. And what happened then? Q. What 3 I was offered a job. 3 ultimately happened that you. that you went from 4 And how did that coos, how did that coma 4 just having an interest to actually contemplating or 5 about? 5 being offered a position? 6 Talking with Russell Adler. 6 A. I didn't say 1 had an Interest. Had you ever had a case against Mr. Adler So, what happened? Now did you then end 8 or with Mr. Adler, either you were on the same side 8 up at ARA? 9 or against? 9 A. Numerous conversations with Russell Adler and 10 A. Yee. 10 him telling me about some of the other people there that 11 O. On how many Occasions/ 11 I hollowed to be good lawyers, respected, ethical 12 A. I can't recall. 12 lawyers, and that this Is a good place t0 work, great 13 Q. Okay. Did Hr. Adler approach you or did 13 comradely. you have a team, I know you handle big cases; 14 you approach him? 14 this will be something that will be good for you. And 15 A. We worked out at the same gym. It wasn't 25 that wall something I talked to him about seriously for 16 about approaching •omebodY. 16 four months maybe before joining AM before finally 17 Q. How did the topic come up? I? agreeing to meet Scott Rothstein. 16 A. He works at this law firm Rothstein Roaenfeldt 20 Q. All right. Had, did Mr. Adler ever 19 Adler. end would talk about it in a positive way for 19 discuss with you parameters or potential Inoue or 20 years before I joined the firs. 20 salary Or whatever the compensation package would 21 Q. And how did It come up that you would be 21 22 Interested in possibly working there; that is did he 22 A. Not specifically. 23 say gee. Brad. you should corm talk to me or did you 23 Q. -- before you first met with 24 say I am interested in working for the firm? 24 Mt. Rothstein? 25 A. He would ask if I would be interested in 25 A. NOt Specifically. PROSE COURT AtromTIPG AGENCY, INC. PROSE COURT MPoRTMC AGENCY. INC. EFTA01100765 Page 69 Page 70 1 Now many tines did you meet with Scott Did you have lunch with him or you just Q. 2 Rothstein prior to accepting a position with ARA? 2 sat down and talked with him et the table at the 3 A. Once. 3 restaurant? Q. Where did the meeting tate place? 4 A. Sat down and talked to him. 5 A. The restaurant BOVA. 5 O. Had you submitted any kind of a resume co 6 0. Old you understand Mr. Rothstein had an 6 Mr. Adler as to what your experience was? Interest in BOVA? 7 A. At the time? 0. SO, you, at that time you are a solo 9 Yee, sir. 9 practitioner. Mr. Adler cells you and says, or you ID A. No. 10 express an interest. Mr. Adler Says we have an 11 Did you learn that during the time that 11 interest in talking to you, and you set up a meeting 12 you worked for BRA 12 with Mr. Rothstein. Is that pretty much It? 13 A. Yes. 13 A. You're now making things up that Is totally 14 0. Okay. who was present other than 14 Inaccurate, end doesn't reflect what 1 have been telling 15 Mr. Rothstein when you met with him at BOVA? IS you at all. I didn't express any interests. I wasn't 16 A. Nobody. 16 looking for a job. I wasn't seeking him out. In fact, 17 O. Mho had set up the meeting? 17 that is the exact opposite of what I have just gone IS A. Russell. 18 through explaining to you about conversations at the gym 19 Q. And had anything been discussed at least 19 that ultimately lead to him convincing me this is a good 20 as of that time with regard to what your opportunity 20 place to cash into and me agreeing to this meeting with 21 was or an terms of compensation? 21 Scott Rothstein. 22 A. Specifically, no. 22 Okay. When you went to meet with Mr! O. 23 Q. Wow long did the meeting with 23 Rothstein did you have any interest or was this just 24 Mr. Rot/Mein lest? 24 a throw-away meeting. Maybe I misunderstood. What 25 A. Ten minutes. 25 did you -- let me strike that. Whet was the purpose PROSE COURT REPORTING AGENCY, INC. PROSE COURT REPORTING AGENCY, IXC. Page 71 Page 72 of the meeting if you had no interest in considering 1 A. I believe so. 2 an opportunity with Rah? 2 O. Okay. What did you talk about: that is, 3 FOf the most part placate Russell Adler. 3 what Was the substance of the meeting? 4 Did Mr. Adler know the type of cases YOU Russell Says you would be an asset to the 5 had? 5 firm. I will treat you fairly. Now, how much 60 you 6 A. Of course. 6 expect to make? Okay. 1 can't do that, but as soon as And was he aware as of that date you had you *hew your worth here, your salary is exponentially filed the three cases against Mr. tpatein? increased because at this firm we operate under a system 9 A. I don't believe so. 9 of fairness. That was the gist of the mating. 10 Had you -- is it your belief that the 10 Q. Did he ask you how such you were making at 11 three eases against -- well, let me strike that. Do 11 that time or how much you had made the preceding 12 you recall when the first meeting was or the only 12 year. '08? 13 meeting that you had with Mr. Rothstein prior to 13 I believe so. 14 joining the firm? 14 what did you tell him? 15 A. It was prior to joining the firm. 15 MR. SCAAOLA: Objection. InstruCt you not 16 O. All right. When was that? 16 to answer on the basis of economic privacy. 17 A. I don't remember. 17 BY M. CAITTON: IS O. Was it within a month Of your joining AM, IS O. Did you tell him what you had made, total 19 two months, three months, six months? 19 campensation for the year 2006? 20 A. Definitely within six months of joining the 20 A. I don't remember. 21 firm. Definitely within three months of joining the 21 Q. well, if I, If I understood you correctly, 22 firm. Within that three month period, I don't recall. 22 1 thought he said is I can't meet that Salary Of 23 Q. So. sometime between January and April of 23 that level of compensation, so you must have told 24 '09, you would have met with Mr. Rothstein for ten 24 him something. 25 minutes? 25 A. Yeah. I answered his gueStion, what did you PROSE COURT REPORTING AGENCY, INC. PROSE COURT REPORTING AGENCY. INC. EFTA01100766 Page /3 Page 14 expect. I BY HR. CRITTON: 2 Q. What did you tell him that you expected? 2 Q. Old you tell him that you -- did you tell 3 MA. SCMOLA: Objection, economic privacy. 3 him that you wanted to make more money than you had 4 BY HR. CRITTON: 4 In the proceeding year? 5 Q. All I em interested now, not necessarily MA. SCAROLA: Saw* objections and 6 what yOu were earning but what you told him. i.e., 6 instructions. 1 Mr. Rothstein that you wanted to get or expected to BY MA. CRITTON: earn if you considered a job at PRA O. Did he tell you how such you would be paid 9 MA. SCUOLA: Objection. Economic 9 if you came to work at ARA: that is. did he mention ID prIvaCy instruct you not to answer. It's 10 a number: This is what your Salary would be if you 11 neither relevant nor materiel nor seasonably I/ come and work here? 12 likely to lead to relevant material information 12 A. I believe so. 13 and invades the *concede privacy of the 13 O. And what number did he say to you? 14 witness. 14 MR. SCAROLA: Objection and same 15 MA. CRITTON: Is that tone? /5 instruction. 16 BY I . CRIMP: 16 BY HR. CRITTON: 17 Q. Mr. Edwards, you gave him a nuMber, is 11 O. Did he also tell you that you would get an 18 that correct? Ills meaning Mr. Rothstein. 18 economic incentive: that is, at the, at sometime 19 I believe so. 19 during the course of the year based upon your 20 O. And was the number that you gave him more 20 produetiOn2 21 than you had earned for the year 2008 or less? 21 A. I would be compensated fairly. 22 MR. SCAAOLA: Sane Objection. 22 Q. And that was it? 23 M. CAITTON: Or the same? 23 A. That was the gist. 24 MA. SCAPULA: Sane objection. same 24 Q. Okay. Old he talk about any benefits that 25 instruction. 25 you would receive? PRoU Celan' UPORT1NG AGENCY. INC. PROSE edger REPLAYING AGENCY. INC. Page 75 Page 76 Possibly. 1 1, I don't believe I discussed the Epstein 2 O. Do you recall what he said? 2 cases with Russell Adler until after I was employed at 3 A. What do you mean by benefits? 3 RRA 4 O. 1 mean would you get health insurance and 4 O. Did you mention Mr. Epstein at your 5 those types of things as well? meeting with Mr. Rothstein? 6 I believe that was discussed. I'm not sure. 6 A. No. 1 I can't tell you I got them but I don't know. 7 O. Did you mention any of your three clients 0. Did you discuss any of your cases that you who were suing Mr. Epstein at the meeting with 9 had with him? 9 Mr. Rothstein? 10 A. No. 10 12 Okay. Did you sign an employment 11 Q. With regard to the, did you, did you 12 agreement at any time with ARA? 12 discuss with him if you came to work with PM that 13 13 the cases -- well, let me strike that. Did he 14 O. After the -- let me go back. Did you say 14 mention that If, if yOu Cam and worked for the firs 15 you did or did not discuss any of your current cases 15 that those cases would become the property of AAA? 16 with him? 16 A. No. 17 A. Did not. Il Q. Did you understand that to be true? 18 Q. Okay. Were you aware, had you discussed 18 A. I mean, I suppose so. 19 your cases -- I think you said you had discussed 19 O. okay. Did -- 20 your cases or Russell Adler had an idea of the type 20 A. 1 understood that I was going to be an 21 of cases you had? 21 employee of the firm, of course. 22 A. Over the years Puss and I are friends: we 22 O. Nell, did, did you, at the conclusion of 23 talked about cases. 23 the meeting did you say, yes, 1 would like to work 24 Did you say you had discussed the Epstein 24 here or how did you leave it? 25 cases with him? Him. meaning Adler. 25 A. Think about IT. PROSE COURT REPORTING AGENCY, INC. PROSE COURT REPORTING AGD4CY, INC. EFTA01100767 Page ?? Page 70 1 O. And how long did you think about it? 1 an LLP? 2 A. I don't reaarber. 2 A. During the Initial. Initial meeting with Scott 3 Did you, and who did you contact? well, 3 Rothstein. he told me there are only two equity partners 4 let me strike that. At some point did you make 4 of this law firm, and it will always be that way: myself 5 decision -- 5 and Stuart Rosenfeldt. Period. 6 Yes. 6 0. And did he say that they each own 7 to go work for AM, correct? 50 percent, or did he say, they were Just partners? S Correct. 0 Did not say. 9 Q. Did Mr. Rothstein at the Initial meeting 9 Prior to your -- let me Strike that. I 10 tell you whether you would be a partner? 10 think as yOu said at scam point you made a decision 11 A. NO. 11 to Join AM? 12 Q. Did he describe that you would be at least 12 Right. to the public at large you would be described se 13 Q. And who did you convey that to? 14 partner? 14 A. Russell. 15 A. No. 15 O. And what happened thereafter? That is, 16 Q. Did you understand who the partners 16 how did you go from then being a solo practitioner 17 were -- well, let me trick that. Is AM, was BRA a 17 Into PM? Row did YOU integrate yourself? What wee 10 PA? 18 the timing and what did you do? 19 I don't know. 19 At some point in time I was no longer working 20 Did you ever find out during, up through 20 in my Hollywood office and was working at AM on Las 21 today's date do you know whether AM was a PA or an 21 Olas. So, physically I sheared up to work at a different 22 LLC or an LLP? 22 location. 23 No. 23 And did someone -- well, let me strike Q. 24 Did you ever go online to look at who the • 21 that. From the time that you announced that you 25 offices" and directors were or had members if it was 25 would go, you told Kr. Adler up until the time you PROSE COURT REPORTING AGENCY, INC. PROSE COURT REPORTING AGEWcY, 11(c. Page ?9 Page 60 1 ended up at AAA, how much timed passed? 1 A. I'm finished. 2 A. I don't know. 2 Q. Which case was he the referring lawyer, 3 Prior to starting at RAA, did you have any 3 Mr. Nowell? further conversations with Mr. Rothstein: that is. 4 S up until the day that you showed up at that office? 5 Q. And he nay be the referring lawyer on Jane 6 A. No. 6 Doe, and L.N., you lust don't know as you sit here. Q. And in terms of the cases; that Is. the 1 or he is? Cases with L.M., with L.M., Jane Doe and E.M. those 6 A. He referred E.W.'s case. 9 are cases that you had signed up when you were a 9 0. And the other two cases is he is shown as 10 sole practitioner: Is that Correct? 10 the referring lawyer? 11 Correct. 11 Yea. 12 And with each of those cases there was a, 12 There Is also a person named Cassell who I 13 there is also another lawyer that was Involved -- 13 think is an attorney from Utah? 14 well, let me strike that. In one or more of those 14 A. Okay. 15 cases is Nr. Nowell Involved. or was he at the time 15 Q. DO you recognize the name? 16 you were a solo practitioner? 16 Yes. 1? A. What do you moan by involved? 17 0. Okay. And what's hie first name? ID Involved, was he a referring lawyer? 111 A. Paul. 19 A. Yes. 19 Q. All right. Is he in any way a referring 20 Was he the referring lawyer on all three 20 lawyer, considered a referring lawyer with regard to 21 of those cases? 21 any of the three cases against Mr. Epstein? 22 We was at least the referring lawyer directly 22 A. No. 23 on one. 23 Q. What's hie role? 21 Which one? I'm sorry. I didn't moan to 21 A. handles certain appellate issues. 25 interrupt you. 25 Q. Okay. Is he. is he involved in as pact PROSE COURT RAPORTING MERCY, INC. PROSE COURT REPORTING PRICY, INC. EFTA01100768 Page el Page 02 1 of. as a potential recipient of any contingency fee 1 A. well, not co my knowledge. I don't want t0 2 or Is he paid On an hourly basis. either when you 2 say no. but I don't know of any fee agreement that was 3 Wire a sole practitioner during the RRA stages or at 3 signed with the client. 4 the current time? 4 0. As a -- from the time that the original -- 5 A. Contingency. 5 let me strike that. If I understood you correctly 6 Q. Does he get part, at least as it was set 6 is as an example E.M. was your first case? 7 up as a sole practitioner was Mr. Cassell also on 7 A. First client. the Contract with each of the three individuals? 8 Q. First client, right. Mr. Novell would 9 A. I don't believe so. 9 have referred the came, so he would have shown up as 10 You don't -- he Is not on any of the 10 a referring order. And at seal point Kr. Cased') 11 contracts, Mr. Cassell? 11 also came on the contractor er a contract: is that 12 A. There is a contract that he le on but your 12 correct? 13 Question is when the cases were first signed up. was he 13 A. A contract, yes. 14 on the initial contract. And I believe the answer to 14 Q. So, there was at least two contracts with 15 that is no. 15 regard to EN.? 16 Q. Prior to the time or during the time that 16 A. That 1 remember. 17 you were in sole practice before you went to RRA was 11 Q. And with regard to C.M.. Jane Doe, and 1$ Mr. Cassell ever en any of the contracts with the 10 L.M., you don't recall any new contract being signed 19 three Plaintiffs? 19 between those individuals and ARA; Is that correct? 20 A. Yes. 20 A. That is correct. 21 0. Okay. When you moved to RRA, was a new 21 Q. And with regard to the, whatever the 22 fee agreement signed with each of the Individuals. 22 contingency fee was in each of those three 23 each of the three Plaintiffs? 23 contracts, was that to be split? When you went to 24- A. No. 24 AAA, haw was it to be determined what Rite would 25 Q. Was there some form of an assignment? 25 receive versus what you would receive or Mr. Cassell PROSE COURT REPORTING ACIPCV, INC. PROSE COAT *SKATING ARMY, INC. Page 83 Page 84 1 or Mr. Nowell. assuming there had been some 1 lien again those cases? 2 resolution? 2 A. No. 3 A. RRA would be standing In my shoes. 3 0. Nes he sent you any correspondence 4 And if I understand it correctly, there 4 indicating that he intends t0 assert a lien against. 5 was never an assignment of your contracts: that is, 5 for attorney fees and/or costs that were incurred 6 as a 4010 practitioner to RRA: is that correct? 6 during the time those cases were at ARA? 7 Correct. A. Not specifically related to those cases, but 0 Okay. And It was your Intent just a in general, that concept is something that has been 9 whatever the contract said when you went from solo 9 communicated by a receiver or a trustee to us at Threat. 10 practitioner to RRA. Lf those cases had resolved 10 Jaffe, weissing. 11 during that tine period, RRA, you would have paid 11 Q. Nave you at any time: that Is. have you 12 ARA chat portion to which you were been entitled and 12 acknowledged, has anyone at Farmer, Jaffe 13 Nowell and a Cassell would have gotten their 13 acknowledged their responsibility to repay monies to le percentage? 14 RRA? 15 A. Correct. 15 1 don't understand the question. 16 0. And with regard to. with the new firm, the 16 Q. If the case Is settled, does Farmer, Jaffe 17 Farmer. Jaffe firm, where those new fee agreement• 17 intend to repay the receiver a portion of the fees 10 have been signed with your three clients? 18 at coats? 19 Yea. 19 A. That issue has not been resolved. 20 And ere Mr. Cassell and Ms. Nowell still 20 Q. With regard to, with regard to the 21 on those contracts? 21 third-party -- 22 Yes. 22 ?Interruption at the 000r./ 23 Sas the receiver made a claim against the 23 BY KR. CR1TTON: 24 proceeds of these three cases. that is, he filed, 24 O. Other than the attorneys Is there -- with 25 Mr. Seton on behalf of or as trustee, has he filed a 25 regard to the, other than the attorneys, is there MGR coon? sznerrlieg AGENCY. INC. PROSE COURT REPORTING Katy, INC. EFTA01100769 Page 05 Page 06 1 anyone else other than, on any of these three Cases: MA. SCAAOLA: Let me interrupt for lust • 2 that is, potentially RRA, potentially your new firm, 2 moment. 1 don't know whether the circumstance 3 Mr. Cassell. Mr. Nowell and the Plaintiff, does 3 applies but I want to be sure, does the crepe 4 anyone else stand to benefit from • recovery in any 4 of your emotion include a letter of protection 5 of those cases? 5 to a health care provider? 6 NO. 6 MR. CRITTON: No. 7 Has anyone, has any interest in any of the MA. SCARCER: 1 don't know whether that 8 three cases been assigned to a. to a third party S has occurred in any of these cases, but I 9 other than a law firm or a lawyer or a law firmu 9 assume that's not what you're looking for? /0 that is, to an outside service? 10 MA. CSITTOW: I wasn't, but no, I'm 11 A. 11 looking for -- I think it would not be applied 12 O. Okay. Have any of the potential 12 to any of the three. 13 settlements -- I'm sorry. Have any of the potential 13 You understand I wasn't talking about 14 proceeds from any settlement or verdict been It health care providers. I an talking about 15 assigned or sold to anyone to your knowledge? 15 some Independent person or entity that may 16 No. 16 have purchased some interest or have been 11 O. seas E.M., Jane Ddt, Or L.M. Sold. 17 assigned some interest in any of those 18 assigned, exchanged for consideration. money. or 18 three lawsuits. Do you understand that? 19 promises of money. any portion of their potential 19 THE WITNESS: I think I understood your 20 settlements? 20 question, and my answer was responsive and 21 A. No. 21 was not thinking about lectors of protection at 22 O. Or recoveries? 22 the time that I gave my answer. 23 A. No. 23 BY MR. CRITTOPn 24 If I understood you correctly, 24 Q. With -- if I understood you correctly. 25 Mr. Edwards -- 25 E.W. was your first case? PROSE COURT REPORTING AGENCY. INC. PROSE COURT REPORTING AGENCY. INC. Page 61 Page 80 1 You understood me correctly. A. That is correct. 2 All right. Md when did E.M. retain your 2 O. Co you recall when you first -- well, let 3 services, please? 3 me strike that. She was referred to you by 4 A. Md by first case. Just to clarify, she was my 4 Mr. Nowell? 5 first client -- That is correct. 6 O. I will rephrase it. 6 O. Okay. And how did Mx. Nowell know you? 1 A. -- related to the matter that we're all A. 1 have known him for a long time. 6 familiar with that relates to things that happened to O. Law school? 9 E.M. when She was young. 9 A. He. I have known him since. I'm Cron 10 Let me rephrase the question this way: If 10 Jacksonville Beach. He's from Jacksonville. I have 11 I understand your testimony is E.M., and I'm 11 known him when I was probably ten years old. 12 interested in Epstein cases: 1 am not interested in 12 Okay. Has Mr. Howell, prior to C.M., had O. 13 other portions of your practice. You understand 13 he ever referred to you any other client? 14 that? 14 A. Yes. 15 A. I do. Md 1 think that you understand that 15 Old it involve scare sort of a sexual 16 this case. E.M.'s case and L.M. case did not begin as 16 assault or battery? I? case against Jeffrey Epstein. You 'mow that and I know 17 A. Yes. 10 that, and that's why it's difficult for ma to ask, 18 How many clients prior to N.M. had O. 19 answer these questions related to theae clients because 19 Mr. Howell ever referred you? 20 this began as a Case against the United States 20 A. I don't know. 21 Attorney's Office. 21 More than One? 22 Q. All right. with regard to the, at least 22 Yes. 23 your first representation of any of your three 23 when E.M. was referred to you, what was 0. 24 clients that relate to Mr. Epstein in some fashion, 24 your understanding as to the nature of the 25 your first client was E.W; is that correct? 25 representation. what would it be? PROSE car REPORTING AGENCY, INC. PROSE COURT REPORTING AGENCY. INC. EFTA01100770 Page 89 Page 90 1 A. I don't understand. 1 prior to her coming to see you or your seeing her? 2 O. Why did L.M. come, why did she hire you In 2 A. Yee. 3 the first place? What was the purpose? 3 Okay. And did C.M. for the first. on the 4 A. This is going to get into attorney-client 4 first occasion come to your office or did you talk 5 privileged information as to why she hired me which 5 to her by phone or did you go to her place? 6 would incorporate the things that she told me that 6 First time I talked to 5.147 1 related to my representation, therefore, I am invoking 7 Q. Yes, sir. 8 the privilege and not answering. A. was over the telephone. 9 O. With regard to G.M. you flied a case -- 9 Q. All right. And hew long, how much time 30 well, let me ask you this: Do you know how C.W Came 10 transpired before E.M. retained your services: that /1 to contact Mr. Nowell? Did he ever relate that to 11 is. how many conversations did you have with her 12 you/ 12 before she ultimately retained your services? 13 M. SCAROLA: If St's in information that 13 A. One conversation over the telephone and then 14 you obtained from your Client. I Instruct you 14 the next meeting was in person at my office. That IS not to answer. If it's information that you IS meeting culminated with her retaining my services. 16 obtained from Hr. Howell. 1 also Instruct you 16 And the Initial conversation you had with 0. 17 not to answer. Both instructions are on the 11 her, what did she relate to you? le beefs of attorney-client and work-product 18 A. That's attorney-client privilege information 19 privileges. l9 that 1 an not going to divulge. 20 THE WITNESS: Attorney-Client and 20 O. During the tine that you have been 21 work.-product privilege. 21 involved in this case on behalf of C.M. has 22 BY NA. CRITICS: 22 Mr. Howell participated in the case; that is. has he 23 Q. Did you, did mt. Howell -- and I don't 23 done work on the case? 24 want to know the information, at least right now -- -24 A. Yea. 25 did Mr. Howell give you any information about E.W. 25 Q. What kind of -- what has he done? PROSE COURT REP.:411NG AGENCY, INC. PROSE CODA! REPORTING AGENCY. INC. Page 91 Page 92 1 HR. SCAROLA: Objection, attorney-client 1 Q. During the time that you were a solo 2 privilege and work-product. Instruct you not 2 practitioner working on C.w, Jane Doe, whichever of 3 to answer. the three case, that you had, did you keep time 4 BY MR. CRITTCW: 4 records? 5 O. Your second, your next client was whim 5 A. Some. 6 relating to Mr. Epstein or to the United States 6 Co you keep time records on contingency 1 Government? 7 cases generally, or did you during that time period? 8 I don't reeember. A It's my Intent to. 9 You ultimately filed a case styled Jane 9 Okay. Same would be true with, when you 10 Doe 1 and 2 were petitioners versus the United 10 were at REA, did they have a time program? 11 States of Merle. in July of '08, correct? 11 A. They did have a time program. 12 A. That's correct. 12 Q. Did you Input your tine that you spent on 13 Okay. Who was Jane Doe I? 13 the Epstein related 14 A. 14 That aas a reguirement of the firm. IS Q. Who was Jane Doe 2? 15 Q. Okay. So, you would have been put down 16 A. 16 whatever time you spent, whether lc was a 1? O. At the time that suit was filed, were you 17 contingency fee case or an hourly case: is that 18 representing Jane Doe-L.14" I'm sorry, Jane Doe? 18 correct? 19 A. I believe so, but I'm not sure. 19 A. For the most part: that's correct. 20 Q. In terms of the work that you did for. 20 Q. During the time that Mr. Nowell has been 2] that you have done for all three of the individuals 21 associated with the case, does he provide you with 22 when you were a solo practitioner, did you keep 22 time records as to the work or the amount of work 23 track Of the time; that is, did you keep time 23 that he has done on the case? 24 records? 24 A. No. 25 A. What's your question? 25 Okay. Q. Does he kmip track of his time that PROSE COURT REPORTING AGENCY, INC. PROSE COUNT REPCMTING AGIDICY INK EFTA01100771 Page 93 Page 94 1 he hat spent on each of the cases? A. That was filed in the case? 2 A. I do not know. 2 0. Correct. 3 O. Did you -- has he prepared any pleadings 3 A. No. 4 or documents associated with the cases? 4 Q. Okay. Has he worked on documents, whether 5 MR. SCAROLR: You can answer that 5 it's editing, adding, deleting from pleadings that 6 question. 6 you, pleadings or papers that you have prepared? 7 THE WITNESS: Define Prepared. 7 A. Yes. Sob, can you hand me that water? 0 BY KR. SCAROLA: O. Yea. 9 O. All right. Prepared. Prepared, start. 9 A. Thanks. Appreciate it. 10 ❑rst of ell. started from scratch: that is, has he 10 0. You're welcome. Has he COotinued, did he 11 prepared any of the pleadings or papers that have continued to be involved not only when you were a 12 bean filed in any of the three coves stetting from 12 solo practitioner but during the time that you were 13 scratch that he would have been -- net because you 13 with ARA with regard to editing or working on the 14 said this but he started with the complaint and you 14 Cases? 15 may have changed it, but he started the preparation IS To an extent. 16 Of the document? 16 0. Okay. Do you. how often on the cases have 17 A. Your question is has he started the 1? you consulted with Mr. Howell? By that I mean 10 preparation of a document now, right? 10 before a decision is made as to how you want to do 19 O. Any document, any paper that's been filed 19 discovery or proceed with the filing of the pleading 20 in the cases or I would say passed back and forth 20 or how you're going to respond, does Mr. Nowell. do 21 between lawyers in any of the three cases? 21 you consult with Mr. HOuell during the time you were 22 A. HOS he had edited revised, I mean what -- 22 both solo practicer and were at AAA? 23 O. Right now I am lust asking did he start 23 A. Is your question asking for the answer to be 24 the document such as a complaint or a similar typo 24 in a percentage? Now often- do I consult? I am lust not 25 document? 25 sure how to quantify. PROSE COIMT REPORTING AGENCY. INC. PROSE COURT REPORTING AGENCY, INC. Page 95 Page 96 1 O. Sure. I we okay with that. Now often do • 1 during the titre that you were at ARA, how often 2 you consult with Mr. Nowell with regard to those 2 would you consult with Mx. Nowell regarding the 3 three cases prior to the time that you started with 3 Cases? And I recognize every day or every week 4 your Current farmer. Jaffe association? might be different. Mould you Speak with him like 5 A. It is an impossible question for me to answer 5 once a month, or two or three times a month, or 6 accurately with a percentage that I have spoken with 6 generally once every couple of months? Hr. Nowell about any particular document or anything. 7 A. Depending on what was going on in the cases at 6 O. As to pleadings, do you discuss, do you the time. at sometimes more then others. sand it to him for his review, editing, before you 9 O. Now did L.M. Cline to be a client of yours? 10 file a pleading? ID A. She called me. 11 Typically no. 11 O. And how did she get your name? 12 How often do you consult or have you 12 KR. SCAROLA: To the extent that your 13 Consulted with Mr. Howell during the time you were 13 response to that question would require that 14 with RRA? 14 you reveal either work-product or 15 A. What type Of an answer do you want in terms of 15 attorney-client Privileged Information, 1 16 how often have 17 16 instruct you not to answer. 17 O. Do you do it once a day] 17 THE WITNESS: I simply don't know. 1B A. Nave I ever? I have. 1$ BY MR. CR1TTON: 19 O. Is it a pretty cowmen practice that when 19 O. Did Ms. L.M. hire you in the or -- I'm 20 you're going to filo or dO SON:thing that you would 20 going to strike that. 21 contact Mr. Howell? 21 Now many conversations did you have 22 A. Not at all. 22 with and/or meetings did you have with Ms. L.M. 23 0. So. do you -- 23 before you hired her, or before she hired you. I'm 24 A. Not at ell common I mean. 24 sorry. 25 0. So, during the course of the month. say 25 I don't remember. PROSE COURT REPORTING PaZOCY, INC. PROSE COURT REPORTING AGENCY, INC. EFTA01100772 Page 91 Page 98 1 Q. Did she ever come and meet you at your 1 A. Correct. 2 office? 2 0. -- her originally? 3 A. From the beginning of time until today? 3 A. Correct. 4 No. Back at the time prior to retaining O. Did you ever meet her prior to her signing 5 your services. 5 that fee agreement? 6 I don't remember. 6 A. Yes. Did you ever meet her at her residence or O. And do you COMOOLOOl where that meting 0 place of work? Let me ask you this: Have you ever took place? 9 net her at her place of business or a place of 9 A. Generally, yes. 10 business? 10 O. Okay. Where? II A. No. 11 A. A perk. 12 O. Nave you ever met her at her home, whether 12 Q. And what town? 13 it's an apartment or home, whatever? 13 I don't know. 14 A. Now, you're asking from the beginning of time 14 You don't know whether it was in *toward 15 until now? 15 County or Palm Beach County? 16 O. No. Up until the time she hired you, did 16 A. I do know. 17 you ever meet with her? 11 Q. Which county? le A. Okay. 10 A. Palm Stash County. 19 Q. At her Name or apartment. 19 0. Was that arranged by her to meet her 20 A. To the best of my recollection, no. 20 there? 21 Q. Did you -- did she sign, to the best of 21 Yes. 22 your recollection did she sign a fee agreement? 22 Q. And what, for what purpose did W. L.M. 23 Well, let me strike that. There is a, there is a 23 originally hire you? 24 written fee agreement between L.H. and you and - 24 MA. SCAAOLA: I em going to oblect. That 25 then -- 25 calls for attorney-client privilege PROSE COURT REPORTING AGENCY, INC. PROSE COURT stet's/NIG SOUCY. INC. Page 99 Page 100 1 information. 1 recall whether you were representing Jane Doe at 2 BY NR. CRITTON: 2 that time? 3 O. When you met W. L.M. at the park was 3 I believe I was but 1 do not recall for sure. 4 anyone else present? 4 At the time do you know whether, at the 5 A. Yes. 5 time that you represented Jane 004 1, do you know 6 Q. Who/ 6 whether her name, whether she was considered a 1 A. I don't know. 1 victim by the United States Attorney's Office? 8 O. Male or female? A. Ask your question again. 9 A. I presume both. It's a park. 9 O. All right. At the time you began 10 O. No, no. no. In the meeting that you had 30 representing E.W. or at any time prior to the filing 11 with her -- my guess is there were probably a lot of 31 of the lawsuit against the United States Government 12 people in the park? 12 in July of '00, did you learn whether she was listed 13 A. Correct. 13 as a, or deemed to be a victim by the United States 14 Q. In the meeting that you had with W.L.N. 14 Attorney's Office? 15 was anyone else present/ 15 P . SCAROIA: If that Is information that 16 A. For the conversations between myself and 26 you obtained in the course of the performance 17 Ms. L.M., no. 17 of your responsibilities in representation of IS Q. When you first met with B.M. was anyone le any client. I would instruct you not to answer. 19 present for the conversations between that you and 19 If that Information was obtained 20 Hs. C.W.? 20 through some public source independent of 21 No. 21 the work that you performed es counsel, 22 Q. I think you told sae at the time that the 22 then you may respond. 23 complaint was filed or at the time that the Jane Doe 23 THE WITNESS: I cannot respond. 24 1 and 2 sued the United States Government which was 24 BY MR. CRITTON: 25 in early July, it was July 8th Of 'OB. you don't 25 Q. With regard to the question, I an not PROSE COURT IMPORTING AGENCY, INC. PROSE COVE* REPORTING AGENCY, 2NC. EFTA01100773 Page 101 Page 102 1 interested in what you learned from E.N. All right. 1 conversations with the United States Attorney's 2 Dad you learn from either any correspondence or a 2 Office -- 3 telephone call with any third party that whether 3 MR. SCAROLA: 1 assume -- 4 again prior to [he -- let se start again. 4 BY M. CRITTCM: 5 Prior to the filing of the lawsuit 5 -- regarding, regarding, regarding the O. 6 against Jane Doe 1 and Jane Doe 2 against the United 6 subjeCt Of the lawsuit or Jeffrey Epstein) States Government, did you learn fresh any source, 1 MR. SCARPER: Same objection and 0 maybe a document, maybe a telephone call or a 8 instruction. 9 conversation that you had with a third party 9 KR. CRITTON: These are third parties: 10 separate from your Client. that E.N. was a victim Or ]0 where is the work product? 11 was deemed to be a victim by the United States /1 MR. SCARPER: Work product has to do with 12 Goverment or the United States Attorney's Office? /2 anything that was done in connection with the 13 M. SCAROLA: Sams objection and 13 representation of these three clients. It he 14 instruction. 14 had such conversations Independent of his 15 BY MR. CAITTOR: 15 representation of those clients, then he can 16 O. Sane question with regard CO L.M. Miller. 16 respond to the question. 17 MR. SCAROLA: Sane objection and 17 BY MR. CRITTCM: 16 instruction. 16 Q. Well, lot me ask you a broader question. 19 BY MR. CRITTON: 19 After you tiled the lawsuit against the United 20 O. And sane question with regard to Jane Doe. 20 States of America, were you aware that Marie 21 MR. SCAROLA: Same objection and 2] villafana or the United States Attorney's Office 22 instruction. 22 represented the USA, Correct? 23 BY MR. CRITTOM: 23 A. Yes. 24 Q. Prior to your filing the lawsuit with 24 All right. Did you ever speak with Katie 25 united States Government, did you ever any 25 viiiatana during, during the pendency of that Picot COURT REPORTING AGING,, Inc. PROSE COURT REPORTING AGENCY, INC. Page 103 Page 204 litigation which is still pending today? 1 on behalf of his clients. 2 KR. SCARCER: And I assume that question 2 KR. CRITT011: So. any question that I ask 3 Is qualified by inquiring as to whether such a 3 you with regard to conversations that 4 conversation occurred with regard to any of the 4 Kr. Edwards had with the U.S.A.O.'S office, 5 three individuals who he is ',Presenting claims 5 whether St was Mrs. Villafena or anyone else 6 against Mr. Epstein or the U.S. Attorney's 6 from the time, with regard to the Jane Doe 1 7 Office. correct? 7 and Jane Doe 2 versus U.S.A. case, you would 0 MR. CRITTOM: Say that again? 8 Instruct Hr. Edwards not to answer those 9 MR. SCAROLA: Yes, air. Are you asking 9 questions?? 10 whether such conversations occurred that were )0 MR. SCRRPER: that is correct. 11 relevant to his prosecution of the claims on 11 MR. CRITTON: So If I -- 12 behalf of his three clients? 12 MR. SCAROLA: Obviously pending -- 13 MR. CRITTON: Sure. 13 MR. CRITTOM: lot me just finish. 14 MR. SCAROLA: Then, then the instruction 14 MR. SCAROLA: Obviously pending, obviously 35 remains the sans. The Objection remains the 15 pending some instructions or guidance from the 16 same. 16 court with regard to how the court will 11 BY M. SCAROLA: 17 interpret the work-product privilege in this 10 O. SO, even if, do you -- even if you talked 16 context. I might also add that It is our 19 about it with Mrs. Villafana, even if your client 19 position that any such inquiry exerts a 20 Mx. Edwards spoke with Mrs. Ifillafana about a 20 chilling effect upon the work that Mr. Edwards 21 scheduling issue. it's your position that that Is 21 continues to do on behalf of his three Clients. 22 what, work-product? 22 It is intended as a means to obtain 23 MR. SCAROLA: That's correct. We ere not 23 discovery that would net otherwise be 24 going to discuss anything that Kr. Edwards did 24 available in chose pending claims. It is 25 in the course of the prosecution of his claims 25 Intended to annoy, Cs, and emba PROSE COURT REPORTING AGENCY. INC. PROSE COURT REPORTING AGENCY. 111C. EFTA01100774 Page 105 1 Mr. Epstein in a lawsuit that hat decision as to whether or not the 51.10:494 105 2 absolutely no foundation whatsoever, and 2 motion and letter which you sent to me was 3 was filed for purposes other than a 3 filed in good faith or has any basis in 4 legitimate claim against Mr. Edwards based 4 it. We're unable then to, we'll be in 5 upon any good faith belief that he engaged 5 large part unable to evaluate Out 6 in any form of improper or nations 6 position. 7 conduct and -- 7 MR. SCAROLA: And our position is that e MR. CRETTON: Done? a those are decisions that should well have been 9 MR. SCAROLA: -- those Inquires are not 9 made. Could have been made, and should have 10 reasonably calculated to lead to the discovery 10 been made before you ever filed the claim. 13 of admissible and relevant evidence. So, for 11 KR. CRITTON: All right. Are we done? 22 all of those rearms, we object. 12 M. SCAROLA: Yes. 13 KR. CAPRON: Md let me just put on the 13 MR. CR1TTON: All right. 14 record very briefly so et least at this point 14 M. SCAROLA: At least for now. 15 In time this is all information that clearly is 15 MR. CRITTON: I'm shocked. 16 relevant co the complaint as it". alleged. 16 BY MR. CRITTON: 11 I have received a. my client and I 17 0. With regard CO, with regard to the claim 18 have both received a letter from you 16 Jane Doe 1 and Jane Doe 2 that is currently 19 asserting a motion for fees and costs and 19 pending -- or let me strike that. Jane Doe 2 -- 20 certain sanctions under 57.105. by not 20 Jane DO* I and Jane Doe 2 against the O.S.A. that 21 allowing us to ask what are clearly. I 21 was filed in July of '08, that case is still 22 believe, relevant material, basic 22 pending. 23 discoverable information are preventing 23 A. Okay. 24 our ability to-get all of the facts here 24 O. Is that correct? 25 such that We can make a reasonable 25 That was a question, yes. PROSE COURT REPORTING Aar, INC. PROSE COORS REPORTING AGENCY. 1NC. Page 107 Page 108 1 Q. All right. Md have any, have you had any There were times when they were in my office 2 discussions -- well, let me strike that. What's the 2 and there were times when they were kept in filing 3 status of that case? 3 cabinets elsewhere on one of the RAA Iloore. I believe 4 A. It's still pending. 4 there were five or six floors of KRA 5 Q. Other than still pending is a, is there. 5 Q. Okay. Was there a central storage, say if 6 aro there any outstanding motions? 6 there were a number of files In this Instance 7 No. relating to Mr. Epstein, could you send chose to 8 0. I want to ask, to get back to one question basically central storage and if you wanted someone 9 with regard to both the :Ass': and with regard to the 9 could go down and pick them up and bring them up to 10 Fortis System -- well, let me strike that. 10 you? 11 with regard to the hard copies of the 11 A. I don't know. 12 files that you had that is any paper files that you 12 Well, If you wanted to access something 13 had associated with the Epstein files, where would 13 that was in en Epstein file, and it wasn't in your 14 they have been kept at IWO 24 office, how did you access it: that is, a hard copy? 15 A. In a filing cabinet. 15 A. You're speaking specifically about 16 Q. And were the filing cabinets in your 16 Mr. Epstein's cases or hypothetically with any eases? 11 office or were they out in the general hallways? 17 Q. No, MS. Epstein's uses? 18 A. They were filing cabinets In my office and in le A. AS I sit here right now, I can't say with 19 other locations in the office. 19 absolute certainty that I ever had a piece of the hard 20 O. Okay. With regard to the Epstein related 20 copy file requested for it to be brought to me. 21 matters, where did you keep those if they were -- 21 O. Nell, with regard to Mr. Epstein's rtleS. 22 and by that that is the hard copies. did you keep 22 though, if they were in a location, would it be a 23 those solely in your office or would they have been 23 correct statement that those were not, wasn't a 24 both in your office and in other places throughout 24 locked location or a secure location within the 25 MA? 25 contents of within the confines of the firm? PROSE COURT REICOTING AGENCY, INC. PROSE COURT *[PORTING Marcy. INC. EFTA01100775 Page 109 Page 110 1 I don't know that that's a correct statement. 1 that you were aware of; that is, hard copies? 2 O. You don't know one way or the other? 2 A. 1 don't know. 3 A. lime law firm was constantly expanding and 3 O. Okay. Could have been more. COuld have constantly under construction. For the most part in the 4 been less: you just don't know? 5 beginning the canoe were kept in a, in a filing cabinet 5 Cornet. 6 in my office and later wore kept in a filing cabinet, I 6 0. If I understood your testimony. 7 believe, in a locked storage location in another area of 7 Hr. Rothstein, Mr. Rownfeldt, any other attorney or 8 the office. B investigator could have accessed those files 9 Q. And did any attorney have access to that depending or where they were within the firm, true? 10 storage area or do you know? 10 A. I am not sure exactly who could have accessed 21 I believe any attorney could have had access. 11 it. You asked me If the attorneys could and the 12 And if the attorney could have access, you 12 attorneys had swipe cards for various locked areas. 13 wouldn't necessarily know about it, true? 13 Each attorney I believe had access to any area whets 14 A. Correct. 14 those files were located. 1 believe so. 15 Q. In the trustee's filing that they mode in 15 0. Okay. Well, during the time you were 16 response to my motion co preserve evidence, they 16 there did an Individual by the name of Ken Jenne 1? indicated that 13 boxes relating to Jeffrey Epstein 1? work there? 18 had been removed by the FBI or the government when 18 A. Yes. 19 they came into the NIA offices. Do you remember 19 O. Okay. Did an individual by the name of 20 seeing that pleading? 20 Hike Piston work for the firm -- 21 21 Yes. 22 0. Okay. Are you, were there, in fact, 13 22 Q. -- for AM? Were they employees of the 23 boxes of material or at least 13 banker's boxes of 23 firm or were they independent contractors? 24 material that related co matters directed to. 24 A. I don't know. 25 whether. whatever the content related to ear. Epstein 25 O. Okay. During the time they were there. PROSE Car REPORTING AGENCY, INC. PROSE COURT IMPORTING AGENCY, INC. Page Ill Page 112 1 did they also have swipe cards so that they could could be discussed for all I know. 2 access different areas in the firm? 2 Q. I'm sorry. Obviously. where you, where 3 I believe so. 3 you were present. where you ever present at a With regard to when you joined PRA, did 4 meeting where Mr. Rothstein was also present where 5 you ever have any further meetings with 5 the Epstein cases were discussed? 6 Hr. Rothstein: that is, from the day you started at 6 A. No. AM. did you ever meet Mr. Rothstein again? 7 O. Did he ever call you to communicate with By meet him again -- you, call you either by phone, video conference. In 9 0. did you aver have a meeting with him again 9 any fashion to discuss any act aspect of the cases 10 regarding your position in the firm? 10 that you had against Jeffrey Epstein? Il A. No. 11 MR. SCMOLA: You can answer that. 12 O. Okay. Did you ever meet with him and a 12 THE WITNESS: Re has communicated about 13 number of other individuals with regards to firm 13 various, about legal issues related to the Case 14 business? 14 as well as commented about the case to me on 15 15 very few occasions but I would say less than 16 Firm uses? 16 three times. 17 don't believe so. 17 BY HR. CRITTOP: le O. Was Kr. Rothstein ever present in any 10 O. During the time that you. from April of 19 meeting whore any of your cases were discussed? Let 19 '09 through late October of '09. correct? 20 me strike that. Was Hr. Rothstein ever present 20 In that time period, where, is that when 21 wherein at any meeting where any Of the Cases 21 these -- 22 against Jeffrey Epstein were discussed? Don't tell 22 0. Correct. 23 me content; just was he ever present. 23 A. -- things happened? 24 A. Mow would I know that? I don't know. We 24 O. Well, that', the time you were there: 25 could, he could be in a meeting right now where the case 25 that's what I am asking. PROSE COURT REPORT= AGENCY, 1PC. PROSE COIWT REPORTING AGENCY, 1PC. EFTA01100776 Page 113 Page 114 1 A. when 1 was there. 1 A comment in passing. And 1 believe 1 was 2 O. And do you. can you remember the date, any 2 sitting at a table in BOVA when he welted over to my 3 specific date that you spoke with him? 3 table and commented about Jeffrey Epstein. 4 A. No. 4 O. Okay. Who were you there with at the 5 Do you remember any specific month that time? 6 you would have had one of the -- well, what did you 6 A. 1 don't remember. say something less Than five conversations? 1 don't 7 O. Were you with sone friends? Were you with want to misquote you. other lawyers? 9 I said less then three conversations. 9 A. All right. 1 am jagging my memory. I, 1 have 10 All right. So. something less then three 10 no ides. 11 conversations you had with Mr. Rothstein regarding 11 O. What did he say? 12 Epstein cases, either legal issue or a comment. acme 12 101. SCAROLA: To the extent that you can 13 comment about the ease to you, correct? 13 answer that question without disclosing any 14 A. Yes. 14 mental impressions with regard to the lawsuit 15 Q. All right. The first time that he over 15 or any attorney-client privileged 16 spoke to you, did he call you or did you call him? 16 communiCetiOnS, you can answer. 1? 1, 1 never called Scott Rothstein about 1? To the extent that it might invade IS anything. Oh, take that back. About anything related IS either the work-product or attorney-client 19 to Jeffrey Curtain. 19 privilege, you should not respond. 20 O. The first conversation that you can recall 20 THE WITNESS: Cen I talk to you? 21 where either a legal issue or a comment was made 21 KR. SCAROLA: Sure. 22 about Jeffrey Epstein by Kr. Rothstein to you, he 22 IA brief recess was held.) 21 obviously initiated the call? 23 KR. SCAROLA: Are we on? 24 - A. It wasn't a call. 24 THE VIDEOGRAPHER: Yeah. 25 O. What was it? 25 KR. SCAROLA: The record should reflect PAWL COURT REPORTING AGENCY, INC. PROSE COURT REPORTING AGENCY. ]NC. Page 115 Page 116 1 that we have had an opportunity to consult and 1 A. Right. Ho was walking by in his normal, loud. 2 I have advised Mr. Edward, that these is no 2 ostentatious kind of way, greeting everybody in the 3 privilege protection for the particular 3 restaurant. Came over to my table and he feels. at 4 communications involved. 4 least my impression was obliged to say something to 5 BY KR. CRITTON: 5 everyone. And that's the comment he said to me. 6 O. What did he say? 6 Md if you've ever seen him, he is 7 A. Me commented to me, I want you t0 get that 7 basically always lust skipping around end he hoped Pedophile. on over somewhere else. So. yell, it was in, 9 Md your response was what? literally in passing. 10 1 didn't respond. 10 O. Okay. How, how, how did he even know you 11 Q. All right. Second conversation that you 11 had cases involving Mr. Epstein? 12 can remember. where were you? 12 A. 1 don't know. 13 A. I had lust CON out of the conference room on 13 O. Because 1 think you testified earlier chat 14 the main floor after taking a deposition in another 14 you had never discussed an Epstein case with 15 case. And he walked by and said, did you get that ring 15 Mr. Rothstein one-on-one, correct? 16 pedophile yet. 16 Absolutely, true. 17 O. And your response? 1? You never discussed an Epstein Case or le A. Again. IS either of your three clients with Mr. Rothstein even 19 O. NO response. 19 with a group of people around, Correct? 20 A. Didn't respond. 20 A. Correct. 21 O. On the first occasion when he came over 21 O. All right. Do you remember a third 22 and if I understand correctly, all ha said was the 22 occasion that he spoke to you regarding Epstein 23 comment that you referenced and then he left. You 23 related occasion, cases? 24 didn't respond and then he lust made the comment and 24 A. Anything else that he ever spoke with me about 25 then left? 25 related to Epstein related issues is attorney-client and PROSE COURT REPORTING AGENCY. INC. PROSE COURT REPORTING AGENCY INC EFTA01100777 Page 111 Page lie 1 work-product privileged information that L am not going conversation, if you want to cell It. 2 to divulge. 2 Q. And that'', at what time? At that time 3 O. Okay. I am not -- I need to still ask the 3 legal issues were discussed? 4 last question though. 1 thought You said earlier is 4 KR. SCAROLA: Legal Issue was the that you never had any substantive conversations, testimony. a particular legal issue. 6 maybe I misunderstood, with Mr. Rothstein about the 6 KR. CRITTON: Correct. A legal issue. 1 Epstein cases. Did 1 misunderstand you? BY MR. CRITTON: A. I don't believe that that was -- I had 0. When did that occur: that is. this one-day 9 conversations at a point about legal issues related to 9 discussion or a day discussion occur regarding a ID Jeffrey Epstein and that's. that's it. 10 specific legal issue? 11 O. Was that a one conversation? Was that a 11 I don't know. 12 number of conversations that you had where legal /2 Was he present, he Mr. Rothstein and you 13 issues were discussed as to, separate and apart from 13 present at the same time? 14 the two consents he made about the case to you which 14 Yes. 15 you were, you waived any privilege, work-product or 15 Okay. Was anyone else there with you? 16 attorney-client Privilege? 16 Yes. 17 A. 1. I can't tell you. If you and I this 17 Who else was present? morning had a conversation and then we took a bathroom 16 Russ Adler, someone was on the telephone. I'm 19 break, and we had the same continuing conversation. I 19 not remembering who that was. I can't remember. 1 will 20 don't know if that's one conversation or two. But I can 20 tell you if 1 do remember. 21 tell you the, the only time 1 remember Scott Rothstein 21 Wail Bill Berger there? 22 participating in any way, shape, or form in any 22 23 conversation related to anything substantive dealing 23 And, you don't. So, there was you. Well, 24 with, and not dealing with any specific client but a 24 let me strike that. Where did the conversation take 25 legal issue, was on a particular one-day event, one-day 25 place? . PROSE CCUAT REPORTING AGENcV, INC. PAWL COURT REPORTING AGENCY. INC. Page 119 Page 120 A. Scott Rothstein's office. 1 0. 1 actually haven't. 2 Q. Had you been called up to meet with 2 A. Oh, really. Okay. Yeah, it'll -- 3 Mr. Rothstein? 3 Q. In order to get into Mr. Rothsteln's 4 A. Yes. 4 A. It's like a compound. 5 0. Okay. And who contacted you and tole you 5 Q. Kind of concern you that this guy running 6 that Mr. Rothstein wanted to see you? 6 the firm had a compound? 7 A. Nis, his secretary or paralegal or something. A. I -- at the time, no. In retrospect, okay, O. And did you get a cell. saying Mr. now that we all know how this whole thing unfolded, but 9 Rothstein would like to see you right now, or was it 9 at the time, no. 10 something that was scheduled? 10 Q. Had you over worked in en office? And you 11 A. It was not scheduled. 11 had worked at some big offices. You worked at the 12 0. SO, you got a call and somebody told you. 12 State Attorney's office in Brower.) County? 13 Cane up. Scott. Scott wants to sea you. 13 True. 14 A. I don't remember exactly what was used, but it 14 You worked (Or, I think for Kubicki 13 was I believe, Russell is discussing a legal issue with 15 Draper? 16 Scott Rothstein: cane to his office. 16 A. Correct. 17 O. Okay. Was the legal issue, did it involve 17 Did Mr. Kubicki, Gene Kubiak! ever have e IR one of the Epstein cases or the Epstein cases? 10 compound around his office that you had to go 19 A. It, it was a legal issue related to -- yet. 19 through any type of security either people and/or 20 Q. Okay. Now long, how much time did you 20 locked doors or secured doors in order to access 21 spend -- well, let me strike that. So, when you 21 him? 22 went up to ler. Rothstein's office. it's -- I 22 A. No. 23 understand you had to go through some security to 23 Had you ever worked other than the Broward 21 get in? 24 County Sheriff's, at the Broward County State 25 A. You've seen the video? 25 Attorney's Office with, and with Kubicki Draper. had PROSE COURT REPORTING AGENCY. INC. PROSE coon azeoarim AGENCY. INC. EFTA01100778 Page 121 Page 122 1 YOu ever woried fOr a large firm? 1 returned to the office, and then that meeting would 2 A. Ho. You just named all the places I have 2 have occurred? 3 worked. 3 Yeah, that's correct. 4 Q. All right. Is this the first time then 4 When you. in order to get into the office 5 that you had been to Hr. Rothstein's office that he 5 just as you have described it as a bunker, how many, 6 called yOu up there? 6 did you have to go through any security people to 7 NO. 7 get into -- You had been in his office before? e KR. SCAROLA: No, I think the description 9 one time. 9 was a compound. 10 O. And what was that occasion? 10 MR. CRITTON: I will use compound. Ate 11 A. I use having back surgery, and 1 went there CO 11 you more comfortable with compound or a bunker? 12 tell him I am having back surgery. As you know I had 12 I have seen it described both ways. I haven't 13 back surgery, and I was telling him 1 don't know how 23 seen the video, but I have seen it described 14 long I'm going to be off because, you know, the recovery 24 both ways. 15 time is different for everybody. 15 THE WITNESS: I will describe it for you. 16 O. Is that the only thing you talked about. 16 Well, first I will answer your question. 17 the back Ourgeff2 21 Security people, I don't know if there was ever 18 That's the only thing we talked about. 18 a time where one would have to go through 19 Old the meeting you had with Scott. when 19 security people to get to him office. Sut on 20 you went up, when you were called up to his office 20 the day or two days that I have been in his 21 that day, did that occur before your back surgery 21 office. I did not encounter any security 22 episode or meeting or after? 22 personnel. 23 A. 23 BY MR. CRITTON: 24 Q. So, you would, you had back surgery. I 24 Q. Did you have to be buzzed into the office? 25 think you were out two or three weeks and then you 25 A. It was more complicated than that.. PROSE Cain PEPORT/NG AGENCY. /PC. PROSE COURT REPORTING AGENCY, INC. Page 123 Page 124 1 0. How many security, different security was Mr. Jenne or Mr. Fasten present? 2 levels did you have to go through in order to get, 2 3 to go have your meeting with Hr. Rothstein and 3 So, it was, you. Rothstein. Adler. and 4 Hr. Adler? 4 someone on the ohmic; that's it? 5 5 From what I remember. 6 O. And so your recollection you don't 6 How long did the meeting last? 7 remember !VOL seeing a security person? 7 I don't know how long the meeting lasted. 0 Right. rive minutes or was it a substantially 9 O. Okay. Who was in the office? 9 long meeting? 10 A. Well -- 10 A. DO you went how long I was in the meeting, 1 11 O. I'm sorry. 11 can give you an answer. How long the meeting lasted, I 12 A. I do not remember seeing a security person 12 have no idea. 13 manning the door or granting access to his office. 1 13 O. How long did the meeting last while you 14 saw security people every day in the office of IPA 14 were present? 15 O. All right. And when you got into the 15 A. Less than five minutes. 16 office. Mr. Rothstein was there? 16 O. Was the value of any of the three Meg 17 A. Yes. 17 discussed at all? 18 Q. Mr. Adler? 18 A. No. 19 A. Yee. 19 Q. Did Mr. Rothstein, did Mr. Rothstein 20 O. There was someone on the telephone who you 20 appear to be knowledgeable about your cases? 21 don't recall? 21 A. Ho. 22 A. Yes. 22 Q. Mr. Adler. was Hr. Adler someone that you 23 O. Okay. Wee there anyone 01Se present? 23 had diaeueSed the cases with on a somewhat regular 24 A. Not that I remember. 24 basis -- 25 O. Okay. Was, wore there any investigators. 25 MR. SCAAOLA: Objection, compound. non COURT inokntio ROOKY. INC. PROSE cogerr Warm AGENCY, INC. EFTA01100779 Pepe 125 Page 126 1 BY MR. CRITTON: 1 that. Who raised the legal Issue, did 2 0. -- not content. Was Mr. Adler someone 2 Kr. Adler raise it or did Mr. Rothstein? 3 that you had discussed these Epstein cases with 3 A. I don't know. 4 prior to that meeting? 4 Q. Okay. Well. how did the, who stetted the. 5 A. Yes. S if you were there I think you said five minutes, who 6 O. Was he familiar with the cases, generally? 6 did the talking? A. Ne attended Jeffrey Cpstein's deposition. so 7 A. When I came in the, in the office, it was in 0 he heard the questions asked and heard the Filth S the middle of a discussion. 9 Amendment invocation and so the adverse inferences and 9 O. Was a question posed to you? ID was therefore informed -- 10 A. The question was on the table at least from my 11 M. CRITTON: Move to strike as 11 perspective coming into the room and was then directed 12 nonresponsive. 12 at M. what's the answer to this particular legal Issue. 13 BY NP. CR1TTON: 13 O. And what was the legal Issue? 14 O. My question is was he familiar generally 14 104. SCAROLA: Let's talk for just a 15 with the subject matter of the litigation against 15 second. 16 Mr. Epstein? 16 THE VIDCOGRAPAER: Are we going off the 17 A. In that he reed the newspaper articles about 17 record? 10 molesting a bunch of children, yes. he was familiar with 10 MR. SCAROLA: Actually, we don't even have 19 the subject matter. 19 to go off the record. Stay right here. 20 O. And he read -- did you provide him with 20 If this was an issue that was 21 copies of the pleadings in these cases when they 21 identified during the course of the legal 22 cam to ARA? 22 proceedings to opposing Counsel, then I am 23 A. No. 23 going to allow you to you Identify the 24 0. What was the topic? Mat was the legal 24 issue without getting into any of the 25 Issue that you discussed -- well, let me strike 25 substance of the discussion regarding that PROSE casts REPORTING AGENCY. INC. PROSE COURT REPORTING AGENCY, INC. Page 127 Page 120 1 issue. 1 O. Do you know what the name of his business 2 If it was not an issue that was 2 was? 3 identified in the course of the No. 4 proceedings to opposing counsel. I am 4 O. Is Rick still being employed at the 5 going to object and instruct you not to 5 current time by your firm to do investigation? 6 answer on the beets of the work-product 6 A. No. 7 privilege. 7 Is Mr. -- I asked you earlier if you knew THE WITNESS: Work-product privilege. 0 Ken Jenne and Michael Piston and you said yes and 9 BY MR. CRITTCN: 9 you knew that they had an association with ARA: is 10 Q. Do you know an individual by the name of 10 that correct? 11 Tandry. P-a-n-d-r-y7 11 A. Yeah, that's correct. 12 A. That nave doesn't ring a bell right now. 12 O. And do you know whether they were 13 0. Do you know him to be -- does that name 13 employees or whether they were independent 14 man anything with regard to, as an investigator, I4 contractors? 15 Fandry? 15 A. You asked me that and I still have no Idea. 16 A. That's a male? 16 O. Did they have offices within RM, 17 Q. Pardon? 17 Mr. Jenne and Mr. Elston? IS That's a first name or a last name? IA A. They, Mr. Jenne definitely had an office 19 O. Last name, Richard fandry. 19 within RM Mr. Piston was normally in the field end I 20 A. I know en investigator named Rick that did 20 seams/ he had a place to go In SIM I don't know if you 21 work, was contracted out by MA to do investigative 21 call it an office. 22 work. I don't know his last name but -- 22 O. Did you ever go -- 23 Q. D1d. did Rick ever do any work on any of 23 A. That'll it. 24 the Epstein cases to your knowledge? 24 O. Did you aver go met with him within ARA? 25 A. I believe so. 25 A. Yes. PROSE COURT REPORTING AGENCY. INC. PROSE COURT REPORTING AGENCY. INC. EFTA01100780 Page 129 Page 13D O. Where did you go did you go to an 1 A. Correct. 2 office to meet him? 2 O. 110. about Mr. Jenne. Is he currently 3 A. Well, I went to a particular area, a locked 3 employed by your firm? 4 areal that I could get in with my swipe card and there 4 A. No. 5 was a, a room like this. Is this an office? 5 Q. Do Mr. Jenne and Hr. Piston. to your 6 O. Sure. 6 knowledge, have any association at the current tine? 7 A. Okay. Then yea. No. Q. If you wanted to contact Hr. Fisten, did 8 Have, has Mr. Fasten Continued to do work 9 you, did you have a number: that is, an inside 9 on behalf of your firm: that is. investigative work 10 number? 10 relating to Mr. Epstein? 11 I don't know. 13 What do you mean has he continued to? 12 O. Did Mr. Platen do work on the EliSteln 12 Q. Ras he continued, has Mr. Fisten done. 13 related cases? 13 continued to do investigative work since he had been 14 A. Yes. 14 with Farmer Jaffe relating to the Epstein cases? 15 Okay. What kind of work did he do? 15 On, on many uses and Jeffrey Epstein's calf 16 A. Investigator. 16 being one of them, yes, he's done some work. 17 0. Meaning what? 17 O. Has he, has he es well -- well, let me 18 Meaning investigative work. 18 strike that. Has Ken Jenne done any work for any 19 Okay. Has Hr. listen continued to do -- 19 outside agency, investigative egenCy or entity, done 20 let me strike that. When NIA Imploded in early or 20 investigation work relating to Jeffrey Epstein here 21 in late '09. In October of '09, did Mr. Fisten case 21 In the State of Florida? 22 to work for your firm? 22 1 don't, I don't know. I don't talk to him. 23 A. Yea. 23 0. Have you had any contact -- well, let me 24 O. Farmer. Jaffe. Is he an employee of your - 24 strike that. Did you ever have any contact with 25 firm? 25 Hr. Jenne during the time you were at PRA? PR= COURT REPORTING AGENCY. INC. PROSE COURT RtrorriNG AGENCY, INC. Page 131 Page 132 1 A. Yes. 1 He would have approached me. I didn't know 2 Q. Did he ever do any work, or did you ever 2 him. 3 direct him to do any work with regard to the Epstein 3 Do you recall why -- let me strike that. 4 cases? 4 Do you recall how long you were at the firm, RSA 5 A. No. 5 before he approached you to talk about the Epstein 6 O. Did he know about the Epstein cases? 6 2 A. Yes. 7 A. My recollection Is snore) months. 8 O. Okay. Md how did he know? How did you 8 O. Okay. On how many occasions did he 9 know he knew? Well, let me strike that. I think 9 approach you to talk about the Epstein cases? 10 you said you never directed him to do any work? 10 1 don't know. 11 A. Right. 11 Q. More than once? 12 O. Okay. Md how do you know he was /2 A. Yes. 13 knowledgeable about the Epstein cases? 13 Q. Ware than twice? 14 A. I talked to him about it before. 14 Yea. 15 O. Did you discuss the fact, and 15 More then five times? 16 circumstances of the cases with him? 16 A. Yes. 17 A. Of L.M., E.M., and Jane Doe's specific 17 Q. More than ten times? IS clecummtanCes, no. In fact, I would say, I would ID A. Possibly. 19 highly, It's highly unlikely that he would even know 19 O. Okay. Md with regard to Mr. Jenne did 20 their names. 20 you ever give him, was he ever en invite person on 21 O. Rut you have discussed the Epstein cases 21 your Otask? 22 with him generically? 22 A. I dO not believe so. 23 A. Right. 23 Did, did you ever ask Mr. Jenne why he was O. 24 O. Md did he approach you about discussing 24 Interested in your Epstein cases? 25 the Epstein cases or did you approach him? 25 A. Mo. PROSE COMP REPORTING AIWJACV, IMO. PROSE COURT REPORTING AGENCY, INC. EFTA01100781 Page 133 Page 134 1 O. Okay. And on each occasion he approached the media or the press when, that's 10Cated in New 2 you about talking about the Epstein cases? 2 York. City, the State Of New York, about any of the 3 A. On the first I occasion, definitely. 1 can't 3 Epstein cases? 4 say on every occasion that we had a conversation. 4 A. I may have returned telephone calls that were S O. And If I understood you correctly. you 5 initiated by press to me. 6 never assigned Mr. Jenne any tasks, any task: is 6 O. My. my question to you was, did you 7 that correct? 7 initiate any telephone calls; that is, without B That's Correct. B returning a call to the, to any member of the media 9 0. Did you find it odder strange that he 9 or press in New York regarding the Epstein cases? 10 would want to talk to you about your Epstein cases? 10 A. Meaning the first conversation -- 11 11 Q. Right. 12 O. Did you, did you -- Mr. Jenne reported to 12 -- between -- yeah. No, I did not. 13 whom as you understood? 13 Who contacted you from New York with 11 1 didn't understand anything. 14 regard to any Epstein related matter? 15 Do you know what his position with the 15 The press. 16 firm was? 16 O. Who? 11 A. No idea. 1? A. 1 don't remember anybody's name. 16 Q. Did he ever offer to help you with the 16 0. Give me anybody's name that you can 19 Epstein cane? 19 recall. 20 A. In some respect, I guess so. Generally, you 20 George Rush. 21 know. I, I can help. This Is basically a criminal 21 What media, what did you understand his 22 matter: I can help. You know, that kind of thing. I am 22 association? 23 not saying those are his exact words but paraphrasing 23 A. I believe New York Daily Hews. 24 the gist of It, that's what 1 remember. 24 Do you remember when Mr. Rush contacted O. 25 O. Okay. Mt. Edwards. did you ever contact 25 you? PROSE COURT REPO/RIM AGUICr, INC. PR E COURT REPORTING AGENCY. INC. Page 135 Page 136 1 A. No. 1 O. 01d you speak with, other than -- on how 2 O. When Mr. Push contacted you, do you know 2 many occasions did you speak with Mr. Canally? 3 why he contacted your that is, what -- well, let me 3 I don't know. 4 strike that. When ha contacted Mai. did you take 4 O. On how many occasion's have spoken with 5 his Call right sway or was his a call that you had 5 Mr. Rush/ 6 to return? 6 A. I don't know. A. I don't remember. 7 NOre than onCe with Mr. Rush? 8 Q. Do you remember speaking with a person I would say so, yea. 9 named John Canally? 9 O. More than five times with Mr. Rush? 10 Yes. 10 A. That's approximate, that's approximately 11 Okay. What was Mr. Canally's association? 11 correct. 12 I don't know. 12 O. Okay. Mr. Canally, did you speak with him 13 O. Do you know who he was with at the time? 13 on more than one occasion? 14 A. No. 14 A. Yes. 15 What did your discussion with Mr. Canally: 15 O. On how many occasion's have you spoken 16 that is. what was Mr. Canally interested in and what 16 with film? 11 did you tell him? 11 A. I don't know. 15 M. SCAROLA: Objection. compound. 18 O. Flue, two, three. Your best estimate? 19 TIE WITNESS: /, I listened to him more 19 More than five. 20 than told him anything. 20 O. When was the last time you spoke with 21 BY MR. CRITTON, 21 Mr. Canally7 22 Q. Did you provide him any information? 22 A. 2009. 23 A. In the back and forth of the conversation. I. 23 O. Nave you had any contacts with the media 24 you know, maybe general information that one could read 24 or the press during the year 2010, January. 25 from the newspapers 1 talked to him about. 25 February, March, and we're almost, well. we're PROSE cow? REPORTING AGENCY. INC. PROSE COURT REPORTING AGENCY, INC. EFTA01100782 Page 13? Page 13$ 1 almost at the end of March. In the last three 1 Q. The conversations you had with George 2 months, starting in January 1st of 2010. have you 2 Rush, when you returned his call, whet did Mr. Rush 3 had any contact with the pleas? 3 ask you? What was he inquiring about? 4 A. Not that I recall. 4 My response to Jeffrey EpsteLn's consents. 5 9. Nes the press contacted you, but you have 5 Q. Which comments? 6 not returned their Calls? 6 A telephone conversation initiated by Jeffrey A. On hundreds and hundreds of ocCellOrill. 7 Epstein to George Rush related to the various cases and Q. Well, my question is since the beginning claims against Mr. Epstein. 9 Of. Since January let of 2010 has the press 9 0. Did Mr. Rush call you -- I'm sorry, 1 will 10 attempted to contact you? 10 improve it. If I understand correctly when Mr. Rush Yes. 1/ called you, that's the first time you knew who he 12 0. And if I understand your testimony. you 12 13 have not returned any of those calls? 13 A. I didn't know who he was before he called me, 14 A. To the best of my recollection 1, 1 do not 14 15 remember speaking with anybody from the press during 15 What did Mr. Rush tell you what Jeffrey 16 this year, 2010. 16 Epstein had said to him? 17 O. In 2010. do you have a recollection of 17 A. And I'm not sure that that was the first IS having spoken with people but saying you can't quote 10 Conversation I had with, with George Rush. Like I said 19 me. 1.e., I have no comment or I will tell you off 19 I think I've talked to him three or four, five times. 20 the record? 20 Q. Okay. Well, let se see if 1 can place, 21 A. 1 don't even remember having those 21 can you give me a point in time when you first spoke 22 conversations with anybody In 2010. If you know of 22 to Mr. Push and when you last spoke with him the 23 mem:meshing and can refresh my recollection. I. you may be 23 approximately five-tines that you related? 24 - to remind me. but I don't think in 2010 I have had 24 A. Each oS those times were in 2009 between, • 25 -sny'of those conversations. 25 earliest possible, June. I think, yeah, latest possible, PROSE COURT REPORTING AGENCY, INC. PROSE COURT REPORTING AGENCY, INC. Page 139 Page 140 I -Z-billeve. November. 1 communicate with his by e-mail, would it be during 2 r Q. And the first time that Mt. Rush called 2 the time you were with AM? 3 you, what was the subject? 3 A. That's correCt. 4 A. Jeffrey Epstein. 4 Did you communicate with any other member 5 Q. Okay. 1 assume you never talked with 5 Of the press during the time, we'll cone back to 6 Mr. Push about any topic other than pr. Epstein, 6 Mr. Epstein. During the time when you were at AAA, 7 correct? • did you communiCaut with anybody else by. by either, 0 A. That's a safe assumption. • first of all, by e-mail? 9 Q. When he first COntaCted you, can you 9 A. Whet is your question again? I'm sorry. 10 differentiate what he said on the first occasion 10 Q. Okay. Did you -- other than Mr. Rush who 11 versus a later occasion? 11 you're not sure you communicated by e-mail, 12 A. 1, I, no, in chronological order 1 can't right 12 Mr. Canally who you are sure you ccerrounicated by 13 now. 1 haven't gone back and thought about this like 13 e-mail during the time you were at AAA. WS there 14 this before. 14 any master of the press. TV, written news media. 15 0. Did you ever correspond with Mr. Rush or 15 television that you communicated with -- 16 Mr. Canally by -mall? 16 A. I'm sure. 17 A. Mr. Rush. I believe that answer is no. With 11 Q. -- by e-mail? IS Mr. Canally, yes. 10 1 em sure there is. 19 Q. And so 00 you have copies of the e-mails 19 Okay. Do you remember any of their names 20 that you and Mr. Canally exchanged? 20 other than Hr. Rush and Mr. Canally es you sit here 21 A. No. 21 today? 22 O. Okay. Would they have been while you were 22 A. Hot as I sit here today. I do not. 23 at ARA. ARA7 23 Q. Did you ever communicate with Jose 24 A. Correct. 24 Lambiet7 25 O. Wich regard to Mr. Rush, If you did 25 A. I don't know who that Is. PROSE COURT REPORTING AGCNCY. INC. PROSE COURT REPORTING AGENCY. INC. EFTA01100783 Page 141 Page 112 Q. No does a Page 2 or accething with the. 1 interested over the course these cases in havingTh4, 2 Page 1, Page 2 of the Pals Beach Post? 2 clients talk. I was adamant that that was not going to 3 A. No. I'm not, no. 3 happen and Jane Doe wanted that to happen. 4 Q. Okay. Nave you ever spoken with Jane 4 Now did Jane Doe even know that that O• 5 Muskrat 1phonetic1? 5 opportunity existed? If you didn't want It to 6 A. Again. I don't know who that is. 6 happen when the news, when the news people, when the 1 O. Nave you ever -- did you ever give or 7 TV stations called you why didn't you just say my 0 allow one of your clients CO give en Interview to 3 clients sic not available for Interview? 9 one of the local TV stations? 9 A. What's your question? 10 HR. SCAROLA: Clajection, compound. 10 O. The question is. is. with regard to the 11 TNC WITNESS: One of my clients gave an 11 T.V. station, you said multiple TV stations wanted 12 interview to One of the local television 12 to do interviews with your clients. Did 13 stations. 13 understand you correctly? 14 BY NA. CRITTON: le You did. 15 O. Which of your clients gave the interview? 15 Md you said you didn't want any of your 16 A. Jane Doe. 16 clients to do interviews. correct? 1? O. Md did you organize that? 17 A. Right. 18 A. 1 assisted. 18 Okay. So. why didn't you just say, no, I 19 Which, which TV station was it? 19 an not making any of my clients available? 20 A. I don't remember. 20 MA. SCAROLA: 1 as going to object to the 21 0. Do you remember who the person was from 21 extent that that calls for either mental 22 the TV station that contacted you? Let me strike 22 impressions or attorney-client privileged 23 that. Now did it came about that Jane Doe gave an 23 communications and instruct you not to answer. 24 interview to the TV station? 24 THE WITNESS: I'm not going t0 answer 25 A. Various television stations have been 25 based on the privilege. PROSE coupe REPORTING AGENCY, INC. PROSE CONY? REPORTING AGENCY, INC. Page 143 Page 144 1 SY Ni. CRITTON: 1 as I didn't believe it was any portion of the file and 2 Q. Jane Doe. though, did give an interview, 2 ny house flooded and the tape was destroyed. 3 correct -- 3 Md did you try to play the tape? 4 A. That is correct. 4 1 have never watched the tape. 5 O. -- en TV and they blocked out her fate? 5 You still hive it. You just think It's 6 A. That is cOrreCt. 6 destroyed? 7 O. Were you there, were you present when she A. No. I don't even have it. gave the interview? 8 O. You threw it away? 9 A. Yes. 9 It wasn't a natter of throwing anything away. 10 O. Okay. Did you see the interview on TV? 10 Ny entire house was full with water, every square inch 11 No. 11 for 12 inches up the wall, end everything was just in 12 Did they give you a Gan of the tape of 12 mud end got thrown in these huge bins and trashed so -- 13 the interview? 13 O. All right. Have you ever spoken with 14 I believe a copy of the tape was sent to me. 14 Michelle Daryan? 15 O. Okay. Do you still have that in your 15 A. Yes. 16 possession? 16 O. On how many Occasions have you spoken with 17 1? her? 10 O. Who has it? Several. 19 A. I believe it was destroyed. 19 O. Nave you e-meiled, exchanged e-malls with 20 O. Who destroyed it? 20 her? 22 A. Nobody destroyed it. 21 A. Yes. 22 O. Okay. You said, I think you said you 22 O. During the tine you, only during the time 23 believe it's destroyed. Now did it come to be 23 you were with RNA] 24 destroyed? 24 A. I believe ao. Theta, there could have been, 25 A. It was sent to me and it was kept in my house 25 there could have been en e-mail. oh I only think at AM PROSE COURT REPORTING AGENCY. INC. PROSE GENET REPORTING AGENCY, INC. EFTA01100784 Pape 145 Page 146 1 1 believe that's right. O. Approximately. how many. how long have 2 O. As a result of Jane Doe speaking with the 3 your conversations been? 3 press. did she receive any compensation? 3 A. Short. 4 4 O. And with regard to George Rush. what, you 5 O. NM any ineeee been given separate 5 said he was interested In talking about Jeffrey 6 and apart from the TV interview that Jane Doe gave? 6 Epstein. What was he interested in? 7 Did any of the other, did either of your other two 7 A. I don't remember specifically the issue, but 8 Clients. L.M. or L.14., ever give an interview to. 0 it seemed to me that he can* to me with an issue each 9 written to. to the written media, not TV? 9 time. something related to the case. 10 A. No. 10 O. Okay. The case being Hr. Epstein's case 11 With regard to, back to George Rush. you 11 or your three cases? 12 said that Mr. Rush. Mr. Rush contacted you. You 12 A. 1 think that It was typically in general 13 reContacted him, correct? 13 related to the various criminal acts committed by 14 A. That's Correct. 14 Jeffrey Epstein against the large number of girls in 15 O. Okay. Md what was the subject matter? 15 each of the states that Jeffrey Epstein has lived in. I 16 What was Hr. Rush interested in talking with you 16 think that was like the gist of his coamun1catiml to me. 17 about? 17 Well, did he? 18 A. Jeffrey Epstein. 18 Or why he was interested. 19 O. Okay. Md what, what specifically about 19 Old he indicate to you that someone had 20 Hr. Epstein? Mow did he even know you existed, did 20 told him that, that certain acts had 0«urred in 21 he say? 21 Other States or locations other than the State of 22 A. I don't know. Or, or If I knew, I don't 22 Florida? 23 remember how he knew that. 23 A. 1 can't say with any degree of specificity 24 Q. Okay. Did you, did you talk to him? 24 what was said, but that. certainly is the impression that 25 'c Yes, I did talk to him. 25 I have right now thinking back. Go, 1 believe that that PROSE COURT REPORTING AGENCY. INC. PROSE COURT REPORTING AGENCY. INC. Page 141 1 was something he was conveying to me. 2 Q. Okay. Did he tell you that he had any 3 information that Nr. Epstein had been involved with • any other individuals in any other states, females? 5 A. I don't remember. 6 Q. Did you tell him or did you disclose to him that you were aware of Hr. Epstein having been. having assaulted underage females in other states? 9 I don't remesber. 10 IF. [BITTEN: Heed to take -- why don't 11 we. why don't you change the tape now? 12 THE VICEOGRAPMER: We're now off the video 13 record. It's 1:02 p.m. 14 IA luncheon recess was held.' 15 16 17 18 19 20 21 22 23 24 25 PROSE COURT REPORTING AGENCY. INC. EFTA01100785