Page 1
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA
CASE No.502009CA040800XXXXMBAG
JEFFREY EPSTEIN,
Plaintiff,
- vs -
SCOTT ROTHSTEIN, individually,
BRADLEY J. EDWARDS, individually, and
., individually,
Defendants.
VIDEOTAPED DEPOSITION OF JEFFREY EPSTEIN
Wednesday, March 17, 2010
10:17 a.m.- 1:27 p.m.
303 Banyan Boulevard
Suite 400
West Palm Beach, Florida 33401
Reported By:
Sandra W. Townsend, FPR
Notary Public, State of Florida
West Palm Beach Office Job 41358
PROSE COURT REPORTING AGENCY, INC.
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)
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2
3
APPEARANCES:
On behalf ofthe Plaintiff
MICHAEL PIKE,ESQUIRE
2
PROCEEDINGS I
BURMAN CFUTTONLUEIER & COLEMAN, 11? 3 Deposition taken before Sandra W. Townsend, Court
1 303 Banyan Boulevard, Suite 400 4 Reporter and Notary Public in and for the State of
West Pailikirda 33401
Phone: 5 Florida at Large, in the above cause.
0 6
On behalf of the Defendant Bradley Edwards:
JACK SCAROLA, ESQUIRE
7 VIDDOGRAPHER: We are now on video record.
SEARCY, DENNEY, SCAROLA, BARNFIART & SHIPLEY 8 This is media number one in the videotaped
2139 Palm Beach Lakes Boulevard 9 deposition of Jeffrey Epstein in the matter of
West ' 33409
10 Photo: 10 Jeffrey Epstein versus Scott Rothstein, Bradley
11. Oat:chaff° the 11 Edwards and M.
12 BRADLEY EDWARDS,I II‘IRE
FARMER, JAFFE, WESSINO, EDWARDS, HMS,
12 Today is Wednesday, March 17,2010 at
13 & LEEMAN,Pl. 13 10:17 am.
425 North Andrews Avenue 14 We are at the law offices of Burman,
14 Suite 2
Fon Lt. 33301 15 Critton — Banyan — of Burman, Critton on Banyan
15 Phone: 16 Boulevard, Suite 400, West Palm Beach, Florida.
16 Also Present 17 My name is Joe Kozak. I'm the videographcr.
11 STEVEN JAFFE, ESQUIRE
FARMER, JAFFE, WEISER:I, EDWARDS, Ftb ILb 18 The court reporter is Sandra Townsend from Prose
78 & LEHRMAN, P.L. 19 Court Reporting Agency.
425 North Andrews Avenue
19 Suite 2 20 Would Counsel please introduce yourselves and
Fon Lit da 33301 21 then the court reporter will swear in the witness.
20 Phcoe:
21
22 MR. SCAROLA: My name is Jack Scarola. I am
22 23 Counsel on behalf of Brad Edwards in his capacity,
23 24 both as Defendant and Counter-Plaintiff in this
24
25 25 action. Mr. Edwards is present with me.
Page 3 Page 5
--- 1 MR. PIKE: Michael Pike, on behalf of the
2 EXHIBITS 2 Plaintiff, Jeffrey Epstein.
3 3 MR. EDWARDS: Brad Edwards, on behalf of the
4 Defendant,M.
NUMBER DESCRIPTION PAGE 5 Also present Steve Jaffe, on behalf of the
6 Defendant, M., as well.
Exhibit number 1 Eyeglasses 133 7 THEREUPON,
8 JEFFREY EPSTEIN,
8 9 having been first duly sworn or affirmed, was examined
9 10 and testified as follows:
10 11 THE WITNESS: Yes, I do. Thank you.
11 12 MR. PIKE: Before we get started, Jack, I just
12 13 wanted to get on the record, I just want to make
13 14 sure that you received this letter that I sent to
14
15 your office yesterday of March 16, 2010.
15
16 MR. SCAROLA: !did receive the letter.
16
17 17 MR. PIKE: Okay. And we're still on for
18 18 Mr. Edwards' deposition, as we sit here today?
19 19 MR. SCAROLA: That's correct.
20 20 MR. PIKE: Okay. Thank you.
21 21 DIRECT EXAMINATION
22 22 BY MR. SCAROLA:
23 23 Q. Please state your full name and your current
24 24 residence address.
25 25 A. My name is Jeffrey Epstein. Pm currently
2 (Pages 2 to 5)
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residing at 358 El BriIto in Palm Beach. 1 your questions here today. However, on advice of
2 Q. How long have you resided at that location, 2 Counsel, I'm going to have to assert my Fifth. Sixth and
3 Mr. Epstein? 3 14th Amendment Right.
4 A. I'm sorry. On advice of Counsel today, I'm 4 Q. Are you a Plaintiff in a lawsuit against Scott
5
6
7
going to take the Fifth, Sixth and 14th Amendment with
respect to that question, Mr. Scarola.
Q. Have you maintained any other residences over
5
6
7
In,
Rothstein, Bradley J. Edwards and an individual
identified by the initials
A. Yes, sir, l am.
8 the course of the last five years? 8 Q. Who is the individual identified ass?
9 A. Though I'd Ilice to answer each and every one 9 A. I believe from depositions that I've read her
10 of your questions here today, with respect to that 10 full name is M.
11 question 15n going to have to assert my Constitutional 11 Q. When and under what circumstances did you
12 Rights as provided by the Sixth, 14th and Sixth -- 12 first meet the individual referenced by the initials
13 Fifth — sorry — Fifth, Sixth and 14th Amendment. 13
14 Q. Does anyone reside with you at the El Milo 14 A. Mr. Scarola, I think you arc awarc these
15 address? 15 questions are simply designed to have me invoke my Fifth
16 A. Again, Mr. Scarola, though Pd like to answer 16 Amendment, Sixth Amendment and 14th Amendment Right in
17 each and every one of your questions here today, at 17 relation to other questions and other cases
18 least with respect to that question, I'm going to have 18 But in response to your question, I'm going to
19 to assert my rights as under the Sixth, Fifth and 14th 19 have to invoke my right not to testify.
20 Amendment. 20 Q. Do you know the individual named ■
21 And I've been advised by Counsel, though I'd 21 identified by the initials Ini?
22 lute to answer these questions, if I do so, I risk 22 A. Mr. Scarola, at least today -- I would like to
23 losing their representation. 23 answer that question; however, today, on advice of
24 Q. What did your lawyer tell you in that regard? 24 Counsel, I'm going to have to refuse to answer that
25 MR. PIKE: I'm going to instruct you not to 25 question.
Page 7 Page 9
1 answer that question. Attomey/client. 1 Q. Have you ever acknowledged in the presence of
2 BY MR. SCAROLA: 2 any other person knowing the individual identified by
3 Q. Well, didn't you just tell me that your lawyer 3 the Initials M.?
4 advised you that ifyou answered questions he wouldn't 4 MR. PIKE: Form.
5 represent you anymore? 5 THE WITNESS: Again? Sony. Can you repeat
6 MR. PIKE: Mat's exactly what he said, 6 the question, sir?
7 Mr. Scarola, and Pm instructing him not to answer 7 BY MR. SCAROLA:
8 the question. 8 Q. Yes, sir. Have you ever acknowledged in the
9 BY MR. SCAROLA: 9 presence of any other person knowing the individual
10 Q. Okay. So I want to know then — I want to 10 identified by the initials M.?
11 know what your lawyer told you about that. 11 MR. PIKE: Perm. Also could invade
12 MR. PIKE: I'm going to instruct you not to 12 attomey/client.
13 answer that question. Attorney/client. 13 11-16 WITNESS: Again, I would like to answer
14 MR. SCAROLA: And it is our contention, 14 that question, but today I'm going to have to
15 obviously, that by making the statement that he has 15 Invoke my Fifth Amendment, Sixth Amendment and l,ttn
16 made, Mr. Epstein has waived any attorney/client 16 Amendment Right.
17 privilege with regard to that matter. 17 BY MR. SCAROLA:
18 MR. PIKE: Your contention, definitely not 18 Q. Have you ever acknowledged in the presence of
19 mine. 19 any person, other than your ownlw,=, having known the
20 BY MR. SCAROLA: 20 individual identified by the initials M.?
21 Q. Mr. Epstein, who else has shared that 21 MR. PIKE: Form.
22 residence with you at any time over the course of the 22 THE WITNESS: Again, I'd late to answer each
23 last five years? 23 and every one ofyour questions here today,
24 A. Again, Mr. Scarola, I'd like to answer that 24 Mr. Scarola; however, on advice ofCounsel, at
25 question, as Pd like to answer each and every one of 25 least today, fm going to have to reflate to answer
3 (Pages 6 to 9)
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1 that question. 1 invoke my Fifth, Sixth and 14th Amendment Right.
2 BY MR. SCAROLA: 2 Q. Have you ever acknowledged in the presence of
3 Q. Have you ever acknowledged to -- 3 Terri Becker, a court reporter present at a deposition
4 A. Excuse me. 4 taken by Brad Edwards in a — in a case in which the
5 Q. --Bradley- S individual identified by the initials' was a
6 A. Sir, may I suggest that if I say I refuse to 6 Plaintiff that you knew and/or liked —
7 answer, that it means the Fifth, Sixth and 14th or would 7 MR. PiKE: Form.
8 you prefer that I recite it each time? 8 THE WITNESS: Again, --
9 Q. I would prefer that you answer the questions, 9 BY MR. SCAROLA:
10 that's my preference. But if you're going to assert a 10 Q.
11 privilege, I will assume that if you simply say that you 11 MR. Same objection.
12 are refusing to answer, your refusal to answer will be 12 THE WITNESS: Again, I'm going to have to
13 on the basis of various Constitutional privileges 13 assert my Fifth, Sixth and 14th Amendment Right.
14 against self-incrimination without the necessity of 14 BY MR. SCAROLA:
15 specifying, 15 Q. Have you ever acknowledged in the presence of
16 If your refusal to answer is on the basis of 16 Steve Jaffe that you knew and/or likeda ?
17 any other privilege, it will be necessary for you to 17 A. Again, Mr. Scarola, though I'd I c to answer
18 identify that privilege. 18 each and every one of your questions today, Pm going to
19 A. ThanIcyou. 19 have to, at the advice of Counsel, invoke my Fifth,
20 MR. PIKE: And Pm going to instruct you, too, 20 Sixth and 14th Amendment Right.
21 when you do invoke, invoke the Fifth, Sixth and the 21' Q. Why are you suing.?
22 14th. 22 MR. PIKE: Form.
23 THE WITNESS: Yes. 23 MR. SCAROLA: Let me state for the record that
24 BY MR. SCAROLA: 24 I don't consider a form objection to be a proper
25 Q. Have you ever acknowledged in the presence of 25 objection, unless you specify the defect in the
Page 11 Page 13
1 Bradley J. Edwards that you knew the individual 1 form and provide me with an opportunity to correct
2 identified by the initials.? 2 the defect.
3 A. Pm going to have to refuse to answer that 3 MR. PIKE: That's fine. I believe the rules
4 question. 4 provide otherwise. But, nonetheless, i stand on my
5 Q. Have you ever acknowledged in the presence of 5 objection to form.
6 Bradley J. Edwards that you knew.? 6 THE WITNESS: Pm sorry. You have to repeat
7 MR. PIKE: Again, for purposes of the record, 7 the question.
I'm instructing you to invoke the Fifth, Sixth and 8 BY MR. SCAROLA:
9 14th, rather than just simply say -- 9 Q. Why are you suingM?
10 THE WITNESS: Okay. 10 MR. PIKE: Fonn.
11 MR. PIKE: —I refuse to answer. I want it 11 11W WITNESS: is part of a conspiracy
12 to be clear for the Court that you have invoked 12 with Scott Rothstein, ley Edwards, creating --
13 your Fifth, Sixth and 14th. 13 excuse me — creating fraudulent cases of a
14 THE WITNESS: Fine. 14 sexually charged nature in which the U.S. Attorney
15 Then on advice of Counsel, I'm going to have 15 has already charged the firm of Rothstein, a firm
16 to invoice my Fifth, Sixth and 14th Amendment Right. 16 of which Bradley Edwards is a partner, was a
17. BY MR. SCAROLA: 17 partner, with creating, fabricating malicious cases
18 Q. Have you ever acknowledged in Brad Edwards' 18 of a sexual nature, including cases with respect to
19 presence that you liked the individual identified by the 19 me, specifically, in order to fleece unsuspecting
20. initials.? 20 investors in South Florida out of millions of
21 A. Again, Pm going to have to invoke my Fifth, 21 dollars.
22 Sixth and 14th Amendment Right, Mr. Scarola. 22 BY MR. SCAROLA:
23 Q. Have you ever acknowledged in Bradley Edwards' 23 Q. What role do you contend =. played in that
24 presence that you liked 24 conspiracy to create fraudulent cases
25 A. Again, Mr. Scarola, fm going to have to 25 A. testimony before she met Mr. Edwards
•••
4 (Pages 10 to 13
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MIIIIIIIMIOMI
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was dramatically -- sworn testimony to the FBI was 1 according to you, she met Mr. Edwards and changed her
2 dramatically different after she came in contact with 2 testimony, true?
3 Mr. Bradley Edwards, where her testimony then changed to 3 A. Did she change her testimony? Is that — yes,
4 sort ofa hostile and had claims of -- claims never made 4 her testimony was changed.
5 before, never made to anyone before, and allegations 5 Q. My question to you is: Was her testimony
6 that i've read in her Complaint that that had been which you contend was changed true testimony?
dramatically different from the ones she had spoken to 7 A. Your question is not a good question. Is it
the FBI about, sir. 8 her testimony before or after?
9 Q Is it your contention that as statement to 9 Q. Was the subsequent testimony given by
10 the FBI was true? 10 after she met Mr. Edwards which you contend was
11 MR. PIKE: Form. 11 different from her testimony before the FBI, was the
12 THE WITNESS: Mr. Scarola, unfortunately, 12 subsequent testimony true or false?
13 today with respect to that question, iin going to 13 MR. PIKE Form.
14 have to assert my Fifth, Sixth and 14th Amendment 14 THE WITNESS: Sr, I'm going, at least today,
15 Right. Though I know — I believe you know the 15 Pm going to have to assert my Fifth, Sixth and
16 answer to that question, I can't answer the 16 14th Amendment Right
17 question under advice of Counsel. And hes told me 17 BY MR. SCAROLA:
18 if i chose to do so, I risk losing his 18 Q. Did you ever engage in any sexual conduct with
19 representation. 19
20 BY MR. SCAROLA: 20 . I would like to answer that question, but —
21 Q. What is the basis of your belief that i know 21 Q. You don't need to tell me what you'd like to
22 the answer to the question? 22 do, Mr. Epstein. You just need to do it, please.
23 MR. PIKE: Form. 23 THE WITNESS: Please —
24 THE WITNESS: You — I believe you have seen 24 MR. PIKE Mr. Smola, please let the witness
25 this, because you're supposed to be a decent 25 finish his response.
Page 15 Page 17
1 lawyer, youfve read the testimony. I would guess 1 MR. SCAROLA: That's not a response to my
2 you've read the difference in her testimony to the 2 question.
3 FBI versus her testimony after she's met your 3 MR. PIKE: In your mind it may not be a
4 client and his partners, who are currently in jail. 4 response. In a Judge's mind, it may be. We may
5 BY tvfit. SCAROLA: 5 have to certify it to the Court. If such a
6 Q. How does that respond to my question as to 6 procedure even exists, we can take it up with the
7 whether you contend that her testimony to the FBI was Court. But please let the witness finish his
8 true or false? 8 response.
9 MR. PIKE: Form. 9 THE WITNESS: Again, please?
10 THE WITNESS: I don't believe that was your 10 BY MR. SCAROLA:
11 question. Will you repeat? 11 Q. Did you engage — ever engage in any sexual
12 BY MR. SCAROLA: 12 conduct with M7
13 Q. Okay. Well, let's let me rephrase the 13 A. I would u e to answer that question; however,
14 question then. 14 today Pm going to have to assert my rights as provided
15 Is it your contention that M.'s statement to 15 by the Fifth, Sixth and 14th Amendment to that question,
16 the FBI was true? 16 sir.
17 A. Sr, on advice ofCounsel, at least today, Pm 17 Q. Have you ever exchanged anything of value with
18 going to have to assert my Fifth, Sixth and 14th 18
19 Amendment ejR tt. 19 MR. PiKE: Form.
20 Q. Was M.'s statement to the FBI false in any 20 THE WITNESS: At least today, I'm going to
21 respect? 21 have to assert my Fifth, Sixth and 14th Amendment
22 A. Sir, at least, again, today, on advice of 22 Right, sir.
23 Counsel, Pm going to have to assert my Fifth, Sixth and 23 BY MR. SCAROLA:
24 14th Amendment Right. 24 Q. Did you ever direct anyone to deliver anything
25 Q. Was .'s subsequent testimony after, 25 of value to .7
5 (Pages 14 to 17)
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MIL PIKE: Form. 1 which is outrageous.
THE WITNESS: At least today, I'm going to 2 BY MR. SCAROLA:
3 have to refuse to answer that question based on the 3 Q. How much have you settled claims for?
4 Fifth, Sixth and 14th Amendment 4 MR. PIKE: ism going to instruct you not to
5 BY MR. SCAROLA: 5 answer that question.
6 Q. Do you Imow 6 MR. SCAROLA: And the basis of that
A. At least today, sir, 1'm going to have to 7 instruction is?
3 refuse to testify about that question. Based on advice 8 MR. PIKE: Confidential settlement agreements.
9 of Counsel, I'm going to have to assert my Fifth, Sixth 9 to the extent that they exist. And the terms would
10 and 14th Amendment Ri t. 10 be confidential.
11 Q. Di introduce you to M.? 11 BY MR. SCAROLA:
12 A. Sir, nape...tfully, I'd like to answer that 12 Q. Have you settled claims?
13 question today. As I said, I'd like to answer each and 13 A. Yes, l have.
14 every one of your questions. However, on advice of my 14 Q. What is the nature of the claims you settled?
15 Counsel today, inn going to have to assert my Fifth, 15 MR. PIKE: Pm going to instruct you not to
16 Sixth and 14th Amendment Right. 16 answer that question.
17 Q. Did M. suffer any dama ts a consequence of 17 BY MR. SCAROLA:
18 any interaction between you and M.? 18 Q. How many claims have you settled?
19 MR. PIKE: Form. 19 MR. PIKE: IN going to instruct you not to
20 THE WITNESS: Could you repeat the question, 20 answer that question as well.
21 please? 21 MR. SCAROLA: What is the basis for those
22 BY MR. SCAROLA: 22 instructions?
23 Q. Did IN. suffer any damage as a consequence of 23 MR. PIKE: Confidential, as well as there is a
24 any interaction between you and M.? 24 VICTIM'S Right Statute that may — you may be
25 MR. PIKE: Form. 25 tiptoeing into the identity of -
Page 19 Page 21
1 THE WITNESS: I'd hie to answer each and 1 MR. SCAROLA: Pm not tiptoeing anywhere.
2 every one of your questions here today, 2 MR. PIKE: Let me finish my objection,
3 Mr. Scarola; however, on advice of Counsel, today, 3 Mr. Scarola.
4 Pm going to have to assert my Fifth, Sixth and 4 You may be tiptoeing into the identity of
5 14th Amendment Right. 5 various alleged victims underneath the Victims
6 BY MR. SCAROLA: 6 Right Statute, as well as ongoing investigations or
Your Complaint in this action alleges that 7 past investigations that have remained open with
8 . made claims for damages out of proportion to her the State, as well as the Federal Government.
9 alleged damages. What does that mean? 9 So in that regard, we would have to put the
10 A. It means what it says. 10 State Attorney, as well as the Federal Government
11 Q. I don't understand it. Explain it to me. 11 on notice that you were seeking to potentially back
12 MR. PiKE: To the extent you can answer that 12 door certain identities at this deposition.
13 question without disclosing my conversations with 13 BY MR. SCAROLA:
14 you or Mr. Critton's conversations with you, as 14 Q. Other than having allegedly given different
15 well as my work product, you can answer the 15 testimony before she met Mr. Edwards then given after
16 question. 16 she met Mr. Edwards, did S do anything else that
17 THE WITNESS: I believe that as part of the 17 forms the basis for your claim against her?
18 scheme to defraud investors in South Florida out of 18 MR. PUCE: Form. Asked and answered.
19 millions of dollars, claims of outrageous sums of 19 THE WITNESS: I'd like to answer that
20 money were made on behalf of alleged victims across 20 question, as well as every one of your questions
21 the board. And the only way — in fact, Scott 21 with respect to M. here today; however, on advice
22 Rothstein sits in jail. And what I've read in the 22 of Counsel, at least today, Mr. Scarola, Pm going
23 paper, claims that I've settled cases for 23 to have to assert my Sixth Amendment, Fifth
24 S200-million, which is totally not true. 24 A•essIntent and 14th Amendment Right.
25 She has made claims of serious sum of money, 25 BY MR. SCAROLA:
6 (Pages 18 to 21)
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1 Q. Did fail to do anything that she had an 1 MR. PIKE: Mr. Scarola, that's the second time
2 obligation, duty or responsibility to do 2 that I'm going to ask you not to interrupt the
3 MR. PIKE: Form. 3 witness when he's giving a response. He is giving
4 BY MR. SCAROLA: 4 a response. When he finishes his response, you can
5 Q. — that forms the basis for your claim against 5 go on with your next question or you can — you can
her? 6 elicit any sort of information you intend to elicit
7 MR. PIKE: I apologize. Form. 7 from the witness.
8 THE WITNESS: Again? I'm sorry. Has she 8 MR. SCAROLA: He's being unresponsive.
9 failed to do? Can you repeat? 9 MR. PIKE: No, that's your contention.
10 BY MR. SCAROLA: 10 MR. SCAROLA: No, that's a fact.
11 Q. Yes, sir. Lawsuits are generally based, civil 11 MR. PIKE: And you can take it up with a
12 lawsuits are generally based on a claim that someone has 12 Judge. And if we want to continue going back and
13 done something that they shouldn't have done or failed 13 forth and bantering, not allowing the witness to
14 to do something that they should have done. 14 answer the question — we're here for you today,
15 I asked you whether did anything that she 15 for you to ask the questions and for you to get
16 shouldn't have done and you asserted a Fifth Amendment 16 answers. But if you continue to banter with the
17 privilege in refusing to answer that question. 17 witness and interrupt the witness, I will adjourn
18 I'm now attempting to find out whether ■. 18 the deposition. This is not proper and we
19 failed to do something that she should have done that 19 certainly can take it up with the Judge. So that's
20 forms the basis of your claims against her. 20 the second warning, Mr. Scarola. Please —
21 DidM. do anything that she should have done 21 MR. SCAROLA: How many do I get?
22 that forms the basis of your claims against her? 22 MR. PIKE: Inn not sure yet today.
23 MR. PIKE: Form. 23 MR. SCAROLA: Okay.
24 THE WITNESS: On advice ofCounsel, at least 24 MR. PIKE: Okay?
25 today, Mr. Scarola, Pm going to have to refuse to 25 MR. SCAROLA: Good. Then let's move on.
Page 23 Page 25
1 answer that question based on my Fifth Amendment, 1 MR. PIKE: But I can tell you one thing: On a
2 Sixth Amendment and 14th Amendment Right. 2 professional nature, just because you are
BY MR. SCAROLA: 3 interrupting the witness and bantering with me, I
4 Q. Did Brad Edwards do anything that he shouldn't 4 will adjourn the deposition.
have done that forms the basis of your lawsuit against 5 BY MR. SCAROLA:
6 him? 6 Q. Besides having gone to the media in an attempt
MR. PIKE: Form. 7 to, quote, gin up, unquote, these allegations and
8 THE WITNESS: Yes, many things. 8 engaged in what you contend to be irrelevant discovery
9 BY MR. SCAROLA: 9 proceedings, what else did Mr. Edwards, personally, do
10 Q. List them forme, please. 10 that forms the basis for this lawsuit?
11 A. He has — he has gone to the media out of, I 11 A. Mr. Edwards, personally, engaged with his
12 believe, in an attempt to gin up these allegations. Ho 12 partners, Scott Rothstein, who sits in a Federal jail
13 has contacted the media. He has used the media for his 13 cell, potentially for the rest ofhis life, he shared
14 own purposes. He has brought discovery — he has 14 information, what I've been told and — excuse me —
15 engaged in discovery proceedings that bear no 15 what I've read in the newspapers, 13 boxes of
16 relationship to any case filed against me by any ofhis 16 information that had my name on it, with other attorneys
17 clients. 17 at his fum
18 His firm, which he's the partner of, has been 18 Ho counseled his clients to maintain a
19 accused of forging a Federal Judge's signature. 19 position alleging multi-million dollar damages in order
20 Q. I want to know what Mr. Edwards — 20 for them to scam local investors out ofmillions of
21 MR. PIKE: One second. 21 dollars.
22 THE WITNESS: Excuse me. I'm answering. 22 He and his — many ofhis other partners
23 BY MR. SCAROLA: 23 already under investigation by the FBI and the U.S.
24 Q. I %nut to know what Mr. Edwards did. I'm not 24 Attorney have been accused by the U.S. Attorney of
25 asking you about allegations concerning his law firm. 25 running a criminal enterprise.
7 (Pages 22 to 25)
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1 Q. Anything else? 1 Q. Do you understand the question you're supposed
2 MR. PIKE: Form. 2 to be answering, Mr. Epstein?
3 THE WITNESS: Not I can think of at the 3 MR. PIKE: And Fm going to instruct you not
4 moment. 4 to answer that question right now because as your
5 BY MR. SCAROLA: 5 Counsel I cannot let you answer that question until
6 Q. Okay. What media did Mr. Edwards go to? 6 I understand what question is on the table.
7 A. I am aware of at least the Daily News in New 7 There's been a lot of bantering back and
8 York City. 8 forth, so, Mr. Scarola, if you would respectfully
9 I have been told by other people that there 9 repeat the question and then you may be able to ask
10 were other media, local media. 10 him whether or not he understands the question.
11 I've been told that the -- his investigator 11 But I cannot allow him to answer a question that I
12 was sent to California to harass people representing 12 don't understand is on the table.
13 his — Brad Edwards' investigator -- representing 13 BY MR. SCAROLA:
14 fictitiously, fraudulently that he was a FBI agent to 14 Q. What does an investigator going to California
15 try to gather information for Mr. Edwards' claims. 15 have to do with Mr. Edwards allegedly going to the media
16 Q. Does that have something to do with going to 16 in an attempt to, quote, gin up, unquote, these
17 the media? 17 allegations?
18 MR. PIKE: Form. 18 MR. PIKE: Please answer the question.
19 THE WITNESS: I've answered your question. 19 THE WITNESS: Good. It's part of Mr. Edwards'
20 BY MR. SCAROLA: 20 scheme to involve people who have nothing to do
21 Q. Does the investigator going to California to 21 with any of his cases in order to, in fact, go back
22 do something have something to do with the media? 22 to the media and gin up his stories and make false
23 A. I believe I've also told that you that he's 23 allegations of people that have sexually charged
24 gone to the Daily News, sir, is that coned? 24 nature cases in order to attempt to fleece
25 MR. PIKE: Form. Mischaracterizes the 25 investors, local investors out of millions of
Page 27 Page 29
1 witness' testimony as well. 1 dollars.
2 BY MR. SCAROLA: 2 His firm has been accused by the U.S. Attorney
3 Q. Do you understand the question that you're 3 of manipulating the media, by hiring investigators,
4 supposed to be answering? 4 by illegal wire taps, by illegal methods of
S MR. PIKE: Well, let's go ahead and repeat it. 5 eavesdropping in order to go to the media and
6 MR. SCAROLA: No, let's get an — let's get an 6 generate cases.
7 answer to that question. 7 BY MR. SCAROLA:
a BY MR. SCAROLA: 8 Q. When did Mr. Edwards go to the Daily News?
9 Q. Do you understand the question you're supposed 9 A. I don't know.
10 to be answering? 10 Q. How did he go to the Daily News?
11 A. When - 11 A. I don't know.
12 MR. PIKE: I'm confused. Wait one second. 12 Q. What did he say to the Daily News?
13 THE WITNESS: Sony. 13 A. I believe Mr. Edwards knows that. I don't
14 MR. PIKE: I'm confused as to what question is 14 know exactly what he said.
15 on the table. 15 Q. What is the source of your information that he
16 MR. SCAROLA: And when your deposition is 16 went to the Daily News at all, ever?
17 being taken, your confusion is relevant and 17 MR PIKE: To the extent you can answer that
18 material. 18 question without violating any attorney/client
19 MR. PIKE: Right. And it's — 19 privileges, you can answer the questions.
20 MR. SCAROLA: When Mr. Edwards' — excuse 20 THE WITNESS: It's attorney/client
21 me — when Mr. Epstein's deposition is being taken, 21 BY MR. SCAROLA:
22 I'm concerned with whether he understands the 22 Q. You said you were told by other people that he
23 question being asked. 23 went to other media representatives?
24 MR. PIKE: Right. So... 24 A. Yes, sir.
25 BY MR. SCAROLA: 25 Q. Who are the other people that told you that?
A......e..14A4,
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1 A. I don't recall at the moment- 1 themselves or were these anonymous callers?
2 Q. What did these other people who you don't 2 MR. PIKE: Form. 1
3 remember tell you Mr. Edwards did with respect to other 3 THE WTINESS: Sitting here today, Mr. Scarola,
4 media representatives besides the Daily News? 4 I don't recall with specificity.
S A. Again, the question again? 5 BY MR. SCAROLA:
6 Q. What did these other people tell you 6 Q. What specifically did Mr. Edwards allegedly
7 Mr. Edwards did with respect to going to other media? 7 communicate to the Daily News to, quote, gin up these
8 MR. PIKE: Form. 8 allegations, unquote?
9 THE WITNESS: Mr. Edwards went to the media to 9 A. The newspapers have quoted Mr. Edwards -- not
10 gin up his cases in order that the Rothstein firm 10 quoted Mr. — newspapers have made allegations referred
11 could generate profits, falsely taking in 11 to as Mr. Edwards' statements.
12 investors, creating false stories to the local 12 MR. SCAROLA: Would you read the question
13 medial and making statements to local press 13 back, please, Sandy?
14 regarding false claims made by his clients in order 14 (Pending question was read.)
15 that Scott Rothstein, who currently sits in jail, 15 MR. PIKE: Did he answer your question?
16 could defraud, along with his other partners ofhis 16 MR. SCAROLA: No.
17 fimi, local Florida investors, Mr. Scarola, out of 17 MR. PIKE: Are you asking him again?
18 millions of dollars. 18 THE WITNESS: So you're asking the question
19 BY MR. SCAROLA: 19 again?
20 Q. When did these other people whose identity you 20 BY MR. SCAROLA:
21 can't remember tell you these things that Brad Edwards 21 Q. Yes.
22 did? 22 THE WITNESS: Sony. Could you repeat the
23 A. Sometime in the past year. 23 question again?
24 Q. How many other people were there who told you 24 (Pending question was read.)
25 these things about Mr. Edwards? 25 THE WITNESS: He alleged that third parties
Page 31 Page 33
1 A. I don't recall with specificity. 1 had already been involved in some allegations to do
2 Q. Well, do you recall in any degree how many 2 with sexual misconduct.
3 there were? 3 BY MR. SCAROLA:
4 A. I would say, probably five to ten. 4 Q. Which third parties?
5 Q. Where were you when these conversations took 5 A. 1don't recall sitting here today.
6 place that you can't -- the identity of whose 6 Q. Involved how?
7 participants you can't remember? MR. PIKE: Form.
8 MR. PIKE: So we're clear, within the last 8 THE WITNESS: If 1recall with specificity, if
9 year -- correct? — timewise? 9 I had the articles in front ofme, l would be able
10 MR. SCAROLA: Well, that's what your client 10 to recall. Maybe next time.
11 said. I don't believe a word he says, but that's 11. BY MR.. SCAROLA:
12 what he said. 12 Q. What does "gin up these allegations' mean?
13 MR. PIKE: Form. Objection. Overbroad. 13 MR. PIKE: Form.
14 THE WITNESS: Again, sir? 14 THE WITNESS: It means craft allegations of
15 BY MR. SCAROLA: 15 multi-million dollar cases; in fact, alleging in
16 Q. Yes, sir. Where did these conversations with 16 case damages of $50-million, settlements in
17 these five to ten people take place whose identity you 17 order for Scott Rothstein and the rest of
18 can't remember? 18 Mr. Edwards' partners to fleece unsuspecting
19 MR. PIKE: Form. 19 investors out ofmillions and millions of dollars
20 THE WITNESS: On the telephone. 20 based on cases that didn't exist or alleged cases
21 BY MR. SCAROLA: 21 that I had settled.
22 Q. Who initiated the phone calls? 22 Can I take a break?
23 A. Sir, these questions, l have no -- I don't 23 VIDEOGRAPHER: Going off video record, 10:50.
24 have any recollection. 24 (Brief recess.)
25 Q. Did the people who were on the phone identify 25 VIDEOGRAPHER: We're now on video record at
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1 10:57 a.m. 1 Q. I want to know whether when you use the phrase
2 BY MR. SCAROIA: 2 "gin up" and the word "crafted," which you have told us
3 Q. Was your reference to, quote, gin up these 3 is synonymous with gin up, --
4 allegations, unquote, a reference to allegations made 4 A. Yes.
5 against you? 5 Q. -- you mean fabricated?
6 MR. PIKE: Form. 6 A. I'm sorry. On advice of Counsel, sir, and
7 THE WITNESS: As part of the vast conspiracy 7 I've answered that question before, but if you didn't
8 of the Rothstein firm and Mr. Edwards' 8 hear me the first time, I must assert my Fifth, Sixth
9 participation in it, it has been alleged that many 9 and 14th Amendment Right.
10 cases were fraudulently brought — alleged that 10 Q. What specific discovery proceedings did
11 have been brought; ginned up, meaning, crafted, 11 Mr. Edwards engage in which you contend form the basis
12 multi-million dollar numbers put on cases in order 12 for your lawsuit?
13 to fleece investors, where his partner, Scott 13 A. The discovery proceedings of bringing my
14 Rothstein, currently sits in jail for just those 14 attorneys to various people that had nothing to do with
15 purposes, Mr. Scarola. 15 any ofhis clients or these lawsuits.
16 BY MR. SCAROLA: 16 Q. Which various people? Who?
17 Q. My question to you is: Did the reference to, 17 MR. PIKE: Form.
18 quote, gin up these allegations refer to allegations 18 THE WITNESS: For example, he tried to depose
19 against you? 19 Bill Clinton, strictly as a means of getting
20 A. Reported in the newspaper the answer is, yes. 20 publicity so diat he and his firm could
21 And others, but specifically me, yes, by the newspaper 21 fraudulently steal, craft money from unsuspecting
22 reports. 22 investors in South Florida out of millions of
23 Q. Specifically what are the allegations against 23 dollars.
24 you which you contend Mr. Edwards ginned up? 24 BY MR. SCAROLA:
25 A. I would like to answer that question. A, many 25 Q. Who else besides Bill Clinton is included in
Page 35 Page 37
1 of the files and documents that we've requested from 1 your reference to various people?
2 Mr. Edwards and the Rothstein firm are still 2 A. There are people in California There are
3 unavailable. 3 people in New York.
With respect to anything that I can point to 4 Q. Would you name them for us, please?
5 today, I'm, unfortunately, going to have to take the 5 A. I'm sony. Sitting here today, Mr. Scarola,
6 Fifth Amendment on that, Sixth and 14th. 6 Fm going to have to assert my Fifth Amendment, Sixth
7 Q. You seemed to be defining ginned up as 7 Amendment and 14th Amendment Right.
3 crafted; is that correct? 8 Q. Let's then talk about Bill Clinton, by whom !
9 A. That's correct. 9 assume you mean fonner President Clinton; is that
10 Q. Does ginned up or crafted mean fabricated? 10 correct?
11 MR PIKE: Form. 11 A. That's correct.
12 THE WITNESS: I'm sorry, Mr. Scarola. 12 Q. All right. Do you know former President
13 understand that you are trying to back door your 13 Clinton personally?
14 way into a waiver ofmy Fifth Amendment. But 14 A. I'm sorry. As I sit here today, thoughId
15 respect to that question, I'm going to have assert 15 like to answer that question, on advice ofmy Counsel,
16 my Fifth Amendment, Sixth Amendment and 14th 16 at least today, I'm going to have to take the Fifth,
17 Amendment Right. 17 Sixth and 14th Amendment.
18 BY MR. SCAROLA: 18 Q. You said something about Mr. Edwards sharing
19 Q. So you are asserting your Fifth Amendment, 19 13 boxes ofinformation with somebody —
20 Sixth Amendment and 14th Amendment Right to remain 20 A. Yes.
21 silent about what you mean when you use the words "gin 21 Q. — as forming part of the basis for your
22 up" and "crafted;" is that correct? 22 lawsuit against Mr. Edwards, correct?
23 A. I don't believe that was your question. 23 A. Correct.
24 Q. Yes, sir, that's exactly my question. 24 Q. All right. With whom did Mr. Edwards share
25 A. Would you repeat the question for me? 25' these 13 boxes ofinfomartion?
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1 A. It has been reported in the Scherer Complaint 1 Amendment Right, sir.
2 that he shared those boxes with the partners of his firm 2 Q. Your Complaint also makes reference to a claim
3 that was then formally accused by the U.S. Attorney, 3 on behalf of Jane Doe, referred to as Jane Doe versus
4 sir, of being a criminal enterprise. 4 Epstein, case number 08-CIV-80893, a case pending in the
5 MR. PIKE: And just for purposes -- 5 United States District Court for the Southern District
6 BY MR. SCAROLA: 6 ofFlorida.
7 Q. Do you remember my question? 7 Is it your contention that the claim on behalf
8 A. You asked me who he shared it with? 8 of Jane Doe is a fabricated claim?
9 Q. Yes. 9 A. Sir, though I'd like to answer that question,
10 A. The partners ofhis firm, sir. 10 as well as every one of your other questions here today,
11 Q. Okay. So part of the basis of your lawsuit is 11 today I'm going to have to assert my rights as under the
12 that Mr. Edwards allowed members ofhis own law firm to 12 Constitution of the Fifth, Sixth and 14th Amendment.
13 see 13 boxes of information; is that correct? 13 Q. Do you blow the real name of the person
14 A. No. that's not correct. My claim is that the 14 referred to as Jane Doe in that case?
15 13 boxes of information that wore shown to investors by 15 A. i don't know which — I5n sorry, sir. Ho
16 Mr. Edwards' partners, 13 boxes that we've been told by 16 not, sitting here today.
17 the press contain multiple cases, fraudulently -- and if 17 Q. Did you ever have personal contact with the
18 you like the word -- fabricated in order to fleece 18 person referred to by the name Jane Doe in that lawsuit?
19 investors out ofmoney. The 13 boxes were shared with 19 A. I'm sorry, sir. Sitting here today, I'm going
20 investors, Mr. Edwards, Mr. Edwards' partners and some 20 to have to assert my Fifth, Sixth and 14th Amendment
21 of those partners currently under inditement, the others 21 Right.
22 already sitting in jail. 22 Q. When did you first meet the person referred to
23 Q. I had asked you earlier whether ginned up and 23 as Jane Doe?
24 crafted meant fabricated and you asserted your Fifth 24 A. Sir, though I'd like to answer each and every
25 Amendment privilege. 25 one of your questions here today, at least with respect
Page 39 Page 41
1 Are you now telling us that there were claim 1 to that question, I'm going to have to assert my rights
2 against you that were fabricated by Mr. Edwards? 2 under the Sixth Amendment, 14th Amendment and Fifth
3 A. I'm going to again assert my Fifth, Sixth and 3 Amendment.
4 14th Amendment Right, sir. 4 Q. Where did you first meet the person referred
5 I would respond that the newspapers are very 5 to as Jane Doe?
6 clear that the cases were fabricated. 6 A. Sir, though I'd like to answer that question
7 Q. Which newspaper said which case was 7 here today, at least today on advice of Counsel, I'm
fabricated? 8 going to have to assert my Fifth Amendment, Sixth
9 A. Bob Norman's blog said most of the eases were 9 Amendment and 14th Amendment Right
10 fabricated, to my best recollection. 10 Q. How many times have you been in the physical
11 The Scherer Complaint alleged many fabricated 11 presence of the person referred to as Jane Doe?
12 cases, sir. 12 A. The person referred to as Jane Doe?
13 Q. Well, which ofMr. Edwards' cases do you 13 Q. Yeah. How many times have you been in her
14 contend were fabricated? 14 physical presence?
15 A. Again, we've requested most of the -- 15 MR. PIKE: Form.
16 information from the bankruptcy trustee. We've been 16 THE WITNESS: At least -- at least sitting
17 unable — Mr. Edwards has not given us the total file, 17 here today, Mr. Scarola, I'm going to have to
18 but respect to any individual, I would have -- at the 18 assert my Fifth Amendment, Sixth Amendment and 14th
19 moment I would have to assert my Fifth, Sixth and 14th 19 Annulment Right
20 Amendment claim, sir. 20 BY MR. SCAROLA:
21 Q. So you will not answer questions about whether 21 Q. Dld you ever have any physical contact with
22 the claim on behalf of.. was fabricated; is that 22 'arse Doe?
23 correct? 23 MR. PIKE: Form.
24 A. I believe I've already answered that, but, if 24 THE WITNESS: Now, for this purposes, you're
25 again, have to assert my Fifth, Sixth and 14th 25 assuming this Jane Doe is somebody I know? 1don't
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1 think so, since this question makes no sense to me. 1 to as M.?
2 BY MR. SCAROLA: 2 A. I believe it is
3 Q. You have alleged in your Complaint that there 3 Q. How long have you known
4 is a claim on behalfof Jane Doe versus Epstein pending 4 A. Well, with respect to that question,
5 in the Federal District Court of the Southern District 5 Mr. Scarola, I'm going to have to assert my Fifth, Sixth
ofFlorida. 6 and 14th Amendment Rights, though rd like to answer
7 I would like to 'mow whether you ever had any 7 every, single question you have about
a physical contact with the person referred to as Jane Doe 8 Q. How many times have you been in the physical
9 in that Complaint? presence of.?
10 A. Ah, that lane Doe. Pm sorry. But sitting 10 A. I'd like to answer every question about..
11 here today, Mr. Scuola, I'm going to have to refuse to 11 that you have today, Mr. Scarola; however, on advice of
12 answer that question based on the Fifth Amendment, Sixth 12 Counsel, Fm going to have to assert my Fifth, Sixth and
13 Amendment and 14th Amendment. 13 14th Amendment Right.
14 Q. Did you ever exchange any money or gifts with 14 Q. How old is M.?
15 Jane Doe? 15 A. I don't know.
16 A. Again, Mr. Scarola, sitting here today, fm 16 Q. How old was she when you met her?
17 going to have to on advice of Counsel assert my Sixth 17 A. Mr. Scarola, Fm going to have to assert my
18 Amendment, Fifth Amendment and 14th Amendment Right. 18 rights under the Fifth, Sixth and 14th Amendment on
19 Q. Your Complaint makes reference to a case 19 advice of Counsel, though I would like to answer every
20 stylec=aetsus Epstein, case number 20 one of these questions.
21 502008CA028058XXXXMBAB, a case pending in the Circuit 21 Did you ever have any physical contact with
22 Court ofPahn Beach Cot Florida. 22
23 Do you know who MI. is? 23 A. Mr. Scarola, once again, I would like to
24 A. Sitting here today, Mr. Scarola, I'm going to 24 answer each one of your questions here today, but on
25 have to assert my rights as under the Fifth, Sixth and 25 advice of Counsel rm going to have to assert my Fifth,
Page 43 Page 45
1 14th Amendment. 1 Sixth and 14th Amendment Right.
2 Q. Have you ever learned the real name of.'" 2 Q. Did you ever exchange any money or gifts with
3 A. Yes, sir. 3
4 Q. Did that person whose real name you learned 4 A. Sir, Tel like to answer every question you
5 ever spend any time in your physical presence? 5 have about..; however, today, on advice of Counsel
6 A. Sir, at least sitting here today, I would like 6 Pm going to have to assert my Fifth, sixth and 14th
7 to answer each and every one of your questions regarding 7 Amendment Right.
8 your ft and — are we not allowed to use the names of 8 Q. Did you ever cause any money or gifts to be
9 these people, sir? delivered to..?
10
11
12
MR. PIKE: In the past — in the past cases
the names of these individuals have been utilized
for deposition purposes.
10
11
12
IL
A. Mr. Scarola, as I've answered most of your
questions here today regarding
answer every question regarding
I would like to
; however, today, on
13 Brad Edwards, sitting here today, knows that 13 advice of Counsel, I'm going to have to assert my Fifth,
14 we have used; however, any documents that are filed 14 Sixth and 14th Amendment Right because though I would
15 with the Court will redact those names. 15 choose to do so, I've been told that if I do so, I risk
16 So the answer to the question is, yes, for 16 losing my Counsel's representation.
17 purposes of this deposition, to the extent you know 17 Q. What is the actual value that you contend the
18 the names of individuals, you can utilize them with 18 claim of.. against you has?
19 agreement of Mr. Edwards. 19 MR. PIKE: Form. Relevance.
20 MR. EDWARDS: 1 have no problem with that. 20 THE WITNESS: _ iriS_though I'd like to answer
21 THE WITNESS: I think to avoid conflision, so 21 every question about M. and her claims and the
22 there's not — I know who you're talking about. 22 claims of your other people, on advice of Counsel
23 That's all. 23 here today, I cannot do so. I must assert my
24 BY MR. SCAROLA: 24 rights under the Sixth, Fifth and 14th Amendment.
25 Q. What is the real name of the person referred 25 BY MR. SCAROLA:
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Would your answer be the same with regard to 1 A. No. I answered that question, which is, I'd
and to Jane Doe? 2 like to know.
MR. PIKE: Fm going to instruct you if your 3 Q. Yes. But that isn't an answer to my question.
4 answer is the same, to invoke in full. 4 My question is: By whom was Mr. Edwards
5 THE WITNESS: With respect to, I believe, Janc 5 employed at the time that he initiated litigation
o Doe — and who is the other person? Fm sorry. 6 against you? Do you know the answer to that question?
7 BY MR. SCAROLA: 7 A. I'd have no way of knowing the answer to that
3 Q. 8 question, sir.
9 A. Thmigh I'd lthe to answer your claims 9 Q. Among the allegations of wrongdoing against
10 with respect to all three of Mr. Edwards' clients, on 10 Mr. Edwards which you contend form the basis of this
11 advice of Counsel, at least today, I'm going to have to 11 lawsuit is something having to do with sending an
12 invoke my Fifth, Sixth and 14th Amendment Rights. 12 investigator to California.
13 Though I'd prefer to answer the question, I've been told 13 Would you tell me, please, more specifically
14 that if I choose to do so, I risk losing their 14 what it is that Mr. Edwards did with regard to sending
15 representation. 15 an investigator to California which you contend
16 Q. Among those items listed by you as wrongdoing 16 justifies a legal claim against Mr. Edwards.
17 on the part of Mr. Edwards forming the basis for this 17 MR. PIKE: Form. And also mischaracterizes
18 lawsuit is that he, quote, counseled his clients to make 18 the witness' testimony.
19 multi-million dollar claims against you; is that 19 THE WITNESS: Reported widely in the
20 correct? 20 newspapers is the use of illegal activities, wire
21 MR. PIKE: Form. Document speaks for itself. 21 taps, and methods by the Rothstein firm while
22 THE WITNESS: Doctnnent speaks for itself. 22 Mr. Edwards had basically been bringing these
23 BY MR. SCAROLA: 23
24 Q. I'm not asking about a document. I'm asking 24 The investigator, Mr. Fisten, who's mentioned
25 you about the list of wrongdoing that you gave us during 25 in the Complaint, represented himself as an FBI
Page 47 Page 49
1 the course of this deposition, which you allege form the 1 agent, falsely represented himself as an FBI agent.
2 basis for your claim against Mr. Edwards. 2 BY MR. SCAROLA:
3 is it your contention that among those things 3 Q. Do you have any personal knowledge of anything
4 Mr. Edwards did that form the basis for your lawsuit is 4 that Mr. Fisten did while Mr. Fisten was in California?
5 to have counseled his clients to make multi-million 5 MR. PIKE: To the extent that you can answer
6 dollar claims against you? 6 that question without disclosing my conversation or
7 MR. PIKE: Form. 7 my firm's conversation or any of your attorneys'
8 THE WITNESS: What the newspapers have said is 8 conversations with you, you can answer the
9 that the claims purported to have been made by the 9 question.
10 Rothstein firm and its partners allege 10 THE WITNESS: Pm sorry. Based on
11 multi-million dollar claims where no claims exist. 11 attorney/client privilege, I can't answer.
12 However, respect specifically to my claim 12 BY MR. SCAROLA:
13 today, I'm going to have assert my Fifth, Sixth and 13 Q. is it your contention that Mr. Edwards was
14 14th Amendment Right. 14 involved in an illegal wire tap?
15 MR. PIKE: Also, the question mischaracterizes 15 A. It was widely reported in the newspaper
16 the witness' testimony. 16 Q. I'm not asking it was reported —
17 BY MR. SCAROLA: 17 A. Excuse me.
18 Q. By whom was Bradley Edwards employed when he 18 Q. — in the newspaper.
19 initiated litigation against you? 19 A. Excuse me.
20 A. I would like to bow the answer to that 20 Q. I want to know whether your contention is that
21 question. 21 Mr. Edwards was involved in an illegal wire tap.
22 Q. So the answer to that question is, i don't 22 MR. PIKE: Try once again to answer that
23 ►snow? 23 question.
24 A. I would like -- 24 THE WITNESS: It's been widely reported in the
25 Q. Correct? 25 newspaper that his firm and his partners were
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1 involved in illegal wire taps, eavesdropping, hired 1 Jeffrey Epstein, separate and apart from the
2 former FBI and law enforcement officials in order 2 allegations of fraud by his partners, I cannot
3 to fabricate cases ofa sexually charged nature 3 answer that question because of attorney/client
4 against me and other& 4 privilege.
5 BY MR. SCAROLA: 5 BY MR. SCAROLA:
6 Q. Do you have any personal knowledge of 6 Q. Do you have any personal knowledge that
7 Mr. Edwards ever having engaged in any illegal wire tap? 7 Bradley Edwards was involved in any egregious civil
A. I have no personal knowledge; however, what I 8 litigation abuses?
9 read in the newspapers and is widely reported is that 9 M:R. PUCE: Form. Confining.
10 his firm, and I believe Mr. Sakowitz went to the FBI 10 THE WITNESS: It's widely reported in the
11 after he was told that the firm was engaged in illegal 11 newspaper that Mr. Edwards' firm engaged in wild
12 wire taps and his partners were engaged in illegal wire 12 discovery processes, illegal activities, illegal
13 taps. 13 eavesdropping in order to fleece unsuspecting
14 The FBI, the U.S. Attorney has accused his 14 investors in South Florida out of millions in
15 firm of RICO, being the largest criminal fraud 15 dollars by crafting, fabricating malicious cases of
16 enterprise in South Florida's history and engaged in 16 a sexually charged nature in order to perpetrate a
17 illegal wire taps. But the answer specifically to your 17 fraud.
18 question about personal knowledge, sir, no. 18 BY MR. SCAROLA:
19 Q. Do you have any personal knowledge of 19 Q. Do you have any personal knowledge that
20 Mr. Edwards ever having been involved in any illegal or 20 Bradley Edwards ever forged Federal Court Orders and/or
21 improper eavesdropping? 21 Opinions?
22 A. Ifs been widely reported in the newspapers in 22 A. It's attomey/client privilege.
23 South Florida that Mr. Edwards' firm, his partners were 23 Q. Do you have any personal knowledge that
24 involved in illegal wire taps, illegal fact gathering, 24 Bradley Edwards was over involved in the marketing of
25 using what the newspapers quoted as sophisticated 25 non-existing Epstein settlements?
Page 51 Page 53
1 methods. Mr. Sakowitz, who was approached as an MR. PIKE: Same instruction.
2 investor, and Mr. Scherer, who's filed a Complaint, 2 THE WITNESS: I'm sorry. I would like to
3 alleges similar activities. But personal knowledge 3 answer that question, but on attorney/client
4 myself, sir, no. 4 privilege I cannot today.
Q. Do you have any personal knowledge that 5 BY MR. SCAROLA:
6 Bradley Edwards was ever involved in obstructions of 6 Q. It is alleged in your Complaint that you were
7 justice? 7 subject to, quote, abusive investigatory tactics.
8 MR. PIKE: To the extent that you can answer 8 Other than those matters previously referred
9 that question without disclosing any 9 to in earlier questions, is it your contention that
10 attorney/client communications with any of your 10 Bradley Edwards had any personal involvement in any
11 attorneys, you can answer that question. 11 other, quote, abusive investigatory tactics?
12 THE WITNESS: It's attorney/client privilege, 12 MR. PIKE: Form
13 I'm afraid. 13 THE WITNESS: It's been widely reported in the
14 BY MR. SCAROLA: 14 newspapers that Mr. Edwards' firm was engaged in
15 Q. Do you have any personal knowledge that 15 widely — wildly abusive practices throughout the
16 Bradley Edwards was ever involved in any actionable 1e' State of Florida in order to fleece unsuspecting
17 frauds? 17 investors out ofmillions of dollars.
18 MR. PIKE: Same — same instruction, with any 18 The U.S. Attorneys Complaint alleges his firm
19 of your lawyers. 19 engaged in a corrupt criminal enterprise.
20 THE WITNESS: Yes. Outside of the newspapers, 20 Mr. Scherefs Complaint alleges monstrous
21 which have accused his firm of a monstrous fraud, 21 amounts of fraud and discovery abuse.
22 purported to be the largest fraud in South 22 I have no personal knowledge, separate from
23 Florida's history, accused by the U.S. Attorney 23 the attorney/client privileged information,
24 where his partner sits in jail -- excuse me -- 24 regarding Mr. Edwards.
25 reported in the newspapers of boxes ofmaterial on 25 BY MR. SCAROLA:
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1 Q. Do you have any personal knowledge that 1 were adversely affected by the misconduct that is the
2 Bradley Edwards ever filed legal papers that were 2 subject of this Complaint," unquote.
3 unsupportable? 3 Who are those hardworking and honest lawyers
4 MR. PIKE: I'm going to object to form. 4 that you are seeking to vindicate?
And to the extent you can answer that question 5 MR. PIKE: Form.
6 without disclosing any attorney/client 6 Give me a minute. What page of the Complaint
communications with any of your attorneys, I'm 7 are you referring to?
going to allow you to answer that question. 8 MR. SCAROLA: Page 2.
9 THE WITNESS: I'm afraid it's attorney/client 9 MR. PIKE: Give me one second.
10 privilege. 10 THE WITNESS: Can we go off the record just
11 BY MR. SCAROLA: 11 for a second?
12 Q. Do you have any personal knowledge that 12 MR. PIKE: If it's okay with Mr. —
13 Mr. Edwards was ever involved in any conduct that 13 THE WITNESS: It's a bathroom break.
14 quote, compromised the core values of both State and 14 MR. PIKE: There's a question pending and
15 Federal justice systems in South Florida? 15 usually —
16 MR. PIKE: Form. 16 THE WITNESS: Sony.
17 THE WITNESS: Can you just ask can you 17 MR. PIKE: lust give me a second.
18 define for me what you mean by "personal 18 Okay.
19 knowledge," sir? 19 THE WITNESS: Where is it?
20 BY MR. SCAROLA: 20 MR. PIKE: It's page 2 of the Complaint, which
21 Q. Yes. Did you over see, hear, smell, taste, or 21 has my notes on it down here, the last sentence.
22 touch anything that communicated to you directly and not 22 And to the extent that you have knowledge and
23 through the report of some third person or newspaper 23 can answer that question, you can do so.
24 that Bradley Edwards was personally involved in 24 THE WITNESS: Could you repeat the question
25 cot monHising the core values of both State and Federal 25 for me, sir?
Page 55 Page 57
1 justice systems in South Florida? 1 BY MR. SCAROLA:
2 MR. PIKE: Form. 2 Q. Yes, sir. Your Complaint makes reference to a
3 Same instruction with regard to 3 purpose in filing this lawsuit —
4 attorney/client. 4 A. Yes.
5 THE WITNESS: Yes. Are you suggesting that 5 Q. -- to vindicate the hardworking and honest
6 anyone who told me specifically or things that I 6 lawyers and their clients who were adversely affected by
7 might have read that specifically relate to him, is 7 the misconduct that is the subject of this Complaint
8 not what you've been asking me for? 8 A. Yes, sir.
9 BY MR. SCAROLA: 9 Q. Who are those hardworking and honest lawyers
10 Q. Yes, sir, that's exactly right. 10 on whose behalf you are bringing this Complaint?
11 A. You told me if I hear something, that's not 11 MR. PIKE: Okay. Form. Mischaracterizes the
12 personal knowledge. 12 Complaint itself.
13 Q. Not if you hear it from somebody else. 13 To the extent you understand that question,
14 A. Who else would I hear it from, besides 14 you can attempt to answer, if you recall.
15 somebody else, sir? 15 THE WITNESS: Yes.
16 Q. Well, if you heard it directly yourself. 16 The U.S. Attorney, sir, has accused the
17 A. From who? 17 Rothstein firm of misusing the entire legal system,
18 , Q. Maybe Mr. Edwards. 18 a level of abuse never seen before in the United
19 A. Uh-huh. Is that the only person, sir? 19 States history, of forging documents, an affront to
20 Q. That's the only person, that's correct 20 any decent lawyer, signing Judge's Orders, sending
21 A. Well, if it's the only person, separate from 21 false statements to other lawyers. The people who
22 attorney/client privilege, I cannot answer that. 22 have been — excuse me — the Complaint by the U.S.
23 Q. Your Complaint makes reference to a purpose in 23 Attorney, in fact, describes the behavior of the
24 filing this lawsuit to, quote, "vindicate the 24 law firm, as well as Mr. — my Complaint says,
25 hardworking and honest lawyers and their clients who 25 Mr. Edwards being a part of that.
15 (Pages 54 to 57)
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1 BY MR. SCAROLA: 1 We have asked for Scott Rothstein's
2 Q. Now, before you answered that question, you 2 deposition. We hopefully will get it. Maybe he will
. 3 reviewed a document, right? 3 give us some insight on how other lawyers have, in fact,
4 A. The Complaint sir. 4 been handled and the abuses they've undergone, including
S Q. I'd like to see it, please. 5 forging a Federal Judge's signature, sir.
6 MR. PIKE: Definitely not, Mr. Scarola. 6 Q. Now, was it your intention in this sentence to
7 My notes are on that and that's T say that you were trying to vindicate the hardworking
8 attorney/client. I allowed the witness to take a 8 and honest lawyers and their clients?
9 look at the document and he did not write anything 9 A. It's attorney/client. I'm sorry.
10 on the document He looked at the document 10 Q. Your intention is attorney/client privileged?
11 That's my client. And you will certainly not be 11 MR. PIKE: Form. I'm not quite -
12 looking at my notes, which are all over this 12 BY MR. SCAROLA:
13 document. 13 Q. Is that what you're telling us?
14 MR. SCAROLA: He didn't look at everything. 14 MR. PIKE: Wait a second. I'm not quite sure
15 He looked at one page. I would like that one page, 15 I understand the question.
16 please. 16 THE WITNESS: What's the question?
17 MR. PIKE: Absolutely not, Mr. Scarola. 17 BY MR. SCAROLA:
18 MR. SCAROLA: I would like that page marked as 18 Q. Were you attempting to communicate in this
19 an Exhibit to this deposition. 19 Complaint a desire on your part to vindicate hardworking
20 MR. PIKE: Absolutely not, Mr. Scarola. 20 and honest lawyers and their clients?
21 MR. SCAROLA: I would state for the record 21 MR. PIKE: Form.
22 that it is my intention, since that page with 22 THE WITNESS: In this Complaint, I intend to
23 handwritten notations on it was reviewed by the 23 get to the truth of Mr. Edwards' behavior and the
24 witness during the course of this deposition while 24 Rothstein firm, sir.
25 a question was pending, Iwant that page preserved 25 BY MR. SCAROLA:
Page 59 Page 61
1 so that the Court can make a determination as to 1 Q. Well, what this sentence says is, quote, —
2 whether I am entitled to see it 2 A. Yes.
3 MR. PIKE: I would object based upon 3 Q. — "the Rothstein racketeering enterprise
4 attorney/client and work product in that regard. 4 endeavored to compromise the core values of both State
5 THE WITNESS: Now can we take a bathroom 5 and Federal systems in South Florida and to vindicate
6 break? 6 the hardworking and honest lawyers and their clients who
7 MR. SCAROLA: No, sir, because you still 7 were adversely affected by the misconduct that is the
8 haven't answered my question. 8 subject of this Complaint."
9 THE WITNESS: Okay. 9 Is that what you meant to communicate?
10 BY MR. SCAROLA: 10 A. It says what it says, sir.
11 Q. I want to know who the, quote, "hardworking 11 Q. Well, I know it says what it says. I'm trying
12 and honest lawyers" are that are referred to in that 12 to find out if that's what you meant to say; that is,
13 section of your Complaint. 13 that the Rothstein racketeering enterprise endeavored to
14 A. My attorneys, at least, are honest 14 vindicate the hardworking and honest lawyers and their
15 Q. Which ones? 15 clients who were adversely affected by the misconduct
16 A. All of them. 16 that is the subject of this Complaint.
17 Q. And you say that you want to vindicate the 17 MR. PIKE: Form. Mischaraeterizes the
18 hardworking and honest lawyers and their clients? 18 language of the document
19 A. That's correct. 19 THE WITNESS: Yeah, I think you've misread
20 Q. Which clients? 20 that again. You want to — I certainly didn't ask
21 A. Me, some of the other clients, in fact, abused 21 for the Rothstein firm to vindicate the lawyers, is
22 by the Rothstein firm. I don't know the full extent. 22 what you've just —
23 Hopefully when we get to trial, we're going to find out 23 BY MR. SCAROLA:
24 the extent of the people, the lawyers, the clients that 24 Q. Well, that's what I'm trying to find out,
25 were abused by Mr. Edwards and the Rothstein finn. 25 whether you meant to say what you said in this
1101•••••••••10081...1 ,••••••Vshamil
16 (Pages 58 to 61)
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1 Complaint. 1 Q. Knowingly part ofa criminal enterprise?
2 Did you read the Complaint before it was 2 MR. PIKE: Form.
3 filed? 3 THE WITNESS: Attorney/client privilege.
4 MR. PIKE: Form. Move to strike. 4 MR. SCAROLA: You wanted to take a break and
5 THE WITNESS: Thank you, sir. 5 before I move on to another subject, we'll do that.
6 BY MR. SCAROLA: 6 But 1mint — I want to observe for the record that
7 Q. Did you read the Complaint before it was 7 the last break was less than an hour ago. While I
8 filed? 8 want to try to make reasonable accommodations to
9 A. It was a while ago, yes, sir. 9 witnesses so as not to impose unnecessarily upon
10 Q. And did you approve the Complaint prior to its 10 their physical comfort, I will object to breaks
11 filing? 11 occurring at less than one-hour intervals during
12 A. Yes, sir. 12 the course of this deposition.
13 Q. And did you mean to say what this sentence 13 VIDEOGRAPHER: We're now off video record. It
14 says, "die Rothstein racketeering enterprise endeavored 14 is 11:34 am.
15 to vindicate the hardworking and honest lawyers and 15 (Brief recess.)
16 their clients, who were adversely affected by the 16 VIDEOGRAPHER: We are now back on video
17 misconduct that is the subject of this Complaint? 17 record. It Is 11:45 sm. and we are on media
18 MIL PIECE: Okay. I'm going to move to strike. 18 number two.
19 hfischaracterizes the language of the document. 19 BY MR. SCAROLA:
20 The document reads as follows, for purposes of 20 Q. What knowledge do you have of Brad Edwards
21 the record: "The Rothstein racketeering enterprise 21 ever having personally engaged in mail fraud?
22 endeavored to compromise the core values of both 22 A. Ifs been widely reported in the press —
23 State and Federal justice systems in South Honda 23 Q. I'm going to withdraw my question.
24 and to vindicate the hardworking and honest lawyers 24 What personal knowledge do you have ofBradley
25 and their clients who were adversely affected by 25 Edwards ever having been engaged in any mail fraud?
Page 63 Page 65
1 the misconduct that is the subject of this 1 A. Will you describe what you mean by "personal
2 Complaint." 2 larowtedge," sir?
3 BY MR. SCAROLA: 3 Q. I mean direct observation through your senses
4 Q. Is that what you meant to say? 4 on your part.
5 A. What I meant to say, it is — seems to me 5 A. So are you asking me whether or not I've
6 somewhat unclear — is that the Rothstein firm, along 6 witnessed him sending something directly, putting
7 with Mr. Edwards, is part ofa criminal enterprise, the 7 physically in the mail, sir?
8 largest — excuse me — the largest criminal enterprise 8 Q. I'm asking whether you have ever personally
9 in South Florida's history, forging Judges' signatures, 9 witnessed Bradley Edwards ever having engaged in mail
10 engaging in illegal wire taps, illegal behaviors. And 10 fraud.
11 part of this lawsuit should vindicate, which means, I 11 A. I'm not sure how that's possible for anybody
12 believe should set right. 12 to witness a mail fraud, so would you inform me how it's
13 And if it's not clear, the Rothstein firm 13 done?
14 compromised the core values of our legal justice system. 14 Q. So the answer to my question is, you don't
15 It abused every — many of the precepts, the most basic 15 know; is that correct?
16 values of the American justice system. 16 A. My answer to your question is —
17 And, in fact, I believe this lawsuit, part of 17 MR. PIKE: Form. Mischaracterizes the
18 the reason for filing this lawsuit, it will disclose the 18 witness' testimony.
19 various techniques of attorney/client privilege, abuse 19 THE WITNESS: I've asked for a clarification.
20 of technique, abuse of discovery, illegal wire taps, 20 BY MIL SCAROLA:
21 forging signatures engaged in by both Mr. Edwards and 21 Q. Have you ever personally witnessed Bradley
22 his firm. 22 Edwards engaging in mail fraud?
23 Q. So it is your contention that Ms. Edwards was 23 MR. PIKE: Form.
24 part of a criminal enterprise? 24 THE WITNESS: No, sir.
25 A. Yes, it is. 25 BY Wt. SCAROLA:
17 (Pages 62 to 65
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1 Q. Have you ever personally witnessed Bradley 1 payout settlement?
2 Edward — Edwards engaged in wire fraud? 2 MR. PIKE: Form.
3 A. How would one — I'm not sure how anyone would 3 THE WITNESS: I'd like to answer that question
4 personal — have personal knowledge, witness someone 4 by saying that the newspapers have Nina icd that
5 engaging in wire ftaud, unless they were simply sitting 5 his fiim was engaged in fraudulent structured
6 over their computer looking at their bank accounts. So, 6 settlements in order to fleece unsuspecting Florida
7 unfortunately, I would have to say, no, sir. 7 investors.
8 Q. Have you ever personally witnessed Bradley 8 With respect to my personal knowledge, I'm
9 Edwards engaged in money laundering? 9 unfortunately going to, today, but I forward
10 MR. PIKE: Form. 10 to at some point being able to disclose it, today
11 THE WITNESS: Again, sir, the U.S. Attorney's 11 I'm going to have to assert the attorney/client
12 Complaint of the Rothstein firm alleges money 12 privilege.
13 laundering, wire fraud, mail fraud, RICO claims of 13 BY MR. SCAROLA:
14 Mr. Edwards' partners and his firm, calling the 14 Q. Your Complaint alleges that Rothstein and
15 film the largest criminal enterprise in South 15 others in RRA were using RRA to market investments.
16 Florida's history, accused of fabricating malicious 16 Who are the others referred to in the
17 cases, sir, of a sexually charged nature in order 17 Complaint?
18 to fleece unsuspecting South Floridians out of 18 A. From my understanding of the U.S. Attorney's
19 millions of dollars. 19 Complaint, from Mr. Scherefs Complaint, it is the
20 BY MR. SCAROLA: 20 partners and people who held themselves out to be
21 Q. And I'm trying to find out, Mr. Epstein, 21 partners of the Roth -- Scott Rothstein, including
22 whether you have any evidence whatsoever that 22 Mr. Berger, Mr. Adler, Mr. Edwards and other people
23 Mr. Edwards ever personally participated in any of that 23 associated with the fine like Mr. Fisten, Diane
24 wrongdoing? 24 Villegas, if that's how you pronounce her name, Russell
25 MR. PIKE: To that question, to the extent you 25 Adler, and many of the other partners ofhis firm
Page 67 Page 69
can answer it without violating attorney/client and 1 currently wider investigation by either the Florida Bar
2 work product, you can answer the question. 2 or the U.S. Attorney or FBI or all of the above, sir.
3 THE WITNESS: I'm afraid it will be 3 Q. Which — which source of information
4 attorney/client privilege, sir. 4 referenced in that answer specifically made reference to
BY MR. SCAROLA: 5 Mr. Edwards?
o Q. Do you have any evidence knowledge ofany 6 A. !don't recall, sir.
7 evidence whatsoever that Mr. Edwards ever participated 7 Q. But you do have a recollection that one or
8 in any effort to market any kind ofinvestment in 8 more of them did; is that correct?
9 anything? 9 A. I don't recall, sir.
10 A. I would have to claim attorney/client 10 Q. So you want to withdraw the earlier response
11 privilege on that, sir. 11 that you made and your real answer is, I don't know; is
12 MR. PIKE: Font 12 that correct?
13 BY MR. SCAROLA: 13 MR. PIKE: kfischaracterizes the witness'
14 Q. Do you have knowledge of any evidence 14 testimony. Move to strike.
15 whatsoever that Mr. Edwards was ever a participant in 15 BY MR. SCAROLA:
16 devising a plan through which were sold purported 16 Q. Your response, sir?
17 confidential assignments of a structured payout 17 A. My answer stays the same, sir.
18 settlement? 18 Q. Is it your contention that one or more
19 A. The newspapers and blogs have widely reported 19 lawsuits was fabricated against you?
20 that Mr. Edwards' firm crafted — would you repeat the 20 A. It's been widely reported in the newspapers —
21 question for me, again, sir? I'm sorry. 21 Q. That% not my question.
22 Q. Yes, sir. I want to know whether you have any 22 A. Excuse me. I was answering.
23 knowledge ofevidence that Bradley Edwards personalI> 23 MR. PIKE: Please let the witness answer the
24 ever participated in devising a plan through which were 24 question, Mr. Scarola.
25 sold imported confidential assignments of a structured 25 BY MR. SCAROLA:
•1 , I El
18 (Pages 66 to 69)
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1 Q. No, you're not answering my question. 1 potential defendants could be, in essence, blackmailed.
2 MR. PIKE: lie's only said three words, so you 2 MR. PIKE: Would you identify for me,
3 don't know whether he's answering your question or 3 Mr. Scarola, what page?
4 not. 4 MR. SCAROLA: Page 8, paragraph 19.
5 MR. SCAROLA: I didn't ask him anything about 5 BY MR. SCAROLA:
6 newspapers. I asked him about his contention. I 6 Q. Did anyone ever sift through your garbage
7 don't know he's not answering my question. 7 looking for damaging evidence?
8 BY MR. SCAROLA: 8 MR. PIKE: One second.
9 Q. But you can go ahead, Mr. Epstein, and you can In light of clarity, Mr. Scarola, would you
10 make your silly speech one more time. 10 please read the entire paragraph so Mr. Epstein
11 MR. PIKE: Pm going to move to strike. 11 understands the tenor of the paragraph?
12 THE WITNESS: You wan to repeat the question? 12 MR. SCAROLA: No. I want to know whether
13 BY MR. SCAROLA: 13 anyone ever sifted through Mr. Edwards' garbage --
14 Q. Yes, sir. I would like to know whether it is 14 through Mr. Epstein's garbage. That's the pending
15 your contention that one or more lawsuits have been 15 question.
16 fabricated against you. 16 MR. PIKE: To the extent you understand the
17 A. My contention, sir, is that the firm of 17 question, you can answer.
18 Edwards' partners, Scott Rothstein, fabricated many 18 THE WITNESS: I think the question is poorly
19 cases, reported by the press and the U.S. Attorney, 19 phrased. Did anyone ever sift through my garbage?
20 amongst people like me and others of a sexually charged 20 What does that mean?
21 nature in order to fleece investors of South Florida out 21 BY MR. SCAROLA:
22 of millions of dollars. 22 Q. You don't know what sifting through garbage
23 Do I have a — with respect to my individual 23 means?
24 cases that Mr. Edwards has filed in these three cases, 24 A. Does that mean the garbage man? Does that
25 rm unfortunately today, and only today at least, on 25 include the garbage man? I'm sure he sifted through my
Page 71 Page 73
1 advice of Counsel Fm going to have to assert my Fifth, 1 garbage.
2 Sixth and 14th Amendment, sir. 2 Q. Which garbage man sifted through your garbage?
3 Q. Okay. Well, I'm not limiting my question to 3 A. Pm sure people who go through garbage sift
4 the three cases referenced in your Complaint. I want to 4 through the garbage. I have no idea.
S know whether you contend that any claim against you has 5 Q. Did anyone ever sift through your garbage
6 been fabricated? 6 looking for damaging evidence?
7 MR. PIKE: Form. Overbroad and confusing and 7 A. It's been widely reported in the newspapers,
8 its compound. 8 sir, that the Rothstein firm engaged in sifting through
9 THE WITNESS: The question makes no sense to 9 many people's garbage in order -- in an attempt to
10 me. Fm sure you could do better. 10 blackmail them.
11 BY MR. SCAROLA: 11 Q. Yes. But I didn't ask you what some newspaper
12 Q. Is there any pending claim against you which 12 is alleged to have reported.
13 you contend is fabricated? 13 What I did ask you is whether anyone ever
14 A. At least today, sir, I'm going to have to 14 sifted through your garbage looking fa damaging
15 respond by asserting my Fifth, Sixth and 14th Amendment 15 evidence.
16 Right. 16 And the answer to that question, I think, can
17 MR. PIKE: Form, also. 17 be either yes, no, or l don't !mow.
18 BY MR. SCAROLA: 18 MR. PIKE: Move to strike.
19 Q. Is it your contention that Bradley Edwards was 19 BY MR. SCAROLA:
20 ever personally involved in manufacturing false and/or 20 Q. Or you could refuse to answer it on the
21 fraudulent Court Opinions or Orders? 21 grounds that it may tend to incriminate you.
22 A. Attorney/client privilege. 22 A. I think you might —
23 Q. Your Complaint makes reference to someone 23 MR. PIKE: Move to strike.
24 sifting through a potential defendant's garbage looking 24 THE WITNESS: I would like to answer my own
25 for damaging evidence to use with investors to show how 25 questions. If you'd like to answer all my
19 (Pages 70 to 73)
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Page 74 Page 76
1 questions, Mr. Scamla, I'm more than happy to sit 1 You've been interchanging knowledge with personal
2 hem end answer them. Would you like to continue? 2 knowledge. And many of the objections to which i
3 BY MR. SCAROLA: 3 am asserting an attorney/client and work product
4 Q. Yes. N like to know what the answer to that 4 privilege are based upon your malphrased question
5 question is. Did anyone ever sift through your garbage 5 and use ofpersonal knowledge and knowledge
6 looking for damaging evidence? 6 interchangeably with those questions.
7 MR. PIKE: Form. 7 So if you want to rephrase your question to
8 THE WITNESS: I don't know. 8 attempt to elicit a response -- let me finish -
9 BY MR. SCAROLA: 9 then I have no objection to that. However, rim not
10 Q. Did you ever have damaging evidence in your 10 going to sit here and allow my client to waive
11 garbage? 11 attorney/client and work product.
12 A. What's damaging evidence, sir? 12 Now, to the extent you're saying Fm coaching
13 Q. Evidence tending to implicate you in criminal 13 the witness, I object to that because I am
14 conduct. 14 certainly not. The witness is here to answer your
15 MR. PiKE: Form. 15 questions and i believe has been answering your
16 THE WITNESS: At least today, Mr. Scuola, 16 questions today to the best ofhis ability.
17 with these — with your questions and your claims 17 MR. SCAROLA: i am saying you're coaching the
18 and your defeats* ofMr. Edwards and his firm, the 18 witless.
19 Rothstein film, while his partner sits in jail, 19 BY MR. SCAROLA:
20 today I'm going to have to assert my Fifth, Sixth 20 Q. Could you answer the question?
21 and 14th Aowanent Right, sir. 21 MR.. PIKE: Same objection.
22 BY MR SCAROLA: 22 THE WITNESS: You'll have to repeat it.
23 Q. Did you ever have any evidence in your garbage 23 BY MR. SCAROLA:
24 that would subject you to blackmail? 24 Q. Do you have any information indicating that
25 MR. PIKE: Form. Same — same objection. 25 Bradley Edwards ever had any knowledge of anyone
Page 75 Page 77
1 THE WITNESS: Again,I'll respectfully answer 1 associated with the Rothstein firm holding meetings
2 the question by asserting my Fifth, Sixth and 14th 2 during which, quote, "false statements were made about
3 Amendment Right. 3 the number of cases/clients that existed or RRA had
4 BY MR. SCAROLA: 4 against Epstein and the value thereof," unquote?
5 Q. Your Complaint in paragraph 21, page 9, says 5 MR. PIKE: Form. Same objection.
6 that: "Upon information and belief, Rothstein, David 6 THE WITNESS: My best recollection is the U.S.
7 Roden, Debbie Villegas, Andrew Barnett, Michael Fistert 7 Attorney has accused the Rothstein firm ofjust
8 and Kenneth Jenne, all employees ofRRA, through brokers 8 those types of meetings where the partners got
9 or middle men would stage regular meetings during which 9 together, schemed to defraud local investors of
10 false statements were made about the number of 10 millions of dollars by fabricating cases of a
11 cases/clients that existed or RRA had against Epstein 11 sexually charged nature. And whether Mr. Edwards
12 and the value thereof." 12 personally participated, fm going to at least
13 Do you have any knowledge that Mr. Edwards 13 today, sir, have to assert the attorney/client
14 ever knew about such meetings being conducted? 14 privilege, but look forward to one day disclosing
15 MR. PiKE: Form. 15 It
16 To the extent you understand the question and 16 MR. SCAROLA: Move to strike all unresponsive
17 it will not violate any attorney/client or work 17 portions of the answer.
18 product privilege information, you can answer that 18 BY MR. SCAROLA:
19 question. 19 Q. Paragraph 23 of your Complaint says that:
20 MR. SCAROLA: Mr. Pike, it has become evident 20 "RRA, Rothstein and Edwards, claiming the need for
21 that that speaking instruction to your witness is 21 anonymity with regard to existing or fabricated clients,
22 an instruction for him to assert an attorney/client 22 they were able to effectively use initials," et cetera.
23 privilege, regardless of whether it is or is not 23 Do you have any knowledge that Bradley Edwards
24 valid and I object to it. 24 fabricated a client to bring a claim against you?
25 MR. PIKE: Let me make the record clear. 25 MR. PiKE: Form.
20 (Pages 74 to 77)
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1 THE WITNESS: I believe Mr. Scherer's 1 MR. PIKE: then, please, --
2 Complaint — 2 THE WITNESS: Yes.
1 BY MR. SCAROLA: 3 MR. PIKE: — answer Mr. Scarola's question.
4 Q. I'm not asking about Mr. Scherees Complaint 4 THE WITNESS: Separate from —
I'm asking about any evidence that you have. 5 MR. SCAROLA: Objection. Coaching the
MR. PIKE: The witness is basically been five 6 witness.
words into his sentence and you're not allowing him 7 THE WTINESS: Separate from the communication
to finish, once again. 8 I've had with my attorneys, I can't answer that
9 So if you recall the question, then please 9 question.
10 respond. 10 MR. PIKE: Mr. Scarola, I'm confused. I
11 THE WITNESS: Please repeat it back, please? 11 started objecting to form in the beginning of this
12 MR. PIKE: Madame Court Reporter, if you 12 deposition. You then instructed me, which is
13 would. 13 against the rules, Mr. Pike, I don't know what's
14 (Pending question was read.) 14 wrong with the form. I object to you objecting to
15 MR. PIKE: Form. 15 form.
16 THE WITNESS: The pleadings ofMr. Scherer and 16 Then I assert the attorney/client, work
17 his claim against the Rothstein finn for a massive 17 product, and now you're telling me I'm coaching the
18 fraud, as well as Mr. Sakowitz's claims to -- at 18 witness.
19 least in the — described in the public press, 19 So tell me, Mr. Scarola, what is the — what
20 because he went to the FBI, for fabricating cases 20 is the way that you would like me to object In this
21 that included initials. 21 deposition, and maybe I can conform that way for
22 With respect to anything specific with 22 you, which may or may not be consistent with the
23 Mr. Edwards, I'm going to have to claim the 23 Florida Rules of Civil Procedure.
24 attorney/client privilege today, sir. 24 MR. SCAROLA: Mr. Pike, —
25 BY MR. SCAROLA: 25 MR. PIKE: Yes, sir.
Page 79 Page cc
1 Q. Do you have any -- do you have knowledge of 1 MR. SCAROLA: — if you don't know the
2 the existence of any evidence that Bradley Edwards knew 2 difference between a form objection and a privilege
3 that Rothstein was utilizing RRA as a front for a Ponzi 3 objection —
4 scheme? 4 MR. PIKE: Right
5 MR. PIKE: Form. 5 MR. SCAROLA: — then this deposition is not
6 THE WITNESS: That's attorney/client 6 the proper context in which for you to learn the
7 Privilege. 7 difference between a form objection and a privilege
8 BY MR. SCAROLA: 8 action.
9 Q. Do you have knowledge of any evidence that 9 MR. PIKE: Tm pretty clear on what a form
10 would indicate Bradley Edwards should have known that 10 objection is and what a privilege objection is and
11 Rothstein was utilizingRRA as a front for a Ponzi 11 I'm pretty knowledgeable on that. The problem —
12 scheme? 12 MR. SCAROLA: Then we don't need to engage in
13 MR. PIKE: Fount. 13 any further discussion.
14 THE WITNESS: At least today — 14 MR. PIKE: — I want to try to make the record
15 MR. PIKE: Wait 15 clear, because initially you didn't want me to
16 THE WITNESS: Sorry. 16 object to /ann. You wanted me to speak So I'm
17 MB. PIKE: Form. Same objections. Same 17 thinking you're conceding to that point
18 attorney/client, work product as to the last 18 What my question is, is: What's wrong with my
19 question. Same objections here, attorney/client 19 objecting to attomey/client, work product? So
20 work product. 20 guess Tm asking you what you were asking me
21 THE WITNESS: And today I'm going to have to 21 earlier on. What's wrong with the form?
22 assert the attorney/client privilege. 22 We can just move forward.
23 MR. PIKE: To the extent you can answer that 23 BY MR. SCAROLA:
24 question — 24 Q. In your Complaint you identify the RRA law
25 THE WITNESS: I understand. 25 firm, Rothstein and Edwards, as the, quote, "litigation
•
21 (Pages 78 to 81)
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1 team," unquote. 1 Edwards, individually and personally, sold, allowed to
2 You then go on to say in paragraph 31 of your 2 be sold and/or assisted with the sale of an interest in
3 Complaint at page 12 that: "Rothstein and the 3 non-settled personal injury lawsuits?
4 litigation team" — 4 MR. PIKE: Before you answer that question,
5 MR. PIKE: Wait a minute. Put that down for a 5 Madame Court Reporter, will you please read that
6 second. Hold on. 6 question back tome?
7 THE WITNESS: You can read it. 7 (Pending question was read.)
8 BY MR. SCAROLA: 8 MR. PIKE: To the extent you can answer that
9 Q. "Individually and in a concerted effort may 9 question without divulging attorney/client or work
10 have unethically and illegally engaged in certain 10 product information, you may answer that question.
11 specified conduct." 11 MR. SCAROLA: Objection. Coaching.
12 May we correctly conclude from that statement 12 THE WITNESS: You said, allowed to be sold.
13 that you don't have any knowledge as to whether the, 13 I'm going to assert attorney/client privilege to
14 quote, "litigation team," including Mr. Edwards, engaged 14 the answer, I'm afraid, but I'd like to answer that
15 in any unethical and illegal conduct? 15 question.
16 MR PIKE: For now, while I'm reviewing the 16 BY MR. SCAROLA:
17 document itself, I'm just going to just tell you to 17 Q. Do you have knowledge of any evidence
18 hold off — 18 indicating that Bradley Edwards ever reached agreements
19 THE WITNESS: Sure. 19 to share attorney's fees with non-lawyers?
20 MR. PIKE: — on answering that question. 20 MR PUCE: I'm sorry. Mr. Scarola, can you
21 You may want to go off the record, so we don't 21 tell me what page of the Complaint you're referring
22 have a lag in -- 22 to, if you are?
23 MR. SCAROLA: No, I'd hie it on the record. 23 MR. SCAROLA: I'm not referring to any page of
24 Thank you. 24 the Complaint, although I will tell you that that
25 MR. PIKE: Mr. Scuola, did you bring an extra 25 precise allegation is made in the Complaint.
Page 83 Page 85
1 copy of the Complaint that you're questioning 1 THE WITNESS: In fact, Mr. Scarola, we have
2 Mr. Epstein on for Mr. Epstein to look at? 2 subpoenaed Mr. Edwards' documents and documents
3 MR. SCAROLA: No. 3 from his firm that I believe will, in fact, give me
4 MR. PIKE: Okay. I'm going to have to go get 4 more specificity with the answers to that question.
5 him a copy so he can — the paragaphs of this 5 I'm looking forward to getting the -- that
6 Complaint are very long and the Complaint itself is 6 specific evidence. With respect to what we
7 in excess of — It was approximately 35 pages, 7 currently know, sitting here today, I'm
8 8 unfortunately going to have to claim my
9 MR. SCAROLA: I'll withdraw the question. 9 attorney/client privilege.
10 BY MR. SCAROLA: 10 BY MR. SCAROLA:
11 Q. Do you have any evidence that Brad Edwards 11 Q. Do you today have any evidence to support an
12 sold, allowed to be sold and/or assisted with the sale 12 assertiraubatar t dley Edwards ever used investor money
13 of an Interest in non-settled personal injury lawsuits? 13 to pay , and/or Jane Doe up-front money, such
14 MR. PIKE: Form. 14 that they would refuse to settle civil actions?
15 THE WITNESS: The newspapers have widely 15 MR. PUCE: Same instruction.
16 reported that the Rothstein firm engaged in illegal 16 THE WITNESS: Youll have to get — I need to
17 sPectuted settlements of cases of a sexual nature, 17 hear the first part of the question. Do I have any
18 including specifically, me. We have subpoenaed the 18 evidence? Do I have knowledge of evidence? I'm
19 documents from Mr. Edwards and his firm and we have 19 sorry. What was the —
20 not been able to get them as of yet. 20 BY MR. SCAROLA:
21 I am confident that once we do, I will be able 21 Q. Do you have knowledge of any evidence to
22 to answer your questions with more specificity. 22 support that assertion?
23 BY MR. SCAROLA: 23 MR. PIKE: To the extent you can answer that
24 Q. As you sit here today, do you have any 24 question without violating attorney/client, work
25 evidence whatsoever to support an assertion that Bradley 25 product, please do so.
22 (Pages 82 to 85)
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1 MR. SCAROLA: Objection. Coaching, 1 To the extent ybu can answer the question
2 THE WITNESS: Fm going to have to assert the 2 without disclosing attorney/client or work product
3 attorney/client privilege, Tm afraid, though I'd 3 information, do so.
4 like to answer that question as well, sir. 4 THE WITNESS: The pleadings ofMr. Scherer
S BY MR. SCAROLA: 5 with respect to the largest Ponzi scheme in South
6 Q. Do you have arty evidence to support the 6 Florida's history engaged in by Mr. Edwards' firm
7 assertion that Bradley Edwards conducted searches, wire 7 and Scott Rothstein, who currently sits in jail,
8 taps or intercepted conversations in violation of State 8 probably for the rest of his life for engaging in,
9 or Federal laws and Bar rules? 9 not only illegal wire taps and eavesdropping, but
10 A. Your question, once again, asked did Mr. — 10 an abuse of the entire legal system, I believe
11 was Mr. Edwards personally involved in the 11 speaks for itself.
12 eavesdropping? Did he walk to someone's house and sort 12 Unfortunately, with respect to Mr. Edwards
13 ofput a bug in their house? Did he, personally, stand 13 today, I'm going to have to assert the
14 outside? 14 attorney/client, work privilege, sir.
15 The question is, did Mr. Edwards' firm engage 15 BY MR. SCAROLA:
16 in this behavior in an attempt to defraud local 16 Q. Is it your contention that Mr. Scherer's
17 investors out of millions of dollars? The U.S. attorney 17 Complaint even contains the name Bradley Edwards?
18 has filed a Complaint saying that they did. The 18 A. I don't recall, sir.
19 Complaints filed by Scherer saying that his firm did 19 Q. Did sexual assaults ever take place on a
20 The Scherer Complaint says my name and the 20 private airplane on which you were a passenger?
21 boxes of files that we've subpoenaed used my name, sir. 21 MR. PIKE: Form. Relevance.
22 We have requested information, but up until 22 THE WITNESS: At least — I would like to
23 today have not received any. 23 answer each and every, one of your questions here
24 To give you a more specific answer, Tm afraid 24 today, Mr. Scarola. But at least today, I'm going
25 I cannot. 25 do have to assert my Fifth, Sixth and 14th
Page 87 Page 89
1 Q. Do you have knowledge of any evidence that 1 Amendment Rights as provided by the U.S.
2 Bradley Edwards ever conducted searches, wire taps or 2 Constitution.
3 intercepted conversations in violation of State or 3 BY MR. SCAROLA:
4 Federal laws and Bar mks? 4 Q. Does a flight log kept for a private jet used
5 MR PIKE: Same instruction. 5 by you contain the names of celebrities, dignitaries or
6 THE WITNESS: The newspapers and the U.S. .6 International figures?
7 Attorney's Complaint widely reported that 7 A. At least today, sir, I'm going to have to
8 Mr. Edwards' firm and people hired by his firm, 8 respectfully decline to answer based on my Fifth, Sixth
9 investigators hired by his firm fraudulently 9 and 14th Amendment Right, though I'd like to answer that
10 representing themselves as FBI agents engaged in 10 question.
11 just those activities, sir. 11 Q. Have you ever had a personal relationship with
12 BY MR. SCAROLA: 12 Donald Trump?
13 Q. Do you have any knowledge of any evidence that 13 A. What do you mean by 'personal relationship,"
14 Bradley Edwards was ever aware of any such activities? 14 sir?
15 A. I'm going to have to — 15 Q. Have you socialized with him?
16 MR. PIKE: Same objection. 16 A. Yes, sir.
17 THE WITNESS: - assert the attorney/client 17 Q. Yes?
18 privilege to that, sir. 18 A. Yes, sir.
19 BY MR. SCAROLA: 19 Q. Have you ever socialized with Donald Trump in
20 Q Do you have any knowledge that Bradley Edwards 20 the presence of females under the age of 18?
2.1 ever participated in or was aware of actions that 21 A. Though I'd like to answer that question, at
22 utilized the judicial process, including, but not 22 least today I'm going to have to assert my Fifth, Sixth
23 limited to, unreasonable and unnecessary discovery for 23 and 14th Amendment Right, sir.
24 the sole purpose of furthering a Ponzi scheme? 24 Q. Have you socialized with Alan Dershowitz?
25 MR. PIKE: Same objection. 25 A. Yes, sir. He's my attorney, as well as a
23 (Pages 86 to 89)
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1 friend. 1 this — just this type of behavior, the answer is,
2 Q. Have you ever socialized with Alan Dershowitz 2 today, at least, I must assert my Fifth, Sixth and
• 3 in the presence of females tmder the age of 18? 3 14th Amendment Right, though I'd lie to answer
4 MR. PIKE: Form 4 each and every one ofyour questions, Mr. Scarola.
5 THE WITNESS: Sir, at least here today,I'm 5 BY MR. SCAROLA:
6 going to have to assert my Fifth Amendment, Sixth 6 Q. Have you had a social relationship with David
7 Amendment and 14th Amendment Rights. 7 Copperfield?
8 BY MR. SCAROLA: 8 A. Asa reaction to, once again, the abusive
9 Q. Have you ever socialized with Tommy Mottola? 9 discovery process ofbringing in names of people that
10 A. This is the type of questions where people who 10 have absolutely nothing to do with any ofMr. Edwards',
11 have nothing to do with this case whatsoever have been 11 Mr. Rothstein's or their clients' claims, by bringing in
12 brought into the case by Mr. Edwards in an attempt to 12 the names of friends ofmine strictly in an attempt to
13 simply imperil my relationships with social friends and 13 stress my relationships, imperil my business
14 serves as an example of why this case has been brought 14 relationships, I'm going to say, yes, I do know
15 against Mr. Edwards and his firm, sir. 15 Mr. Copperfield.
16 MR. PIKE: Form as well. 16 Q. Have you ever socialized with David
17 BY MR. SCAROLA: 17 Copperfield?
18 Q. Well, do you know who brought those persons' 18 A. Again, as —
19 names into this lawsuit? 19 MR. PIKE: Form.
20 MR. PIKE: Form. 20 THE WITNESS: Sony.
21 And just to be clear, what Mr. Scarola, I 21 It's a typical Edwards/Rothstein strategy of
22 believe, talking about this lawsuit, Epstein versus 22 trying to involve well-known people in maliciously
23 RRA? 23 fabricated cases in order to fleece investors out
24 BY MR. SCAROLA: 24 ofmillions of dollars. They brought up names in
25 Q. Yes, sir, that's the lawsuit I'm talking 25 attempts at abuse of discovery process to try and
Page 91 Page 93
about. The one in which your deposition is being taken 1 take discovery of people who have nothing to do
2 today. 2 with this case.
3 Do you know who brought those persons' names 3 Did I socialize with David Copperfield? The
4 into this lawsuit? 4 answer is, yes.
5 A. As a reaction, and only as a reaction to total 5 BY MR. SCAROLA:
6 misbehavior on Mr. Edwards' pan, and the Complaint was 6 Q. Did you ever socialize with David Copperfield
7 obviously written by my attorneys, sir. 7 in the presence of females under the age of 18?
8 Q. So you know that those names are in your 8 A. Pm sure, again, this question is a typical
9 Complaint, right? 9 question ofMr. Edwards/Rothstein scheme to defraud
10 A. Yes, sir. 10 investors, asking questions knowing it serves no purpose
11 Q. Okay. So because those names are in your 11 or relationship relevance to their case whatsoever.
12 Complaint, Pm asking you about the people you named. 12 At least today, though I'd like to answer that
13 Have you had a social relationship with Tommy 13 question, on advice of my Counsel, and only on advice of
14 Mottola? 14 my Counsel, Prn going to have to assert my Fifth. Sixth
15 A. The names in my Complaint are strictly as a 15 and 14th Amendment Right
16 reaction to the abusive discovery process by 16 MR. PUCE: Form as well.
17 Mr. Edwards, his partners, Scott Rothstein, who sits in 17 BY MR. SCAROLA:
18 jail, in an attempt to imperil my friendships. 18 Q. Have you ever had a social relationship with
19 But, yes, I have socialized with Mr. Mottola. 19 Bill Richardson, Governor ofNew Mexico and formerly
20 Q. Have you ever socialized with Mr. Mottola in 20 U.S. Representative and Ambassador to the United
21 the presence of females under the age of 18? 21 Nations?
22 MR. PIKE: Form. 22 MR. PIKE: Form.
23 THE WITNESS: At least today, the typical to 23 THE WITNESS: As is typical of the Edwards
24 the Edwards contention of bringing cases ofa 24 scheme, along with his partner, Scott Rothstein,
25 malicious nature where his partner sits in jail for 25 who sits in jail, what they attempted to do was
24 (Pages 90 to 93)
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1 bring in any celebrity I might have known, 1 question, I'm told by my Counsel that if I choose
2 well-known people, in an attempt to strictly 2 to do so, which is my preference, I risk losing
3 imperil my relationships with these people where 3 their representation.
4 these people have no bearing whatsoever on any of 4 BY MR. SCAROLA:
S their claims or cases. 5 Q How many children have you sexually abused?
6 Yes, I do have a social relationship. 6 MR. PIKE: FOnn.
7 BY MR. SCAROLA: 7 And I just want to be clear on the record.
8 Q. Have you ever socialized with Mr. Richardson 8 These types of questions are argumentative and
9 in the presence of females under the age of 18? harassing. And, moreover, it's my contention that
10 MR. PIKE: Font 10 these types of questions are not related to this
11 THE WITNESS: Again, typical of the 11 lawsuit by any stretch of the imagination. In this
12 Edwards/Rothstein scheme of bringing in well-known 12 deposition, while I've been liberal in allowing
13 people, asking them ridiculous questions, 13 these questions, are being utilized in an attempt
14 ridiculous questions in an attempt strictly to 14 to provoke a waiver of the Fifth Amendment Right.
15 imperil my relationships with these people where 15 There has been an Order entered by, I believe,
16 they have absolutely nothing to do with anything to 16 Judge Hafele regarding these types of questions.
17 do with Edwards, Rothstein or any of their alleged 17 So with that caution, Mr. Scarola, I would ask
18 victims, the answer to your question is, yes, I 18 you that you refrain from asking abusive and
19 have socialized. 19 harassing questions that are not relevant to this
20 BY MR. SCAROLA: 20 case.
21 Q. Yes, but that wasn't my question. 21 MR SCAROLA: Well, ifs very interesting that
22 My question was: Have you ever socialized 22 you claim they're not relevant when they are
23 with Mr. Richards in the presence of females under the 23 directly taken from the allegations in your
24 age of 18? 24 Complaint.
25 MR PIKE: Form. 25 And I agree with you that they are not
Page 95 Page 97
1 THE WITNESS: In response to your question, 1 relevant because there is no basis whatsoever for
2 again, my full answer was, typical of the 2 this claim against Mr. Edwards. But since you've
3 Edwards/Rothstein scheme to ask questions of a 3 made these baseless allegations, I am obliged to
4 sexual charged nature, crafted cases, the U.S. 4 pursue the allegations by asking these questions.
5 Attorney has called his firm the largest fraud in 5 So we'll move on from there. And whenever you
6 U.S. history, fleecing investors out of millions of 6 think it's appropriate to terminate this deposition
7 dollars by engaging in just these types of 7 because you believe that I've acted
8 questions. Though I would like to answer each and 8 inappropriately, be my guest.
9 every question about every one of these people, on 9 MR. PIKE: I appreciate your invitation,
10 advice ofmy Counsel today, I must take — assert 10 Mr. Scarola
11 my Fifth Amendment, Sixth Amendment and 14th 11 I'm going to move to strike.
12 Amendment Right. Though I'd prefer to anew the 12 The fact is, Mr. Scarola, is that, these types
13 question, I was told that if I choose to do so, I 13 of questions have already been ruled upon as being
14 risk losing their representation, sir. 14 argumentative and harassing.
15 BY MR. SCAROLA: 15 If you want to direct some questions relevant
16 Q. Have you ever sexually abused children? 6 to your lawsuit, I invite you to do so. But
17 MR. PIKE: Form. 17 attempting to use this deposition process as a
18 THE WITNESS: On advice of Counsel, and only 18 mechanism to provoke a waiver of the Fifth
19 upon advice of Counsel, though I'd like to answer 19 Amendment and to obtain information that is more or
20 that question, as well as every other one of your 20 potentially more relevant to Mr. Edwards' cases in
21 claims brought by Mr. Edwards and his partner, who 21 which he is lead Counsel on, I think is improper.
22 currently sits in jail, sir, I would like to answer 22. BY MR. SCAROLA:
23 those questions. But today at least, I have to 23 Q. Did you have staff members that assisted you
24 assert my Sixth Amendment, 14th Amendment and Fifth 24 in scheduling appointments with underage females; that
25 Amendment Right. Though I'd prefer to answer the 25 is, females under the age of 18?
25 (Pages 94 to 97)
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A. So along with many of the other claims that 1 reference in that response? You said, "me and others."
the Rothstein firm crafted with malicious claims against 2 Who are the others?
3 people like me and others ofa sexually charged nature 3 A. Can you repeat where it says me and others?
-1 in order to simply fleece investors out of millions of 4 Pm sony.
dollars in South Florida, those types ofquestions, 5 MR. SCAROLA: Read it back again, please,
though I'd like to answer today, at least this specific 6 Sandy.
7 question, Pm going to have to assert, unfortunately, my 7 (Answer was read.)
Fifth, Sixth and 14th Amendment Right, though I'd prefer 8 THE WITNESS: The others are people reported
9 to answer the question. 9 in the press to be many people in South Florida who
10 BY MR. SCAROLA: 10 were the victims of the Rothstein scam.
11. Q. Who are the others referred to in that 11 I'm glad — I'm happy to answer the others.
12 response? 12 Pd Wm to know the others. In fact, we've
13 A. Again, sir? 13 subpoenaed documents from the bankruptcy trustee of
14 Q. You said you and others. Who are the others 14 Brad Edwards' rum in an attempt to find out more
15 that you were referring to? 15 details of the others that you've just asked about.
16 A. You'll have to read my answer back. 16 People — I believe the Attorney Scherer has
17 MR. PIKE: I'm sorry. Madame Court Reporter, 17 filed a Complaint for some of the others who have
18 would you please read the witness' answer back? 18 been defrauded, as well as some of the investors
19 THE WITNESS: You'll have to I have to take 19 who were told about many others, sir.
20 a bathroom break 20 BY MR. SCAROLA:
2/ MR.. PIKE: Actually 1 don't ono second. 21 Q. So you don't know any names; is that comet?
22 For the record, we're going on 12:30 now. Is 22 MR. PIKE: Form. Move to strike.
23 there — do you have a time frame as to when you — 23 Mischaraoterizes the witness' testimony.
24 MR. SCAROLA: About a halfhour. 24 THE WITNESS: Fm sure that's an — it's an
25 MR. PIKE: You have a halfhour left? 25 easy way of saying that as a response to the
Page 99 Page 101
1 MR. SCAROLA: Uh-buh. 1 questions and subpoenas we've asked Mr. Edwards to
2 MR. PIKE: Okay. Do you have an objection to 2 produce so we can find out the specific names of
3 us taking a quick bathroom break and -- 3 the others who have been — the U.S. Attorney has
4 THE WITNESS: just walk out and back in. 4 claimed have been blackmailed and victims of the
5 MR. SCAROLA: If Mr. Epstein needs to go to 5 Rothstein firm.
6 the bathroom, Mr. Epstein needs to go to the 6 I'd be happy, and hopeffilly at the end of this
7 bathroom. 7 trial everyone will know some of the names of the
8 THE WITNESS: Thank you, sir. 8 others, sir.
9 MR. PIKE: Then we're off the record? 9 BY MR. SCAROLA:
10 VIDEOGRAPHER: We're off the record. 10 Q. Do you know the names of any of the others?
11 (Brief recess.) 11 A. No, sir, I do not. However, the U.S.
12 VIDEOGRAPHER: We are back on video record at 12 Attorney, we believe, is going to file more charges
13 12:43 p.m. 13 against Mr. Roth — Mr. Edwards' partners. And
14 BY MR. SCAROLA: 14 Mr. Scherer and us have subpoenaed the bankruptcy
15 Q. I think when we went off the record you had 15 trustee for the names of the others.
16 requested that the last answer that you gave and the 16 So sitting here today, I do not. Hopefully
17 question asked of you based on that answer be read back, 17 sometime before trial we will have names of the others,
18 so we'll start there. 18 sir.
19 MR. PIKE: Madame Court Reporter. 19 Q. Have you ever pled guilty to any criminal
20 (Previous question and answer were read.) 20 wrongdoing?
21 THE WITNESS: Sounds like a complete runner to 2/ A. Yes, sir.
22 me. 22 Q. What criminal wrongdoing did you plead guilty
23 BY MR. SCAROLA: 23 to?
24 Q. NO, Sir. My question to you following that 24 A. A solicitation of prostitution and procuring a
25 answer was: Who are the others to whom you made 25 minor for prostitution, sir.
iftltilm,...hmawmehweaLL.4.44.,..0w
26 (Pages 98 to 101
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1 Q. On how many occasions did you solicit 1 MR. PIKE: Form. And relevance.
2 prostitution? 2 BY MR. SCAROLA:
3 A. Under — excuse me? Again? 3 Q. How many minors have you procured for
4 Q. On how many occasions did you solicit 4 prostitution?
5 prostitution? 5 MR. PIKE: Fenn.
6 A. At least sitting here today, going to have 6 THE WITNESS: On advice of Counsel, sir, I'm
7 to, on advice of Counsel, assert my Fifth Amendment, 7 going to have to assert my Fifth, Sixth and 14th
8 16th Amendment (sic) and Fourth (sic) Amendment Right. 8 Amendment Right, though I pled guilty to procuring
9 Q. On how many occasions did you plead guilty to 9 a single minor.
10' soliciting prostitution? 10 BY MR SCAROLA:
11 A. Once, sir. 11 Q. Yes, but my question wasn't about what you
12 Q. How many acts of solicitation of prostitution 12 pled guilty to. I just want to know how many minors you
13 did you plead guilty to? 13 have procured for prostitution.
14 A. Three. 14 MR. PIKE: Asked and answered.
15 Q. What are the names of the individuals who you 15 THE WITNESS: Again, at least with respect to
16 pled guilty to soliciting as prostitutes? 16 what I've pled guilty to, !pled guilty to
17 A. 1 do not know. 17 procuring a single minor.
18 Q. When did those acts occur? 18 With respect to the rest of your question, Fm
19 A. I do not know. 19 going to have to assert my Fifth, Sixth and 14th
20 Q. How many prostitutes have you solicited? 20 Amendment Rights as provided by my Counsel.
21 MR. PIKE: Fonn. 21 BY MR. SCAROLA:
22 THE WITNESS: On advice of Counsel, at least 22 Q. When did you procure the minor for
23 sitting here today, sir, I'd like to answer each 23 prostitution as to which procurement you pled guilty?
24 one of those questions. However, today Em going 24 MR. PIKE: Form.
25 to have to assert my Fifth, Sixth and 14th 25 THE WITNESS: i don't know.
Page 103 Page 105
1 Amendment Right. 1 BY MR. SCAROLA:
2 BY MR. SCAROLA: 2 Q. Was there a time before you entered your
3 Q. Who are the minors who you solicited for 3 guilty plea when you knew the identity of the
4 prostitution? 4 prostitutes that you solicited?
5 MR. PIKE: Form. MR. PIKE: Form.
6 THE WITNESS: Who aro the — I pled guilty to 6 THE WITNESS: Again?
7 soliciting prostitution. There was no soliciting 7 BY MR. SCAROLA:
8 minors charge, sir. 8 Q. Was there a time before the entry of your
9 MR. SCAROLA: Could you read back the response 9 guilty plea when you knew the identity of the
10 to the question about what Mr. Epstein pled guilty 10 prostitutes you solicited?
11 to, please? 11 MR. PIKE: RIM
12 MR. PIKE: About four questions bark. 12 174E WITNESS: I don't recall.
13 (Previous question and answer were read.) 13 BY MR. SCAROLA:
14 MR. PIKE: And his answer? 14 Q. Was there a time before the entry of your
15 MR. SCAROLA: That was his answer. 15 guilty plea when you knew the identity of the minor that
16 BY MK. SCAROLA: 16 you pled guilty to procuring for prostitution?
17 Q. Who are the minors who you procured for 17 MR. PIKE Form.
18 prostitution? 18 114E WITNESS: 1 don't know.
19 MR. PIKE: Form. 19 BY MR. SCAROLA:
20 THE WITNESS: I believe if you — my answer 20 Q. Did you plead guilty because you were, in
21 was procuring a minor, sir, not minors. 21 fact, guilty?
22 BY MR. SCAROLA: 22 MR. PIKE: Form.
23 Q. Who is the minor that you procured for 23 That's attorney/client, work product
24 prostitution? 24 Attorney/client
25 A. I do nor know. 25 MR. SCAROLA: I haven't asked anything about
27 (Pages 102 to 105)
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1 any communication. 1 crafting cases of a sexual nature against people in
2 MR. PIKE: It definitely could get into a 2 South Florida, me and others, the others yet to be
3 communication with Mr. Epstein's lawyers at the 3 determined. However, today, though I'd like to
4 time of the criminal proceeding. 4 answer every one of his questions, on advice of
5 MR. SCAROLA: No, sir, it can't. 5 Counsel, at least today, I'm going to have to
6 BY MR. SCAROLA: 6 assert my Fifth, Sixth and 14th Amendment Right.
7 Q. I want to know whether you pled guilty because 7 BY MR. SCAROLA:
8 you were, in fact, guilty. 8 Q. How many times have you engaged in fondling
9 A. I'm going to have to assert my Fifth, Sixth 9 underage females?
10 and 14th Amendment, sin 10 MR PIKE: Form
11 Q. Do you understand the term John to be a slang 11 THE WITNESS: This is relevance here at some
12 reference to the customer of a prostitute? 12 point?
13 MR. PIKE: Form. 13 MR. PIKE: To the extent you can answer the
14 THE WITNESS: Yes, sir. 14 question.
15 BY MR. SCAROLA: 15 THE WITNESS: Again, as another one of the
16 Q. How many times were you one A% 16 irrelevant questions asked of this lawsuit with
17 customers? 17 respect as a client how I was abused by the
18 MR. PIKE: Form 18 Rothstein firm for his — the practices, the abuse
19 THE WITNESS: f.'s customers. 19 of the legal system, the — hopefully, the ladies
20 You'll have to rephrase the question, sir. 20 and gentlemen of the jury will be able to see
21 BY MR. SCAROLA: 21 through some of these ridiculous questions with
22 Q. Your Complaint says — 22 respect to questions that today, at least, l must
23 MIL PIKE: What page were you reading from? 23 take the Fifth, Sixth and 14th Amendment, but I
24 MR. SCAROLA: Page 22. 24 believe are obvious to the ladies and gentlemen of
25 MR. PIKE: Thank you. 25 the jury what you're trying to do here,
Page 107 Page 109
1 BY MR. SCAROLA: 1 Mr. Scarola.
2 Q. Paragraph 46(a), last sentence: "Under the 2 MR. SCAROLA: Move to strike. Unresponsive.
3 circumstances, her claim for damages against Epstein, 3 MR. PIKE: No. That's fine.
4 one ofe.'s many Johns during that same period," et 4 BY MR. SCAROLA:
5 cetera. 5 Q. How many times have you engaged in illegal
6 You have identified yourself in this Complaint 6 sexual touching of minors?
7 as one oft.'s many Johns, which you acimowledge to be 7 MR. PIKE: Form. Relevance.
8 a reference to a customer of a prostitute. 8 THE WITNESS: Again, an irrelevant question to
9 How many times were you one 9 this lawsuit, strictly as a continued attempt to
10 customers for purposes of prostitution? 10 bring in irrelevant facts to the fact of what the
11 A. Well, now that you've now put on the record 11 Rothstein firm has done to both me and others in
12 theta., I believe, in her deposition is an admitted 12 South Florida, defrauding investors of millions of
13 prostitute, I would like to answer that question, but on 13 dollars, knowing that at least today I'm going to
14 advice of Counsel, sir, I'm going to have to 14 have to with respect to that particular question
15 respectfully decline. But I am happy to hear you 15 assert my Fourth excuse me — Fifth, Sixth and
16 finally admit it in your own questions that your... is 16 14th Amendment Rights.
17 an admitted prostitute. 17 MR. SCAROLA: Move to strike as unresponsive.
18 MR. SCAROLA: Move to strike. Unresponsive. 18 MR. PIKE: Mr. Scarola, he's answering your
19 BY MR. SCAROLA: 19 question. You're asking abusive and harassing
20 Q. Have you ever coerced, induced or enticed any 20 questions that are unrelated to this lawsuit.
21 minor to engage in any sexual act with you? 21 If you can direct me to anywhere in the
22 MR. PIKE: Penn. 22 Complaint that even remotely addresses your two
23 THE WITNESS: A typical question from 23 questions that you've just posed to Mr. Epstein,
24 Mr. Scarola representing Mr. Edwards and the firm 24 I'd be happy to look at the section in the
25 of Rothstein, who Scott Rothstein sits in jail for 25 Complaint. But moving to strike the witness'
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1 answer when he's answering your abusive and 1 Harassing. And not reasonably calculated to lead
2 harassing questions is improper. 2 to admissible evidence in this case.
3 BY MR. SCAROLA: 3 THE WITNESS: One more of Mr. Scarola's
Q. How many times have you engaged in oral sex 4 irrelevant questions designed nothing more to try
with females under the age of IS? 5 to harass me, to divert attention from the fact
o MR. PIKE: Objection. Relevance. Abusive and 6 that Mr. Edwards and his firm perpetrated one of
7 harassing. Not reasonably calculated to lead to 7 the largest frauds in South Florida's history by
8 discovery of admissible evidence in this case. 8 using people like me and others in an attempt to
9 THE WITNESS: A typical question posed by 9 fleece South Florida investors out of millions of
10 Mr. Scarola in an attempt to divert the attention 10 dollars, where the U.S. Attorney has accused his
11 away from the wrongdoing of Bradley Edwards, his 11 fin]] of being the largest militia& enterprise in
12 partner, Scott Rothstein, who sits in jail for 12 South Florida's history, where Mr. Edwards' partner
13 defrauding investors of South Florida of millions 13 sits in prison, potentially for the rest of his
14 of dollars, by crafting malicious cases of a sexual 14 life.
15 nature just in order to fleece investors, called by 15 IV like to answer all of your questions here
16 the U.S. Attorney one of the largest frauds in 16 today, Mr. Scarola, even though they're irrelevant;
17 South Florida's history. 17 however, on advice of Counsel, at least today, I'm
18 Mr. Scarola, as I would like to respond to the 18 going to have to assert my Fifth, Sixth and 14th
19 questions regarding of your underage girls, the 19 Amendment Right.
20 fondling or the other questions you've asked me 20 MR. SCAROLA: Move to strike as unresponsivc.
21 here today, unfortunately, I cannot on advice of 21 BY MR. SCAROLA:
22 Counsel answer those questions, so I must assert my 22 Q. Your Complaint at page 27, paragraph 49, says
23 Filth, Sixth and 14th Amendment Rights, though 23 that: TRA and the litigation team took an emotionally
24 these questions are totally irrelevant to this 24 driven set of facts involving alleged innocent,
25 lawsuit. 25 unsuspecting, underage females and a Palm Beach
Page 111 Page 113
1 MR. SCAROLA: Move to strike as unresponsive. 1 billionaire, and sought to turn it into a gold mine,"
2 BY MR. SCAROLA: 2 end of quote.
3 Q. Do you have a personal sexual preference for 3 Who is the Palm Beach billionaire referred to
4 children? 4 in that sentence?
5 MR. PIKE: Form. Relevance. Abusive. 5 A. On advice of Counsel today, Mr. Scarola,
6 Harassing. Not reasonably calculated to lead to 6 thought would like to answer each one of your
7 the discovery of admissible evidence in this case. 7 questions, I'm going to have to assert my Fifth, Sixth
8 THE WITNESS: Mother totally irrelevant 8 and 14th Amendment Right.
9 question to this lawsuit, Mr. Edwards' behavior, in 9 Q. What is die emotionally driven set of facts to
10 an attempt to strictly divert attention from the 10 which you make reference in that sentence?
11 wrongdoing of the Rothstein firm in this matter by 11 A. It's the same set of facts that were used by
12 asking sexually charged questions in a case where 12 the Rothstein firm to fleece unsuspecting investors out
13 the Rothstein firm has been charged by the U.S. 13 of millions of dollars, crafting, fabricating malicious
14 Attorney of fabricating claims of a malicious 14 cases of a sexually charged nature with no fundamental
15 nature, hiding behind attomey/client privilege, 15 basis whatsoever, reported wildly by the press. The
16 forging documents excuse me but as with 16 U.S. Attorney has accused Mr. Edwards' partner of not
17 respect to these questions designed for nothing 17 excuse me — Mr. Edwards' partner sits currently in
18 more than to harass me, Mr. Scarola, I'm going to 18 jail, pled guilty to some of these charges. There are
19 have to, unfortunately, take the Fifth, Sixth and 19 other members of his firm under investigation for just
20 14th Amendment 20 these types of questions and fabrications.
21 MR. SCAROLA: Move to strike as unresponsive. 21 But, however, today, though I'd like to answer
22 BY MR. SCAROLA: 22 every one of your questions with specificity, on advice
23 Q. Have you ever acted on a sexual preference for 23 of Counsel I'm not going to be able to, Mr. Sterols, and
24 children? 24 respectfully decline based Fifth, Sixth
25 MR. PIKE: Form. Irrelevant. Abusive. 25 Amendment Right.
29 (Pages 110 to 113)
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1 Q. What day are you prepared to answer all these 1 and 14th Amendment.
2 questions? 2 Si What are the voluntary and consensual actions
. 3 MR. PIKE: Form. Attorney/client and work 3 byM. that you are referencing there?
4 product. 4 A. Sir, though I'd like to answer each one of
5 THE WITNESS: That's attorney I wish I 5 your questions here today, I'm going to have to
6 could answer that question as well, but ifs 6 respectfully decline based on advice ofmy Counsel, and
7 attorney/client privilege, sir. 7 have to assert my Fifth, Sixth and 14th Amendment Right.
8 BY MR. SCAROLA: 8 Q. What are the damages that you claim to have
9 Q. Your Complaint says that: "Rather than 9 suffered as a consequence of any wrongdoing on the part
10 evaluating and resolving the cases based on the merits," 10 of Bradley Edwards?
11 open parens, "i.e., facts," close patens, "which 11 MR. PIKE: Fenn.
12 included larowledgeable, voluntary and consensual actions 12 THE WITNESS: The cost ofridiculous
13 by each of the claimants; et cetera. 13 litigation, ofhaving my attorneys prepare
14 Who are the claimants that are referenced 14 responses to wildly Irrelevant discovery in various
15 there? 15 locations at a minimum, sir.
16 A. It's — I'm sorry. You have to repeat the 16 BY MR. SCAROLA:
17 question. 17 Q. Which lawyers?
18 Q. Yes, sir. Your Complaint says,: -- 18 A. Burman Critton, Jack Goldberger, and a bunch
19 MR. PIKE: Page? 19 of the others, sir.
20 Q. -- "rather than evaluating" -- 20 Q. Which ones? Name them for me, please.
21 MR. PIKE: Can you give me a page, sir? 21 A. Specifically — !have so many lawyers
22 MR. SCAROLA: Page 27, paragraph 49, second 22 defending me here against Mr. Edwards, I can't sit
23 sentence. 23 here — at the moment I can't recall it with
24 BY MR. SCAROLA: 24 specificity.
25 Q. Quote, "rather than evaluating and resolving 25 Q. You don't remember any of your lawyers' names?
Page 115 Page 117
1 the cases based on the merits, that is, facts which 1 A. Oh, I do.
2 included knowledgeable, voluntary and consensual actions 2 Q. Besides Mr. — besides the Burman Critton firm
by each of the claimants." 3 and Mr. Goldberger?
4 A. Yes. 4 A. Are you asking me for the firm, sir, or are
Q. Who are the claimants that you're referencing 5 you asking me for the names?
6 there? 6 Q. I want as much information as you can give me
A. They're the prostitutes you referred to in the 7 about this element of damage which you claim; and, that
8 past, sir. 8 is, the cost of legal services that you claim to be
9 Q. What are their names? 9 damages in this case.
10 A. I think the prostitute? names were the 10 A. Okay.
11 prostitute that you described before was M. 11 MR. PIKE: Form. And move to strike.
12 With respect to the others, Fm going to have 12 THE WITNESS: Mr. Roy Black.
13 to claim the Fifth, Sixth and 14th Amendment, sir. 13 BY MR. SCAROLA:
14 Q. So one of the individuals that you're 14 Q. Okay. Who else?
15 referencing there is is that correct? 15 A. Mr. Marty Weinberger. Mr. Alan Dershowitz.
16 A. It's — the individual I've referenced is a 16 Mr. Jay Lefkowitz. The firm of Bunnan Critton Luther.
17 person who filed a claim against me. 17 That's it for the moment.
18 Q. hit ? 18 Q. How much have you paid the law firm ofBurman
19 A. It is , as far as I 'mow from the claim, 19 Critton and Luther which you claim is damages?
20 sir. 20 A. Hundreds of thousands ofdollars, sir.
21 Q. Okay. So one of the people that you're 21. Q. How much?
22 referring to is who you've identified as ni; is 22 A. I don't have that figure offhand.
23 that correct? 23 Q. Can you give us any better figure than
24 A. With respect to that question, sir, on advice 24 hundreds of thousands of dollars?
25 of Counsel, I'm going to have to assert my Fifth, Sixth 25 A. No, not sitting here today.
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1 Q. Are you paying them on an hourly basis? 1 A. I don't }mow.
2 A. Yes, sir. 2 Q. Does someone do that on your behalf?
3 Q. What is the hourly rate at which you are 3 A. I would guess so.
4 compensating members of the law firm? 4 Q. Who?
5 A They're ordinary rates. 5 A. I don't know.
6 Q. What are they? 6 MR. PIKE: Form.
7 A. I don't know. 7 BY MR. SCAROLA:
8 Q. How much have you paid Mr. Goldberger? Q. Who are the people who are authorized to make
9 A. I'm not aware total amount, sir. 9 payment on your behalf?
10 Q. What is the hourly rate at which you're paying 10 A. With respect to that question, I'm going to
1/. Mr. Goldberger? 11 have to assert the Fifth, Sixth and 14th Amendment, sir.
12 A. His normal hourly rate. 12 Q. Are there any other elements of damage, apart
13 Q. How much is that? 13 from the money paid to lawyers?
14 A I don% know. 14 A. Yes, sir.
15 Q. How much have you paid Mr. Black which you 15 Q. What?
16 claim as damages in this case? 16 A. The stress and emotional damage of imperiling
17 A Hundreds of thousands of dollars. 17 my friendships and business relationships with no
18 Q. Are you paying him on an hourly basis? 18 relevance whatsoever to these cases, brought by a rum
19 A. I believe so. 19 that whose partner sits in a Federal prison, who engaged
20 Q. What is the hourly rate? 20 in discovery to harass my friends and social contacts
21 A. I'm not — 'do not know, sir. 21 with no consideration or relevance to this case
22 Q. How much have you paid Marty Weinberg& 22 whatsoever, in an attempt to simply fleece — partly
23 A I don't know the exact amount, sir. 23 fleece investors In South Florida out of millions of
24 Q. What's your best estimate? 24 dollars, sir.
25 A. More than a hundred thousand dollars. 25 Q. What is the value of those losses?
Page 119 Page 121
1 Q. Are you paying him on an hourly basis? 1 MR. PIKE: Form.
2 A. I believe so. 2 THE WITNESS: I'm not sure yet, sir.
3 Q. What's the hourly rate? 3 BY MR. SCAROLA:
4 A. I don't know, sir. 4 Q. Do you have any idea at all?
5 Q. How much have you paid Alan Dershowitz? 5 A Not sitting here today.
6 A. Hundreds of thousands of dollars. 6 Q. More or less than $10?
7 Q. A!e you paying him on an hourly basis? 7 MR. PIKE: Form.
8 A I believe so. 8 THE WITNESS: I would guess it's more than
9 Q. At what hourly rate? 9 $10, sir.
10 A I don't know, sir. 10 BY MR. SCAROLA:
11 Q. How much are you paying Jay — how much have 11 Q. More or less than a hundred?
12 you paid Jay Letkowitz? 12 A I would guess it's quite an amount of money.
13 A. I'm not sure, sir. 13 Q. Is it more or less than a hundred?
14 Q. Do you have any idea at all? 14 A Yes, sir.
15 A. More than a hundred thousand dollars. 15 Q- More or less than a thousand?
16 Q. Are you paying him on an hourly basis? 16 A I would say it's more than 150,000.
17 A. Yes, sir. 17 Q. More or less than a million?
18 Q. What's the hourly rate? 18 A I don't Imow, sir.
19 A I don't know. 19 So somewhere between 150,000 and a million?
20 Q. What is the form of payment to your lawyers? 20 A No, sir. It's not —
21 How do you transfer money to them? 21 MR. PIKE: Form. Mischaracterizes the
22 A. I don't know, sir. 22 witness' testimony.
23 MR. PIKE: Form. 23 THE WITNESS: No, sir. That's not what I
24 BY MR. SCAROLA: 24 said. I said, !did not know.
25 Q. Pardon me? 25 BY MR. SCAROLA:
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1 Q. Maybe more than a million? 1 BY MR. SCAROLA:
2 A. Maybe. 2 Q. Do you attribute all of the damages that you
3 Q. More or less than a billion? 3 have described to Mr. Edwards' conduct?
4 MR. PIKE: Fonn. 4 MR. PIKE: Form.
5 THE WITNESS: I don't know. 5 THE WITNESS: As a participant — I don't know
6 BY MR. SCAROLA: 6 how to proportion the conduct as opposed to
7 Q. Maybe more than a billion? 7 Mr. Edwards and his partner who sits in jail. I
8 A. Maybe more. 8 guess the U.S. Attorney will also make a decision
9 Q. How are you going to go about finding out what 9 to how much the conduct and proportion is relevant
10 the value of that loss is? 10 to both damages and anything else he's done in this
11 MR. PIKE: Attorney/client, work product. 11 case, sir.
12 To the extent you can answer without 12 BY MR. SCAROLA:
13 disclosing our conversations or the conversations 13 Q. But Pm not asking you about what the U.S.
14 with your other attorneys that you've delineated, 14 Attorney's opinion is.
15 you can do so. 15 I want to know whether you hold Mr. Edwards
16 BY MR. SCAROLA: 16 responsible for all of those elements of damage that you
17 Q. Or you can just take the signal and say, I 17 have described to us.
18 refuse to answer because it's attorney/client privilege. 18 A. It's a difficult question to answer,
19 A. I resent that 19 Mr. Scarola.
20 MR. PIKE: Move to strike. 20 Q. No, it's easy. Yes, no, or I don't know.
21 THE WITNESS: But its okay. You can continue 21 MR. PIKE: Mr. Scarola, you know as well as I
22 to try to harass me, sir. It doesn't work. The 22 do, the witness is attempting to answer your
23 ladles and gentlemen of the jury, hopeftilly what 23 question.
24 they see the deposition will recognize and see 24 MR. SCAROLA: I don't think so. I think he's
25 these pile of ticks. The answer — 25 attempting to evade all of my questions.
Page 123 Page 125
1 MR. SCAROLA: Hopefully they will. 1 MR. PIKE: And I understand your contention.
2 THE WITNESS: Yes. 2 However, if you would, allow Mr. Epstein to finish
3 MR. PIKE: Move to strike. 3 his response.
THE WITNESS: I will respectfully decline to 4 THE WITNESS: Could you repeat your question?
answer that. 5 BY MR. SCAROLA:
BY MR. SCAROLA: 6 Q. Do you hold Mr. Edwards responsible for all of
Q. On what basis? 7 the damages that you have described?
8 A. Attorney/client privilege. MR. PIKE: Font
MR. PIKE: And work product. 9 THE WITNESS: It's difficult for me to
10 BY MR. SCAROLA: 10 proportion the damages that I have described
11 Q. Any other elements of damage? 11 between Mr. Edwards, his partner, who is currently
12 A. Not -- there might be, but sitting here today, 12 in jail, his -- the other people named in the
13 I can't think of them. 13 Complaint Hopefully a jury will do that.
14 Q. Do you have written contracts with any of your 14 BY MR. SCAROLA:
15 lawyers? 15 Q. Do you hold M. responsible for all of the
16 A. I don't know. 16 damages you have described?
17 Q. Who does? 17 MR. PIKE: Form.
18 A. I don't know. 18 THE WITNESS: Again, these questions, these
19 MR. SCAROLA: Let's take a short break. We 19 ambiguous questions, as opposed to who
20 may be finished. 20 participated, I would let Mr. Edwards and his
21 VlDEOGRAPHER: We are now off the record at 21 clients and his partners decide whose proportionate
22 1:12p.m. 22 responsibility it is, sir.
23 (Brief recess.) 23 BY MR. SCAROLA:
24 VIDEOGRAPHER: We are back on video record at 24 Q. So you defer to them?
25 1:18 p.m. 25 MR. PIKE: Fonn.
deatat WCOJY.VataLolailC•SPILliraile•S••
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1 THE WITNESS: As proportionate to the amount 1 contention on the record.
2 of damages, I think Mr. Edwards played a vital 2 Okay.
3 role. I believe his partners potentially played a 3 CROSS EXAMINATION
4 role. I've only had any contact with Mr. Edwards, 4 BY MR. EDWARDS:
5 sir. Q. Mr. Epstein, is your sole basis for your claim
6 BY MR. SCAROLA: againstM. that she changed her testimony from the
7 Q. Which partners? time she testified to the FBI id2007?
8 A. Beg your pardon? MR. PIKE: Form. To the extent you can answer
9 Q. Which partners, besides Mr. Edwards and 9 that question without invading attorney/client,
10 Mr. Rothstein, do you claim engaged in conduct that 10 work product, you can do so.
11 renders them liable to you? 11 THE WITNESS: Unfortunately, I'd like to
12 A. I believe it's in the Complaint, sir. And 1 12 answer that question, but I can't do so without
13 believe it's Mr. Adler, Mr. Berger. There's Mr. Jenne, 13 invading attorney/client privilege.
14 Mr. Fisten, but those are not partners. 14 BY MR. EDWARDS:
15 So Mr. Berger, Mr. Adler — and I forgot the 15 Q. Is there anything in Nis Complaint that was
16 mines of the others at the moment, sir, but it's in the 16 filed against you in September of 2008 which you contend
17 Complaint 17 to be false?
18 Q. Why didn't you sue them? 18 MR. PIKE: Asked and answered.
19 MR. PIKE: Form. 19 THE WITNESS: I recognize, Mr. Edwards, again,
20 THE WITNESS: Attorney/client privilege, sir. 20 the concept of attempting me to get to waive my
21 MR. PIKE: Work product 21 Fifth Amendment privilege; however, in this lawsuit
22 MR. SCAROLA: I have no further questions. 22 I've answered questions with respect to your
23 MR. EDWARDS: I have three or four questions. 23 lawsuit. And with regard to the question you just
24 That's it. 24 asked, I'm going to have to, unfortunately, assert
25 MR. PIKE: Okay. I just want to be clear for 25 my Fifth Amendment, Sixth Amendment and 14th
Page 127 Page 129
1 the record. Mr. Scarola represents Mr. Edwards in 1 Amendment Right.
2 this case; is that correct, Mr. Scarola? 2 But I'm willing to listen to any other
MR. EDWARDS: That's correct. 3 questions you may have.
MR. SCAROLA: Yes. 4 MR. EDWARDS: Finished.
MR. PIKE: And in this particular case, 5 MR. PIKE: 1have a couple questions.
a• • Epstein versus Rothstein, et al, Mr. Edwards, who 6 CROSS EXAMINATION
7 do you specifically represent? 7 BY MR. PIKE:
8 MR. EDWARDS: M. 8 Q. Mr. Epstein, earlier in the deposition
MR. PIKE: Okay. I believe that if you follow 9 Mr. Scarola was reading from page 2 of the Complaint
10 through with questioning, you have an 10 filed in the Epstein versus Rothstein, Rosenfeldt and
11 irreconcilable conflict with rItEd to the other 11 Adler, et aL Do you recall that?
12 case in which you represent M. and M. 12 A. Yes, sir.
13 1cannot stop you from asking any questions; 13 Q. And then I showed you page 2 of a Complaint
14 however, if you do move forward with asking 14 that I bad my notes on, correct?
15 questions, I will take the appropriate action. 15 A. Yes.
16 MR. SCAROLA: And on behalf— on behalf of my 16 Q. Did you read the black type or did you mad
17 client — 17 the handwritten notes in the corners of the Complaint,
18 MR. PIKE: Yes, sir. 18 that particular page that I showed you?
19 MR. SCAROLA: — we do not accept your 19 A. Unfortunately, my eyesight is not good enough
20 assessment ofMr. Edwards' ethical 20 to read the notes. I only read the black letter.
21 responsibilities. 21 Q. And it was that one sentence, correct?
22 MR. PEKE: That is absolutely fine for you to 22 A. It was two sentences, I believe, but, yes.
23 do that. I just wanted to put it on the record 23 MR. PIKE: Thank you.
24 that 1am, by no means, going to prevent you from 24 Well real.
25 questioning today. However, I wanted to put my 25 REDIRECT EXAMINATION
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BY MR. SCAROLA: 1 to read the handwritten notations; is that correct?
Q. What is your eyesight? 2 MR. PIKE: Form.
A. Sorry? 3 TEE WITNESS: In this particular instance,
Q. What is your eyesight? 4 sir, these glasses did not. I'm not saying they
D A. My eyesight? 5 cannot, but did not allow me to read the notes,
Q. Yes, sir. You said that your eyesight was not 6 that's correct
good enough to be able to read the handwritten 7 MR. SCAROLA: I would hie those glasses
notations. What is your eyesight? 8 marked as an Exhibit to this deposition.
9 A. Are we on the record or off? 9 MR. PIKE: I don't think so.
10 Q. We're on the record. 10 MR. SCAROLA: You're refusing to allow that to
11 MR. PIKE: We're on the record. 11 happen?
12 THE WITNESS: I need 3.5 glasses. 12 MR. PIKE: I don't see how you can mark a set
13 BY MR. SCAROLA: 13 of glasses as an Exhibit to a deposition.
14 Q. And you had those on when you were reading the 14 The witness has already said that he did not
15 Complaint, didn't you? 15 read the handwritten notes in the corner or the
16 A. But these aren't my 3.5s, sir. 16 corners of page 2 of the Complaint.
17 Q. What are they? 17 MR. SCAROLA: The witness is a liar. The
18 A. I don't know. 18 witness' testimony is totally incredible. The
19 Q. Let's hand them over, if you would. Let's 19 witness made up a response and I want to be able to
20 take a look at them. 20 demonstrate to the Court and jury that the witness
21 A. Sure. 21 lied when he said that those glasses did not
22 Do you see anything? 22 correct his vision sufficiently to be able to read
23 Q. No. 23 the handwritten notes.
24 Is it your contention that those glasses were 24 I want the glasses marked as an Exhibit.
25 inadequate to enable you to read the handwritten 25 If you refuse to mark them, lam placing you
Page 131 Page
1 notations on the Complaint? 1 on notice that they are relevant and material to
2 MR. PIKE: Form. Mischaracterizes testimony. 2 issues involved in this lawsuit and need to be
3 THE WITNESS: My testimony was, I only read 3 preserved.
4 the black letter and partially because I cannot see 4 MR. PIKE: All right. We'll mark the glasses.
thoroughly through these glasses, sir. 5 We'll mark the glasses as an Exhibit. Okay? And I
6 BY MR. SCAROLA: 6 will keep them here in my office.
7 Q. Is it your contention that those glasses did 7 MR. SCAROLA: Thank you.
8 not sufficiently correct your vision to be able to read 8 MR. PIKE: That's fine.
9 the handwritten notations on the papers that were handed 9 VIDEOGRAPHER: This concludes today's
10 to you? 10 videotaped deposition ofJeffrey Epstein. The time
11 MR. PIKE: Form. 11 is 1:27.
12 THE WITNESS: Again, we can play this game 12 (Exhibit number I was marked for
13 back and forth. What ljust said, and I think I 13 identification purposes and retained by Counsel le•
14 was very clear, that I did not read the notes. 1 14 Plaintiff.)
15 said 15 (Witness excused.)
16 BY MR. SCAROLA: 16 (Deposition was concluded.)
17 Q. What you said was, you couldn't read the 17
18 notes? 18
19 MR. PIKE: Allow the witness to finish. 19
20 THE WITNESS: Let me fetish. And what I said 20
21 was, with these glasses it would be almost 21
22 impossible for me to read the notes on the page. 22
23 BY MR. SCAROLA: 23
24 Q. Yes, sir. So your contention is, that those 24
25 glasses do not adequately correct your vision to be able 25
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1 CERTIFICATE OF OATH 1 DATE: March 26, 2010
2 TO JEFFREY EPSTEIN Job II358
2 STATE OF FLORIDA do hficbad Pile. Esquire
3 COUNTY OF PALM BEACH 3 303 Banyan Boulevard, Suite CO
West Pabn Beach, Florida 33401
4
5 DIRE: Epatem vs, Edwards. etas
6 I, the undersigned authority, certify that 5
CASEN02 502609CA0408003COCOABAG
7 JEFFREY EPSTEIN personally appeared before me and was 6
8 duly sworn on the 17th day ofMarch, 2010. Phase take ram that oc Wednesday, the 17th
7 of histch,20104ou gave your deposition, in the
9 alxweiefened nutter. At that rune, you did not waive
10 Dated this 26th day ofMarch, 2010. 9 signature. It is now neonatey that you sign your
deposition.
11 9 Please call our office al the belesolisted
12 number to schedule an semoitinnat brewed, the boos of
13 10 960 a.m. and 4:30 p.m_ Mondry &mash Pnday, at the
Esquire office leered neared
14 11 If you do riot read and sign the deposition
ciatchtetioast 12
withal a reasonable time, the oeiginal. whet bas
already beta fonvuded to the cadet* adorn*, may be
15 filed with the Oak of the Cows If you wish to want
Sandra W. Townsend, Cant 13 you signature. sign your name in the blank at the
16 bottom of this terra and serum it to us
Notary Public - State ofFlorida 14
My Commission Expires: 6/26112 Very truly met
17 My Commission No.: DD 793913 15
16
18 Job #1358 17 Sandra W Townsend, PPR
19 PROSE COURT REFORM() AGENCY
Ia 150 Australia Awn" &ate 1500
20 West Pailltrida 33401
21 17 Flame
22 I do haeby waive my nithamre.
23 _2 JEI₹REY EPSTEIN
24 I do hereby waive my signature:
cc: Via tract* All Conned of Record; file copy
25 25
Page 135 Page 1 3 7
1 CERTIFICATE 1 CERTIFICATE
2 STATE OF FLORIDA
3 COUNTY OF PALM BEACH 2
I. Sandra W Townsend. Court Resume tied
3 THE STATE OF FLORIDA
Wary Public in and for the Sue of florid, at Large,
do hereby certify that the aforememioned wtneut wu by
4 COUNTY OF PALM BEACH
me first duly sum to testify the vobtie truth; that I 5 I hereby certify that 'have read the
7 wat nothorized to and did mood raid donation in 6 foregoing deposition by me given, and that the
nemtype, and that the foregoing pages numbered —
a to —inchanu, we a inn and correct transcription of 7 statements contained herein are true and correct to the
my shorthand notes of said deposition 8 best of my knowledge and belief, with the exception of
9
I further °edify that said deposition was 9 any corrections or notations made on the errata sheet,
10 lakes at the time and place hereinabace set forth and 10
Out the taking of mid deposition nit commenced and
if one was executed.
II ethoploted as hereinalxec set out. 11
12 I (tether certify that I an not attorney or
comet of any of the patios. nor am I a relative or 12 Dated this day of
13 employee of nue attorney or counsel of patty connected 13 2010.
with the action, nor am ! financially intetened in de
14 mean. 14
15 The fon:going certificatica of this transcript 15
does not 4,ply to any reproduction of the sane by any
16 means unless wider the died control ands direction 16
of the canning divot/ 17
17
19 18
Dated this 26th day of March, 2010.
19 19 JEFFREY EPSTEIN
20 20 Job #I358
~ 1 moult 21
21
Stain W. Townsend, Court Reporter 22
22
Job It WS 23
23 24
24
25 25
35 (Pages 134 to 137)
PROSE COURT REPORTING AGENCY, INC.
Electronically signed by Sandra Townsend (401
Electronically signed by Sandra Townsend (401 1ddcfb84-b324-4437-a670-765e29067146
EFTA01076646
Page 138
1 ERRATA SHEET
2 INRE: EPSTEIN VS. EDWARDS,ET AL at S. TOWNSEND
3 DEPOSITION OF: JEFFREY EPSTEIN
4 TAKEN: 3/17/10 10B740.: 1358
5
6 DO NOT WRITE ON TRANSCRIPT- ENTER CHANGES HERE
7 PAGE/ LINEN CHANGE REASON
9
:0
it
12
13
14
15
16
17
18 Please Reward the original signed errata sheet to this
office so that copies may be distributed to SI parties.
19
Under penalty of perjury, I declare that I have read my
20 deposition and that it is true and COMO subject to
any changes in form or substance mitered here.
21
22 DATE:
23
24 S1ONATUREOF DEPONENT:
25
36 (Page 138)
PROSE COURT REPORTING AGENCY, INC.
Electronically signed by Sandra Townsend (401M
Electronically signed by Sandra Townsend (401 iddclb844,324-44374670-765029067145
EFTA01076647