EFTA00798337

1 3 IN THE CIRCUIT COURT OF THE I INDEX FIFTEENTH JUDICIAL CIRCUIT, IN 2 AND FOR PALM BEACH COUNTY, FLORIDA 2 Videotaped Depoeitien ofWILLIAMBERGER Page lb. Case No. 502009CA040800XXXXMB 4 JEFFREY EPSTEIN, 5 Direct Examination by Hr. Scarola 5 Plaintiff/Counter-Defendant, 4 Cross-Lamination by Mr. Lick SS Vs. 7 Redirect Examination by Mr. Scarola 131 SCOTT 0.0TNSTBIN, individually; 0 Rocones-Exaninatien by Mr. Lick 138 BRADLEY EDWARDS, Individually, 9 Further Redirect Examination by Mr. Scarola 160 Defendants/Counter-Plaintiff. 10 Certificate of Oath 170 / 11 Certificate of Reporter 171 12 13 PLAINTIFF'S EXHIBIT INDEX VIDEOTAPED DEPOSITION le OF WILLIAM BERGEA 15 No. Descriptich Page No 16 1 Razosbadt Cctplaint OS 17 2 (Premarked but not mentioned during deposition.) Taken on Behalf of Defendant/Counter-Plaintiff IS 3 Cceplaint in current case 118 19 Friday, February 23rd, 2028 20 9:27 . - 1:32 . 21 DEFENDANTS/COUSTER-PLAINTIFFS' EXHIBIT IM3EX 2255 Glades Road, Suite 218-A 22 (No exhibits were tacked.) Boca Raton, Florida 33431 13 24 25 2 4 1 Examination of the witness taken before 1 THE VIDEOGRAPHER: This is the 23rd day 2 Sonja D. Hall 2 of February 2028. The time is approximately Palm Beach Reporting Service, Inc. 9 1665 Palm Beach Lakes Boulevard, Suite 1001 $ 9:27 West Palm Beach, FL 33401 4 This is the videotaped deposition of 4 1561) 471-2995 5 Berger in the matter of Jeffrey 5 APPEARANCES: 6 For Plaintiff: 4 Epstein versus Scott Rothstein and Bradley 7 LINK 4 ROCKENBACH, . Edwards. 1555 Palm Beach Lakes Boulevard, Suite 301 , This deposition is being hold 2255 0 West Palm Beach, FL 33401 By SCOTT J. LINK, ESQUIRE Glades Road, Suite 218-A, Boca Piton, 9 :0 Florida 23431. 10 For Plaintiff: 11 DARREN K. INDYKE, PLLC Ii My name is Manuel Santiago. I am the 575 Lexington Avenue 12 VICIOD9taptier representing Above a Beyond 12 New York, NY 10022 By DARREM K. INDERE, ESQUIRE 29 Reprographics. IS 24 Will the attorneys please announce 14 For Defendant/Counter-Plaintiff: 15 their appearances for the record? 15 SEARCY, DENNEY, SCAROLA, BARNHART 4 SHIPLEY, . 16 MR. LINK: Sure. Scott Link on behalf 26 2139 Palm Beach Lakes Boulevard 17 of plaintiff, Jeffrey Epstein. West Palm Beach, FL 33409 27 19 MR. INDYKE: Darren Indyke on behalf of By JACK SCAROLA, ESQUIRE la 19 plaintiff, Jeffrey Epstein. 19 ALSO PRESENT 20 MR. SCAROLA: My name is Jack Scarola. 20 Above 4. Beyond Reprographics 2161 Palm Beach Lakes Boulevard 21 I am counsel on behalf of Brad Edwards. II West Palm Beach, Florida 33401 22 Brad Edwards is plaintiff in the By Manuel Santiago, videographer 22 23 counterclaim in which this case -- excuse me 23 24 -- in which this deposition is being taken. 24 25 25 Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798337 5 7 THEREUPON, Of Florida graduate school and got a master's degree in 2 WILLIAM BEAZER, 2 philosophy. I then applied to trio university of Miami being a witness in the notice heretofore ) law school. And I went to law school iron 1972 to 4 and being first duly sworn in the above cause, 4 1975, when I graduated the University of Miami law S testified on hla oath as follows: 5 school. THE WITNESS: I do. 4 Q Tell us how you came t0 select philosophy DIRECT EXAMINATION ▪ an a major? 4 BY HR. SCAROLA: • A How such flaw do you have? • Q Could you please introduce yourself to the • Q Well, I have a lot of tine, but I expect 10 ladles and gentlemen of the jury, before whom this 10 that the jury would like you to be relatively brief. II deposition is likely to be shown? 11 A I have also had a very longstanding interest 12 A My name is William Joseph Berger. 12 in the ideas, concepts, fundamental principles, and I 13 Q And where la the deposition being taken 13 was attracted to philosophy. 14 today, Mr. Berger? II CI All right, sir. Were your plans when you II A It's being taken in the Law Office of Weirs, 17 chose that major to eventually go to law school? IS Handler 4 Cornwell, the firm that 1 work for. IS A No. I7 O What is your capacity with the firm? 17 0 what were your plans? IS A I an an attorney with the firm. IS A I was going to open up a philosophy shop and If Q How tong have you been employed by Kelm, Is tell people if Choy existed or not. 20 Handler Cornwell. 20 Q sounds like an endeavor that was not likely 2l A Since approximately December of 2009. 21 to enable you to support a family? 22 Q You understand that this deposition is 22 A Actually, It was teaching. I was going to go 2) being taken in a case in which Bradley Edward➢ has 2) into teaching, and then I decided to go into law 24 brought suit again➢t Jeffrey Epstein for malicious 24 school. 25 prosecution, correct? 25 Actually, law seamed to me to be -- I have 6 8 A Yes. I always thought of law a➢ the combination of 2 O And can you tell us, understanding 2 philosophy in action. That's what, to ma, law is, 3 that the case is set to be tried the second two weeks 3 the application of principles to real life • in arch, whore you are going CO be the second two 4 situations. • weeks Of Mirth? 0 Where were you born and raised? 4 A I will have surgery out of town March 5, and 4 A I wan born in Philadelphia, Pennsylvania. / I will bo rehabilitating or recovering probably for the 7 And at the age of ono year, my family moved to Miami • resit of the month. • Beach, and I grew up on Miami. Hooch. 9 0 All right, sir, thank you. We wish you 9 Q Do you have a family of your own now? 10 beat of luck with your surgery. Sorry that you are 10 A Yea. Linda and I have been married for 47 II not going t0 be with us at trial in person. But IL years and we have three daughters. 12 that's the reason why wo are taking this videotaped 12 Q Let's pick up with your graduation from law 1) deposition today. 1) school in 1975, and tell ua what you did after 14 A Thank you. 14 graduating. 15 Q I want, before we begin dealing with the 15 A From 1975 to 1997 I was an attorney in Miami, If issues involved in this case, co talk to you a little If and I wan with several law firm during those 22 years. 17 bit about your professional history. So let'➢ start 17 I was with the Greenberg Traurig law fire; the Fine In with higher education. IS Jacobson law firms a firm called Hughes Hubbard t Read, 19 Where did you go to school and what did 19 which is a New York firm that had a *Maul office. And 20 you study? 30 I had my own practice in between. So that takes me to 31 A I went to college for a year at Syracuse, 21 1997. 22 then I transferred to the University of Florida. I 22 Then in 1997 Linda and I decided that we 23 graduated from the University of Florida with a 33 Were going to ROVO to Boca Raton, and we did. I 24 bachelor's degree. I had a degree in philosophy, and 21 joined this fire in 1997, the Rehm Handler firm. 25 that was to 1971. And then I stayed at the University 25 was here for a year, and then I started ny own Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798338 9 11 practice, just a solo practice until 2002. Q Tell us atittle about them, if you would, 2 And in 2002, I ran for circuit court Judge 2 please. 2 hero in Palm Beach County and I was elected. I A My daughter Marla is 43 today. It'➢ her 4 served a➢ a circuit judge in Palm Beach County from 4 birthday. she's a mental health counselor. • January of 2003 until Juno of 2008. S Unfortunately, her -- in the sense that she specializes Q Lot's talk a little bit about the nature of 4 in grieving, she administers mental health counseling 7 your practice before you were honored with a position 1 to -- particularly to children -- she works for a s on the bench. Toll us, if you would, please, about a charity called Tomorrow'➢ Rainbow in Broward County. * what kind of legal work you did in those decades / she has her hands full right now with the shooting. It before you became a circuit court judge? 10 My daughter Lauren is 41, and oho'➢ a 11 A I handled lawsuits of people suing other II social director -- rather, an activitie➢ director 12 ',maple, companion suing companion. General -type work, 12 for a large temple here in Boca Raton. 13 state and federal. 13 My youngest daughter is Brooke, who is 29 In the 1 90. I started to focus on 14 years old. Brooke is looking co find herself, so 13 employment discrimination law whore I represented 13 she's back at hone now, and wo are going to nee 14 the employe*a who had been fired or disciplined. 14 where She goes next. I7 Those were cases against their employers. And so if If Q I have a few of those myself. Is I had any kind of concentration, it was in that IC Tell us, if you would, please, how you IS area. Probably a third of my practice was in that went about addressing the financial issues that 20 area until I was elected to the bench. 20 arose in '07 and '08 that compelled you to leave the 21 Q During that period of tine before taking 2L bench? 22 the bench, did you focus your practice exclusively on 22 A I decided I needed to go back to private 22 representing either plaintiff➢ or defendants? 23 practice. I took a substantial cut in pay to become a 24 You told us that your employment law 24 Judge, and we realized that going into it. But it was 25 practice was focused on representing plaintiffs. 25 just something that needed to be addressed as a result 10 12 I What about prior to that? of the recension, so I decided to look to go back into 2 A well, I did -- I did -- oven during that 2 practice. And I was -- I interviewed with a couple of 3 time, I did represent Gone employers, so I did 3 largo firms. 4 represent both aides. 4 Q roll us, before wo leave focus on your In other types of canon, there wan no 3 Judicial career, what you did during those five to 4 exclusive representation of plaintiffs or defendants 4 nix yearn? 7 in what we would call civil matters, comeorcial 7 A well, in Palm Beach County, the circuit t disputes and those types of things. • court, which is the higher-level trial court, La 9 Q What motivated you to nook a position on • divided into five divisions: civil, criminal, family, 10 the bunch? 10 probate and Juvenile. In the five to six years that I Il A Maybe the same thing that motivated no to go IL was a Judge, I served in the civil division for ono 12 into philosophy. It was something whore I could 12 year, then I nerved to the family division involving 13 actually apply principles, legal principles to 13 divorcoa, custody fights for two and a half years. And 14 real -life situations and deal with people's Isamu➢ and 14 that was in the branch court in Delray Beach. And I 15 really do something for society. And it was something 15 was the administrative judge for the Delray Beach 14 that was vary rewarding when I was on the bench. 14 Courthouse. 11 O What were the circumstances under which you 11 And then the last approximately two year➢ IS left? IS that I was on the bench, I Served in the criminal IS A well, unfortunately in 2007/2008, wo wore 19 division, so I presided over Colonial/capital case➢ 24 hit -- my family wan hit with the recession, no w0 24 for two years. 21 had -- it was a serious financial ➢ltuation for us, so 21 Q I know from the review of your professional 22 I decided I needed to go back into private practice. 22 sestina that you currently, in addition to doing trial 23 Q You told ua about your 47-year marriage. 23 work, also do soma appellate work; is that correct? 24 Do you have Children? 24 A Yea. 33 A Yea, three daughters. 33 O Did you have any app responsibilities Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798339 13 15 l while you were a judge? 1 circuit court judge➢. 1 A Yes. Judges that are circuit court judges 1 Q In going through your career, we had 3 have appellate responsibility for cases from the county 3 reached the point where in 2008 you faced the 4 court being appealed to the circuit court, and I worked 4 economic reality of having to leave the bench. where S on those. And then I was also invited by the Fourth S did you than go? f District Court of Appeal, which is our appellate court A I was hired by the Rothstein, Rosonfoldt a / for Palm Beach County, Broward County and the Treasure Adler firm. • Coast. a O How did that cone about? I was invited ono simmer to sit on -- to A As I said, I was interviewing with two firms. 10 sit on that court in place of a judge who was on 10 There wore two largo firma that had offices in Palm 11 vacation, Judge Barry Stone. So I served on the 11 Beach County -- largo offices In Palm Beach County. 12 Fourth District and served with a panel of judges 12 Neon wo moved up hove in 199?, my daughter 13 and heard quite a number of cafes and wrote several 13 Brooke got to know Stuart Rosonfoldt,a daughter, and 14 decisions for the Fourth District. 14 we became socially acquainted with Stuart Rosenfeldt 13 Q The jury may not be familiar with the 13 and his wife. So I know him from 2997 until -- wo 14 procedure, but when the appellate court reviews 14 aro at 2008. I knew him that entire time. 17 decision➢ that are rendered and jury trial re➢ult➢ at In fact, when I went on the bench in 2003, 18 the trial court level, how many judges aro involved 18 I referred to Stuart my employment case➢ that I had. It in that review process? It I had a great deal of respect for Stuart. 20 A Three. 20 Stuart was a very prominent attorney in 21 Q And you then wore one of three panel 21 the employment law area. No wrote for the Florida 21 members in the review of multiple cases that were 21 Bar the teat that lawyers take to become board 23 heard before the Fourth District Court of Appeal? 23 certified in labor law. lie had an excellent 24 A Yea. 24 reputation in that area. 2S Q Did you ever have the responsibility of 2S And Stuart, I would see ha every once in 14 16 1 writing opinions on behalf of the court, oven though a while, and ho would toll mo about this firm that 2 you were an a➢sociate judge and not a regular member 2 ha was now with, Rothstein, Rosenfeldt 4 Adler, and 3 of the Court? 3 it was upbeat. Be portrayed it as a vary dynamic 4 A Yea, I wrote several divisions that were 4 firm. 3 published and -- for the courts -- for the court of So during CM time I was looking to go 4 appeal. 4 back into private practice talking to other firms, I 7 Q Did you also, during the course of those 7 road In the paper that Rothstein, Roacmfoldt 4 Adler ▪ years, when you were serving as a circuit court judge, • had just hired the former mayor of Boca Raton Stove 9 receive the honor of having been selected by the 9 Abraea to open up a Boca Raton office. 10 chief justice of the Florida Supremo Court to fulfill 10 Now, I knew Stove Abrams. Ho was my II any responsibilities on behalf of the Supremo Court I mayor. NO was our mayor here In Boca Baton during 12 of Florida? 12 9/11, and I had a groat deal of respect for hie. 13 A Yes. The position of chief justice rotates 13 Ne had an anthrax attack here in Boca at 14 among the justices in the court. And at the time the 14 the National Enquirer building. And Mayor Abrams IS chief justice of the Florida Supreme Court was Fred IS was like Mayor Giuliani for Boca Baton. He was If Lowia. And Justice Lewis appointed me to a ➢tatewide If vary -- showed great leadership skills. 17 panel conflating of laypersons, judges at the trial 17 So when I saw and then ho was not the 18 level, and appellate judges and retired Supreme Court IS mayor anymore, of course, in 2009. But when I saw 19 justices on a cormittoo to study how the public Could 19 that the firm was hiring -- had hired Steve Abrams 20 130 batter informed in voting for trial judges. 20 to open up an office here, which would be a 21 In Florida, county and circuit court aro 21 brand-new office, not a branch office of a big firm 22 elected. Appellate judges are appointed by the 22 that had -- that already had a largo number of 33 governor. And the purpose of the panel was to deal 23 people in a branch office, it just seemed like an 24 with how the public could bo bettor informed in 24 opportunity I needed to explore. 33 decisions of -- towards voting for county and 23 So I called Stuart. And I said, Stuart, I Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798340 17 19 would like to talk to your fire about -- I told him A Probably maybe double the total, if you 2 I was thinking of leaving the bench. And I asked if 2 counted the lawyers. So it probably had 120 to 140 3 I could be interviewed by the firm to work with omployoos. 4 Stove Abrams in opening up the office here. Q What happened to the aim of the firm 5 Q Did you then interview with the firm of S during the period of tiro that you were associated 4 Rothstein, Rosenfoldt a Adler? 4 with the firm? 7 A Yea. Stuart and I talked, and then ho A Tho firm did grow. It also -- I moan, it 4 introduced ma to Scott Rothstein, and that was the a grow in Fort Lauderdale. We also hired wo • interview I had. * eventually did open up a Boca Raton office where Nayor 10 Rothstein and I talked for about a half ic Abram and I practiced. He had one attorney along with II hour in his office, and he made me an offer and I 11 us that was full-Cleo there and another attorney that 12 accepted it. 12 was part-time. 13 Q Which office wad it at which you were If And then the firm al➢o acquired an office 14 interviewed by Mr. Rothstein? 14 in Venezuela and maybe in Tallaha➢lee. not sure A The firm didn't have a Boca location. It had 13 about that. No also had an office In Washington, 14 a Fort Lauderdale location on East Las Olaa Boulevard, it III. that wasn't staffed -- fully ➢taffed. There 12 ➢o it was in that suit of offices there, in hi➢ office. 12 might have boon one other office possibly in Now Q roll ua about that suit of offices. IS York. I don't recall. A Noll, at the tine the -- I call it RRA for is Q You told us about knowing Mr. Rosonfoldt 20 Rothstein, Rosonfoldt a Adler -- MA had -- if not 20 and knowing Mayor Abrams. Wore there any other 21 mistaken, it had one and a half floors of that 2L lawyers working in that office who you either know or 22 high-rise office building on East Las Olam. And 22 know of? 23 Rothstein's office was on the floor -- the main floor 23 A Yea. And that'➢ one of the reasons that 24 whore they had the entire floor. 24 chose that firm. Thera were several people. I learned 25 Q Describe the offices. 25 that -- I think front al discus➢ion with Scott Rothstein 18 20 A Noll, the offices wore a number -- you had a when he interviewed no -- Judge Barry Stone, the sane 2 waiting room, you had a number of attorneys' office➢, 2 appellate judge that I had taken his place when I sat 3 and sort of common . Sono of the offices were 3 on the Fourth District -- that ha had been hired by the 4 bigger, some wore corner offices, depending on the 4 firm, and he had either already started or he was going 3 attorney's position with the firm, and Rothstein had 3 to start. 4 his own office, which, of course, was larger than 6 Judge Stone baa a tremendous reputation. 7 others. • I think he was Cho longest sitting judge on the • Q Descrlbo Kr. Rothsteln's office for the S Fourth District. 9 benefit of the jury, if you would please. In cases whore I wa➢ -- as a circuit court 10 A Noll, it was a big office. It got bigger 10 judge whore I was reversed by the Fourth District II later. It was renovated in 2009 after I was hired. At IL Court of Appeal ho dissented from those naveaaaaa 12 the time, it wa➢ -- iC wa➢ not an overly large office, 12 several times. 13 but it wa➢ clearly the office of the attorney that wan 13 Q So ho had a special place in your heart? 14 the named partner in the firm -- the first named A Right. Right. So I had a groat deal of 15 partner in the firm. 15 respect for Judge Stone. If Q How about once the office got renovated? If Another attorney, who is Gary Farmer Jr., 11 Did you have occasion to over be in Mr. Rothstein's 17 Gary Farmer Jr. is the ➢on of Gary Farmer Sr. And IS office after the renovations? IS Cary Farmer Sr. wan also a judge on the Fourth 19 A Yeah. It wan either maybe triple the size 19 District Court of Appeal. And I knew his son was an 30 than it had been before, lavishly decorated. 30 active, prominent personal injury attorney and class 31 Q How largo wan the firm at the time you 21 action attorney, consumer attorney. Ho had just 22 joined it? Now many lawyers, approximately? 22 settled a gigantic, hundreds-of-millions-of-dollars 33 A It had about 60 or 70 lawyers at the time. 23 whistletdower case against the pharmaceutical 34 • And total number of omployooa, could you 24 industry. Noll, that was very impressive. So Gary 25 estimate that for ua? 25 either had joined the firm or was going to join the Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798341 21 23 firm. I knew that. represented another law firm in a breakup of firma 2 In addition to Mayor Abrans and -- there 2 And the Scherer firm waa owed over a million 3 was also an attorney named Steve Lippman, who I did In Coos. And the client, the other law firm, was 4 not know. But I got to know him. I heard of him. 4 reneging on paying that. And Scherer won at the • He had quite a number of financial institutions a➢ 5 trial level, and then Judge Stone and I defended clients. So when I joined the firm, the firm was 4 that judgment and protected that judgment on appeal, 7 representing Citicorp, Walla Fargo, JCPenney, Ed 7 and we were ultimately successful. 4 Morse Automotive dealer➢hip.. It was a crui➢e • So you had a very prominent attorney, who, * line -- I forget the name of it, but we represented * ironically later, became an attorney for clients 10 a cruise line. 10 suing the firm after the firm'! demise. But at the II Robert &ache], who was an attorney who II time, Bill Scherer -- I was very impressed with the 12 was at that fire. Roach.' represented police 12 fact that Bill Scherer was a client of the firm. 13 unions. So we had as clients the union➢ that 13 And he spoke publicly in -- I remember a newspaper 14 represented police officers. And I think those are 14 article on the Internet that Michael Mayo, I Is the attorneys that I knew going into the firm. 15 believe, with the Sun Sentinel, interviewed Bill 14 Q Do you remember the approximate month that 14 Scherer about Rothstein. And I remember Scherer I/ you actually joined RRA? 17 saying that -- he ➢aid, I don't know what Scott IS A Julie of 2009. sorry. June of 2000. 10 Rothstein la doing, but whatever in it I like it. It Q You remained with the fire, then, [or haw II He said, I like it so much that my firm has given 20 long? 20 him hla major case. So that was -- I thought that 2L A Until probably around November 8th to 10th, 21 was a testament to the firm's reputation. 22 something like that, 2009. So June 2008 to November of 22 Q When you joined RRA, how was your position 23 2009. 23 with the firm, your relationship with the firm 24 Q Approximately 18 months -- about year and a 24 publicly described? what position did you have? 25 half? 25 A Noll, I had -- I was called a shareholder. 22 24 A Yeah. The firm had associates, partners and shareholders. I 2 O All right. 2 wasn't really an equity owner in the firm. It was -- 3 At that time you joined the fire and 3 When I was with the Pine Jacobson firm I through the end of October of 2009, how would you 4 was designated as a partner. I wasn't really an a describe the perception of the firm, the firm's 5 equity owner in that. So I had the -- that was sort 4 reputation in the South Florida legal community? 4 of -- there were probably 10 people that were A I think it was in very high regard by the 7 designated as shareholders. legal community. When I joined the firm, I looked up Then under that -- ➢o we had sort of a 9 ea the Internet, articles about RRA. And it was a firm • mere senior role with the firm. 10 that had -- that was very much involved in civic and 10 Q Was it unusual, based upon the experience II charitable work, giving, that sort of thing. II that you have described, for law firma to de➢ignate 12 Rothstein was awarded many honors by 12 employeen of the fire a➢ being shareholders or 13 charities for his work, charitable work. The 13 partners without those individual! having an equity 14 attorneys that I associated with at the firm I 14 interest in the firm and ownership interest? 15 thought were very, very high-caliber -- extremely 15 A No. I had seen that before. As I ➢aid, the IS high-caliber. I got to know more people there, of 19 Fine Jacobson firm was a ?0-attorney fire in Miami that Il course. 17 was a vary, very prominent fire In the 1980s. And I IS One of the clients of the firm was the IS was a partner with that firm, but I did not have an It Conrad Scherer firm. The Conrad Scherer firm was 19 equity interest in it. 20 ran by Bill Scherer. Bill Scherer la one of most 20 Now, afterward➢ when RR. collapsed, 21 prominent lawyers in South Florida, certainly in 21 obviously among all of the things that all of ua at 32 Seaward County. And he was a client of the firm. 32 the firm went through in terms of being interviewed 33 In [act, Judge Stone and I worked on a 33 by law enforcement and that sort of thing, I was 24 case that he had with u➢. It was a major cane for 34 also interviewed by the Florida Bar. And one of the 25 that law firm. It was -- that law firm had 25 points they raised was the fact that I was being Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798342 25 27 1 called a shareholder and yet didn't have an equity i effect. He stepped into the ➢hoes of the law firm, and 2 Interact In the firm. 2 he was now responsible for -- the firm had clients. No 3 I learned from the Bar, really, that that was responsible for collecting whatever foes could be O was not -- not that It was widely -- a widely used O collected for paying aqsloyees, for seeing that there 5 practice, but it was ono that the Bar was well aware 5 was a transition from the firm to other attorneys i of and did not discipline the attorneys, to my 4 outside the fire to take over those matters, and also 7 knowledge, certainly not In my case, for having been 1 to collect, against whoever was responsible, money to • called a shareholder and not having equity. • re -- in effect to reimburse the firm for money that But I learner!d from that inquiry that this * was stolen from the firm. So Herb Stettin had that 10 is a practice that seemed to be common, ao to speak, IC role. II throughout the 11 Q So tell us, if you would -- you have 12 0 You have told us that your relationship 12 described the fact that the firm collapsed. How did 13 with Rita ended in early November of 2009. Tell ua 13 your knowledge of the circumstances surrounding that 14 about the circumstances under which that occurre➢. Is collapse evolve? II A well, the exact circumstances are that the II A Well, it evolved very quickly. On Saturday 14 firm had already collapsed. November 1 was a Sunday. 14 October 31st, I was copied on an email that said -- 17 And that's when I learned that there were problems, and 17 that was -- that didn't have broad circulation within le that Rothstein had left the country. I➢ the firm that said something about, Where's Scott? November 2 was a Monday. And the attorney Is Something like that. 20 that the firm hired co represent it in this 20 Q Scott meaning Scott Rothstein? 21 Rothstein problem and who had filed a lawsuit for 21 A Yeah. Two or three days before that, maybe 22 the firm against Rothstein immediately -- Kendall 22 Wednesday of that prior week, at the and of October, 23 Coffey was the attorney -- I stayed on for a couple 2) there was a charitable event at his home and he didn't 24 more day➢, probably a week, 10 days, something like 2• attend. He wasn't there. Nis wife was there and 2S that, and then I left. 25 dozens and dozens, if not over 200 people were there. 26 28 1 The firm had basically collapsed. We It was a big event, but he wa➢n't there. It raised 2 weren't getting a paycheck. I felt I owed it co the 2 questions. Where was he? 3 people in the firm -- we atilt had employees that 3 So on Saturday I saw an email that ➢aid he 4 weren't getting paid but atilt had some benefits -- 4 has left the country. Something like that. And 5 maybe they were getting paid somewhat. The 5 then Sunday morning or Sunday afternoon, I got an • attorney➢ weren't getting paid. I felt I needed to • email that -- I forget who sent it -- but said to 7 stay there for scam period. 7 re, Ma are going to have a meeting among -- I think And Herb Stettin had been appointed by S the people -- the shareholders at the fire that t Judge Streitfeld a➢ a receiver for the firm. I knew 9 afternoon or evening, and I went to that. 10 Herb Stettin for years and I felt some loyalty to 10 So there were probably about seven or 11 him to stay for a while, at leant. But then it got IL eight or nine of u➢ there. Somebody -- maybe Stuart 12 to the point where I had to leave. I had to get a 12 Rosenfeldt -- had already hired Kendall Coffey, who 13 paycheck, so I left probably around November 7th or 13 was -- Kendall la a Miami attorney. Kendall and I 14 10th, something like that. practiced together at Greenberg Traurig in the '70a. IS • Explain to the jury, if you would, please, IS Kendall became the united States attorney for the li what a receiver la. What was the responsibility that If Southern District of Florida. 17 Mr. Stettin was appointed to fulfill by circuit court I/ 0 A presidential appointment? Ii Judge -- IS A Pre➢ident Clinton hired him. It A Streltfeld. It And then Kendall, at sans point, left that 30 O Streitfeld. 30 position and he we➢ out in private practice. 21 A A receiver la somebody who is appointed by 21 So Kendall we➢ there at this meeting, 22 the court -- and It's typically an attorney -- to take 22 along with seven or eight of the other attorneys in 23 charge and to basically run whatever the company is or 23 the firm, and that'➢ when I learned that Scott 24 the business that is now in receivership. And that was 24 Rothstein was in Morocco. And I was shocked. And 25 the law firm. So he was -- he became the law firm, in 25 also -- because we were there for a couple hours, I Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798343 29 31 al➢o learned that our tru➢t account➢ -- and those that were being prosecuted on behalf of throe young 1 are bank accounts that contain client money on deal➢ 1 woman: M., B.N. and Jane Doe. And w➢ will refer to 3 that are pending, deal➢ that are settled, but the them when I talk to you about them in that ➢ame way, 4 money he➢n't been di➢tributed -- million➢ of 4 referring to sham by those initial➢ and that 5 -- that those account➢ had been looted, they 5 pseudonym. 4 were empty. I learned that that night. So those 4 Describe how it i➢ you cam, to ➢hare 7 were the circumstances where I learned that the firm ro➢ponsibility for those ca➢es with Brad. 4 had basically imploded. A I don't remember the first -- my first Q Did there coma a point in time when you s introduction to the ca➢e➢. 0bviou➢ly, there wan a 10 became aware that Scott Roth➢tein was operating a 10 meeting. Obviously, I met Brad for maybe the first 11 Renzi scheme out or the law firm? 11 time, and I was -- I wa➢ asked -- I don't remember by 12 A I learned that maybe a day or two after 12 whom -- to work with Brad on these case➢ I think 13 November 1st, and I think I read it in the paper. 13 principally becau➢e they were ➢ignificant ca➢e➢. 14 4) Before the disclosures that you have 14 I had been practicing for quite a while. Is described to us, the raiding of the trust account and 15 I had been a Judg➢ in Palm Beach County and had 14 the operation of the Moral ➢chme, having been at 14 practiced in Palm Beach County. The fife was In 15 that the firm for approximately a year and a half, 15 Fort Lauderdal➢. Brad wa➢ a Broward County lawy➢r, II did you over have oven the slightest suspicion that la I think, primarily. And I had thi➢ connection with It Scott Rothstein or anyone also associated with is Palm Beach County. 20 Roth➢tein, Rosenfeldt t Adler wore engaged in any 20 Q Where were the case➢ pending? 2L kind of improper activity? 21 A The canes were pending in Palm Beach County. 21 A No. 22 So there was a natural Lit for me to work on the➢e 23 Q Evan in retrospect, as you sit here today, 23 cases, and I think that'➢ why I was brought in to work 24 can you look back on that time period and say, You 24 with him. 25 know, I should have realized there was something 25 Q You described these as significant cases. 30 32 1 wrong that wa➢ going on here? I What doe➢ that mean? 2 A No. 2 A Well, they involve terrible thing➢ that 3 0 Did all of thi➢ new➢ coma as a complete and I happened co these three young women when they were 4 total shock to you? 4 minors, ➢o they were significant in the ➢ense that the 5 A Absolutely. 5 personal injury to them wan enormou➢. They were al➢o 0 Do you know Brad Edwards? 4 significant ca➢es in terms of what their potential A Yes. damages were in terms of dollars. 5 Q When and how did you first moot Brad? 0 Why? 9 A I met him at the firm sometime in the first 9 A Because jurie➢ are asked to use their common 10 three months, something like that, of 2009, after I had 10 sense and their reasoning to come up with a dollar 11 been with the firm [or about almost a year. I met him Il amount to compensate victims of wrongdoing by others. 12 there. 12 Q We have identified the defendant in these 13 Q Well, the jury will have been told, by the 13 case➢ as Jeffrey Epstein. Was there anything about 14 time that your to➢timony is played to then, that Brad 14 the circumstances, nature or character of the 15 joined the firm con➢iderably after you joined and wan IS de fendant that had any influence on your describing 14 there for a period of about five months. So you were 14 these a➢ ➢ignificant case➢? 17 there for almo➢t a year before Brad joined the firm, I/ A Yes. If you are going to be representing IS correct? In somebody who has suffered, what I would call -- 19 A Right. 19 although it wa➢n't exactly physical, it wan mental -- 20 0 Did you ever have occasion to ➢hare any 20 catastrophic damage➢, catastrophic trauma, which I 21 ro➢ponsibilities with Brad Edwards. 21 believe these young women experienced when they more 22 A Ye➢. I believe the only matter Brad and I 22 minors and wa➢ ➢till affected by, if you're going to 23 worked on together, if not mistaken, was the -- or 23 represent them in that type of ca➢e, the case la more 24 were the three lawsuits against Nr. Epstein. 24 significant IC the person that you aro suing has a➢sets 25 Q We have identified those case➢ as case➢ 25 that you can go after ➢o that you -- so that your Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798344 33 35 client can be compensated. And Jeffrey Epstein was a But you do recall Paul Cassell's 2 billionaire. 1 involvement. What about other local lawyers? Wore 3 And ao in terms of compensating, making there other local lawyers who were participants in g➢od to these young women, which would be called 4 the prosecution of she cases against Jeffrey 5 compensatory damage➢, this was a very significant 5 Epstein? case. You had terrible injuries, mental injuries. 4 A Yeah. Not representing our three clients, 7 You had a defendant who, to me, was clearly libel, but there were other firms that were representing other s and so there would a very, very significant award of s young woman that had been abused by him. Ye➢, I did compormatory damage➢. * know of those firms. 20 In addition, if you were able to prove a Is There vas the Podhurst firm in Miami, a II certain degree of willfulne➢➢, that the➢e act➢ -- II very prominent firms Bob Josofsborg, who I have 12 that he did thesethings intentionally, or he did 12 known for years. Bob is one of the moat prominent 13 them with a certain mindset, you could recover, 13 attorneys also in South Florida. He had a case -- le what's callsd under the law, punitive dmage➢. IS ho had cases against Mr. Epstein. Or he had clients Is Punitive damages are based on how wealthy Is -- I don't know if he actually filed cases, but he 14 the defendant is, ➢o that the defendant could be 14 had clients that were victims of MX. Epstein. 11 punished. And lf a person is extremely wealthy, 17 Sid Garcia is a very prominent attorney in Is then an award of punitive damages that'➢ $100,000, Is Palm Beach County, who was also representing Is which would seem like a largo award if it wa➢ Is victim. 20 awarded against mo, would be an insignificant award 20 Spencer Nuieln was another lawyer. Ted 21 of punitive damage➢ against somebody who is 21 Leopold, another prominent attorney, ho also had 22 billionaire. 22 clients. The Searcy Denney, who is a prominent 23 So to -- so the firm wan In a position in 23 firm, had clients as well against Kr. Epstein. And 24 representing 'these young women to go to a jury and 24 I believe an attorney named Adam Horowitz also. 25 ask for very, very high number of -- in dollars 25 Those are attorneys that I recall had similar cases 34 36 I compensatory damages, as well as an extremely high I to ours. 2 norther in punitive damages, because it would take a 2 Q Tell ua about shit extent to which you wore 3 very large amount of punitive damages to punish 3 working together in coordinating efforts with those 4 somebody who is a billionaire. I other lawyers. I Q Dld the prosecution of the three lawsuits A Well, wo had -- we were conmenlcating, we for which you and Brad Edwards were responsible wore comparing notes, we were strategiming with then. 7 involvo efforts of any lawyers outside of RRA? 0 What is a joint prosecution agreement? A There was a Paul Cassell who wan co-counsel S A A joint prosecution agreement la an agreement with Brad. I never met him. I have spoken so him. t typically in writing -- although it doesn't have to 10 And he had been working with Brad -- Brad brought these 10 be between the attorneys for different clients to II cases to the firm. No didn't -- he didn't get hired on 11 pool their efforts and to keep confidential their 12 these cases after he joined ARA. Be had already filed 12 confidential communications and to jointly assist each 13 these cases, I believe. I know ho had shoe -- the 13 other because their clients have a common goal and aro 14 ladies as clients before he joined the firm. And le typically litigating against the sane person or IS Cassell was co-counsel with him on those. 15 company. It's an agreement to share information. It So in terns of attorneys that were If Q Did such an agreement exist to which you 11 co-counsel wish ua, he was a co-counsel representing 17 and you Brad, as lawyers with RNA, were cooperating IS the three young woman that we represented. le in a joint prosecution effort with Bob Joaaf➢berg, It 0 Toll ua about Paul Caaaell. IS Spencer kuvin, Sid Garcia, Tod Leopold, Adam Horowitz 20 A Well, I don't know a whole lot about him, 30 and the Searcy Denney law firm? 21 other than he lives out of atato. And I think he's 21 A Yea. 22 connected with a university. I may be mistaken. 22 0 To what extent did Brad Edwards as➢um a 23 0 No, I think that you aro recalling 23 leadership role in that prosecution effort? 24 correctly, but we will get those detail➢ from other 24 A With our firm, with RNA, I was -- I took a 31 wan aaaaa 23 secondary role to Brad. Brad was the load attorney. Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798345 37 39 These were his clients, and I had -- I had specific I BY I . SCAROLA: 1 roles, really. I wasn't handling the same breadth of 1 Q When you refer to young women being on the 3 issues that Brad was. I wan handling certain specific planes, did you ever make a determination as to 4 aspects to the case, and also strateglzing with Brad. 4 whether there were, In fact, children balm; S But he had the lion's share of the representation. S transported on those planes by Mr. Epstein? 4 Q And were there also joint prosecution 4 A I have to correct myself. When I talk about 7 conferences regarding how discovery was conducted, ▪ young unman, they were young women when we wore 8 who wan to lead the discovery efforts, what discovery ▪ representing them and at the tine that I was involved. * was to to taken among this group of lawyers who wore * But at the time these things happened, they wore 10 all prosecuting claims on behalf of child victims IC minors. 11 against Jeffrey Epstein? 11 • You were involved in the representation of 12 A Yes. We had verbal. I think I attended one 12 three specific individuals. Of what significance was 13 in peIlon. 13 it in your representation of those three individuals O Did those neetinga go on throughout your II to be investigating and cooperating in the 19 involvement in the prosecution of those claims? 19 investigation of offenses alleged to have A Yea. 14 conflicted -- to have been comnatted by Jeffrey I, Q Describe the nature and extent of the 17 Epstein against other children? 14 investigation into Jeffrey Ep➢tein's activities that to A Well, although we just represented three It was undertaken in connection with thin group effort 11 minors, or three young women at the time, the rules of 20 to hold Mr. Epstein responsible for the victimization 20 evidence at a trial do allow an attorney for -- would 21 of children. 21 have allowed us, as attorneys for these waxen, to put 21 MR. LINK: Object to the form. 21 on evidence of other victims and other bad acts by 23 BY MR. SCAROLA: 23 Mr. Epstein. 24 Q Let me restate the question. 24 There's a Florida statute, 90.404, that 2S Describe, if you would, please, the nature 2S allows other acts, even though they weren't 38 40 1 and extent of the investigation that was undertaken committed against your particular client, to be 2 into Jeffrey Epstein's wrongdoing. 2 introduced to show a pattern, a practice, a modus 3 MR. LINK: Object to the form. 3 operandi, motives, and so it was important for ue to 4 THE WITNESS: Well, it was pretty 4 investigate any wrongdoing by Hr. Epstein against extensive. There were a number of people 5 any young woman that was similarly situated and interviewed and you had a network of -- you 4 groomed and recruited, like ours were, when they had people that were -- that surrounded 7 were teenagers. That would all possibly have been 8 Epstein In terns of members of his entourage • evidence that could be presented to a jury in a 9 or his organization or -- that worked for 9 trial, even though our clients weren't directly 30 him, and there was a major effort to locate 10 involved in those instances. 32 these individuals that may be potential 11 • In light of the rules of evidence and the 32 witnesses. 11 Florida statute that you have referenced, did you 39 There were third parties that -- such 13 perceive that any obligation existed to investigate 34 as pilots that wore -- we were trying to 14 alleged crimes committed against other children by 24 track down or communicate with, because IS Jeffrey Epstein under the same circumatances as your 16 there had been statements made about how 14 own clients had been victimized? 17 sane of these victims wore on planes that 17 A I think it would have been professional 18 wore chartered or owned by Mr. Epstein, so IS malpractice not to have investigated other instances, 19 there were efforts to get the flight logs, 19 because they were all potentially relevant and it was 20 and to depose people who -- many of whom 20 powerful evidence that if he did it to other women, he 21 turned out to be very prominent, nationally, 21 did it to us. If the techniques wore the same and the 22 individuals that were on planes that we 22 same pattern of activity existed -- so I think we were 23 believed contained -- at the same time there 23 bound as attorneys to conduct these other 24 were young women on the planes -- to track 24 investigations. 25 down those witnesses. 21 Q Were any of your three clients molested by Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798346 41 43 Jeffrey Epstein onboard any of Jeffrey Epstein's Why would Jeffrey Epstein be flying on a 2 pats? 1 plane with a minor child who is not his child? And 3 A I don't recall that, no. what connection did that child have to him? why 4 Q In spite of the fact that there wore no 4 would she be on the plane. That would tend to prove • specific allegations that any of your clients were S that he had evil motives and it had fit the pattern 4 abused onboard Jeffrey Epstein's jets, why did you of molestation of our clients. 7 pur➢ue an investigation as to what went on onboard So the slightest -- any proof that he was • the jots? • in the presence of minor children that weren't his • A Nell, if -- IC minors wore molested on those * children that he had no connection with was valuable IC jets, even though they weren't our clients, it would IC evidence because it fit the pattern. II fit the pattern of what Mr. Epstein had done to our II Q What was the geographic scope of the Id clients, and could have been evidence that the judge 12 Investigation that was undertaken with regard to 13 would have allowed the Jury in that case to hoar. iI Jeffrey Epstein? II 0 You mentioned that names of high -profile A Nell, it was almost global, really, because 14 individuals and celebrities came up during the course II of the range of his movements. It was certainly 14 of the investigation. were investigative loads 14 national. I know he had also prope 17 pur➢ued with regard to those individuals? 17 property in the Bahamas -- the Caribbean, so chore were II A I didn't have any direct involvement of that. I• tie➢ throughout the western hemisphere. It I just know that wo talked about specific Individuals, II Q As an active participant responsible for 20 that they were on the planes or they were at 20 sharing the task of representing these throe clients' 21 Mr. Epstein'! house. 21 in claim* against Jeffrey Epstein involving pattern➢ 21 Whether -- when I was working on the 21 of the molestation of children, was there ever 23 ease -- the cases before the firm collapsed -- 2) anything illegal, unethical or even unreasonable 24 whether we issued ➢ubpoenas or tried to issue 24 about the things that wore investigated in the 2S subpoena➢ to those persons, I don't recall that. 2S Epstein cases? 42 44 0 If, in fact, there was evidence that A No. 2 high-profile individuals and celebrities were in a 2 Q Was there ever anything illegal, unethical 3 position to have observed Jeffrey Epateirrs conduct 3 or even unreasonable about the people included in the 4 in the presence of minors who turned out to be 4 scope of that investigation? I victims of sexual molestation, would there to any A No. 4 reason to refrain from pursuing investigative lead➢ 4 Q was there ever anything illegal, unethical 7 with regard to those individuals? 7 or even unrea➢onable about the way in which the MR. LINZ: Object to the form. S Investigation was conducted? THE WITNESS: No. 1 A No. 10 BY MR. SCAROLA: 10 Q Did you over have any reason to question 11 You spoke about an obligation to pursue II the legitimacy of any of the claims that were being 12 investigative loads. Now would that obligation 12 prosecuted against Jeffrey Epstein by your law firm 1) pertain, if at all, to investigative leads that lead 13 and by you? 14 to high -profile and celebrity individuals? 14 A No. IS A You know, the Bar has in writing that an IS Q Did you ever have any reason to question 14 attorney is supposed to zealously represent a client. If the legitimacy of any of the claims that were 17 To ma we were duty-bound to pursue these lead➢. And I 17 prosecuted against Jeffrey Epstein by those with whom IS think that we were obligated to do it. IS you were participating in a joint prosecution IS If Mr. Epstein was on an airplane, either If agreement? 30 his plane or a plane he chartered, and he was with 30 A No. 31 another person, whether that person was a 31 Q You have told us that, from your 32 high-profile person or somebody else, and there was 32 perception, based upon your experience and training, 33 a minor, a young minor -- female minor on that 23 these were significant cases. Did you ever Corm an 34 plane -- whether molestation occurred on that plane 24 opinion regarding the potential value or the claims 33 or not, to me that'➢ powerful evidence. 33 from a compensatory damage standpoint? Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798347 45 47 I A They were in the multi-millions of dollars 1 So there was then discovery directed to 2 from a compensatory standpoint. 2 VS to her to discuss her life as a ) 0 And did you form an opinion regarding the 3 prostitute. Nell, as a prostitute, a 4 potential punitive damage value of the cases? 4 prostitute would have a pimp, a guy that 5 A Again, multi-millions of dollars. S would control her, that would be her boss, 4 0 Who controls the decision as to whether to 4 and who would have her under his thumb, and f settle a civil lawsuit? 7 who could threaten her and physically harm 0 A Well, as in any case, the client calls the 8 her if she didn't do what he wanted. I shots and makes the decision to settle. q Nell, Epstein's attorneys wanted us to le 0 What was your perception of the 10 disclose -- wanted our client to disclose 11 difficulties, If any, faced by the child victims who II those relationships, who was her pimp, 12 were prosecuting claims against Jeffrey Epstein? 12 things like that. Her life was now 13 A In toms of bringing choir claims? 13 completely in danger, so we had to deal with 14 0 Yes, sir. In corms of pursuing these 14 those issues. Is claims. Did they face any difficulties, or did they 15 So every person who brings a lawsuit II jest turn this matter over to choir lawyers and they 10 whore their main damage is what's been done 19 didn't need to be concerned about it from that point? 17 to their mind, not so much what's been done 10 MR. LIWR: Object to the form. 16 to their body -- those young women weren't II THE WITNESS: Well, yeah, Choy nada 19 physically disabled. They were mentally 20 themselves targets of personal criticism by 20 disabled and their lives had been destroyed. 21 Mr. Epstein's attorneys. And similarly to 21 Any person that brings that type of a 22 how, I think, the plea deal cane down, sane 22 lawsuit, everything about them IS open to 2) reasons. 23 investigation. That's part of bringing a 24 But the process that we are involved in 24 lawsuit. That was particularly difficult in 25 right now is discovery. So the discovery 25 those circumstances. So those young women 46 48 I process with regard to bringing these claims I wont through a lot during the time that I 2 by these young women involved opening up 2 was representing then in that regard. It 3 their lives to Mr. Epstein and his 3 was very, very difficult for them to go 4 investigators and to the public. 4 through this lawsuit process. These were young women who were groomed 0 It wasn't just, here is my case, by him. They wore identified by him and his 4 Attorney. You represent no. They wore now 7 associates as candidates for his 1 part of it and they wore paying the price. 6 molestation. They were from broken homes, $ BY KR. SCAROIA: 9 broken families. Their mothers night have 9 Q Did you over observe anything during CIO 10 boon prostitutes themselves. And those 10 course of the prosecution of those claims chat was. 11 young woman's lives were destroyed by tan. 11 intended co inproporly or falsely exaggerate the 12 And consequently, after he was finished 12 seriousness of the impact that these molestation had 13 with them, they had to then live their I) had on your clients? 14 lives, and many of them had problems, and 14 A I wouldn't go so far as to say that is was an 15 they faced hardships as a result of what he 15 attempt to exaggerate it. I think that the attorneys 14 did to them. And all of those things would 14 chat wo wore facing wore trying co diminish the effect 17 be made public and would be investigated. 17 of what Epstein did co our clients by saying that 18 And you also had a situation -- it was IS they somehow -- that our clients sonehow would have 19 a very difficult situation -- I was directly 19 done these things anyway. 20 involved with it -- in terms of courtroom 20 But I can't really -- it was very 21 appearance where, if not mistaken, one 21 difficult. It took a lot of courage -- a lot of 22 or two -- maybe ono of our clients was 22 courage for those young women co pursue those cases. 23 accused of being a prostitute herself as she 23 But I couldn't say that -- really that it was 24 grew up and after Epstein was finished with 24 anything unethical that the opposing attorneys were 25 her. 25 doing. They wore representing him zealously, too. Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798348 49 51 Q So let's focus on what you and Brad Edwards Jeffrey Epstein wa➢ attempting to defend himself over 2 were doing. Waa there anything ever improper that 2 the course of the month➢ that you were involved in 3 was undertaken to try to exaggerate the value of ) these claims? 4 these claim's or the impact that Jeffrey Epatein's 4 A Nell, he took the Fifth amendment and then he molestation had had on these young children? 5 went after the clients -- or his attorney did very A No. 4 aggressively. 7 Q Did you ever see anything that was done in 7 Q In light of hi➢ aggressive attack➢ on the 4 prosecuting the Epstein cases that was illegal, s victim, did it coma as a surprise to you that * unethical or unreasonable in any way? * Jaffrey Epstein had attempted to attack Brad Edward➢? IC A No. IC A Well, it was -- again, I was ➢till ➢tuned II Q Was anything done that was not part of a II that he did. 12 completely proper effort to protect the legal rights 12 0 In addition to prosecution of these three 13 of your three child victims? 13 civil lawsuit➢ against Jeffrey Epstein, did you IS A No. 14 become aware of the fact that Brad WAS volunteering II Q Dld there coma a tine when you learned that 13 his services to challenge the validity of Jeffrey It Rothstein had used the cases that we have been 14 Epstein'➢ criminal plea deal? I? referring to to attract Ponsi schema investor➢? I7 A I didn't know what Brad'➢ financial IS A I learned that sometime in the beginning of 14 arrangement wa➢ at all. I did know that he wa➢ IS November of 2009 by -- , by reading it in the I* representing, I think, the throe same clients in a 20 paper. 20 federal lawsuit challenging the plea agreement. 21 Q prior to that tine, was there any reason 21 Q Dld you become aware of the terms of that 22 whatsoever for you to have even suspected that any of 22 plea agreement? 23 [base claims being legitimately prosecuted by you and 23 A Yes. 24 Brad Edwards were being used for any improper 24 Q And what was your reaction when you learned 25 purpose? 25 that Jeffrey Epstein had been granted federal 50 52 A No. immunity -- not only for himself, but from -- for all 2 Q Evan as you sit here today, looking back in 2 of his co-conspirators -- against any federal 3 retrospect, la there anything that you can point to prosecution in exchange for an 1S -month state )all 4 and say, you know, I didn't reopens* it at the time, 4 sentence? but maybe that should have raised ➢ome suspicion? A It gas an outrageou➢ly wrong plea agreement. 4 A No. Tho idea that he wan conducting a Ronal 4 I was embarra➢sed for the -- that the V.S. Attorney's scheme had never -- I never had the slightest inkling / office and the state attorney in Palm Beach County that that was occurring. S would agree to such a deal. 9 0 No are bore taking your deposition today 9 Q What was the ➢ignificance of Brad'➢ 10 because, as you know, Jeffrey Epstein filed a lawsuit 10 involvement in attempting to undo that transaction on II against Brad Edward➢ accusing him of having been a II behalf of Jeffrey Epstein•a victims? 12 knowing participant in Scott Rothstein'➢ Rani 12 MR. LINK: Object to the form. 13 scheme -- 13 NITHESS: Nell, it was the right 14 MR. LINK: Object to the form. 14 thing to do. They were -- I didn't have any IS BY I . SCAROLA: IS direct involvement in that proceeding. As I If 0 -- of having been involved in the If understood it, as in Florida -- Florida has 17 commission of a variety of serious crimes. 17 a law -- as a criminal judge, I try to IS What was your reaction when Epstein sued IS uphold that and I ➢aw it unfold in front of la Brad alleging that he had participated in 19 me, because people who are victim have a 20 fabricating or exaggerating claims against Jeffrey 20 right to notice and to participate and to bo 21 Epstein? 31 present during key facets of the prosecution 22 A I read that in the paper and I was ➢tunned. 22 of the parson who is the wrongdoer, the 33 0 Why? 33 person who is Charged With a crime, 24 A It was outrageous. 34 particularly when it came to a sentencing 23 Q Had you come to know the manner in which 31 hearing. And the right of a victim to Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798349 53 55 1 attend the sentencing hearing and to bo I the court reporter would like to do. 2 apprized that it's coming and to have the 2 THE VIDEOGRAPHER: Going off the record 3 right to give input to the prosecutor is a ) at 10:45 4 right that I try to enforce, and I saw It 4 4A recess was had.) 5 unfold. And the state attorney's office S THE VIDEOGRAPHER: Going back on the 6 complied with that when I was on the bench, 4 video record. The time is 10:55 . 7 so I was somewhat familiar with that 1 CROSS-EXAMINATION 8 concept. We are dealing here with the 4 BY KR. LINK: 9 federal prosecution. I came to learn that 4 0 Good morning. 10 under federal law, there's a similar law to is A Good morning. 11 the one that we have under the state system. II 0 As you know, Scott Link, and 12 And so I thought it was very 12 representing the plaintiff, Jeffrey Epstein, in this 13 significant. It was unique for an attorney 13 matter. 14 to bo representing victims who had -- where is We, too, hope that your surgery is IS the perpetrator was prosecuted in a federal II successful and that you recover fully. If casco, and the attorney was trying to uphold is A Thank you very much. 17 the right of these victims to have 17 Q And we appreciate you being hero today. le participated in and boon consulted and given is During your direct examination, ono of the 19 notice for an opportunity to bo heard with Is things that you were talking about was the Pons" 20 regard to the sentencing of the parson who 20 scheme that Mr. Rothstein ran as part of the -- you II did those crimes to them. I thought Brad 21 called it RIM -- that's the law firm -- the 22 was doing something that I had never hoard 21 Rothstein firm, right? 22 an attorney do. It was a very courageous 2) A Noll, you said right. It wasn't part of the 24 act and ho should be commended for it. 24 RRA firm. IS 2S Q It wasn't? 54 56 I BY I . SCAROLA: I A No. 2 Q During the course of your decades of 2 Q So there wasn't any part of the cases or 3 practice, including the time you spent as a circuit 3 the omployeea or anybody at the Rothstein law firm 4 court judge, had you over oven hoard of a plea deal 4 that were participants in the Rothstein Ponsi schema. 3 where not only was the defendant himself 'amazed, 2 Is that your testimony? 4 but all of his unnamed co-conspirators were given 6 MR. SCAROLA: Objection, compound. 7 Imaunity for all of Choir unnamed crises? 7 THE WITNESS: I mean, there wore S MR. LINK: Object to the form. I employees that wore -- I don't consider it 9 THE WITNESS: No. 9 part of the BRA firm. It was a rogue IC By I . SCAROLA: 10 criminal activity that was outside the 11 0 Except as an effort to try to intimidate II purpose of the firm and -- I moan, I admit 12 and bully Brad Edward,' into backing off what Brad was 12 it was done by Rothstein. And certainly 11 doing both in attempting to hold Jeffrey Epstein 1) several of the attorneys were prosecuted. 14 civilly responsible for his wrongs and to challenge 14 Sena of sham, of course, were prosecuted, IS the plea that he had been permitted to enter, are you IS but having nothing to do with the Ponsi 14 aware of any reason whatsoever that would justify 14 scheme, such as Steve Lippman and Stuart 17 Jeffrey Epstein In suing Brad Edwards? 17 Rosenfeldt, as far as I know. And there II MR. LINK: Object to the form. II wore a couple of employees that were 19 THE WITNESS: No. 19 irplicated in connection with the Ponsi 35 MR. SCAROLA: Thank you. I don't have 25 scheme. And there wan even one or two 31 any further questions. 21 clients that More part of the Ponsi scheme. 32 MR. LINK: Mr. Borger, before we start 22 But maybe. being -- playing on 33 [roes-examination, do you want to take a 23 nocantics. I just don't consider it to be 24 break or aro you okay? 24 part of the firm. But I have acknowledge 33 THE WITNESS: I would go with whatever 21 those connections that you are pointing out. Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798350 57 59 BY RR. LINK: 1 particular who eventually wrote a book -- 2 Q Do no a favor. Toll the jury what a Banal 2 Sako -- something like that. No said that 3 scheme is. the reason -- ono of the reasons ho backed A A Ronal schema la -- is -- not that I know -- 4 out of investing money is because he wasn't I have learned much more as to what it is by reading allowed to see the file. 4 about the Rothstein scam. A Ronal scheme is where you 4 So I don't know if Rothstein actually ? solicit investors and you have something that you're 7 physically showed these three files to ➢ promoting with their money. You're soliciting their victims of his scam. But he certainly had * money and you are paying them a return on their money, physical possession of them and used then in 14 not from profits of whatever enterprise it, but you are IC soma way. 11 paying them from money that you are getting from II BY NR. LINK: 12 lnve➢tors after them. 12 O so you don't know the details, but you aro 13 so the business enterprise that you're 13 aware that Rothstein used the three pending cases 14 promoting, that you're soliciting the money for 12 II against Epstein and fabricated settle ants and 13 not really a legitimate business enterprise with a If information in order to try to keep his Ponsi scheme 14 purpose of being self-➢ufficient. It'➢ one that'➢ 14 alive? 12 funded by the continual investments or investments 17 MR. SCAROLA: objection. Secondhand 14 by investors and investors after them, and so it ha➢ is knowledge and compound. 1* no substance. So at some point it's got to fall It THE WITNESS: Again, when you say, I 20 apart because you can't keep bringing in now 20 know, I heard that. I don't know if it was IL investors and milking new Investors to keep 2L all three. And I don't know exactly how he 22 everything afloat and payoff the return to the other 22 used then In terms of -- since we didn't 23 investors. 23 have -- you know, the cases wore going by 24 0 so would you agree with me Mr. Rothstein 24 initials -- and I just don't know what use 25 wa➢ fabricating settlements and using those 25 he put then to. 58 60 I fabricated settlements to try to entice folks to give BY NR. LINK: 2 him money? 2 Q Can you tell me the first time you spoke to 3 A Yea. 3 Mr. Rothstein about ono or all of the three pending 4 Q Investors to give hie money? I cases against Hr. Epstein? A Yes. 5 A You know, not even sure I talked to Scott 4 Q And he would use actual, sometime➢, cases about the case➢. 7 that were pending at the law firm? Q You don't have a memory, as you sit here A Apparently that is what he did. I learned S today, of participating in group conversations with 9 that after the fact. the lawyers involved in the Epstein cases meting 10 Q Can you tell the jury what Mr. Rothstein 10 with Mr. Rothstein? II did with the three cases that were pending against IL A No. 12 Mr. Epstein? Now did Rothstein use them? 12 Q How often would you neat with 13 MR. SCAROLA: objection. Predicate. 13 Mr. Rothstein? THE WITNESS: I don't know exactly. I 14 A You know, I would see him in the hall. I 15 have read -- I have only read that he 15 would go co his office If I had a question. How often? physically had the flies of those cases, the 14 Sometimes I saw him ovary day. 13 case file➢, and I think had -- at ➢one point When you say moot with him, wo didn't IS had brought then into his office after IS have -- I moan, we did have -- we did have -- 19 hours. It don't know if they were regular or periodic, but we 30 I don't know what he did with them. I 24 did have meetings of shareholders in the firm. Not 31 don't know if he showed thew to investors or 21 to discuss specific cases, really, but just to -- 32 he was just familiarizing himself with the 22 just firm business. So I saw him probably everyday. 33 details, because in reading sone other 33 Q so mentioned the fire's shareholders. That 34 statements by people who were scanned, ono 31 was the small elite group of the senior lawyers of 35 of the things that -- well, one person in 25 the firm, right? Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798351 61 63 1 A Well, it was the small group of the senior I meetings to discuss the business of the firm, did you 2 attorneys. I don't know that I would call It elite. 2 talk about the financial aide of the business? 0 And you were ono of them? 3 A we talked about finances just in general, not 4 A Yoa. 4 really -- not numbers in terms of, for example, the 5 0 And you held yourself out to the public as S firm had revenue of k dollars this month. No, we 6 a shareholder? didn't have that type of discussion. 7 A Yoa. Q Mere you aware of revenue that the lawyers 0 What does it moan to bo a shareholder? 4 in the firm were generating? 9 A It could mean -- I guess the common s A No. 10 knowledge -- or the common connotation would be 10 Q You aro not aware that in 2008 the total 11 somebody that owns a piece of the conpany. 11 revenue was about 58 million? 12 0 Sure. If you own shares In the company, 12 A No. 13 right? 13 Q How such revenue a year did you generate, 14 A Right. 11 air? 25 0 Did you, in fact, own shares company? 15 A I don't remember. 26 A No. 14 Q Now such were you paid when you first 22 0 Yet you did hold yourself out as a 17 started? 28 shareholder? IS A Three hundred thousand a year. 29 A Yes. It Q Dld your salary go up when you were there? 20 0 I fact, I've road newspaper articles that 20 A No. 21 talk about you as a shareholder. Do you romanber 21 Q Did you have any clients when you started 22 A 22 at the firm? 22 MR. SCAROLA, Excuse me. 23 A Well, I had just loft the bench, so I didn't 24 Object to the form of the question. 24 have clients, no. IS 25 Q How such was your salary when you were on 62 64 BY MR. LINK: the bench? 2 Q Do you remember seeing newspaper articles 2 A About 150,000. 3 holding you out as a shareholder? 3 Q So you doubled your salary by going with 4 MR. SCAROLA: Objection. Secondhand 4 the Roth➢tein fir? 5 knowledge, hearsay. 5 A Correct. t IRE WITNESS: I don't remember Q Did you have any offers from law fires 7 seeing -- I can't recall an article whore I 5 Other than the Rothstein firm? was totaled as a shareholder. I wouldn't A No. Not offer➢. doubt it, though, because that's what I was 9 0 During the tine that you were with the 10 called. 10 Rothstein firm, you said chinos changed, the way -- II BY MR. LINK: Il the office size and things, of that nature, right? 12 Q That's what you were called and that's what 12 A Right. 13 you hold yourself out aa, right? 13 0 Mr. Scarola asked you about whether Chore 14 MR. SCAROLA: Sara objection. 14 was anything you saw that was a bit of a red flag at IS TIC WITNESS: Right. IS the time or when you look back. I want to talk to If BY MR. LINK: If you about the changes that you saw, okay? 11 O How many shareholders wore there In this 17 Can you describe for the jury how you IS roughly 70-lawyer firm? IS would gat to Kr. Rothstein , . office in October 2009? 19 A I think there were about 10. 19 What process did you have to go through? 30 Q And who were the other shareholders? 30 A You had to speak to -- Ms. Feiss, I believe, 31 A Stuart Rosenfeldt, Russell Adler, Lea 21 was hla aaaaaaa nt -- or scootody else to soo if Scott's 22 Streltfeld, Steve Lippman. There were others -- Mare 22 in, could you talk to him. 23 think might have been -- - pretty sure Hunk was a 23 Q Was his office just sitting out there on 24 shareholder. I just don't camber other names. 21 the main floor like your office la here at this law 35 Q And when you would have these shareholder 25 fi rm? Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798352 65 67 1 A Well, it was on the nain floor. It was -- 1 Q lust in the cannon areas you thought? 2 there wa➢ a corridor, and his office wa➢ behind the 2 A I didn't know that there were speakers or 3 door at the end of the corridor. 3 wiretaps or surveillance In people's offices. 4 Q Was there ➢ecurity guards? In order to get 4 0 Were you aware that he had a private 5 to his office you had to go passed security guards? S elevator in his office? A There w➢ security at tines in the firm. I MR. SCAROLA: Could we identify when 7 wouldn't -- keeping in mind I was in Boca most of the 7 this. awareness arose? s time around that time, ➢o I couldn't say whether there MR. LINK: Mr. scarola, we already * was security in the Fort Lauderdale office 24/7. But • talked about it being October 2009. 10 there wore a couple of ➢ecurity guards that -- they THE NITNESS: sorry, you talked 11 didn't wear uniforms, but they were bodyguard➢. That's 11 about -- you asked no how did you get in the 12 how I phrase theft. 12 office in October of 2009. 13 Q Rothstein had bodyguards? 13 BY MR. LINK: 14 A Yeah. • That's what talking about. 15 O Nave you ever had a bodyguard as a lawyer? 15 A I wasn't aware of electronic surveillance in 14 A No. 14 October of 2009. I learned that afterwards. 17 Q Dld you think it at all strange that 17 0 You were not -- 14 Mr. Rothstein had a couple of bodyguards protecting IS A No. Is him? It Q so while you were at the fi rm you were 20 A I thought it was strange, yeah. 20 unaware that there was electronic surveillance at the 21 Q I have heard that to get to his office that 21 firm? 22 you had to actually pass dawn this corridor and that 22 A Yes. 23 there were sort of obstacles and hurdle➢ in ardor to 23 Q Were you aware that his office had a 24 get in there. It wasn't as though you could walk 24 private elevator? IS down the main hallway, open his door and walk in. 2S MR. SCAROLA: When? 66 68 MR. SCAROLA: Object to the fore of the BY MR. LINK: 2 question. 2 Q sir, all of them questions are 3 THE WITNESS: If you're talking about October 2009, okay? 4 something like a mall would have an 4 A When you say a private elevator -- when I obstacle➢ for somebody -- they couldn't joined the fire in June of 2008, there was an elevator drive a car through a door at NaCy'S or 4 that Stuart Rosenfeldt and Scott Rothstein used that smoothing like that -- I don't remember any was in the building. It's not like in October of 2009 obstacle➢. 8 they had an elevator constructed. 9 BY MR. LINK: 9 There was an elevator that would -- it 10 • You don't remember there being an off -duty 10 wasn't in the public corridor where the other II sheriff in the building providing ➢ecurity? IL elevators were. 12 A Not really, no. 12 Now, whether this elevator serviced other 13 O Do you remoter the electronic surveillance 13 people in the building or not, I have no idea. I 14 equipment that Mr. Rothstein had at the firm? 14 never was on it. IS A Yes. IS Q You were never invited to ride on If O Describe it for us, If Mr. Rothstein's elevator? I A Re had -- there was a loudspeaker, and I A Well, you call it Mr. Rothstein's elevator. IS learned that it wa➢ a two-way one where he could listen IS It was in a location that accessible by Stuart and 19 to what you were saying. 19 Scott. Whether it could have been acce➢sible by 30 O In your office? 30 somebody else, I don't recall. I might have ridden OA 31 A No. That I didn't know. 21 the elevator, but I don't know that it was one that was 32 Q NOW about in the conference room? 22 specifically for then as opposed to any other tenants 33 A I didn't knew specifically whore. 33 in the building. 34 Q Whore would he be listening to people at? 34 It wasn't One that was publicly used. 25 A The common areas. 25 will agree to that. Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798353 69 71 Q You mentioned Hr. Kendall Coffey. Old you But before that, Scott's office, basically, 1 read hi➢ report on the layers of secrecy that he 2 you could just walk in on his office. 3 described as he wa➢ trying to ➢ay that what Rothstein I once walked into Scott Rothstein'➢ 4 was doing was unknown because of the secret world 4 office -- again, before the renodallm -- S that Mr. Rothstein created at the firm. Did you road 5 and -- within the Jewish religion, people, that report, ➢ir? 4 if they are devout believers, would do A No, I didn't road the report. 7 something called davening, and that's Are you familiar with what El talking praying. My father did that every morning. s about? And that would mean you had the Bible, the Is A No, I didn't know there was a written report. Torah, and you prayed and you chanted and II I did see Kendall Coffey on TV. No invited newspaper II you talked in Hebrew. 12 reporters -- he Malted reporters and a cameranan to 12 I walked in and Scott was davening. It 13 walk through the office. That I did see. 13 was ao -- excuse no. So it was almost an 4) Okay, tell ue -- tell the jury what it is 14 open door policy for most of the tine that I 12 that you saw. What was Hr. Kendall Coffey pointing 13 was there until this remodeling occurred. 14 out sheet the layer of Hr. Rothstein? 14 BY I . LINK: 17 MR. SCAROLA: Excuse ne. Could we set I7 Q Right. And that's what focused on, 'a a tine frame, please? 14 which la how things changed during the tine that you Is BY I . LINK: is were at the fins. 20 Q Has there more than one tine you saw 20 A Right. 2l Mr. Coffey on TV? 2L Q so he had an open door policy, than Chore's 22 A No, this was probably in November of 2009. 21 a renodallng and his open door policy vanished, 23 Q Can you ➢hare with the jury what Mr. Coffey 23 correct? 24 was showing the world about Rothateln'a inner 24 A To moat extent, yea. 25 sanctum. 25 Q Could you just walk up and go into hla 70 72 MR. SCAROLA: Object to the form of the office without being cleared first? 2 question. 2 A Sonatinas, yea. 3 THE WITNESS: He showed them that to 0 Into the remodeled space? 4 get to the office, you had to walk through a 4 A Yeah. It's happened. 5 corridor. TILL➢ is just what I can visually Q So you had that level of relationship with 4 Mr. Rothstein that you could go to the Fort Again, I do not recall obstacles, as 7 Lauderdale office, once it wan remodeled, and simply 8 you put it. walk ln, open his door and go see him without having Certainly, there weren't any security 9 to clear any ➢taff person or ➢ecurity to do that; is 10 guards Standing there when Coffey was 10 that right? 31 showing the newspaper reporters things. II A sonatinas that happened once or twice, and it 32 Then there was a door. The door -- you 12 happened with other people, too. It's just that 19 would open the door and there was the 13 somebody wasn't there. 34 office. What he was actually showing to a 14 You would walk dawn the corridor. And if Is TV audience in the way of security, you 15 somebody didn't say Scott's busy or acmothing like 16 really couldn't toll because there was If that, you just knock on the door and ho would say, 17 nobody there and he wasn't -- he couldn't 17 Come in, something like that. That may have 18 point to anything electronic. He was just IS happened a couple of [Irma. It wasn't because of m➢ 19 showing where the corridor was and wham the 19 or who I was. It was ju➢t the timing of M. It 20 doors were and there wa➢ a door. It could 20 wasn't like it was 24/? all the tine. 21 have boon a double door or not. And that 21 SO I will agree it was different at the 22 Was -- again, that was -- as I said, the 22 tine period you are talking about than before in 23 office had been remodeled. 33 terms of access. 24 How soon before that -- I don't 24 In your 40 years of being a lawyer, have 25 remember when that remodeling had occurred. 23 you ever seen a law office like Mr. Rothstein's once Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798354 73 75 I he romodolod it? I him need two bodyguards to protect him? Who was 2 A You moan the physical layout. 2 after him? Q Yes, air. A I don't know. A To ➢one extent. 4 MR. SCAROLA: Objection, compound. Are you talking about the decor in the S THE WITNESS: I don't know. I f office itself? don't know. 7 Q Let's talk about the whole thing, the BY KR. LINK: 4 process to gat to that office, where he wont from Q Did you ever go to his house? * being doors open to a secluded office. A Yes. le A Wall, I mean, look, I worked for Mel so Q What was hla house like? 11 Greenberg who founded Greenberg Traurig, which is now II A It was a lavish home. It wasn't the biggest 12 the largest firm in the world. I couldn't just knock 12 home in the community. He lived in a very high-end 13 on Nal Greenberg's. door and walk in. I had to go 13 cowounity on the water off of Las Olas Boulevard. It's 14 through -- I had to go through -- not security, a➢ you 14 kind of a zero-lot-line community. There's not a lot II would call it, but I had to go through hla secretary or Is of land outside the homes. So it was a very lavish 14 I had to make an appointment. He didn't have an open 14 la door policy. 17 Q Hawaii:Iabout 66 million for it? Q Did Hr. Greenberg have bodyguards? la A I don't know what he paid. A No. It Q Do you know what kind of cars he had? 20 Q How big was his office? 20 A Well, I know he had a Rolls-Royce and he had 21 A He had a big office. 21 a Bugatti. 22 0 How big, roughly? 22 Q What's a Bugatti? loll the jury what a 23 A I can't -- the conference room was bigger Bugatti is. 24 than this conference room. 24 A It's a very expansive sports car. 25 Q And how about Kr. Rothateln's office 25 Q Approximately how much to a buy a Bugatti? 74 76 1 compared to this conference room? A Half a million. 2 A It was a little bit bigger. Obviously it was 2 Q What other kind of care did he have? 3 configured differently. Thin isn't a rectangular 3 A I don't know what other care he had. I moan 4 office. 4 I know he had other cars. I don't know -- I worked for Marty Fine and Bernie Q Did you ever ➢ee his Ferraris? 4 Jacobson in Miami. They didn't have an open door A No. / policy. O His Lamborghinis? • So their office was set up in the ➢ane way A No. 9 as Rothstein? 9 O Did he have a boat? 10 A You are talking about an open door, 10 A Yea. Il okay. Open door can be different things. You still 11 Q What kind of boat did he have? 12 had to make -- you ➢till had to speak to their 12 A Ho had a -- I don't know Cho make of it. It 13 secretary to got in. You didn't have -- no, there 13 was about 9O-foot -- I guess call it a -- not la weren't bodyguards. Not that there were bodyguard➢ la aura if you would call It a yacht. But it was a 15 everywhere and all the tine. 15 90-foot boat. If There were people -- security people in If Q I would call 90-foot a yacht. 17 the Roth➢tein firm. I didn't see that in other 17 A I wean it didn't have a sail -- it didn't IS firma, no. IS have a west. So you could call it a yacht. A motor 11 Q Are you aware that Nr. Rothstein traveled 19 yacht I would call it. 20 with bodyguards when he would go to meetings? 20 0 So it was 90 feet long? 21 A Not specifically, no. I wouldn't be 21 A Right. 32 surprised, but I didn't know that. 22 4) Did he have a crow or did he drive that 23 Q It wouldn't surprise you if he did? 33 boat himself? 24 A No. 24 A No, he didn't drive it himself. There wan a 2s Q What was is about Mr. Rothstein that made 2s captain. not ➢ure if there was a mato or anybody Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798355 77 79 else that was associated with the boat. I think there that will give plaintiffs money for an a➢➢ignment of 2 2 the potential recovery, right? 3 Q Any other lawyers in Fort Lauderdale that A Right. 4 you knot. have the 56 million home and the 90-foot 4 Q Were you aware that Hr. Rothstein was doing 5 boat behind it? S something like that? 4 MR. SCARALA: Excuse me. IM going to 4 A I had no idea. 7 object. No proper predicate to the Q Did Hr. Rothstein over talk to you about question. Assumes facts not In evidence. e the cases you were working on and what type of THE WITNESS: I don't know. I counts -- legal counts you had include! in your 10 BY MR. LINK: 10 complaint. 11 0 Can you tell no ono other lawyer in Fort 11 A No. You aro talking -- no, ho didn't. 12 Lauderdale that has the Bugatti, Ferraris, 12 Q Would there to a difference in -- from ➢ort 13 Rolla -Royce, Lantorghlal, two bodyguards, a very 11 of this factoring standpoint -- the Pons,. scheme 4 large house on the , and a 90-foot boat? 14 standpoint between a tort count and a non-tort count 13 MR. SCAROLA: Objection. Improper II from a settlement ➢tandpoint? 14 predicate. kaaLlilaa facts not in evidence. 14 A Nell, I. not sure I ROCS Whit you're talking THE WITNESS: I don't know. 17 about. I don't know what you mean by the difference. Is By KR. LINK: is I know what a tort claim is. A tort claim 0 Do you know of anyone? If is ono where ➢omebody is personally injured, and a 20 A No. 20 non-tort clam would be not involving a personal 21 Q Whore did the noway coma from for tl injury. 22 Mr. Rothstein to buy all of those things? 22 Q Is there any difference in the law and the 23 A I don't know. 23 regulations on structured settlements between tort 24 Q Did you ever ask him any questions about 24 claims and non-tort claims? 25 where all this stuff cane from? 25 A No. That, I don't know. 78 80 A No. Q Mr. Rothstein, during the tine that you 2 Q While you were working at the Rothstein 2 were employed there, I understand, bought a 2 firm, how many multi-million-dollar employment camas a restaurant called Bova. Are you familiar with that 4 did y 4 restaurant? A I don't know of any. A Yes. It was downstairs in the building. 4 Q In the practice group that you Were in -- 0 Did you ever eat there with Mr. Rothstein? 7 you were in tort practice group? 7 A Yes. S A No. No, I wasn't in the tort practice group. Q Can you tell no any other restaurants 9 0 Okay. 9 Mr. Rothstein owned other than Bova? 10 So in the tort practice group, though -- 10 A Nell, Bova had -- I believe Scott had an II you are familiar with, right -- how many 11 ownership interest with Tony BOVa in the Bova that 12 multi -million -dollar employment cases dad they 12 you're talking about, which was in the lobby of the 13 wattle during the time that you were employed at 13 office building. Tony Bova also had a restaurant here 14 RRA? 14 in Boca called Bova. And I don't know if Scott had an 15 A I don't know. 15 interest in that. If 0 Any? If 0 Did the firm have boxes at sporting events? I/ A I don't know. I didn't hoar of any. 17 A That, I don't know. No had -- I mean, I have II Q More you aware that Mr. Rothstein was -- IS used tickets, but not in a box. 19 let's not call it a Reail scheme -- but that he was 19 0 Not in a box? 30 using canes and was looking to generate moray to pay 30 A No. 31 off the plaintiffs ahead of time? 21 4) Have you heard that Hr. Rothstein had very 32 A After the fact. No. 32 expensive boxes at sporting events? 33 Q But not while it was happening? 33 MR. SCAROIA: Objection. Hearsay, 24 A No. 24 secondhand knowledge. 21 Q You know there aro twainaaaaa out there 31 THE WITNESS: not sure. I don't Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798356 81 83 I remember that. I overwhelming evidence. It doe➢n't even mean that you 2 BY NR. LINK: 2 have -- that it's more likely than not that your cane 3 Q You talked earlier about Bill Scharer. ) la a winner. It means that you have something. It 4 Re'➢ a friend of yours? 4 mean➢ that you have acme evidence. 5 A No, he's not a friend of nine. 5 Q In your plaintiffs practice, you have f 0 As a lawyer did you have respect for him? 4 brought -- filed complaints against different 3 A Yeah. I heard of Bill Scharer. Bill Scherer 1 defendants? 4 is a prominent Fort Lauderdale attorney who wa➢ a 0 A Sure. 3 client. His firm Conrad Scherer -- yeah, I've 1 Q And before you would file that complaint, 10 practiced here since 1975. And I had a number of cases 10 you would make sure that you had some information II in Port Laude , even though the offices I worked II before you would file it, right? 12 out of wore in Miami. And I have heard of the Conrad 12 A Right. 13 Scherer firm throughout my practice. II Q Would you note every single fact that 14 4) You said one of the things in your direct 14 existed at the time you filed it? Is examination that made you feel comfortable about is A No. It joining the Rothstein fire was that Bill Soberer was 14 Q Would you know maybe even half of all the 13 a client. 17 information you might learn through the course of the 14 A Right. Is case? It Q Because of his stellar reputation. It A No. 20 A Right. 20 0 So what you really would noel to have is -- 21 Q Does he continue to have a stellar 21 like on a scale of ono to ton, what level of 22 reputation? 22 information would you need to have? 23 A Nell, he's -- there's some bad press about 23 A Ono. 24 him now -- occurring now. This year. 24 0 For probable cause? Ono? 25 Q How about in 2009? what wan hla reputation 25 A Yeah, you need to have sone sense that the 82 84 1 like? I client -- what the client is telling you is provable. 2 A In 2009? 3 0 oh-huh? 3 MR. SCAROLA: Co ahead. I didn't mean 4 A I don't know what his reputation was like in 4 to interrupt. 3 2009, specifically. 3 THE WITNESS: Some degree of proof. 4 Q 2009 is when Kr. Scherer filed a lawsuit 6 MR. SCAROLA: . going to voice an 7 against Scott Rothstein and others related to the 7 objection to the line of questioning to the S Foss,. scheme he wa➢ running. S extent that it call➢ for legal conclusion➢ 9 A Exactly. Scherer became probably the moat 9 that invade the province of the court. 10 noted attorney to sue the Rothstein firm. 10 MR. LINK: Okay, this is a discovery 11 0 on your knowledge of Mr. Scherer, do 11 deposition. I only objected to the form for 12 you believe he would have filed that lawsuit without 12 you, because we will be doing the objections 13 having probable cause to do so? 13 for trial, and I would ask that you do the 14 MR. SCAROLA: Objection. Hearsay, 14 same thing. You don't need to make your 15 secondhand knowledge, predicate. 15 trial objection➢ now. You know they're 14 THE WITNESS: I don't think that Bill If preserved. I? Scherer Mod that lawsuit without probable 11 MR. SCAROLA: Thank you. Ii cause. I think ho had probable cause. IS By I . LINK: 19 BY NR. LINK: 19 0 So, Hr. Berger, I may have steppe! on you 24 Q Can you tell the jury what the term 20 when you were speaking. But I think you said on a 21 probable cause means, please? 31 scale of one to ten it takes a ono; is that right? 22 A It means -- the probable cause means that 22 A Yes. 23 there's a -- there's -- this is not going to be very 23 Q When you were evaluating probable cause as 34 informative -- but a colorable claim. You have 24 a lawyer, were there Cases that you thought were 35 something there. Doesn't mean that you have 25 going to turn out better than they, in fact, did? Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798357 85 87 A Yes. defendant's side, right? 1 Q And probably ➢one casea turned out better 1 A Right. 3 than you thought they might otherwise, right? Q when you were a plaintiffs lawyer [or a 4 A If I was fortunate, yeah. 4 client, were you aggressive and zealous for than? 5 0 Somatimea. not aura I have ever had S A Yea. any of those. Not often, right? Usually ca➢es get Q when you represented a defendant, were you 7 worse as they go along? aggressive and zealous for then? 4 A Or at least no better than you thought they A Yes. I. Were. 1 0 Would it be your expectation that 10 Q I got it. Did you look at the complaint, Is Mr. Epatein'a lawyers, on his behalf, would have been II that you have as Exhibit 1 In front of you that II 2.0.110.32 and aggressive in defending him? 12 Mr. Scherer filed In November 2009? It's called the 12 MR. SCAROLA: Objection. Calls for 13 Razorback Complaint? 13 speculation. II A 14 THE WITNESS: Y02. 13 4Plaintiff'a Exhibit Norther 1 was marked Is BY KR. LINK: 14 for identification.' 14 Q You don't find anything inappropriate, 17 0 You have never seen that before? 17 illegal about Hr. Epateln * 2 lawyer being zealous and II A No. a aggressive, do you? It 0 Would you do ma a favor and turn to page 12 it A No. 20 of 147? 20 Q In fact, we've heard that your law firm -- 21 A Okay. 21 Mr. Edwards was aggressive and zealous, right? 21 0 Why don't you just read paragraph 40 for a 21 A Yea. 23 minute, and I an going to ask you a fat questions. 23 0 And that's what you would expect him to do, 24 A Okay. 24 right? 25 Q If you look -- you know that this is the 25 A Right. 86 88 lawsuit that Kr. Scherer filed, right, on behalf of 0 Just like you would expect if you were 2 Razorback? 2 defending Mr. Epstein. Would you have boon zealous 3 A Right. 3 and aggressive in his defense? 4 Q And you ➢ee what Mr. Scherer alleges here 4 A Yea. 3 is D3, a potential investor, was shown 13 Bankers Q Would you have -- strike that. 4 Boxes of actual case files in Jana Doe. Do you see I will coma back to it. 7 that? What you observed during the tine that you A That's what it says. were at Kr. Rothatein's firm, can you point to Oft0 0 Do you have any reason to suspect that thing that Mr. Epstein's lawyers did that you 10 Mr. Scherer didn't write that down properly? 10 thought vas unethical? A I don't know what Mr. Scherer investigated or A No. 11 what the basis for him making this allegation is. 11 Q Can you point to one thing Hr. Epatein'a 13 Q What I would like to know is, was there 13 lawyers did that you thought was illegal? 14 ever a tine that Mr. Rothstein offered 5200 million 14 A You aro talking about LA defending against -- IS dollars to settle the three cases being prosecuted by 15 O Yea. If the law firm you gore a shareholder in? If A -- the throe cases? I/ A Not to my knowledge. la O Yes, air. IS Q Did Hr. Epstein, during the tine you were a IS A No. 1/ shareholder at the Rothstein firm, ever offer 19 42 and are you familiar with the law firm that 20 530 million for a pre-suit settlement? 20 was representing Mr. Epstein while you were involved? 31 A Not to my knowledge. 21 A well, lack Goldberger and the Luttier firm, I 32 Q You mentioned earlier m direct that a 22 believe. 33 lawyer is duty-bound to be zealous, right? 33 0 Bob Critton. 24 A Right. 24 A Critton. 23 Q That's on both on plaintiff's side and the 23 0 Dld you know Bob Critton? Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798358 89 91 A Causally. A I don't know. 2 0 What was Kr. Crltton's reputation in -- 2 Q How old was Jane Doe? 3 A It's a good firm. I know the firm. A I don't know. 4 0 It'➢ an excellent law firm, correct? 4 Q When did you first moot..? 5 A Yes. S A I don't know -- I don't know which ones I 6 0 Ara you aware of Mr. Critton's skills as a 4 mot. I can't recall. I would have known at the time. 7 lawyer that you -- from when you were either on the • And I don't know how many, either. I know there'➢ only bench or Ln the practice of law? 4 three. But I can't really recall if I met ono, two or 9 A No, not really. I think I nay have -- I s three. 10 think I mot him during the Ep➢tein deposition. But le Q So you didn't moot all of them? II that might have bean the first time I mot him. II A I may have. I may have. I just don't 11 0 Now about Kr. Goldberger, Jack Goldberger? 12 recall. 13 A Probably the first time I mat him, too. 13 Q Let's talk about III. for a minute. What 14 0 Did you do any research on Mr. Crltton or 14 do you remember about her? 39 Mr. Goldberger? 13 A Again, I don't know which ono was III. which 26 A No. I didn't do research. 14 one was .314 laic'. 27 0 Was there anything Kr. Critton did during 17 Q You were ■.'➢ lawyer, weren't you? 30 his representation of Mr. Epstein that you thought 1➢ A Yes. 19 was illegal? It Q And you told u➢ that you evaluated the 20 A No. 20 financial, right, Narita of her case' what that case 21 0 Unethical? 2L was worth in compen➢atory damages. Isn't that what 22 A No. 22 you told the jury? 22 0 Improper? 23 A Yea. 14 A No. 24 Q So I want to know what was it about III.'a Si 0 Now about Kr. Goldberger? 25 case -- I want to go through what the pros and the 90 92 A No. I con➢ were that caused you to be able to render your 2 O Do you know Mike Borman? 2 opinion to this jury about the financial value of 3 A I've heard of him. 3 that case. And the only way I know to that is to 4 O What have you heard of Mike Borman? 4 talk about III. A He has got a good reputation. So let's talk generally, okay? Rave you 4 O Mr. Berson was ono of Mr. Epstein'➢ lawyers 4 handled alleged sexual abuse cases? at the time, right? 7 MR. SCAROLA: I am going to object to A I don't know what his personal involvement • the predicate as, argunentive. Move that It was. His firm certainly represented Epstein. 9 be stricken. 10 Q Can you tall ma of anything that Mr. Berman 10 I have no objection to have you handled Il did that you aro aware of in representing Mr. Epstein IL sexual abuse cases. 11 that wan unethical? 11 THE WITNESS: Could you -- II A No. 13 BY MR. LINK: 14 O Illegal? 14 Q other than the throe cases that you were 15 A No. 15 involved with at the Rothstein firm, have you 16 O Inappropriate? 14 represented clients, either plaintiffs or defendants, I/ A No. I7 involved in alleged sexual abuse? IS Q Do you know Joe Ackerman? No's at the IS A Never a minor. And not the degree that was la Fowler White Elm. I9 involved hero. I represented several wem➢n -- adult 30 A No. 20 women LA an employment context who were touched, 21 Q During the time that you were at the 21 seduced, not -- not in the sense of violently raped, 22 Rothstein firm and representing E.M. and Sane 22 but talked into having sox with the boas. But -- so 23 Doe, tell me how old was M.? 23 that's -- verbally abused. But again, not minor -- 24 A I don't know. 34 Q Was that before you started at the 25 Q How old was L.M.? 25 Rothstein firm or aft➢r? Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798359 93 95 1 A Yes, before. 1 0 And what happens -- and things that they do 2 Q So before you took on the representation of 2 afterwards -- that they are touched -- is information 3 ., E.N. and Jane Dee, your only experience with ) you would evaluate in evaluating their case, wouldn't 4 alleged sexual abuse were three -- 4 you? 5 A No, not three. It might have been alx to 12 5 A Yes. 4 woman la that circumstance. 4 Q So their history before the event and after 7 0 Slx to 12 women in that circumstance. 7 the event la relevant to an evaluation of their a A Under an employment setting. a emotional damage. Would you agree with that? * Q And you represented the wcmen in that s A Yes. IC setting? Is Q And lf you were defending that cospany II A Right. II instead of the 6 to 12 women, would you have done all 12 Q And sued whoever the boss was, right? 12 you could to discovery what emotional stress they had 13 A The company. 13 been through before the incident? II 0 The corpany. II A Yea. is By the way, did you explain to those women 12 0 And would you have done all you could to 14 before you undertook their representation that their 14 discover what emotional di➢tre➢➢ they had been 17 life would be examined under a microscope? 17 through after the accident? IS A Yes. IS A Yea. IS Q You know that before the case is filed, IS Q How would that lapact the evaluation of the 20 right, that that's going to happen? 20 case? Tell the Jury how that information impacts al A Right. 21 when you're evaluating the financial worth of a case, 22 Q }barn nothing surprising to you as a 22 please? 23 lawyer about that, is it? 23 A Nell, it has some significance. You try to 24 A No. 24 analogize it to a person that has a pre-existing 25 Q If you were defending whoever that company 2S physical injury. And the question la whether this 94 96 I was, would you have put the 6 to 12 wcman'a live! 1 particular incident perpetrated by this particular 2 under a microscope? 2 parson aggravated a pre-existing condition or didn't. 3 A Yea. 3 On the other hand, you take your victim as 4 0 That's your Job, right? 4 you find her. And if somebody has a pre-existing a A Right. 5 back condition and you drive your car into their car 4 Q To learn everything you can about their 4 and you aggravate thole pre-existing back condition, 7 sexual history? 7 you are still responsible for having done that. S A I don't know about that. Depends on the S So there is some relevance. It's a t case, what relevance it has. t question as to how much relevance it has for or 10 0 But it might have relevance, right? le against the person bringing the case. Sometimes 11 A Theoretically it might. ll if a -- well, it could have a positive effect, it 12 0 What if the only claim that was Deming -- 12 could have a negative effect, it could have no 13 was the claim you were making mental anguish or some 13 effect. 14 type of physical injury? 14 Same with the person's post-event IS A Mental anguish. It wasn't physical injury. IS experience: could have a positive effect, could have 14 Q In evaluating those cases, things that 14 a negative effect. It's a complicated ease-by-ease 11 happened before the unwanted touching by whoever I7 analy➢i!, and it's ➢orething that you would look le their boss vas, something you would look at in le into. 1* evaluating the lamaet of that event on their mental IS Q It absolutely is case-by-case, isn't it? 24 health? 20 A Yes. 21 A Yes. 21 Q Two people going through the exact sale 22 4) So what happened to them before the 22 unwanted sexual abuse could have a totally different 23 accident la relevant to determining what emotional 23 emotional reaction to it, right? 24 damages they nay have suffered. You agree with that? 24 A Right. 23 A Right. 23 Q If you lined up 10 manor, who -- or 12, like Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798360 97 99 1 you nay have represented, who had an unwanted sexual agreement unsealed. That's something I spent a lot of 1 experience, they may all have had different emotional 1 time on. 3 reaction➢ to it, correct? I attended, I believe, at leant two 4 A Correct. 4 hearings In front of Judge Colbath -- 5 Q And one of the things you try to evaluate S • To get that unsealed? on both the plaintiff's ➢ide and defense's side is A -- to get that unsealed. / what impact that particular event had on that per➢on 7 • What wan the purpose in getting that • front an emotional damage standpoint. Do you agree • unsealed? • with that? • A So that it could be used as evidence because IC A Right. IC It was sealed. I believe we already had a copy of it, II Q And I know you don't remember whether you 11 but it wasn't something that we could disclose because 12 met all three of the Epstein-related clients in 12 it had boon sealed. 13 parson, but did you remember talking to them on the 13 Q Disclosed to whom? Who did you want to I4 phone? 14 disclose it to? A I don't remember that, no. 15 A To a jury or to third parties for use In Q Tell Oa what you knew about the background 14 investigation. 17 of before she mot Mr. Epstein? I, Q What was it about the non-prosecution A I don't remember. I don't remember anything 14 agreement that a third party would need to do an It specific about our particular clients in tome of their 1* Investigation related to these three folks? 20 backgrounds. 20 A I don't know the specific point. I know that 21 0 so when you wore at the Rothstein firm in 21 we wanted to get the document unsealed. It had 21 2009 and you wore working on these three camas, did 22 Information in it that was important to us. 23 you sit down and do a list of the strengths and 23 Q Did you want it for press purposes? 24 weaknesses of each of these individual cases? 24 A No, not for press purposes. 25 A No, I didn't do that. 25 Q Aro you aware that Mr. Edwards communicated 98 100 Did you do an evaluation of each of the with the press while ho wan at the Rothstein firm 2 throe canon at that time of what you thought the 2 about the Epstein cases? 3 settlement value was? 3 MR. SCAROLA: Objection. Assuan facts • A No. • not in evidence. s Q Did you do an evaluation for each of the s THE WITNESS: Yes, I believe so. • throe individual canon to determine from a jury • BY I . LINK: 7 standpoint how much each of them individually might 7 0 Were you aware that one of those clients of • be awarded? • the Rothstein firm actually did a TY interview? 9 A No. A I don't recall that. 10 Q And when you wore doing -- it sound➢ like 10 0 An you sit hero, you don't remember 11 your role in those cases may have been limited. Was 11 Mr. Edwards having ono of his clients on an NBC 12 it? 12 interview? 13 A Yes. 13 A No, I don't remember that. 14 Q How much time during 2009 while those three 14 Q Dld he consult -- did Mr. Edwards consult 15 folks were clients of the Rothstein firm did you 15 with you before he would talk to the press about the II spend on M.'s case? 14 Epstein cases. 17 A I can't quantify by the number of hours that A No. IS I spent on the cases. I didn't work on them Cull-time IS Q Dld you over talk to the press about the 19 and I didn't work on them every day. There were 11 Epstein cases? 20 certain specific things that I did. 30 A Well, yes, when I -- I think two of the 31 Q You attended a couple of hearings? 21 hearing➢ that I attended, when I loft the courtroom the 32 A Yeah, I attended a couple of discovery 22 pre➢➢ was there out in the corridor, so reporters asked 23 hearings, and I also -- I was also involved -- and it 33 to questions on Camera. 24 was my relpon➢ibility to appear in front of the 24 Q You are not required to answer them, aro 25 criminal court to try to get the non-prosecution 35 you? Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798361 101 103 A No. A No, no. They had already been brought into 2 Q So what made you decide that you wanted to 2 the case -- into the firm. I was not doing intake. Wo 3 answer the reporters' questions akout the Epstein already had the ca➢es. 4 cases? 4 Q So whether the➢e cases financially were 5 A I was an➢wering que➢tion➢. weak or ➢trong, you didn't do any work to reach an 4 Q Knowing that it was going to be in the 4 opinion; is that true? 7 press? 7 A When you aay I didn't do any work, I did 4 A Yes. O reach an opinion. If you were a young -- if I • Can you toll ma, how old was III. when she • represented an underage young girl who was trolled by a la met Mr. Epstein? 10 billionaire's assistant and selected because she didn't 11 A I don't recall what her ago was, other than 11 have any tattoos and she was white and she was young 12 she was a minor. 12 and attractive and ➢he was lured by money to go to the 13 0 Were you aware of mother Doing a 13 guy's house and help him masturbate, I don't need to 14 prostitute and III. working with her before ➢he met 14 know a whole lot more to tell me that that's a 13 Mr. Epstein? 13 significant case. 14 A I seen to recall that ono of the young woman 14 Q So were you aware that III. actually 17 we represented, her mother was a prostitute. I don't 17 brought E.N. to Mr. Epsteln's house to be paid fast Is know which one it was. And I had never heard before la money to give him a manage? I* you mentioned it just now that there was a statement A Well -- 20 that she worked with her mother as a prostitute, no. 20 0 Did you know that, air? 2l Q Were you aware that all three of the 21 A I don't know whether what you said is true, 22 Rothstein clients were paid for every tine they 22 and I hadn't hoard it before or that I can recall. 23 provided Mr. Epstein with a massage? 23 Q Dld you know that ■. brought Jane Dos to 24 A Not as specific as you say it. I knew 24 Mr. Epstein's house and that III. was paid for doing 25 generally that was part of the allegations that they 25 that? 102 104 I were paid money, or given money by either -- personally A I don't know that that happened. I nay have 2 by Epstein or by one of hla aaaaatans. I couldn't say 2 heard that as part of the case. I don't recall that 3 that I heard that it we➢ every time, but that it was 3 4 all three. • 4) Are those all facts that you would take • Q Doe➢ it surprise you that all three of have 5 Into consideration in evaluation of the strengths and • testified that every single tine they wont to see • weaknesses of the cases from a financial standpoint? 7 Mr. Epstein to give him a massage they were paid? A If I was working the case -- S A Would it surpriae me? I have no opinion S 0 Yea. t about that when it -- If it would surprise ma. A -- and I -- I would want to know If that 10 Q Were aware in 2009 that all throe of the 10 haft:ono!. Il Rothstein clients solicited other people co cone Q Right. 12 provide massages to Mr. Epstein and were paid a 12 A What significance it would have, not 13 solicitation fee? 13 sure. 14 A So these minor girls that you are saying 14 0 But you would take it Into consideration, 15 solicited other minor girls? 15 wouldn't you? 14 Q Yea, and brought then to Mr. Ecutein'a 14 A I would take it into consideration. To no house, told then what they were going to do, and were If what it does is It enhances the reprehensible nature of IS paid for bringing them? Did you know that? IS what Epstein did, that he would have young woman do 19 A No, I never heard of that. IS this typo of thing, because legally they couldn't be 20 Q Never heard of that, okay. 30 consenting to what they were doing. 31 Did you read statement to the FBI 31 22 as part of your evaluation -- let no go back for a 23 A So it doesn't -- to me it does not negatively 23 second. 23 affect the economic value of the case or lessen the 34 Did you evaluate these cases from a 24 damage to the young women if they did what you say. 23 financial standpoint at all? 35 Q So if they had already been involved in Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798362 105 107 i prostitution, would that impact your view of this I not sitting here a➢ a judge, are you? 2 reprehensible conduct of masturbating in front of 2 MR. SCAROLA: Objection, argumentative. 3 them? 3 THE WITNESS: Of course, no. 4 A You are talking about children, so no. 4 BY I . LINK: 5 In fact, it'➢ Worse. You're dealing with 5 Q You haven't been a judg➢ for over 10 year➢, 4 troubled, damaged, young -- if what you aay i➢ 4 right? / true and the girl -- let'➢ assume that the girl was 7 A Of course. That'➢ correct. You are asking • a paid prostitute a➢ a minor and Epstein Caro➢ along a my opinion. • and he does what he doe➢ to than, it's even worse. , Q And asking about while you Were 10 Q Masturbating In front of them? la amployof at the Rothstein firm. ?hat'➢ what 11 A It'➢ oven Worse, because he'➢ taking a II interested in. interested in these three folk➢. 12 damaged child and Making her even more damaged. 12 And so is it your opinion that if you are a 13 Q You didn't meet with any of these three to 13 17-year-old girl involved in prostitution that you 14 evaluate whether they wore more damaged, did you? I4 cannot to hold accountable for the deci➢ions you II A Are you asking ne hypothetically whether la make? I➢ that your to➢timony? 14 these things would be thing➢ that you would take into 14 MR. SCAROLA: objection, argumentative. I/ consideration? 17 THE WITNESS: Kell, you can, but not in IS 0 Yea. la this context. These young woman wore 19 A And ■ pointing out, yeah, they would be, Is manipulated by this guy and he trot 20 and they could ➢Mane the case a➢ opposed to detract 20 advantage of th➢n, and they can't be hold 21 from it. 21 responsible for that. 22 0 Could b➢ a &optima, could b➢ a positive. 22 And the fact that they have a past, as 23 A Could b➢ a negativ➢, could b➢ a positive. 2) you described it, nay -- nay make what he 24 Q D➢pends on what spin you put on it. 24 did even ➢ore reprehensible. 25 MR. SCAROLA: Object to the form of the 25 106 108 1 qu➢ltlon. I BY I . LINK: 2 THE WITNESS: I don't 14110W about a 2 Q Or make it 3 spin. R➢ality doesn't have a ➢pin. 3 A May make it less. 4 BY NR. LINK: 4 Q But it's a subjective evaluation, isn't it? a 0 I agree with that. So ■ asking you -- s A By a lawyer, or course. It's subjective and 4 it's your testimony -- 4 you try to build objectiv➢ facts. You hire expert➢, 1 A And the truth doesn't have a spin. / you hire a psychologist to review the people and you 5 0 IMI a➢king if it's your opinion that if you S build this a➢ a factual case. 9 are sexually active, a prostitute, your mother i➢ a • 0 And you are exactly right. And the reason 10 prostitute, you have boon homeless, your parents are 10 I ➢aid subjective i➢ because you could take 10 really Ii drug addicts, that the trawna of watching an older II competent lawyers t0 evaluate each of these throe 12 man masturbate in front of you when you are getting 12 case➢ and all 10 may coma up with a different opinion 13 paid and voluntarily come back dozens or time➢ is 13 of whether the ca➢e➢ are strong, median of weak. Can Id more aggravating than all of the pr➢condition➢? 14 you agree with that? 15 MR. SCAROLA: Object to the form of the 15 MR. SCAROLA: Objection to form. 14 qua:Miro. 14 THE WITNESS: No, I don't agree with 11 THE WITNESS: Fir➢t of all they 17 it, becau➢e if you have a case where a young IS can't -- under the law they are not IS woman, regardle➢s Of the Circumstances, is 19 voluntarily doing anything. The law doesn't 19 brought into a billionaire's hone by 20 recognize that. 20 herself, by herself, not with her parent➢' 21 You know, I sat as a judge on capital 21 knowledge, but by herself, one-on-one, 22 rape case➢ where people tried to defend and 22 there's nothing about her pa➢t that would 23 said consent. There is no con➢➢nt. 23 make that a bad case. 24 BY LINK: 24 BY KR. LINK: 25 0 Thi➢ isn't a capital rape case and you are 25 0 I didn't ➢ay it was a bad case. I said in Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798363 109 111 evaluating the economic damages, would 10 lawyer➢ in Nurik or Rothstein -- did they feel bullied or 2 evaluating the fact➢, could they reach reasonably 2 threatened by Epstein lawyer➢? 3 different opinion about the dollar value of the MR. SCAAOLA: Objection, predicate. 4 ca➢e? 4 THE WITNESS: You are assuming that A It would just be how many more zero➢ you Nurik and Rothstein worked a➢ attorney➢ on 4 would add to the case -- to the value of case. That's 4 these cases. I don't know that they did. 7 all. Adler was tangentially involved. I Q That'➢ your opinion of it, right? ▪ don't think that anybody was bullied by A That'➢ my opinion, exactly. • Epstein. 10 Q By the way, are you always right In your 14 BY MR. LINK: II opinion? 11 Q And do you think any quality of the MR. SCAAOLA: Objection, argmmentive. 12 representation of the three clients while at II THE WITNESS: No, not always right 13 Roth➢tein wa➢ impacted by the aggre➢sive, zealous in my opinion. 14 behavior of Mr. Epstein'➢ lawyers? Is BY MR. LINK: 15 A No. 14 Q You mentioned when you Nero a trial court 14 Q Is Ws. Edward➢ a tough, hard-nosed 17 judge you were rever➢ed a few time➢. 17 lawyer? II A More than a few times. A Yeah. IS Q How many tire➢ wore you reversed? If 0 Tried criminal caaaa? 20 A I don't know. I made a lot of deci➢ion➢ and 20 A Noll, I a➢➢me so. You know, I -- until -- 21 a lot of then were affirmed and a lot of them wore 21 until you mentioned it, I forgot that Brad had been a 22 appealed. I wa➢ reversed a number of times. 22 prosecutor. I didn't really remember that until you 23 0 Rough gue➢➢? 23 mentioned it. 24 A I Couldn't tell you. I couldn't tell you how 24 Q Ho wa➢ a prosecutor in the Broward State 2S many [limos. 2S Attorney'➢ Office and told us ho prosecuted murderers 110 112 O Ton? and hard criminal➢? 2 A More than 10. 2 A Okay. 3 O One hundred? 3 Q That's not a job for the weak of heart, is 4 A No, not 100. 4 it? Q S0013Where between 10 and 100 tine➢? A No. 4 A I would aay between -- maybe 10 and 20, 30 4 Q Was there any part of your evaluation of 7 tides. ➢seething like that. Twenty, 30. Something 7 Mr. Edwards that made you think that he was afraid of • like that. S Mr. Epstein and hi➢ lawyer➢? 9 Q Somewhere in that range. Okay. 9 A No. 10 Where three people that evaluated your 10 MR. SCAAOLA: Objection, compound. 11 deci➢ion decided that -- for whatever reason to IL BY MR. LINK: 12 reverse your deci➢ion, right? 12 0 When you were working on the throe Epstein 13 A Yeah. 13 cases while you were at the Rothstein firm, wore you 14 Q Old you over feel threatened and bullied by 14 aware that III. gave a ➢worn ➢tatement with immunity IS Mr. Boatman's lawyer➢? IS to the FBI? 14 A No. 14 A No. 17 O Old 14r. Edwards come to you and aay I feel Il 0 What'➢ the reason for the FBI to give IS threatened and bullied by Mr. Epateln's lawyer➢? IS iMMUnity when they take a ➢worn statement from 19 A No. It somebody? 20 Q Do you think Mr. Edwards, who had been a 30 MR. SCAAOLA: Objection. No predicate. 21 former criminal prosecutor, wa➢ bullied and 31 THE WITNESS: I could only talk in 22 threatened by Hr. Ep➢tein'a lawyers? 22 general a➢ to -- 23 A No. 23 BY MR. LINK: 24 0 Were any of the lawyers at the Roth➢tein 24 0 Toll the jury in general, 25 flea that were working on thi➢ ca➢e -- Mr. Adler or 33 A I would a➢➢we that a police agency or a Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798364 113 115 prosecutor would give ismiunity. Immunity means the clients you wore representing gave FBI sworn 1 basically a promise not to prosecute the person in 1 testimony and then changed her story at her 3 exchange for information. deposition, did you go nay, Let me look and ➢ee 4 0 In telling the truth? 4 what's going on, let ma compare then? A In telling the truth. S A I think that it was presented in writing, so 4 Q so there's a premium on telling the truth 4 when you say did I go and compare it, I think that, not / to keep your innualty. You agree with that? only was It stated to the judge, but beforehand in soma • A Noll, a condition for the isownity to stick, a written paper, Hr. battier or Mr. Goldberger had out • I would anima, would be that you've told the truth. * the two ➢tatemnts ➢ide by side, so I compared it in 10 Q Which would mean that if you were providing la that sense. 11 a sworn ➢tatemnt to the FBI to gat isownity you ll I don't have a particular recollection of 12 should tell the truth? 12 doing it. I generally remember that there was 13 A Yeah. 13 statement by counsel that one of the clients had II Q Did you ever review the transcript of 14 said something to the FBI that was different than II taped ➢tatemnt that wan given to the FBI in 15 what she said at the time. 14 April of 2001? 14 O I understand. If A No. I don't believe I ever read it. I, A So generally what you are saying El familiar is Q Did you ever -- did anybody ever tell you a with. la that there wore significant differences between the I, Q And I understand that there's sane snippets 20 statement given by before she was repre➢ented by 20 of it in the papers they filed. What asking is the Rothstein firm and what her testimony was after 21 different. Did you, once you had that information, 22 being represented by the Roth➢tein firm? 21 go back, pull the two transcripts and look at them 23 MR. SCATtOLA: objection. Calla for 23 personally to evaluate the Inconsistencies in her 24 hearsay, secondhand knowledge, argumentive. 24 under -oath te➢timony. 25 THE WITNESS: I think I heard that. 25 A No, I didn't pull the Whet* -- no, I didn't 114 116 BY NB. LINK: pull the whole transcripts to do that, no. 2 0 Who told you that? 2 0 You mentioned Ns. tutelar, Mark tattler. 3 A I think I hoard it, at least, by either 3 Ha was one of the lawyers at Ns. Crleton's firm? 4 Mr. Critton or Hr. Goldberger at one of the discovery 4 A Yes. • hearings. 5 Q You aro familiar with Mark 'Antler? 4 O And they were informing the court? 4 A Yes, I know Nark LUttier. A Yes. 7 Q What kind of reputation does he have? S Q And you were there as a participant for ono S A He'➢ a very good attorney. of the Rothstein clients, and they were describing 9 Q Was there anything that Hr. battier did 10 that gave a sworn statement with Immunity and 10 during his representation of Epstein that you thought II now at the Rothstein firm her testimony has changed. IL was unethical? 12 Did you take that information, go back and compare 11 A No. 13 them to see if what they said is accurate? 13 O Illegal? 14 MR. SCAROI.A: Objection. Calla for 14 A No. IS hearsay, secondhand knowledge, improper IS O Inappropriate in any way? If predicate. If A No. 11 THE WITNESS: They didn't couch it in If Q Are you aware of their firm, the Berman, IS terms of now that ➢he's with the Rothstein IS Critton 4 tattler law firm we re the lawyers that were 19 firm, okay. I think it was couched in terms 19 representing Ns. Epstein at the time that the lawsuit 20 of she said one thing one time and now ➢he's 20 against Hr. Rothstein, III. and Hr. Edwards wan 21 saying something else. 21 filed? 22 And now you're asking ma if I actually 22 A No. I didn't know who wan representing 23 went and compared it side by side. 23 Mr. Epstein at that time. 24 BY HR. LINK: 24 Q Mr. Berger, wore you involved In the motion 25 Q Once you heard to open court that ono of 25 to set a bond for $15 million based on the illegal Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798365 117 119 transfer of a➢aota by Mr. Epstein that waa filed with about earlier at the Critton the Borman, Critton 2 Judge Marra? 2 Luttler firm, right? 3 A No. I never hoard of that. A Correct, and Michael Pike. 4 Q Did you review the order entered by Judge 4 0 Do you know Michael Pike? Marra where he found that there wa➢ no evidence to A Yeah. f support the filing of that motion by Mr. Edwards? 4 Q What is Michael Pike's reputation in the 7 A No. community? 4 MR. SCAAOLA: I am going to object to A No is a good attorney. a the form of the question. It assumes facts Q Did Michael Pike do anything in his 10 not in evidence. IC representation of Kr. Epstein you thought was 11 BY I . LINK: II illegal? 12 Are you familiar with Judge Marra? ix A No. 13 A Oh, I know Judge Marra. 13 Q Unethical? What is his reputation? 14 A No. 13 A Very good judge. 13 0 Inappropriate? Excellent juri➢, right? 14 A No. 17 A Yeah. 17 Nave you ever seen anything in looking back Q Would it surprise you that Mr. Edwards and Is at the representation of Mr. Epstein by Berman, IS the Rothstein firm would file such a motion that Is Critton a tutelar and their lawyers that causes you 20 Judge Marra would find had no merit? 20 to think that something they did in that 21 A I don't even know the context. I don't know 21 representation was illegal? 22 anything about what you're talking about. I didn't 22 A No. 23 know that such a motion was filed. 23 Q Unethical? 24 I will show that to you in a minute. Take 24 A No. 25 a look at that. But you weren't involved in drafting 25 Q You mentioned during your direct 118 120 I that motion or arguing it in any way? examination that you thought it would to malpractice A No. 2 not to investigate every other instance of alleged 3 MR. LINK: Can we mark that as number 3 wrongful conduct by Mr. Epstein. Do you remember three, please? 4 saying that? (Plaintiff's Exhibit Number 3 was marked a A Yea. 4 for identification.' Q Is it your testimony that while you wore 7 BY MR. LINK: 1 representing the three plaintiffs and Rothstein that S 0 Wo are looking at Plaintiff's Exhibit S every single incident of potential wrongful conduct Member 3, the original complaint filed by Mr. Epstein / by Kr. Epstein wan investigated by your firm? 10 against Scott Roth➢tein, Bradley Edwards and ■. 10 A I don't know that. 11 Nave you ever seen this complaint? IL Q so if they didn't do that, would you agree 12 A Yes, I saw it. 12 that that was committing malpractice? 13 0 When did you see it? 13 A I think that'➢ too speculative a question to 14 A I saw it the other day. Mr. Scarola sent mo 14 ask. 15 a copy of it. 15 0 You remember testifying that it was If Q Had you seen it before the other day? If Malpractice not to investigate every other instance 17 A No. I? Of wrongful activity by Kr. Epstein? IS Q Did Mr. Edward➢ ever call you to talk to IS MR. SCAAOLA: Excuse me. MI going to 19 you about this complaint? IS object. No proper predicate. Misstate➢ 20 A No. 30 prior testimony. 21 Q rake a look -- I asked you if you know who 21 BY NR. LINK: 22 filed it. Will you just take a look and sea the 22 Q Do you remomber that testimony, air? 23 lawyer that signed this complaint when it was filed? 23 A Conaaaaay, yeah. I said -- yeah. 24 A Robert Critton. 24 0 You said that, right? 23 Q And that'➢ NC. Critton We were talking 23 A Yes. Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798366 121 123 I Q And ao that would moan -- for example, 1 when you aay -- it wasn't during the time of the 2 Mr. Scarola's firm represented a client against 2 Rothstein -- Brad Edward➢ wasn't working for the ) Mr. Epstein, right? ) Rothstein firm, I don't believe, when this happened. 4 A Correct. 4 Q When he settled? 5 Q So if Mr. Scarola's firm, before settling 5 A When he settled. S that ease, did not investigate every other incident 4 Q Correct, he was not. 1 of alleged wrongdoing by Hr. Epstein, you would deem 7 And you didn't get any part of the • that as malpractice, wouldn't you? • financial arrangement, did you, sir? s A Not if enough money wan put on the table, s A No. IC they wouldn't need to do it. Ici Q We were talking about this duty to II Q Oh. Whoa, whoa, whoa. So I can avoid II investigate. And ono of the things that you said 12 malpractice and the fulfillment of my ethical 12 that caught my attention was that I don't have to 13 obligations by getting enough money for the client? 13 fulfill thin duty to investigate and it wouldn't be 14 A If the client -- once they accept the 14 malpractice if I settled for an amount that the 15 settlement, then there'➢ -- the case is over. 15 client approved. Is that your sworn testimony? 14 0 I got lt. But during that window between 14 A Yeah. 17 when the case is filed and when it's nettled is when I7 Q So, you made the statement that your law Is you aro supposed to be doing thin investigation, Is firm had a joint prosecution agreement with other law Is right? It firms. Old you ever see that agreement? 20 A Correct. 20 A I don't recall -- I can't recall seeing it. 21 0 You are not telling this jury that I can 21 I recall hearing of it. 22 discharge my ethical obligations by simply getting 22 Q Was there a written joint representation 2) money for a client, are you? 2) agreement? 24 A Well, not sure I know what you mean. I 24 A I don't know if it was written. 25 moan, if a client is suing, if a client has a 25 0 Did you ask to sea it? 122 124 1 particular dollar amount that she thinks will make her i A No. 2 whole for what he has done to her, and Kr. Epstein 2 0 You said you attended a meeting, right, of 3 offered that amount, then the client has achieved their 3 tamers from other ['arm? 4 purpose. 4 A I remoter -- and it's very vague. I a 0 Let me a➢k you this. Since you -- 5 remember -- I think it was the first time I met Adam 4 MR. SCAROLA: . sorry. I don't 4 Horowitz. And I think I met Spencer Kuvin. I just 7 believe the witness has finished his 7 can't place exactly where it wan. It wasn't at the 8 response. S Rothstein office. And I just don't -- it was somewhere 1 THE WITNESS: And wo keep talking about t in Went Palm Beach -- at a law firm in West Palm. 10 money. But a➢ attorneys always tell jurors, 10 Q So the joint prosecution agreement concept II this is the only way the system can IL la that you can share information with each other and 12 compensate or make somebody whole. It's 12 not waive your attorney-client or work product I) financial. So It does toll down to that. 1) privilege, right? 14 BY KR. LINK: 14 A That's one of them -- ono of the features of 15 0 I got it. 15 it, yeah. The other would to that you are going to If So what you said is if the three If cooperate. 1/ plaintiffs represented by the Rothstein firm made a 17 0 sure. You are going to share information. IS decision that the money they were offered would IS A Right. It compensate them fairly, then they have the right to 19 Q plaintiffs lawyers do that all the time in 24 take it and to done, right? 24 multiple cases, don't they? 21 A Correct. 21 A Yea. 22 Q And that'➢ what happened here, correct? 22 0 That's not uncommon? 23 A I have heard that there wan a settlement. I 23 A No. 24 wasn't involved personally, so I don't have personal 24 Q And defense lawyers do that, right? 25 knowledge of it. I heard that's what happened. And 21 A Correct. Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798367 125 127 Q So I heard you say on direct examination 1 developing their case? Do you believe that, sir? 1 that Brad Edwards wa➢ the lead lawyer for thin group 1 MR. SCAROLA: objection. Compound, 3 of distinguish lawyers that had cases against speculative and argunentivo. 4 Mr. Epstein. Ia that true? 4 THE WITNESS: You aro proposing an 5 MR. SCAROLA: objection. No proper extreme example. I could see how an 4 predicate. 4 attorney -- Bob Sonefaborg, Ted Leopold, Sid THE WITNESS: not sure I said that. 7 Garcia, Adam Horowitz, Spencer Kuvin, any of If I did I made a mistake. ▪ them could nay, You know, Brad, you go ahead Brad -- you are dealing with none very 1 and pursue this particular line of Inquiry. 14 heavy-weight people. Brad wan an excellent 10 We will rely on you to do that. That's not II lawyer, but ho didn't have the reputation of II out of the question. 12 Bob iceoCaberg. I didn't -- 12 BY RR. LINK: 12 BY NR. LINK: 13 Q It happens all the time. II O I didn't moan to interrupt you. II A If you are saying that they turned everything is A I didn't mean to nay that Brad lad the 15 over to Brad, ■ not saying that that happened, but I 14 collective group of attorney➢. within our firm he wan 14 could see the particular lino of investigation could I, the lead attorney. 17 have boon delegated co Brad. IS Q He wan a lead lawyer at the Rothstein firm, is 0 Was it? It right? is A I don't know. I don't know it it wan. I 20 A Correct. 20 know that there van coononleatlen among Brad and these 21 Q He wan not the lead lawyer for Bob 21 other lawyers, because I heard of it secondhand. I 21 Josefaborg, wa➢ he? 21 didn't directly participate in much of it. I have 23 A No, he wasn't. When you nay lead, he didn't 23 very, very vague recollections. 24 have a leadership role. First of all, I didn't 24 I know -- I think I talked to Josernberg 25 attend -- I can only recall -- and that's only vague -- 25 once or twice, and the nano would be with regard to 126 128 I one 'meting with other counsel. Bob Sonefaberg wan not Kuvin, Leopold, Garcia, Horowitz, and I do remomber 2 at that meeting. 2 this meeting. 3 0 So you've known Bob Josefaborg for a long O To share information? 4 time, right? 4 A To share information and to strateglze, sure. 5 A Yeah. Did any or these lawyer➢ ask you, 4 Q He's ono of the top trial lawyers in our 4 Mr. Berger, to do anything on their behalf? 7 state, isn't he? 5 Mr. 30203[2130r07 Sid Garcia? S A Yes. S A No, I don't member that. I know that we Q Ho'n a dean of the trial bar, right? took the lead, meaning Brad and I, and ma, 10 A Yes. 10 apoclflcally, In trying to got the non-prosecution Il 0 You agree with that? IL agreement unsealed. 11 A Yeah. 11 Whether or not that wan ➢omething that was 13 0 And at the time, Mr. Edwards wan about a 13 asked of ua collectively by the group or we just 14 six-year lawyer, right? 14 went ahead and did it, I don't remember that. I 15 A I don't know. I don't know when Brad started 15 don't remember anybody also making that effort but 14 practicing. He wasn't as senior as Bob Josefsborg. 14 myself. Actually, I wan Cho ono that filed the 17 O Probably none of us are. 17 papers and argued it. IS A Not ne. IS Q And you don't remember Bob Sosefaberg It Q Right. Re either. I think not even IS calling you and asking you to do that? 20 probably Hr. Scarola. 30 A No. 21 So do you really think Bob Sosefsberg in 31 • You don't [member Adam Horowitz calling 22 his head in representing his clients said, I an 32 you and asking you to do that? 22 going to let Hr. Edwards, thin young lawyer, handle 23 A No. 24 the representation of my clients and gather 24 0 Or Mr. Scarola? 23 information for them and be respm➢ible for 25 A No. I don't remember that. Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798368 129 131 0 Did you over talk to Mr. Scarola about his 1 notes and son if wo can wrap up. 2 case? 2 THE VIDEOGRARMER: Going off the record 3 A No. at 12:18 III. 4 0 Obviously Kr. Scarola didn't ask you to do 4 4A recess was had.) • anything to help hla client. S THE VIDEOGRAPHER: Going back on the 6 A I don't remember that. 4 record. The tine is 12:21 III. Did you swat any of the other lawyers who REDIRECT EXAMINATION • had pending cases with clients in order to evaluate O BY KR. SCAROLO: 9 their situation? 1 Q Hr. Berger, I want to start where opposing 10 A The clients, no. 50 counsel left off talking about the scope of the 11 O Did you review any of the discovery that 11 investigation necessary with regard to other 12 was being filed by the other law firms? 12 circumstances where Jeffrey Epstein was involved in 13 A You mean the discovery requests? 13 the sexual abuse of children. 14 Q Discovery requests and information coming 4 When you spoke about the need to 35 ln. 13 investigate other Epstein -- other incidents of 36 A I don't natant:or that. 14 Epetein'➢ abuse of children, is it necessary to 1? 0 Did you participate in negotiating 17 evaluate how much damage was done to child victims 28 Mr. Scarola'a settlement for his client? 14 who wore not your clients? 19 A No. Is A No. Not -- certainly not In the sane detail. 20 0 Did you participate in negotiating any of 20 Q What la it that you aro focusing on when II the non-Rothstein clients' settlement discussions? 21 you aro investigating other incidents of the sexual 22 A No. 22 abuse of children by Jeffrey Epstein? 22 0 Are you aware of the cases that wore 23 A Well, you are not specifically looking to how 24 settled that were unrelated to the Rothstein three 24 damaged that other victim was. what you aro looking at 26 clients? 25 are the circumstances -- Cho objective circumstances of 130 132 A Well, I wan -- just in general. I think the abuse. So was it -- how was it done? What was the 2 dosefaberg settled a number of thank. There wore a 2 method? Did it even occur? 3 number that wore settled, but I only -- ■ not really 3 Even if it wasn't a similar setting or a 4 aura how I learned of this information. I didn't 4 similar technique, if it happened it's relevant to 3 participate in them. 5 proving that it had happened to your client. 4 Q Was the Rothstein firm asked to participate 4 The whole point is to prove that it 7 in negotiating settlements for clients they didn't / happened to your client, Donau.* it happened to • represent? • other people. And the circumstances, if they can be 9 A No. • similar, that helps as wall. 10 O Were you aware that Mr. Joaefsberg settled 10 • You spoke about modus operandi. What does IL multiple cases without filing them? II that Latin phrase mean? 12 A I heard that ho did, yea. 12 A That means how did the parson do it. What 13 Q Did he consult with you and 14r. Edwards 13 was the method of operation. 14 about whether he should settle the case or file suit? 14 And in particular hare, you aro dealing, IS A No, he didn't consult with us about that, no. IS in soma respect, with a one-on-one situation. It'➢ If O Did he consult with you about whether the 14 conceivable that Epstein could say that although he 17 money being offered by 14r. Edwards to his client was Il was present -- In the presence of a young woman, our 18 a fair nuaber? IS clients, nothing bad over happened, and it would be 19 A No. 19 a he-said-oho-said. So it would to important to 30 Q Did you discuss with Mr. Josefsberg or any 20 have evidence of other abuse to discredit that 21 other lawyers the differences in each of the clients' 21 nothing happened. 22 mental statamanta at the time of the alleged abuse? 22 So modus operandi would be how was it 33 A No. 33 done; what was the method of operation that the 24 MR. LINK: Why don't we take a couple 24 person used. 21 minute -- quick break, let ma go through my 31 Q Of what significance, if any, would it be Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798369 133 135 if it were determined that Epstola's method of abuse 1 MR. LINK: Joseph Ackerman? Joe 2 was to intentionally target disadvantaged children as 2 Ackerman? 3 young as 12 and 13 years of age to entice them with MR. SCAROLA: Yes. 4 substantial sums of money, not only to engage in 4 THE WITNESS: Yes. • sexual conduct with Jeffrey Epstein and to submit to S BY NE. SCARCNA: moaaaaationa by Jeffrey Epstein, but also to go out 4 Q And you acknowledged that as far as you 7 and bring other similarly situated, similar ▪ were concerned, those were lawyers who had good ▪ circumstanced individuals to Epstein who would be ▪ reputations and they didn't do anything unethical, * willing to endure the sane abuse at the same age? * improper or unreasonable in their representation of 14 Would that have any significance? 14 Jeffrey Epstein, correct? II MR. LINK: Form, compound, speculative, 11 THE WITNESS: Correct. 12 no facts in evidence. Maybe the NhOla 12 BY NR. LINK: 13 evidence code. 13 Q It was then pointed out that one or sore of 1 THE NIT HESS: Nell, lb would 111303/ a 14 those lawyers was involved in bringing the suit 13 pattern that that's what he did. la against Bradley Edwards, correct? 14 If it can be proven that he did it to 16 A Correct. 17 other children and your client is testifying 17 Q In order for Jeffrey Epstein to even that he did the sane thing to her, it 14 suggest that he has the protection of having been Is corroborates your client's testimony. 11 represented by good, ethical lawyers in filing that 20 By NB. SCAROU: 20 lawsuit, Jeffrey Epstein would need to waive 21 Q Are you familiar with the concept of an al attorney-client privilege so that we could take the 22 advice of counsel defense? 22 depositions of those lawyers and find out what it was 23 A Yea. 23 that Jeffrey Epstein told them that convinced them it 24 Q Describe, for the benefit of the jury, if 24 was proper to sue Brad Edwards, right? 25 you would, please, what an advise of counsel defense 25 MR. LINK: Ctject to the form. 134 136 I is. I BY NE. SCAROLA: 2 A It mane that you can't hold no liable for 2 Q Lot me restate the question. 3 what I did because I was acting on the advice of my 3 what extent, if any, would it be necessary 4 attorney. 4 for ua to find out what those lawyers were told in s Q In order to raise an advice of counsel 3 order to rake a judgment about whether they acted 4 defense, is it necessary for the individual who is 4 properly or improperly in filing the suit against 7 seeking the protection of advice of counsel to waive 7 Bradley Edwards? • the attorney-client privilege so that the jury la S A I think you have to know -- you have to know • able to evaluate whether the counsel was giving .3 that. 10 advice on the basis of truthful information or on the 10 Q Is a lawyer entitled, unless he knows II peals of lies? II otherwise, to assume that his client la being 12 A I believe that the Florida Evidence Code says 12 truthful with him? 13 that if you -- that you can't assert the 13 A Yea. 14 attorney -client privilege when -- to prove your 14 Q So, for example, if Jeffrey Epstein wore to 15 position -- it's relevant as to what was stated between IS have lied to his ethical lawyers, and his ethical If you and your attorney. 14 lawyers antlered he was telling the truth, would his 11 • So you were asked queationa about the 17 ethical lawyers be permitted to rely upon the assumed IS reputation and your observations of the conduct of IS truthfulness of Jeffrey Epstein if they didn't know 15 Mr. Critton, Ns. Goldberger, Mr. battier, Mr. Berman IS better? 20 and Mr. Pike, all of when were involved at some point 20 A Yes. 21 In time in the representation of Jeffrey Epstein, 31 Q You were shown Plaintiff's Exhibit Number 32 Correct? 32 1, referred to as the Razorback complaint. 33 A Yea. 33 A Right. 24 Q I think I missed Mr. Ackerman on that list. 0 And when that complaint was handed to you, 23 Mr. Ackerman as well. 23 It was stated by opposing counsel that Bill Scherer, Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798370 137 139 a respected lawyer, sued the Rothstein firm. Do you 0 Are you aware that the V.S. Attorney's 2 remember that being said? 2 Office announced that there were a number of unnamed 3 A Yea. co-conspirators that they wore still evaluating in 4 Q Take a look at the complaint, if you would. 4 November and December of 2009? S That complaint identifies all of those people who A No, I don't remember that. were defendants who were sued by Bill Scherer, 4 Q so you gave the opinion that you didn't 7 doesn't it? • think there was probable cause to ➢ue Mr. Edwards. O A Correct. a But have you reviewed any of the evidence that MR. LINK: Object to the form. * Mr. Epstein monod on in bringing the suit? 10 BY RR. SCAROLA: 10 MR. SCAROLA: I don't think you meant 11 Q All of those defendants who presumably Bill 11 to ➢ay that. 12 Scherer had probable cause to sue when the complaint 12 Which suit? 13 was filed, correct? 23 MR. LINK: Thin suit. 14 A Correct. 14 MR. SCAROLA: sorry. I thought you II Q And among all of the defendants that Bill Ii wore talking about Razorback. 14 Scherer had probable cause to sue, la the Rothstein, It By RR. LINK: 17 Roaenfeldt a Adler included? 27 Q Let me ask it again. Mr. Scarola asked you Is A No. la if, in your opinion, a reasonably prudent person Is Q Are you among the lawyers who were ➢ued by It would have probable cause to have made the allegation 20 Bill Scherer as having been actively involved in this 20 that Bradley Edwards could have been connected to the 21 Penn achame? 21 Rothstein POnil scheme. Do you remember that 22 A No. 22 question? 23 Q Is Bradley Edwards identified as someone 23 A I was thinking of your other question. Not 24 that Bill Scherer had some basis to believe had been 24 exactly, but -- 2S involved In the Rothstein Pont scheme? 2S 138 140 A No. Q Okay, so let me ask you this. What 2 Q Was there own the ➢lightest ➢uspicion that 2 information have you evaluated as a lawyer to 3 would have justified any reasonably cautious person 3 determine whether you would have found probable cause 4 in ➢uing Bradley Edwards and alleging that he was a 4 in Deceaber of 2009 to allege that Hr. Edwards may 5 participant in the Rothstein Pons' ethane? 5 have been connected co the Rothstein Maui school.? 4 A No. 4 A There is no way in the world that Jeffrey 7 MR. SCAROLA: Thank you. I don't have 7 Epstein had probable cause to sue Brad Edwards. • any further questions. 0 My question -- 9 RECROSS-EXAMMATION 9 MR. SCARCER: Pardon me. The witness 10 By NB. LINK: 10 had not finished his response. 11 Q Mr. Berger, the Exhibit 1 by Mr. Scherer, II MR. LINK: He's not answering it. 12 who does it sue -- who does he sue? 12 MR. SCARCER: The witness had not 13 A Scott Rothstein, David Roden, Debra 'Allegan, 13 finished hla response. 14 Andrew Barnett, TO Bank, Frank Spinoaa, Jennifer 14 Go ahead, Hr. Berger. IS Kerstetter, Rosanne Caretsky and Frank Prove. IS THE WITNESS: Jeffrey Epstein knew what 14 Q And Mr. Rothstein was the chairman of the If he did, and he knew that what Brad was ➢uing 17 Rothstein firm? 17 him for was true. IS A On November 20, 2009, I don't believe he was, IS By RR. LINK: 19 but he had been. 19 not asking you that. Masking you 20 Q And at all times during the operation of 20 what evidence did you look at -- I am not asking you 21 the Ponsi scheme? 21 about Mr. Epateln'n sexual contact with anybody. 22 A Yes. 22 asking you what evidence did you look at to ➢ee 23 Q And are you aware that Mr. Scherer anended 23 whether there was a rea➢onable basis to allege -- in 24 that complaint to add additional defendants? 24 thin one-out-of-ten standard that you articulated -- 25 A No. 25 to allege that Hr. Edwards may have been connected to Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798371 141 143 the Rothstein Ponsi scheme. what evidence did you A The fact of the matter is, it's Epstein that 2 review? 2 filed it, and I know that it was false, ao -- 3 A I know ho wasn't. 3 0 Co ahead. 4 0 IM not asking you what you know, air. IN 4 A -- I don't know how to answer your question. 5 asking you what evidence did you review. 5 Q Because you know that you don't judge A well, hold on a second. You're saying -- I 4 whether somebody had probable cause based on whether 7 moan, when would I have reviewed it? I mean, it turns out to be true or false, correct? Is that 4 Mr. Stomata asked ne the question -- s the standard you're hold to a➢ a lawyer, Hr. Berger? Q Before you gave your opinion. s A I think I understand your question. I would 10 A So you mean what did I review during this IC answer yea to your question. II deposition when Mr. Scarola asked no the question? II Q so it's not whether you aro right or wrong II Q No. I an asking you did you review the 12 that you allege at end of the day that determines 13 evidence that existed in December 2009. 13 whether you had probable cause, la it, air? 24 A Let ne just atop you. Did I review in A You are talking abaft the attorney or are you is December of 2009? 15 talking about the party that the attorney represents? 14 0 No, no, before giving your opinion to 0 Ono in the sane. 27 Mr. Stomata and this jury that no reasonable person 17 MR. SCAROLA: Objection. Is could have brought a claim against Brad Edwards. a TIM WITNESS: It's not ono in the nano. It asking you before you gave that atatorant to this It It's not ono in the same. 20 jury, what of the physical evidence that Hr. Epstein 20 If I murdered you and your spouse sues 21 relied on did you review? 2L mo [or wrong -- 22 A I just know what happened. There's no -- 22 BY MR. LINK: 23 when you may did I review, you moan did I review during 23 Q You don't want to murder no, do you? 24 the course of this deposition? 24 A -- sues ne for wrongful death -- coming 25 0 No, air, before giving your opinion. 25 up with a bad example. I apologize. 142 144 Did you just toll this jury that, in your But there's no way in the world that 2 opinion, no reasonable lawyer In the world could 2 Jeffrey Epstein had probable cause to sue Brad 2 have filed the lawsuit against Mr. Edwards? 3 Edwards. 4 MR. SCAROLA: Pardon me. That's 4 Q And what Masking -- I appreciate that. not what -- that'➢ not what the testimony 5 You consider Brad Edwards a friend, don't you? 6 was. That's a complete mischaractorization. 4 A Yeah. 7 That question had nothing to do with 7 0 You like Brad Edwards? lawyers. It had to do with Jeffrey Epstein. S A I da. 9 BY HR. LINK: What's his reputation In the legal 20 Q sir, is it your opinion -- you know 10 community? 31 Mr. Epstein didn't file the case, right? No's not a IL MR. SCAROLA: Objection. Beyond the 32 lawyer. 12 scope of redirect. 22 A I know. 13 THE WITNESS: I think be has a good 24 0 So my question is really simple. Is it 14 reputation. 36 your opinion that no reasonable person could have 15 BY MR. LINK: 16 filed a complaint in December of 2009 making an If Q And has he always had a good reputation? )7 allegation that Mr. Edwards may have boon connected 17 A I baileys, ao. 10 somehow to the Rothstein Ponsi scheme? IS Q SO, What really trying to understand 19 MR. SCAROLA: Objection. 19 from you la will you agree with me that you evaluate 20 Mischaracterimation of the allegations Ln 30 probable cause at the time that the lawsuit is filed? 21 the complaint. 21 A Yes. 22 THE WITNESS: when you say no person, 22 Q And sometimes the allegation,. prove to be 23 do you mean no lawyer or no party? 23 true, right? 24 BY KR. LINK: 24 A Right. 25 Either one. 25 0 And sometimes the allegation you make prove Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798372 145 147 to be untrue, right? Epstein? 2 A Correct. 1 A It's patently [also that Jeffrey Epstein wan Q Have you over pied any allegations, not Intel injured by anything that Brad Edwards did or 4 Mr. Berger, that turned out to be untrue. down the 4 if -- I don't deny that there wan a 0042l scheme that 5 lino? S used the three cases we had as bait. 4 MR. SCAROLA: Objection, argumontivo, 4 Q Thoy did, right? 7 repetitious. MR. SCAROLA: Excuso me. Please lot THE WITNESS: I have never plod the witness finish his response. allegations that I knew were false. THE WITNESS: I wasn't there. I don't 10 BY I . SCAROLA: 10 have personal knowledge. I am telling you 11 Q so it's your view that the allegations In 11 my conclusion based on what I have road In 12 the complaint were known to be false? 12 the papers and all that -- so -- the 13 A To Jeffrey Epstein. 13 Pont! -- Rothstein did use the Penal scheme. SO which allegations - - II Brad Edwards had no involvement in it. IS A Are we talking about the Scharer lawsuit -- 13 Jeffrey Epstein was not damaged in any 14 14 way, shape or Corm by the Pont! scheme. A -- or aro we talking about Epstein's I, It's impossible. 14 allegations? 10 Jeffrey Epstein sexually abused dozens, It Q Epstein. I, if not hundreds, of children. The. fact that 20 Show me which allegations in there 20 that -- that those [acts were used by a 21 Mr. Epstein knew wore filse at the CUM he made it. 2L crook to promote a Son21 schwas didn't hurt 22 That's what you just said, so show me. Please point 22 Jeffrey Epstein ono bit. 23 out the allegations in that complaint, air, that 23 BY NB. LINK: 24 Mr. Epstein knew wore false when ho made them. 24 Q so can you separate in your mind for your 25 You can underline with my pen. 25 testLmony today what Mr. Epstein did and suits 146 148 1 A If he's alleging that he didn't do what he against him by plaintiffs that allege wrongful sexual 2 did -- 2 Conduct and his lawsuit against Rothstein, M. and Q You just testified that Mr. Epstein made 3 Edwards related to the Pone' scheme? Can you draw 4 allegations ho know wore . This is the 4 separation, Mr. Berger? complaint. I would like you to highlight them for A I think so. Q Because you hoop telling me about the A okay. Take a break. 7 sexual conduct that Mr. Epstein -- 8 Q Sure. S A My point is, he was not -- he wan not 9 THE VIDEOGRAPHER: Going off the record 9 Injured -- no reasonable person could think that 30 at 12:40 III. 10 Jeffrey Epstein who abused dozens of children and wan 31 IA recess was taken. IL sued for it could be injured mentally. Noire talking 12 THE VIDEOCRAPHER: Going back on the 12 about mental injury hero mentally Injured by Scott 13 record. The tine is 1:14 III. 13 Rothstein using those legitimate cases to defraud 14 BY HR. LINK: 14 investors. 15 Q Hr. Berger, before we took our break, I 15 Jeffrey Epstein'a reputation was not 36 asked you to underline every allegation In that 14 damaged at all. Ho had no reputation. Ho wasn't 37 complaint that you know that, at the time it was 1/ mentally -- no one can convince ma he was 30 written, that Mr. Epstein know the statement was 18 emotionally disturbed by the [act that he learned 19 false, right? 19 that his sexual predatory tactics wore used in a 20 A Right. 24 Manzi scheme. It's inconceivable. And that's 21 Q So may I moo what you have underlined that 21 basically the -- by the way, I didn't road the parts 22 you know that Mr. Epstein know it was false? 22 that deal with the legal counts. I read the factual 23 Okay, so on the first page you underlined 23 parts. 24 that -- what happened at the Rothstein flat that 24 Q so, can I just see the rose of it for a 25 resulted in profoundly serious injury to Jeffrey 33 minute that you marked? Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798373 149 151 A I didn't go through them -- A -- between what she said to her depo➢ition. Q I understand. 2 But she was not a part of any schwa. Epstein knew 3 A when I got to count ono, I stopped. That was ) that. 4 legal discussion. I Just looked at the factual 4 0 So Epstein knew the reason why she changed 5 allegations. her sworn testimony to the FBI and then when she got Q So, can you point out to no here where f to the Rothstein firm was -- how did ho know why she Mr. Epstein talks about the damage to his reputation? did that? How would ho know? 4 A It's damages. Tho first lino you read said A Sir, Epstein knew that her second testimony profoundly damaged, swathing like that. * whore she accu➢ed his of those was true. So she didn't 10 Q well, profoundly damaged, you could have IC change it because of a Ponsi scheme. she's changed it 11 monetary damages, right? m because ➢he told the truth. 12 Is there a distinction in monetary damages 12 So she lied to the FBI? 13 and emotional damage➢? 13 A Right. 14 A Theoretically there are. 14 0 So she's an admitted liar to the federal 15 Q Show me where Mr. Epstein asked for his 15 government. 14 damage to reputation. That'➢ what you just said, hi➢ 14 Is there a consequence for lying CO the 15 reputation couldn't have boon thinned. 17 federal goverment? 14 Mere does he ➢oak damage➢ for his 10 MR. SCAROLA: Objection, argumantive. Is reputation? II THE WITNESS: I don't know. 20 MR. SCAROLA: Excuse me, Counsel. What 20 was she prosecuted? 2l was read was, •resulted In profoundly 21 BY Ma. LINK: 22 serious injury to Jeffrey Epstein.• That's 21 0 just asking lf there's usually a . 23 what was just discussed. 23 consequence. 24 THE WITNESS: Brad Edwards did not have 24 A I don't know. 25 anything to do with the Ronal schwa. 25 0 You don't know? 150 152 I BY M. SCAROLA: A No. 2 Q I know you believe that, sir. I believe in 2 I don't think that ➢he wa➢ prosecuted. 3 my heart that you believe that, okay? 3 Q So you underlined that Rothstein and his 4 A I believe Jeffrey Epstein knew that. 4 co-conspirators unlawfully obtained approximately But what I asked you to do is to point out 5 1.2 billion. Mat is untrue about that? 4 in here the allegations that you S0110M1041 know that, 4 A well, if it's reflected on Brad, he wasn't a / when they were nado, that Mr. Epstein in his mind 7 co-conspirator. know they were false. Q It doesn't my Brad's nano, doe➢ it? 9 MR. SCAROLA: And that's exactly what 9 A Just ono second. I assume that it's part of 10 the witness la doing. would you please let 10 a complaint against Brad, so if it didn't mean to 11 him finish his response? II include Brad, then I shouldn't have underlined it. 12 THE WITNESS: So the first one was 11 Q So do you want to squiggle through that I) that -- Epstein saying he was profoundly 13 ono? rite it out? 14 damaged. There's no way in the world that 14 A Do you want to put in hare that it's not 15 that's true. 15 Brad? I will do that if you write, •except Edwards.• If BY M. LINK: If Co ahead. I/ 0 So he was not profoundly damaged, okay. 17 Q I. not going to change it, if that's Whit IS The next thing underlined was that the allegation IS you want to put in there. 19 about III. being a participant in the schema by, 19 Okay, let's see what else. Is it a true 24 among other things, changing her prior sworn 24 statement that Rothstoin and his co-conspirators 31 testimony. 21 stole over a billion dollars from unexpected 33 A she was not a participant in a schema. She 32 victims? 23 may have changed her prior testimony. You pointed out 33 A Yes. 24 an inconsistency -- 34 Q So you underlined in paragraph 18 the XS 0 Right? 25 Matament, •What la clear is that a fraudulent and Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798374 153 155 Improper investment or Poral scheme was In fact 1 Q A203 you aware of meetings that Hr. Edwards, conducted and operated by RRA and certain of the 2 had with Hr. Rothstein? 3 named defendants.' A not aware of any meetings he had. 4 One of the named defendants is 4 Q Mere you aware of the walla between S Mr. Rothstein, right? 5 Mr. Rothstein and Kr. Edwards about these lawsuits? A Yea. 4 A No. Q And did Kr. Rothstein, in fact, participate 7 Q Mere you aware of the amain between Marc 4 in the Moral scheme? s Nurik and Mr. Rothstein about these lawsuits? A Yea. A No. 10 Q So what la it about that allegation that 10 Q Were you aware of any structuring of these II wan untrue when it was written? II lawsuits with Hr. Edwards and Hr. Rothstein related 12 A If it meant to include Brad and III. -- le to what would be pled? 13 O Does IX say Brad and III. in there? 13 A Am I aware -- II A No. But it could be road to mean that. So II 0 Are you aware of that? 13 saying it would false lf it was meant to include 13 A If it happened? 14 them. 14 0 Yeah. I7 O But it doesn't nay Brad and ■.? 17 A No. IS MR. SCAROLA: No, but it does say IS Q So an you sit 11024 today, isn't it true Id defendants, plural. Is that you really, as I understand it, have no personal 20 Please stop arguing. Ask gentians, 20 knowledge of the way the scheme was, in fact, 21 let the witness answer them, but p 21 conducted or who waa involved; isn't that true? 22 don't argue. 22 A I don't have any eyewitness knowledge. 23 TEE WITNESS: If it said Rothstein, It 23 Q Personal knowledge, do you, air? 24 would bo true. 24 A Personal knowledge la the lawyers term for 25 25 eyewitne➢s knowledge, and I don't have any eyewitness 154 156 1 BY KR. LINK: knowledge. 2 0 So in your world it's partially true 2 Q You don't have any, do you? 3 because It included Kr. Rothstein? Yes? So what you're telling this jury is you 4 A No, it's not in my world. It's reality. 4 happen to like Brad Edwards, and you don't want to 5 0 So I thought you told us that you had no even conceive for one second that he may have had 6 idea what was going on at the firm at the time, some connection with Mr. Rothstein in the way these 7 right? three cases wore used' is that true? S In 2000 and '09, you had no idea about the S MR. SCAROLA: Objection, argumentive. 9 Portal scheme or what Mr. Rothstein was doing, is THE WITNESS: There aro ➢tatements in 20 that right? 10 here that are categorically false because II A Right. II Jeffrey Epstein knew what he did. 12 0 Do you know every action that Mr. Edwards 12 I do like Brad Edwards, and I don't 19 took in dealing with Mr. Rothstein? 13 believe that he participated in the scheme 14 MR. SCAROLA: Excuse me. Could we ask 14 with Rothstein. 1S one question at a time? And the cm, 15 BY KR. LINK: I6 that la pending is to identify those If • I got it. But you aro not aware of any of 17 portions of the complaint which this witness 17 the evidence connecting Kr. Edwards and Hr. Rothstein 10 can identify as knowingly false statements IS that relate to the three cases that were pending at 19 by Epstein. Can we lot him finish that 19 the Rothstein firm, are you? 20 question? 20 MR. SCAROLA: Excuse me. IM going to 21 BY RR. LINK: 21 object. That question assumes that any such 22 0 You can answer my question. 22 evidence exists, when Mr. Epstein had every 23 Are you aware of all of Mr. Edwards' 23 opportunity to present that evidence to the 24 interactions with Mr. Rothstein? 24 court and has never present/pi any, because 25 A No. 23 it doesn't exist. Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798375 157 159 MR. LINK: pretty sure that lawsuit sentence had nothing to do with the Ponzi 2 has gone, Mr. scarola. Please, save the 2 schema. 3 commontary. I appreciate it. It's groat ) BY HR. LINK: 4 advice, and I will continuo to try to learn 4 Q Did Hr. Adler go to jail? 5 from you. 5 A Mr. Adler did go to jail. 6 MR. SCAROLA: Thank you. How about you 4 Q Nora you surprised that Mr. Adler would end let the witness finish the answer to your up going to jail for election Improprieties? question before you got involved -- A Yee. 9 MR. LINK: I change the question as I 1 Q How about your really good friend 10 go. I can do that. 10 Mr. Rosenfeld? 11 BY HR. LINK: II A Sams thing. 12 0 So, Mr. Borger -- 12 0 Same thing. 13 MR. SCAROLA: So as long as the record 13 So these are people that you know really 14 is clear that you have declined to allow him 14 well, right? 25 to continue to answer the question, that's Is A Right. 36 fine. 14 Q Worked wish then, trusted them, and they 21 BY HR. LINK: 13 did things that you couldn't imagine, isn't that 36 0 Is there something more you wanted to say is true? 29 about my pending question? It A That's true. 10 MR. SCAROLA: The pending question was 20 Q So the fact that you can't imagine Brad 21 to identify ovary portion of this 21 doing it doesn't moan that Brad wasn't somehow 22 complaint -- 22 connected, does it? 29 MR. LINK: Not -- 23 A Maybe to you it doesn't. 14 MR. SCAROLA: -- that Mr. Barger knows 24 Q You thought that way about Mr. Rothstein, 25 to be false. 25 didn't you? 158 160 I BY HR. LINK: MR. SCAROLA: Objection. Argumentiva, 2 Q I will give you a vary simple question. 2 repetitious. 3 Rave you reviewed any of the ommunlcations BY MR. LINK: 4 involving Rothstein and the three plaintiff cases 0 Yos, sir? that were being handled at the tins you were at the 5 A Yos. 4 Rothstein firm? 0 And Mr. Adler? 7 A I don't know of any and I haven't reviewed MR. SCAROLA: Objection. Argumentiva, any. 0 repetitious. 9 0 So isn't it true that your opinion about 9 BY MR. LINK: 10 Brad Edwards is based on your personal view of him? 20 0 And Mr. Rosonfoldt? II A And my Interaction with him. 33 MR. SCAROLA: Objection. Argumentiva, 12 Q And I suspect you wouldn't have joined the repetitious. 13 Rothstein firm if you didn't think ho was a good guy, 23 THE WITNESS: Correct. 14 would you? 24 MR. LINK: I don't have any further 15 A Yes. 25 questions. 16 Q Right. And I bet it was a shock to you 16 REDIRECT EXAMINATION 13 that ho was running a Ponzl scram, because nowhere 17 BY KR. SCAROLA: IS in your mind would you have thought that was 10 0 Ara there any other sections of this 19 possible, true? 19 complaint that you know Mr. Epstein could not have 30 A True. 20 allagod in good faith? 31 Q And probably the same thing with your 21 MR. LINK: That was not my question if 22 friend Mr. Adler. Didn't Mr. Adler have to go to 22 you want to -- 23 jail? 23 MR. SCAROLA: It's my question. ICs 34 MR. SCAROLA: Excusable. • going to 24 my question. 33 object. Compound. And Adler's jail 25 MR. LINK: okay. So you aro changing Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798376 161 163 1 the standard. That's fine. correct? 2 Do you want the rest of it back, 2 A Correct. 3 Mr. Berger? Q And were also aware at the tine that the THE WITNESS: It's along the ➢ame 4 use of initials and pseudonyms were re:patrol to 5 lines -- all of these aro basically along S protect the identity of individuals who were 6 the sane lines in terms of lumping 4 juveniles at the tine these offenses were committed • Mr. Edwards together with -- I should say ▪ against them? o Mr. Edwards and III. together with ▪ A Yes. 9 Rothstein. So that's basically the -- my Q Was there ever any effort to use initials 10 criticism of this, as well as -- as well as 10 or pseudonyms as an element in a fraudulent ➢chins as 11 any suggestion that he could have been 12 opposed to simply following the law to protect the 12 damaged. 12 identity of juveniles? 12 And if he was damaged financially, it 13 MR. LINK: going to object the 14 was -- he wasn't damaged -- he wa➢ 1 fora. going CO nova CO strike. It'➢ IS out-of-pocket financially, but it's by his beyond the scope. He did not underline any le own doing, so I wouldn't consider that to be 14 Of the phrases that you are referring to. 1> legal damages. If THE WITNESS: No. le BY MR. SCAROLA: le By MR. SCAROLA: 29 C. It was suggested that Hr. Epstein, in If Q Dld Jeffrey Epstein know that the victim 10 filing this complaint, may have somehow relied upon 20 he was abusing were juveniles at the tires he abused 21 internal email communIcationa within Rothstein, 21 them? 22 Raaaaaaadt a Adler. This complaint that we are 22 A Yea. 22 looking at -- 23 Q In paragraph 31, the allegation is made 24 MR. LINK: I am going to object. That 24 that the litigation team -- of which you were IS is not that I said. 25 identified as a member -- the litigation team reached 162 164 I BY RR. SCAROLA: agreements to share attorney'➢ foes with non-lawyers. 2 0 This complaint that we aro looking at -- 2 Dld you ever roach an agreement to ➢hare 3 MR. LINK: Mr. Scarola, you aro 3 attorney's fees with non-lawyers? 4 misstating what I ➢aid. 4 A No. 2 BY HR. SCAROLA: • Q Could there have possibly been any basis 4 Q shows a filing date of December 7, 2009. 6 for Jeffrey Epstein to have alleged that there wa➢ an 7 Do you know of any way whatsoever that Mr. Epstein 7 agreement reached by you or Brad Edwards to ➢hare S could have had access to internal aaaaaa of S attorney's fees with non-lawyers? t Rothstein, Rosonfoldt s Adler in December of 2009? 9 A No. 10 A No. 10 Q Subparagraph C says the litigation team IL MR. LINK: Move to ➢trike. II used investor money to pay plaintiffs -- that is, 12 MR. SCAROLA: Paragraph 23 of -- 12 III., E.N. and Jane Doo -- upfront noney such that 13 THE WITNESS: Excuse me. Excuse Ifia. I 13 plaintiffs would refuse to settle the civil actions. 14 at going CO frOVO strike. It'➢ a 14 Did that over happen? IS misstatement of what I said. IS A No. If BY HR. SCAROLA: If Q Could there ever have possibly been any O Q Paragraph 230C this complaint says that 11 rea➢onable basis for Jeffrey Epstein in December of IS Edwards claiming the need for anonymity with regard IS 2009 to have alleged that it happened? 19 to existing or fabricated clients, they were able to 19 MR. LINK: Object to the form. Hove to 20 effectively u➢e initials, Jane Doe or other anonymous 30 strike. 21 designations, which was a key element in the 21 How he known what's in Jeffrey's mind, 22 fraudulent SChOISO. 22 I don't know. And the words say may have. 23 Let me a➢k you, first of all, about your 23 It doesn't say it was done. 24 own conduct. You were aware that these cases were 24 You can answer. 25 being prosecuted using initials and pseudonyms, 3, THE WITNESS: No. Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798377 165 167 1 BY MR. SCAROLA: dozen of children over an extended period of time, 2 Q Were any searches, wiretaps or intercepted 2 could Jeffrey Epstein have possibly made that 3 conversations use! in violation of state or federal allegation in good faith? 4 lawn and Bar rules in connection with those -- the 4 MR. LINK: Object to the form. Move to S prosecution of the claims against Epstein? S strike. A No. THE WITNESS: No. Q Y➢u have already told u➢ that there was no * BY MR. SCAROLA: 4 unreasonable or unnec➢➢➢ary discovery that was a Q When it is alleged in subparagraph E, on * engaged in for the sole purpose of furthering the s that same page, that you and Brad Edwards together 10 panel scheme, correct? 14 addaaaaad the court on variou➢ motions using 11 A Correct. 11 ridiculous, inflammatory and sound-bite-rich 12 O Did Jeffrey Epstein know what Jeffrey 12 Matments for purposes of pumping a Penal scheme, 13 Epstein did and, therefore, recognized the fact that 13 could Jeffrey Epstein possibly have believed that to 14 when other victim' cases were being investigated, 14 DO true when Jeffrey Epstein knew that ho had, in 15 activities on the airplane were being investigated, 15 fact, engaged in dozens and dozens and dozens of 14 what Jeffrey Epstein was doing on his private Inland 14 sexual molestation crimes? 1/ was being investigated, what Jeffrey Epstein was I? MR. LINK: Object to the form and move le doing in hla 102 of millions of dollars Now York is to strike. is penthouse was doing, did he know what he himself did? Ia THE WITNESS: Ho. 20 A Of course. 20 BY MR. SCAROLA: 21 Q So whom Jeffrey Epstein alleges in 21 Q When Jeffrey Epstein alleges in 22 paragraph 33 that the litigation team know that 22 subparagraph N that the litigation team, defined as 23 issues were balm; pursued and evidence was being 2) including you, know or should have known that their 24 pursued unrelated to and unnecessary to the claim 24 filed cases were weak and had minimal value, could 2S plod in the cases on behalf of III., E.M. and Jana 2S Jeffrey Epstein, knowing what he did to those three 166 168 Doe, did Jeffrey Epstein know about those things that children, have possibly mud➢ that allegation in good 2 Jaffrey Epstein himself had done? 2 faith? 3 A Of course. 3 MR. LINK: Object to the form and move 4 Q And if Jeffrey Epstein alleges there wore 4 to strike. 5 no juveniles, no children being transported on his THE MITNESS: No. 4 plane when the flight logs reflect that there were 4 BY RR. SCAROLA: • children transported on Jeffrey Epstein•s plane when 7 0 When it is alleged In subparagraph K that • Jeffrey Epstein himself was on the plane, is there • the litigation team sought pilot and plane loge to 9 any reasonable basis for Jeffrey Epstein to have 9 prime the investment pump with new money without any 10 alleged otherwise? 10 relevance to the existing claims made by the MA 11 A No. II clients, could Jeffrey Epstein, knowing about what 12 Q Paragraph 42C on page 16 alleges that 12 went on on those airplanes, have made that allegation 13 Bradley Edwards, you and Russell Adler participated 13 in good faith? 14 in a deposition whore outrageous questions were asked 14 MR. LINK: Object to the form and move IS of Epstein which had no bearing on the case, but so IS to strike. If that the video and questions could be shown to 14 THE MITNESS: Ho. I/ inve➢tort. Is BY MR. SCAROLA: IS Could Jeffrey Epstein possibly have had IS Q If Jeffrey Epstein alleges in this IS any good faith basis for making that allegation? 19 complaint against Bradley Edwards that III., E.W. or so A No. 24 Jane Doe voluntarily consented to their sexual 21 Q When Jeffrey Epstein alleges that discovery 21 molestation, could Jeffrey Epstein have possibly made 22 was conducted and attempted, that was completely 22 that claim on the basis of any probable cause 23 irrelevant discovery, unrelated to the claims, when 23 whatsoever? 24 Jeffrey Epstein knows that he had been engaging in MR. LINK: Object to the form. 25 the sexual abuse of dozens and dozens and dozens and 35 THE WITNESS: No. Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798378 169 171 1 MR. SCAROLA: I have no further 1 REPORTER'S DEPOSITION CERTIFICATE 2 questions. 2 3 MR. LINK: I think we aro done. 3 STATE OF FLORIDA 2 4 MR. SCAROLA: Good. Thank you. : SS S THE VIDEOGRAPRER: Going off the 4 COUNTY OF PALM BEACH 2 2 I, SONJA D. MALL, certify that I was 5 record. Tho tiro is 1:32 4 authorised to and did stenographically report the MR. SCAROLA: Before we go off the 7 deposition of WILLIAM BERGER; that a review of the 8 record, would you like to road the 4 transcript was not requested, and that the transcript deposition transcript? t is a true and complete record of my stenographic 10 THE WITNESS: No. 10 notes. 11 MR. SCAROLA: Witness waives. 11 I further certify that I an not a relative, 12 - - - 12 employee, attorney, or counsel of any of the parties, 13 4Tho deposition concluded at 1:32 13 nor an I a relative or employee of any of the parties' 14 14 attorney or counsel connected with the acticm, nor am Is 15 I financially inaaaaaaad in the action. :o If 37 17 Dated this 27th day of February 2028. 30 14 9 IS 20 20 21 21 SONJA D. MAIL 22 22 22 23 14 24 26 25 170 1 STIPULATION 2 It is hereby stipulated by and between counsel for the respective parties and the witness 3 that the reading and signing of the foregoing deposition, and notice of filing be, and the soma aro 4 hereby waived. 5 A182 FURTHER DEPONENT SAITH NAUGHT f 7 CERTIFICATE OF OATH 4 STATE OF FLORIDA 2 a COUNTY OF PALM BEACH 2 10 11 I, the undersigned authority, certify that 12 WILLIAM BERGER personally appeared before ma and was 13 duly sworn. 14 WITNESS my hand and official seal this 27th 15 day of February 2028. 14 11 II It Sonja D. Hall 20 Commission No.: GC 268652 21 Notary Public - State of Florida 22 My Commission Expires: 02-01-2022 23 24 25 Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798379 172 A addition 12:22 21:2 airplanes 168:12 appealed 13:4 114:22 115:20 1:214:3 55:3,6 33:10 51:12 alive 59:16 109:22 128:19,22 140:19 able 33:10 92:1 additional 138:24 allegation 86:12 appear 98:24 140:19,20,22 134:9 162:19 addressed 11:25 139:19 142:17 appearance 46:21 141:4,5,12,19 Abrams 16:9,10,14 167:10 144:25 146:16 appearances 2:5 144:4 151:22 16:19 17:4 19:10 addressing 11:19 150:18 153:10 4:15 aspects 37:4 19:20 21:2 Adler 15:7 16:2,7 163:23 166:19 appeared 170:12 assert 134:13 absolutely 30:5 17:6,20 29:20 167:3 168:1,12 appellate 12:23,25 assets 32:24 117:1 96:19 62:21 110:25 allegations 41:5 13:3,6,16 14:18 assignment 79:1 abuse 92:6,11,17 111:7 137:17 101:25 142:20 14:22 20:2 assist 36:12 93:4 96:22 130:22 158:22,22 159:4,5 144:22 145:3,9,11 application 8:3 assistant 64:21 131.13,16,22 159:6 160:6 145:14,18,20,23 applied 7:2 103:10 132:1,20133:1,9 161:22 162:9 146:4 149:5 150:6 apply 10:13 assistants 102:2 166:25 166:13 allege 140:4,23,25 appointed 14:16,22 associate 14:2 abused 35:8 41.6 Adler's 158:25 143:12 148:1 26:8.17,21 associated 19:5 92:23 147:18 administers 11:6 alleged 39:15 40:14 appointment 28:17 22:14 29:19 77:1 148:10 163:20 administrative 92:6,17 93:4 73:16 associates 24:1 46:7 abusing 163:20 12:15 120:2 121:7 appreciate 55:17 assume 36:22 105:7 accept 121:14 admit 56:11 130:22 160:20 144:4 157:3 111:20 112:25 accepted 17:12 admitted 151:14 164:6,18 166:10 apprized 53:2 113:9 136:11 access 72:23 162:8 adult 92:19 167:8 168:7 approved 123:15 152:9 accessible 68:18,19 advantage 107:20 alleges 86:4 165:21 approximate 21:16 assumed 136:16,17 accident 94:23 advice 133:22 134:3 166:4,12,21 approximately 4:2 assumes 77:8,16 95:17 134:5,7,10 157:4 167:21 168:18 5:21 12:17 18:22 100:3 117:9 account 29:15 advise 133:25 alleging 50:19 138:4 21:24 29:17 75:25 156:21 accountable 107:14 affect 104:23 146:1 152:4 assuming 111:4 accounts 29:1,2,5 affirmed 109:21 allow 39:20 157:14 April 113:16 attack 16:13 51:9 accurate 114:13 afloat 57:22 allowed 39:21 41.13 area 9:19,20 15:21 attacks 51:7 accused 46:23 151:9 afraid 112:7 59:5 15:24 attempt 48:15 accusing 50:11 afternoon 28:5,9 allows 39:25 areas 18:3 66:25 attempted 51:9 achieved 122:3 age 8:7 101:11 amended 138:23 67:1 166:22 Ackerman 90:18 133:3,9 amendment 51:4 argue 153:22 attempting 51:1 134:24.25 135:1.2 agency 112:25 amount 32:11 34:3 argued 128:17 52:10 54:13 acknowledge 56:24 aggravate 96:6 122:1.3 123:14 arguing 118:1 attend 27:24 53:1 acknowledged aggravated 96:2 analogize 95:24 153:20 125:25 135:6 aggravating 106:14 analysis 96:17 argumentative attended 37:12 acquainted 15:14 aggressive 51:7 Andrew 138:14 107:2,16 98:21,22 99:3 acquired 19:13 87:4,7,11,18,21 anguish 94:13,15 argumentive 92:8 100:21 124:2 act 53:24 88:3 111:13 announce 4:14 109:12 113:24 attention 123:12 acted 136:5 aggressively 51:6 announced 139:2 127:3 145:6 attorney 5:18 8:15 acting 134:3 agree 52:8 57:24 anonymity 162:18 151:18 156:8 15:20 18:13 19:10 action 8:2 20:21 68:25 72:21 94:24 anonymous 162:20 160:1,7,11 19:11 20:16,20,21 154:12 171:14,15 95:8 97:8 106:5 answer 100:24 arose 11:2067:7 20:21 21:3,11 actions 164:13 108:14,16 113:7 101.3 143:4,10 arrangement 51:18 23:8,9 25:19,23 active 20:20 43:19 120:11 126:11 153:21 154:22 123:8 26:22 28:13,15 106:9 144:19 157:7.15 164:24 article 23:14 62:7 35:17,21,24 36:25 actively 137:20 agreement 36:7,8.8 answering 101:5 articles 22:9 61:20 39:20 42:16 48:6 activities 1I:11 36:15,16 44:19 140:11 62:2 51:5 52:7 53:13 37:18 165:15 51:20,22 52:5 anthrax 16:13 articulated 140:24 53:16,23 81:8 activity 29:21 40:22 99:1,18 123:18,19 anybody 56:3 76:25 asked 17:2 31:11 82:10 116:8 119:8 56:10 120:17 123:23 124:10 111.8 113:18 32:9 64:13 67:11 125:17 127:6 acts 33:11 39:22,25 128:11 164:2,7 128:15 140:21 100:22 118:21 134:4,16 143:14 actual 58:6 86:6 agreements 164:1 anymore 16:18 128:13 130:6 143:15 171:12,14 Adam 35:24 36:19 ahead 78:21 84:3 anyway 48:19 134:17 139:17 attorney's 18:5 52:6 124:5 127:7 127:8 128:14 apart 57:20 141:8,11 146:16 53:5 111:25 139:1 128:21 140:14 143:3 apologize 143:25 149:15 150:5 164:1,3,8 add 109:6 138:24 152:16 Apparently 58:8 166:14 attorney-client addicts 106:11 airplane 42:19 appeal 13:6,23 14:6 asking 105:15 106:5 124:12 134:8,14 165:15 20:11.19 23:6 106:8 107:7,9 135:21 Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798380 173 attorneys 4:14 Bankers 86:5 143:8 145:4 bought 80:2 Broward 11:8 13:7 21:15 22:14 25:6 bar 15:22 24:24 146:15 148:4 Boulevard 2:3,7,16 22:22 31:17 26:6 27:5 28:22 25:3,5 42:15 157:12,24 161:3 2:20 17:16 75:13 111:24 34:16 35:13,25 126:9 165:4 170:12 171:7 bound 40:23 Bugatti 75:21,22,23 36:10 39:2I 40:23 Barnett 138:14 Berman 90:2,4,6,10 Bova 80:3,9,10,11 75:25 77:12 45:21 47:948:15 BARNHART 2:15 116:17 119:1,18 80:11,13,14 build 108:6,8 48:24 56:13 61:2 Barry 13:11 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