EFTA01089049

IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants. VIDEOTAPE DEPOSITION CONT'D OF BRADLEY EDWARDS VOLUME II OF II PAGES 110 - 250 October 10th, 2013 10:00 A.M. - 2:30 P.M. 401 East Las Olas Blvd., Suite 1400 Fort Lauderdale, FL Stenographically Reported By: WENDY ROBERTS, RPR Notary Public, State of Florida Empire Legal Support, Inc. Fort Lauderdale Office Phone: EFTA01089049 Bradley J. Edwards taken on 10/10/20 I 3 APPEARANCES: ATTORNEY(S) FOR MR. EPSTEIN: TONJA HADDAD COLEMAN, ESQUIRE Tonja Haddad, PA 315 SE 7th St Ste 301 Fort Lauderdale, Florida 333013158 Phone: Fax: E-Mail: FRED HADDAD, ESQUIRE Fred Haddad PA 1 Financial Plz Ste 2612 Fort Lauderdale, Florida 333940061 Phone: Fax: E-Mail: JACK GOLDGERGER, ESQUIRE Atterbury Goldberger ■ Al 250 S Australian Ave Ste 1400 West Palm Beach, Florida 334015015 Phone: Fax: E-Mail: ATTORNEY FOR BRADLEY EDWARDS: WILLIAM KING, ESQUIRE Searcy Denney Scarola ■ Al 2139 Palm Beach Lakes Blvd West Palm Beach, Florida 334096601 Phone: Fax: E-Mail: ALSO PRESENT: JEFF EPSTEIN, PLAINTIFF (telephonically) DEBRA FEIN, LAW CLERK Empire Legal Support. Inc. Page: I I 1 EFTA01089050 Bradley J. Edwards taken on 10/10/2013 INDEX WITNESS: Page BRADLEY EDWARDS Direct Examination cont'd by MR. HADDAD 114 EXHIBITS PLAINTIFF'S: EXHIBITS: Description Page Comp. No. 1 Response to RP#7 Correspondence between BJE and US Government RE Epstein in BJE Possession 66 pages 244 Comp No. 2 E-mail from Russell Adler to Bradley Edwards RE: Oct. 28th depo, sent on 10/14/09 58 pages 244 Empire Legal Support. Inc. Page: 112 EFTA01089051 Bradley J. Edwards taken on 10/10/2013 1 (Continued from Volume I dated May 15th, 2013.) 2 Videotape Deposition taken before Wendy Roberts, 3 Registered Professional Reporter and Notary Public in 4 and for the State of Florida at Large, in the above 5 cause. 6 _ _ _ 7 THE VIDEOGRAPHER: We are now on the video 8 record. Today's date is October 10th, 2013. The 9 time is 10:15 A.M. Would counsel please state 10 their appearances for the record. 11 MR. KING: William King, Searcy Denney Scarola 12 Barnhart & Shipley for Mr. Edwards. 13 MR. GOLDBERGER: All right. Jack Goldberger, 14 Atterbury, Goldberger & Weiss, West Palm Beach, on 15 behalf of Jeffrey Epstein. 16 MR. INDYKE: Darren K. Indyke of Darren K. 17 Indyke, PLLC, on behalf of Jeffrey Epstein. 18 MR. HADDAD: I am Fred Haddad -- Fred Haddad 19 on behalf of Jeff Epstein. 20 MS. COLEMAN: Tonja Haddad Coleman, Tonja 21 Haddad, PA, on behalf of Jeffrey Epstein. 22 MS. FEIN: Debbie Fein of Tonja Haddad, PA, on 23 behalf of Jeffrey Epstein. 24 MR. HADDAD: This is a continuation of the 25 deposition of, I guess it was a couple months ago Empire Legal Support. Inc.. Page: 113 EFTA01089052 Bradley I. Edwards taken on 10/10/2013 1 that we stopped. 2 Thereupon: 3 BRADLEY EDWARDS 4 having been previously duly sworn or affirmed, was examined and testified as follows: 6 DIRECT EXAMINATION (Cont'd) 7 BY MR. HADDAD: 8 Q And Mr. Edwards, since the deposition of last 9 time, I guess some discovery has been provided, correct? 10 A Right. 11 Q All right. And those would be in response to 12 request for production No. 7, I guess, correspondence, 13 and I think that's what that means R4P, correspondence 14 between BJE and U.S. Government regarding Epstein, that 15 was in your possession, correct? 16 A Okay. 17 Q That's what this appears to be. I think that 18 came from Scarola, if I'm not mistaken. Under response 19 to request to produce, or Scarola, Searcy Denney, II al. 20 A Okay. It looks like correspondence between 21 myself and the United States -- 22 Q All right. 23 A -- Attorney's Office. 24 Q All right. And that would comp comprise 25 all of the correspondence that was actually gauged Empire Legal Support, Inc. Page: 114 EFTA01089053 Bradley J. Edwards taken on 10/10/2013 1 between yourself and either, what's his name, , or 2 Miss , whatever you want 3 to call her? 4 A That's my understanding. 5 Q All right. Well, this all came from your 6 files and from your records, correct, e-mails, whatever 7 you call those things where you store e-mail servers or 8 whatever there? 9 A You sent a request, I did whatever searches 10 that I could to come up with all of the documents 11 between us and I turned them over to my attorney who 12 turned them over to you. 13 Q All right. And I don't know if that request 14 contained anything regarding any memorandums of 15 conversations that you might have had, telephonic 16 conversations or in-person conversations. Did any of 17 those exist? 18 A Not to my recollection. 19 Q Okay. So -- 20 A I think that's everything. 21 Q That's what I'm asking, everything that there 22 is, correct? 23 A I believe so. 24 Q All right. And this would take -- some of 25 it's not numeric -- not numerically -- not -- Empire Legal Support. Inc. Page: 115 EFTA01089054 Bradley J. Edwards taken on 10/10/20 I 3 1 A Chronological? 2 Q Chronological, thanks for the word, 3 chronologically presented. But I note the first thing I 4 have is to and it states something about 5 October 9, 2008, regarding some potential false 6 statements the Government made in a sworn declaration 7 with the above-captioned case. That was you writing to 8 them, correct? 9 A What I'm looking at right now appears to be on 10 my letterhead from back then, so I would say yes. 11 Q All right. And whatever it says, it says -- 12 A That's my signature. 13 Q Okay. And that would be the same with all of 14 these? Let me -- let me just go through them. Let me 15 see which ones I'm going to ask. 16 MR. KING: Take your time to look at them 17 MR. HADDAD: Yeah. 18 MR. KING: -- if you think you need to. 19 MR. HADDAD: What do you think, I altered 20 them? 21 MR. KING: No, no, no, no. Because I'll need 22 to take a look at them if you have any questions 23 about -- 24 MR. HADDAD: I understand that. 25 Empire Legal Support. Inc. Page: 1I6 EFTA01089055 Bradley J. Edwards taken on 10/10/2013 1 BY MR. HADDAD: 2 Q Now, the letter here that I'm looking at on 3 March 15th from Wifredo Ferrer to Paul G. Cassell, and I 4 guess it was turned over by you in this discovery, and 5 that was on March 25th of 2011, I believe, correct? 6 A It's dated March 15th, 2011. 7 Q Oh, I'm sorry, my glass -- even with glasses, 8 I can't see that well. All right. 9 So that was March 15, 2011. Paul Cassell, I 10 take it, was your co-counsel who was some kind of law 11 professor and judge and all that stuff? 12 A Right. 13 Q All right. And he was co-counsel with you on 14 these cases? 15 A Right. 16 Q Does he still remain co-counsel with you on 17 these cases? 18 A Well, the only case that is remaining is the 19 Crime Victims Rights Act case -- 20 Q Yeah. 21 A -- and yes. 22 Q But that's been -- that's in the 11th Circuit, 23 right, now 24 A Right. 25 Q -- in -- pending stayed or briefing, I don't Empire Legal Support. Inc. Page: 117 EFTA01089056 Bradley J. Edwards taken on 10/10/20 I 3 1 know what, something is out there, correct? 2 A It has been fully briefed. I think oral 3 argument is January, February, but yes. 4 Q All right. And he's still on that case with 5 you, correct? 6 A Yes. 7 Q All right. Would this letter have been 8 sent -- when this letter was sent to Mr. Cassell, would 9 you have received a copy of it contemporaneously? 10 A I can't -- I don't know. 11 Q All right. But somehow it -- 12 A I either got it from Paul -- 13 Q Right. 14 A -- or I got it from them and I don't really 15 remember. Am I copied on it? 16 Q I don't see a CC to you. No. 17 A Okay. 18 Q So you are familiar with this though, it was 19 in your files? 20 A Right, I -- I was involved in the whole 21 process, so, yeah, I'm familiar with it 22 Q Yeah, I understand that but I 23 A Yeah, I'm familiar with it. 24 Q -- I don't want to speculate though. 25 A No. Empire Legal Support. Inc. Page: 1I8 EFTA01089057 Bradley J. Edwards taken on 10/10/2013 1 Q I want the answer from you. 2 All right. And then on September 29th, 3 2011 -- on September 29th, 2011, there is another letter 4 to the United States Attorney, Mr. Ferrer, and it's a 5 follow-up on Jeffrey Epstein by the same Mr. Cassell, 6 correct? 7 A That's what it appears to be. 8 Q All right. There is a carbon copy to 9 and , correct? 10 A Okay. 11 Q Okay doesn't answer. Yes or no? I need 12 A That's what it appears to be. 13 Q Yeah, but -- yeah, I know. I am just asking 14 you -- 15 A I mean, I didn't send the letter. I'm looking 16 at the same thing you are looking at. 17 Q I know. 18 A Paul signed it and then he copied 19 and 20 Q Do you know how you received a copy of this? 21 A I don't remember right now. 22 Q But it is in your records? 23 A Yes. 24 Q And would you have read it at the time it came 25 in? Empire Legal Support. Inc. Page: 119 EFTA01089058 Bradley J. Edwards taken on 10/10/2013 1 MR. HADDAD: Where is that thing of hers? 2 MR. GOLDBERGER: Chill. Chill. 3 MR. HADDAD: Chill, I always chill. 4 THE WITNESS: What is your question? 5 MR. HADDAD: I don't remember. 6 A I think -- I think it was whether or not I 7 received it at the time that it was sent, and I don't -- 8 I don't know exactly the timing of when I received this 9 letter. But it would have been close in time to when it 10 was sent. I don't know exactly. 11 BY MR. HADDAD: 12 Q So you could -- you all were working these 13 together, correct? 14 A Yeah, right. 15 Q And whatever is in these documents speaks for 16 themselves, correct? 17 A Exactly. 18 Q Would they have engendered by you any 19 follow-up calls to the U.S. Attorney or to anyone in the 20 U.S. Attorney's Office? 21 A No. 22 Q All right. Things such as -- at the same 23 time, this -- Rule 26 disclosures, and Jane 1 -- and 24 Jane Doe 1 and Jane Doe 2, those are your CRVA {SIC} 25 cases, correct? Empire Legal Support. Inc. Page: 120 EFTA01089059 Bradley J. Edwards taken on 10/10/2013 1 A Just tell me what your question is. I'm not 2 sure that-- 3 Q I said CR -- John Doe 1 and 2 your CRVA cases? 4 A Right. 5 Q All right. And then this is the -- 6 A That's the case number for it. 7 Q Okay. And what I'm asking you is, this is a 8 document sent by Farmer, Jaffe, Weissing, Edwards, 9 Fistos, and then what, you emulate Searcy and Denney to 10 have as many names as they do? I guess. Any rate, this 11 is on your letterhead and it's sending the United States 12 Attorney's Office a list of, I guess, discovery; is that 13 correct? 14 A Well, no, I think that we were just complying 15 with the 26(a) witness disclosures in that case. There 16 has always been a -- a -- I don't want to say 17 disagreement because I don't think anybody actually 18 knows whether this case falls under the civil rules of 19 procedure or criminal, but an abundance of caution, if 20 it fell under the civil rules, we felt that those 21 disclosures were necessary. 22 Q All right. But let me ask you this: Was this 23 in response to a request to produce by the Government or 24 was this a voluntary disclosure of what you thought you 25 had as evidence? That is, I mean, was there a civil -- Empire Legal Support. Inc. Page: 121 EFTA01089060 Bradley J. Edwards taken on 10/10/2013 1 you know, I'm not that adept at the rules of civil 2 procedure, but I understand that before you respond to 3 something, there is usually a request to produce, 4 request to disclose, interrogatories, something like 5 that. 6 A Right. 7 Q But you can make a voluntary disclosure at 8 times if you wish to -- to have litigation go forward 9 faster, as it were. I don't know the proper term -- 10 A Right. 11 Q -- they use in civil litigation. 12 A All right, I will tell you a couple things. 13 One is, the only thing that -- that I'm a little uneasy 14 about right now is that we are getting into work product 15 not on this case, we are not on the underlying case, but 16 on the Crime Victim's Rights Act case that is still 17 actively being prosecuted. However, to the extent that 18 I can answer this question, the purpose of this was 19 solely because Judge Marra, I believe, was of the 20 mind-set that this fell into a civil category rather 21 than criminal, and therefore, Rule 26 disclosures would 22 need to be made. And so in hopes that the Government 23 would reciprocate, we provided our witnesses and 24 expected for them to do the same. 25 Q All right, but I understand what you are Empire Legal Support. Inc. Page: 122 EFTA01089061 Bradley J. Edwards taken on 10/10/2013 1 saying there. The simple thing -- my simple question is 2 this. Were you in the litigation status that you needed 3 to produce this or was this a voluntary production for 4 purposes of hoping the Government would respond to you? 5 A We felt it was necessary. 6 Q That's not my question. 7 A I understand that. 8 Q Was this -- okay 9 A I don't know the answer to your question, 10 though. 11 Q You are an attorney, you are fairly bright and 12 we went through that last time, I don't want to have to 13 go through that again, how smart you are. This was -- 14 you're saying here, if you are correct that the civil 15 rules apply, that's , then both sides of the 16 case are obligated to make voluntary initial disclosures 17 under Rule 26(a). We are writing to make our initial 18 disclosures and ask that you promptly do the same, 19 correct? 20 A We felt it was our obligation. 21 Q I can read what it says here. 22 A Okay. 23 Q We are making our initial disclosures and ask 24 you to do the same, voluntary initial disclosures, okay? 25 A Right. Empire Legal Support. Inc. Page: 123 EFTA01089062 Bradley J. Edwards taken on 10/10/2013 1 Q You felt it was necessary, it wasn't required 2 by rule, by anything, it was a voluntary thing you are 3 doing, as you are say in your own words, correct? 4 A Correct. 5 Q Did you get a response from the Government? 6 A I don't remember. 7 Q Okay. 8 A This is something from March of 2011, I just 9 don't remember. 10 Q You don't remember whether or not the 11 Government provided you a list of their discovery, their 12 evidence, their witnesses or anything, whatever there is 13 in response to Rule 26 that they are required to comply 14 with? 15 A I can tell you they've provided us very 16 little, much less than we wanted. Have they provided us 17 nothing? I don't know that that's true. 18 Q Well, they provided you a letter saying you 19 have no business being in this thing, but besides that, 20 have they done anything in here? 21 A I don't remember that. 22 Q Okay. 23 A The -- the dockets on PACER will speak for 24 itself though, if they've made those disclosures, I 25 think -- Empire Legal Support. Inc. Page: 124 EFTA01089063 Bradley J. Edwards taken on 10/10/2013 1 Q I don't know how to open an e-mail, as you 2 well know. I am asking you a simple question. Do 3 you -- 4 A I'm trying, Fred. 5 Q I understand you are trying, Brad, I 6 appreciate that. We all try. A little harder at my age 7 than yours but we all try. I had to get one age joke in 8 there. 9 All right. Now, correspondence has been going 10 on since 2008 -- 2008 regarding this CRVA, correct? 11 A That's correct. 12 Q My -- excuse me, I don't want to stutter. 13 With everything you produced, I'm at a loss to find 14 anything that was produced while you were with 15 Rothstein; is that correct? 16 A That may be correct. 17 Q I would like you to look through that because 18 I really want to know whether or not anything was 19 produced while you were with -- and Rothstein would be 20 Rothstein, Rothstein and Adler? 21 A Right. 22 Q No, Rothstein from -- 23 MS. COLEMAN: Rosenfeldt. 24 BY MR. HADDAD: 25 Q Rosen -- Rosenfeldt and Adler, your former Empire Legal Support. Inc. Page: 125 EFTA01089064 Bradley J. Edwards taken on 10/10/2013 1 partnership. 2 A Was anything produced between 3 Q Yeah, did you -- a CRVA -- 4 A -- April and October 2009? 5 Q Yeah, when you -- 6 A Right. 7 Q -- were with that firm, was there anything 8 going on between you and the Feds while you were with 9 A Well, what you are asking though is, was 10 anything produced in the Crime Victims' Rights Act 11 while -- between -- 12 Q Okay. Let me put it this way, I mean in the 13 way of pleadings, in the way of pleadings or any type of 14 correspondence with the Federal Government. You were 15 there five months? 16 A Five or six months. 17 Q During those six months, let's give it six 18 months. 19 A Fine. 20 Q Okay. That you were with -- in this building? 21 A Correct. 22 Q The building that Scott built, the house that 23 Scott built. Is that like The House That Ruth Built or 24 something? 25 At any rate, at any time, were there any Empire Legal Support. Inc. Page: 126 EFTA01089065 Bradley J. Edwards taken on 10/10/2013 1 correspondence between the Federal Government and 2 Bradley Edwards' partner, Rothstein, Rothstein and 3 Adler, as the way you signed off -- or Bradley 4 Edwards -- anything? 5 A Come on, come on. You're going to have to go 6 back in the bag and grab a question that I can actually 7 answer. 8 Q Look through all of this and tell me if this 9 is everything you have, if there is one thing during the 10 period of time you were with Rothstein? 11 A In this? 12 Q In -- well, that's everything you own, you 13 said, regarding the -- that -- that request to produce 14 regarding the CRVA, as well as the correspondence. 15 A All right. Correspondence. 16 MR. GOLDBERGER: I think you are one letter 17 away. 18 MR. HADDAD: Oh, what difference does it make, 19 he knew what I was talking about. Crime Rights, 20 Victims, Crime Victim Rights, okay. ASPCA, the 21 same thing. 22 THE REPORTER: Counsel, do you want that on 23 the record? 24 MR. HADDAD: You can type it, I don't care. 25 (Thereupon, a discussion was had off the Empire Legal Support. Inc. Page: 127 EFTA01089066 Bradley J. Edwards taken on 10/10/2013 1 record.) 2 A I don't see anything. 3 BY MR. HADDAD: 4 Q All right. Thank you. 5 MR. GOLDBERGER: Wait, let -- 6 MR. HADDAD: What? 7 MR. GOLDBERGER: I want to make sure the 8 question is answered, Fred, before you jump on the 9 next one. 10 THE WITNESS: I was going to say -- 11 MR. HADDAD: I don't have a next one to jump 12 onto yet. I just dug into a few things here this 13 morning when I got up getting my kid ready for 14 school. I just dog-eared a few things this morning 15 when I woke up, get my kid ready for school. 16 A You were going to ask me how to do that? Oh. 17 BY MR. HADDAD: 18 Q I have been doing it for 40-something years. 19 I have here, I forget where they came from, a 20 whole bunch of e-mails you turned over. 21 A Okay. 22 Q Since the last time we met, or since -- yeah, 23 since after that deposition, correct? These are e-mails 24 that were given over in discovery to Miss Coleman, I 25 believe, or somebody, to Mr. Indyke, is that -- huh? Empire Legal Support. Inc. Page: 128 EFTA01089067 Bradley J. Edwards taken on 10/10/2013 1 MR. INDYKE: To Fowler. 2 MR. HADDAD: To Fowler? 3 MR. INDYKE: Yes. 4 MR. HADDAD: Oh, how come we didn't -- okay. 5 A Right, this predates the last deposition. 6 BY MR. HADDAD: 7 Q All right. I -- well, did they ask you about 8 these, I don't think they would have? 9 A They would only be you, and I don't know if 10 you have or not. 11 Q I never saw them before. Well, I mean, you 12 can object. I'm going to ask. I don't see -- I didn't 13 see any questions or answers regarding any e-mails. 14 A I don't remember. 15 MR. KING: At the last deposition? 16 BY MR. HADDAD: 17 Q At the last deposition. In the first 18 deposition, Mr. Scarola didn't last -- let anybody ask 19 anything, so I'm not going to be long with these and 20 rather than go through a whole hearing, I mean, if am 21 out of order, okay, that is not unusual. 22 A What else is new, right? 23 Q That -- that -- yeah, I mean, this is just a 24 simple discovery depo. All I want to do is these, is 25 I've got a stack of Bates stamped things, I guess we Empire Legal Support. Inc. Page: 129 EFTA01089068 Bradley J. Edwards taken on 10/10/2013 1 found or somebody found, I don't know, of -- 2 A If you found them, I turned them over. 3 Q I -- I understand that. I just want 4 A I just don't want the record to make it seem 5 like they were floating around on the street. 6 Q Brad, no one is doubting your bona fides as 7 far as discovery is concerned. When I if I did that, 8 I would say it right out, I don't 9 A I know. 10 Q -- I don't hint around, you know that. All 11 right. 12 Look at -- but these would be dep -- these 13 would be e-mails that were actually during the course of 14 your time actually at -- 15 MS. COLEMAN: Can I mark this as an exhibit? 16 BY MR. HADDAD: 17 Q Rothstein, Rosenfeldt and Adler, I believe. 18 They are all in 2009, from June until -- actually, 19 think the last one is October 29th or 30th. Just look 20 through these, just for purposes -- I am not going to 21 sit here and ask you questions about everything or 22 and many of them, because, you know, they speak for 23 themselves, but I just want to make sure we are accurate 24 in what we have there, and those things would have been 25 things that you would have produced. Empire Legal Support. Inc. Page: 130 EFTA01089069 Bradley J. Edwards taken on 10/10/2013 1 MS. COLEMAN: While he is looking at that, 2 just so the video is clear, the request to produce 3 regarding the Government exhibits, I have attached 4 as Exhibit 1 to the deposition that he just went 5 over and those will be Exhibit 2. 6 MR. HADDAD: Oh, okay. I don't know how to do 7 that. 8 MR. GOLDBERGER: Yes. Yes, that's what we 9 want to do. 10 MS. COLEMAN: I'm the token civil lawyer in 11 the room. I thought I would just throw that out 12 there. 13 MR. HADDAD: Token woman in the room too. 14 MR. KING: So the Rule 26 disclosures to the 15 Government will be Exhibit 1; is that right? 16 MR. GOLDBERGER: Yes. 17 MS. COLEMAN: No, no -- 18 MR. GOLDBERGER: It will be part of it. 19 MS. COLEMAN: -- those -- those were 20 provided those -- the Exhibit 1 is responsive to 21 Request No. 7 on the Schedule A, to which 22 Mr. Edwards objected prior to the last deposition. 23 So they were responsive. 24 MR. KING: All I want to know is what is being 25 marked as Exhibit 1. Empire Legal Support. Inc. Page: 131 EFTA01089070 Bradley J. Edwards taken on 10/10/2013 1 MS. COLEMAN: It's all -- that's it. 2 MR. KING: This document -- 3 MR. GOLDBERGER: Your resp -- Edwards' 4 response. 5 MR. KING: Got it. 6 MS. COLEMAN: This is off the record. 7 (Thereupon, a discussion was had off the 8 record.) 9 A You want me to read through these? 10 BY MR. HADDAD: 11 Q Just look at them and see -- you know, you 12 don't have to read every word of -- word of them, I'm 13 not going to -- if I have one I'm going to ask you 14 something about, I will tell you. I am not here to try 15 to trick you yet. 16 (Thereupon, a discussion was had off the 17 record.) 18 THE VIDEOGRAPHER: The time is 10:36 A.M. We 19 are now coming off the video record. 20 (Thereupon, a discussion was had off the 21 record.) 22 THE VIDEOGRAPHER: The time is 10:40 A.M. We 23 are now back on the video record. 24 BY MR. HADDAD: 25 Q All right. So did you have the ability in the Empire Legal Support. Inc. Page: 132 EFTA01089071 Bradley J. Edwards taken on 10/10/2013 1 last couple of minutes to read through these e-mails, 2 correct? 3 A Yeah. 4 Q Do you recognize them? 5 A Some of them. 6 Q And some of them you do not recognize? 7 A Well, some of them, I'm on the e-mail -- 8 Q Right. 9 A -- some of them I'm not, so I do not recognize 10 the e-mail. 11 Q All right. The ones that you are not on, 12 obviously, you don't know if you've seen them before? 13 A Correct. 14 Q Okay. Do you know whether or not you saw them 15 at the time they were produced? 16 A Definitely not. I don't normally see them. 17 Q Oh, excuse me, produced for discovery. Did 18 you review these before they were produced in response 19 to discovery demand by, who is it, Greenberg? 20 MR. INDYKE: It was Fowler, I believe. 21 A Fowler White maybe. 22 MR. HADDAD: Oh, Fowler White. 23 MR. INDYKE: On demand by Fowler, yes. 24 MR. HADDAD: Yeah. 25 A I re -- I reviewed what I think was 25,000 Empire Legal Support. Inc. Page: 133 EFTA01089072 Bradley J. Edwards taken on 10/10/2013 1 page -- pieces of paper, so I -- at some point in time, 2 I think I have probably seen them. 3 BY MR. HADDAD: 4 Q Well, let -- let me just take one of these and 5 obviously who's Bill -- William J. Berger? 6 A He was an attorney at RRA, formerly a judge in 7 Palm Beach County. 8 Q All right. Who's Pat Carter? 9 A I don't know who Pat Carter is. 10 Q Who's Brad Edwards? 11 A That's me. 12 Q Who's Grace Torres? 13 A I don't know. 14 Q Who's Jackie Johnson? 15 A She was a secretary at -- 16 Q For whom? 17 A RRA. 18 Q Any particular, a floater or whatever they 19 call those? 20 A She was mine for some period of time, a short 21 period of time, and maybe somebody else's, I don't 22 remember. 23 Q All right. And this one I'm looking at, 24 Berger, is Pat -- just checking, it looks like it should 25 go to Brad Edwards -- oh, go to Brad Edwards. Brad, see Empire Legal Support. Inc. Page: 134 EFTA01089073 Bradley J. Edwards taken on 10/10/2013 1 the attached check from Searcy, they should go into 2 trust account, you should keep your own running account 3 of checks in and out. 4 A It is an e-mail from Bill Berger to Pat 5 Carter, who, by this, I would say the e-mail is at RRA, 6 so it is probably his secretary. 7 Q All right. 8 A That is what I would assume. 9 Q Okay. But it's saying it would go to you, 10 Brad Edwards is you, this and any other others like it 11 should go to Brad Edwards. And then it says Brad. So 12 see, it says to Brad Edwards -- 13 A Right. 14 Q -- also. Brad, see attached check from 15 Searcy. 16 A Right. 17 Q They should go into trust account. 18 A Right. 19 Q The trust account that they were going into -- 20 this is dated October 26, 2009. The trust account they 21 are going into, I suppose, is RBA's trust account; would 22 that be correct? 23 A I don't know. 24 Q Well, it's -- they are telling you to put 25 stuff into a trust account. The only trust -- did you Empire Legal Support. Inc.. Page: 135 EFTA01089074 Bradley J. Edwards taken on 10/10/2013 1 have your own separate Brad Edwards PA trust account? 2 A No. No. 3 Q The only trust account you would have had was 4 the RRA trust account, right? 5 A I didn't have an RRA trust account. 6 Q The trust account that was in existence for 7 when you were with RRA would have been the RRA trust 8 account, right? 9 A I don't know, I was never -- 10 Q Well -- 11 A -- part of any trust account. 12 Q Well, if you received a check and it was 13 directed that you should put this into a trust account, 14 where would you put it? 15 A I didn't do any of those things. Here's what 16 happened. All of the law firms, it was myself, Bob 17 Josefsberg, Jack Scarola, and Sid Garcia, Ted Leopold, 18 I'm missing -- Adam Horowitz or Jeff Herman or somebody, 19 everybody agreed or forensic accountants. 20 Q Okay. 21 And sent checks to the firm. I never 22 Q To your firm? 23 A -- asked for the firm. To RRA. 24 Q Yeah. 25 A I never actually saw any of the checks, so the Empire Legal Support. Inc. Page: 136 EFTA01089075 Bradley J. Edwards taken on 10/10/2013 1 checks all came to one place. Somebody took possession 2 of those checks and made sure that it was, you know, all 3 pulled together for this purpose. 4 Q Okay, let me just -- let me 5 A It was not me though. 6 Q That's me. Okay. It says here, they -- these 7 should go into a trust account. That's the direction to 8 you. 9 A I know. 10 Q I'm just asking, you know, I'm just asking 11 what it says, simple English, these should go into the 12 trust account. Did you do anything in response to that 13 ques -- that directive? 14 A No. 15 Q Was he some kind of superior to you, this guy, 16 Berger? 17 A Not necessarily, I mean. 18 Q Well, was he in the litigation division you 19 were in or was he helping run stuff? He is a judge, he 20 probably can't do too much. 21 A He wasn't actually in this office. He worked 22 out of the Boca office. 23 Q Oh, you guys have a Boca office too? 24 A I think it was only him in it. 25 Q Okay. All right. You should keep your own Empire Legal Support. Inc. Page: 137 EFTA01089076 Bradley J. Edwards taken on 10/10/2013 1 running account of all checks in and out, that's a 2 directive to you from Berger. Did you keep a running 3 account of all checks in and out? 4 A No, and I didn't take directions from Berger, 5 so the fact that he is sending me one is totally 6 meaningless to me. 7 Q Did you ever respond to why is this numbered 8 different than the ones I have seen before and what does 9 it mean, why is it there? 10 A I know the answer to that question, but this 11 is -- 12 Q Well, good, then tell me. 13 A -- but this is just him -- this is just 14 evidence that he was kind of oblivious. What everybody 15 agreed to was, let's say that I represented three people 16 and Horowitz represented 10 and Bob Josefsberg 17 represented 20, the amount that you paid for the 18 forensic accountants would be pro rata based on the 19 number of clients that you represent. So if Searcy 20 Denney represented one or two, their amount would be 21 smaller than somebody who represented 10 clients. And 22 so that's what I'm -- that's why I know what Bill is 23 talking about. Why he doesn't know the answer to that 24 just means he is oblivious to how the formula was 25 working with -- amongst the various plaintiff firms that Empire Legal Support. Inc.. Page: 138 EFTA01089077 Bradley J. Edwards taken on 10/10/2013 1 were prosecuting the case against Jeffrey Epstein. 2 Q And all of the money was being put into, 3 without doubt, RRA? 4 A I don't know. I don't know if it was being 5 put into RRA or anything. All of the money came in -- 6 Q All right. Well, let me put it very simply. 7 Let's say that you were working with all these guys, 8 Josefsberg and the rest of these guys 9 A That's true. 10 Q -- trying to come up with $5,000 to pay the 11 forensic accountant. 12 A Yeah. 13 Q It came out of your trust account, correct? 14 A I don't know. 15 Q You don't know? Who manned the trust account, 16 who did all the -- who took all the monies out of that? 17 A I don't know. 18 Q You don't know anything about trust accounts? 19 A I am assuming now what everybody knows, 20 including yourself, is that Scott Rothstein is the only 21 person that ran a trust account. 22 Q All right. 23 MR. HADDAD: I'm so glad you can anticipate 24 everything that I'm going to ask in a few minutes. 25 Sorry. Empire Legal Support. Inc. Page: 139 EFTA01089078 Bradley J. Edwards taken on 10/10/2013 1 BY MR. HADDAD: 2 Q All right. Now, this is on October 26, 2009, 3 this is probably the last days you had trust accounts, 4 so you don't know what what was told to Berger to 5 talk about these trust accounts, correct? 6 A Correct. 7 Q You don't know whether or not he was in 8 contact with Rothstein and whether Rothstein, who was 9 always looking for money was looking for money into the 10 trust accounts? 11 A I have no idea. 12 Q All right. You don't know whether or not 13 Josefsberg, Scarola or Searcy Denney or any of these 14 other lawyers, Herman or any of them had money in the 15 Scott Rothstein RRA trust account that was lost? 16 A I don't -- I don't know, but in -- in -- I do 17 believe that they sent the checks. Now, what happened 18 with the checks and who accumulated the checks and where 19 the checks went to fund the forensic accounting project, 20 to determine what to do from that aspect against Jeffrey 21 Epstein, I really -- I have no idea. 22 Q So the forens -- 23 A I didn't accept the checks, personally. 24 Q All right. The forensic accountants were 25 going to be for what, because you were not in civ -- Empire Legal Support. Inc. Page: 140 EFTA01089079 Bradley J. Edwards taken on 10/10/2013 1 were you in civil litigation, you were trying to plan a 2 depo, I guess, and have forensic account determine the 3 net worth of Epstein? 4 A No, the idea was that it was the cumulative 5 belief of the plaintiff attorneys that Mr. Epstein was, 6 at that point in time, nearly dead in the water as it -- 7 in respect to liability, and that the damages was going 8 to be extraordinary and that his only real defense 9 remaining was probably to use his experience in finances 10 to ship money offshore, hide money. And so the forensic 11 accountants were going to try to determine where he was 12 shipping money and hiding money. 13 Q Through what vehicle? 14 A I don't know. I'm not a 15 Q Well, forensic accountants don't have any 16 ability to get anything unless they are presented 17 documentation and that be would the lawyer's job to 18 present the documentation, what documentation and what 19 method of production, as this was in October of 2009, 20 when you are imploding, were you guys planning on using, 21 do you know? 22 A No, they didn't tell me. 23 Q All right. Did -- 24 A It was only an idea between myself, Jack 25 Scarola and Bob Josefsberg, and here, let's hire Empire Legal Support. Inc. Page: 141 EFTA01089080 Bradley J. Edwards taken on 10/10/2013 1 forensic account and see what they come up with. 2 Q Okay, wait, wait, let me see if I understand 3 this. You are telling me that as you're planning all 4 these things, Scarola was involved in the conversations 5 on how to obtain these things? 6 A Of course. 7 Q Your lawyer? I'm just asking the question -- 8 A All of the lawyers that were prosecuting cases 9 against Jeffrey Epstein, we were all involved in all of 10 these decisions, yes. 11 Q I understand, I just have to make it clear for 12 the record. Josefsberg was involved? 13 A Yeah, of course. 14 Q All right. As as how you are going to do 15 this, right? 16 A Of course. 17 Q And he was your co-counsel and -- with 18 codefendants -- co-plaintiffs, Scarola, as well as 19 Josefsberg and others, correct? 20 A Right. 21 Q And you were pooling your thoughts, your 22 abilities and your monies? 23 A Right. 24 Q To go after these cases? Okay. 25 A Exactly. Empire Legal Support. Inc. Page: 142 EFTA01089081 Bradley J. Edwards taken on 10/10/2013 1 Q All right. Now, Bradley Edward, from Bradley 2 Edwards to Jackie Johnson, October 22nd, 2009, please 3 look at the following schedules, see if you can book a 4 conference room for many to attend as the following 5 group of people for tomorrow, 10 days before, eight 6 days -- well, not -- eight days before you guys fell 7 apart. Please look at the following schedules and see 8 if you can book a conference room for as many -- for as 9 many as can attend from the following group of people 10 for tomorrow: Jenne, Adler, Berger, Stone, Wheeler, 11 Holmes, Bruschel {SIC}, Fi Fiston and Jaffe. Do you 12 know what that's about? Do you know why you were having 13 a conference? Obviously, from the names, it had 14 something to do with Epstein, I would imagine? 15 A Yeah, the subject is Epstein meeting. 16 Q Yeah. Do you know? 17 A We would -- we would frequently have meetings 18 on cases, including this one, to brainstorm about what 19 to do with the various issues that were going on in the 20 case. 21 Q Well, you had no other -- did you have other 22 cases while you were at RRA, besides these? I'm not 23 saying that pejoratively, I mean did you have other 24 cases? 25 A Yeah, of course I did. Empire Legal Support. Inc. Page: 143 EFTA01089082 Bradley J. Edwards taken on 10/10/2013 1 Q All right. 2 A I brought with me many cases. 3 Q I didn't -- okay, I didn't know that. Nobody 4 asked you anything about other cases pretty much, they 5 only asked you about this case. You had other cases you 6 were working on? 7 A Right. 8 Q Did you settle any while you were there? 9 A I don't remember. 10 Q Okay. 11 MR. HADDAD: Yes? 12 MR. GOLDBERGER: I just -- 13 BY MR. HADDAD: 14 Q There was one I wanted to ask you about -- you 15 know, there was one I really wanted to ask you about 16 and, of course, I'm sure I lost it. Okay. Can I have 17 one second since I haven't taken a second? I should 18 have had it dog-eared but-.-.-. 19 When was it that you first met with Josefsberg 20 and -- and Scarola and all those about pooling your 21 resources, was that before you went with RRA? I'm not 22 getting into any conversations you had, I don't want to 23 violate your -- 24 A I don't remember the exact timing. 25 Q -- you are going to assert anyhow so. Empire Legal Support. Inc. Page: 144 EFTA01089083 Bradley J. Edwards taken on 10/10/2013 1 What did -- well, do you recall if you ever 2 met with -- I mean, Josefsberg is easy to remember, did 3 you meet with him? Did you meet with him prior to going 4 with Rothstein? 5 A Yes. 6 Q Okay. And it was about those cases? 7 A It was about those cases. I don't know if it 8 was about the finances aspect. 9 Q All right. No, just about the cases, I am not 10 going to ask you 11 A Oh, yeah, we 12 Q All right. 13 A -- we were meeting as a group once or twice a 14 month from 2008 on. 15 Q All right. 16 A Through the end. 17 Q And excuse my ignorance, but in criminal law, 18 when we do things like that we have what we call joint 19 defense agreements, we share stuff, we share expenses, 20 we make sure no one stabs each other in the back, 21 which -- II cetera. It's not even worth the paper it's 22 written on half the time. Did you have any sort of 23 joint agreement with these lawyers, a shared 24 responsibility agreement, a shared agreement, a written 25 agreement of any kind, without going into anything that Empire Legal Support. Inc.. Page: 145 EFTA01089084 Bradley J. Edwards taken on 10/10/2013 1 it says, I don't want to invade any privilege here, did 2 you have any written agreements with these lawyers? 3 MR. KING: Hold on one second. Let's take a 4 break, discuss privilege. 5 MR. HADDAD: Five minutes, so I can look for 6 what I'm trying to find. 7 MR. KING: Okay, that's fine. 8 MR. HADDAD: I've got the bomb question. Oh, 9 no, I don't, but I'm trying to find one. 10 THE VIDEOGRAPHER: The time is 10:52 A.M. We 11 are now coming off the video record. 12 (Thereupon, a discussion was had off the 13 record.) 14 THE VIDEOGRAPHER: The time is 11:00 A.M. We 15 are now back on the video record. 16 MR. HADDAD: All right. 17 MR. KING: Let me -- 18 MR. HADDAD: Yeah. 19 MR. KING: -- assert an objection as to this 20 line of questioning. If you are going off of it, 21 great, but any further communications or 22 conversations relating to communications that 23 Mr. Edwards had with the other lawyers, there are 24 motions that were pending and may have been 25 granted, I don't know, by at least two lawyers to Empire Legal Support. Inc.. Page: 146 EFTA01089085 Bradley J. Edwards taken on 10/10/2013 1 preclude any disclosure of work product information 2 that they would have a right to assert. And so 3 we're -- in honor of that, of those motions or the 4 order, if it was entered, and I apologize for not 5 knowing that, we would -- we would object to any 6 questions relating to communications that occurred 7 that would fall within a work product doctrine that 8 would be owned by those other lawyers. 9 MR. HADDAD: I -- I -- I don't think that's 10 what I was doing. In fact, I thought I made it 11 specifically clear I am not trying to invade any 12 privilege. I just asked whether or not there was a 13 written -- an agreement among the lawyers, and I 14 don't think that would be privileged. Shared 15 information among the lawyers would not be -- I 16 mean, I'm not going to put you in bad position 17 because not -- you're -- you're not the lawyer that 18 should -- that, like I said, should have been here, 19 but you are not the lawyer that is more familiar 20 with this, so I don't want to put -- my usual 21 expression would be something else, so I will just 22 leave it there and we will take it up with the 23 Judge, okay. 24 MR. KING: Very good. 25 MR. HADDAD: Because I just want to know if Empire Legal Support. Inc.. Page: 147 EFTA01089086 Bradley J. Edwards taken on 10/10/2013 1 there's a written -- like -- just like the lawyers 2 have a -- a -- what do we call that, a joint 3 defense agreement. Whether it's a plaintiff's 4 agreement -- a sharing you can assert -- you 5 objected, I will leave it at that. I don't want 6 to -- as I said, I don't want to cause any -- 7 MR. GOLDBERGER: Just identify the specific 8 question you are asking that Mr. King is telling 9 his client not to answer. 10 MR. HADDAD: Specifically, I already asked 11 him, whether or not there was any specific 12 agreement among the lawyers to share information 13 and share expenses, because we already know they're 14 sharing checks into a pooled account, which -- 15 which already gave us the answer to that when there 16 was a joint agreement about sharing information and 17 work -- and workload and so forth, without ever 18 discussing what -- what their work product was. I 19 mean, the end result was to sue Epstein and get as 20 much money as we can, we know that. But as to any 21 other thing, I just want to know whether they had a 22 formalized agreement saying that we will e-mail 23 each other on some secret e-mail account, or what 24 do you call that thing in the sky that Adler said 25 he invented, Qtask, any of that stuff, that's what Empire Legal Support. Inc. Page: 148 EFTA01089087 Bradley J. Edwards taken on 10/10/2013 1 the question is. I will respect your objection and 2 I think it's a fair objection, particularly since 3 you weren't, you know, the attorney handling all of 4 this and we will take it up at another time. 5 If I can proceed? 6 A Go ahead. 7 BY MR. HADDAD: 8 Q Okay. Thank you. I got this in a list of 9 e-mails and this is from Debra Villegas. I don't have 10 her prison number right now, but it's to Scott 11 Rothstein. At any rate, Ken Jenne advised that we need 12 these documents for depo as early as next week, are you 13 familiar with that e-mail? 14 A No. 15 Q Okay. And you have no idea why Beth would be 16 looking for financial documents, police reports, arrest 17 reports, call logs, all information of a -- a copy of 18 Epstein's counsels' client list, all the rest of that 19 stuff? 20 A You said Beth did what? 21 Q No, it's Debra Villegas to Scott Rothstein, 22 forward inventory, Ken Jenne. Ken Jenne was the guy 23 that was in your meeting that you called with all those 24 guys that I showed you the -- the thing before, 25 remember, Berger wanted to have you, Adler, I think one Empire Legal Support. Inc.. Page: 149 EFTA01089088 Bradley J. Edwards taken on 10/10/2013 1 of those-.-.-. 2 A We are going to mark this, right, so it's 3 accurately -- 4 Q Everything is going to be there, of course. 5 A All right. So there is an e-mail from Lee 6 Caplan, I don't know who that is, to several other 7 people that does not include me. 8 Q Umm-hmm, I am just asking you if you saw it 9 before? 10 A I don't remember ever seeing this but it has a 11 Bates stamp number, which means that we turned it over. 12 So going through 26,000 pieces of paper, I must have 13 seen it at some point in time during this case, well 14 of -- you know, sometime in 2011, I would guess. I 15 don't remember seeing it. 16 Q The date of the e-mail, I'm going to get to it 17 in a minute, but that date of that e-mail is 18 October 30th, the day before Scott got the G5 and left, 19 correct? 20 MS. COLEMAN: You say it well. 21 A October 30th, 2009. 22 BY MR. HADDAD: 23 Q All right. All right, now this one I like, 24 because this is something, like me, Brad Edwards to Ken 25 Jenne, August 19th, 2009, the paperless world really Empire Legal Support. Inc. Page: 150 EFTA01089089 Bradley J. Edwards taken on 10/10/2013 1 scares me in this case. This is about Edwards, isn't 2 it? 3 A That's me. 4 Q There is so much pape -- not Edwards, I -- I'm 5 confusing you guys now, Epstein. There is so much paper 6 and so many motions and dates and times of everything, 7 so important, so many motions, I think we need an 8 organized paper file in this case. That's you talking 9 about Epstein's case, correct? 10 A It sounds like it, yes. 11 Q Okay. And organized paper file would mean 12 like a war room, I think, in fact, you have an e-mail 13 where you asked for a war room. 14 A Right in there. 15 Q Is it in this one? It said war room there? 16 Oh, yeah. I just thought I was -- great memory, sorry. 17 Okay. 18 So on October 19th, Ken Jenne to Epstein. 19 Subject: Epstein. To Ken from Bradley J. Edwards. I 20 know you are aware of the urgency, and Russell and I 21 have discussed the various necessary witnesses in the 22 case and the urgent need to speak them. We have a 23 discovery deadline coming up and four crucial witnesses 24 are in California. And you are talking about Fiston 25 going out there. That's in relation to what coming up, Empire Legal Support. Inc. Page: 151 EFTA01089090 Bradley J. Edwards taken on 10/10/2013 1 discovery deadline in the cases that you had before you 2 settled them, if you -- 3 A Uh, from memory -- 4 Q Yeah, I'm not -- 5 A -- the case was a -- the Jane Doe v. Epstein 6 case was initially set for trial in November of 2009, so 7 I think the discovery deadline was coming up and we had 8 some more witnesses to talk to before that. 9 Q All right. Who's Pat Diaz? 10 A He's an investigator. 11 Q Okay. Let me -- let me -- yeah, this one, 12 probably just because it intrigued me, is from Bill 13 Berger to Edwards, Adler, Jaffe, Weissing, Farmer, 14 May 19th, 2000. It was mostly your partners now. You 15 are invited to attend our three P.M. conference room, 22 16 floor conference room, interview of Amy Swan, a 17 psychologist, who you are considering as a damage expert 18 in Epstein cases. Even if you are not working on the 19 case, if you can attend, I would appreciate your input. 20 What -- what -- what was she, like a child psychologist 21 or something? 22 A Right. 23 Q Is she here in Broward? 24 A I don't remember. 25 Q Okay. Empire Legal Support. Inc. Page: 152 EFTA01089091 Bradley J. Edwards taken on 10/10/2013 1 A Local though, tri-county, I don't remember. 2 Q All right. And that was for purposes of 3 potential witness in your cases if you went to trial, 4 correct? 5 A Correct. 6 Q Okay. And would Edward -- but the rest of 7 your partners were invited, your present partners were 8 invited, do you know why they were invited? 9 A No. 10 Q Okay. Did they actually have work on-.-.-. 11 A Not at all. 12 Q Okay. 13 A I will finish the question first. Work on 14 Epstein's case 15 Q That's okay, we both know what we are talking 16 about. 17 How come you turned over Scott's schedule for 18 the July 26 call from Governor Barbour, lunch with David 19 Shope, Alonzo Mourning charity breakfast? 20 A I didn't have access to my e-mails. These 21 e-mails were turned over to me by the trustees. 22 Q Okay. 23 A When they were turned over to me, I turned 24 them over to you. 25 Q And let me ask, Epstein conference 3:30, Brad Empire Legal Support. Inc. Page: 153 EFTA01089092 Bradley J. Edwards taken on 10/10/2013 1 Edwards, Steve Jaffe, Ken Jenne. 2 A Until these were turned over to me by the 3 trustee, I had never seen them before. 4 Q Oh, so you don't know, okay. 5 A I have no idea. 6 Q I guess Scott's not on the charity board for 7 Alonzo Mourning anymore? 8 A I would hope not. 9 Q Did you get to go to Mo's Dinner Event at The 10 Palms Grill? 11 A Did not. 12 Q Do you know who Mo is? 13 A Do not. 14 Q The cigar guy, that gave all the cigars for 15 all the charities? 16 A No. 17 Q Okay. Do you know who Micki Cummings is that 18 he was interviewing for the second time? 19 A No. 20 Q The divorce lawyer who tried to become a 21 judge? 22 A Michele Cummings? 23 Q You don't keep up with divorce lawyers? 24 A I try not to. I know you do. 25 Q That's for sure. Nice. Touché. Empire Legal Support. Inc. Page: 154 EFTA01089093 Bradley J. Edwards taken on 10/10/2013 1 I assu -- is this one on your Web site or is 2 this just here, "Florida Lawyer Ruffles Feathers in High 3 Society With His Pesky Subpoenas," did you post that 4 one? 5 A I don't think so. 6 Q You should, it's a pretty good article for 7 you. Okay -- 8 A Send it to me again and I will post it. 9 Q All right. I -- I think -- I don't know if I 10 have any more of these on these e-mails, but -- but at 11 some point or another, these all -- were either 12 recognized by you, came -- or were produced by you, 13 correct? 14 A They came to me by -- from the trustee, 15 sometime -- 16 Q Yeah. 17 A -- in 2011 and then I forwarded them on to you 18 guys. 19 Q All right. 20 Were you deposed at all in any clawbacks or 21 anything? 22 A No. 23 Q Okay. 24 A This is my third deposition in this case and 25 that's it. Empire Legal Support. Inc. Page: 155 EFTA01089094 Bradley J. Edwards taken on 10/10/2013 1 Q Well, I understand that. I don't understand 2 how you get to take more than one deposition because you 3 don't in criminal, but we are doing it. Maybe I can 4 invite you back again in a few months. 5 A I'm hoping for today to be the last time that 6 we are meeting under this circumstance. 7 Q I'm enjoying it so much. 8 A I know. 9 Q Just so long as you're -- I have never taken a 10 deposition this long in a first-degree murder. Of 11 course, this is much more serious. 12 Let me ask you, this is a document 13 MR. HADDAD: Yeah, you got to mark all of 14 those, I guess. Do we have copies? 15 MR. GOLDBERGER: Do you want to sanitize this 16 and make sure it's all good? 17 MR. HADDAD: Go ahead, you going to take my 18 dog-ears off, I need them -- yeah, whatever. 19 MR. GOLDBERGER: That's Exhibit 2. 20 MS. COLEMAN: Quarter-million-dollar education 21 and I am -- 22 MR. HADDAD: Do you want -- did you want a 23 copy, Bill, did you a copy right here? 24 MS. COLEMAN: No, this is 2 because 1 is 25 the -- Empire Legal Support. Inc. Page: 156 EFTA01089095 Bradley J. Edwards taken on 10/10/2013 1 MR. HADDAD: Do want us to make a copy of the 2 ones that we saved or -- okay, I didn't know if you 3 needed extra. 4 MR. KING: I just want to have -- I assume 5 that you are going to mark that entire package. 6 MR. GOLDBERGER: Composite exhibit. 7 MR. HADDAD: Is that what they call those? 8 BY MR. HADDAD: 9 Q All right. I guess in response to a recent -- 10 I think it's recent, after objections and all that other 11 stuff, you produced your time records? 12 A Okay. 13 Q Could you say yes or no. Okay means okay, did 14 I, I don't know, maybe somebody else produced them. I 15 need a yes or no so I can -- and I am not trying to be a 16 jerk. 17 A I produced them based on my attorney telling 18 me to produce them. 19 Q Well, I understand that, but okay doesn't 20 answer that. You can -- you get into court, you are a 21 smart lawyer, okay means who came from, you know that. 22 You were a prosecutor, you knew what to do. 23 Is this -- this what you produced? 24 What time is it, almost lunchtime? 25 (Thereupon, a discussion was had off the Empire Legal Support. Inc. Page: 157 EFTA01089096 Bradley J. Edwards taken on 10/10/2013 1 record.) 2 THE WITNESS: Do you know if these Bate stamps 3 were put there by me or by you? 4 MS. COLEMAN: They are by you. 5 THE WITNESS: By me? 6 MR. HADDAD: How would I know, I don't know 7 how -- I don't have a Bates stamp machine. 8 A Then, yes. Then, yes. 9 BY MR. HADDAD: 10 Q I don't think you need these. Thanks. 11 A These appear to be my time records from this 12 case. 13 Q And when this Edwards versus Epstein, when 14 these time records, just so at least I'm somewhat clear, 15 is this the time for the Epstein loss, not not the 16 claims that were occasioned by your -- 17 A Right. 18 Q -- plaintiff's cases, this is solely involved 19 in this litigation that we're presently taking your 20 deposition for? 21 A Only for the defense of the lawsuit that 22 Epstein filed against me and it should end at the time 23 when that lawsuit was dismissed against me. 24 Q Which would have been August 20th, 2012? 25 A And I kept only those time records. Empire Legal Support. Inc.. Page: 158 EFTA01089097 Bradley J. Edwards taken on 10/10/2013 1 Q Okay. 2 If -- do you remember approximately when you 3 were served with the complaint? 4 A 2009. 5 Q I understand that. I see here channel -- 6 channel -- December 7th, rather prophetic, 2009, you 7 were with hit with the initial complaint, correct? 8 It -- it say here you -- initial complaint, review and 9 research. 10 A Then that sounds accurate to me. 11 Q Okay. And did you retain -- did you -- you 12 didn't know it was coming, obviously? 13 A Right. 14 Q You were only involved at that time in the 15 Jane Doe, let me just call them Jane Doe, whatever you 16 want to call them, II ■, II, whatever you call them, 17 civil suits and it's GVRA? 18 A CVRA. 19 Q CVRA stuff, correct? 20 A As it related to Jeff Epstein. 21 Q Right. So that when you -- when got sued, 22 this was a blanket new civil litigation that you were 23 getting involved in. 24 A That's correct. 25 Q And that's before the counterclaim and all Empire Legal Support. Inc. Page: 159 EFTA01089098 Bradley J. Edwards taken on 10/10/2013 1 that, this was just a brand my new piece of civil 2 litigation 3 A Right. 4 Q where you got sued? Okay, and the first 5 complaint for a number of comps. 6 A Right. 7 Q Correct? 8 All right. When was it that you -- what 9 approximate date did you hire Mr. Scarola? 10 A I don't remember. 11 Q Approximately. The day you got served? I 12 mean, you were already friends with him, I guess. 13 A Right. Um, I -- I can say with pretty good 14 certainty that it was before the end of that year 2009. 15 Q Okay. Because I'm I am seeing here -- 16 A Sometime in the month of December, I think. 17 Q All right. Because you got 12/7/2009, initial 18 complaint, review and research, 8.1 hours. What did he 19 send you, War and Peace? 20 A Basically. 21 Q Oh, okay. Exhibit 2, seven point sev 22 what's .7 hours translate to, I don't I don't -- 23 A 42 minutes. 24 Q Okay. All right. 12/10, let -- letter 25 confirming registration. What would that mean? What Empire Legal Support. Inc. Page: 160 EFTA01089099 Bradley J. Edwards taken on 10/10/2013 1 would a letter confirming regist -- representation 2 that -- that -- that you're confirming that 3 what's-his-name is going to represent you, Scarola, or 4 you are sending him a letter, this is to confirm our 5 conversation today that you will represent me? 6 A It was -- it was time for our discussion and 7 then him sending me a letter confirming that he was 8 going to represent me, so that means that I must have 9 retained Scarola within three days, actually, of file 10 filing the complaint. 11 Q Okay. So a letter -- it just says letter 12 confirming representation, 30 minutes? 13 A Well, that would have included the 14 conversation as well -- 15 Q I see, I am just asking. That's -- 16 A -- that went into that letter. 17 Q I know that you guys know how to bill. Us 18 poor guys have to work, we don't work by the hour so 19 we -- 20 A Just told me a story about billing $75,000 for 21 a traffic ticket. 22 Q That wasn't a bill, that was a retainer. I 23 don't have -- I don't have that stuff. I would never do 24 that hourly work. Eight hours -- okay, so did you ever 25 add up with what the hours are in this thing Empire Legal Support. Inc. Page: 161 EFTA01089100 Bradley J. Edwards taken on 10/10/2013 1 approximately, I'm sure you must? 2 A Probably a thousand hours, I don't know. I 3 mean, it was a ridiculous amount of time. 4 Q Yeah, letter to Mr. Akerman -- 5 A And a lot of that time was a consequence of 6 being dumped 26,000 e-mails on me, so, but, yes, I think 7 that there is a total somewhere. 8 Q All right. I don't have it here. 9 A Okay. 10 MS. COLEMAN: It's on the last page at the 11 bottom. 12 MR. HADDAD: It's on the last page? 13 MS. COLEMAN: Yeah. 14 MR. HADDAD: Oh, total time 1,351 hours .8? 15 THE WITNESS: I was pretty close. 16 MR. HADDAD: Anybody got a calculator? Just 17 for my edification, can somebody divide that by 40. 18 Do you have a -- I don't -- 19 MR. GOLDBERGER: Yeah, I can do that for you, 20 Fred. 21 MR. HADDAD: Thanks. Just out of curiosity. 22 I'm not -- I was going to go through this page by 23 page with you so we could spend some quality time 24 together. 25 THE WITNESS: That would be so much fun, Fred. Empire Legal Support. Inc. Page: 162 EFTA01089101 Bradley J. Edwards taken on 10/10/2013 1 MR. HADDAD: Huh? 2 THE WITNESS: That would be so much fun. 3 (Thereupon, a discussion was had off the 4 record.) 5 MR. HADDAD: So a couple months a year. 6 MR. GOLDBERGER: No. 7 BY MR. HADDAD: 8 Q Letter from Nurik re depo of Rothstein. What 9 would that have to do with this case? Just -- just -- I 10 am just trying to figure out why that would have 11 something to do with this case. 12 A What? 13 Q It says here, you know, 35 minutes, Marc Nurik 14 couldn't write a letter that lasted 35 minutes. A 15 letter from Nurik re depo of Rothstein. He was in my 16 office. He is not able to write that well. 17 A So -- 18 Q Well, how did you -- what does that have to do 19 with this case? I mean just -- just looking through -- 20 A Out of context, that's a tough question for me 21 to answer. But I know that in your recent pleadings, 22 you have discussed certain things that Scott Rothstein 23 testified to in other cases that included me, and so I 24 would have read those portions of that deposition and 25 that's what I am presuming that that is. Empire Legal Support. Inc. Page: 163 EFTA01089102 Bradley J. Edwards taken on 10/10/2013 1 Q Whoa, whoa, whoa, whoa. The pleadings that 2 they -- you have not -- this is -- this is within a few 3 months of the initial complaint and -- and -- and I 4 don't want to be real argumentative with you, because 5 there is no jury here, but it says here, 4/14/2010, 6 letter from Nurik, re depo of Rothstein. The depo of 7 Rothstein wasn't for another three months. Why would 8 you bill Epstein -- what's four-tenths, is what, 9 25 minutes? 10 MS. COLEMAN: Umm-hmm. 11 BY MR. HADDAD: 12 Q 25 minutes to read a letter from Nurik. Dear 13 Brad, I'm going to be taking the deposition of 14 Rothstein, do you have any input, is about the most that 15 Nurik could get out of a sentence. 16 A I don't -- I don't think that that's what that 17 means though. 18 Q Okay, well what -- you are the one who wrote 19 it. 20 A We would have to look at the docket of this 21 particular -- 22 Q Okay. 23 A -- case to see what was going on -- 24 Q So -- so we -- 25 A -- in this particular case. Empire Legal Support. Inc. Page: 164 EFTA01089103 Bradley J. Edwards taken on 10/10/2013 1 Q All right. So we can assume then that 2 everything on here is not necessarily accurate and to be 3 taken as it's written here because you don't even know 4 what this means? 5 A Out of context, I don't know what every single 6 entry -- 7 Q Well, I didn't -- I didn't write it, you are 8 the one who put the context there, Brad, correct? 9 A From 2010? 10 Q Oh, okay. I'm just asking, I'm just asking. 11 A There are certain things you could give me to 12 refresh my recollection, so I could give you an accurate 13 accounting. 14 Q Edward -- Edward's motion 57.105, somebody 15 screwed up and you want attorney's fees. I learned that 16 one one time. 4/15/2010. For an hour and a half, an 17 hour and something minutes to write a 457.101 motion? 18 You have been a -- you have been a lawyer for 15 years, 19 how did -- how did it take you that long? 20 A Well, I have to read what is the basis for the 21 motion. 22 Q So we don't know? So we would have to get all 23 of this correspondence to find out the accuracy of what 24 you are saying? 25 A You would probably just have to give me the Empire Legal Support. Inc. Page: 165 EFTA01089104 Bradley J. Edwards taken on 10/10/2013 1 docket so that I could tell you, based on what was going 2 on in the case right now, what -- what exactly each 3 entry had entailed. 4 Q Prep -- preparation of deposition of Michael 5 Fiston. What -- what did Michael Fiston have to do with 6 this case for a deposition in 2010? 7 A You are the one who set him for deposition. 8 Not you, but it was one of Epstein's 20 attorneys, so 9 you would have to tell me that. 10 Q He only had 13 at the time. 11 A I think it was attorney No. 12 served him for 12 depo. 13 Q All right. So you are saying you prepped the 14 depo. You had a lawyer though too, didn't you? 15 A What's your question? 16 Q Did you have a -- well, this deposition, you 17 have 1.1 hours here and another .7 hours here -- 18 A Right. 19 Q -- for the deposition of Michael Fiston at -- 20 on Third Avenue. 21 MR. HADDAD: Could you guys stop talking, I 22 can hear you, it's my only good ear, for one 23 second. 24 BY MR. HADDAD: 25 Q Did you have Scarola represent you at the Empire Legal Support. Inc. Page: 166 EFTA01089105 Bradley J. Edwards taken on 10/10/2013 1 time? 2 A Scarola did represent me at the time. 3 MR. GOLDBERGER: He did. 4 MR. HADDAD: Okay. 5 BY MR. HADDAD: 6 Q And Scarola attended this deposition? 7 A It was never taken, it was canceled. 8 Q Okay. Did you meet with Scarola for the 9 deposition, no discussions you -- between you and 10 Scarola, did you prepare him notes, did you do 11 something, send them to him? 12 A I met with Mike Fiston. 13 Q Okay. So you prepared the witness for the 14 deposition? 15 A I talked to the witness about the deposition, 16 yes, prepared him for the deposition, yes. 17 Q For one point -- for almost two hours? 18 A No, for 1.1 hour. 19 Q 1.1 and .07? 20 A But that's a different deposition. 21 Q Oh, Fendi, I'm sorry, I can't read. 22 Okay. So you prepped two people for 23 depositions that day? 24 A Right. 25 Q Okay. To be taken by one of Epstein's Empire Legal Support. Inc. Page: 167 EFTA01089106 Bradley J. Edwards taken on 10/10/2013 1 multiple lawyers and to be attended by your lawyer? 2 A Right. 3 Q Okay. So you are acting as an adjunct to the 4 law firm but you won't tell me whether you already had a 5 cooperation agreement with when they were prepping 6 depositions -- 7 MR. HADDAD: Well, change it now. You want to 8 do that? 9 THE VIDEOGRAPHER: The time is 11:22 A.M. We 10 are now coming off the video record. This is the 11 end of Tape No. 1. 12 (Thereupon, a discussion was had off the 13 record.) 14 THE VIDEOGRAPHER: So the time is 11:23 A.M. 15 We now back on the video record. This is the start 16 of Tape No. 2. 17 BY MR. HADDAD: 18 Q Could -- could you explain to me -- and I'm 19 sorry, maybe it's your shorthand, 5/5/2010, not 20 attending, notice of hearing, motion to enlarge time to 21 respond to discovery. Two-tenths is what, 12 minutes? 22 A Right. 23 Q What does that mean, not attending, notice of 24 hearing, you got to read the -- it took 12 minutes to 25 read a notice of hearing? Empire Legal Support. Inc.. Page: 168 EFTA01089107 Bradley J. Edwards taken on 10/10/2013 1 A And then communicate with my attorney about 2 whether or not I was attending that particular hearing. 3 Q What do you have a translator to take 4 10 minutes to say, I'm not going to be attending? I'm 5 just blowing smoke up your butt. 6 A Okay. No. 7 Q All right. I'm sorry for the sarcasm, it's 8 just just sitting so close to you brings it out in 9 me. 10 A You are like an insurance company going 11 through the bills. 12 Q All right. And -- oh, this I could see taking 13 10 minutes, notice of appearance, Goldberger for 14 Epstein, probably took 10 minutes to understand the 15 notice of appearance, Hi, I'm Jack Goldberger, I'm 16 filing an appearance. Okay. Let me see if anything 17 else stands out. 18 All right. But at any rate, this is pretty 19 much continuing. When you have Internet, internal 20 e-mail with attorneys on 2/15/11, there's four or five 21 of them, what would that mean, but I don't want to get 22 into what you talked about, who you talked about, but 23 what would Internet e-mail -- 24 A Let's say I e-mail my partners, they send an 25 e-mail back, then we have an e-mail discussion as to Empire Legal Support. Inc. Page: 169 EFTA01089108 Bradley J. Edwards taken on 10/10/2013 1 some certain issue. That's basically what that is. 2 Q But we don't know what part of this case it 3 might be related to, correct? 4 A Based on that, we don't. 5 Q All right. And correspondence with counsel 6 would be letters -- eight letters to Scarola on two -- 7 A Or e-mails. 8 Q Well, you have internal e-mail and 9 correspondence. Correspondence would mean a regular 10 e-mail -- 11 A It could be. 12 Q -- as opposed to an internal e-mail? 13 A All right. I'm not that technical myself 14 15 Q Okay. Review correspondence from Carney and 16 letter to Mr. Akerman from J. Carney. Are you talking 17 about Rob Carney? 18 A Right. 19 Q Okay. And oh, he was a general mast 20 appointed a master or something in this case? 21 A I don't really remember what his role was, 22 but -- 23 Q Okay. 24 A -- something along those lines. 25 Q 2/16/2011, hearing re privilege log at Jack Empire Legal Support. Inc. Page: 170 EFTA01089109 Bradley J. Edwards taken on 10/10/2013 1 Scarola's office, West Palm Beach with Judge Carney, 2 6.1 hours. Would that be your atten 3 A Probably longer than that, but yes. 4 Q Okay. That would be your attendance there? 5 A Right. 6 Q Did you participate in that at all or -- 7 A Yes. 8 Q -- did Carn -- did Scarola do it? 9 A We all did. 10 Q What do you mean, we all did, what did you do 11 at that hearing, Scarola let you talk and argue? 12 A Yes. 13 Q Okay. All right. 14 A And I think everybody had some input as to 15 what the process was going to be. It was a complicated 16 process related to e-mails. 17 Q 2/17/2011, 4.1 hours, Edwards hearing on 18 Edwards motion to compel Judge Crow, 4.1 hours. 19 A It takes three hours just to get back and 20 forth, so yes, I mean -- 21 Q Well, I'm just asking what this is. So you 22 are charging for your time. Did you testify at it? 23 A I don't remember. 24 Q All right. Motion to compel are generally not 25 testimony, it's usually a hearing, correct? Empire Legal Support. Inc. Page: 171 EFTA01089110 Bradley J. Edwards taken on 10/10/2013 1 A I don't remember what my role was at that 2 particular hearing. 3 Q Well, you were co-counsel for all of this 4 crap, right? 5 A Yeah. Yeah. 6 Q For all of this stuff? 7 A Yeah. 8 Q Okay. And you were billing for all of your 9 time as well as the time, whether it was duplicated by 10 Mr. Scarola or not, correct? 11 A I don't have Mr. Scarola's bills, so I was 12 billing for all of my time. 13 Q Okay. Well, I mean, if Jack called you up and 14 said, hey, Brad, what about this or that, it was 15 discussing the case, you would bill for it? 16 A Right. 17 MR. HADDAD: What? Excuse me, yes. 18 MR. GOLDBERGER: Is this the good ear? 19 MR. HADDAD: Yes. 20 (Thereupon, a discussion was had off the 21 record.) 22 BY MR. HADDAD: 23 Q Okay. I'm ending with this so we're going 24 to -- you know, it's getting close to lunchtime. I 25 don't know, if there is something more important, I will Empire Legal Support. Inc. Page: 172 EFTA01089111 Bradley J. Edwards taken on 10/10/2013 1 have to wait for it. I -- I like -- you are unable to 2 give any of these details, but on 10/15/2011, the detail 3 of your 9 hours spent reviewing transcripts is 4 incredible. Was that for shock benefit or was that just 5 something that you managed to completely -- 6 A This was internally in my office so if it was 7 for shock benefit, to benefit to shock myself? I 8 mean, this is -- 9 Q I don't know, you probably knew you were going 10 to have to produce this some day. 11 A I didn't. 12 Q Brad. 13 A I thought that would have to produce hours 14 but the details, I didn't. 15 Q All right, 9 hours to review transcripts for 16 whom? 17 A For, it says, lies told by Epstein -- 18 Q I know what it was for there. I am saying for 19 whom, for whose benefit? If you have a lawyer, are you 20 being deposed, is that what it was for, do you remember 21 what it was for where you spent 9 hours looking at 22 something? 23 A When was my first deposition? No, it was 24 after that. It wasn't about my deposition. 25 Q Okay. Do you know what it was for? Empire Legal Support. Inc. Page: 173 EFTA01089112 Bradley J. Edwards taken on 10/10/2013 1 A Yes. I mean, it -- 2 Q I know what you did. I mean, I know what you 3 said. 4 A Well, it seems like the amended counterclaim 5 was the next day, so it was for whatever input -- 6 Q Your -- your counterclaim -- 7 A -- that related to that malicious prosecution. 8 Q -- your what was your ammend I'm sorry. 9 MR. KING: Hold on, hold on a second. 10 MR. HADDAD: I -- I apologize, Mr. King, we 11 were cutting each other off. 12 Go ahead Mr. Scaro -- Edwards. 13 A A malicious counterclaim -- or the count that 14 Epstein filed against me, I was reviewing all of those 15 things in preparation for our amended counterclaim, 16 which was a count for malicious prosecution. 17 BY MR. HADDAD: 18 Q All right. Let me ask you this. I understand 19 that. And it was drafted by Mr. Scarola, correct, or 20 did you do the drafting of the documents and he signed 21 them? 22 A It's been different on different pleadings. 23 Q All right. I mean -- 24 A For that one, I -- I don't really remember. 25 Q So would it be fair to say that you, at times, Empire Legal Support. Inc. Page: 174 EFTA01089113 Bradley J. Edwards taken on 10/10/2013 1 would prepare pleadings, send them to Scarola and he 2 would sign them? 3 A Fair. 4 Q Pardon? 5 A That's fair. 6 Q All right. Now, on 10/18, after you've 7 already filed your -- or prepared your amended 8 counterclaim, which took an hour, your motion for 57 0 9 105 attorney fees, you should have those rote, don't you 10 have those you send out with everything, they are all 11 the same? I mean, you just have to hit a button and say 12 print, no? 13 A Is that how it works in your office? 14 Q I don't -- we don't do civil. I only do them 15 once every once in a great while. The last one I 16 had, we just mediated out with Judge Crow. 17 Review depositions again, all pleadings, all 18 offers and pending motions in preparation for conference 19 with counsel regarding strategy for defense and also in 20 preparation for prosecution of counterclaim, 11 hours, 21 which is a little over a day. 22 You've been a -- well, let -- let -- let me 23 just ask you. What all offers were you having that you 24 had to review, what offers were there? 25 A It would have been all offers that Mr. Epstein Empire Legal Support. Inc. Page: 175 EFTA01089114 Bradley J. Edwards taken on 10/10/2013 1 had ever made to the girls. 2 Q What did that have to do with your 3 counterclaim? 4 A Okay. 5 Q Just educate me. 6 A I'm going to try -- 7 Q -- because I have to get this case. 8 A I'm going to try. 9 Q Thanks a lot. 10 A So Mr. Epstein files a complaint against me 11 alleging that I am a fraud and I am part of some RICO 12 enterprise, and the basis for his claims were that I 13 conducted discovery that could not have possibly been 14 relevant to any legitimate claims I was prosecuting, 15 such as, I took depositions of pilots, I included that 16 one of the girls gave him oral sex when it was actually 17 different underage girls that gave him oral sex, and so 18 forth and so on. 19 Q Okay. 20 A So I reviewed those things to make sure that I 21 have all of the, what I'll call lies, in order that 22 would support the basis of my malicious prosecution 23 claim and prove that since he drafted and -- and made 24 allegations that he knew to be false, that is the proof 25 that there was no good faith basis, and the proof that Empire Legal Support. Inc. Page: 176 EFTA01089115 Bradley J. Edwards taken on 10/10/2013 1 it was done with malice and with an intent to extort me. 2 Q But you remember -- you already you had 3 already filed your amended counterclaim. 4 A Okay. 5 Q So that's post. So you filed a pleading then 6 you look for the proof? 7 A I filed the pleading. 8 Q Yeah. 9 A And then it says: In preparation for a 10 conference with counsel regarding strategy for defense. 11 Q Yeah. Oh, okay. Two days of -- one day after 12 the counterclaim is filed. Okay. 13 A Is there a problem with that timing, I -- I 14 just don't understand? 15 Q Well, we will find that out later. 16 Uh, what's page -- what's Scarola re Facebook, 17 did you become friends and you are charging for that, 18 hit the friend button? 19 A No, I think there was a -- a letter from 20 Mr. Scarola about -- about social media. 21 Q Regarding Edwards or regarding you guys? 22 A I think that that would violate the 23 attorney-client privilege. 24 Q Oh, okay. Well, not if it's social, if it's 25 you and he becoming Facebook friends. Empire Legal Support. Inc. Page: 177 EFTA01089116 Bradley J. Edwards taken on 10/10/2013 1 A It's not that. 2 Q Are you Facebook friends with him? 3 A No. 4 Q Do you go on Facebook? 5 A No. 6 Q Okay. Are you getting hot? 7 A No. 8 Q I should say mad, that doesn't come out too 9 good. 10 A I do have -- I do have a Facebook account but 11 I don't go on Facebook. 12 Q All right. I could look through this all day. 13 I had some others that stood out but I'm -- wait for 14 later. All right. Let me just have a minute. 15 MR. HADDAD: Do you want to talk, do you got 16 something? Go ahead. 17 MR. GOLDBERGER: Anything constructive? 18 MR. HADDAD: Yeah, I mean, let me see. I'm 19 sorry, I have got to go to my mentor's now. 20 What? 21 MS. COLEMAN: Well, i wanted to know why he 22 talked about Epstein hiring me for an hour and a 23 half, that's my favorite part of the time sheet. 24 (Whispering) 25 MR. HADDAD: Oh, I know that. Okay. I didn't Empire Legal Support. Inc.. Page: 178 EFTA01089117 Bradley J. Edwards taken on 10/10/2013 1 see if there was anything else there. 2 BY MR. HADDAD: 3 Q This all -- all of this preparation, this 4 document, why did you talk for an hour and a half about 5 hiring Tonja? Well, you did charge an hour and a half 6 for that. 7 A I probably talked longer than that about that 8 fact. 9 Q Oh, did that upset you? 10 A Yeah. 11 Q Okay. 12 A I told her that, she knows it upset me. 13 MS. COLEMAN: We worked it out. You had to 14 know. 15 MR. HADDAD: Huh? 16 BY MR. HADDAD: 17 Q All right. What did you use to prepare this? 18 I mean, do you have just a running computer table? 19 A No, I would just write it out -- 20 Q Yeah, I know that. 21 A -- I would give it to the secretary, somebody 22 would type it in. 23 Q What do you, you bill like a lot of lawyers, 24 you look at the clock and say, okay? I don't have 25 billing sheets, I have never billed a time in my life so Empire Legal Support. Inc. Page: 179 EFTA01089118 Bradley J. Edwards taken on 10/10/2013 1 I don't know how you do it. 2 A I grab a piece of paper, I look at the clock 3 on the computer, finish doing what I'm doing with it, 4 write review correspondence point whatever that is 5 closest to a sixth and pass the piece of paper on. 6 Q Let me ask you this. To -- to -- and if you 7 delineated what you actually did during this time, I 8 suppose it would take as much time to write what you did 9 as it is to do what you did. So there must be -- do you 10 have any kind of like on a computer where you can hit on 11 a pro -- do you -- do you have a billing program? They 12 do make billing programs where you have certain codes 13 where can you hit like No. 1, talked to client, No. 4? 14 A We do. 15 Q Make up a couple hours? 16 A We -- we have one. We have a billing program. 17 Q All right. And -- 18 A I can't say that the attorneys are all that 19 familiar with it. But, you know, the entries are done 20 by the staff. 21 Q You are. 22 A I write it on -- I write it by hand. I still 23 know how to do things. 24 Q Yeah, do you still have those notes? 25 A No. I write it, it gets entered -- Empire Legal Support. Inc. Page: 180 EFTA01089119 Bradley J. Edwards taken on 10/10/2013 1 Q Were you a policeman at one time, get rid of 2 the rough notes? 3 A No. I would have paper to the ceiling if I 4 kept all those notes. 5 Q All right. I think that's where we ended off 6 the last depo and I'm -- I don't even want to go into 7 I'm not going to bother you with it. Um -- 8 A Go ahead, bother me, I want this to be my last 9 time being bothered. 10 Q You're not I'm -- I'm not bringing you back 11 unless you get arrested, then you will have to hire me, 12 but I would have a conflict. 13 A You are going to admit a conflict, I doubt 14 that. 15 Q Me, never. If I get paid, there could be a 16 conflict. 17 A I understand that rule very well. 18 MR. HADDAD: That's criminal law rule No. 1. 19 Right, Jack? 20 MR. GOLDBERGER: Um-hmm. 21 BY MR. HADDAD: 22 Q Okay. Let me see if there is anything else. 23 Q Okay. We went -- anything change on your 24 damages? I -- where were we with damages, I just 25 remember, that just came to me because -- Empire Legal Support. Inc. Page: 181 EFTA01089120 Bradley J. Edwards taken on 10/10/2013 1 A We discussed it. 2 Q Yeah, I know, we discussed it before -- 3 A Has anything change -- 4 Q -- total time lost, time -- 5 A -- since the last time until now? 6 Q Yeah, I mean, have you gotten any more awards 7 or anything? 8 A Not that I remember. 9 Q You haven't been speaking at any more places? 10 You get asked to speak a lot now, don't you? 11 A Right. Yeah. 12 Q You are getting more and more famous all the 13 time. What? 14 A Is that a question? 15 Q No, I'm just asking, I mean, your practice is 16 growing, how many people you got in your office now? 17 A Seven attorneys. 18 Q Okay. How many support staff and everything? 19 A Around 10, maybe a little more. 20 Q Okay. You are updated still on Best Lawyers 21 and all that other stuff? 22 A I learned that from you. 23 Q Not from me. 24 A I think so. 25 Q You -- okay, you still getting all of those Empire Legal Support. Inc. Page: 182 EFTA01089121 Bradley J. Edwards taken on 10/10/2013 1 other things that you don't have to pay for, they really 2 think you are okay? 3 A I think so. 4 Q Okay. Let me ask you, how many cases do you 5 carry? 6 A I usually try to stay around the 40-case mark. 7 Q Okay. And that's 40 intentional 8 A All litigation. 9 Q -- 40 tort cases? 10 A Right. 11 Q You don't do anything else, right? 12 A That's it. 13 Q I don't mean that pejoratively, but you are 14 tort lawyer. 15 A Basically. I mean, I do -- 16 Q Okay. 17 A -- I do have some commercial cases but they 18 usually involve some form of criminal act where I am 19 representing somebody that I perceive to be a crime 20 victim in the case. 21 Q Okay. 22 MR. HADDAD: Anybody got anything? 23 A Well, I know that you have a pending motion 24 about certain objections to work product privilege that 25 were stated in the first deposition -- Empire Legal Support. Inc. Page: 183 EFTA01089122 Bradley J. Edwards taken on 10/10/2013 1 BY MR. HADDAD: 2 Q Yeah. 3 A -- and since, those cases are no longer being 4 litigated. And to the extent that I have injected 5 certain things into this litigation to prove why I did 6 certain things during discover, I'll answer whatever 7 questions you have in that regard. 8 Q I didn't even look at it. 9 MS. COLEMAN: I didn't either. 10 A I just want to make sure this is the last time 11 I'm coming back, so I saw your motion, I'm here until 12 we're not here. 13 MS. COLEMAN: Can we go off the record for 14 minute? 15 MR. HADDAD: No, leave it on the record. If 16 he is going to withdraw his objection, I am not 17 I am not prepared to proceed on that anyhow. 18 MS. COLEMAN: Yeah, we don't have it with us. 19 MR. HADDAD: I don't even have -- I don't even 20 have the prior deposition. 21 MR. GOLDBERGER: Well, let's get on the record 22 that he is withdrawing them so that we don't have 23 to -- 24 MR. HADDAD: Well, yeah. I mean, if you are 25 withdrawing everything, we don't even have to go Empire Legal Support. Inc. Page: 184 EFTA01089123 Bradley J. Edwards taken on 10/10/2013 1 forward with a hearing, we just see where it is, 2 you can ask him in trial or see where we go from 3 there. I'm -- 4 MR. GOLDBERGER: No, no, I think we want to 5 redepose on it but-.-.-. 6 MR. HADDAD: Well, I don't -- no, let's -- 7 MR. KING: Hold -- hold on a second, hold on a 8 second. That's -- that is not appropriate. He's 9 here, this is his third time. He is prepared to 10 answer questions -- 11 MR. HADDAD: Fine, so take a -- let's take a 12 lunch break and I'll come back after lunch and -- 13 MR. KING: We'll get the documents. 14 MR. HADDAD: -- we'll go. See you at one 15 o'clock, 1:30. Is that good? 16 MR. GOLDBERGER: Yeah, one -- how about 1:15, 17 can we do 1:15? It's a quarter of 12. 18 MR. HADDAD: Well, I -- I would like to take 19 my time. 20 MR. KING: Okay. 21 MR. HADDAD: Who took the first -- who took 22 the last depo, Chritton? Who took the depo we 23 invoked on, Chritton? 24 MS. COLEMAN: The first one, yeah. 25 MR. HADDAD: That was 200 pages -- well, there Empire Legal Support. Inc.. Page: 185 EFTA01089124 Bradley J. Edwards taken on 10/10/2013 1 was only 12 questions asked. The rest of it was 2 Scarola objecting to everything. 3 MS. COLEMAN: Can we go off the record? 4 MR. GOLDBERGER: Yeah, we are off the record. 5 MR. KING: Off the record. 6 THE VIDEOGRAPHER: The time is 11:40 A.M. We 7 are now coming off the record. 8 (Thereupon, a discussion was had off the 9 record.) 10 (Thereupon, a luncheon recess was taken from 11 11:45 A.M. - 1:15 P.M.) 12 THE VIDEOGRAPHER: The time is 1:19 P.M. We 13 are back on the video record. 14 MR. HADDAD: Is Epstein on the phone? 15 MR. EPSTEIN: Yes. 16 MR. HADDAD: Okay, good. I'm still reeling 17 from lunch, excuse me. 18 BY MR. HADDAD: 19 Q At any rate, I just saw this and I just 20 thought I would ask. Your lawyer and your law firm 21 filed a amended expert witness list of Bradley J. 22 Edwards, through his undersigned attorney hereby amends 23 his witness list for trial as follows. Experts include 24 all attorneys listed in the prosecution of civil claims 25 against Jeffrey Epstein arising out of your usual crap Empire Legal Support. Inc. Page: 186 EFTA01089125 Bradley J. Edwards taken on 10/10/2013 1 about serial abuse and stuff. Did you -- are you 2 familiar with this document? 3 A No. 4 Q And it says here, you are listing all 5 attorneys involved in the prosecution of civil claims, 6 who would that be, who would the experts be that are 7 involved in the civil claims, which attorneys do you 8 know that to be? 9 A Which attorneys were involved in the civil 10 claims? 11 Q Well, your experts -- 12 MR. GOLDBERGER: Ask him what what he 13 what his lawyer means by that, those words? 14 MR. HADDAD: Jack. 15 MR. GOLDBERGER: I'm sorry. 16 MR. HADDAD: Thanks, I wouldn't figure that 17 out on my own. Let me stumble through four or five 18 questions. 19 BY MR. HADDAD: 20 Q Did you understand Goldberger's question? 21 A Between the two of you, I think there is a 22 question in there somewhere. 23 Q This is going to be frick and frack trying the 24 case in there. 25 All right, so you listed -- what it boils down Empire Legal Support. Inc. Page: 187 EFTA01089126 Bradley J. Edwards taken on 10/10/2013 1 to is every frickin' civil lawyer that had a claim, 2 you're listing as an expert witness, which would be 3 Josefsberg -- 4 A Josefsberg. 5 Q Horo -- 6 A Adam Horowitz. 7 Q Horowitz, all of them? 8 A Ted Leopold. 9 Q Yeah. So you are listing them all as expert 10 witnesses, which would waive any claim of privilege 11 right now, if they are going to be witnesses for you, if 12 they are going to testify about your claims and about 13 everything involved in the claims. So let's go back to 14 my other question is, did you have a joint -- joint 15 agreement with any of these guys? 16 MR. KING: Objection to the form. 17 MR. HADDAD: Okay. 18 MR. KING: Also reassert the same objection I 19 had before. 20 MR. HADDAD: Okay. Form objections don't mean 21 much, because you know the question. 22 MR. KING: It's only the -- only the preface 23 to the question. 24 MR. HADDAD: Well, I understand that. 25 Empire Legal Support. Inc. Page: 188 EFTA01089127 Bradley J. Edwards taken on 10/10/2013 1 BY MR. HADDAD: 2 Q Here it is. You -- you've listed -- Scarola 3 has listed all these people as attorneys -- as -- as -- 4 as witnesses now, so my preparatory question to you is: 5 Are you aware that he did it? 6 A I am. 7 Q Okay. The second question is: If these are 8 all listed witnesses, they must have some material 9 knowledge to be expert witnesses, correct? 10 A Right. 11 Q Number 3, speaking of expert witnesses, did 12 you happen to read Mr. Scarola's expert witness 13 deposition to Bill Sheer in the Rothstein Ponzi scheme 14 clawback thing? 15 A No. 16 Q Were you aware that Mr. Scarola was listed as 17 an expert witness? 18 A In what? 19 Q In -- in the clawback scheme, he is an expert 20 witness for Sheer on punitive damages. 21 A No. 22 Q Would you share Mr. Ep -- with Mr. Scarola's 23 comments that he would never believe a single word that 24 Scott Rothstein said? 25 A Would I do what? Empire Legal Support. Inc. Page: 189 EFTA01089128 Bradley J. Edwards taken on 10/10/2013 1 Q Would you adopt the statement of your lawyer, 2 Mr. Scarola, in his deposition, that he would never 3 believe a word Scott Rothstein said? 4 A Show me the statement and the context in which 5 he said it and I will tell you whether or not I agree 6 with it. 7 Q Well, would you believe a word, anything Scott 8 Rothstein said? 9 A I listened to Scott's deposition in this case. 10 Q All right. 11 MR. GOLDBERGER: Did we have the dep of him? 12 MR. HADDAD: Huh? I don't have it here. I -- 13 I'll -- I'll save it for trial, that will be more 14 funny anyhow. 15 BY MR. HADDAD: 16 Q All right. So now these experts are -- they 17 will testify based upon their background, training, 18 experience as civil litigants and their personal 19 involvement that each adverse prosecuting claims against 20 Jeffrey Epstein about the legal and ethical propriety of 21 the actions taken by Bradley Edwards in fulfilling his 22 obligations to the victims of Epstein's assaults. 23 A Okay. 24 Q You must have had helped him prepare that. 25 A I didn't prepare that one. Empire Legal Support. Inc. Page: 190 EFTA01089129 Bradley J. Edwards taken on 10/10/2013 1 Q All right. So this is -- these persons, these 2 lawyers are going to be testifying to everything they 3 did in conjunction with you. My question comes back to 4 what we asked before the luncheon break. Did you 5 gentlemen have what would be considered in essence a 6 joint agreement for purposes of prosecuting claims 7 against Edwards? 8 MR. KING: The same objection. 9 A I am Edwards. 10 BY MR. HADDAD: 11 Q Huh? 12 A I am Edwards. 13 Q I mean against Epstein. 14 MR. KING: The same objection we had before. 15 MR. HADDAD: All right. And are you going to 16 instruct him not to answer so I can get it there 17 quicker? 18 MR. KING: Yes. 19 MR. HADDAD: All right. That makes it very 20 simple. Okay. 21 MR. KING: And you under -- you understand 22 there -- 23 MR. HADDAD: I understand what -- 24 MR. KING: -- are pending motions or motions 25 that were resolved that were filed by those lawyers Empire Legal Support. Inc. Page: 191 EFTA01089130 Bradley J. Edwards taken on 10/10/2013 1 and so, you know, in an abundance of caution we -- 2 MR. HADDAD: Bill, I have no problem, we will 3 take care of it, I want to make sure I cover the 4 record so that I can get it out at some point in 5 time. 6 A I just can't waive their privilege, that's it. 7 BY MR. HADDAD: 8 Q I -- I am not asking for privilege, I'm asking 9 you whether you had agreement. There is no privilege to 10 an agreement. 11 MS. COLEMAN: Once they filed it, they waive. 12 MR. KING: No, no, if there was a filed 13 agreement, I would agree, it -- it would be a 14 public record, but most joint agreements -- 15 MS. COLEMAN: What I am saying is, by placing 16 them on the record as expert witnesses -- 17 MR. HADDAD: I understand that. 18 MR. KING: I understand your position, I 19 would -- 20 MR. HADDAD: They waived it. We understand 21 what waiver is. 22 MR. KING: They waived it. 23 MR. HADDAD: Why am I arguing with you, you 24 are on my side? 25 MR. KING: That's right. Empire Legal Support. Inc. Page: 192 EFTA01089131 Bradley J. Edwards taken on 10/10/2013 1 MS. COLEMAN: Have it. 2 MR. HADDAD: See, I -- I can't -- you're like 3 a little wife. 4 MS. COLEMAN: Because I look like my mother. 5 MR. HADDAD: I could always slap you. All 6 right. The only one not laughing is Brad, why, we 7 are all having a good time here, enjoy the show. 8 BY MR. HADDAD: 9 Q All right. The other thing is -- the other 10 thing we're here on is Epstein's motion to overrule 11 objection, all that stuff. You said that you are going 12 to withdraw your objections to the questions that were 13 asked that were set for a hearing on November. 14 MR. KING: Man -- many of those. Let me 15 just -- 16 MR. HADDAD: Well, yeah, we'll -- 17 A Ask the question and I'll give you an answer. 18 BY MR. HADDAD: 19 Q Yeah, that's fine. 20 MR. KING: Right, because, just as -- for 21 example, the financial questions, Judge has already 22 ruled, so those would -- those would still be 23 asserted. The other ones were in the list that 24 you -- that you've put in here, a number of them 25 were answered so-.-.-. Empire Legal Support. Inc. Page: 193 EFTA01089132 Bradley J. Edwards taken on 10/10/2013 1 MR. GOLDBERGER: Why don't we just ask every 2 question. 3 MR. HADDAD: Yeah, here's the simple thing. 4 I'm easy, as you know, I don't get mad, I don't 5 worry about -- just say you don't do -- you know, 6 whatever. 7 THE WITNESS: Fire away. 8 BY MR. HADDAD: 9 Q In this particular instance associated with 10 Mr. Epstein, what investigators worked on Epstein's 11 cases during the time you were at RRA? 12 A I communicated directly with Mike Fiston. 13 Other investigators that worked on the case were Pat 14 Roberts. 15 Q Okay. 16 MR. GOLDBERGER: Wait for the answer. 17 A And I think Pat Diaz. 18 BY MR. HADDAD: 19 Q Would you consider Ken Jenne, our great 20 illustrious lawyer sheriff to be an investigator? 21 A Yes. 22 Q I mean, he did some work on -- 23 A In some general way. 24 Q Yeah. All right. So that answers the whole 25 first set of questions, I think. Empire Legal Support. Inc. Page: 194 EFTA01089133 Bradley J. Edwards taken on 10/10/2013 1 Did Fistein Fiston interview an individual 2 by the name of Michael Friedman? 3 A I think so. 4 Q And who's Michael Friedman? 5 A A former housekeeper of Jeffrey Epstein. 6 Q All right. Did you obtain a written statement 7 from him or written investigative file or anything that 8 you are aware of? 9 A No, I don't think so. 10 Q Okay. Who was the first investigator that you 11 believe involved -- who cares. 12 Who was the first investigator that you 13 believe was involved in this, who took this depo? 14 MS. COLEMAN: Not me, don't look at me. 15 MR. GOLDBERGER: Just ask the questions. 16 MR. HADDAD: I'm sitting here astounded. 17 BY MR. HADDAD: 18 Q Who was the first investigator to work on 19 these cases? 20 A That I had anything to do with? 21 Q Yeah. Work product, instruct you not to 22 answer, okay. Work product. 23 Who was it, Fiston? 24 A Wayne Black. 25 Q Okay. Wayne Black, and I saw some stuff. Empire Legal Support. Inc. Page: 195 EFTA01089134 Bradley J. Edwards taken on 10/10/2013 1 That's the same Wayne Black that in the e-mails we 2 looked at earlier this morning -- 3 A Right. 4 Q -- was referenced by Ken Jenne and stuff? 5 A That's right. 6 Q Okay. You already answered this pretty much. 7 MR. GOLDBERGER: You don't need to look to me 8 for approval, just ask the questions. 9 MR. HADDAD: Well, apparently you are telling 10 me I'm asking him wrong when I don't ask right. 11 BY MR. HADDAD: 12 Q Did -- did you ever direct investigators to go 13 through Epstein's trash? 14 A No. 15 Q Okay. Here, I -- I -- I have to ask it again 16 a second time, I guess these guys can't ask a question 17 15 different ways. With regard to your investigators, 18 you gave direction regarding the Epstein cases during 19 the time which you were at RRA, did you ever tell them 20 or direct them to go through Mr. Epstein's trash? 21 A No. 22 Q Did you conduct surveillance of Epstein's 23 property? 24 A No. 25 Q Did you direct anyone to conduct -- let me do Empire Legal Support. Inc. Page: 196 EFTA01089135 Bradley J. Edwards taken on 10/10/2013 1 it my way, I get the right answer. 2 Did you ever direct anyone to go to Epstein's 3 property and conduct surveillance? 4 A No. 5 Q Did you tell police to put up pole cams over 6 there? 7 A No. 8 Q Did you ask the police if they had pole cams 9 over there? This is my own question now. 10 A I don't think so. 11 Q Did you ever ask whether or not the City of 12 Palm Beach actually had cameras that they use for all 13 the streets that you could get surveillance from? 14 A Me, personally, no. 15 Q No, direct anyone else to do that. 16 A No. 17 Q Because civil lawyers aren't smart enough to 18 ask these questions. 19 A No. 20 Q Okay. 21 MR. HADDAD: No offense, Mr. King, you are. 22 BY MR. HADDAD: 23 Q Have you ever instructed -- no, that one's 24 same one. 25 Have you ever authorized employ -- Empire Legal Support. Inc. Page: 197 EFTA01089136 Bradley J. Edwards taken on 10/10/2013 1 investigators, either employees from a firm, blah, blah, 2 blah, to walk around the perimeter of Mr. Scarola's -- 3 Mr. Scarola -- Mr. Epstein's home on or the same time 4 that -- March 17 of 2010? 5 A No. 6 MR. HADDAD: What are you trying to show me? 7 MR. GOLDBERGER: I am just sending you a 8 message from your client. 9 MR. HADDAD: Oh. 10 BY MR. HADDAD: 11 Q Who paid for -- who paid for the 12 investigators, it just came out of RRA funds as part of 13 employment? 14 A Who paid for the investigators I just told you 15 about? 16 Q Yeah. 17 A Mike Fiston and all that? 18 Q Yeah. 19 A To my knowledge, they were employees of RRA. 20 Q Okay. But you don't know whether or not 21 Scarola and everybody else's money jointly went in to 22 pay for all these guys, because that would have been 23 done by the trust department, which you didn't know? 24 A Yeah, and it didn't. It didn't. I mean, they 25 were employees of RRA. Empire Legal Support. Inc. Page: 198 EFTA01089137 Bradley J. Edwards taken on 10/10/2013 1 Q Okay. 2 MR. GOLDBERGER: You are okay. 3 BY MR. HADDAD: 4 Q All right. Let me ask you this: Did you 5 auth -- were any informants, comma, did you authorize 6 your investigator to hire informants? 7 A I don't even know what that means. 8 Q Neither do I, but I am just asking the 9 question. 10 A Like a mole inside Epstein's house? 11 Q I think so. 12 A How could I possibly mean that? No, I did 13 not. Regardless, the answer is no. 14 Q I don't know, maybe you went to the Sunrise 15 Police Department, it's in the news now, and got one of 16 their informants to go out and hire somebody. 17 A I didn't have that idea. 18 MR. GOLDBERGER: Does he -- does he know if 19 they went through the -- 20 MR. HADDAD: Huh? 21 MR. GOLDBERGER: Does he -- does he know if 22 they went through the -- 23 BY MR. HADDAD: 24 Q Does anybody -- did anybody go through the 25 trash? Empire Legal Support. Inc. Page: 199 EFTA01089138 Bradley J. Edwards taken on 10/10/2013 1 A The police went through his trash. 2 Q Well, I know the police did, I read that. 3 A Right, that's all I -- and that's why I know 4 it. 5 Q Okay. Did the police hand you some of the 6 stuff they found in his trash? 7 A I got it the same way everybody else did, it 8 was in the State Attorney's file, FOIA request, 9 et cetera, I got the stuff from his trash. 10 Q A four-year request? 11 A Freedom of Information -- 12 Q Oh, FOIA. 13 MS. COLEMAN: FOIA, F-O-I-A. 14 BY MR. HADDAD: 15 Q I thought you said four-year request. My bad 16 ear. 17 A But, no. 18 Q Okay. 19 A Nobody that I know went through his trash. 20 Q Let me ask, did you authorize any 21 investigators to trespass on Epstein's property? 22 A No. 23 Q I guess March 17th must be a big day because 24 there is 15 questions regarding March 17th, what was 25 that day, besides St. Patrick day? Empire Legal Support. Inc. Page: 200 EFTA01089139 Bradley J. Edwards taken on 10/10/2013 1 A Other than St. Patrick's day, no idea. 2 Q Okay. Question: Did he, Mr. Roberts, ever 3 perform investigative work on any of the Epstein files? 4 A Yes. 5 Q Okay. And who's Roberts? 6 A Pat Roberts, he was -- 7 Q He's an investigator. 8 A -- the other investigator that was working at 9 RRA. 10 Q Yeah. And Rick Fandy, Rich Fandy, Fandray 11 perform any work on the Epstein files, any 12 investigation? 13 A I'm not sure. 14 Q Okay. 15 A He wasn't an RRA employees but they contracted 16 extra work out to certain people and Rick was one of 17 those people. 18 Q Okay. Outside contractor? 19 A Right. 20 Q Were those the ones that protected Scott when 21 he took all the money to the airport to flee the 22 country? 23 A No. Those were the actual police. 24 Q Did you ever authorize or direct Ken Jenne to 25 perform any investigation on the Epstein files? Empire Legal Support. Inc. Page: 201 EFTA01089140 Bradley J. Edwards taken on 10/10/2013 1 A No. This is what I understand -- 2 MR. GOLDBERGER: Answer the question. 3 A This is what I understand Ken Jenne's role to 4 have been. I -- I communicated directly with Mike 5 Fiston. Ken Jenne had something to do with locating 6 forensic accountants to deal with the money aspect of -- 7 related to Epstein. I didn't direct Ken Jenne, I don't 8 think, to do anything. 9 Q All right. Ken Jenne, of course, had been a 10 lawyer for many years, State attorney -- State attorney. 11 MR. GOLDBERGER: Sure. 12 MR. HADDAD: And then a sheriff. 13 THE WITNESS: I know that -- 14 MR. HADDAD: He was a State attorney for 15 years. 16 BY MR. HADDAD: 17 Q Okay. He was -- he was actually the first 18 economic investigator, a State attorney prosecutor. Did 19 you know anything about that? 20 A No. 21 Q Okay. Were you advised of his abilities in 22 the economic field? 23 A No. 24 Q All right. Did you know whether or not he was 25 partners with, what's that guy's name we are talking Empire Legal Support. Inc. Page: 202 EFTA01089141 Bradley J. Edwards taken on 10/10/2013 1 about, Sheer? 2 MS. COLEMAN: Bill Sheer. 3 BY MR. HADDAD: 4 Q Bill Sheer, did you know he was partners with 5 Sheer before he went with Rothstein? 6 A I know that now. I did not know that then. 7 Q Do you know whether or not Sheer actually used 8 Rothstein as an attorney? 9 A I think I have heard that since, but I didn't 10 know that then. 11 Q Okay. What is the existence of an entity 12 called Blueline Research and Development, do you know 13 what that is? 14 A No. I think that there is a similar title, 15 Blueline is a private investigation -- 16 Q Okay. 17 A -- firm of some sort. 18 Q But did you ever use them, because that is 19 probably what they are talking about? 20 A During the time I was at RRA, I am assuming? 21 Q Yeah. 22 A No. 23 Q I think all these questions were about when 24 you were at RRA. 25 A Right, I just -- I just wanted to clarify Empire Legal Support. Inc. Page: 203 EFTA01089142 Bradley J. Edwards taken on 10/10/2013 1 that. 2 Q Okay. Now, your -- your assoc -- the next 3 subject of the matter is on the motion that -- that 4 turned to Mr. Edwards interac -- reported interactions 5 with anyone associated with the Epstein case and the 6 first question is -- excuse me -- during the time that 7 you were with RRA -- excuse me, somebody else's 8 handwriting -- and had investigation done on 9 Mr. Epstein, was any of your investigation that you 10 performed turned over to any person outside of RRA or 11 your clients? 12 A No. 13 Q You understood that? 14 A I think that you were asking, did I do 15 investigation, get evidence and then turn it over to 16 somebody outside of the firm. 17 Q That -- that's what the attempt of that 18 question was. The answer is no? 19 A Right. 20 Q Okay. And any of the directions that you ever 21 gave to the investigators, did you ever put that in the 22 form of memo, that is, would you give them written 23 directions? 24 A I would just talk to Mike. 25 Q The discussion turns to the matter -- manner Empire Legal Support. Inc. Page: 204 EFTA01089143 Bradley J. Edwards taken on 10/10/2013 1 in which cases were handled while Edwards was a partner 2 at RRA. The one meeting that you had in Mr. Rothstein's 3 office with Russell Adler and some persons unknown -- 4 some unknown person on the phone, were you given any 5 direction at that time that certain discovery should be 6 done or tactics should be used with regard to 7 prosecuting the Epstein cases? 8 A No. 9 Q Okay. At the meetings that you -- at the 10 meetings that occurred with these various lawyers, 11 Berger, Adler, Stone, Rob Buschel were present and 12 Epstein was discussed, was the discovery that -- 13 discovery and/or investigation regarding Mr. Epstein 14 ever discussed? 15 A I -- I would assume so. 16 Q Well, I -- 17 A In meetings, that we were talking about, was 18 Epstein discussed? 19 Q Yeah, I -- I -- I assume, based upon the -- 20 what we saw in the e-mails today, that is exactly the 21 purpose of the meeting, correct? 22 A Exactly, that was the purpose of the meeting. 23 MR. INDYKE: Discovery I think was the purpose 24 of the question. 25 MR. HADDAD: I'm sorry? Empire Legal Support. Inc. Page: 205 EFTA01089144 Bradley J. Edwards taken on 10/10/2013 1 MR. INDYKE: I think the question related to 2 discovery that you were doing at the time. 3 MR. KING: Actually, the way the question 4 reads, it says, discovery and/or investigation. 5 MR. HADDAD: Yeah, didn't I read that? 6 MR. KING: Yes. 7 MR. HADDAD: Yeah, okay. 8 MR. KING: And I think he's answered. 9 BY MR. HADDAD: 10 Q Mr. Edwards, were you involved in discussions 11 regarding the deposing of any of the people -- excuse 12 me, I apologize for what I have to read because I am 13 trying to make sense out of it. Mr. Edwards, were you 14 involved in the discussions regarding the deposing of 15 any of the people of these individuals, Mr. Trump, that 16 is, in discussions with any of the other lawyers in your 17 law firms including Scott Rothstein? 18 A If you can make sense out of that question, 19 ask it your way, I'll try to answer it 20 Q All right. 21 A -- I have to idea what it means. 22 Q But simple thing is, were you involved in the 23 discussions of the desired -- deposed Trump, Clinton, 24 all those people? 25 A Yeah. Empire Legal Support. Inc. Page: 206 EFTA01089145 Bradley J. Edwards taken on 10/10/2013 1 Q And of course, Dershovitz, the other one is 2 Amber Wexner, David Copperfield, all the rest of them, 3 correct? 4 A Yes. 5 Q Okay. And there is no question about that, 6 it's in all the rest of the discovery we got afterwards? 7 A I was involved in the decision to take 8 anyone's deposition that was -- 9 Q And -- and I think there is an e-mail that we 10 saw yesterday, we better do this to put pressure, an 11 e-mail or something, it seems like yesterday, I guess it 12 was this morning. 13 Okay. Did you have any discussions within 14 your firm regarding the taking of the depositions of 15 several -- of celebrities or famous people who were 16 purportedly on Mr. Epstein's plane, so that they could 17 be deposed such that would be an inducement to 18 Mr. Epstein to settle his lawsuit? 19 A Was I involved in a discussion? 20 Q Yeah, well, you know, what this question is 21 asking, did you guys decide to take some depositions so 22 you could induce him to settle the lawsuit, that is, 23 almost like pressure. I guess inducement means 24 pressure, doesn't it, lure, pressure? 25 A Do you want the short answer or the long Empire Legal Support. Inc. Page: 207 EFTA01089146 Bradley J. Edwards taken on 10/10/2013 1 answer? 2 Q Probably the short answer first. 3 MR. KING: The right answer. 4 A The correct answer is this. What we knew at 5 the time was that -- 6 BY MR. HADDAD: 7 Q This is going to be the long answer. 8 A It is going to be. It is going to be, but to 9 be complete, I have no other choice. What we knew at 10 the time is that Jeffrey Epstein was molesting children 11 literally every day. So we tried to take his deposition 12 and he took the fifth. We tried to take his various 13 co-conspirators' depositions and they took the fifth. 14 We tried to take the next tier of people that we knew 15 information about him molesting these children and they 16 had lawyers who were paid for by Jeffrey Epstein or they 17 had lawyers paid for by Jeffrey Epstein and said they 18 were leaving the country forever. The next level of 19 people that we were attempting to take the deposition 20 Q Or his father? 21 A Right. 22 Q Okay. 23 A The next level of people that we were 24 attempting to take the deposition of were people that we 25 thought Epstein could not directly control, and people Empire Legal Support. Inc. Page: 208 EFTA01089147 Bradley J. Edwards taken on 10/10/2013 1 who were in his presence in places where we knew the 2 criminal molestation of children had had happened. 3 Those people, some of them were high-profile or 4 celebrity-type people. So in addition, did we think 5 that that could induce him to settle cases? Some people 6 thought that. I don't think he personally cares about 7 anybody, so I never adopted that, but that train of 8 thought was discussed and we took -- and we elected that 9 those were the next people in line whose deposition 10 should be taken. 11 Q Well, without being argumentative, that is the 12 way every civil case works. 13 A Yeah. 14 Q You try to pressure people in to sue. I mean, 15 it is no different in this case than in any other case. 16 You've got people who will settle the case rather than 17 put up with a bunch of crap and you were hoping that 18 this is what happened. Somebody was hoping that's what 19 would happen in this case. 20 MR. KING: Objection to form, compound. 21 MR. HADDAD: Oh, okay. I can't even read it. 22 Okay, I will do that in a little bit, okay. Can 23 you just print it a little better so I can read it? 24 I don't -- I don't mean to be rude, but I -- 25 MR. INDYKE: That's fine, Fred. Empire Legal Support. Inc. Page: 209 EFTA01089148 Bradley J. Edwards taken on 10/10/2013 1 MR. HADDAD: -- have a tough time reading it 2 period. 3 MR. GOLDBERGER: Period? 4 MR. HADDAD: Huh? 5 MR. GOLDBERGER: Hard time reading, period? 6 MR. HADDAD: Period. 7 THE WITNESS: He intentionally reads the 8 sentence. 9 MR. HADDAD: I mean, to quote -- to quote 10 blazing saddles, that's -- that's like American 11 gibberish. No offense, Darren. 12 MR. INDYKE: None taken. 13 BY MR. HADDAD: 14 Q Did Mr. Jenne, did you direct -- I don't know 15 why it's back up again -- did you direct Mr. Jenne to do 16 an investigation on his Ep -- on the Epstein cases? 17 A Other than what I have otherwise -- 18 Q Yeah. 19 A -- described already, no. 20 Q Did Jenne do any investigate -- we've already 21 asked and answered that, I am not going through that 22 again. 23 Did you -- did you contact any persons who 24 were listed in the book that was eventually produced by 25 Mr. Rodriquez after he got arrested with the book and Empire Legal Support. Inc. Page: 210 EFTA01089149 Bradley J. Edwards taken on 10/10/2013 1 the book was made public? A relevancy objection by 2 Mr. King. 3 A Did I contact any people? 4 Q First good objection so far. 5 Does Scarola read these things? 6 A I don't think so. 7 Q Scarola doesn't read them or-.-.-. 8 A I don't think so. 9 Q Scarola doesn't read them? 10 A I don't even know what question is on the 11 table right now. 12 MR. KING: I think you -- you directed that 13 last question to me. 14 MR. HADDAD: Yeah, I know. 15 BY MR. HADDAD: 16 Q Did you -- did you have contact with any 17 persons who were listed in the book that was eventually 18 produced by Mr. Rodriquez after he got arrested and -- 19 A I don't remember. 20 Q -- and the book was made public? 21 A I don't remember. 22 Q Were you 24 A Yes. 25 Q Okay. And that wasn't even here, but thanks. Empire Legal Support. Inc. Page: 211 EFTA01089150 Bradley J. Edwards taken on 10/10/2013 1 Well, along the lines that were taken the last 2 time with regard to whatever work product was involved, 3 that didn't take Inspector Clouseau to figure that out, 4 anyhow. 5 A I don't think I am telling anybody anything 6 they don't already know. 7 Q Yeah, I -- I know. I didn't want it to seem 8 like I was that smart but-.-.-. 9 Well, along the lines that were taken with 10 regard to whatever work product was involved in the 11 investigation in light of the current state of the case, 12 you know, who asked these questions? Even -- 13 A Is it a question? 14 Q Never mind, I'm am reading Mr. King's 15 objection. That's not a question. 16 MR. KING: That's right. 17 MR. HADDAD: He didn't want He 18 wanted the book. We will get to that later. 19 That's a good trial question. 20 MR. GOLDBERGER: Oh, I'm sorry. 21 MR. HADDAD: That's okay. 23 Right? 24 MS. COLEMAN: Or 25 MR. HADDAD: No, Empire Legal Support. Inc. Page: 212 EFTA01089151 Bradley J. Edwards taken on 10/10/2013 1 . This is a polite trial. 2 BY MR. HADDAD: 3 Q Did you have any contact with Kendall Coffey 4 regarding propriety or ask him for an opinion of the 5 propriety of taking that book from Rodriguez? 6 MR. KING: We'll assert the attorney-client 7 privilege. 8 MR. HADDAD: Okay. 9 MR. KING: Instruct him not to answer. 10 MR. HADDAD: That's fine. I got to -- yeah, 11 that's got to be a motion anyhow. 12 BY MR. HADDAD: 13 Q All right. If you were asked each of these 14 questions, transcript of deposition dated -- I'm not 15 going to -- the same objection, I don't even know what 16 that is. And then Mr. Goldberg objects. 17 MR. HADDAD: Jack, do you remember what you 18 were objecting to? 19 MR. GOLDBERGER: No, I don't. 20 MR. HADDAD: Of course. Let me just kind of 21 clean it up. Oh, and then add Coleman objects. 22 Everybody objects. 23 MS. COLEMAN: I didn't object, I was laying a 24 record and you don't have to ask all those 25 questions, it was for the purpose of the motion for Empire Legal Support. Inc. Page: 213 EFTA01089152 Bradley J. Edwards taken on 10/10/2013 1 the Court to know it was asserted a second time, 2 that's all. 3 MR. HADDAD: Oh, okay. Was that from my depo? 4 MS. COLEMAN: Umm-hmm. That was from your 5 depo last time. 6 MR. HADDAD: All right. Let me see if I got 7 anything on Edwards. 8 MS. COLEMAN: So we don't have to sit here for 9 nine hours. 10 MR. HADDAD: See, they took the -- they took 11 the conspiracy out, so I can't have Rothstein. 12 THE WITNESS: I know, I know. 13 MR. HADDAD: Oh, proper predicate, okay. Let 14 me read what these are. Edwards compensation at 15 RRA and the payment of expenses. 16 BY MR. HADDAD: 17 Q Did you do any hourly billing yourself or were 18 you strictly a contingency fee person? I guess that 19 would be contingency fee basis, I guess. 20 A While I was at RRA? 21 Q Yeah. Well, you answered it, 90 percent 22 contingency, so why the hell am I asking the question 23 with no objection? 24 Oh, here we go. Where did you -- where did 25 you think that the expense money incurred in the Epstein Empire Legal Support. Inc. Page: 214 EFTA01089153 Bradley J. Edwards taken on 10/10/2013 1 cases was coming from, the source of the money to pay 2 the extensive bills that were being incurred on Epstein 3 and other cases? 4 A The law firm. 5 Q Okay. And that was based 6 MR. HADDAD: Jack, do you want do you want 7 me to stop and take a break so you can tell me what 8 to follow up with? 9 MR. GOLDBERGER: No. 10 MR. KING: Just so -- just so you know, he did 11 answer that at the bottom but -- 12 MR. HADDAD: Yeah. 13 MR. KING: -- in the last line. 14 MR. HADDAD: I saw it now. He said the law 15 firm. 16 A Good. 17 BY MR. HADDAD: 18 Q And -- and let me just ask you this. In 19 regards to the law firm at that time, and I know we have 20 been through this before, there was no perception of the 21 law firm being involved in anything other than legal 22 activity? 23 A Of course not. And other than being involved 24 in legal activity. 25 Q Legal activity, yeah, that was representing Empire Legal Support. Inc.. Page: 215 EFTA01089154 Bradley J. Edwards taken on 10/10/2013 1 Sheer, had -- 2 A You were talking fast. It's -- I wanted to be 3 sure there wasn't an issue. 4 Q I know, but I wasn't trying to sneak one in. 5 I did that with the other thing. But any rate, Sheer, 6 representing Sheer, it represented everybody in town, it 7 was repres -- it was -- you were -- you were playing 8 around with John McCain and all those right-wingers, 9 tea-party people and all that other -- not -- not you, 10 but you know what I mean, taking care of all of that, 11 right? So it gave the appearance of a legitimate law 12 firm? 13 A Yeah, it was a le -- it was, to everybody 14 else, a legitimate law firm. 15 Q Except for nobody in town, just you guys at 16 and the firm. But anyway -- 17 A You should have shared that with Russ Adler 18 before. 19 Q I knew that was coming. 20 Okay, hourly billing confirmed, financial 21 privacy. Okay. These questions aren't too bad. 22 MR. HADDAD: Okay. Thanks, Darren. 23 THE WITNESS: You have another book over here. 24 MR. HADDAD: Oh, I know. I see there is 25 another book over there. Empire Legal Support. Inc. Page: 216 EFTA01089155 Bradley J. Edwards taken on 10/10/2013 1 BY MR. HADDAD: 2 Q Did Rothstein ask you how much you were making 3 at the time or how much you had made in the preceding 4 year, 2008? Answer: I believe so. Question: What did 5 you tell him? 6 MR. KING: Well, I think these -- all these 7 questions and answers would fall within the ambit 8 of the Court's ruling of financial privacy -- 9 MR. HADDAD: I don't remember what that was. 10 MR. KING: And -- 11 MR. HADDAD: We don't need to -- if you don't 12 want to, just tell me and we'll take it from here. 13 MR. KING: Well, the one thing, I don't want 14 him to have to come back for another deposition 15 so -- 16 MR. GOLDBERGER: Let him answer it. 17 BY MR. KING: 18 Q You didn't make -- you made whatever you made. 19 I mean, I 20 A Yeah, I don't remember. 21 Q -- could get your tax returns. 22 MS. COLEMAN: No. 23 MR. HADDAD: Huh? 24 MS. COLEMAN: That's what we are not allowed 25 to have. Empire Legal Support. Inc. Page: 217 EFTA01089156 Bradley J. Edwards taken on 10/10/2013 1 MR. HADDAD: Why? 2 MS. COLEMAN: The Court said we can't have his 3 private tax returns, but if what he was making was 4 related to -- 5 BY MR. HADDAD: 6 Q Is you wife -- are you still married? 7 MS. COLEMAN: -- a claim, we could have it. 8 MR. HADDAD: Maybe I could get you divorced 9 and have it produced from her. 10 MR. GOLDBERGER: Just ask the question, how 11 much he was making. 12 MR. HADDAD: I will. 13 BY MR. HADDAD: 14 Q How much were you making? 15 MS. COLEMAN: We are not precluded from the 16 questions, just the documentation. 17 BY MR. GOLDBERGER: 18 Q You were -- you were -- you were a PI lawyer 19 at that time before you went there, right? 20 A Right. 21 Q And you just -- didn't you just settle a big 22 case with the church, just before you got pulled in 23 there? 24 A I don't remember that. 25 Q Oh, I thought you -- somebody said that you Empire Legal Support. Inc. Page: 218 EFTA01089157 Bradley J. Edwards taken on 10/10/2013 1 settled a big church case with one of those priests with 2 the Archdiocese? 3 A No. 4 Q Okay. So how much were you making? 5 MR. KING: The same objection, based on the 6 Court's rule. 7 MR. HADDAD: Okay. Then -- okay. 8 MR. KING: Let me -- let me just -- let me 9 just touch base with him on one on one issue 10 relating to that. 11 MR. HADDAD: Yeah. 12 MR. KING: Because again, we don't want to 13 come back. 14 THE VIDEOGRAPHER: The time is 1:46 P.M. We 15 are now coming off of the video record. This is 16 the end of Tape No. 2. 17 (Thereupon, a discussion was had off the 18 record.) 19 MR. KING: Let me just tell you our position 20 on -- 21 THE VIDEOGRAPHER: The time is 1:49 P.M. We 22 are now back on the video record. This is the 23 start of Tape No. 3. 24 MR. KING: Sorry. 25 THE VIDEOGRAPHER: No problem. Empire Legal Support. Inc. Page: 219 EFTA01089158 Bradley J. Edwards taken on 10/10/2013 1 MR. KING: Let me tell you what our position 2 is. These questions, to the extent I believe all 3 of them are directed for him to say are asking, 4 what did you tell Rothstein about what you were 5 making and what did you tell Rothstein about what 6 you expected to make, we will let him answer those 7 questions. 8 MR. HADDAD: Okay. 9 MR. KING: I think those are the questions to 10 which the objections were made and I don't think it 11 goes beyond, and then -- but to the extent that 12 there are any questions about how much did you 13 make -- 14 MR. GOLDBERGER: Right. 15 MR. KING: -- at any time, then it falls 16 within the Court's order. So let's -- 17 MR. HADDAD: No. 18 MR. KING: -- let's -- if you want to go 19 that -- 20 MR. HADDAD: Can you answer his question, 21 because I don't want to -- let him answer the 22 questions. 23 A I don't remember what I told him either. What 24 I had previously made or what I expected, I don't 25 remember that cony -- that part of that conversation Empire Legal Support. Inc. Page: 220 EFTA01089159 Bradley J. Edwards taken on 10/10/2013 1 2 BY MR. HADDAD: 3 Q Okay. Well, you would have been a contingency 4 fee lawyer there anyhow? 5 A Right. 6 Q Let me ask you this: Did you have an 7 agreement as to what percentage of the profits -- Well, 8 let me put it this way. 9 Let's say it settled for a million bucks, you 10 bring it into the firm, you are now a part of RRA, you 11 were not a separate LLC or a separate P.A., how much of 12 what you brought into the firm did you get to keep, 13 as -- if the firm settled -- if you settled and the firm 14 got 40 percent, I don't know if you get 40 percent 15 anymore, 33-1/3. At 33-1/3, one million came in, how 16 much of that would you keep to the firm, what would your 17 cut be? 18 MR. KING: Well, I believe that the Court's 19 order covers that. 20 MR. HADDAD: Oh, does that cover that? Okay, 21 then I -- I -- I don't understand financial orders. 22 You know, in my business we deal in cash. Cash 23 ain't income, so we don't have -- 24 A Cash ain't income, that's a good one, for the 25 record. Empire Legal Support. Inc. Page: 221 EFTA01089160 Bradley J. Edwards taken on 10/10/2013 1 MR. HADDAD: I said -- I tell you that -- I 2 said that one time when I was giving a -- asked to 3 talk at a criminal law seminar. I said it as a 4 joke, 5 MR. GOLDBERGER: No kidding. I am shocked. 6 MR. HADDAD: Huh? 7 MR. GOLDBERGER: I'm shocked. 8 MR. HADDAD: All right. I'm not even going to 9 get into the financial stuff. Let me get into some 10 of these other questions so we can get out of here. 11 BY MR. HADDAD: 12 Q Did you hire Kendall Coffey in the Epstein 13 cases, hire, not any questions? Well, I think silence 14 would say yes, so-.-.-. 15 MR. GOLDBERGER: Well, he is waiting to see 16 whether his lawyer is -- 17 MR. KING: No, I think the way -- I think the 18 way the question is asked, you could answer that. 19 A No. 20 MR. HADDAD: Okay. It took that long to say 21 no, I thought you were going to say yeah. I deal 22 with them every day. 23 MR. KING: But privilege objection still 24 stands. 25 MR. HADDAD: I know. I understand that. Empire Legal Support. Inc. Page: 222 EFTA01089161 Bradley J. Edwards taken on 10/10/2013 1 MR. KING: Right. 2 BY MR. HADDAD: 3 Q Okay. I am just going to -- how much -- how 4 much -- 5 A Do you read questions off your hand now? 6 Q That's how I do everything. Okay. Did 7 anybody else hire Kendall Coffey, that you know of, on 8 any cases? It's not you, so it can't be privileged. 9 MR. KING: Well, because -- because we have 10 asserted the privilege, I -- I believe it is -- 11 it's appropriate to inquire about why that 12 privilege was asserted. 13 MS. COLEMAN: I'm sorry, did you say which 14 privilege it was? 15 MR. KING: The attorney-client privilege. We 16 asserted attorney-client privilege to a previous 17 question. 18 MR. HADDAD: Well, that was about all the 19 different lawyers that were involved. 20 MR. KING: No, no. You had asked him whether 21 or not -- one of the questions in here was, did you 22 consult with -- with Kendall Coffey about a 23 subject. 24 MR. HADDAD: Oh, that was about whether he 25 consulted Kendall Coffey about the guy that -- Empire Legal Support. Inc. Page: 223 EFTA01089162 Bradley J. Edwards taken on 10/10/2013 1 Rodriguez. 2 MR. KING: Right. 3 MR. HADDAD: The boy. 4 MR. KING: And we asserted the privilege -- 5 MR. HADDAD: You asserted the privilege on 6 that, but this is just hiring without ever 7 consultation. Did any -- 8 BY MR. HADDAD: 9 Q Well, let me just ask it and then you can just 10 say what you want to. 11 Did any of the lawyer -- other lawyers who are 12 now listed as your expert witnesses ever hire Kendall 13 Coffey, to your knowledge, not consult, what they did 14 with him? 15 A I don't know. 16 Q You don't know. 17 What was your involvement with in the Rodriguez case? 19 A Nothing. 20 Q Okay. Did -- did RRA ever hire Kendall 21 Coffey, to your knowledge? 22 THE WITNESS: I can answer? 23 MR. KING: Umm-hmm. 24 A Yes. 25 Empire Legal Support. Inc. Page: 224 EFTA01089163 Bradley J. Edwards taken on 10/10/2013 1 BY MR. HADDAD: 2 Q Okay. And would that have been after the 3 implosion? Was Kendall Coffey called -- 4 A I think that they did hire him after the 5 implosion, but that had nothing to do with what I was 6 thinking about. 7 Q All right. Well, what did you -- what were 8 you thinking about? 9 MR. KING: Well, be careful what you're 10 thinking about doesn't tread on -- on privilege. 11 A I understand. I think that -- all right. I 12 feel comfortable saying this. RRA hired Kendall Coffey 13 to answer one specific issue. RRA was the client. 14 Kendall Coffey -- 15 MR. KING: Well, I think that is getting too 16 far into it. The bottom line is, RRA hired Coff 17 Kendall Coffey and that was the basis for our 18 assertion of privilege earlier. 19 MR. HADDAD: Okay. 20 MR. KING: All right. 21 BY MR. HADDAD: 22 Q Nothing to do with 23 A No. 24 Q In the Rodriguez's cases? 25 A No. Empire Legal Support. Inc. Page: 225 EFTA01089164 Bradley J. Edwards taken on 10/10/2013 1 Q Did -- well, did they ever show you the 2 running expenses, by the way, of what your cost is? 3 A What they 4 Q You know, whoever ran the books at RRA? I 5 mean Rothstein didn't know what was going, Adler was 6 just taking all the money. 7 A At the time when I was at RRA, no. 8 Q Okay. 9 A Subsequently, yes. 10 Q Subsequently? 11 A Way after. 12 Q But that would have been by the trustee and 13 bankruptcy or someone like that -- 14 A Right. That's how -- 15 Q -- corroborating whether or not the money was 16 valid, where it went, how it went and so forth? 17 A Correct. And the total costs on all of the 18 cases was $203,000 for all the cases combined. 19 Q That's what you said before. 20 A I think that I said it was greater than that 21 before. But once we did the closeout sheets, the exact 22 number was $203,000. 23 Q Let me ask you this, just for the hell of it. 24 How much did you spend before you went to RRA working up 25 these case, approximately? Empire Legal Support. Inc. Page: 226 EFTA01089165 Bradley J. Edwards taken on 10/10/2013 1 A I don't know, but it was less than $25,000, 2 you were right in the last motion, I don't know exactly 3 what it was though. 4 Q Okay. So at least not that they should, you 5 went with a big firm and they had the money to 6 produce -- the ability to prosecute these cases? 7 A Any cases, right. 8 Q Yeah, I mean, I understand, you didn't have 9 any other cases -- oh, yeah, you did. 10 A Right, I did. 11 Q Okay. Did you share info with 13 A I shared public information with her. 14 Q Is that that 15 A Right. 16 Q Because they didn't put down who it was and 17 I'm asking questions. 18 A Right. 19 Q Okay. 20 MR. GOLDBERGER: Well done, way to figure it 21 out. 22 MR. HADDAD: Huh? 23 MR. GOLDBERGER: Way to figure it out. 24 MR. HADDAD: I never met somebody named 25 unless she was dancing down in a place in Empire Legal Support. Inc. Page: 227 EFTA01089166 Bradley J. Edwards taken on 10/10/2013 1 Mexico when I was down there drinking. Okay. 2 Wasn't that Cafe in -- down in , town of 4 MS. COLEMAN: Yes. 5 MR. HADDAD: Marty Robbins -- beautiful -- 6 yes. Okay. 7 BY MR. HADDAD: 8 Q While you were there with RRA living the high 9 life, as it were, did you make political contributions 10 at all? 11 A No. 12 Q Okay. Did they make contributions in your 13 name? Did you ever become aware whether or not Scott 14 was making contributions in your name, because he made a 15 contribution in tons of people's names and covered it 16 up? 17 A Not that I know of. 18 Q Okay. 19 A No one's ever told me that to this date. 20 Q Because you look like a Republican, I thought 21 maybe that they would have done that. Did you have 22 contact with the U.S. Government in this -- Epstein 23 civil cases? 24 A What? 25 MR. HADDAD: I don't understand the question, Empire Legal Support. Inc. Page: 228 EFTA01089167 Bradley J. Edwards taken on 10/10/2013 1 you ask it. I know it's only supposed to be one 2 witness, but I can't -- 3 MR. GOLDBERGER: I can't. 4 MR. HADDAD: I can't answer them, I don't want 5 to ask that question. 6 All right, anybody got anything else? 7 Give me one second, because we can't have you 8 back. 9 MR. GOLDBERGER: Let me -- would it make it 10 easier, guys, if -- if you could just step out for 11 one second. I think that's going to end the depo, 12 I just need to have a consultation. 13 THE WITNESS: Anything that is going to end 14 the depo I will do. 15 MR. GOLDBERGER: I hear you. I hear you. 16 MR. HADDAD: Are you going to read? 17 THE VIDEOGRAPHER: The time is 1:57 P.M. We 18 are now coming off the video record. 19 (Whereupon, a break was taken.) 20 THE VIDEOGRAPHER: The time is now 2:00 P.M. 21 We are back on the video record. 22 MR. HADDAD: It's two o'clock. Your Rolex 23 doesn't keep very good time, Bill. 24 MR. GOLDBERGER: It is now two o'clock, 2:01. 25 MR. HADDAD: Oh, it was a sweep secondhand, I Empire Legal Support. Inc. Page: 229 EFTA01089168 Bradley J. Edwards taken on 10/10/2013 1 didn't see it that well. 2 BY MR. HADDAD: 3 Q All right. You entered into settlement 4 agreements with various people that Epstein signed, 5 correct? 6 A Right. 7 Q Okay. Were any changes to the settlement 8 agreements ever made, as far as distributions after they 9 were signed, did the girls get what they said they were 10 going to get? 11 A Right. 12 Q The agreements were fulfilled? 13 A Yes. 14 Q In every single way? 15 A In every single way. I don't understand the 16 question, but yes. 17 Q I understand that. 18 A Settlement agreements, what was said in the 19 settlement agreement. 20 MR. KING: Is somebody calling in? 21 MR. INDYKE: Hit the green button. 22 MR. GOLDBERGER: I got it. I got it. 23 BY MR. HADDAD: 24 Q Go ahead. 25 MR. GOLDBERGER: We got you back now? Empire Legal Support. Inc. Page: 230 EFTA01089169 Bradley J. Edwards taken on 10/10/2013 1 MR. EPSTEIN: Yes. 2 MR. GOLDBERGER: Okay. 3 BY MR. HADDAD: 4 Q Okay. So there were no changes to the 5 settlement agreements. 6 The other thing is, have you had any contact 7 with lately in the last 8 year, say? 9 A . Yes. 10 Q And are you still maintaining contact with her 11 regarding the litigation? 12 A What litigation? 13 Q Well, the CVRA? 14 A We have no choice, but we are engaged in 15 litigation with the Government and she is one of the 16 people that participated. 17 Q All right. And so you maintain contact with 18 her regarding that litigation? 19 A Right. 20 Q All right. Are you meeting with her at all in 21 the possibility of prosecuting or re-prosecution and 22 discussing that with her, or just the -- 23 A That has never been discussed. 24 Q Okay. Now, lastly -- 25 MR. GOLDBERGER: Go ahead. Empire Legal Support. Inc. Page: 231 EFTA01089170 Bradley J. Edwards taken on 10/10/2013 1 MR. HADDAD: Go ahead. No, tell me. 2 (conferring). Oh. 3 BY MR. HADDAD: 4 Q Have you discussed with her this case that you 5 are doing right now -- 6 A No. 7 Q -- involved in this case? 8 A I don't believe so. 9 Q Do you know if she runs over to the Courthouse 10 to look at the docket, what do you call that, PACER? 11 That's Federal, whatever you call the docket. 12 A I have no idea. 13 Q All right. Let's go back to the last thing I 14 wanted to do and I had forgotten about it, was damages. 15 What are you -- what are you still claiming for damages, 16 other than the lost time, anything else? 17 A It hasn't changed since last time. 18 Q I don't remember what I asked you, I don't 19 remember what you said. 20 MR. KING: You got into a very detailed 21 reputation. 22 MR. HADDAD: Is he still -- he is not claiming 23 reputation anymore. 24 BY MR. HADDAD: 25 Q You have a reputation better than ever. What Empire Legal Support. Inc.. Page: 232 EFTA01089171 Bradley J. Edwards taken on 10/10/2013 1 are you claiming? 2 MR. KING: You asked the same question last 3 time. 4 MR. HADDAD: I don't remember it. I thought 5 the last time we said you -- taking time away from 6 your family and that stuff for economical -- 7 MR. KING: He went -- but he went into great 8 detail, as you might recall, where he talked about 9 the fact that, you know, he would go to the -- he 10 would go over to the Courthouse and lawyers would 11 look at him, and his reputation was -- was impacted 12 by that and what -- what he was able to do to 13 truncate that later on. 14 MR. HADDAD: You're right. 15 BY MR. HADDAD: 16 Q Do you still maintain that stuff? 17 A As I said then, have I done a good job at 18 resurrecting whatever damage was done? Yes, I did. Is 19 there -- is there -- 20 Q What was the -- what was the impact to you 21 from supposed -- and I don't mean that pejoratively, 22 damage to your reputation by being sued for being with 23 Rothstein? 24 A Uh, what -- for being falsely accused of 25 committing crimes I didn't accuse by Epstein. Empire Legal Support. Inc. Page: 233 EFTA01089172 Bradley J. Edwards taken on 10/10/2013 1 Q You are not accused of committing a crime, you 2 were sued for -- in civil court. 3 A I was sued for fraud, I was sued for RICO. 4 Q Civil. That's civil. There's civil -- you 5 know what a civil RICO -- that's not a crime, it could 6 also be a civil -- 7 A Civil RICO is based on criminal violations. 8 Q I'm not going to argue, of course it is. 9 MR. KING: Hold on, hold on, objection. It is 10 a nice colloquy to have with him, but he hasn't 11 answered your question yet. 12 MR. HADDAD: All right. 13 BY MR. HADDAD: 14 Q What's your damages? What damages are you 15 maintaining today if we go to trial next week, two 16 weeks? 17 MR. KING: Objection, he has answered it 18 extensively in the last deposition. 19 But go ahead. 20 BY MR. HADDAD: 21 Q Are you adopting -- let me put it this way, 22 we'll go from there. 23 Are you adopting the answers in your last 24 deposition as still being the damages that you maintain 25 today? Empire Legal Support. Inc. Page: 234 EFTA01089173 Bradley J. Edwards taken on 10/10/2013 1 A Yes. 2 MR. HADDAD: Any -- all right. 3 MS. COLEMAN: You have any -- can I ask the 4 question? 5 MR. HADDAD: Yeah. 6 MR. GOLDBERGER: It will get us out of here 7 quicker if you let Tonya. 8 MS. COLEMAN: Okay. 9 CROSS-EXAMINATION 10 BY MS. COLEMAN: 11 Q Do you have any documentation that would 12 support the claim of financial loss with respect to any 13 injury to your reputation or your emotional distress, 14 which you claimed previously? 15 A I never made a claim for financial loss in 16 this case. And -- 17 Q Do you have any -- 18 A -- emotional distress is what I testified 19 about last time, is that it is a matter of who it is 20 that is suing me and the level of stress and anxiety 21 that has gone along with that is certainly extreme. And 22 I have been and remain to be in fear for my safety 23 because of him. So will that -- is that still the same? 24 Yes, it's the same now, was then, you know. 25 Q How do you plan to quantify that? Empire Legal Support. Inc. Page: 235 EFTA01089174 Bradley J. Edwards taken on 10/10/2013 1 THE WITNESS: Should I answer this, I mean -- 2 MR. KING: Hold on, hold on a second. 3 THE WITNESS: I can answer it with a question, 4 maybe. 5 MR. KING: No, no. 6 THE WITNESS: Okay. 7 MR. KING: Ultimately, the quantification is 8 up to a jury. But it's fair -- it would be fair to 9 inquire. He can't put a number on it and it's 10 unfair to ask witnesses to put a number on a matter 11 that a jury is going to respond to and I would 12 object if that's the intent of your question. 13 MS. COLEMAN: It is not. 14 MR. KING: If -- if there is a proper more 15 precise question, I will let him answer. But that 16 question calls for -- that's an inappropriate 17 question, in that it call -- it asks for what he 18 thinks the number might be or what a jury might 19 evaluate it to be. At least, arguably, it could be 20 construed that way. 21 MS. COLEMAN: I mean -- 22 MR. KING: If you -- if the question is, 23 are -- are there any documents that you are 24 introducing, documentation to support a particular 25 claim, I believe he has already answered those Empire Legal Support. Inc. Page: 236 EFTA01089175 Bradley J. Edwards taken on 10/10/2013 1 questions last time and I believe that the 2 discovery was directed to that, but I could be 3 wrong on that. So within that -- within those 4 confines, if you want to restate the question, go 5 ahead. 6 BY MS. COLEMAN: 7 Q We established last time that with respect to 8 your emotional distress and any kind of mental anguish 9 damages, you never , correct? 11 A It's still the same. 12 Q So in forms of any type of evidence, physical 13 demonstrative evidence, other than testimony of other 14 people, do you have anything upon which you are relying 15 or asserting that claim of damages? 16 A Outside of testimony, are there any documents, 17 no. 18 Q The same holds true with injury to reputation. 19 You said last time that you listed people such as Russ 20 Adler, Earleen Cote and I believe a former judge, I 21 forget off the top of my head, as people who would 22 testify as to the injury of your reputation; is that 23 correct? 24 A Right, I don't -- I don't know what you -- 25 what you would mean by documentation to support that. Empire Legal Support. Inc. Page: 237 EFTA01089176 Bradley J. Edwards taken on 10/10/2013 1 If newspaper articles that were printed after the filing 2 of the claim against me is something that would support 3 that, then I guess to that extent, yes, but if you are 4 asking about medical documents or anything like that, 5 then the answer would be no. I'm not exactly sure what 6 you are getting at but I -- 7 Q Well, for example, you are claiming your 8 reputation was injured. 9 A Right. 10 Q And based on the elements of proof required to 11 prove injury to damage to reputation, there are certain 12 factors that you must meet. 13 A Right. 14 Q I'm asking if you have any physical 15 documentation or any you've objected to all your 16 financial information, so I guess my question in plain 17 English is: How are you going to prove that you have 18 any kind of pecuniary -- pecuniary loss as a result of 19 an injury to your reputation if we don't have any 20 documents to back that up? 21 A I have not claimed an economic loss as a 22 result of my reputation. I haven't. And the only thing 23 that I can say to answer your question is, I know who 24 has hired me. I will never know who would have hired me 25 but elected not to because of what it was that they Empire Legal Support. Inc. Page: 238 EFTA01089177 Bradley J. Edwards taken on 10/10/2013 1 read. So therefore, I have not had a phone call where 2 somebody has said, hey, Brad, I was going to hire you 3 but I read this and, so, therefore, I'm not, and I am 4 hiring some other person, which is the only context in 5 which that could ever arrive. 6 Q But have you always advertised Jeffrey Epstein 7 on your firm Web site since you guys founded Farmer 8 Jaffe? 9 MR. KING: All right. Look, I'm going to 10 object. This is repetitious and now we are 11 getting -- we are getting to other lawyers asking 12 questions well beyond. 13 MR. HADDAD: All right, fine. 14 BY MR. HADDAD: 15 Q When was the last time you talked to , by 16 the way, {SIC}? 17 A I don't I don't remember. 18 Q Within the last month? 19 A No. 20 Q Okay. And I had one good question and it 21 escapes me. 22 A It's on your hand. 23 Q No, that wasn't the one that was on my hand. 24 Uh, It was on damages, I will worry about it later. One 25 second. Empire Legal Support. Inc. Page: 239 EFTA01089178 Bradley J. Edwards taken on 10/10/2013 1 MR. HADDAD: Huh? 2 MR. GOLDBERGER: The safety stuff, he says he 3 got some -- 4 MR. HADDAD: Oh, yeah, yeah, yeah. 5 BY MR. HADDAD: 6 Q How many bodyguards have you hired for your 7 safety? 8 A I haven't hired bodyguards. 9 Q Have you changed -- have you changed your 10 place of living, hiding in an apartment, in a 11 safe-house, witness protection? 12 A Not in witness protection. 13 Q Has anybody made any threats to you, 14 surveilled you, followed you? 15 A Yes. 16 Q Now, recently? 17 A Well, I don't know about recently whether they 18 have or have not. I know that in the past, people did. 19 Q For purposes of -- you don't know what 20 purposes for -- for preparing for litigation, like 21 people do, you know, with those videotapes like the guys 22 who said they got bad legs and they play golf when no 23 one is looking? 24 A Right. There is a purpose behind that 25 surveillance. Empire Legal Support. Inc. Page: 240 EFTA01089179 Bradley J. Edwards taken on 10/10/2013 1 Q Yeah. 2 A If you are making a claim that somebody during 3 2009 was somehow conducting some bad discovery against 4 you and that forms the basis of a lawsuit, then how -- 5 how in the world would performing the surveillance on 6 that person in 2010 go to proving that case? It's only 7 for the purposes of intimidation, that's it, period. 8 Q Well, if -- if they are going to intimidate 9 you, they wouldn't be surveilling you surreptitiously so 10 that you are not -- 11 A I saw people. 12 Q Saw people, you don't know who it is. It 13 might -- it might -- you know do you know it was from 14 Epstein? 15 A Oh, yeah. 16 Q How? 17 A Well, I told my investigator, hey, this is who 18 was following me. And within days, he was also followed 19 and he learned the identity of the investigator and it 20 was somebody that was used by Epstein. 21 Q Who was the investigator? 22 A Who was the investigator that I talked to? 23 Q No. Who was the first -- the investigator, 24 probably somebody used by Epstein? 25 A I don't -- I don't remember. Empire Legal Support. Inc. Page: 241 EFTA01089180 Bradley J. Edwards taken on 10/10/2013 1 Q Well, I thought something might -- I might 2 remember if somebody was following you. Was it a 3 private investigator that was following you? 4 A Yeah. 5 Q Isn't that what private investigators do, 6 follow people? 7 A At somebody else's direction, yes. 8 Q Okay. I mean, it wasn't like he sent two 9 goons from East Mulberry Street down to follow you. 10 A I don't know -- 11 Q You know where Mulberry Street is, don't you? 12 A No. 13 Q In little Italy. 14 A Okay. 15 Q Nobody from Little Italy -- I mean, you know, 16 Guido and his buddies didn't come and follow you, it was 17 just a private investigator? Yes? 18 A To the best of my knowledge. 19 Q Okay. 20 A I don't know. 21 Q I don't have anything else. Thank you. 22 MR. HADDAD: Anybody have anything? Can I 23 finish? 24 MR. GOLDBERGER: Yes, you can wrap it up. 25 MR. HADDAD: Thank you. Empire Legal Support. Inc. Page: 242 EFTA01089181 Bradley J. Edwards taken on 10/10/2013 1 MR. KING: Can we determine that this -- this 2 deposition is concluded? 3 MR. HADDAD: Yes. 4 MR. KING: All right. Thank you, sir. 5 THE VIDEOGRAPHER: The time is 12:00 P.M We 6 are now coming off the video record. This is the 7 end of Tape No. 3. 8 (Thereupon, a discussion was had off the 9 record.) 10 THE REPORTER: Do you want to read this? 11 THE WITNESS: Oh, I can't wait. 12 MR. KING: Yeah, he will read. Do you want to 13 go back on the deposition. He will read. 14 THE REPORTER: And do you want one if this 15 ordered? 16 MR. HADDAD: I can't afford it. 17 MS. COLEMAN: I will take it. 18 THE REPORTER: Do you want a copy of the 19 transcript? 20 MR. KING: Yeah. 21 (Thereupon, a discussion was had off the 22 record.) 23 (Witness excused.) 24 (Thereupon, Plaintiff's Exhibit Nos. 1 and 2 25 were marked for identification.) Empire Legal Support. Inc. Page: 243 EFTA01089182 Bradley J. Edwards taken on 10/10/2013 (Deposition was adjourned at 2:30 P.M.) AND FURTHER DEPONENT SAITH NOT SIGNATURE OF WITNESS STATE OF FLORIDA BROWARD COUNTY SUBSCRIBED AND SWORN to before me this day of , 2013 at Broward County, Florida. Notary Public, State of Florida at Large Commission No: My Commission Expires: Empire Legal Support. Inc. Page: 244 EFTA01089183 CERTIFICATE OF OATH STATE OF FLORIDA COUNTY OF BROWARD I, the undersigned authority, certify that BRADLEY EDWARDS personally appeared before me and was duly sworn on the 10th day of October, 2013. Witness my hand and official seal this 24th day of October, 2013. Wendy Roberts Registered Professional Reporter Notary Public, State of Florida at Large Commission No.: My commission expires: March 29, 2016 EFTA01089184 CERTIFICATE STATE OF FLORIDA, ) COUNTY OF BROWARD. ) I, WENDY ROBERTS, Registered Professional Reporter and Notary Public in and for the State of Florida at Large, do hereby certify that the foregoing testimony was taken before me; that the witness was duly sworn by me; and that the foregoing pages constitute a true record of the testimony given by said witness. I further certify that I am not a relative or employee or attorney or counsel of any of the parties, or a relative or employee of such attorney or counsel, nor financially interested in the action. Under penalties of perjury, I declare that I have read the foregoing certificate and that the facts stated herein are true. Signed this 24th day of October, 2013. WENDY ROBERTS, Registered Professional Reporter EFTA01089185 EMPIRE LEGAL SUPPORT, INC. 401 EAST LAS OLAS BOULEVARD, STE 1400 FORT LAUDERDALE, FL 33301 To: BRADLEY EDWARDS, ESQUIRE Farmer Jaffe Weissing Edwards Fistos Lehrman 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Re: CASE NO.: 502009CA040800XXXXMBAG Dear BRADLEY EDWARDS, Your deposition taken in the above entitled cause is now ready for signature. Please come to this office and sign same; or if you wish to waive the signing of the deposition, please so advise. If this deposition has not been signed within 30 days of today's date, October 24th, 2013, we shall consider your signature waived. Your prompt attention in this matter is appreciated. Sincerely, Wendy Roberts, RPR EFTA01089186 DEPOSITION ERRATA SHEET Our Assignment No. 12217 Case Caption: JEFFREY EPSTEIN vs. SCOTT ROTHSTEIN DECLARATION UNDER PENALTY OF PERJURY I declare under penalty of perjury that I have read the entire transcript of my Deposition taken in the captioned matter or the same has been read to me, and the same is true and accurate, save and except for changes and/or corrections, if any, as indicated by me on the DEPOSITION ERRATA SHEET hereof, with the understanding that I offer these changes as if still under oath. Signed on the day of , 2013. BRADLEY EDWARDS EFTA01089187 DEPOSITION ERRATA SHEET Page No. Line No. Change to: Reason for change: Page No. Line No. Change to: Reason for change: Page No. Line No. Change to: Reason for change: Page No. Line No. Change to: Reason for change: Page No. Line No. Change to: Reason for change: Page No. Line No. Change to: Reason for change: Page No. Line No. Change to: Reason for change: SIGNATURE: DATE: BRADLEY EDWARDS EFTA01089188 DEPOSITION ERRATA SHEET Page No. Line No. Change to: Reason for change: Page No. Line No. Change to: Reason for change: Page No. Line No. Change to: Reason for change: Page No. Line No. Change to: Reason for change: Page No. Line No. Change to: Reason for change: Page No. Line No. Change to: Reason for change: Page No. Line No. Change to: Reason for change: SIGNATURE: DATE: BRADLEY EDWARDS EFTA01089189