EFTA00611238

Page 148 Page 150 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL 1 e<INDEX START» CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA 2 CASE NO. $02009CA040800XXXXMB AO 3 INDEX Complex Litigation, Fla.R.Civ.Pro. 1201 4 5 JEFFREY EPSTEIN, Plaintiff, 6 EXAMINATION DIRECT CROSS REDIRECT ors- VOLUME110F II 7 CONTINUED EXAMINATION OF BRADLEY J. EDWARDS, ESQUIRE SCOTT ROTHSTELN, 8 BRADLEY J. EDWARDS, BY MR. CRITTON 1S1 individually, and 124. individually, 9 10 Defendants. 11 12 VIDEOTAPED DEPOSITION OF BRADLEY J. EDWARDS, ESQUIRE 13 EXHIBITS 14 Tuesday, March 23, 20010 15 10:00 - 517 p.m 16 EXHIBIT DESCRIPTION PAGE 17 2139 Palm Bach Lakes. Boulevard PLAINTIFFS EX. I ALFREDO RODRIGUEZ 21I West Palm Beach, Florida 33401 18 CRIMINAL COMPLAINT PLAINTIFFS EX. 2 COMPLAINT 239 Reported By: 19 PLAINTIFFS EX. 3 JULY 22, 2009 276 Cynthia Hopkins, RPR, FPR PACSMILE Notary Public, State of Florida 20 Prose Court Reportmg 21 kb No.: 1333 22 23 24 25 Page 149 Page 151 . APPEARANCES: 1 PROCEEDINGS 2 0nd:halfoft& Ptaintilll ROBERT D. CRITTON. JR.. ESQUIRE 2 COLDAAN. LLP 3 THE VIDEOGRAPHER: We're now on the record 4 at 1:54 p.m Volume 2. S 5 CONTINUED DIRECT EXAMINATION 6 BY MR. CAPTION: and 7 Q. Mr. Edwards, when we broke, we were JACK ALAN GOLDBERGER ESQUIRE SS, P A. 8 talking a little bit about, we were talking about 9 9 George Rush and different, many people that you had 10 10 spoken with and you said you had spoken with 11 Mr. Rush approximately five times, correct? 11 12 and 12 A. Contd. 0 On behalfof the Plaine:I 13 Q. With regard to Mr. Rush, did you ever 14 ALAN M. DERSHOW1TZ. ESQUIRE HARVARD LAW SCHOOL. 14 provide him with any documents? 15 15 A. I don't believe so. 16 16 Q. Did you tell Mr. Rush, did you EVER advise 17 17 or did Mr. Rush ever ask you who your clients were, IS JACK SCAROLA. ESQUIRE SEARCY. DENNEY. SCAROIA. 18 I mean not by name but as to how your clients 19 MI Y 19 factored into any of the conversations that you were 10 20 having? 21 A. I don't remember that. 21 22 Q. Do you recall discussing with Mr. Rush 22 ALSO PRESENT: 23 Jcffivy Epstein 23 Ghislaine Maxwell? Or in fact, let me ask it this 24 Joseph Kcal, vsloormiss 24 way: Did you talk with Mr. Rush about Ghislaine Prose Reporting Saviors 15 25 Maxwell in any way? 1 (Pages 148 to 151) PROSE COURT REPORTING AGENCY, INC. Electronically signori by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins 2d394112d.67f24170-9d82-0511f178c2eta EFTA00611238 Page 152 Page 154 1 A. I'm not sure. 1 A. I don't remember that subject coming up in the 2 Q. Why would you -- did any of your clients 2 conversations with Mr. Rush. Had he asked - I, i don't 3 claim or have any of your clients claimed to have 3 remember that conversation. 4 any contact with Ohislaine Maxwell at all? 4 Q. You're not denying it. You are just 5 A. That is something that certainly calls for 5 saying you don't remember it or are you — 6 attorney-client privilege and not something that I ant 6 A. Correct. 7 going to be answering today. 7 Q. - saying it didn't happen? Q. With regard to at least you have attended 8 A. No. I am saying I just don't remember. 9 the deposition of both Jane Doe and o' correct? 9 Q. Did you, did you tell Mr. Rush that 10 A. Yes. 10 Mr. Fruein had transported females on his plane for 11 Q. Okay. And have you heard them reference 11 the purposes of having sex with other individuals? 12 Ghislaine Maxwell during the course of those 12 A. I don't know. 13 depositions? 13 Q. Well, why -- 14 A. No. 14 A. I just don't remember. 15 Q. Would it be a correct statement that none 15 Q. If Mr. Rush would testify that you told 16 of the three of your clients — let's take a look at 16 him that other females had traveled on Mr. Epstein's 17 the two that have testified. Bakof the two that 17 plane and had had sex during the time they were on 18 have testified, Jane Doe and M. have testified 18 the planes„ why would you have had that discussion 19 that they did not ever take, travel with or were 19 with him? 20 transported in any ■ by Mr. Epstein, correct? 20 A. You're asking a hypothetical if i said that, 21 A. No, that is incorrect. 21 why would have i have said that? 22 Q. Okay. Did, who, which? 22 Q. Well, let me rephrase it this way: With 23 A. I believe. 23 Mr. Rush, if i asked you to assume that he would 24 Q. I am sorry? 24 testify that you, you told him about the 25 A. !guess the transcript will speak for itself. 25 transportation, that Mr. Epstein transported other Page 153 Page 155 1 1 don't remember their specific — 1 women on the plane to have sex with them, what 2 Q. is it your belief that Jane Doe ever 2 information did you have that was the basis for that 3 traveled with Mr. Epstein on his plane? 3 claim at that time? 4 MR. SCAROLA: Excuse me, is the question 4 MR. SCAROLA: I am going to object to the 5 limited to the testimony — 5 form of the question. It assumes facts not in 6 MR. CRITTON: Correct. 6 evidence. It has no proper predicate. 7 MR. SCAROLA: — that has been given? 7 BY MR. CRITTON: 8 MR. CRITTON: Correct. 8 Q. Mr. Edwards, did you have Ohislaine 9 THE WITNESS: No. I do not believe she 9 Maxwell served in this case with a subpoena? 10 testified that she traveled with Mr. Epstein on 10 A. Yes. 11 his plane. 11 Q. For what purpose? I mean, obviously to 12 BY MR. CRITTON: 12 take her deposition. 13 All right. And same would be true with 13 A. Exactly, to take her deposition. 14 IE., she did not testify that she traveled with Mr. 14 Q. All right. Do you, is she nei would 15 Epstein on his plane, true? 15 you agree that neither Jane Doe nor M. have 16 A. 1 believe that's true as well. 16 testified to any, that they had any connection 17 Q. Okay. Are you aware of any other 17 whatsoever with Ghislaine Maxwell? 18 infornAgga from any other source that either Jane 18 A. Yes, I would agree. 19 Doe or M. traveled on Mr. Epstein's plane? 19 Q. And what, what was, what is the purpose; 20 A. No. 20 that is, with regard to your three clients and only 21 Q. Did you, did you indicate to — well, let 21 your three clients is they — what connection if 22 me strike that. Did you tell Mr. Rush that none of 22 any, did Ghislaine Maxwell have to those 23 your clients had ever traveled with Mr. Epstein on 23 individuals? 24 his plane or any, on his plane or with him in any 24 MR. SCAROLA: Objection, work-product. 25 fashion, in any other manner? 25 Instruct you to not answer. zatetwe•am, avant-naV.eamtr•-•••••••....T.14.. 2 (Pages 152 to 155) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins 2d39412d-67f2-4170-9d82-0511,178c2ea EFTA00611239 Page 156 Page 158 1 BY MR. CR1TTON: 1 A. I didn't do that. 2 Q. \Vhen you originally started working with 2 Q. You didn't. Did you choose not to do 3 the Rothstein firm, did you have any discussions 3 that? 4 with Mr. Rothstein regarding how your cases would be 4 A. No. 1,1, the statement was made to me by 5 funded; that is, your personal, your personal injury 5 Scott Rothstein that the costs would be reimbursed. And 6 cases and specifically the cases relating to 6 I anticipated that the costs would be reimbursed. I was 7 Mr. Epstein? 7 there for a fairly short period of time and I didn't 8 A. No. 8 know Scott Rothstein personally. So, I didn't go to him 9 Q. Okay. With regard to, prior to taking 9 additionally to tell him something that we already had a 10 your cases to prior to starting at RRA, you were 10 meeting of the minds about. 11 responsible for the funding of your personal injury 11 Q. Well, how much in costs did you have 12 cases or any contingency fee case, correct? 12 outstanding at the time from your cases, including 13 A. Right. 13 the Epstein cases when you went to the firm RRA, in 14 Q. And I assume you had either your own 14 April of '09? 15 personal funds or you had a line of credit or both? 15 A. I don't know the total. 16 A. Right. 16 Q. Was it $1,000? Was it $50,000? Was it 17 Q. And when you came to RRA and you brought 17 $100,000? 18 the cases with you; that is, the personal injury 18 A. More than 100. 19 cases and as well, the Epstein cases, were you 19 Q. And did you have that both from, was it, 20 reimbursed for the costs that you had already 20 the debt, was that comprised of both your own money 21 expended thus far on those cases? 21 and as well as LOC, line of credit money through a 22 A. No. 22 bank? 23 Q. Did you request that you be reimbursed? 23 A. Correct. 24 A. Yes. 24 Q. Was it more than 150? 25 Q. And with, to whom was the request made? 25 A. I'm not sure. Page 157 Page 159 1 A. Directly to Scott Rothstein. 1 Q. Was it someplace between 100 and $200,000 2 Q. Was that at the ten minute meeting that 2 your best estimate? 3 you had? 3 A. That is my best estimate. 4 A. Yes. 4 Q. Did you find that to be a significant 5 Q. At BOVA? 5 amount of money? 6 A. Yes. 6 A. Of course. 7 Q. And what did he say? 7 Q. Okay. And you said you were at RRA for 8 A. No problem. 8 only a short period of time. In fact, you were 9 Q. He said he would reimburse you? 9 there April, May, June, July, August, September, 10 A. Correct. 10 October. You were there seven months, true? 11 Q. And did that, in fact, take place? 11 A. Yes. 12 A. No. 12 Q. Okay. And at no time, even though 13 Q. And how did you attempt to get reimbursed 13 Mr. Rothstein said he would reimburse those funds or 14 for the costs that you had thus far incurred on your 14 the finn would reimburse those funds to you, at no 15 personal injury cases including Mr. Epstein's case 15 time during those seven months which you have 16 when you went, when you started at RRA? 16 described as a short period of time, did you ever 17 A. What do you mean? 17 make a request that you be reimbursed; is that 18 Q. Well, you said that Mr. Rothstein agreed 18 correct? 19 in the ten minute conversation that RRA would 19 A. I never made a, well, I don't know the process 20 reimburse those costs? 20 for getting reimbursed, but I never made a formal 21 A. Correct. 21 request. I said it to, at least to Russell Adler on 22 Q. You go to RRA in April of '09, and I 22 several occasions. And it was always told to me, don't 23 assume you had to ask someone and say, look, Iliad a 23 worry about it; the firm is growing; there is a lot of 24 conversation with Scott Rothstein. He said he would 24 things to deal with right now; he operates under the 25 _ reimburse fr. costs. system of fairness; you will get reimbursed agassems.w 3 (Pages 156 to 159) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins 2d39412d47f2-4170-9082-0511ff76c2ea EFTA00611240 Page 160 Page 162 1 And obviously nobody expected the ending 1 A. Well, you've thrown a lot of things in there. 2 'to the law firm that ultimately occurred. 2 navel expenses come beck with your receipts, hand them 3 Q. With regard to the case, !assume you 3 over to, I would hand them over to my secretary. And 4 settled a couple of personal injury cases during the 4 she would get them to the appropriate place in the 5 seven months you were there, yes? 5 machine known as Rothstein Rosenfeldt Adler. And in my 6 A. Yes, you assume that. 6 next — and I would get a check, l believe. 7 Q. That's correct? Let me ask the question. 7 Q. All right. How about depositions, I mean 8 Did you settle any contingency fee cases during the 8 during the time that we, we took depositions from 9 sevens months that you were at the RRA firm? 9 the time you were at RRA, transcripts were ordered 10 A. Yes. 10 of depositions. They were expedited of various 11 Q. And when you settled those cases did you, 11 hearings. You took trips. You took a trip to New 12 and they closed, they were settled through, did you 12 York to take the deposition of Mark Epstein, 13 have any control of the trust account? 13 correct; all those things occurred? 14 A. No. 14 A. Yes, all of those things occurred. 15 Q. Okay. Settlement monies come in on a 15 Q. So, when you would get a bill in for the 1.6 personal injury case What did you do with the 16 trip for to go up and see Mark Epstein. or to take 17 money once the, once the client had endorsed the 17 Mark Epstein's deposition, you had travel costs 18 check? 18 associated with that and you had plane fare, 19 A. i, I didn't personally do anything with the 19 taxicab, hotel, whatever else you had, correct? 20 money. It was not handled by me. 20 A. I had costs associated with that 21 Q. Okay. Were you there- 21 Q. All right. And when you met with Mr. 22 A. That's why I'm confused. Did i settle the 22 Rothstein initially, what was your understanding or 23 case? I mean, Rothstein Rosenfeldt Adler firm settled 23 did you have an understanding as to how costs would 24 personal injury cases while I was there. There were no 24 be handled; that is, how they would be paid on cases 25 eases that were solely my cases. They were firm cases. 25 that you brought to the firm? Page 161 Page 163 1 Q. Let me rephrase the question. You 1 A. It was unspoken but I had some understanding 2 brought, you brought cases to the firm, correct? 2 just based on logic. 3 A. That is correct. 3 Q. Separate and apart from logic, did anybody 4 Q. Of any of the cases that you brought, did 4 tell you that you had; that is, that RRA would pay S you settle those cases? 5 all of the costs associated with prosecution of the 6 A. No. 6 Epstein cases? 7 Q. Okay. So, you never had an instance — so 7 A. Did anybody tell me? No. 8 there was never a set of circumstances where you 8 Q. Okay. Were you ever required to draw 9 would have been reimbursed for costs as a result of 9 against either your personal funds or your personal 10 a settlement? 10 LOC after you started with RRA to fund the Epstein 11 A. That's correct. 11 cases? 12 Q. All right. And, and so during the seven 12 A. I don't know how to answer your question, 13 months that you were there, you were never 13 Mr. Critton, because if I were to go out of town and 14 reimbursed a nickel of the one to $200,000 that you 14 purchase a plane ticket, yeah, I would purchase that 16 had outstanding in costs? 15 personally and then I would be reimbursed. If I ordered 16 A. That is correct. 16 a deposition transcript, which is a totally different 17 Q. All right. With regard to the costs that 17 category, that gets billed to the firm. I never see the 18 were to be incurred for prosecuting the cases, 18 bill or anything else. So, you're just throwing a bunch 19 specifically the Epstein coign what was your 19 of things together that don't necessarily go together. 20 understanding — was that ever discussed with 20 I am trying my best for you. 23. Mr. Rothstein at the ten-minute meeting? 21 Q. No, that's fine. Commonly in a personal 22 A. Repeat that. I'm sorry. 22 injury closing, you would see the recover, you would 23 Q. Sure. How were, how were costs 23 see a list of the costs. The costs would include 24 investigation costs, deposition costs, travel 24 court reporters, investigation fees, subpoenas, 25 expenses to be reimbursed? 25 things of that nature, correct? 4 (Pages 160 to 163) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Cynthia hopkIns Electronically signed by cynthia hopidns Electronically signed by cynthia hopkins 2434412443724170441B241611M6ean EFTA00611241 Page 164 Page 166 1 A. I have seen them before, yes, sir. 1 responsibility to pay those bills. 2 Q. Okay. And as well there would be 2 Q. And is that what Russell Adler told you? 3 reimbursable expenses such as when you went to New 3 A. Yes. 4 York and took Mark Epstein's deposition. You, you 4 Q. Did you ever discuss that with anyone else 5 paid for the expense up front but, in fact, it was 5 in the firm or just Russell Adler? 6 then reimbursed by the firm, correct? 6 A. last Russell Adler. 7 A. Now we're specifically, specifically talking 7 Q. So, if the bill came in fix one of those 8 about Mark Epstein's deposition, yes, that, what you 8 types of costs, you would give to your secretary or 9 just said is correct. 9 would she handle it automatically? 10 Q. Okay. Not only was the, and if I 10 A. I never would see the bill. Why would it come 11 understand your testimony is the deposition was paid 11 into my name? It just didn't do — that never happened. 12 for directly by the firm. With regard to your 12 It was billed to Rothstein Rosenfeldt Adler. 13 travel, any hotel, other expenses that you had, you 13 Q. So, you would never see the bill that came 14 put in a request for reimbursement and the firm 14 in? 15 would reimburse you? 15 A. Correct. 16 A. Correct. 16 Q. — even if it was a RRA attention Brad 17 Q. All right And with regard to those 17 Edwards, you wouldn't see that? 18 costs, you said you and Mr. Rothstein never had a 18 A. Presuming that happened, attention, Brad 19 discussion about that; is that correct? 19 Edwards, I still never saw it. No, I never saw a bill 20 A. Correct 20 to my recollection right now the whole time I was at 21 Q. All right But you did speak with 21 Rothstein Rosenfeldt Adler. 22 Mr. Adler about how costs would be handled on your 22 Q. Did Mr. Rothstein ever discuss with you 23 cases including Mr. Epstein's case after you started 23 whether there would be a budget associated with how 24 with BRAT 24 much money you could spend on a particular case? 25 A. Correct. 25 A. No. Page 165 Page 167 1 Q. Okay. And is he the only one who 1 Q. Okay. Did anyone at the firm ever talk to 2 explained what the procedure was? 2 you about whether or not there would be a budget 3 A. Yes. 3 associated with how much you could spend on an 4 Q. And what did he tell you? Well, let me 4 Epstein case or any personal injury case? 5 ask you this: Did he tell you what; that is, that 5 A. No. 6 the firm would pay for all of the reimbursements 6 Q. In terms of authorization, if you wanted 7 either costs and/or reimbursements for costs that 7 to order a deposition expedited or if you wanted to 8 were incurred in prosecuting the Epstein files and 8 pay for a specific expense, whether it was an 9 any other files that you had? 9 outside investigator or to send an investigator to a 10 A. Can you split this question up so that we're 10 location, whose decision was that? Is that you and 11 not talking about reimbursement and costs and things 11 you alone to incur that cost? 12 like that 12 A. Which question do you want me to — you asked 13 Q. Sure. With regard to costs such as 13 a bunch of things there that some of them may have been 14 depositions .- 14 my decision. Other parts of that would obviously be 15 A. Okay. 15 somebody else's. But you're throwing five or six items 16 Q. — court reporters, court tcputter fees, 16 in there and you want me to give you an answer. 17 video depositions, transcripts of hearing, whether 17 Q. Let me break it them down. With regard to 18 they were expedited or whether they were asked on a 18 any costs that you wanted to incur, incur relating 19 routine basis? 19 to a Jeffrey Epstein matter, was there an 20 A. Right. 20 authorization process; that is, did you have to get 21 Q. Where would the — who was responsible for 21 someone's okay before you could spend X amount of 22 paying those bills? 22 dollars? 23 A. The bills would, to my to the best ofmy 23 A. No. 24 knowledge would be billed to the law firm of Rothstein 24 Q Okay. It was, and who told you that you 25 Rosenfeldt Adler, and it would be their financial 25 never had to get an approval for any expense 5 (Pages 164 to 167) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins (601.051.976.2934) 2d39412d-6712-41704d82-05111176c2ea EFTA00611242 Page 168 Page 170 1 associated with the Jeffrey Epstein case? 1 Q. Did you meet, did you know Mr. Fisten 2 A. I didn't say that anybody did. So, no, 2 before you started working at RRA? 3 nobody, nobody. 3 A. Same answer, no. 4 Q. You could just spend whatever money you 4 Q. No. All right. And Mr. Fisten, did you 5 wanted to in prosecuting your cases; is that 5 direct Mr. Piston to do investigations in Martha's 6 correct? 6 Vineyard? 7 A. No, I didn't say that either. 7 A. No. 8 Q. What was the procedure then? 8 Q. Did you direct Mr. Eislen to do 9 A. That if I was at a deposition and there was a 9 investigations in California? 10 need in my judgment for the transcript to be expedited 10 A. I directed Mr. Fisten to interview people and 11 then i would order it expedited and nobody ever told me 11 ultimately it was learned that they lived in California. 12 that they had a problem with my judgment as to those 12 Q. And did Mr. Fisten go to California to 13 things. And not as to those things. As to that thing 13 interview those individuals? 14 which we were talking about which right now is 14 A. To the best of my knowledge he did. 15 expediting deposition transcripts. 15 Q. Okay. And who did he go and interview? 16 Q. With regard to — so any, how about an 16 MR. SCAROiA: That is work-product and I 17 expense associated with hiring, with either 17 instruct you not to answer. 18 directing -- well, let me strike that. With regard 18 BY MR. CRITIDN: 19 to Epstein, did, were you ever required or did you 19 Q. Did Mr. Fisten interview a person by the 20 ever hire outside investigators to do work 20 name of Michael Sanka (phonetic)? 21 associated with the Epstein case? 21 MR. SCAROLA: That is work-product and I 22 By outside i mean someone who was not an 22 instruct you not to answer. 23 employee of RRA and now i mean dealing with the time 23 MR. CRITTON: Did Mr. Fisten interview a 24 that you were at RRA 24 individual by the name of Michael Friedman 25 A. Right. And your question is did I over hire 25 (phonetic)? Page 169 Page 171 1 an outside investigator to perform work on Jeffrey 1 MR. SCAROLA: That is work-product and I 2 Epstein's case? 2 instruct you not to answer - 3 Q. Correct? 3 MR. CRITION: Mr. Fisten -- 4 A. The answer is no. 4 MR. SCAROLA: — except to the extent as 5 Q. Were, were all the investigations that 5 may have already been disclosed to the defense 6 were done during the time that you were employed by 6 in any of the three cases that are currently 7 RRA, were they done by in-house investigators? 7 pending. Any and all questions about 8 A. I don't know. 8 investigative work will meet with the same 9 Q. Well, if you wanted investigation done on 9 objection and same instruction. 10 Mr. Epstein, how would you go about authorizing that 10 BY MR. CRITTON: 11 or directing that that be done? 11 Q. Did you direct Mr. Fisten that he could 12 A. I would ask one of the investigators to do it. 12 represent that he was an agent of the FBI in 13 Q. So, you would direct the specific 13 interviewing individuals in California? 14 investigator? 14 A. Of course not 15 A. Yeah. There were plenty of times where I 15 Q. Did you — and if in fact Mr. Piston 16 directed the specific investigator. i want you to talk 16 represented he was an agent of the FBi, you would 17 to this witness or so-and-so, yes, just like you would 17 find that reprehensible, true? 18 in any case. 18 A. This is some hypothetical question that I do 19 Q. In this particular instance associated 19 not believe exists. 20 with Mr. Epstein, what investigators worked on 20 Q. I'm asking you to assume that Mr. Fisten 21 Mr. Epstein's case during the time you were at RRA? 21 represented that he was an agent of the FBI. You 22 A. If you want an exclusive list, I don't know. 22 would find that type of conduct by the investigator 23 Q. I want to know? 23 to be inappropriate, correct? 24 A. I can tell you Michael Fisten did because I 24 A. I'm not going to render an opinion on a 25 communicated with him directly. 25 hypothetical that doesn't exist 6 (Pages 168 to 171) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia bodkins Electronically signed by cynthia bodkins Electronically signed by cynthia bodkins 2d39412d-6112-4170-9d82-0511ff76c2ea EFTA00611243 Page 172 Page 174 1 Q. So, you're refusing to answer that 3. Q. Could he -- is it your — 2 'question? 2 A. How would I know associate, he may have been? 3 A. You're asking me about my definition of 3 Q. Let me ask you this, was he employed by 4 reprehensible as it pertains to a specific hypothetical 4 the Miami-Dade Police Department in addition to RRA 3 5 that you've just created. 5 during the time he worked there? 6 Q. Let me ask you -- 6 A. To the best of my knowledge, no. 7 A. Now, you want me to try to analyze that 7 Q. Did -- with regard to Mr. Epstein's cases 8 particular hypothetical and tell you whether it meets 8 was there any type of cost account set up for, for 9 the definition of reprehensible? them? 10 Q. I will let you — if Mr. Fisten, if l ask 10 A. I don't know. 11 you to assume that Mr. Fisten represented to a 11 Q. Could you access any of the financial 12 witness out in California that he was an agent or 12 files within the RRA firm? 13 working for the FBI, would you find that conduct 13 A. No. 14 appropriate by Mr. Fisten? 14 Q. Could you access any files that were 15 MR. SCAROLA: And I will tell you that you 15 associated with your specific, excuse me, clients or 16 are not obliged to answer hypothetical 16 your specific case such as if you wanted to know how 17 questions. 17 much in costs had been incurred by Mr. Epstein -- on 18 THE WITNESS: And therefore I am not going 18 Jane Doe's case while at the RRA firm, could you 19 to answer that question. 19 request that, could you access that information? 20 BY MR. CRITTON: 20 A. I don't know. 21 Q. If Mr. Fisten represented that he was 21 Q. Did you ever try to rots that 22 associated with the Miami-Dade Police Department, 22 information? 23 Miami-Dade County Police Department, would you find 23 A. No. 24 that conduct inappropriate? 24 Q. At any time did you request that anybody 25 MR. SCAROLA: Same instruction and I would 25 provide you copies of what the costs were associatcd Page 173 Page 175 1 also observe with regard to each of the 1 with Mr. Epstein's cases? 2 hypothetical questions that you are asked that 2 A No. 3 they are incomplete. And without knowing all 3 Q. Since you left the firm have you requested 4 of the surrounding circumstances, it would be 4 any type of detailed billing or cost analysis such 5 impossible for any witness to pass judgment 5 as to the cost of any of the costs that were 6 upon what may have occurred. 6 incurred on any of Mr. Epstein's cases? 7 BY MR. CRITTON: 7 A. Of course. 8 Q. So, Mr.-- would it be a correct statement 8 Q. Okay. And did you receive those costs? 9 at least as you understood it, Mr. Edwards, that 9 Did you receive that information? 10 Mr. Fisten was not an agent, was not an FBI agent 10 A. Yes. 11 during the time that he worked for RRA? 11 Q. And what costs have been incurred in the 12 A. You're asking me was he an FBI agent or did he 12 cases, in the Epstein cases associated up — let me 13 work for RRA He worked for RRA 13 strike that. What costs, what is the total amount 14 Q. Correct. He was not an FBI agent, true, 14 of costs that were incurred in the Epstein cases 15 to the best of your knowledge during the time he 15 during the time that those files existed in the RRA 16 worked for RRA 16 firm? 17 A. Okay. 17 MR. SCAROLA: If you're able to answer 18 Q. I am not talking about any other time 18 that question with regard only as to amount 19 period right now. 19 without specifying any of the specific cost 20 A. Okay. Then the answer is he was not an FBI 20 expenditures, then I think we can answer that 21 agent at the time he was working for RRA 21 question only as to 8MOUnt. 22 Q. During the time he worked for RRA he as 22 THE WITNESS: And the question as to the 23 well was not associated with Miami-Dade Police 23 aggregate in the three cases? 24 Department, comet? 24 MR. CRITTON: Correct. 25 A. Oh, I don't know that. 25 THE WITNESS: Because I can't delineate 7 (Pages 172 to 175) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthla hopkins Electronically signed by cynthia Napkins Electronically signed by cynthla hopkins 2d39412d-6712-4170-9•182-0511t176c2ea EFTA00611244 Page 176 Page 178 1 for you. 1 firm had you, you had spent some of your own money 2 MR. CRITTON: Your best estimate. 2 and/or LLC money on the files; is that correct? 3 THE WITNESS: Okay. I believe more than 3 A. That's comet. 4 $300,000. 4 Q. Approximately how much is that amount? 5 BY MR. CRITTON: A. Fin, I'm not sure. I think as you're aware 6 Q. With regard to, if investigation was done 6 most of the depositions and costly work that was done on 7 on, on a Epstein case, was the investigator charged, 7 the files happened to have been done during that time 8 that is for his time, as an example Mr. Fisten, if 8 period for all of the respective cases or claims against 9 he did work in California would his time, I'm not 9 Mr. Epstein during that time period of last summer of 10 talking about his expenses, would that be billed as 10 2009. 11 a cost to the file? 11 Q. All right. But in terms of your costs 12 A. I don't know. 12 prior to coming to RRA, what's your best estimate of 13 Q. On the cost that you received, well, let 13 the costs that you have paid either out of pocket or 14 me strike that. If I understood it, up to 300,000 14 are responsible to a bank to repay? 15 approximately $300,000 that's been spent on the 15 A. I don't know. 16 Epstein file, were you able to look -- 16 Q. More than 25,000, less than 25,000? 17 A. It would be more than that. I am just saying 17 A. I'm not sure. 18 it's at least $300,000. 18 More than 100,000? 19 Q. Something between three and $400,000, 19 A. No. 20 could it -- 20 Q. More than 50,000? 21 A. Something that I would say is definitely 21 A. I don't know. 22 between 300 and $500,000, but I'm not sure. It could be 22 Q. That's a record obviously you could pull 23 301. It could be 450. I really don't know. 23 up, correct? 24 Q. When was the last time that you looked at 24 A. Correct 25 that ledger or the printout associated with the 25 Q. All right. Now, with regard to, prior to Page 177 Page 179 1 Epstein files? 1 your coming to RRA, had there been any investigation 2 A. I have never looked at the printout. 2 work that you had done on the Epstein files -- and 3 Q. Okay. How, how do you know what is amount 3 let me strike that. Had you hired or retained an 4 is then? That is how do you have the estimate of it 4 investigator to do any work for you on the Epstein 5 being between 350, I'm sorry between 300 and 5 files prior to coming to RRA? 6 $500,000, the cost associated with Epstein? 6 A. I don't think so. 7 A. I asked a paralegal within my current fimi for 7 Q. All right. 8 the total amount of costs on these three cases that is 8 A. It would have been around that time. !don't 9 being claimed by Rothstein Rosenfeldt Adler. And I 9 remember whether the initial investigator was hired by 10 remember the cost number in the aggregate being given to 10 me from my previous, from my solo firm or was hired by 11 me reflecting an amount what I just told you. 11 Rothstein Rosenfeldt Adler. I can't say. 12 Q. Have you requested a copy of the — let me 12 Q. Who was the first investigator that you 13 strike that. Did she say she had, that is did 13 believe was involved in investigating the Epstein 14 she — did you actually receive a document that 14 cases? Just a name not topic? 15 reflects the breakdown of the costs from the 15 MR. SCAROLA: Work-product, instruct you 16 trustee? 16 not to answer. 17 A. I personally have not seen that 17 BY MR. CRITTON: 18 Q. Okay. Has your firm received it? 18 Q. Was the first person that was retained as 19 A. I don't know. 19 an investigator someone who ultimately became 20 Q. I assume -- would it be a correct 20 employed by RRA? 21 statement that the three to S500,000 is, includes 21 MR. SCAROLA: You can answer that. 22 only the time between April of '09 and October of 22 THE WITNESS: No. 23 '09 when you were with the firm? 23 BY MR. CRITTON: 24 A. Ws a good question. I, I believe so. 24 Q. The, the person who you hired to -- and by 25 Q. And approximately, prior to joining the 25 investigation I mean something other than looking up 8 (Pages 176 to 179) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins ( Electronically signed by cynthla Electronically signed by cynthia hooking hopkInsr( 2d39412d-67f2-4170-902-0511f176c2n EFTA00611245 Page 180 Page 182 1 an address to serve a subpoena or, or doing some 1 MR. CRITTON: You are claiming 2 minimal background. 2 work-product? 3 A. lam glad you clarified because I am using 3 MR. SCAROLA: Yes. 4 that same definition. 4 BY MR CRITTON: Q. All right. So, it's, it's your best Q. The investigators, did you understand them 6 recollection that you did or did not hire an 6 to be salaried employees of RRA? 7 investigator to do real investigative work with, 7 A. I really have no idea. 8 associated with Mr. Epstein prior to joining RRA? 8 Q. Did you ever ask them? 9 A. I believe I did, but it was after a time when 9 A. No. 10 I had, I was contemplating or at least to myself had 10 Q. Do you know whether the, do you have any 11 committed to going to RRA So, it was within that time 11 knowledge as to whether the investigators kept tirrc 12 period I believe that I hired that person prior to RRA 12 records? 13 Q. When you then went to — now you had 13 A. I do not have that knowledge. 14 committed to go to RRA or at least mentally 14 Q. In terms of when an investigator would 15 committed to go to RRA As soon as you started with 15 come back -- well, do you know how the investigators 16 RRA, did you terminate the services of that 16 were paid? 17 investigator? 17 A. With money. 18 A. No. 18 Q. From RRA? 19 Q. Did that investigator continue to do work? 19 A. I would presume. Totally speculation. 20 A. Yes. 20 Q. Would the RRA -- were the investigators 21 Q. Okay. Has, does he or she or it continue 21 for RRA bonused? 22 to do work today for you? 22 A. I have no idea. 23 A. No. On Mr. Epstein's case you're asking, 23 Q. Did you ever discuss with Mr. Piston what 24 right? 24 his financial compensation was associated with RRA? 25 Q. Yes, sir. 25 A. No. Page 181 Page 183 1 A. No. 1 Q. Did, did you ever promise either 2 Q. Okay. For how long a time period did that 2 Mr. Fisten or any other investigator that when the 3 person continue to do the work before it got 3 case settled, they would get a bonus from an Epstein 4 transferred to Mr. Fisten or other investigators? 4 case? 5 A. Question doesn't make sense. 5 A. No. 6 Q. Okay. How long did the investigator that 6 Q. Okay. Did Mr. Fisten ever inquire of you 7 you may have hired prior to joining RRA work on the 7 as to whetter he would gm a bonus Cin fact, the 8 Epstein files before you ceased that work after you 8 cases on which he worked including the Epstein cases 9 started working for Epstein in April of '09? I'M 9 settled for a favorable verdict or result owe in? 10 sony, for RRA in '09. 10 A. No. 11 A. The person was hired in either March or April 11 Q. Did you lave any understanding from either 12 of 2009, which is why I can't say with absolute 12 your conversations from Mr. Rothstein whether 1.3 certainty whether 1 was at RRA or not. And that person 13 investigators were bonused based upon the work that 1.4 continued to do investigative work in some capacity 14 they did? 15 probably throughout the entire time that I was at RRA 15 A. Excuse me? 16 Q. Were all of the bills for that 16 Q. Did you ever have an understanding from 17 investigator paid by RRA7 17 Mr. Rothstein that, that investigators would be 18 A. Yes. 18 bonused from cases on which they worked based upon 19 Q. With regard to the payments for the 19 their work product or their contribution? 20 investigators -- well, let me strike that. Who 20 A. No. I had no understanding. 21 other than Mr. Fisten from an investigator, from an 23. Q. Did you, from I assume you've read a 22 internal investigator at RRA employee worked on 22 number ofthe news reports associated with 23 doing investigation on the Epstein files? 23 Mr. Rothstein and the implosion of the firm? 24 MR. SCAROLA: Same objection, same 24 A. Okay. 25 instruction. 25 Q< I assume you have seen a number of them? 9 (Pages 180 to 183) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by Cynthia hopkins 2d39412d-8712-4170-94:182-0511ff78c2ea EFTA00611246 Page 184 Page 186 1 A. What do you mean by a number? 1 representing Mr. Epstein including myself? 2 . Q. Mon than one. 2 MR SCAROLA: Same objection, same 3 A. Yes, I have seen more than one. 3 instruction. 4 Q. Have you seen articles were it's alleged 4 BY MR. CRITTON: 5 that investigators that were employed by Rothstein, 5 Q. Did you ever? 6 by RRA would go through the garbage of prospective 6 MR. SCAROLA: Mr. Edwards will not answer 7 Defendants to search for incriminating or favorable, 7 any questions regarding what he did or didn't 8 incriminating evidence against the Defendant or 8 do. 9 favorable evidence for a Plaintiff who might be 9 MR. CRITIDN: I understand. I just want 10 working or who might be a client of the firm? 10 to make it certain it's for the court on some 11 A. I have not seen an article saying that. I 11 of these issues. 12 think I have heard your client say that before. 12 MR. SCAROLA: Well, for the court I am 13 Q. Separate and apart -- 13 telling you he is not going to answer any of 14 A. Right. 14 those questions. And continuing to ask them in 15 Q. You don't have to rely on anything my 15 light of the fact that we have told you and 16 client has said before, the testimony -- 16 made it clear the scope of our assertion of 17 MR. SCAROLA: I am sure we won't 17 privilege serves no useful purpose. 18 MR. CRITION: I am confident of that. 18 BY MR. CRTITON: 19 BY MR. CRITTON: 19 Q. Mr. Edwards, at any time, did you -- well, 20 Q. In terms of, were you aware from the 20 let me strike that. Did you ever direct the 21 articles, did you see in the article — let me 21 investigators to, during the time you were at RRA, 22 strike that. Did you ever direct your investigators 22 to conduct a surveillance on Mr. Epstein's property? 23 to go through Mr. Epstein's trash? 23 MR. SCAROLA: Same objection, same 24 MR. SCAROLA: I am going to object, 24 instruction. 25 work-product, attorney-client privilege. 25 Page 185 Page 187 1 BY MR. CRITTON: 1 BY MR. CRITTON: 2 Q. Have you directed, did you ever direct — 2 Q. Since the time you have left RRA in your 3 this is the investigators during the time you were 3 current firm, have you conducted surveillance on Mr. 4 at RRA and that's the question you're claiming the 4 Epstein's property? 5 privilege over, correct? 5 MR. SCAROLA: Same objection, same 6 MR. SCAROLA: I am claiming the privilege 6 instruction. 7 with respect to any action that was taken by 7 BY MR. CRITTON: B Mr. Edwards or at Mr. Edward's direction in — 8 Q. Have you instructed anyone, either of the 9 MR. CRITTON: Tell you what, I will 9 in-house investigators to conduct surveillance of 10 withdraw the last question. 10 Mr. Epstein's property? 11 MR. SCAROLA: — in connection with the 11 MR. SCAROLA: Same objection, same 12 investigation in prosecution of the claims 12 instruction. 13 against Mr. Epstein. 13 BY MR. CRTITON: 14 BY MR. CR1TTON: 14 Q. Have you authorized investigators employed 15 4 Let me make my question clear, 15 by RRA, either employees of the firm or an outside 16 Mr. Edwards. With regard to your investigators, you 16 investigation firm, to walk around the perimeter of 17 gave direction with regarding the Epstein cases, 17 Mr. Epstein's home on or about March 17th of 2010? 18 during the time you were with RRA did you ever tell 18 MR. SCAROLA: Same objection, same 19 them or direct them to go through Mr. Epstein's 19 instruction. 20 trash? 20 THE WITNESS: What's the date? 21 MR. SCAROLA: Same objection, same 21 MR. CRITTON: March 17th 2010. 22 instruction 22 MR. SCAROLA: St Patrick's Day. Did you 23 BY MR CRITTON: 23 employ any leprechauns? 24 Q. Did you ever direct the investigators to 24 THE WITNESS: Actually -- 25 go through the trash of the lawyers who were 25 10 (Pages 184 to 187) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins 2d39412d.6712-4170-9d82-0511t176c2ea EFTA00611247 Page 188 Page 190 1 BY MR. CRITTON: 1 Q. Okay. Well, if you could authorize any 2 ' Q. With regard to the, with regard to the 2 expenditure that you wanted and nobody ever told you 3 investigators, with regard to the investigation 3 not to, that you couldn't spend the particular 4 bills that would come in from outside investigators, 4 money, what controls, if any, existed with regard to 5 specifically the one that you — well, let me strike 5 monies spent on the Epstein cases? 6 that. 6 A. The presupposition that you just created is 7 The investigator that you hired before you 7 incorrect, so I cannot answer that question. You began 8 went to RRA, I think you testified that bill was 8 with I have no limit to how I can spend money and that 9 paid by RRA, correct? 9 there is no regulation. I mean, that's just not true, 10 A. Yes. 10 so I don't understand what to tell you. 11 Q. All right. And in terms of the 11 Q. What limits if any did you have in 12 investigators who were employed by RRA for whatever 12 spending money in prosecuting Mr. Epstein's case? 13 investigation you directed them to do, those 13 A. We went through expediting transcripts and I 14 individuals were also paid from funds from RRA, 14 used my own judgment. 15 correct? 15 Q. I understand that 16 A. During the time period when l was at RRA 16 A. If we have another specific example, I will 17 you're asking about specifically, correct? 17 address it and I will tell you whether I had that 18 Q. Correct. 18 authority or somebody else may have had that authority. 19 A. Then the answer is, yes. 19 But specifically related to expediting transcripts and 20 Q. Was there any specific cost account that 20 things involving depositions, ordering depositions, I 21 was set up for Mr. Epstein's cases? 21 used my judgment and it was never questioned. 22 A. I don't know. 22 Q. Separate and apart from transcripts, if, 23 Q. Did you ever speak with the — 23 if — you've testified that the expenditures for 24 A. Again we're talking about the tint period at 24 costs that the firm or the trustee is seeking back, 25 RRA? 25 at RRA is seeking bacic, is seeking relating to any Page 189 Page 191 1 Q. At RRA 1 recovery in any Epstein cases is between three and 2 A. Okay. 2 $500,000, correct? 3 Q. During the time you were at RRA did you 3 A. Correct. 4 ever speak with the accounting department or the 4 Q. All right. So, separate and apart from 5 accounting department ever call you to talk about 5 expedited transcripts or video depositions or 6 the amount of costs, assuming they were something 6 serving subpoenas, that, there has to he, you know, 7 between 300 and $500,000 that were being expended on 7 hundreds of thousands of dollars in additional 8 Mr. Epstein files? 8 expenses that were associated with prosecuting 9 A. No. 9 Mr. Epstein's cases, correct? 10 Q. Did, did anyone at the rum ever call you 10 A. Correct 11 to discuss the issue of the amount of costs between 11 Q. And with regard to those types of 12 300 and $500,000 that were being incurred to 12 expenditures that are in the hundreds of thousands 13 prosecute Mr. Epstein's cases? 13 of dollars, who authorized those types of 14 A. No. 14 expenditures? 15 Q. Okay. Who had checked — did you have any 15 A. I don't know. 16 check-signing authority at RRA? 16 Q. Well, you said that you used judgment 17 A. No. 17 certainly with regard to transcripts. So, who, if, 18 Q. Who did sign the checks? 18 if spending an extra two, three, $400,000 separate 19 A. I don't !mow. I was — 19 and apart from transcripts, serving subpoenas is not 20 Q. In terms of the, the work that was being 20 a limitless budget, how would you describe it; that 21 done or the, the work that was, that is the costs 21 is, what controls if any did you have in prosecuting 22 that were being incurred including reimbursable 22 the Epstein cases? 23 costs, did you understand that you had a, basically 23 A. First, I haven't seen the delineation of that 24 an unlimited budget to prosecute those cases? 24 amount and I don't know that we agree with Rothstein 25 A. No. 25 Rosenfeldt Adler as to their costs, but that is what 11 (Pages 188 to 191) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins ( 2d39412d.8712-4170-9d$2•0511ffitic2ea EFTA00611248 Page 192 Page 194 1 they're claiming. I never juxtaposed that with what 1 1 suggests that those terms are mutually 2 believe should be the proper amount. But beginning with 2 exclusive. 3 the fact that I do recognize that as the amount that 3 THE WITNESS: That was apart of my answer 4 they are claiming, I was not aware that the costs were 4 is that, I don't know 5 that high. 5 MR. CRITTON: I am shocked to hear that. 6 The cases were firm cases, paid for by the 6 THE WITNESS: I don't know that being an 7 firm. I was simply an employee and I made judgment 7 employee means that you can't also be a 8 calls. If somebody had told me at any given time, partner. There are equity partners and 9 we shouldn't serve these subpoenas, or we shouldn't 9 non-equity partners to nearly every single 10 take this deposition, I wouldn't have done it. 10 large firm, so I was a non-equity pastier 11 Q. In fact, with regard to -- well, let me 11 otherwise known as a salaried employee. That's 12 ask you this: Were any informants, did you 12 just the way it was. 13 authorize your investigators to hire informant, 13 BY MR. CRITTON: 14 informants? 14 Q. But your card just reflected partner as 15 MR. SCAROLA: Same objection, same 15 did your -- 16 instruction. 16 A. Rather than that whole script I just told you. 17 BY MR. CRJTTON: 17 Q. Right. Rather than the qualifying 18 Q. Did you authorize your investigators to do 18 provisions. 19 electronic eve's dropping? 19 A. Yes, you're right. The qualifying positions 20 MR. SCAROLA: Same objection, same 20 didn't make the card. 21 instruction. 21 Q. With regard to the monies that was, that 22 BY MR. CRITTON: 22 were being paid by, by Rothstein, I'm sorry, by the 23 Q. You indicated that you were just an 23 RRA firm for the costs -- let me strike that. 24 employee, correct? 24 During the time that you were at the RRA firm, the 25 A. Yes. 25 seven months that you were there from April through Page 193 Page 195 3. Q. Okay. In fact, you, on various documents 1 the end of October, do you recall any significant 2 reflected that you were a partner of the firm, 2 settlements that were coming into the firm; that is, 3 correct? 3 that were publicized? 4 A. Yes, document, documents do reflect that 4 A. Do I recall significant settlements — 5 title, of course, yeah. 5 Q. Correct 6 Q. And if I had asked for a card during the 6 A. -- coming into the firm that were publicized? 7 time that you started at RRA up until the time of 7 Q. Correct? 8 the implosion of the firm in late October of '09, 8 A. lbelieve, I can't say with any degree of 9 would your card have also reflected that you were a 9 specificity whether I remember anything that falls into 10 partner of the firm? 10 all of those categories. 11 A. I think you did request a card. I think I 11 Q. Now, I forgot my question fix a minute. 12 gave it to you and I believe that it did say partner on 12 If I understand your answer, and assuming I remember 13 it. 13 my question, Mr. Edwards, you don't recall any 14 Q. And you would agree that at least up until 14 significant settlements coming into the firm that 15 the time of the implosion ofRRA you held yourself 15 were, that were publicized either internally within 16 out to the public, and including other lawyers, as 16 the from or within the newspapers; is that a fair 17 being a partner ofRRA, true? 17 statement? 18 A. What do you mean by held myself out to the 18 A. Fair statement. 19 public? 19 Q. Where did you think all of the money that 20 Q. You called yourself a partner. You didn't 20 was coming from — let me strike that. At that time 21 say I'm an employee; I'm not a partner, correct? 21 how many lawyers were there in the Fort Lauderdale 22 You held yourself out to the public as being a 22 office; that is, during the time you were there? 23 partner? 23 A. I don't know. 24 MR. SCAROLA: Pm going to object to the 24 Q. Best estimate? 25 form of the Question to the extent that it 25 A. Seventy. 12 (Pages 192 to 195) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cyrithis hopkins Electronically signed by Cynthia hopkins Electronically signed by cynthia hopkins 2d39412d-11712-4170-9d82-0511ff76c2ea EFTA00611249 Page 196 Page 198 1 Q. Okay. And the support, how many floors 1 BY MR CRITTON: 2 did ERA occupy in the Fort Lauderdale -- 2 Q. Where did you think the law firm -- let me 3 A. I believe six. 3 strike that. Did you ever discuss with anyone 4 Q. And approximately how many square feet on 4 whether it was from current cash that was being used 5 each floor? 5 or whether they had a line of credit or both? 6 A. I don't know. A lot. 6 A. Didn't know. 7 Q. More than 10,000 square feet on each 7 Q. Mr. Edwards, did you come to learn that 8 floor? 8 investigators had, that investigators had gone to 9 A. I don't know. 9 Mr. Epstein's property on March 17th, 2010? 10 Q. And what was the support staff at the time 10 A. No. 11 that you were there approximately? 11 Q. Did you ever authorize any investigators 12 A. In quantity or quality? 12 to enter Mr. property (sic). Mr. Epstein's property 13 Q. Quantity, the number of people. 13 on March 17th, 2010? 14 A. I don't know. A lot of people. 14 MR. SCAROLA: Objection. Instruct you not 15 Q. Did you do any hourly billing yourself at 15 to answer on the basis of work-product 16 all or were you strictly a contingency fee person? 16 privilege. 17 A. 90 percent contingency. 17 BY MR. CRITTON: 18 Q. And with regard to the monies that were — 18 Q. Let me just be clear. Are, are you aware 19 separate and apart from the Epstein, Epstein cases 19 of any investigators who entered Mr. Epstein's 20 where at least you now know that they cost between 20 property on March 17th, 2010? 21 three and $500,000, you were, I assume, incurring 21 MR. SCAROLA: Same objection as well as 22 other expenses on other cases, true? 22 attorney-client privilege and instruct you not 23 A. True. 23 to answer. 24 Q. All right. And where did you, where did 24 BY MR. CRITTON: 25 you think that the money was coming from; that is, 25 Q. Mr. Edwards, did you authorize any Page 197 Page 199 1 the source of the money to pay the extensive bills 1 investigators to trespass on Mr. Epstein's popcity 2 that were being incurred on Epstein and other cases? 2 on March 17th of 2010? 3 MR. SCAROLA: I am going to object to the 3 MR. SCAROLA: Same objection and 4 extent the question calls -- excuse me, Pm 4 instruction. 5 going to object because there is no proper 5 BY MR. CRITTON: 6 predicate to the question, and that is that it 6 Q. Mr. Edwards, did you authorize 7 was a matter that was ever given a thought by 7 investigators to hide in the bushes at Mr. Epstein's 8 Mr. Edwards. 8 house in order to take photographs of either 9 MR. CRITTON: Is that form? Form is 9 Mr. Epstein or any associated objects on his 10 adequate so you don't have to instruct him. 10 property? 11 MR. SCAROLA: Thank you. 11 MR. SCAROLA: Same objection and 12 THE WITNESS: What's thc question? 12 instruction. 13 BY MR CRITTON: 13 BY MR. CRITTON: 14 Q. What did you consider, what did you 14 Q. Mr. Epstein -- Mr. Epstein. Mr. Edwards, 15 believe was the cost; that is, the source of the 15 do you know a lady name Christina ICittaman? 16 money that was used to be paying these extensive 16 A. Yes. 17 costs that were being incurred in Epstein and other 17 Q. Okay. And who - how do you know her? 18 cases? 18 A. She was a lawyer at Rothstein Rosenfeld( Adler 19 MR. SCAROLA: Objection. 19 when I was a lawyer at Rothstein Rosenfeldt Adler. 20 MR. CRITTON: Just of yours and yours 20 Q. Did you have any dealings with her on any 21 alone? 21 of your cases? 22 MR. SCAROLA: Objection, form and 22 A. None. 23 compoluxl. 23 Q. What did you understand her area of 24 THE WITNESS: The law firm. 24 practice? 25 25 A. Never knew. •cumas•Zettsal‘amen elawawlin$SKIMIO,••••••• 13 (Pages 196 to 199) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins 2d3g4126,6712-4170-9032-0511tf76c2ea EFTA00611250 Page 200 Page 202 1 Q. Did you know an individual by the name of 1 instruction. 2 Patrick Roberts? 2 MR. CRITTON: Says he doesn't know them 3 A. Yes. 3 How can that be an instruction? 4 Q. Okay. And who is Mr. Roberts during; that 4 MR. SCAROLA: Well, because I am not going 5 is, what did iv1r. Roberts do for RRA? 5 ..) to tell you, we're not going to permit 6 A. He was an investigator. 6 Mr. Edwards to answer any questions about 7 Q. Did he ever perform investigation work on 7 either what he did or what he didn't do that 8 any of the Epstein files? 8 are part of the work product involved in his 9 MR. SCAROLA: Same objection, same 9 representation of the Plaintiffs with claims 10 instruction. 10 against Mr. Epstein whom Mr. Edwards is 11 BY MR. CRITTON: 11 representing. 12 Q. Did you ever authorize Mr. Roberts to 12 MR. CRITTON: Did you ever — 13 perform investigation on the Epstein files? 13 MR. SCAROLA: So, in light of that and 14 MR. SCAROLA: Same objection and 14 what i have attempted to make very clear with 15 instruction. 15 regard to the scope of our objections, if you 16 BY MR. CRITTON: 16 continue to ask questions which it is clear 17 Q. All right. I asked yo, earlier about 17 fall within the scope of my instructions to 18 Richard Fandrey, F-a-n-d-rl-y. I think you said 18 Mr. Edwards and my announced intention with 19 you don't know who that — you knew someone named 19 regard to the scope of those instructions, then 20 Rick; is that correct? 20 we will terminate this deposition so that i can 21 A. I know an investigator named Rick. 21 seek a protective order. 22 Q. Did Rick, did Rick perform any 22 My suggestion is that you move onto other 23 investigation on the Epstein, did you authorize Rick 23 areas that are outside the scope of that 24 to perform any investigation on the Epstein files? 24 instruction, if you have any other questions 25 MR. SCAROLA: Same objection and 25 outside the scope. Page 201. Page 203 1 instruction. 1 MR. CRiTTON: Oh, I have a lot of other 2 BY MR. CRITION: 2 questions. 3 Q. And 1 believe we talked a little bit 3 MR. SCAROLA: Okay. 4 about, we certainly talked about Mr. Jenne, did you 4 MR. CRITTON: Let me be clear with you 5 ever authorize or direct Mr. Jenne to perform any 5 with regard to any, for purposes of following, 6 investigation on the Epstein files? 6 asking any follow-up questions should the court 7 MR. SCAROLA: Same objection and 7 determine that I am entitled to this 8 instruction. 8 information, you would agree that should the 9 BY MR. CRITTON: 9 court determine I am entitled to ask the name 10 Q. Are you familiar with the company called 10 of these individuals and possibly other 11 Blue Line Research and Development? 11 questions is, is that by not asking questions l 12 A. No. 12 am in no way waiving my right to ask as many 13 Q. Are you, are you aware at the current time 13 questions as the court ultimately determines as 14 that there is an entity called Blue Line Research 14 appropriate, proper, and as the court allows, 15 and Development which is composed of Mr. Roberts, 15 correct? 16 Mr. Richard Fandrey, Mr. Michael Fisten and Ken 16 MR SCAROLA: I absolutely agree. 17 Jenne? 17 MR. CRITTON: All right 18 A. No. 18 BY MR. CRiTTON: 19 Q. If you're unaware of the existence of the 19 Q. Mr. Edwards, are you familiar with a 20 entity called Blue Line Research and Development, 20 person named Alfredo Rodriguez? 21 LLC, would it be a correct statement that you have 21 A. Yes. 22 never authorized anyone from Blue Line Research and 22 Q. And how do you know Mr. Rodriguez? 23 Development, LLC, to conduct any investigation of 23 A. Who do I know him to be? How do I know him? 24 Jeffrey Epstein? 24 i met him the same — well, i met him after you did, 25 MR. SCAROLA: Same objection, same 25 after you and your investigators pre-depoed him on three 14 (Pages 200 to 203) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthla hopkine Electronically signed by cynthia hopkins Electronically signed by Cynthia hopkIns 2d39412d4M2-4170,9d82-05111176c2ea EFTA00611251 Page 204 Page 206 1 various occasions for a total of about 15 hours before 1 July 29th and August 7th? 2 we took this deposition. I met him for the first time 2 A. And if I did or if I didn't, either ■ that's 3 during that deposition. 3 going to be protected by the work-product privilege and 4 MR.. CRITTON: Let me move to stake as 4 Fin not going to give you that information because 5 nonresponsive. 5 you're not entitled to it. 6 BY MR CR1TTON: 6 Q. I disagree even in a simple 7 Q. My question to you is when did you first 7 attorney-client privilege you also, you identify the 8 meet Mr. Rodriguez? 8 date, you don't identify the subject, but you 9 MR. SCAROLA: And you have an answer to 9 identify the date, who may have been present 10 that question. 10 MR. SCAROLA: We understand your position 11 THE WITNESS: It's a very complete answer. 11 and it's not necessary to articulate it on the 12 l, the day of his deposition. 12 record. 13 BY MR. CRITTON: 13 MR. CRITTON: I just want to be clear. 14 Q. Had you ever spoken with Mr. Rodriguez 14 And your position is the same is you're not 15 before that time? 15 talking. 16 A. No. 16 MR. SCAROLA: Work-product. 17 Q. Okay. Had anyone on your behalf spoken 17 MR. CRITTON: Work-product, correct? 18 with Mr. Rodriguez? 18 MR. SCAROLA: That's correct. 19 A. No. 19 BY MR. CRITTON: 20 Q. Mr. Rodriguez's deposition occurred over a 20 Q. Mr. Rodriguez was requested to bring 21 twirday period; is that correct? Two separate days. 21 documents to his second deposition that he had 22 A. I believe that's right. 21 referenced that he might have. Do you recall that 23 Q. And you were present for both of those 23 from the first deposition, Mr. Edwards? 24 depositions; is that comet? 24 A. Id°. 25 A. Yes. 25 Q. And in fact when he came to the second Page 205 Page 207 1 Q. And the first one I believe at least in 1 deposition, he didn't bring any documents with him. 2 looking at the transcript the first one occurred on 2 did he? 3 January 29th of '09? 3 A. I don't remember. 4 A. I'm assuming. 4 Q. Well, do you lunenrber him producing any 5 Q. And the second, the follow-up was on 5 documents at the second, at his completion of his 6 August 7th, 2009, correct? 6 deposition? 7 A. When was the first, January you said? 7 A. I don't remember. 8 Q. Excuse me. Pm sorry. July 29th, 2009. 8 Q. Do you recall him saying that he might 9 A. Okay. 9 have some sort of book or some sort of list of names 10 Q. With the follow-up July, I'm sorry 10 and addresses and/or names, excuse me, of females 11 August 7th, 2009. 11 who may have come to Mr. Epstein's house along with 12 A. If you say so. I'm not quarreling with that. 12 phone numbers? 13 Q. And I will just represent that is what I 13 A. I don't remember if he said that or it says 14 read off the transcripts. Between those two dates, 14 that in the police report, but I remember that 15 that is July 29th and August 7th of '09, did you 15 inforniation at some point in time. 16 speak with Mr. Rodriguez at all? 16 Q. All right. And subsequent, at the 17 MR. SCAROLA: Same objection, same 17 conclusion — well, let me strike that. 18 instruction to the extent that any such 18 Do you recall receiving any documents from 19 conversation may have occurred in connection 19 Mr. Rodriguez that were produced at his deposition 20 with your representation of the Plaintiffs and 20 that had the names and addresses and/or phone 21 claims against Mr. Epstein. 21 numbers of any other females? 22 BY MR. CRITTON: 22 A I don't know. Do you? We were there together 23 Q. All I am asking right now, not the 23 I don't remember specifically. I think the answer is 24 substance but just so the record is clear I am just 24 no. 25 asking, did you speak with Mr. Rodriguez between 25 Q. And I think you're right. WI•aZ-{4.0.40. 15 (Pages 204 to 207) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins 2d39412d-67f2-4170.9d82.05111O6c2ca EFTA00611252 Page 208 Page 210 1 A. Okay. 1 instruction. 2 ' Q. We agree on that. 2 BY MR. CRITTON: 3 A. Okay. 3 Q. Did Mr. Mr. Rodriguez ever make a request 4 Q. Subsequent to the deposition; that is, 4 of you at any time for any type of monies for 5 after Mr. Rodriguez's deposition, did Mr. Rodriguez 5 testimony, documents, or any other information 6 contact you? 6 associated with any existing or potential claimants 7 MR. SCAROLA: Objection, instruct you not 7 directed to Mr. Epstein? 8 to answer. 8 MR. SCAROLA: Same objection and 9 MR CRITTON: Well, this is — okay. This 9 instruction. 10 is a third patty contacting Mr. Edwards. All 10 BY MR. CRITTON: 11 right. 11 Q. Subsequent, after Mr. Rodriguez or from 12 MR. SCAROLA: It is not — 12 the time that Mr. Rodriguez completed his deposition 13 MR. CRITTON: It's just a yes or no I'm 13 on August 7th of 2009, did you have an occasion to 14 looking for. 14 speak with either the FBI, well, with the FBI 15 MR. SCAROLA: It is a witness in these 15 regarding Alfredo Rodriguez? 16 proceedings. 16 MR SCAROLA: Same objection and 17 MR. CRITTON: So. 17 instruction. 18 MR. SCAROLA: So, anything that 18 BY MR. CRITTON: 19 Mr. Edwards has done or may have done in 19 Q. Did you after Mr. Rodriguez's completion 20 connection with his investigation and 20 of his deposition on August 7th, 2009, did you have 21 prosecution of the claims against Mr. Rothstein 23. an occasion to speak with any representative, a 22 it is our position is not the appropriate 22 professional attorney, professional slash attorney 23 subject matter of inquiry in the context of 23 for the U.S. Attorney's Office? 24 this lawsuit, and is an attempt to invade the 24 MR. SCAROLA: Same objection and 25 attorney-client and work-product privileges. I 25 instruction. Page 209 Page 211 1 am instructing him not to answer. 1 BY MR. CRITTON: 2 If the court, if the court determines that 2 Q. Mr. Edwards, are you familiar with the, 3 the scope of the privilege permits a response 3 the criminal complaint that was filed relating to 4 to these questions, we would be happy to 4 Alfredo Rodriguez? s respond to them. MR CRITTON: Let me show you what I will 6 But we have an obligation to, to 6 mark as Exhibit i to the deposition. 7 Mr. Edward's clients to protect their rights to 7 (Plaintiffs Exhibit No. I was marked for 8 a fair trial and their rights to B identification.) 9 confidentiality, and for that reason we are 9 MR. SCAROLA: By that question, does that 10 obliged to interpret those privileges in their 10 mean has he seen it before? 11 broadest sense unless and until the court 11 MR. CRITTON: First, let me show you 12 decides that a more restrictive interpretation 12 Exhibit I. Do you it's a criminal 13 should be applied. 13 complaint, the United States of America versus 14 BY MR. CRITTON: 14 Alfredo Rodriguez. 15 Q. BUNT - a the first and second deposition of 15 MR. SCAROLA: Is your question has he seen 16 Mr. Rodriguez I think you, I think you indicated 16 it before? 17 that you did not speak with him; is that correct? 17 MR. CRITTON: Yes. 18 A. You're asking me if I indicated to you 18 MR. SCAROLA: I'm not sure what "are you 19 previously during this deposition whether — 19 familiar with it" means. 20 Q. Right. 20 BY MR CRITTON: 21 A. — I spoke to him or not? I, I don't 23. Q. Have you seen this criminal complaint 22 remember. 22 before today? 23 Q. Did you speak with Mr. Rodriguez between 23 A Yes. 24 his first and second. 24 Q. When did you first see this document? 25 MR. SCAROLA: Same objection, same 25 A. I — I don't know. 16 (Pages 208 to 211) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins 2d39412d40,24170-90124511ftfleae EFTA00611253 Page 212 Page 214 1. Q. Did you, did you see Exhibit I, the 3. during your years that you had worked as a State 2 criminal complaint, prior to the time that it was 2 Attorney? 3 filed in the United States District Court? 3 A. No. 4 A. Did I see it prior to it being filed? 4 Q. Okay. Did you meet her only as a result 5 Q. Yes, sir. 5 of Epstein related matters? 6 A. No, no. 6 A. Yes, in its broadest sense I suppose. 7 Q. Okay. Did you provide an affidavit to any 7 Q. Did you did you have, before yineji 8 individual at the FBI or the U.S. Attorney's Office 8 representing." did you know who 9 in support of, although not attached to this, to 9 was? 10 Exhibit I, the criminal complaint? 10 A. I don't know. 3.1 A. Repeat. 13. Q. What, what was your first association or 3 12 Q. Did you sign any affidavit or give, give 12 what contact was, what was your first contact with 13 any sworn testimony associated with the criminal 13 ever? 14 complaint that was filed by the United States of 14 A. 'don't 15 America versus Mr. Rodriguez? 15 Q. But if I understand correctly you only 16 A. Ifs obvious to me that you're trying to 16 know her through the context of the Jeffrey Epstein 17 circumvent the privileges that have been placed on the 17 matter, is that correct? 18 record. I will answer that question that, no, I did 18 A. Her involvement with, yes. 19 not, but i am not here to divulge anything that may 19 Q. And that you only knew of her involvement 20 waive my attorney-client or work-product privilege or 20 in the Jefficyalein matter after you began 21 otherwise jeopardize the claims that my three clients 21 representing OM? 22 are pursuing against Jeffrey Epstein for their being 22 A. I don't believe that to be accurate. 23 sexually molested by him when they were underage minor 23 Q. What involvement could you possibla 24 females. 24 involvement would you have had with Mrs. 25 Q. Mr. Edwards, are you the cooperating 25 before you became involved in representing someone Page 213 Page 215 1 witness who was tefcl2,R.d in the criminal 1 associated with the Epstein matter? 2 complaint, Exhibit I? 2 A. 'believe that i had read her name in the 3 MR. SCAROLA: Could you explain to us for 3 newspaper related to some involvement with Jeffrey 4 the record, please, how that line ofinquiry is 4 Epstein's criminal investigation and/or cast I think 5 reasonably calculated to lead to admissible 5 that's the first time 1saw her name, I believe. 6 evidence in this case? 6 Q. Before, before you filed a lawsuit against 7 MR. CRITTON: I am not prepared to do that 7 the United States of America, and i may have asked 8 right now. 8 you this earlier so 1apologize, did you ever speak 9 MR. SCAROLA: Then I am not prepared to 9 with Mrs. a 10 allow Mr. Edwards to answer that question 10 A. I believe that any communications that I would 11 outside the presence of an Assistant United 11 have had with respect to Mrs. would have only 12 States Attorney who can make a judgment as to 12 been in the interest of pursuing claims on behalf of the 13 whether that is information that ought to be 13 clients that I represented. And therefore i am going to 14 disclosed. 1.4 claim a work-product privilege as to those 15 BY MR. CRITTON: 15 communications. 16 I .,. Edwards, you knew or you first 16 Q. Okay. My, my question was is only did you 17 through the complaint you filed on behalf 17 speak with her prior to filing that complaint? Just 18 of Jane Doe 1 and Jane Doe 2 in July of 2008, 18 a yes or a no, and I am looking, that question is 19 correct? 19 not asking for the substance. I am just asking for 20 A. No. 20 ayes or no. 21 Q. Had you spoken with her before that period 21 MR. SCAROLA: Same objection, same 22 of time; that is, before the complaint was ever 22 instruction. 23 filed? 23 BY MR. CRITTON: 24 A. Yes. 24 Q. During the course of the litigation with 25 And I am now did‘ yoU !al?, 25 the United States Attorney's Office, I assume you 17 (Pages 212 to 215) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins Electronically signed by cynthia bodkins 2d39412d-6712-4170-9082-0511f(76c2oa EFTA00611254 Page 216 Page 218 1 had conversations with Mrs. from tint to 1 BY MR. CRITTON: 2 time? 2 Q. Did you speak with Agent at that 3 A. Okay. 3 dine? 4 Q. Is that true? 4 A. Yes. 5 A. Is your assumption true? 5 Q. Okay. And what did, what did, did she 6 Q. Correct. 6 initiate the conversation or did you? A. I have spoken with Ms. 7 A. The court initiated the conversation. B Q. And when you spoke with Ms. -- 8 Q. Did the court say go outside and talk? 9 let me strike that. Have the conversations 9 A. Right. 10 iik u have had with Mr. tha or 10 Q. The court being Judge Marra? 11 have they only been in the context of 13. A. Correct 12 Jane Doe 1 and 2 versus United States of America, 12 Q. And who else was present for that 13 only in the context of that case? 13 conversation? 14 MR. SCAROLA: Same objection. 14 A. I don't mmember. 15 MR. CRITTON: And I will separate out to 15 Q. Okay. What was the discussion about that 16 the extent that you were at the June 12th, 16 the court ordered? 17 2009, hearing in front of Judge Marra where she 17 A. The failure of the U.S. Attorney's Office to 18 was present. 18 meaningfully confer with the numerous victims of Jeffrey 19 MR. SCAROLA: Same objection, same 19 Epstein's sexual abuse prior to negotiating a plea in 20 instruction. 20 his criminal matter. 21 BY MR. CRITTON: 21 Q. How long did the conversation last? 22 Q. Has Ms.— have you Igtigajjave you had an 22 A. Less than ten minutes. 23 occasion to speak with Ms. with regard to 23 Q. Was Agent a there as well? 24 the criminal complaint, Exhibit No. 1, involving 24 A. There was a male agent there. I don't know 25 Alfredo Rodriguez, Mr. Rodriguez? 25 his name, but there was another FBI agent. Page 217 Page 219 1 MR. SCAROLA: Same objection, same 1 Q. Did Agent did she say 2 instruction. 2 anything? Did she participate in the conversation? 3 BY MR. CRITTON: 3 A. No. 4 Q. Mr. Edwards, have you ever been 4 Q. Okay. Was it just Mrs. IIMI? 5 interviewed by the FBI or the U.S. Attorney's office 5 A. There was another U.S. Attorney there. I 6 with regard to any of your clients? 6 Q. A U.S.A.O. there? 7 MR. SCAROLA: My of the three clients who 7 A. Yes. 8 have claims against Mr. Epstein? 8 Q. Do you remember a he or a she? 9 MR. CRITTON: Correct. 9 A. He. 10 MR. SCAROLA: Sant objection, same 10 Q. ou remember his name? 11 instructMn. 11 12 BY MR. CRITTON: 12 Q. 13 Q. Do you know .‘MIM sir? 13 A. I think that's hi la t i 14 A. Yes. 14 Q. Did Mr. -- did is he the one 15 Q. And how do you know Agent from the 15 who conducted the conversation with you? 16 FBI? 16 A. Yes. 17 A. I can answer if you want. 17 Q. What was his response to your statement? 18 MR. SCAROLA: fine. 18 A. That this conversation is more complicated 19 MR. CRITI'ON: 19 than the time constraints that we have right now will 20 THE WITNESS: I don't know her last name 20 allow. We arc not going to come to a resolution at this 21 but I do know the first name is, the lust name 21 point on any issues that you or your clients believe are 22 is obviously an unusual name, so I do ;mow who 22 pertinent to the case you filed. 23 that is. I met her outside of the courtroom 23 Q. That was the end of the conversation? 24 related to the Jane Doe 1 and 2 versus United 24 A I mean, I am not quoting verbatim, but, yes 25 States of America case. 25 that was the 33 18 (Pages 216 to 219) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins 2d39412d-6712-4170-9d82-0511ff76c2ea EFTA00611255 Page 220 Page 222 1 Q. And did you go back in front of Judge 1 Rothstein. 2 Main that same day? 2 Q. So, it would be a correct, and I am going 3 A. I can't remember. 3 to expand it, would it be a correct statement that 4 Q. Did he issue an order based upon that 4 no representative of the federal government and by 5 hearing? 5 that I mean the Department of Justice, FBI, any 6 A. The, the record in the case will speak for 6 other law enforcement agency nor any state 7 itself. I really, I don't remember right now. 7 governmental agency has ever asked you or quizzed 8 ...had any other conversations with 8 you or questioned you about your association with 9 other that? Well, I mean any 9 Rothstein, Rosenfeldt, and Adler during the seven, 10 other face-to-face conversations with her other than 10 approximately seven months you were there; is that 11 that one day back in July of, July or August of 11 correct? 12 2008? 12 A. That's correct. 13 A. No. 13 Q. Mr. Edwards, has, has anyone from the 14 lave you seen , Agent 14 United States Attomey's Office discussed the 15 since July, July or August of 2008 during 15 topic well, let me strike that Have you been 16 that short conference as physically seen her 16 granted immunity with regard to any aspect of your 17 someplace? 17 work associated with either the Epstein files or the 18 A. Unless she was at the hearing we all attended 18 Rothstein prosecution? 19 on your motion to stay that day when there were a lot of 19 A. I don't understand your question. 20 people in the courtroom, the answer is no. 20 Q. Okay. You're aware that Mr. -- 21 Q. Okay. Have you seen ent , asstra nik ! 21 A. I can answer, no. I haven't been granted 22 the male agent's name was or 22 inununity to anything, so it doesn't matter what your 23 have you seen him since that yin July or AT,. 23 question is. 24 012008? 24 Q. Okay. Have you ever had any conversations 25 A. I do not believe I have. 25 with any of the probation officers in Palm Beach 1 sire 2 m yet!) with either Page 221 elating to any Epstein 1 2 County regarding Mr. Epstein? A. No. Page 223 3 related matter since July or August of 2008? 3 Q. Have you directed that anyone have any 4 MR. SCAROLA: I am going to instruct you 4 discussions with the probation officers in Palm 5 not to answer on the basis of the privilege as 5 Beach County regarding Mr. Epstein? 6 previously described. 6 A. That is clearly calling for work-product 7 BY MR. CRITTON: 7 privilege information. I'm not going to answer the 8 Q. Mr. Edwards, have you spoken with any rep, 8 question. 9 has any representative of the FBI attempted to speak 9 Q. Have you had any discussion with any of 10 with you regarding your association with the RRA 10 the other lawyers who represent clients in the 11. firm? 11 Epstein, in Epstein related matters regarding 12 A. No. 12 Mr. Epstein's probation? 13 Q. Has any member of the U.S. Attorney's 13 MR. SCAROLA: Same objection, same 14 Office discussed with you any aspect of your tenure 14 instructions, and I would add to those 15 or employment at the RRA firm? 15 objections the objection based upon a joint 16 A. No. 16 prosecution interest. 3.7 Q. In any conversations that you, that you 17 BY MR. CR1TTON: 18 had that you've had with the United States 18 Q. Mr. Edwards, among the Plaintiffs' 19 Attorneys Office at any time, has anyone ever asked 19 lawyers, is there any type of joint prosecution 20 you any questions about Scott Rothstein? 20 agreement related to Mr. Epstein? 21 A. You're presupposing that I had conversations, 21 MR. SCAROLA: Same objection, same 22 but I will answer the question whether !have or have 22 instruction. 23 not had conversations. Nobody has asked me any 23 BY MR. CRITTON: 24 questions from the State Attorney's Office, U.S. 24 Q. Did you have — did you engage in weekly 25 Attorney Office FBI? or other agency related to Scott 25 or month meetings among the Plaintiffs' lawyer to 19 (Pages 220 to 223) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins I Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins ) 2dS9412d47124170-9632-0511ffridea EFTA00611256 Page 224 Page 226 1 share investigative material regarding, that you had 3. instnetion. 2 obtained regarding Mr. Epstein? 2 BY MR. CROTON: 3 MR. SCAROLA: Same objections and 3 Q. Mr. Edwards, do any of the 4 instructions. 4 investigators — let me strike that. Did any of the 5 BY MR. CRITTON: 5 investigators who worked for RRA refer any Epstein 6 Q. Did you provide any of the investigative 6 client to you? 7 materials that had been acquired by you to any other 7 A. What is an Epstein client? 8 person outside of the RRA firm and the Farmer, Jaffe 8 Q. I am sorry. Did any of the investigators 9 firm up through the current date? 9 who worked for RRA refer a perspective claimant 10 MR. SCAROLA: Would you read that question 10 against Mr. Epstein to you? 11 back? 11 A. No. 12 BY ta. CROTON: 12 Q. Did any of your, did any of the RRA 13 Q. Let me ask it. During the time that you 13 investigators ever meet with your three clients? 14 were with RRA, excuse me, and had investigation done 14 MR. SCAROLA: Same objection. Same 15 on Mr. Epstein, was any of your investigation that 15 instruction. 16 you had performed turned over to any person outside 16 MR. CROTON: Okay. And I'm looking for 17 of RRA or your clients? 17 is a yes/no. 18 MR. SCAROLA: Same objection, same 18 MR. SCAROLA: Correct. Same objection, 19 instruction to the extent that that would 19 same instruction. 20 encompass other attorneys with a shared 20 BY MR. CROTON: 21 interest in the prosecution of Mr. Epstein. 23. Q. Mr. Edwards, during the tine that you were 22 If any of those materials were turned over 22 with RRA, did you, your e-mail, was your only e-mail 23 to persons who did not have a direct interest 23 address bedward......... 24 to lawyers who did not have a direct interest 24 A. I only had one e-mail address. 25 in the prosecution of the claims against 25 Q. All right. Did you ever receive any Page 225 Page 227 1 Mr. Epstein or to clients who did not have, to 1 information regarding your cases at your home 2 persons who did not have a direct interest in 2 e-mail? 3 the pursuit of their claims against 3 A. I don't tenadober. 4 Mr. Epstein, then you can answer to that 4 Q. Okay. What is your home e-mail address, 5 extent. 5 please. 6 THE WITNESS: Privileged. 6 THE WITNESS: Do I give this? 7 BY MR. CRITFON: 7 MR. SCAROLA: . Sterols nods his head. 8 Q. And i just want to be clear is, is there 8 THE WITNESS: 9 any written agreement and I know you, I want to make 9 BY MR. CROTON: 10 certain that the objection is there, is as we both 10 Q. Did you have a separate fax number at RRA 11 know there are a number of claims. There are a 11 when you were there; that is, just so a fax would 12 number of claims that are outstanding against 12 come directly to either yours or an area where you 13 Mr. Epstein brought by a number of different 13 were located? 14 lawyers. 14 A. No. 15 MR. SCAROLA: The objection extends to 15 Q. In any of the directions that you ever 16 both written agreements and oral agreements. 16 gave to the investigators, did you ever put that in 17 THE WITNESS: Yes. We both know that 17 the form of a memo; that is, would you give them 18 there are a lot of claims against Mr. Epstein 18 written directions? 19 for basically the sane conduct. 19 MR. SCAROLA: Same objection, same 20 BY MR. CRiTTON: 20 instruction. 21 Q. And my question to you is is, is there any 21 BY MR. CIUTTON: 22 written agreement between the Plaintiff lawyers who 22 Q. To your knowledge did any of the 23 have filed claims against Mr. Epstein regarding the 23 investigations that were done regarding Mr. Epstein, 24 sharing of information? 24 were they provided to any other person at RRA? 25 MR. SCAROLA: Same objection, same 25 A. Excuse me? 20 (Pages 224 to 227) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins (601-051.976.2934) 2d39412c1-67f2-4170-9d82.05111176c2oa EFTA00611257 Page 228 Page 230 1 Q. You have testified that investigations 1 and I'm using just as an example, is that he came in 2 were done during the time, on Mr., relating to 2 or Scott Rothstein came in and looked at a 3 Mr. Epstein during the time that you were at RRA 3 particular file of yours, whether it related to 4 A. Right. 4 Mr. Epstein or not, you don't know? 5 Q. My question to you is, did you -- first of 5 A. 1 can't answer that question accurately. 6 all did you receive written reports in addition to 6 Q. Okay. Did you ever send investigative 7 oral reports? 7 reports to other lawyers regarding Mr. Epstein; that 8 A. From the investigators? 8 is, if you got an investigative report from 9 Q. Yes, sir. 9 Mr. Fisten or Mr. Jenne or whomever, would you send 10 THE WITNESS: Answcr? 10 those on to certain lawyers on a regular basis? 11 MR. SCAROLA: Yeah. 11 MR. SCAROLA: You can answer that 12 THE WITNESS: The reports were — yes, I 12 question. 13 did. 13 THE WITNESS: No. 14 BY MR. CFUTTOIsk 14 BY MR. CRITTON: 15 Q. And were the reports provided by e-mail or 15 Q. What lawyers, other than yourself, were 16 were they provided by, in the form of a memo that 16 involved in the Epstein cases during the time you 17 would be sent from the investigator to you or both? 17 were associated with RRA? 18 A. I,1do not remember there being any in the 18 A. What do you mean by "were involved? I guess 19 form of an e-mail. Does not mean that there was not. I 19 all. 20 did communicate by e-mail with other members of the firm 20 Q. What, what lawyers actually worked on the 21 and other members of the investigative team on all cases 21 file? I know Mr. Berger worked on the Epstein 22 as has been my practice all along practicing law. There 22 cases, correct? 23 were memos, though, that were given to me that were not 23 A. In some limited capacity, correct. 24 e-mail form that were the standard nItI10.10 that I would 24 Q. Okay. Mr. Adler I know attended 25 incorporate into a witness memo file. 25 Mr. Epstein's deposition, correct? Page 229 Page 231 1 Q. And again that would just be in your, 1 A. Correct. 2 would that be in your electronic storage as well as 2 Q. Did, did any other lawyers other than 3 in the hard copies? 3 Mr. Adler or Mr. Berger attend any depositions? 4 A. The version I saw was the electronic. 4 A. Your memory is going to be as good as mine 5 Q. So, that would be stored in the Fortis 5 there. I'm thinking. Mark Epstein's deposition was 6 program? 6 attend by Russell Adler. 7 A. That's correct. 7 Q. He went with you to New York? B Q. All right. And again other individuals in 8 A. No. He didn't go with me to New York. He 9 the firm, other lawyers in the firm might be able to 9 attended the deposition, and I also attended the 10 access that program, you just don't know? 10 deposition. 11 A. Right. Well, the program, obviously that's 11 Q. Both in person? 12 the program that the firm used. Now, whether they could 12 A. Right. 13 access, if you could go across cases that weren't cases 13 Q. Was he there for another file or did he 14 you worked on, I really just don't know. 14 meet you there to specifically attend Mark Epstein's 15 Q. As an example could Mr. Fisten, on the, on 15 deposition? 16 the Fortis, could he access your, your file on an 16 A. Coincidence that he was in New York during the 17 Epstein case? 17 time when his deposition was being taken. 18 A. I don't know. 18 Q. Any other lawyer that you can recall being 19 Q. If someone accessed your file, accessed 19 at a deposition other than Adler, Berger and 20 your electronic file, would you necessarily know 20 yourself? 21 that? 21 A. Not right now. If you remind me,I, 1may 22 A. No. 22 remember. I don't remember right now. 23 Q. All right. So -- 23 Q. Did other lawyers in the firm at RRA 24 A. I don't believe so. 24 perform services on the files; that is, and by that 25 Q. It wouldn't show up that Michael Fisten, 25 I mean did they, were they involved in draft' 21 (Pages 228 to 231) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601451.9764934) Electronically signed by cynthia hopkins (601.051.976.2934) Electronically signed by cynthia hopkin► (601451.976.2934) 2d394126417f2-41704id82-0511078c2ea EFTA00611258 Page 232 Page 234 1 motions, research, appeals, pleadings, papers that 1 Epstein case? 2 were filed? 2 A. When I was giving you that list of names, I 3 MR. SCAROLA: You can, you can answer 3 was picturing one of the couple meetings related to 4 whether they were, there were other lawyers 4 Jeffrey Epstein's case. Could there have been other 5 involved in drafting tasks without identifying 5 lawyers in the room, yes, but J think that is the 6 what those may have been. 6 exclusive list. 7 THE WITNESS: Other lawyers contributed to 7 Q. Did Mr., did anyone ever attend by phone 8 some extent to the prosecution of those cases. 8 meetings associated — 9 BY MR. CROTON: 9 A. 'understand. 10 Q. Who? Names. I'm not asking for tasks. 10 Q. — that involved Mr. Epstein? 11 MR. SCAROLA: You can answer. 11 A. !understand. No. 12 MR. CRITTON: I am asking for names. 12 Q. Did Scott Rothstein ever attend any 13 THE WITNESS: Bill Hager, Judge Stone, 13 meetings wherein strategy was discussed regarding 14 Russell Adler, Rob Buschel. 14 the Epstein cases? 15 BY MR. C 15 A. No. 16 Q. B-o-u-e-h 16 Q. The one meeting that you had in Mr., 17 A. I dent know hug to spell it B-u, I don't 17 Mr. Rothstein's office with Russell Adler and some 18 know how, B-u-s-c-h-klbelieve. 18 unknown person on the phone, were you given any 19 Q. All right. Is he currently with you now? 19 direction at that time that certain discovery should 20 A. No. 20 be done or certain tactics should be used with 21 Q. My other lawyers? 23. regard to prosecuting the Epstein cases? 22 A. And you're asking for no matter how minimal, 22 MR. SCAROLA: Same objection, same 23 just anything done by any lawyers? 23 instructions. 24 Q. Correct. 24 BY MR. CRITTON: 25 A. Michael, I think his name is Michael. It was 25 Q. Did you ever receive any 'mail Page 233 Page 235 1 another lawyer. That's, that's -- those are the ones 1 correspondence from Scott Rothstein that detailed or 2 that I can remember right now. 2 that set forth discovery that would be, that should 3 Q. Wore them ever meetings that occurred, 3 be undertaken with regard to the Epstein cases? 4 well, not were there ever specific meetings that 4 MR. SCAROLA: You can answer that with a 5 were attended by various lawyers to discuss 5 yes or no. 6 Epstein's cases? 6 THE WITNESS: No. 7 MR. SCAROLA: You can answer whether there 7 BY MR. CRITTON: 8 were meetings. 8 Q. Did you ever have, did you ever receive 9 THE WITNESS: There were meetings to 9 any correspondence directly, Mr., Mr. Rothstein to 10 discuss every case including Jeffrey Epstein's 10 you, during the time that you were at RRA? 11 Cases. 11 A. Yes. 12 BY MR. CRITTON: 12 Q. Did any of the correspondence ever involve 13 Q. And when you say there were meetings to 13 Epstein or communication ever involve Epstein? 14 clictims every case, were there routine meetings that 14 MR. SCAROLA: You can answer that. 15 were held to discuss your cases or cases in general? 15 THE WITNESS: To some extent, yes. 16 A. It's how the firm worked. If you wanted to 16 BY MR. CRITTON: 17 discuss cases, or the case was a case that was thought 17 Q. Okay. And what did, what did, what 18 to need more than one or more than two attorneys, then a 18 information did Mr. Rothstein send you that involved 19 meeting could easily be assembled within RRA to sit 19 Mr. Epstein? 20 around the table and discuss issues related to any case. 20 MR. SCAROLA: Same objection, same 23. And yes, that happened with respect to cases filed 21 instruction. 22 against Jeffrey Epstein. 22 BY MR. CRTITON: 23 Q. And so there could have been additional 23 Q. Is the information that you received or 24 lawyers in addition to Adler, Stone, Berger, and Rob 24 the communication you received from Mr. Rothstein 25 Buschel and yourself that would have commented on an 25 regarding, that involved Mr. Epstein. was that by 22 (Pages 232 to 235) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins 2d39412d4M4170403241511Mkaa EFTA00611259 Page 236 Page 238 3. way of e-mail? 1 RICO claims. 2 • A. Yes. 2 Q. But you certain have brought RICO claims 3 Q. Did you ever receive any memorandum from 3 against Mr. Epstein? 4 hint that is, a typewritten memo that was then sent 4 A. I know about one now. 5 to you through office mail that was not electronic 5 Q. Okay. At the time that you were at the 6 involvingMr. Epstein? 6 State Attorney's Office, what kind of — how long 7 A. No. 7 were you there? 8 Q. At the meetings that you, at the meetings 8 A. Three years. 9 that occurred where these various lawyers, Berger, 9 Q. And what kind of crimes did you prosecute? 10 Adler, Stone, Rob Buschel were present and Epstein 10 A. Beginning with Dill's through attempted murders 11 was discussed, was the discovery that, discovery 11 and everything in between. No — well, not no, very few 12 and/or investigation regarding Mr. Epstein was that 12 economic crimes, some insurance fraud cases but very 13 ever discussed? 13 few, otherwise drugs, guns, robberies, burglaries 14 MR. SCAROLA: Same objection, same 14 attempted murder, aggravated batteries, those types of 15 instruction. 15 crimes, false imprisonment 16 BY MR. GLUTTON: 16 Q. Well, were you ever, do you know what 17 Q. Mr. Edwards, are you aware as a former 17 money laundering means in a criminal context? 18 state prosecutor that there are laws against 18 A. In some basic sense I do knew what money 19 conducting certain financial transactions in money 19 laundering means. 20 that's derived from a crime? 20 Q. What do you understand that to be? 21 A. I don't understand your question. 21 A. That you, that the criminal takes money and 22 Q. Okay. Well, you were a former state 22 through some illegal means attempts to make bad money 23 prosecutor; is that correct? 23 legitimate. 24 A. Right. Yes. 24 MR. cRrrroN: Let me show you what I will 25 Q. Right. Are you aware that there are 25 mark as Exhibit 2 which is the complaint that Page 237 Page 239 1 certain laws both state and federal that, that are, 1 was filed against Mr. Rothstein, yourself, and 2 that preclude conducting certain financial 2 3 transaction, transactions in money that is derived 3 (Plaintiffs Exhibit No. 2 was marked for 4 from a crime? 4 identification.) S A. Still don't understand your question. But 5 BY MR- CRITTON: 6 first before I try to answer your question, are you 6 Q. You're familiar with this complaint, sir? 7 taking me back to a time when I was a State Attorney and 7 A. Unfortunately I have read this frivolous 8 asking back then did I know and then your question? 8 complaint. 9 Q. Yes. 9 MR. CRITTON: Move to strike as 10 A. Back when I was a State Attorney did I know 10 nonresponsive. You've seen -- all I want is a 11 that there are crimes related to money transactions? 11 yes or no. 12 Q. No. 12 Are you familiar with this document? 13 MR. SCAROLA: Could I help you? Do you 13 MR. SCAROLA: I am going to object to the 14 want to ask him whether he was aware of the 14 form of the question. It is vague and 15 existence of a state RICO statute? 15 ambiguous. I don't know what familiarity 16 MR. CRITTON: No. 16 means. He has seen it before. 17 MR. SCAROLA: Okay. 17 BY MR. CRITTON: 18 MR. CRITTON: I am okay with that first, 18 Q. Mr. Edwards, you have seen and read the 19 but I am still going to ask my question. 19 entire complaint along with the attachments, 20 BY MR. CRITTON: 20 Exhibit 2? 21 Q. I assume you're aware of the existence of 21 A. I've read the complaint I have never read in 22 a state RICO statute, correct? 22 the entirety Exhibit 2. 23 A. I don't know that I was aware of that back 23 Q. Are you familiar, do you know what an 24 then. I just can't remember whether I knew about RICO 24 information is? 25 back at the State Attorney's Office. I never prosecuted 25 A. Yes. 23 (Pages 236 to 239) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins ( - 76.2 Electronically signed by cynthia hopkins ( Electronically signed by cynthia hopkins (601-051-976-2934) 2d39412d437t2-4170-9a32-0511816c2ea EFTA00611260 Page 240 Page 242 1 Q. And that's Exhibit I attached to the 1 asserted that the firm was a racketeering 2 complaint, correct? 2 enterprise, correct? 3 A. Correct. 3 A. Not necessarily — no. 4 Q. And you're aware that, and this is the 4 Q. Well, if you look in Paragraph 2, see 5 information that was brought by the United States of 5 where the firm is identified as the enterprise of 6 America, U.S.A. versus Scott Rothstein, correct? 6 the racketeering conspiracy? 7 A. Yes. 7 A. Law firm. Paragraph 2 of the information says 8 Q. And you're aware that within the — well B Rothstein Rosenfeldt Adler, P.A., was a law firm with 9 let me strike that. Are you aware that 9 10 Mr. Rothstein has pled guilty to, excuse me, the 10 and elsewhere. The law firm 11 information that was brought against him by the 11 employed approximately 70 attorneys and engaged in the 12 U.S.A.? 12 practice of law involving a wide range of specialties 13 A. I am aware that he pled guilty to something. 13 including labor and employment law. 14 Q. With regard to the complaint brought by 14 Q. Are you in Paragraph 2? 15 the U.S.A., I am sony, the information brought by 15 A. Of the information, yes. 16 U.S.A. against Mr. Rothstein, I assume you have read 16 Q. Pm sorry. I am looking at my 17 the allegations associated with the racketeering 17 apologies. On Paragraph 2 under Count 1, my error. 18 conspiracy, the pattern of racketeering activity, 18 A. Okay. 19 correct? 19 Q. See where the law firm is identified as 20 A. !haven't. 20 the racketeering enterprise? 21 Q. Okay. If you turn to Page 3, Paragraph 4, 21 A. I'm sorry. Your question is am I, do I 22 were you aware, were you aware prior to coming in 22 recognize that the law firm is categorized as an 23 here today that Mr. Rothstein was, that the charges 23 enterprise. Yes, in that paragraph I see that. 24 that were brought against him were for under, under 24 Q. Have you had an occasion to discuss with 25 RICO but with regard to mail fraud, wire fraud, 25 any, with either Mr. Adler or Mr. Rosenfeldt any of Page 241 Page 243 1 laundering of monetary instruments, engaging in 1 the allegations directed to Mr. Rothstein — 2 monetary transactions, and conspiracy to launder 2 A No. 3 monetary instruments and engage in monetary 3 Q. — in the criminal complaint? 4 transactions? 4 A. No. 5 A. I, I have read that in the newspapers. I have 5 Q. Since the implosion at the firm have you 6 been told that by numerous people. So, yes, I was aware 6 had an oerasion to talk about or speak or discuss 7 of that. 7 any firm business regarding Mr. Rothstein and the 8 Q. And within the complaint at Paragraph 6 it 8 ponzi scheme that he was running at RRA? 9 says the Defendant -- 9 A. Have I had an occasion where I could have 10 A. The information or the complaint? 10 talked — 11 Q. Tin sony. Within the information, 13. Q. No, Pm sorry. Have you had an occasion 12 Exhibit I to the complaint, in Paragraph 6 where it 12 to discuss with Mr. Adler since you left the firm or 13 speaks in terms of the Defendant and his 13 since the implosion any aspects of the, of the ponzi 14 co-conspirators, conspirators agreed, agreed to 14 scheme that Mr. Rothstein and his co-conspirators 15 engage in a pattern of racketeering activity through 15 were running through the firm? 16 its base of operation at the offices of RRA Do you 16 MR. SCAROLA: Are you asking whether he ' 17 see that? 3.7 did have such a discussion or whether he had an 18 A. Yes. 18 occasion to have such a discussion? 19 Q. Okay. Do you know who the, do you know 19 BY MR. CRII1ON: 20 any of the co-conspirators in addition who are 20 Q. Did you have such a discussion? 21 associated with Mr. Rothstein? 21 A. No. 22 A. Assuming that they are former employees of 22 Q. Okay. Have you discussed that or have you 23 RRA, which I would presume several of them are, I am 23 seen Mr. Adler at all other than hi, hello, since — 24 sure that I probably know them. 24 A Yes. So, the occasion existed. We just 25 Q. And you're aware that the government has 25 have that discuss ra„ am100.1.0tat nis.001H/10.0 'moo.I el Smormw•-"WadlOW1•••••••••••.. 24 (Pages 240 to 243) PROSE COURT REPORTING AGENCY, INC. Electronically signod by cynthla hopkins Electronically signed by Cynthia hopkins Electronically signed by cynthia hopkins 2d3941246712417046324511fMkgea EFTA00611261 1 2 Page 244 Q. Have you, and if I understand correctly you haven't discussed any firm business with 1 2 Page 246 THE VIDEOGRAPHER: We are now off video record -- I 3 Mr. Adler since the implosion; is that correct? 3 MR. SCAROLA: That will be a refreshing 4 A. Firm business? 4 change. 5 6 7 Q. Any firm RRA business? A. Right, no. Q. How about with Mr. Rosenfeldt, have you 5 6 7 THB VIDEOGRAPHER: We are now off video retold at 3:44 p.m. (A brief recess was held.). I 8 had any discussions with him — 8 MR. CRYTTON: Mr. Edwards -- 9 A. None. 9 THE VIDEOGRAPHER: Were back on video 10 Q. — since the implosion of the finn in late 10 record. It is 3:59 p.m. 11 October of '09? 11 BY MR. CRITTON: 12 A. No. 12 Q. Mr. Edwards, when you joined RRA, if I 13 Q. If you wanted, if you had any, other than 13 understood your earlier testimony, with regard to 14 your existing partners have you had an occasion to 14 the Epstein cases and your other cases when you came 15 speak with any other partners or former partners of 15 there as far as you were concerned is you had the 16 the firm regarding the implosion well, let me 16 ability to spend whatever money was necessary to 17 strike that — regarding the ponzi scheme that was 17 prosecute the Epstein cases, fair statement? 18 being run by Mr. Rothstein through the firm? 18 A. I don't know that that's wile or ifs not true 19 A. I have spoken to my current partners about it. 19 I mean. 20 Q. Are your current pinions, are you aware 20 Q. Well — 21 of any of your current partners being a target of an 21 A. My judgment was never questioned. 22 investigation as a potential co-conspirator with 22 Q. Correct. And therefore whatever monies 23 Mr. Rothstein? 23 you spent either in investigation, in doing 24 A. No, way. 24 discovery, that was your decision and your decision 25 Q. You're not aware of or no one has told you 25 alone, true? Page 245 Page 247 1 that, correct? 1 A. Whatever money that I spent was my decision -- 2 A. I am not aware of that and nobody has told me 2 Q. No. Whatever money you spent on 3 that. 3 investigators, on doing depositions, on requesting 4 Q. Mr. Rothstein founded what was, what 4 transcripts, on doing what was necessary to 5 ultimately became RRA in approximately 2002. Were 5 prosecute the Epstein cases, that was >our decision? 6 you aware of that fact? 6 A. No. The actions were my decisions in terms of 7 A. No. 7 how to prosecute the case. The amount of money to spend B Q. How long did you think Mr. Rothstein had 8 per exercise was not my decision nor was I privy to that 9 been -- well, let me strike that. How long did you 9 information. 10 think RRA had been in existence prior to your 10 Q. Well, but, you were the one who directed 11 joining the firm? What were you told? 11 that the particular task be taken, correct? 12 A. I don't know what I was ever told. I think 12 MR. SCAROLA: This is, this is 13 that I learned that information when the implosion, as 13 repetitious. 14 you call it, occurred. 14 MR. CRIITON: tarn setting a stage. 15 Q. And were you, in terms of what the 15 MR. SCAROLA: This is repetitious of areas 16 revenues of the firm were, were you ever advised 16 of examination that were covered thoroughly in 17 what the revenues of the firm were? 17 the earlier portions of this deposition. 18 A. No. 18 THE WITNESS: If I wanted a witness 19 Q. Okay. Were you, were you familiar with 19 interviewed, l could ask an investigator to 20 what the expenses were associated with operating the 20 interview. The investigator, how they were 21 RRA firm? 21 paid, how much they were paid, whether they 22 A. No. 22 were paid is not something that I had any 23 Q. Were you in anyway -- well, let me strike 23 knowledge of at all. 24 that With regard to — let me take a five minute 24 BY MR. CRITION: 25 break and let me collect any thoughts. 25 Q. y. When you ran mur own firm tu MOIN 25 (Pages 244 to 247) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins 2d39412c1-6712-41704082-051 lif76c2ea EFTA00611262 Page 248 Page 250 1 obviously knew what, whether hiring an investigator 3. Q. Okay. Were they all on the, were they, 2 or what a particular cost was because you had to pay 2 were they -- 3 it, correct? 3 A. Some were B.S.O as well. Some were Broward 4 A. Yes. 4 Sheriffs Office. Some were from Fort Lauderdale. It 5 Q. Okay. And I think as you described 5 was both. 6 earlier is that there had been very little discovery 6 Q. With, with regard to the police °Thetis 7 up until the time you started working for RRA in 7 and the Sheriffs Deputy's that were present, where 8 your three cases, true? 8 they on every floor ofRRA? 9 A. Not very little discovery. Obviously we had 9 A. It seemed that way. 10 gone through interrogatories, responses, request for 10 Q. And had you ever been in a, in a law firm 11 production, responses or lack ofresponses, however, the 11 either as a visitor or as an employee or partner 12 majority of the depositions that were taken, the cases 12 where you had seen armed guards from either a 13 just happened to be right last summer for most of those 13 Sheriffs Office or a police department roaming the 14 depositions to take place, and that's what happened. 14 halls? 15 Q. Not only depositions but as well the 15 A. No. 16 investigation as you have described, your 16 Q. Had you ever been to the KRA offices 17 investigator that you hired as an outside person 17 before you accepted the job? 18 didn't really start until late March or early April 18 A. No. 19 in conjunction with the other investigation that you 19 Q. When you got there and you saw the anted 20 did during the time you were with RRA, correct? 20 guards patrolling the floors, did you ever have a 21 A. Fair statement. 21 convetsation with Russell Adler or anyone else as 22 Q. All right. And when you were at RRA you 22 like what in heaven's name is going on here? 23 described earlier, and I won't belabor it, but you 23 A. I didn't see them when I first got there. 24 described the compound I think is the word that you 24 Q. How much time passed before you saw the 25 used that Mr. Rothstein kept himself in when he was 25 guards? Page 249 Page 251 1 at the firm, correct? 1 A. When I first started I believe that the people 2 A. Correct. 2 patrolling, I'm not sure that they initially were 3 Q. Right. And he was not accessible to 3 Broward Sheriffs or Fort Lauderdale police. I think 4 everyone else, true? 4 that may have been a month after I began. From what I A. Right. 5 remember seeing, and I can envision the people in my 6 Q. And was he on your floor or was he on a 6 head, they were private security people. At least that 7 completely separate floor? 7 was the appearance or the interpretation that I had. 8 MR. SCAROLA: M opposed to a partly 8 And I didn't question it at the time who they were. 9 separate floor. 9 Q. Within — 10 THE WITNESS: For the most part he was on 10 A. I don't think. 11 a separate floor. 13. Q. Within a short period of time though you 12 BY MR. CRITTON: 12 recognized that they were either Sheriffs Deputies 13 Q. Okay. And were there guards during the 13 or police officers? 14 time that you were at, at the RRA firm, RRA, were 14 A. At the point in time where I recognized that 15 there ever guards that patrolled the hallways? 15 they were armed uniformed police officers in the finn, 16 k Yes. 16 yes, I questioned it not only to Russell Adler but to 17 Q. And was that from the day you started? 17 anybody else, anybody else, because all of the lawyers 18 A. I believe so. 18 in the finn thought it was strange. 19 Q. And had you ever been in a firm where — 19 Q. Okay. And what did Adler tell you? 20 bless you. Had you ever been in a firm where 20 A. That Scott Rothstein has a lot of money, prior 21 there -- well, let me strike that. The guards were 21 to you being here, a female attorney was murdered and he 22 what, Broward County Sheriff's Officers? 22 wants to make sure that his friends and family are as 23 A. I don't remember the agency but they were 23 secured as possible, that while he has this extra money 24 armed uniformed police officers. I believe Fort 24 to spend on security, he is going to do that for all of 25 Lauderdale. 25 our safety. 26 (Pages 248 to 251) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthla hopkins 2d39412d-8712.417043d82-0511876c2ea EFTA00611263 Page 252 Page 254 1 Q. Did you understand as well that he had, 1 A. I went there one time. 2 that the firm was paying for armed guards to guard 2 Q. For what occasion? 3 his house 24 hours a day? 3 A. I don't remember the occasion, but it was a 4 A. No. 4 gathering that he had at his house and he asked, during 5 Q. When did you team that fact? 5 the course of me working there were ten occasions where 6 A. After the disbandment of RRA 6 everybody was invited to go to his house for various 7 Q. Did Mr. Adler tell you that Mr. Rothstein 7 events and on one occasion, I went. had amazing or substantial wealth? 8 Q. Oh, all right. And from being in his 9 A. I don't }mow in those words, but I, I 9 house did you recognize immediately that this was a 10 definitely understood that. 10 multi-million dollar house? 11 Q. Okay. In meeting Mr. Rothstein initially, 11 A. Yes. 12 initially for the ten minutes as you were 12 Q. Okay. Was it on the water? 13 contemplating taking a job and on the two other 13 A. Yes. 14 occasions or the one other occasion when you saw him 14 Q. And could you tell from the interior 15 out in the restaurant, I think you described him as 15 design or the decorations that existed that this was 16 flamboyant? 16 at least a man, a man that had significant wealth? 17 A. I'm not sure I used that word but probably one 17 A. Yes. 18 synonymous, and, yes, I would describe him as such. 18 Q. All right. And could you, did you have an 19 Q. Was he someone that at least -- well, let 19 opportunity to see his collection of automobiles? 20 me strike that Were you aware that he had a, a 20 A. No. 21 watch collection of hundreds of watches? 21 Q. During the time that you were in the 22 A. No. 22 house, did you have an opportunity, did, did you 23 Q. Did you see him wear expensive jewelry 23 walk around the house? 24 when you saw him; that is, the few occasions that 24 A. No. 25 you saw him? 25 Q. How many people were there, best estimate? Page 253 Page 255 1 A. Never. I didn't take notice of that. 1 Are we talking like ten or 12? 2 Q. Okay. When you saw him, was he dressed in 2 A. No, no, no. 250. 3 a suit or was he dressed in business, or in casual, 3 Q. Did you talk to Mr. Rothstein at all? 4 more casual clothes? 4 A. Not even fora second. 5 A. Always a suit. 5 Q. Could you walk anyplace in the house that 6 Q. And looking like a million bucks? 6 you wanted? 7 A. Looking ridiculous. 7 A. The party, at least to the extent that I 8 Q. But something that looked very expense, 8 participated in it, was outside. So I, I don't know if 9 flashy, showy? 9 I could have walked around the house, but I did not walk 10 A. I couldn't tell how expensive it was, but 10 around the house nor did I really walk inside the house 11 flashy and showy, yes. It may be a pink shirt with a 11 other than to go in the front door, straight out back, 12 purple tie and a blue suit, something that you would 12 and then leave the exact same pathway that I entered. 13 never expect a lawyer to be wearing, yes. 13 Q. What his property located on Castillo 14 Q. And in terms of the, in terns of the, of 14 Island? 15 his personal wealth or his, his personal assets, 15 A. I don't know. 16 were you aware of where be lived? 16 Q. Were you aware or did you become aware 17 A Was I aware when? 17 that Mr., during the time that you were there that 18 Q. During the time you worked for RRA 18 Mr. Rothstein had investments in multiple real 19 A. Yes. 19 properties? 20 Q. Okay. And were you aware that he was 20 A. No. 21 living in a multi-million dollar house? 21 Q. Were you aware at the time that you met 22 A When, when I went to the house!, 'recognized 22 him first at the BOVA restaurant that he had an 23 it as such. 23 interest in BOVA restaurant? 24 Q. You said you want to the house. Did you 24 A. When I met him, no. 25 fm to Mr. Rothstein's house? 25 Q. Did he have an interest in BOVA restaurant 27 (Pages 252 to 255 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hooking Electronically signed by cynthia hopkins 2W9412&67f24170-9d82-0511076c2ea EFTA00611264 Page 256 Page 258 1 at that time? 1 A. No. 2 A. I heard that sometime after I began working 2 Q. Were you aware that he had multiple jet 3 there. He certainly acted like he did. 3 skis? 4 Q. Did you learn that he had investments in 4 A. No. 5 other business entities, whether they were other 5 Were you aware that he had a 55-foot Sea 6 restaurants or other business entities -- 6 Ray? 7 A. Through -- 7 A. No. 8 Q. during the time that you worked at RRA? 8 Q. Were you aware that he owned a 9 A. Through minors. 9 Lamborghini? 10 Q. And rumor was he had his fingers in many 10 A. No. 11 different businesses? 11 Q. Again during the time that you were at 12 A. It sounded like hundreds. 12 RRA? 13 Q. And did you understand that he had a 13 A. I understand that. The answer is no. 14 substantial collection of automobiles? 14 Q. In addition to the, to the business of 15 A. What do you mean by substantial selection or 15 owning BOVA what other business ventures did you 16 collection? 16 understand he had? I think you said you thought he 17 Q. Well, were you, during the time that you 17 was in hundreds of businesses. 18 were at RRA were you aware that he had Ferraris? 18 A. Through a nunor. 19 A. No. 19 Q. Right. 20 Q. Multiple Ferraris? 20 A. I understood that he owned a Vodka. I 21 A. No. 21 understood generically that he owned or purchased 22 Q. Were you aware that he had a Bentley? 22 various patents. I understood -- I didn't know what the 23 A. Yes. 23 patents were. I understood that he owned other 24 Q. Were you aware that he had a Bugatti? 24 restaurants. I understood that he owned or was partial 25 A. I heard that. 25 owner of Cafe Iguana. Page 257 Page 259 1 Q. Were you aware that he had a Rolls Royce? 1 At some point in time I learned that he 2 A. No. 2 was owner or partial owner of the Versace mansion. 3 Q. Were you aware that he had multiple 3 And I think in general it was always explained to me 4 Corvettes? 4 or I overheard he had, he has his hands in all of 5 A. No. 5 these, this assortment of businesses and those 6 Q. Either a Corvette or multiple Corvettes? 6 business ventures have done very well, and that is 7 A. No. 7 the source of his apparent extreme amount of wealth. 8 Q. Were you aware that he had multiple B Q. Who told you that? 9 Mercedes Benz? 9 A. I don't, I don't know. More, more than one 10 A. No. 10 person. I mean, that was just kind of the word around 13. Q. Were you aware that he owned a yacht? 11 the campfire so to speak. 12 A. Yes. 12 Q. Did you inquire as to -- let me strike 13 Q. Okay. And was that parked behind his 13 that. Did you ever see any documents that reflected 14 house? 14 or documents or read any information about 15 A. Yes. 15 Mr. Rothstein that preexisted 2002 which was kind of 16 Q. Were you aware that he also — and did it, 16 the start of the RRA firm? 17 if I was to say it was approximately an 85 to 17 A. I don't understand. 18 90-foot yacht or, in fact, an 87-foot yacht? 18 Q. Okay. Well, I think we established 19 A. I wouldn't quarrel with that. 19 earlier that your understanding was that RRA kind of 20 Q. Did it also appear that he had a 20 started as a film in the 2002 time frame. 21 substantial sport fisherman that was parked out 21 A. Well, you told me that and I have been told 22 there as well? 22 that after the implosion that that was the time period 23 A. I didn't see that. 23 that RRA started. I didn't know anything about Scott 24 Q. Were you aware that he had 33-foot Aqua, 24 Rothstein until the year 2009 at all. 25 A uaviva? 25 Did • do an research with re • d to 28 (Pages 256 to 259) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins 2d39412d-6712.4170-9d132-0511tflEic2oa EFTA00611265 Page 260 Page 262 1 Mr. Rothstein prior to going to the firm and by 1 matters with regard — 2 researchltnean people Google. Did you Google him? 2 MR. CRITTON: Form? 3 A. No. 3 MR. SCAROLA: — to these cases? 4 Q. Did you, did the fine have a brochure? 4 MR. CRITION: Form? 5 A. I don't know. 5 MR. SCAROLA: No, no. It's a, it's a 6 Q. Did you ever see brochures in the waiting 6 speaking inquiry- 7 room or the reception rooms that described the finn 7 BY MR. CRITTON: 8 when it was founded, background of the firm, et a Q. Mr. Edwards, did you ever have any 9 cetera? 9 dealings with Deborah Villegas? 10 A. No. 10 A. No. 11 Q. Was it on your web site? 11 Q. Am I saying it right? 12 A. Was what on my web site? 12 A I don't know. 13 Q. The history or the background of the firm. 13 Q. V441-e-g-a-s? 14 Let me strike that. RRA had a website? 14 A. I've seen the name. 15 A. RRA had a website. 15 Q. Did you know who she was? 16 Q. That's no longer in existence, true? 16 A. In what way? 17 A. True. 17 Q. As it related 18 Q. And — 18 A. I knew that she worked for the firm. 19 A. To my knowledge. 19 Q. What did you understand her position was? 20 Q. Did you ever go on the website and 20 A Rothstein's 21 checkout the web site for the history or the 21 Q. Did you unoersi no ter robe the COO of 22 background of RRA and Mr. Rothstein? 22 the company, of the firm? 23 A. I went on the website. I don't know that the 23 A. Right. I don't know if COO or whatever, but 24 website even had a history. If it did, I don't remember 24 his right-hand man; that's the person who gets him what 25 ever looking at it. 25 he wants. That's at least in a broad term what I Page 261 Page 263 1 Q. Did it, did, at least from what you saw 1 understood her position to be. 2 and observed of Mr. Rothstein, did it appear to you 2 Q. Did you understand she was a financial 3 that the, his wealth far exceeded the type of 3 person? 4 business that it appeared to you that the firm was 4 A. it. 5 doing? 5 Q. Or an administrative person? 6 A. I have no understanding whatsoever. No, 6 A. My understanding was administrative. 7 that's not something that ever crossed nw mind. 7 Q. With regard to Mr. Rothstein's; that is, 8 Q. Well, under these circumstances is, is 8 his real property, his vehicles, his boats, his 9 when you went to the firm, you had the ability to 9 business interests, would it be a coned statement, 10 your discretion to spend whatever monies you wanted 10 sir, that you weren't concerned about the source of 11 in prosecuting your personal injury and Epstein 11 his wealth? 12 cases. You, no one ever turned down a request 12 A. You went through a list of the things that i 13 either fora reimbursement or told you not to expend 13 knew or did not ;mow him to have in tennis of assets. 14 any money, true? 14 And i told you for the most part I didn't even know that 15 MR. SCAROLA: Objection, compound and 15 he had those things. In fact, while you were out of the 16 repetitious. 16 room, I just educated myself by reading the information 17 THE WITNESS: I don't understand the 17 on some of the things he had and I didn't know until 18 question. 18 right now that he had those things. But certainly while 19 BY MR. CRITTON: 19 I was working at RRA I didn't know that he had those 20 Q. No one, as to any expenditure that you 20 things. 21 ever made on an Epstein case - 21 Q. Then let me be specific. With regard to 22 MR. SCAROLA: Isn't this about the fourth 22 the, with regard to the house that you ;mew he had, 23 time that you're eliciting exactly the same 23 with regard to the yacht that you knew he had, with 24 testimony? isn't it very clear the extent to 24 regard to the vehicles that you knew he had, with 25 which Mr. Edwards had control over financial 25 re X d to the business interests, at least BOVA and 29 (Pages 260 to 263) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthla hopkins ( Electronically signed by cynthia hopkins Electronically signed by cynthla hopkins 20.412c187a41704d1124$11,178o2se EFTA00611266 Page 264 Page 266 1 at least what was rumored to be his business 1 things of that nature. 2 interest, did you believe that the source of his, of 2 Q. And that's my question to you: Did you 3 his apparent wealth was as a result of the law firm? 3 hear these names before or during the time that you 4 A. I believe that the source of his wealth was 4 were at RRA as distinct from now? 5 the law finn as well as the, what I have described as an 5 A Of that list you just read until right this 6 assortment of businesses that he had his hands in of 6 second, Michael Szafranski is the only one that I have 7 which only a fraction I was aware. 7 ever heard of and that was after implosion of RRA 8 Q. Well, what did you understand to be the $ Q. And again this question is specific to the 9 source of the finding of the, of the Epstein cases time frame — 10 and the other lawsuits that you had? 10 A. Sure. 11 A. The checks i believe were written by the law 11 Q. — that you were there? Dominic 12 firm. 12 Ponatchio, 13 Q. Okay. And what did you believe was the 13 A. No. 14 source of the monies that the law firm got to expend 14 Q. Moto, M-o-t-o, Ban, B-a-n, Adon, A-d-o-n? 15 some, just on the three cases that you had with Mr. 15 A. No. 16 Epstein, some three to $500,000, I mean separate and 16 Q. Ever heard of Benozon (phonetic) Varon, 17 apart from all of the, your other personal injury 17 V-a-r-o-n? 18 cases and separate and apart from all of the other 18 A. No. 19 69 lawyers who were in the law firm who also had 19 Q. Onyx Capital? 20 cases? 20 A No. 21 A. ;didn't have a belief at all as to the source 21 Q. Onyx Options Consultants? 22 of any of the monies that were used for any of the case. 22 A. No. 23 Q. Was it your position it really wasn't your 23 Q. BWS Investments? 24 concern; that is, wherever the money cant from, it 24 A. No. 25 didn't bother you; all you knew is that the Linn was 25 Q. Puulin, P-i-r-u44-n, Group? Page 265 Page 267 1 funding your cases? 1 A. No. 2 MR.. SCAROLA: Objection, argumentative. 2 Q. Shimone (phonetic) Levy, L-e-v-y? 3 THE WITNESS: Yeah. At the time I believe 3 A. No. 4 that I am working at a well recognized law firm 4 Q. Obidia Levy, Pm sorry, d-i-a? 5 with good people and that is a successful law 5 A. No. 6 firm and this is the way that law limn at that 6 Q. Daniel Minkowitz, 7 level operate, and right, I didn't — 7 A. No. 8 BY MR. CRITTON: 8 Q. Fortress, an entity know as Fortress 9 Q. Didn't care? 9 Investments or Fortress Capital? 10 A. Right, I didn't care. I didn't question it. 10 A. No. 11 Q. With, with regard to, let me ask you some li Q. Drawbridge? 12 mums and see if you recognize the names. Do you 12 A. No. 13 lavw a person by the name of Barry Bekkadan, 13 Q. Capital or finding? 14 14 A. No. 15 A. Never heard the name until right now. 15 Q. Do you know an individual by the name of, 16 Q. Al Discala? 16 have you ever heard of, heard during that time 17 A. Again same answer. 17 period, did you hear of or know a person named 18 Q. Clockwork Capital Advisers? 18 George Levin, 19 A. No, never heard of them. 19 A. No. 20 Q. Razorback Funding? 20 Q. Banyan Investment Fund? 23. A. Nerve heard of it 21 A. No. 22 Q. Michael Szafranski, S-z-a-f-r-a-n-s-k-i? 22 Q. Dickyoulmow or hear of the name Frank 23 A. Heard that name - 23 Prove, P-r-1-v-I? 24 Q. And — 24 A. No. 25 A. — only after implosion and thryili papers and 25 0. Okay. Mr. Prevc is rtedl , was 30 (Pages 264 to 267) PROSE COURT REPORTING AGENCY, INC. Electronically signed by synth's hopkins Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by synth's hopkins (601.051-976.2934) 2d39412d-67t2.4170.9d82-0511M6c2ea EFTA00611267 Page 268 Page 270 1 purported to have an office within RRA's offices. 1 A. No. 2 'Have you seen that? 2 Q. Ed Morse? 3 A. Have I seen what? 3 A. No. 4 Q. Have you seen that in any of the news 4 Q. Richard Pearson, P-I-a-r-s-o-n? S media, that Mr. Preve had an office within RRA? 5 A. No. 6 A. That name doesn't sound familiar at all. So, 6 Q. Steven Levin, Ilv-i-n? 7 no, the answer to your question is no, I haven't seen 7 A. No. 8 that 8 Q. Ira Sochet? S-h or Sochet, S-o-c-hl-t? 9 Q. Bill Brock? 9 A. No. 10 A. Yes. 10 Q. Mark Melvin? 11 Q Okay. Who is Mr. Brock? 11 A. No. 12 A. In the law firm he went by the name Uncle 12 Q. !lack Samoney (phonetic)? 3.3 Bill. 13 A. No. 14 Q. Okay. All right. Who is Uncle Bill? 14 Q. Lawrence King? 15 A. Who do I tmderstand him to be? I don't know 15 A. No. 16 who he really was. At this point in time looking back, 16 Q. Steve Jackel? 17 there is no telling what anyone, what anyone or anything 17 A. No. 18 was. But at the time I believe that he was a relative 18 Q. Have you ever heard an attorney name 19 of Scott Rothstein's. 19 Michael Legamaro? 20 Q. What did he do? What did, what did Uncle 20 A. No. 21 Bill do — 21 Q. Kevin Draher, D-r-a-h-[r? 22 A. Some- 22 it No. 23 Q. - at the firm? 23 Q. David Boden, do you know David Boden? 24 A. Something with money. 24 A. Yes. 25 Q. Did behave an office at the firm? 25 Q. Okay. Who is Mr. Boden, an associate -- Page 269 Page 271 1 A. i think the trustees are still trying to 1 A. Are you asking me what I know now or what I 2 figure out what he exactly did do. 2 thought then? 3 Q. Did you have any dealings with him? 3 Q. Who did you understand Mr. Boden, David 4 A. Dealings, no, I didn't have dealings. 4 Boden to be when you became employed or associated 5 Q. Dealings of any kind? 5 with RRA in April of '09? 6 A. I talked to him 6 A. In Aptil of '09 i had not heard the name but 7 Q. Did you ever discuss any of your cases? 7 let's just skip to it. Sometime in let's say June or 8 Was he — he wasn't a lawyer? 8 July, I am guessing, sometime during the summer, I 9 A. Far from it. 9 understood him to be a lawyer at the firm. 10 Q. All right. Did you ever discuss any of 10 Q. Did you understand, did you understand he 11 your cases with him? 13. was a Florida lawyer or you just understood he was a :2 A. No. 12 lawyer? 13 Q. Just a hi, hello? 13 A. I understood he was a lawyer. I made the 14 A. Hi, hello, and 1 was one of the lawyers who 14 presumption or assumption at that time that since he was 15 would come in often and wodc on weekends and he would be 15 a lawyer for ARA that he was a Florida lawyer. i have 16 there. That's when i would see him, and he would kind 16 subsequently learned otherwise. 17 of, hey, how are you doing on a weekend. 17 Q. Did you know, did you ever have any 18 Qi And do you know a Dean ICretchmar, 18 business dealings with Mr. Boden? 19 K-44-c-h-m-a-r? 19 A. Never spoke a word to the guy. 20 A. No. 20 Q. What did you understand that he actually 21 Q. Same question again. do, these names 21 did at the firm? 22 dining the time period, Doug Van Allman, 22 A. Had no idea 23 A-I.1-m-a-n? 23 Q. How about Andrew Barnett? 24 A. No. 24 A. Don't know who that is. 25 Q. Ted Morse? 25 Q. There was an individual, he is described 31 (Pages 268 to 271) PROSE COURT REPORTING AGENCY, Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins 2d39412d.47f2-4170-9d82-0511,176c2ea EFTA00611268 Page 272 Page 274 1 as the director of Corporate Development for RRA 1 Fistos is my partner now. Marc Nurik is the lawyer who 2 . A. I don't know even know what that means. 2 represents Scott Rothstein now. I don't know which it 3 Q. Have you ever heard of the Centurion 3 was, but it was one of the two. 4 Credit Fund or the Platinum Management Fund? 4 Q. Okay. Were you ever present at a meeting 5 A. No. 5 where someone who you didn't know was present when 6 Q. Alan Sakowitz? 6 the Epstein case was discussed? 7 A. No. Wait. Alan Sakowitz. I have heard that 7 A. No. 8 name recently. I don't know why. I believe I actually 8 Q. Were you ever asked to get on a phone call 9 heard that name in a response. Never mind. In some 9 where the Epstein cases were discussed that you 10 nonresponsive answer that your client gave, I heard that 10 didn't, that you couldn't confirm who, you may have 11. name. 11 someone who may have said this is Joe Smith on the 12 MR. SCAROLA: Keep going. 12 other line, but where you discussed the Epstein case 13 BY MR. CRITTON: 13 over the phone with another lawyer from your firm? 14 Q. Mr. Edwards, with regard to your phone, 14 A. I don't understand that question. 15 did you have a direct line at RRA? 15 Q. Did you ever make a phone call or did you 16 A. Yes. 16 ever receive a phone call where you discussed the 17 Q. What was that phone number? 17 Epstein case with another lawyer in your firm; that 18 A. I don't remember. 18 is, that person — 19 Q. And is your cellphone today the same as it 19 A. Yes. 20 was back then? 20 Q. -- outside of the office? 21 A. Yes. 21 A. What? 22 Q. And what's that number, please? 22 Q. Okay. Obviously you would get calls 23 MR. SCAROLA: r? 23 within — 24 THE WITNESS: 24 A. Even you. 25 25 Q. -- the confines of your office. Right. I Page 273 Page 275 1 BY MR. CRITTON: 1 understand that. 2 Q. Did You ever have a firm eellphone or just 2 A. You fall in that category. lam having a hard 3 your own personal cellphone? 3 time. 4 A. No. Just my own personal cellphone. 4 Q. The question is did you ever have, were 5 Q. During the time that you were at the firm, 5 you ever conferenced in on a call that was supposed 6 were you ever involved in making any type of a 6 to be among RRA lawyers regarding an Epstein case? 7 presentation to anyone regarding the Epstein cases? 7 A. No. 8 A. Including other lawyers within the firm? 8 Q. Did anyone ever request that you prepare a 9 Q. Let me rephrase it I am going to 9 summary of any of_your Epstein cases that you in 10 rephrase. You already told us that you have talked 10 turn sent by either I -mail or memo to anyone else? 11 about the Epstein cases with other lawyers, correct? 11 A. I don't believe so. 12 A. Right. 12 Q. After you joined the RRA finn in April of 13 Q. Were you ever present in a meeting where 13 '09. did there come a point in time when you 14 there was a person whom you did not know wherein the 14 requested that, that you requested the depositions 15 Epstein, where the Epstein cases were discussed? 15 be taken out of state of a number of witness? Well, 16 A. No. 16 let me ask you this question. 17 Q. At the, ()when you met with Mr. Rothstein 17 MR. CRITTON: Let me, let make it easy. 18 in his office when Mr. Adler or whoever asked you to 18 Let me show what I will mark as Exhibit 3. 19 come up that one time and there was Adler, Rothstein 19 (Plaintiffs Exhibit No. 3 was marked for 20 and yourself; you said there was an individual on 20 identification.) 21 the phone? 21 BY MR. CRITTON: 22 A. Right. It was another lawyer with the firm 22 Q. Before I get to that, Mr. Edwards, were 23 Q. And how do you know it was another lawyer 23 you aware of any cases that Mr. Rothstein himself 24 with the firm? 24 settled for over $5 million while you were employed 25 A. It was either Marc Nurik or Mark Fistos, Mark 25 at the firm? 32 (Pages 272 to 275) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Cynthia hooking Electronically signed by cyntha hopkins Electronically signed by synth's hooking 2d3941264712-41704d82-0511f116c2ea EFTA00611269 Page 276 Page 278 1 A. 1 was never aware of any cases that Rothstein 1 Q. Do you recall sending or directing that 2 even handled much less settled. 2 this facsimile be sent. Or let me strike that. Who 3 Q. Were you aware of whether, did anyone ever 3 was your secretary at that time? Who is, well, WE 4 tell you whether Mr. Rothstein even did legal work 4 is you. Who is the MGL? 5 at the firm or whether he was just a rainmaker? 5 A. Who is the MGL? Let's see. 6 A. I — no, no one ever told me one way or the 6 Q. On Page 2. There are your initials, 7 other. 7 Brantley J. Edwards, BJE, and then MGL. Do you 8 Q. Would it be a correct statement that you 8 recognize that? 9 never saw him perform any legal work during the time 9 A. No. I mean, as you are very aware problems 10 you were at the fum? 10 with secretaries during that period of time, I, I had 13. A. That's a correct statement. 11 more than my share and that could have been a time 12 Q. Would it be a correct statement as far as 12 period where I did not have a legal assistant at all. 3.3 you knew he was kind of a gadfly going to his 13 And I do not recognize the initials MGL to identify 14 various business ventures and then he would hole 14 anybody that i know. 15 himself up in the office. 15 Q. With regard to the individuals who were 16 A. He was the guy on the billboards and at the 16 listed in Exhibit 3, specifically Donald Trump, 17 Triple A arena and everything else marketing the firm 17 Leslie Wexner, Bill Clinton, with those individuals, 18 and bringing business in, and that's at least what I 18 you sent out this facsimile or at least your office 19 believe he did. If it's true or not, I don't !mow to 19 sent out the fax, Exhibit 3, requesting dates for 20 this day. 20 these individuals to be deposed, correct? 21 Q With regard to Exhibit 3, do you recognize 21 A. Yes. 22 this mail? 22 Q. All right. Prior to your joining RRA you 23 A. I, I don't recognize the 'mail. 23 had never requested either that the deposition of 24 Q. Do you recognize, and I will represent to 24 Mr. Trump be taken, Mr. Wexner, nor Bill Clinton, 25 you that I received the limit It was sent to me 25 correct? Page 277 Page 279 3. as well athough I am not shown as a recipient, I 1 A. I never requested a deposition to be taken 2 received Frail. 2 including any deposition of those three individuals. 3 THE WITNESS: Are you talking about the 3 Q. I understand but all tight. 4 fax? 4 A. The answer to your question is, yes. 5 MR. CRITTON: I am sorry, the fax 5 Q. All right Thank you. Paula Heil, do you 6 MR. SCAROLA: Exhibit, Exhibit 3. 6 know who that person is? 7 MR. CRI1TON: Exhibit 3. Let me start 7 A. Do I know who it is? I know that it's 8 again. Exhibit 3 is a fax. 8 somebody who was involved with Bear Sterns at some point 9 THE WITNESS: Correct 9 in time. 10 Iva. CRITTON: Dated July 22nd, 2009. 10 Q. You also requested dates, and in fact 11 THE WITNESS. I recognize that. 11 served a subpoena on Alan Dershowitz, the Harvard 12 BY MR. CRiTTON: 12 law professor, correct? 13 Q. And do you recognize on Page 2, it says 13 A. Correct. 14 very truly yours, Rothstein, Rosenfeld; Alder and 14 Q. And Mr. Dershowitz you were aware was one 15 then there is a, what appears to be a signature and 15 of Mr. Epstein's criminal defense lawyers, correct? 16 under that it says Bradley J. Edwards, Esquire, 16 A. At some point in time, I knew that in the past 17 partner fort (sic) the firm. Do you see that? 17 he had been an attorney of Mr. Epstein. 18 A. Yes, I see that. 18 Q. Well, you had, you had certain records 19 Q. Do you recognize the signature? 19 from the State Attorneys Office, didn't you, or 20 A. No. 20 from the police report? 23. Q. Is that how you sign your name? 21 A. And that's what I'm saying, yes, involved in 22 A. No. 22 the civil cases with us, no, l didn't ;mow that he had 23 Q. Do you know whose signature that is or 23 involvement. But, yes, I did know he was a former -- 24 purports to be? 24 Q. I'm sorry, go ahead - 25 A. I have absolutely no idea. 25 A. I did know that he was a former attorney of ....••••aMi•I•44 33 (Pages 276 to 279) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins I= ) Electronically signed by cynthia hopkins ) Electronically signed by Cynthia hopkins ( ) 2d39412d-87124170-9d82.0511078c2ea EFTA00611270 Page 280 Page 282 , 1 Jeff Epstein. 1 Tommy Mottola was listed. Do you know who 2 Q. Well, you also understood Mr. Epstein has 2 Mr. Mottola is? 3 had ongoing criminal law issues even during the time 3 A. Generally I think I know who that is. 4 of the civil case, correct? 4 Q. Who did you understand Mr. Mottola was? 5 A. No. 5 A. Something to do with the music industry. 6 Q. Sure. Well, you were aware that 6 Q. All right. And the name David Copperfield 7 Mr. Epstein was operating under the nonprosecution 7 was also referenced as a potential witness in the 8 agreement, that he was bound by the, a 8 case, correct? 9 nonprosecution agreement, coned? 9 A. That is correct. 10 A. I'm aware of the existence of a nonprosecution 10 Q. All right. And did you -- and you, in 11 agreement. 11 fact, attempted to coordinate a deposition for 12 Q. Well, and in fact you came into possession 12 Mr. Copperfield; is that correct? 13 of the nonprosecution agreement sometime in 2008 13 MR. SCAROLA: Are you asking about whether 14 because Judge Marra ordered that, ordered the United 14 communications occurred with you -- 15 States Government to turn over to all of the 15 MR. CRITTON: Sure. 16 attorneys and the clients who were listed as alleged 16 MR. SCAROLA: -- regarding such a 17 victims, correct? 17 deposition. 18 A. Yes. 18 BY MR. CRITTON: 19 Q. So, you had possession of the N.P.A. as of 19 Q. Let me rephrase it. With regard to the 20 sometime in the year 2008, correct? 20 lawyers in the case, including myself, you attempted 21 A. Right. 21 to coordinate a time for completing or taking the 22 Q. All right. And so you, and you were aware 22 deposition of Mr. Copperfield, Mr. Mottola, who I 23 that under the nonprosecution agreement Mr. Epstein 23 will represent is the former president of Sony 24 was required to meet certain requirements, that 24 Records, former president Bill Clinton, Alan 25 Mr. Epstein had a requirement to Inset certain 25 Dershowitz, Donald Trump, and Leslie Wexner, true? Page 281 Page 283 1 standards or certain provisions of the agreement 1 A. False. 2 otherwise the U.S.A. could potentially declare there 2 Q. Which of those, as to which one of those 3 was a breach of the agreement, true? 3 is that false? 4 A. I suppose. 4 A. Tommy Mottola. 5 Q. Well, you're a former prosecutors too, so 5 Q. So, but you did attempt to coordinate the 6 you knew what a nonprosecution agreement was, true? 6 depositions of Donald Trump, Mr. Dershowitz former 7 A. No, I had never seen a nonprosecution 7 president Clinton, David Copperfield, and Leslie 8 agreement in my life before this one. 8 Wexner, correct? 9 Q. When you got the nonprosecution agreement, 9 A. I believe so. 10 you reviewed it? 10 Q. And with regard to Mr., well, let me 11 A. Yes, l did. 11 strike that. In setting these depositions; that is, 12 Q. So, you were familiar with? 12 in requesting these deposition be taken sometime in 13 A. Right. 13 June and July of 2009 or requesting dates for them, 14 Q. And you understood from at least looking 14 did you have discussions with other attorneys in 15 at the police report that you had access to, that 15 your firm as to the benefits that would exist in 16 Mr. Dershowitz had represented Mr. Epstein with 16 your case, your three cases against Mr. Epstein by 17 regard to negotiating his plea that ultimately was 17 taking these individuals' depositions? 18 reached in negotiations with the federal government, 18 MR. SCAROLA: Objection. Same as grounds 19 true? 19 previously stated; instruct you not to answer. 20 A. I ;mew he played a role. 20 BY MR CRITION: 21 Q. Now, with few(' to Mr., with regard to 21 Q. Mr. Edwards, were you involved in the 22 the depositions of -- well, let me strike that. 22 discussions regarding the deposing of any of the 23 Also listed both on your, on Jane Doe's and 's 23 people of these individuals, Mr. Trump; that is, in 24 and .'s updated interrogatory answers which were 24 discussions with any other lawyers in your firm 25 provided during the year 2009, an individual named 25 including Scott Rothstein? •••••••••••••••••••• 34 (Pages 280 to 283) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkIns 2d39412d-87f2-4170-gd82-0511M6c2ea EFTA00611271 Page 284 Page 286 1 MR. SCAROLA: Same objection, same 1 BY MR. CRITTON: 2 instruction. 2 Q. Pint, my question in the broad sense. 3 BY MR. CRITTON: 3 Were you involved in the decision to pursue flight 4 Q. Same question with regard to 4 data associated with any planes Purportedly own by 5 Mr. Dershowitz, former president Clinton, Tommy 5 Mr. Epstein? 6 Mottola, David Copperfield, and Leslie Wexner. 6 MR. SCAROLA: My objection - 7 THE WITNESS: No. 7 MR. CRITTON: In tens of the discussions B MR. SCAROLA: Same objection, same 8 within your firm. 9 instruction? 9 MR. SCAROLA: My objection and my 10 THE WITNESS: And with respect to Tonally 10 insbuction stands. 11 Mottola, I, that was not my firm that was a 11 BY MR. CRITTON: 12 separate law firm that intended to take his 12 Q. Did you have discussions within your firm 13 deposition. 13 with regard to taking the depositions of celebrities 14 BY MR. CRITTON: 14 or famous people who were on, purportedly on 15 Q. Who was it that you understood was taking 15 Mr. Epstein's planes so that they could be deposed 16 Mr. Mottola's deposition? 16 such that that would be an inducement to Mr. Epstein 17 A. Searcy, Denney. 17 to settle his lawsuit? 18 Q. Did you ever discuss with Mr. Rothstein or 18 MR. SCAROLA: Same objection, same 19 anyone on his behalf the value of taking the 19 instruction. 20 depositions of Trump, Dershowitz, former president 20 BY MR. CRITTON: 21 Clinton, David Copperfield, and Leslie Wexner as an 21 Q. Isn't it true, Mr. Edwards, that in taking 22 inducement to get Mr. Epstein to settle his 22 the deposition or in attempting to take the 23 lawsuits? 23 deposition of Donald Trump, you had no information 24 MR. SCAROLA: You have already inquired of 24 that Mr. Trump had any knowledge of any female 25 Mr. Edwards about the communications that he 25 having; that is, underage female ever having been on Page 285 Page 287 1 had with Mr. Epstein. He has responded to 1 Mr. Epstein's plane and been, and having been 2 those questions previously. So, any further 2 assaulted by him? 3 questioning along those lines is entirely 3 MR. SCAROLA: What Mr. Edwards knew or 4 repetitious 4 didn't know in connection with this prosecution 5 BY MR CRITTON: 5 of pending claims is protected by a privilege. 6 Q. Can you answer that question, sir? Would 6 I instruct him not to answer. 7 you like it read back? 7 BY MR. CRITTON: 8 MR. SCAROLA: Beyond what he has already 8 Q. Mr. Edwards, did you know Officer Recarey? 9 responded, we would object on the basis of 9 I mean, I know you have meet him now because you 10 work-product and attorney-client privilege and 10 have seen him at his deposition, correct? 11 1 instruct you not to answer. 11 A. Correct. 12 THE WITNESS: Okay. 12 Q. Did you ever meet with, did you ever meet 13 BY MR. CRITTON: 13 Mr. or Officer Recarey at any time prior to his 14 Q. Were you involved in any of the decision 14 deposition in person? 15 to pursue obtaining flight data from Mr. Epstein? 15 A. No. 16 Well, let me strike that. Were you involved in the 16 Q. Have you ever spoken with Officer Recarey 17 decision to pursue flight data associated with any 17 at any time prior to his deposition, by phone or 18 planes that were purportedly owned by Mr. Epstein? 18 otherwise? 19 MR. SCAROLA: I will allow Mr. Edwards to 19 A. Yes. 20 acknowledge whether he did or did not 20 Q. Okay. And what context were you speaking 21 communicate about such matters with opposing 21 with Officer Recarey? 22 counsel. But beyond that I would assert 22 THE WITNESS: Answer? 23 attomey.client and work-product privileges and 23 BY MR. CRITTON: 24 instruct you not to answer. 24 Q. Well, first of all, let me withdraw that 25 25 question. Excuse me. On how many occasions have 35 (Pages 284 to 287) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins 2d30412d-6712-41704d82•0511ff713c2ea EFTA00611272 Page 288 Page 290 1 you spoken with Officer Recarey prior to his 1 proceeding relating to any matter during the year 2 deposition? 2 2008 or 2009? 3 A. Onetime. 3 MR. SCAROLA: You may answer. 4 Q. And when was that? 4 THE WITNESS: No. 5 A. 2008. 5 BY MR. CRITTON: 4 6 Q. What was the purpose of the — let me 6 Q. Did Jane Doe ever come -- let me strike 7 strike that Did you initiate the conversation or 7 that. Did Jane Doe ever come to your firm, the RRA 8 did he? 8 firm for any reason? 9 THE WITNESS: Answer? 9 A. Yes. 10 MR. SCAROLA: You can answer that. 10 Q. On how many occasions did she come to your 11 THE WITNESS: I did. 11 fimt, to RRA? 12 BY MR. CRITTON: 12 A. I believe one time. 13 Q. Okay. What was the purpose of your 13 Q. In addition to, I assume you met with her 14 conversation? 14 on that occasion? 15 MR. SCAROLA: To the extent that the 15 A. Right. 16 purpose of your conversation was unrelated to 16 Q. Was anyone else present? 17 any pending legal matter, including in 17 A. I don'Stelieve so. 18 particular the claims against Mr. Epstein, you 18 Q. Did M. ever come to your firm at RRA? 19 may answer. To the extent that it had anything 19 A. No.. 20 at all to do with Mr. Epstein, you should not 20 Q. Did M. ever come to your firm at RRA? 23. respond on the basis of privilege. 23. A. Yes. 22 THE WITNESS: Privilege. 22 Q. On how many occasions? 23 BY MIt CRITTON: 23 A. Onetime. 24 Q. Did you ever speak with Chief Reiter at 24 Q. Did anyone meet with her other than 25 any time -- well, let me strike that. You were not 25 yourself? Page 289 Page 291 1 at his deposition, were you? 1 A. Yes. 2 A. No. 2 Q. Who was present? 3 Q. Okay. Have you ever spoken with Chief 3 A. Bill Berger. 4 Reiter at any time for any purpose as it relates to 4 Q. Did any RRA lawyer ever have an occasion 5 Mr. Epstein? 5 to meet with Jane Doe at, at a location other than 6 THE WITNESS: Answer? 6 your office; that is, did you ever request that some 7 MR. SCAROLA: Only to the extent that 7 other lawyer meet with her, Jane Doe, for a specific 8 well, you asked specifically whether the 8 reason? Don't want to know the reason just whether 9 conversation related to Epstein? 9 another lawyer met with her. 10 THE WITNESS: Did the conversation occur 10 A. No. 11 is the question. 11 Q. Did any other RRA lawyer meet with M. 12 MR. SCAROLA: Relating to Epstein. Read 12 separate, at any time? 13 the question back if you would, please. 13 A. No. 14 MR. CRITTON: Let me rephrase it. 14 Q. Did any other lawyer ever met with M. 15 MR. SCAROLA: Okay. 15 separate and apart from the one meeting that you had 16 BY MIt CRITTON: 16 with Bill Berger and yourself in 2000 — I'm sorry 17 Q. With regard to Chief Reiter, have you ever 17 did — 18 spoken with Chief Reiter or now former Chief Reiter 18 A. We're talking always about the time period at 19 from the Palm Beach Police Department for any 19 RRA I understand that. 20 reason? 20 Q. Co= Did any lawyer from RRA ever 21 MR. SCAROLA: You can answer the "for any 21 meet with In. separate from the single occasion 22 reason" part. 22 that you and Mr. Berger met with her at RRA's 23 THE WITNESS: No. 23 office? 24 BY MR. CRITTON: 24 A. No. 25 M Q. Have ou ever testified in a rand ury 25 Q. Did,, did ou ever veart i., 36 (Pages 288 to 291) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by Cynthia hopkins 2d39412d47t24170-9012-0511ffnic2ea EFTA00611273 Page 292 Page 294 1 2 communication, and by that I mean either a conversation or any writing with Mr. Scott Rothstein 1 2 not, just did you just not have an understanding? A. I had an understanding. 4 3 about the value of the J — of the Jeffrey Epstein 3 Q. Okay. What was your understanding and 4 cases? 4 what was it based on? 5 MR. SCAROLA: You can answer yes or no. 5 A. Based on numerous conversations with Russell 6 THE WITNESS: No. 6 Adler that even he had a very difficult time gaining 7 BY MR. CRITTON: 7 access to Scott Rothstein for any reason. 8 Q. Did you ever have a conversation or 8 Q. Did Mr. Adler, did you ever ask Mr. Adler cormamication where Scott Rothstein was present and 9 to pass on information to Mr. Rothstein about the 10 the value of the Epstein cases was discussed? 10 Epstein cases? 11 A. No. 11 A. No. 12 Q. Did you ever have a conversation with 12 Q. Other than Mr. Jenne who would make, I 13 other attorneys at RRA regarding the value of the J, 13 think you indicated earlier, on eight to ten 14 of the Epstein cases that you had? 14 occasions ask you about the Rothstein, I am sorry, 15 A. Yes. 15 asked you about the Epstein cases, did any other 16 Q. Okay. With whom? 16 person inquire on a somewhat regular basis or even 17 A. Russell Adler, Bill Berger. I believe that's 17 an irregular basis as to the status of the Epstein 18 it. 18 cases? 19 Q. From, from your observations when you were 19 A. Yes. 20 at RRA, did it appear that certain individuals had 20 Q. Who? 21 access to Mr. Rothstein; that is, other lawyers in 21 MR. SCAROLA: Again I assume you're 22 the firm had access to him? 22 talking about persons within the firm? 23 A. It appeared to me like nobody had access to 23 M t CRITTON: Correct I'm back to only 24 hint 24 within RRA You understood that, didn't you, 25 Q. In the particular instance that you got 25 Mr. Edwards? Page 293 Page 295 1 called up to his office, Mr. Adler was present along THE WITNESS: No, i didn't. i thought you 2 with Mr. Rothstein and either Mr. Nurik or somebody 2 meant anybody. 3 else who was on the phone, comet? We already 3 BY MR. CRITTON: 4 established that? 4 Q. Okay. Then i am back within RRA because i 5 A. Correct had asked you about Mr. Jenne. 6 Q. From your observations and or your 6 A. Got it. 7 conversations with Mr. Adler, did you get the 7 Q. So, i wouldn't go out I want to stay 8 impression that Mr. Adler could have or would have 8 within the firm. Did anyone ask you or inquire of 9 access to Mr. Rothstein? 9 you about the status of the RRA cases; it was either 10 MR. SCAROLA: By that I assume you mean 10 a lawyer or an investigator within the firm? 11 unfettered access? 11 A. Maybe but, but none that I can really picture 12 MR. CRITTON: No, just easy access. 12 as somebody who would do it regularly. If I was talking 13 Unfettered suggests someone can walk in and out 13 in some lawyer's office about any case or any issue, 14 of the office and you already told me it was a 14 there were times where I remember generally how is this 15 compound. Let me reask my question. 15 specific case going or that specific case, and at times 16 BY MR. CRITTON: 16 it was Jeffrey Epstein case. 17 Q. From what Mr. Adler told you, if you had a 17 Q. With regard to Mr. Jenne, what did you 18 conversation with Mr. Adler about a particular, 18 understand with regard to what his position was in 19 whether it was an Epstein case or another case, was 19 the firm? 20 it your understanding that Mr. Adler had regular, 20 A. Something to do with the investigative 21 some form of regular communication with 21 22 Mr. Rothstein? 22 Q. Okay. What did you understand about 23 A. No. 23 Mr. Jenne's background. Let me strike that. Were 24 Q. Okay. Did you understand that he didn't 24 you a State Attorney's when Mr. Jenne was a Broward 25 have any communication with Mr. Rothstein or did you 25 County Sheriff? 37 (Pages 292 to 295) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins ( Electronically signed by cynthia hopkins ( Electronically signed by cynthia hopkins ( 2d39412d-67f2-4170-9d82-0511ff76c2ea EFTA00611274 Page 296 Page 298 1 A. I believe so. 1 A. No. 2 Q. Were you still a State Attorney when 2 Q. Did you ever find it strange that 3 Mr. Jenne was indicted and then eventually ended up 3 Mr. Jenne was asking you questions about the Epstein 4 in jail? 4 cases? s A. No. 5 A. No. 6 Q. Were you in private practice at that 6 Q. Did you ever ask Russell Adler as to why 7 point? 7 Mr. Jenne would be asking you questions about the 8 A. Correct 8 Epstein cases? 9 Q. But you lived then in Broward County, so 9 A. No. 10 you followed the developments of Mr. Jenne's 10 Q. And I think you told me earlier, but I may 11 downfall in becoming a convicted felon? 11 be wrong so i want to clear this up. i don't want 12 A. I was aware. /2 to be repetitious here. Did Mr. -- 13 Q. All right. Was Mr. knne, would it be a 13 MR. SCAROLA: When did you change your 14 correct statement that Mr. Jenne and Mr. Fisten and 14 nand about that? 15 Mr. Roberts were all at the RRA firm when you 15 MIL CRITTON: Earlier. 16 started in April of '09? 16 BY Iva CRITTON: 17 A. I don't believe so. 17 Q. Did Mr. Jenne, did you ever direct 18 Q. Which one was there when you started? 18 Mr. Jenne to do any investigation on the Epstein 19 When hay "there." was already employed by RRA when 19 cases? 20 you started? 20 MR. SCAROLA: Objection, work-product. 21 A. lam not sure if any of the three were there 21 BY MR. CRTITON: 22 but perhaps all of them were there. 22 Q. Did Mr. Jenne ever do any investigation on 23 Q. All you know is at some point you came to 23 the Epstein files? 24 be involved with them as investigators? 24 MR. SCAROLA: Objection, work-product. 25 A. Correct. 25 Page 297 Page 299 1 Q. All right. With regent to Mr. Jenne, was 1 BY MR. GIRTON: 2 his office on the same floor as yours? 2 Q. Did Mr., were you aware that Mr. Jenne was 3 A. No. 3 attempting to shop the Epstein cases to investors 4 Q. Where, was his office in any way near 4 during the time you were at the RRA firm? 5 Mr. Rothstein's? 5 MR. SCAROLA: Objection, assumes facts. 6 MR. SCAROLA: What does any way near Mr. 6 THE WITNESS: No. 7 Rothstein's mean? 7 MR. SCAROLA: That% allright 8 MR. CRITTON: Same floor. 8 BY MR. CRITTON: 9 THE WITNESS: No. 9 Q. Do you know Bill Scherer, Attorney Sill 10 BY MR. CRITTON: 10 Scherer? 11 Q. Did it appear to you that -- well, let me 11 A. No, I know of him. 12 strike that. You said that Mr. Jenne had something 12 Q. You are aware that he has a pending 13 to do with investigation, correct? 13 lawsuit against various individuals includingID 14 A. Correct 14 Bank and other Defendants on behalf of various 15 Q. Okay. Did he ever describe for you what 15 investors; is that a fair statement? 16 he did for the firm? 16 A. ;remember when that first came out. I have 17 A. No. 17 not followed it. I don't know if it's active, if it's 18 Q. And i third( you said, did you say what his 18 still pending, or what the status is at all. But i do 19 title was? 19 remember a lawsuit being filed on behalfof sorrrbody 20 A. I didn't know his title. I don't know what 20 against Scott Rothstein and others. 21 his title is now. 21 Q. All right. And do you remember, it's 22 Q. Did you ever ask Mr. Jenne why he was 22 within Paragraph 20 of the complaint it's a — 23 asking you questions about the Epstein case or 23 A. Of? 24 engaging you in a dialogue regarding the Epstein 24 Q. Of, rm sorry, ofExhibit No. 2. And it 25 cases? 25 states Fort Lauderdale attorney William Scherer 38 (Pages 296 to 299) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins 2d39412d-6712-4170-9d82-0511ff76c2ea EFTA00611275 Page 300 Page 302 1 represents multiple Rothstein related investors. He 1 A. No. 2 indicated in an article that RRA, slash, Rothstein 2 Q. Okay. Were you aware that Scott Rothstein 3 had used the Epstein ploy as a showpiece, as a 3 had represented to other individuals that be had 4 showpiece, as bait. That's, and the quote is, 4 multiple other cases, multiple other Jane Doe's 5 Epstein ploy, as a showpiece, as bait. That's the 5 which he was trying to market to investors? 6 way he raised all the money. 6 A. No. 7 He would use cases as bait for luring 7 Q. Were you aware that -- do you have any 8 investors into fictional cases. All the cases he 8 knowledge that Ken -- let me strike that. 9 allegedly structured were fictional. I don't 9 Were you aware that Ken Jenne was 10 believe there was a real one there. 10 attempting to market or shop non-existent Epstein 13. Okay. If I asked you to assume that that 11 cases to investors? 12 quote is accurate from Mr. Scherer, would it be a 12 A. I wasn't aware then nor am I aware of that 13 correct, would it be a correct statement -- well, 13 now, so, no. 14 let me strike that. 14 Q. Do you have any knowledge that Mr. Fisten 15 Were you aware that Rothstein and other 15 and/or Mr. Jenne would cart boxes of Epstein related 16 individuals were using the Epstein ploy, that is, 16 materials; that is, existing Epstein related 17 the Epstein cases in order to, as bait in order to 17 materials relating to Jane Doe and show those to 18 raise money for, for the firm and Mr. Rothstein? 18 other investors? 19 MR. SCAROLA: I am going to object to the 19 A. Do I have knowledge that somebody caned? 20 form of the question, but you can certainly 20 Q. Yeah, are you aware that Mr. Fisten or do 21 answer it. 21 you have any knowledge that Mr. Fisten brought boxes 22 THE WITNESS: Okay. I am going to answer 22 of Epstein-related materials to show perspective 23 it to the extent that I understand it. No, I 23 investors? 24 was not aware that the Epstein cases were being 24 A No. 25 used as a showpiece, as bait. But you are also 25 MR. SCAROLA: Objection, assumes, Assumes Page 301 Page 303 1 asked me to assume that the statement that you 1 facts not in evidence, no proper predicate. 2 have injected as Paragraph 20 of the complaint 2 BY MR. CRITTON: 3 is true and it begins with, or ends with I 3 Q. Do you have any knowledge that Mr. Jenne 4 don't believe there was a real one in there, 4 either directly or directed someone else to bring 5 talks, speaking as to all the cases. And you 5 boxes of Epstein-related materials to show 6 know and I know that that statement is 6 investors? 7 absolutely false in that you know each and 7 MR. SCAROLA: Objection, assumes facts not 8 every one of the claims that have been asserted 8 in evidence, no proper predicate. 9 against Mr. Epstein related to his molestation 9 THE WITNESS: No. 10 of children, they are all Ins including the 3.0 BY MR. CR1T'TON: 11 three that I have against Mr. Epstein. 11 Q. If, based on your earlier testimony, if 12 So, if you're asking me to assume that 12 there were boxes of Epstein materials on existing 13 this is it true, no, I did not know that they 13 cases, Jane Doe, . and M., again if I 14 were being used for anything. 14 understood your testimony, that information would 15 BY MR. CRITTON: 15 have been available someplace in the firm and 16 Q. Okay. Well, as to whether Mr. Scherer was 16 someone who had access to the room could have 17 aware as to whether there were three pending Cases 17 grabbed those files or taken those files and done 18 or he assumed that they were all just made-up cases, 18 whatever they wanted to them, with them, and then 19 neither you nor I know what he was thinking, 19 brought them back for storage, correct, and you 20 correct? 20 wouldn't know? 21 A. Yeah, I don't know. 21 A. As is the case with every case in every law 22 Q. All right. With regard to the Epstein 22 firm in America, yes. 23 ploy, with regard to Epstein cases, were you aware 23 Q. With regard to the three cases that you 24 that Scott Rothstein was trying to market Epstein 24 have now, does any law firm other than your current 25 cases; that is, three, three cases that existed? 25 firm, which is Fanner, Jaffe? 39 (Pages 300 to 303) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins (60145141 ) 2d39412d4712-4170-9482-0511076c2ea EFTA00611276 Page 3 0 4 Page 306 1 A. Weissing. 3. the information that is held by the FBI which would 2 Q. Or ERA, Mr. Howell, or Mr. Cassell have 2 include the pamphlet and the yellow, the pamphlet 3 any interest in those cases? 3 and the yellow pages, true? 4 A. No. 4 A. I have. Adam Horowitz has, and I may or may 5 Q. At any time — let me strike that. You 5 not have piggybacked his motion. But as sitting here 6 are aware that Mr. Alfredo Garcia has pled guilty to 6 right now, I, I don't remember drafting that motion. 7 an obstruction of justice charge based on the news? 7 Q. Are you sure he hasn't piggybacked your 8 A. I don't know Alfredo Garcia at all. 8 motion? 9 Q. Sorry about that The head of Alfredo 9 A fm not sure. If you show ne my motion, l can 10 Garcia. With regard Mr. Rodriguez, Alfredo 10 tell you whether I drafted it or not. 11. Rodriguez, are you aware through news reports that 11 Q. Have you — 12 he pled guilty to obstruction of justice? 12 A. That, that was certainly an idea. 13 A. Yes. 13 Q. Have, have you also you have also 14 Q. At any time have you been given access to 14 served a motion to obtain FBI files that relate to 15 the pamphlet book and/or any of the yellow pages 15 Mr. Epstein; is that correct? 16 that have been referenced in the criminal 16 A. Correct. 17 indictment? 17 Q. Olcay. Have you spuktn as a result of the 18 MR. SCAROLA: I am going to instruct you 18 motion that you filed, has the government, have you 19 not answer that question on the basis of 19 spoken with the United States Attorney's Office or 20 attorney-client and work-product privilege. 20 representatives for the FBI with regard to the 21 BY Mit CRITTON: 21 motion which you filed? 22 Q. Has the, have you been, have you had any 22 MR. SCAROLA: Objection, privilege and 23 contact with the criminal defense lawyer for 23 instruct you not to answer. 24 Mr. Rodriguez? 24 BY MR. CRITTON: 25 MR. SCAROLA: You can answer yes or no. 25 Q. Have you received any type of response Page 305 Page 307 1 THE WITNESS: No. 1 from the United States Attorney's Office or the FBI 2 BY MR. CRITTON: 2 with regard to the motion that you have filed? 3 Q. Have you had any communication, not a 3 MR. SCAROLA: You may answer that only 4 conversation but any oranniunication with the criminal 4 with respect to those matters that are matters 5 defense lawyer about obtaining a copy of the 5 of public record; that is, if a response has 6 pamphlet and/or the pamphlet book or the yellow 6 been filed with the court or provided to you in 7 pages that are referenced in the criminal indictment 7 the form of a pleading, you may respond. 8 that were at one time in the possession of Mr. 8 THE WITNESS: I cannot respond to that 9 Rodriguez and that he apparently was trying to sell 9 question. 10 to the cooperating witness? 10 MR. CRITTON: All right. We're going to 13. MR. SCAROLA: I am going to instruct you 11 quit at 5. I don't want to go on. 12 not to answer any question about anything that 12 MR. SCAROLA: You already, you already 13 you may have done in connection with the 13 missed that. 14 fulfillment of your responsibilities as counsel 14 MR. CRITTON: All right. Well, let's, 15 for the Plaintiffs in the three pending cases. 15 Ill adjourn the deposition today, and I will 16 BY Mit CRITTON: 16 arrange with you fora time to finish. 17 Q. Again, of course you're going to continue 17 MR. SCAROLA: Well, so that the record is 18 to follow Mr. Scarola's direction? 18 clear, it is our position that you have had 19 A. On what I have done or what I have not done, 19 more than adequate time to conduct an 20 all of that is work-product. 20 appropriate examination of Mr. Edwards, and we 21 Q. Well, you have filed a motion to obtain a 21 will resist any further effort to depose him. 22 copy of the pamphlet book and the yellow pages of 22 MR. CRITTON: I understand your position. 23 Mr. Rodriguez, correct? I am sorry, either a 23 Disagree with it but understand it. 24 motion — well, strike that. You have filed a 24 MR. SCAROLA: Thank you. 25 motion in federal court to obtain a co • of the, of 25 THE VIDEOGRAPHER: This concludes today's 40 (Pages 304 to 307) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601451476.2934) Electronically signed by cynthia hopkins (601451476.2934) Electronically signed by cynthia hopkins (6014514764934) 2d39412c1-6712-4170-9d82-0511f176c2oa EFTA00611277 Page 308 Page 310 I videotape deposition of Scott Rothstein. The 1 CERTIFICATE OF OATH 2 time is -- 2 THE STATE OF FLORIDA 3 THE WITNESS: Whoa whoa. 3 COUNTY OF PALM BEACH 4 4 THE COURT REPORTER: Yes. Bradley 5 5 Edwards. 6 1, the undersigned authority, certify that 6 THE WITNESS: Please don't lump me in with 7 BRADLEY1. EDWARDS, ESQUIRE personally appeared 7 that guy, num B before me and was duly sworn on the 23rd day of 8 MR. SCAROLA: This concludes the 9 March, 2010. 9 deposition of Mr. Bradley Edwards. 10 10 THE VIDEOGRAPHER: Oh, Pm sorry. This 11 Dated this 5Ih day of April, 2010. 11 concludes the deposition ofMr. Bradley 12 13 12 Edwards. The time is 5:07 p.m. 14 13 (A discussion was held off the record.) 15 14 THE COURT REPORTER: Did you want to order ' 5: c As 15 this? 16 16 MR. CRITTON: Ask me tomorrow. Cynthia Hopkins, RPR, FPR I? MR. SCAROLA: I will take a copy ofit. 17 Notary Public - State ofFlorida 18 Let's stay on the record. We don't need to be My Commission Expires: February 25,2011 19 on the video record but I want to make the 18 My Commission No: DD 603788 20 statement that we would consider it entirely 19 20 21 inappropriate for any portion of this 21 22 deposition to be used for any reason whatsoever 22 23 that is not directly connected with the 23 24 prosecution of the pending claim against 24 25 Mr. Edwards or the defense of the 25 Page 309 Page 311 1. counterclaims. Thank you. I CERTIFICATE 2 THE STATEOFFLORIDA 2 MR. CRITTON: Bye. 3 COUNTY OF PALM BEACH 3 MR. SCAROLA: Bye. 4 S I, Cynthia Hopkins, Registered Prokssional 4 (Witness excused.) Reporter, Florida Professional Reporterand Notary 5 (Deposition was concluded.) 6 Public in and for the State of Florida at large. do hereby cenily that I was authorized to and did 6 7 report said deposition in stenotype, and that the 7 foregoing pages are a true and cottons transcription 8 a ofmy shorthand notes of said deposition. 9 I further certify that said deposition was 9 taken at the time and place hereinahme set forth 10 10 and that the taking of said deposition was commenced and completed as hereinabove set out. 11 11 12 1funhcr certify Statism not attorney or 12 counsel of any of the panics, nor am l a relative 13 ix employee of any attorney or counsel of party 14 13 connected with the action, nor am I financially interested in the action. 15 10 16 The foregoing ceniflealion of this franc* 17 rs does na apply to any reproduction of the same by any means unless under the (hied C091901 andlor 18 16 direction of the certifying reporter. 19 17 Dated this% day orApril, 20'0. re 20 19 21 20 22 21 Ice J a, , 23 22 23 24 29 25 25 41 (Pages 308 to 311) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins ( ) 2d39412d-67f2-4170-9c182-0511E7622ea EFTA00611278 Page 312 Page 314 DATE Apt11990o10 1 ERRATA SHEET 2 TO BRADLEY J. EDWARDS. ESQUIRE do het Snob. ERuire 2 IN RE: EPSTEIN VS. ROTHSTEIN 1 CR: Cynthia Hopkins, RPR, FM 4 6 NMI RI RR F;rwina Rotatin 3 4 5 DEPOSITION OF: BRADLEY J. EDWARDS, ESQUIRE TAKEN: JOB NO.: March 23, 2010 1333 DO NOT WRITE ON TRANSCRIPT - ENTER CHANGES HE CASE NO, 50 MCMINN:0000UB AQ PAGES UNE SI CHANGE REASON 7 Pleabe et mkt Waco al Sc 23n1 of 6 Maid 2•314 dapcdom ia 7 it' nose. Mimi Una. Wr dd sot 9 wive sjpsuie kis nos reosarpha snip 8 yaw *indica 10 Al Pita/ Cad I% OS NOW* 4.41 W 10 As00441or>441Kwith War Cowed limo not the Colo.* Inurskr• caret* 11 Mitt end oft traracrIpl •41 Wats 12 12 outage. Al yeti read war depsilke. 4419 clews et*main Oal ma viol quake sheaf 13 13 ix Dosed ca the allia sham disposed hoc 14 riartxrdudd dot. DO NOT who ce 15 14 Moab" stlt Noe r:a kn. real IS traBaipl acted any chime* te sure rip 16 15 te4 daft anis sheer ad rya diem saw 9a 17 Please forward the original signed arms sheet to 16 If you 43rrx rod and wan the *mai/km this office so that copies may be distributed to all wahl4 s MEWS* eiae.St Otioll. Vat. haS 18 parties, 17 tsbody teen forsatod Rabe ado* focnty, ray 1:41114 wit the Clerk of Re Can Bye, wish 19 Under penalty of pajury, I declare that I have read 1$ b0.4h. Sag 60•11111‘ beyew ern: kg Oa Wok my deposition and that it is true and correct Sc6=m dais kilo awl mom ii toot 20 subject to any changes in form or substance entered 19 here. 20 21 21 22 DATE: Cydd I4cOm. COIL FPR 23 22 23 I 4:amet, vaMmysismort 24 SIGNATURE OF 24 DEPONENT: 25 BACCW t UP.thWA aroma 25 Page 313 3. CERTIFICATE 2 3 THE STATE OF FLORIDA 4 COUNTY OF PALM BEACH 5 I hereby certify that I have read the foregoing 6 deposition by me given, and that the statements 7 contained herein are true and correct to the best of 8 my knowledge and belief, with the exception of any 9 corrections or notations made on the errata sheet, 10 if one was executed. 11 12 Dated this day of 13 2010. 14 15 16 17 18 1.9 BRADLEY J. EDWARDS, ESQUIRE 20 Job #1333 21 22 23 24 25 42 (Pages 312 to 314 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthla hopkins 2d3,41244.02-4110-00824$11ff76c2cta EFTA00611279