EFTA01126110

Page 3 IN THE CIRCUIT COURT OF THE INDEX 15TH JUDICIAL CIRCUIT, IN AND WITNESS: Page FOR PALM BEACH COUNTY, FLORIDA BRADLEY EDWARDS CASE NO.: 5021109CA040800XXXXMBAG Direct Examination by MR. HADDAD 4 EXHIBITS JEFFREY EPSTEIN, PLAINTIFFS: Plaintiff, EXHIBITS: Description Page vs. No. l pan of Farmer, Jaffe, Weissing Web site 93 SCOTT ROTHSTEIN, individually, No. 2 from the Web site 93 and BRADLEY J. EDWARDS, No. 3 from the Web site 93 individually, No. 4 from the Web site 93 Defendants. No. 5 from National Trial Lawyers Web site 93 / No. 6 from AVVO, A-V-V-O 93 No. 7 from the Farmer, Jaffe, Weissing Web site 93 No. 8 from lawyers.com 93 VIDEOTAPE DEPOSITION OF BRADLEY EDWARDS No. 9 from for 40 under 40 93 No. 10 & II interrogatories directed to 93 May 15th, 2013 Mr. Edwards and responses 10:00 A.M. - 12:20 P.M. No. 13 transcript of the sentencing proceedings 93 for Alfredo Rodriguez 401 East Las Olas Blvd., Suite 1400 No. 14 plea agreement between the United States 93 Fort Lauderdale, FL and Alfredo Rodriguez. Stenographically Reported By: WENDY ROBERTS, RPR Notary Public, State of Florida Empire Legal Support, Inc. Fort Lauderdale Office Phone: (954)241-1010 Page 2 Page 4 APPEARANCES: 1 Videotape Deposition taken before Wendy Roberts, ATTORNEY(S) FOR MR. EPSTEIN: IONIA HADDAD COLEMAN. ESQUIRE 2 Registered Professional Reporter and Notary Public in Tonja Haddad. PA 3 and for the State of Florida at Large, in the above 315 SE 7th St Ste 301 Fon Laudeidak, Florida 333013158 4 cause. Phonc 5 Fax: E-Mail: 6 THE VIDEOGRAPHER: We are now on the video FRED H 7 Fred Haddad PA record. Today's date is May 15th, 2013. The time I Financial PH Ste 2612 8 is 10:17 M. This is the video deposition of Fon Lauderdale, Florida 333940061 Piton 9 Bradley Edwards taken in the matter of Jeffrey Fax: 10 Epstein v. Scott Rothstein, Case E-Mad: JACK GOLDGERGER, ESQUIRE 11 No. 502009CA040800XXXXMBAG. Atterbury Goldberger Et Al 12 We're located at 401 East Las Olas Boulevard, 250 S Australian Ave Ste 1400 Wear Palm Bead, Acrid, 334015015 13 Fort Lauderdale, Florida. The court reporter is Phone: 14 Wendy Roberts, the videographer is Anthony Estevez, Fax: E-Mail: 15 both with Empire Legal. ATTORNEY FOR BRADLEY EDWARDS: 16 Would counsel please state their appearances WILLIAM KING. ESQUIRE Searcy Denney Scarola Et Al 17 for the record. 2139 Palm Beach Lakes Blvd 18 MR. KING: William King. Searcy Denncy Scarola West Palm Beach. Ronda 334096601 Phone: 19 Bamhan & Shipley for Mr. FAwards. Fax: 20 MR. HADDAD: Fred Haddad on behalf ofleff 21 Epstein. ALSO PRESENT: JEFF EPSTEIN, PLAINTIFF 22 MR. GOLDBERGER: Jack Goldberger, Atterbury, DEBRA FEIN, LAW CLERK 23 Goldberger & Weiss on behalf of Jeffrey Epstein. 24 MS. HADDAD COLEMAN: Tonja Haddad Coleman on 25 behalf ofJeffrey Epstein. 1 (Pages 1 to 4) EMPIRE LEGAL SUPPORT, INC. (954) 241-1010 Electronically signed by Wendy Roberts Electronically signed by Wendy Roberts Electronically signed by Wendy Roberts e96817a7-3aa9-4fcc-b5a9-1e7a13379799 EFTA01126110 Page 5 Page 7 1 THE COURT REPORTER: Would you raise your hand 1 division? 2 to be sworn in, please. Do you solemnly swear the 2 A Not long. I don't remember. 3 testimony you are about to give in this case will 3 Q You left to go with which firm? 4 be the truth, the whole truth and nothing but the 4 A Kubicki Draper. 5 truth, so help you God? 5 Q Where are they located? 6 THE WITNESS: Yes. 6 A Fort Lauderdale. 7 Thereupon: 7 Q What kind of work did you do? 8 BRADLEY EDWARDS 8 A Insurance defense. 9 having been first duly sworn or affirmed, was 9 Q And how long did you stay with them? 10 examined and testified as follows: 10 A A couple years. 11 DIRECT EXAMINATION 11 Q All right. Then you went out on your own? 12 BY MR. FIADDAD: 12 A Correct. 13 Q State your name, please. 13 Q And then you started a plaintiffs' firm, 14 A Brad Edwards. 14 correct? 15 Q All right. And is that your practicing name 15 A Yes. 16 or your legal name? 16 Q And I know the whole story, when you met 17 A My practicing name. 17 Russell Adler, et cetera, at the gym and all of that so 18 Q All right. You're Bradley Edward, what's your 18 we don't need to go through that again, you ended up 19 middle name? 19 with RRA for a period of time, correct? 20 A Bradley James Edwards. 20 A True. 21 Q Okay. You're how old? 21 Q All right. And of course this is old home 22 A M 22 week here in this building. as a matter of fact, I 23 Q Okay. You were admitted to practice when? 23 forgot, correct? 24 A 2002. 24 A The same building. 25 Q All right. So that's 13 years you have been 25 Q Same building. All right. And then one day Page 6 Page 8 1 practicing -- no, II years? 1 in October of -- was it 2009? 2 A Yes. 2 A Yes. 3 Q All right. And my recollection is you gave a 3 Q Halloween weekend, correct? 4 deposition in 2010, correct? 4 A Yes. 5 A Correct. 5 Q All right. You were advised that the firm had 6 Q A couple hundred pages of depositions? 6 no longer the ability to function. 7 A Correct. 7 A Correct. 8 Q All right. And I am not here to reinvent the 8 Q Yourself, I know Gary Farmer was with you at 9 wheel or reinvent the deposition. I know what you said 9 RRA, was Man Weissing there too? 10 then. \Ve've had three years elapse since that time so I 10 A Yes. 11 just want to catch up a little bit to start with. You 11 Q And who else, Scott Lehrman, is that his name? 12 spent some time in the State Attorney's Office, correct? 12 No, not that one. Who else was there with you? Let me 13 A Correct. 13 do it that way, it's easier. 14 Q How many years? 14 A I think there were 60 lawyers there with me. 15 A Roughly three. 15 Q No, no, lam talking about in your unit of 16 Q All right. And when you left the State 16 torts lawyers, that you can recall? 17 Attorney's Office, were you a division prosecutor, 17 A In my unit it was Russ Adler -- 18 special units prosecutor? 18 Q Right 19 A Division prosecutor. 19 A -- myself, Scott Goldstein. 20 Q Which division were you in when you left, if 20 Q That's it. Okay. 21 you recall? 21 A Seth Lehrman, Tami Wolfe. I think there were 22 A Judge Gates. 22 others, I can't really remember. 23 Q Okay. And were you the lead? 23 Q All right. Farmer was not part of the firm at 24 A Yes. 24 the time? 25 Q And how long had you had the lead in that 25 A He was part of the firm but he wasn't a 2 (Pages 5 to 8) EMPIRE LEGAL SUPPORT, INC. (954) 241-1010 Electronically signed by Wendy Roberts Electronically signed by Wendy Roberts Electronically signed by Wendy Roberts eilleel7a7-3aa9-4fice-b5a9-leaf3379799 EFTA01126111 Page 9 Page 11 1 personal injury tort lawyer. He did mainly qui tam and 1 A You are asking me a bunch of questions. 2 class action, which was a separate division of RRA. 2 Q Nevermind, let me just -- 3 Q All right. Now, you left that firm obviously 3 A But I think we all know -- 4 for the obvious reason, there was no firm, and you guys 4 Q Yeah, let me just go from there. All right. 5 started your own firm; would that be fair? 5 Let's start — let's go backwards from 20 -- let's start 6 A I started my own firm with some of the other 6 backwards. It's now 2013, correct? 7 people that were previously at RRA, correct. 7 A Yes. 8 Q All right. And my recollection is you arc an 8 Q Do you have any active cases involving Jeffrey 9 association of P.A.s, correct? 9 Epstein? 10 A Yes. 10 A Yes. 11 Q P.A., that's another association of P.A., am I 11 Q How many? 12 correct? 12 A This one that we're here for today. 13 A The current firm that I'm at? 13 Q No, I'm talking -- okay, yes, this one and 14 Q Yeah, yeah. 14 what else? 15 A Yeah. 15 A And another case that I would say involves 16 Q You arc Bradley Edwards, P.A., as part of the 16 him, in that he has intervened in the case and it's a 17 rest of the firm P.A., correct? 17 Federal Court matter relating to some of the victims 18 A You have the right idea. 18 that he molested that is directly against the United 19 Q Huh? 19 States Government. 20 A You have the right idea. 20 Q And that is your victims' rights case? 21 Q Thank you. 21 A That's one way to characterize it for sure. 22 MR. GOLDBERGER: He's an LLC. 22 Q Okay. Well, that's what you -- you filed a 23 MR. HADDAD: Huh? 23 lawsuit, correct, against the United States? 24 MR. GOLDBERGER: He's an LLC, that's what he's 24 A Under the Crime Victims' Right Act, correct. 25 trying to tell you. 25 Q Okay. And that lawsuit is still pending? Page 10 Page 12 1 A Yeah, but you are on the right track, I got 1 A Yes. 2 you, we understand each other. 2 Q Is it being actively litigated? 3 MR. HADDAD: We are the same, Jack. You know, 3 A Yes. 4 us poor sole practitioners don't get along with 4 Q And is there any other co-plaintiffs in that 5 that sort of thing, you know. We are from the old 5 case, if that's the right word, besides yourself? 6 school, we don't need to keep books. 6 A I'm not a plaintiff in the case. 7 BY MR. HADDAD: 7 Q Well, an intervener, are there any other 8 Q So at any rate, you became with that firm, 8 co-interveners or 9 correct? 9 A I'm not an intervener. 10 A Yes. 10 Q What are you? 11 Q All right. Now, you brought with you, and I'm 11 A An attorney representing the plaintiffs. 12 not going through all of this other stuff, the Epstein 12 Q Okay. How many plaintiffs are there? 13 cases, correct? When you went to RRA, that was part of 13 A In that case there are two. 14 the reason Russell was asking you to come in? 14 Q Are there any other cases that you are 15 MR. KING: I'm going to object because this is 15 involved with or sharing information with, without 16 repetitious. 16 getting into what's being shared, and lawsuits pending 17 MR. HADDAD: I understand that. 17 against Jeffrey Epstein at this time? 18 MR. KING: It was all done in his first depo. 18 A Other than what I just described, no. 19 I'm giving you a little leeway here so -- 19 Q Okay. And those suits have been pending for 20 MR. HADDAD: Yeah, I understand. I'm just 20 how long? 21 trying to lead into this. I am not trying to go 21 A This one has been pending since November 2009, 22 into that all over again. 22 I believe. 23 BY MR. HADDAD: 23 Q Okay. 24 Q It's just from more of a pointing chip for the 24 A And that lawsuit has been — the Crime 25 deposition, correct? 25 Victims' Rights Act lawsuit has been pending since the 3 (Pages 9 to 12) EMPIRE LEGAL SUPPORT, INC. (954) 241-1010 Electronically signed by Wendy Roberts Electronically signed by Wendy Roberts Electronically signed by Wendy Roberts e96.17a7-3aa9-4fcc-b5a9.107a13379199 EFTA01126112 Page 13 Page 15 1 summer of 2008. I don't know the exact month. 1 for relief in your complaint, correct? 2 Q All right. And is it near resolution? 2 A Correct. 3 A I don't know. 3 Q What does your prayer for relief seek? 4 Q Is -- can you tell me the style of the case? 4 A Do you have the document to show me, maybe 5 A Yes, it's Jane Doe I and Jane Doe II versus 5 that would refresh my recollection, I mean I think that 6 United States of America. 6 we have filed many pleadings and in one we asked for 25 7 Q All right. And the purpose of that lawsuit is 7 prayers of relief. I can't recite them all for you. 8 to do what? 8 Q I don't ask you to recite them word-for-word. 9 A Hold the United States Attorney's Office and 9 Give me a synopsis. You must have an idea since you are 10 Government responsible for violating the rights of the 10 the plaintiffs' lawyer and have been doing this stuff 11 victims in that particular case. 11 for 10 or I I years, give me some idea of what you are 12 Q By entering into a settlement agreement with 12 seeking. 13 Mr. Epstein? 13 A Yeah, I mean, we want a declaration that the 14 A It has nothing to do with Mr. Epstein. He 14 rights were violated, we want some apology-type 15 voluntarily intervened into the case, had something to 15 information coming from the Government. 16 do with discovery that we were trying to get. 16 Q Right. 17 Q All right. 17 A Ultimately, if we got everything that we 18 A I think Roy Black represents him in that. 18 wanted -- I can tell you what my clients want, they want 19 Q Okay. And that's for the -- okay, I will let 19 the non-prosecution agreement, the immunity agreement -- 20 it go at that for just a minute. 20 Q Umm-hmm. 21 The ultimate result of what you are seeking in 21 A -- overturned and for that to allow for 22 it that suit is what? 22 Mr. Epstein to be prosecuted for the crimes that he 23 A Something that compensates the victims. 23 actually commit -- committed against them and that -- 24 Q Financially or otherwise? 24 for which they cooperated with the Government. 25 A I don't believe the Crime Victims' Rights Act 25 Q Okay. And that's been the goal that you have Page 14 Page 16 1 allows for financial recovery. 1 been pursuing since you filed it, in essence, isn't it? 2 Q What -- what recovery does it allow? 2 A That is their main goal, but then, you know, 3 A Well, that's pan of -- that is what that 3 at this point, there are many other possibilities. 4 lawsuit is about, I mean, I think that we have proven 4 Q Does the -- I'm sony, does the successful 5 that there was a violation, now we're at a stage where 5 prosecution, as it were, by you of that case allow for 6 there is an attempt to uncover what Judge Marra believes 6 attorney's fees? 7 is the appropriate remedy for the violation. 7 A I don't believe so. 8 Q All right. 8 Q All right. So are you being compensated for 9 A And I don't know what his result is going to 9 that at this time? 10 be. 10 A Not at all. 11 Q All right. 11 Q You are doing that completely pro bono? 12 A It's going to be a judge-made decision. 12 A Absolutely. 13 Q I'm sony. That lawsuit has been pending 13 Q All right. How many hours would you say since 14 since 2008, you said, correct? 14 2008 you have donated or devoted to that case? 15 A That was the first of all of the lawsuits that 15 A A lot. 16 was filed. 16 MR. KING: I'm going to object, because now I 17 Q All right. 17 think the question of relevancy and materiality of 18 A Yes. 18 this line of questioning is -- is -- 19 Q And like you said, there is still Jane Doe I 19 MR. HADDAD: He has made a -- he has made a 20 and Jane Doe II are still pending? 20 claim for lost time, inability to work, et cetera, 21 A In that case? 21 et cetera, et cetera and his claims for punitive 22 Q Yeah. 22 damages as well as for claims for damages for 23 A Yes. 23 malicious prosecution and for abuse of process. If 24 Q All right. And what does your -- I guess 24 you read his prayers for relief and his answers to 25 since you represent the plaintiffs, you filed a prayer 25 interrogatories and his ability to not work because 4 (Pages 13 to 16) EMPIRE LEGAL SUPPORT, INC. (954) 241-1010 Electronically signed by Wendy Roberts Electronically signed by Wendy Roberts Electronically signed by Wendy Roberts e96e17a7-3aa9-4fcc-b5a9-1e7af3379799 EFTA01126113 Page 17 Page 19 1 of this lawsuit and because of the suit that was 1 A I haven't kept my hours on that case. 2 filed, I think it's totally relevant. 2 Q All right. You have no independent idea of 3 MR. KING: Well, I -- I -- 3 whether it's one hour, a thousand hours? 4 MR. HADDAD: If you want to instruct him not 4 A It's more than one, less than a thousand. 5 to answer, we can take it up before a judge. S Q Okay. How many hearings would you approximate 6 MR. KING: Right. I disagree. 6 you have attended in front of Judge Marra? 7 MR. HADDAD: It's up to you, Mr. King. 7 A Since 2010, you said? 8 MR. KING: I disagree. 8 Q Yeah, let I'm going to let -- go over 9 MR. HADDAD: That's why we have judges. 9 everything in your prior deposition since 2010. 10 MR. KING: I will allow you some -- some 10 A I believe that the answer to that is one or 11 leeway there, but then I'll evaluate it as you go 11 two. I can't remember for sure, but I believe it's only 12 along. 12 one or two hearings that have taken place since my last 13 MR. HADDAD: Can you give me his answers 13 deposition. 14 per diem? 14 Q And representing the Government is whom? 15 BY MR. HADDAD: 15 A It was Marie Villafana and Dexter Lee. 16 Q So I will ask the question again, how much 16 Q And who's doing it now? 17 time — and see what the leeway is — how much time 17 A I don't know. 18 would you say roughly you devoted -- let's -- okay, 18 Q All right. Could you approximate for me the 19 let's call it since to 2010, since your last deposition 19 last time you had a hearing in this case? 20 'til today, approximately? 20 A I think it was 2011. 21 A I don't know. If you showed me the docket on 21 Q All right. 22 that case or something that would help me, then I could 22 A I'm not sure if there were any in 2012, I 23 approximate a little better, but I really don't know. 23 don't believe so. 24 Q All right. Just for -- in your answers to 24 Q All right. So the cast is just a pending 25 interrogatories, you have been obligated to divert — 25 advisement or ruling by Judge Marra, is it just sifting Page 18 Page 20 1 your response was: "To divert time, effort and attention 1 there, is it what? 2 from the productive practice of his profession to defend 2 A Judge Marra has many motions that have been 3 tortious misconduct of Epstein. Every minute the 3 fully briefed on his -- on the table right now and we're 4 verdict -- verdict from his professional pursuits 4 waiting for rulings. That's—.—.—. 5 impeded his ability to advance the claims and interest 5 Q All right. 6 of existing clients and precluded him from taking other 6 MR. HADDAD: Yes, sir (counsel confer outside 7 and additional responsibilities. Time records made 7 the hearing of the reporter.) 8 available in response to Epstein's response, request to 8 BY MR. HADDAD: 9 produce detail, at a minimum, the extent of the 9 Q In fact, there are motions pending right now, 10 diversion he is suffering." 10 correct, you are saying? 11 So you obviously must have been aware of these 11 A Correct. 12 when you produced these and filed these responses to 12 Q Actively pending. So that would stay the time 13 interrogatories. I'm just asking for an approximation. 13 for dismissal for lack of prosecution? 14 A Of what? 14 A I would think so. 15 Q Time spent. 15 Q Well, I think Federal rule is the same as 16 A I produced the time I spent on this case. 16 Civil and State, isn't it? 17 MR. KING: On this case. 17 A Right. 18 A I produced it. 18 Q You've got a certain amount of time to act 19 BY MR. HADDAD: 19 upon it. It was dismissed previously for lack of 20 Q I un -- on this case, I never -- I'm talking 20 prosecution, correct? 21 about the other case, the -- the -- the Federal case, 21 A I don't remember it being dismissed. I think 22 approximately how much time have you spent? 22 they filed a motion to dismiss. 23 A Show me a docket or something and I will help 23 Q Okay. 24 you out there. I just don't know. 24 A I don't really remember procedurally how that 25 Q No -- no, I'm just -- 25 really worked. 5 (Pages 17 to 20) EMPIRE LEGAL SUPPORT, INC. (954) 241-1010 Electronically signed by Wendy Roberts Electronically signed by Wendy Roberts Electronically signed by Wendy Roberts e96617a7.3849-4fcc-b5a9-197af3379799 EFTA01126114 Page 21 Page 23 1 Q Was that the Government who filed it or was it 1 with you from RRA that were your cases besides the 2 someone intervening who filed it? 2 three, you know, LM and all of that stuff, those three, 3 A It wasn't someone intervening. It was either 3 and stuff that's pending in the case right now, which 4 the Government filing a motion or the Court sua sponte 4 would be five total -- four or five total cases, 5 issuing -- I don't remember it being an order, but I 5 correct? 6 remember seeing some notification that it was going to 6 MR. KING: Objection, relevancy, materiality. 7 be dismissed or something along those lines. 7 MR. HADDAD: I'm tying it up to his damages 8 Q All right. I think since I started with this, 8 claim for loss of reputation, et cetera. 9 with the diversion of time, effort, when you started the 9 MR. KING: Immaterial. 10 law firm in 2000 -- well, 2009 you started the law firm, 10 MR. HADDAD: You can instruct him not to 11 correct, October of 2009, your deposition was in 11 answer. You want -- 12 February of 2010; as I recall, correct? 12 MR. KING: Not yet. Not yet, but um -- 13 A Okay. I'm taking your word for it. 13 MR. HADDAD: Go ahead. 14 Q Well, do you think I would bull — I would 14 MR. KING: -- if you are going to try to get 15 make a misrepresentation to you? 15 into every case with him -- 16 A Not intentionally. 16 MR. HADDAD: Not -- not even remote -- not 17 Q Well, I just did because it was March 23rd. 17 even remotely, Mr. King. 18 A There we go. 18 MR. KING: Okay. 19 Q I apologize so—.—.—. I forgot we have a video 19 MR. HADDAD: I have been doing this a long 20 recording. I almost slipped and thought I was in 20 time too. All right. 21 trial — in criminal court. 21 Go ahead. 22 At any rate, March 23rd, so that would have 22 MR. KING: Go ahead. 23 been five months after you went into practice, correct? 23 A Tell me your question again. 24 A Five months after we started -- 24 BY MR. HADDAD: 25 Q You started the firm? 25 Q Yeah, how many cases did you take with you? Page 22 Page 24 1 A -- our current law firm. 1 A I don't remember. 2 Q All right. Now, when RRA imploded, you 2 Q All right. Would you -- well, let me look 3 started the current firm, were all the named partners in 3 here. One of your claims, I can't remember what I did 4 that firm members of RRA? 4 with them but I read them someplace. Oh, yeah, the 5 A Yes. 5 damage that you suffered is emotional distress, 6 Q Farmer, Jack. Matt Weissing had been over 6 embarrassment, mental anguish, humiliation, loss of 7 there? 7 reputation and standing in the community, loss of value 8 A Yes. 8 of time expended in defense of and responding to the 9 Q All right. And you all regrouped. Where are 9 abuse, correct? That's what you said in your answers to 10 your offices located now? 10 interrogatories; do you want to see them? 11 A Andrews Avenue. 11 A Sure. 12 Q Where? 12 MR. KING: Which number is that? 13 A 425. 13 A Yeah. It's an interrogatory signed May 26, 14 Q Andrews Avenue, north or south? 14 2011, served on me May 16th, 2011. And yes, I believe 15 A Just south of Maguire's, north of Broward. 15 that you read that accurately. 16 Trying to give you landmarks you may know. 16 BY MR. HADDAD: 17 Q No, nothing is better for you guys than that 17 Q Thank you. The nuns will be happy where I 18 law firm, that — I tell you, I used to be right next to 18 went to school. 19 Grady's. It was even better when I did it. All right. 19 Do you still maintain these as your damages 20 At any rate — 20 that you suffered? 21 A I figured you would appreciate the landmark. 21 A For the most part, that's about right. 22 Q Yeah, to say the least. Actually, Boyd's Bait 22 Q All right. What -- what's not right? 23 and Tackle is better. 23 A The diversion of time, clearly I diverted a 24 At any rate, so you started the law firm and 24 lot of time that should not have been diverted to 25 approximately how many cases did you have that you took 25 defending against frivolous ac -- accusations and I 6 (Pages 21 to 24) EMPIRE LEGAL SUPPORT, INC. (954) 241-1010 Electronically signed by Wendy Robe Electronically signed by Wendy Robe Electronically signed by Wendy Robe e96e1787-3aa9-4fcc-b5a9-telaf3379799 EFTA01126115 Page 25 Page 27 1 produced this time record. With respect to reputation, 1 you -- joined you as party or a -- 2 1 believe that over the course of the last three years I 2 A It didn't happen. 3 have done a pretty darn good job resurrecting any damage 3 Q -- defendant or anything? 4 that was done to my reputation in this community. 4 A That did not happen. 5 Q Well, let's -- lees start with that. You 5 Q Name one person, other than this lawsuit, 6 don't — you never had a reputation damage, did you? 6 which we'll get into later, other than this lawsuit. 7 MR. KING: Objection, form. 7 what newspaper article, what Daily Review article, what 8 BY MR. HADDAD: 8 any article accused you of being involved in the Scott 9 Q Okay. What damage, if any, did you initially 9 Rothstein debacle? 10 have done to your reputation by the filing of a lawsuit 10 A I can't recite them off of my head. 11 against you that suggested that you were so aggressive 11 Q Is there any? 12 as a lawyer someone was going to sue you? 12 A I believe that newspaper articles were written 13 A No, the lawsuit that was filed against me — 13 when the lawsuit was filed about me and Scott being 14 MR. KING: Object to form, argumentative. 14 accused of being some co-conspirator in a Ponzi scheme, 15 A The lawsuit that was filed -- 15 yes. 16 MR. HADDAD: I was paying a compliment. 16 Q All right. There were newspaper articles 17 MR. KING: Yes. 17 written quoting a pleading as opposed to someone 18 Go ahead. 18 suggesting you committed a criminal act; is that 19 A The lawsuit that was filed against me said 19 correct? 20 that I was part of some racketeering scheme, said that I 20 A I don't know the distinction that you are 21 was involved in a Ponzi scheme, that I was 21 trying to make. 22 co-conspirator of Scott Rothstein's and that I was 22 Q We'll worry about that later, I'm just asking 23 committing fraud and conspiracy to commit fraud. A 23 you, do you know whether or not it was someone quoting a 24 bunch of criminal actions were alleged against me. In 24 newspaper -- a -- a -- a legal pleading, or was it a 25 fact, I think the complaint was entirely crimes that I 25 individual making an accusation that you were a Page 26 Page 28 1 had committed as a lawyer, which is the exact opposite 1 criminal? 2 of the type of reputation that you want as a lawyer. 2 A The legal pleading made an accusation that I 3 With that being said, that complaint, the 3 was a criminal and that was reported on. 4 various motions making those allegations about me being 4 Q I'm asking you, was there anything other -- 5 some form of co-conspirator in a Ponzi scheme was 5 was there any person, reporter, anyone, any of the 6 repeatedly filed and stated on the record and in 6 people you had all of these thousands of e-mails with, 7 hallways over at the bankruptcy court, because every 7 anyone who suggested that you were a criminal, other 8 lawyer who was anybody in South Florida had something to 8 than the pleading filed that suggested because of 9 do with the bankruptcy proceedings over at the 9 Rothstein's inclusion of your cases as part of the basis 10 bankruptcy court. So I had to go over there 10 for his Ponzi scheme that you were involved, other than 11 continuously and fend off these lawyers who believed 11 that lawsuit? 12 that there must be some merit to it, because somebody 12 A People believed that I was involved. 13 who has a lot of money is hiring lawyers who have a 13 Q Who expressed that to you? You're a young 14 pretty good reputation to say these things, there's got 14 lawyer, you're in the courthouse every day or almost 15 to be something to it. 15 every day, you're around town, correct? 16 BY MR. HADDAD: 16 A Yes. 17 Q Name one case in which you were impleaded 17 Q You go to different restaurants. Name one 18 because of your alleged involvement with Scott 18 person that came up to you and said, I can't believe you 19 Rothstein? 19 are not in jail, you area Ponzi scheme or you are 20 A I did not lose a single client. 20 anything, name one person -- 21 Q Name one -- no, name one person who impleaded 21 A There were lawyers over at the bankruptcy 22 you, one other person in bankruptcy court, whether it be 22 court, when I had to sit there listening to the things 23 the clawback scheme, whether it be Shears, whatever the 23 that were being said, that told me, you are going to be 24 hell he calls what he did, whatever you call any of that 24 a target of mine given this information that we -- 25 stuff, name one person that impleaded you or asked 25 that -- that is being told to us by Jeffrey Epstein and 7 (Pages 25 to 28) EMPIRE LEGAL SUPPORT, INC. (954) 241-1010 Electronically signed by Wendy Roberts Electronically signed by Wendy Roberts Electronically signed by Wendy Roberts e96.1787-3aa9-41cc-bSa9-1e7af3379799 EFTA01126116 Page 29 Page 31 1 his lawyers. 1 obviously, that Scott preyed upon you, as it were. You 2 Q Let me ask you this as a lawyer. Let me ask 2 were one of Scott's victims. No -- no -- incredibly -- 3 you this as a lawyer. You are a prosecutor, correct? 3 not -- not incredibly because Scott would do that to 4 A Yes. 4 anybody, you were one of Scott's victims. He didn't 5 Q And I read in your deposition you didn't do 5 care two cents about using you; would you agree? 6 RICO cases and you didn't really do economic crimes, 6 A Clearly. 7 correct? 7 Q Obviously, he put you in that position, 8 A Right. 8 correct? 9 Q All right. Did you investigate cases? 9 A Clearly. 10 A Yes. 10 Q He brought you in and every single investor, 11 Q Okay. And you're aware that in the instance 11 whether they were criminal investors or not criminal 12 of this case that Mr. Rothstein used, and I mean it's 12 investors, were led to believe that Bradley Edwards was 13 hundreds of pages to your depo that I'm not going to 13 assisting him and using his cases to promulgate these 14 reinvent the wheel on or 10's of 20 pages that 14 settlements, correct? 15 Mr. Rothstein had your boxes and your cases included in 15 A I don't know that at all -- 16 a room right upstairs here where he brought in 16 Q All right. Well, you've heard that from 17 investors, correct? 17 Sheer-- 18 A I am aware of that. 18 A -- to be true. 19 Q And he used your cases, Bradley Edwards' cases 19 Q -- when he won his verdicts and his lawsuits, 20 to lure investors into his fraudulent schemes, you've 20 didn't you? I am just asking -- 21 testified to that in bankruptcy court and other courts, 21 A No. 22 haven't you? 22 Q -- if you familiarized yourself with -- 23 MR. KING: Objection, form. 23 A No. 24 MR. HADDAD: Oh, excuse me, you are right 24 Q — that tome that he filed that he called a 25 counsel, I'll try. 25 complaint? Page 30 Page 32 1 BY MR. HADDAD: 1 A Because of how long it was, I may have read 2 Q You are aware of that, correct? 2 10 pages of it. But it was 2,000 or 3,000 pages — 3 MR. KING: The same objection. 3 Q Did you find it to be grammatically correct at 4 A Now? Yeah. 4 all? S BY MR. HADDAD: 5 A In the first 10 pages, I don't remember. 6 Q Yes. 6 Q Sheer doesn't like me, so I don't care. At 7 A Yes. 7 any rate. 8 MR. KING: The same objection. It's compound. 8 All right. So you — you realized what 9 I don't know what question you are asking him -- 9 happened there, they used your cases, et cetera. Now, 10 MR. HADDAD: Oh, he understood it, he 10 let me -- just —just because you brought this up at 11 answered. 11 the other part I want to go into, is there was an 12 MR. KING: Not necessarily. 12 unified Federal case, correct, that you have been asked 13 MR. HADDAD: Oh, okay. 13 about a bunch of times with the misspelled names, 14 MR. KING: But then the answer would be -- 14 something or another, 290-page complaint or 240-page 15 MR. HADDAD: Strike the whole thing, okay. 15 complaint? 16 I'll do it over again. 16 A About me? 17 THE COURT REPORTER: Counsel, aeuld you stop 17 Q No, not about you, about another Pon -- about 18 interrupting him at the same time. I only can get 18 another alleged Epstein victim that was unified that 19 one down at the same time, please. 19 Scott was showing when he needed money? 20 MR. HADDAD: Just hold up your hand and I'll 20 A I don't know that. 21 stop. 21 Q You don't know anything about it? 22 MR. KING: Okay. 22 A Scott was showing—.-..—. 23 MR. HADDAD: All right. 23 Q Scott -- excuse me, did — was there ever a 24 BY MR. HADDAD: 24 complaint that was filed but never served in this case 25 Q So you were -- sorry. You were aware, 25 and against Mr. Epstein? 8 (Pages 29 to 32) EMPIRE LEGAL SUPPORT, INC. (954) 241-1010 Electronically signed by Wendy Roberts Electronically signed by Wendy Roberts Electronically signed by Wendy Roberts e96e17a7-3aa9-4fcc-b5a9-1e7af3379799 EFTA01126117 Page 33 Page 35 1 A A complaint that was -- 1 Q Why did you file it? 2 Q Umm-hmm. 2 THE WITNESS: Is it okay for me to answer 3 A -- filed but never served — 3 that? 4 Q Yeah. 4 MR. KING: No, at this point -- 5 A -- against Epstein? 5 THE WITNESS: Don't mind answering it. 6 Q Yeah, a complaint that was 6 MR. KING: -- I see no relevancy or 7 A By Scott Rothstein? 7 materiality to this line of inquiry. It has 8 Q No, by you? You signed it -- 8 nothing to do with damages, it has nothing do with 9 A Oh, did I? 9 the elements of the claims -- 10 Q Yeah. And it was a misspelling of some type. 10 MR. HADDAD: It has everything to do with -- 11 A Fred, just ask me a question, I will answer 11 MR. KING: -- against Mr. Epstein. 12 it. You are asking so many different things. I don't 12 MR. HADDAD: Okay. I'm -- I'm not arguing 13 know what you are talking about. 13 with you. It has a lot to do with his loss of 14 Q Do you remember filing another lawsuit at the 14 reputation, as everything that he said that 15 time Rothstein's Ponzi scheme was falling apart? 15 happened with Scott Rothstein, he said his 16 A Did I file a lawsuit -- 16 reputation was destroyed by this case, by this man. 17 Q Yes -- 17 MR. KING: Correct. 18 A -- when Scott Rothstein's -- 18 MR. HADDAD: His reputation, he has already 19 Q -- that was never served? 19 admitted, was partially destroyed by Scott 20 A -- Ponzi scheme was falling apart? 20 Rothstein by including him in his Ponzi scheme. 21 MR. HADDAD: Let me just see, Jack. Do you 21 However you want to slice it later for a jury is 22 want to take over? 22 one thing or another. 23 BY MR. HADDAD: 23 THE WITNESS: Can I just talk to Bill outside 24 Q Okay. You don't remember a Federal court 24 and I think that I will be able to answer the 25 case? 25 question for you? Page 34 Page 36 1 A About Jeffrey Epstein. 1 MR. HADDAD: Yeah, go ahead. 2 Q Umm-hmm. 2 THE VIDEOGRAPHER: The time is 10:47 a.m. We 3 A Or about -- it had nothing to do with 3 are now coming off the video record. 4 Rothstein? 4 (Thereupon, a discussion was had off the 5 Q No, Jeffrey Epstein. 5 record.) 6 A Okay. 6 THE VIDEOGRAPHER: The time is 10:50 a.m. We 7 Q A lengthy Federal case against Mr. Epstein? 7 arc now back on the video record. 8 A I filed Federal complaints against Jeffrey 8 BY MR. HADDAD: 9 Epstein before. 9 Q Do you recall when it might have been that 10 Q Okay. Do you recall one that was filed that 10 Mr. Rothstein was deposed about who was involved in the 11 was never served that contained a misspelling of 11 Ponzi scheme, do you recall when the first time might 12 someone's name? I'm just asking if you recall. If you 12 have been? 13 don't recall it, you can tell me. 13 A No. 14 A I recall filing a complaint against him that 14 Q There came a point in time where Mr. Rothstein 15 was never served. I don't know about a misspelling or 15 stated that he was certain that you were not involved in 16 what we are talking about. 16 the Ponzi scheme, you had no knowledge of a Ponzi scheme 17 Q Do you recall filing one against him that was 17 and that he had used all of your cases without your 18 never served, correct? 18 knowledge, correct? 19 A I do recall filing a complaint against him. 19 A The first two parts of that, I was in a 20 It was never served. 20 deposition, yes. That he said he used all of my cases 21 Q How long was that complaint? 21 is not true. 22 A I don't know. If you have it, I will look at 22 Q Okay, I don't mean all of your cases. He used 23 it. It will definitely help to refresh my recollection. 23 some of the cases against Epstein as a basis for his 24 It was long, because I know why I filed it and I know 24 Ponzi scheme? 25 how many counts that there were. 25 A I think I understand what you mean, I am not 9 (Pages 33 to 36) EMPIRE LEGAL SUPPORT, INC. (954) 241-1010 Electronically signed by Wendy Roberts Electronically signed by Wendy Roberts Electronically signed by Wendy Roberts eseeirar-saaa-4tec-bsaa-le?af3379799 EFTA01126118 Page 37 Page 39 1 trying to be difficult but I'm just going off what you 1 You became aware of certain members of RRA 2 said. 2 becoming targets or noticed of being persons of interest 3 Q Be difficult, it's fine with me. 3 to the Federal Government, correct? 4 A I don't want to be. I want it to be over with 4 A I don't know that I remember that. 5 so go ahead. 5 Q Well, you know that? 6 Q It will be over with tomorrow. 6 A I mean, now I know things now. It's hard to 7 A At this rate, for sure. 7 rewind time remembering -- 8 Q So at any rate, Rothstein had said what he 8 Q No, I'm talking about -- 9 said in the deposition, the deposition speaks for itself 9 A -- when I learned them. 10 but -- 10 Q I didn't mean to interrupt you. After the 11 A Right. 11 firm imploded, based upon just publicity or whatever, 12 Q -- do you recall -- 12 you were aware that certain persons were implicated in 13 A I was there. 13 the scheme, correct? 14 Q -- when was that deposition? 14 A Correct. 15 A I don't remember. 15 Q And you are aware that — let me ask you this: 16 Q Do you recall the year? 16 At any point in time, did you request or seek counsel, 17 A Can you show me the deposition? It was either 17 without asking anything about that, to make inquiry to 18 2011 or 2012. 18 the Federal Government about yourself? 19 Q Okay. When he was deposed for those days that 19 MR. KING: Objection. 20 Judge Bray -- Judge Cohn allowed? 20 A No. 21 A Deposed in this case I think -- 21 MR. KING: It's irrelevant. 22 Q Yes. 22 MR. HADDAD: Okay. 23 A -- that your daughter took the deposition. 23 MR. KING: Irrelevant and immaterial and it 24 Q Do we -- she's old, can you refer to her as 24 would be privileged. 25 co-counsel? All right. She took the deposition. All 25 MR. HADDAD: Not if he asked if he saw -- not Page 38 Page 40 1 right. And that was -- that was the video deposition as 1 if I don't ask him what he said. At any rate, I 2 opposed to Scott being in person when he was over the 2 will let it go and take it up later. 3 grand jury room, correct? 3 BY MR. HADDAD: 4 A I didn't even know that happened, so, yes, 4 Q All right. Let me go on to something else. 5 that's when it was. 5 We are talking about 2009. 6 Q All right. Now, that would have been within a 6 A Okay. 7 year, year and a half later ago, correct, something like 7 Q You're a lawyer how many years now? 8 that; would that be accurate? 8 A In 2009 or now? 9 A I'm not going to quarrel it, if you are 9 Q Now, now, now, now. 10 telling me -- 10 A Didn't we start here. 11 Q Yeah. 11 Q Yeah, I know, I just can't remember. 12 A -- that's what it was, that's it. 12 A 2013, minus, I mean—.--.—. 13 Q All right. And at that point in time, any 13 Q I'm old, Brad. 14 person who knew anything at all or was following the 14 A Eleven and a half years. 15 case would have learned that Scott Rothstein 15 Q All right. Now, your reputation, obviously, 16 affirmatively stated you had no involvement? 16 there is no loss of reputation for you, correct? 17 A I agree with that. 17 A We just went through this. 18 Q Okay. Do you know whether or not he had made 18 Q No, I am going to go through it in detail. 19 that representation to others prior to that in other 19 A Did -- 20 depositions or in debriefings or anything that was 20 Q You have no loss of reputation, correct, your 21 communicated to you by any individuals? 21 reputation has expanded immensely since the Epstein 22 A No. 22 cases, correct? 23 Q All right. I know from the way the deposition 23 MR. KING: Objection to form, it's 24 was asked the last time that you were asked -- let me 24 argumentative. 25 sec how I want to do this. 25 10 (Pages 37 to 40) EMPIRE LEGAL SUPPORT, INC. (954) 241-1010 Electronically signed by Wendy Roberts Electronically signed by Wendy Roberts Electronically signed by Wendy Roberts e96e17a7-3aa9-4fcc-b5ati-le7af3379799 EFTA01126119 Page 41 Page 43 1 BY MR. HADDAD: 1 A Maybe I should pay more attention to those 2 Q Well, let me ask you this: In -- 2 things. I don't know about all those old people. 3 A Do I believe that right now my reputation is 3 Q Well, you do have -- I look at it from what 4 better than it has been at any time in the past, yes. 4 you do with them. Come on Brad, you have an ego, 5 Q All right. And as a matter of fact, since the 5 everybody does. At any rate, you are considered in the 6 Rothstein case, you're now included, probably one of the 6 top 40 under 40, in that group, correct? 7 youngest guys there is, in Best Lawyers in America, 7 A Right. 8 correct? 8 Q And have you ever looked on the Web site for 9 A Probably. 9 that group to see the type of lawyers that are included 10 Q All right. There are not many guys that have 10 in that? 11 been practicing II years to be included in that. 11 A No. 12 A I agree. 12 Q Okay. And you have that distinction of being 13 Q And that is 100 percent for old people like 13 included and you promote it with your -- as most lawyers 14 Goldberger, for the most part. You are included in that 14 would, correct? 15 based upon peer review and nothing else? 15 A Personally, I don't, but I know that my law 16 A That's true. 16 firm does. I mean, we do have a PR firm for our law 17 Q You -- 17 firm. 18 A I mean, I don't ac -- actually don't know the 18 Oh, is that who does all of that stuff? 19 answer to that. 1— if you are saying that's what it 19 A Yeah. 20 is, it might be. 20 I mean, this is about a month's worth. All 21 Q Did you solicit anybody to become in that? 21 right. 22 A No. 22 A You looked at a lot more than I have. 23 Q Did you receive a letter saying you have been 23 I have to do something to earn the money I 24 nominated for Best Lawyers in America? 24 make. 25 A 1 don't think so. 25 A Thank goodness, right. Page 42 Page 44 1 Q No, you just got a notice one day that you -- 1 Q Now, you are also -- there is another service 2 A Right. 2 called AVVO, are you familiar with that? 3 Q -- are included, correct? 3 A Yes. 4 A Right, that's true. 4 Q All right. And that's another unsolicited — 5 Q Out of the whole world, out of thousands of 5 out of the top 40 under 40, you can't buy your way into 6 lawyers practicing law 10 years, you are notified, hey, 6 that one either, you didn't know you were getting that, 7 you are one of the best lawyers in America for what you 7 correct? 8 do? 8 A That's true. 9 A Right. 9 Q You get a notice, hey, you have just been 10 Q Okay. Now, you also are one of the top 40 10 included in all of this stuff, whether you like it or 11 lawyers under 40, correct? 11 not, you are considered one of the top lawyers in 12 A Right. 12 Florida. 13 Q You are 37 years old? 13 A That's true. 14 A Correct. 14 Q Okay. Then you have AVVO where people can 15 Q And you are considered one of the top trial 15 arrest -- arrest, I see arrest records, two secrets 16 lawyers in Florida? 16 under your name here. I guess that is part of the 17 A Right. 17 advertising that goes with having a Web site or 18 Q There is a group called the Top 100 Trial 18 something. Five Farmer, Jaffe, Weissing attorneys 19 Lawyers in America, correct? 19 recognizes the best lawyers in America, that is pretty 20 A I think so. 20 good for a bunch of young lawyers, yeah? 21 Q That's part of what you are in? 21 A Yeah. 22 A Okay. 22 Q And AVVO, another one. Do you participate in 23 Q Yeah, they have the top 100 trial lawyers for 23 their promotion, AVVO, they promote lawyers I think, do 24 old guys like Goldberger, Scarola, part of his firm and 24 you participate in that at all? 25 all those old people, correct? 25 A Not really. 11 (Pages 41 to 44) EMPIRE LEGAL SUPPORT, INC. (954) 241-1010 Electronically signed by Wendy Roberts Electronically signed by Wendy Roberts Electronically signed by Wendy Roberts e96.17a7-3aa9-4fcc-bSalMe703379799 EFTA01126120 Page 45 Page 47 1 Q Okay. 1 has something to do with him that my reputation has 2 A I answered one question one time. 2 improved, I just wanted to make that clear. 3 Q Yeah, about herpes or something? 3 Q Well, you don't know what's improved your 4 A 1 participate a lot less than everybody else 4 reputation. Reputation is what the community thinks of 5 in my law firm, yes. 5 you, you don't know where it conies from. 6 Q Okay. But I am just saying, you got -- they 6 A Well, it's certainly not from becoming accused 7 rated you without your request, correct? 7 of being a Ponzi schemer, that's for darn sure. 8 A That's true. 8 Q You don't know who voted on your reputation, 9 Q And they rated you as a superb lawyer? 9 maybe it was — 10 A Okay. 10 A You. 11 Q Yes or no? 11 Q Actually, we will go from there because I 12 A I don't know. 12 don't want to be argumentative, I don't want to get your 13 Q Let me -- well -- 13 counsel objecting. I am trying to keep him happy here. 14 A You keep up with this more than I do. I'm 14 At any rate, and -- so for reputation in the 15 telling you, I don't —I don't — 15 community, you have never asked any lawyers to state 16 Q I didn't keep up with this at all. 16 their opinion of you, correct? 17 A I don't know these things. 17 A That's right. 18 Q I don't know how to use computers. Somebody 18 Q Or any other members of the public, correct? 19 did this for me. 19 A Right. 20 A Show me what it is and I'll — 20 Q Okay. So let's see, all within 20 days, 21 Q Yeah. Do you think I care about looking up 21 24 days in 2013, you have people rate you on lawyers.com 22 Brad Edwards? 22 five out of five is what an excellent exceptional 23 A Apparently. 23 attorney you are, correct? 24 Q I don't even look up myself. 24 A I don't even know what that Web site is. This 25 A Exactly, that's my point. 25 is the first time I have seen. Page 46 Page 46 1 MR. GOLDBERGER: Someone did it for me. 1 Q I don't either, I'm just -- I just saw it. 2 MR. HADDAD: Oh, someone did it for you? 2 You don't know? 3 MR. GOLDBERGER: Look at the number. 3 A News to me, no. 4 MR. HADDAD: What? 4 Q Well, I mean, but that's part of your 5 MR. GOLDBERGER: 10.0.B. 5 reputation is what — is news to you is that you don't 6 MR. HADDAD: 10.0? 6 even know what's going on or where it's coming from but 7 A Yep. I don't know -- 7 that's your reputation. 8 BY MR. HADDAD: 8 A I don't disagree with you. 9 Q Okay. You're rated as a superb lawyer, 9 Q Okay. Yeah, I mean, I am blowing — I can't 10 correct? 10 say the word. I'm making you look good. Okay, now, the 11 A Okay. Yes. 11 other thing you're in it is for your verdicts, correct, 12 Q Okay. Now, that's not a bad reputation to 12 you are in for the publication for some of the verdicts 13 have at I I years out, correct? 13 you have received? 14 A No, I -- I agree, I said that from the 14 A Right. 15 beginning. 15 Q Okay. And how much money do you think you 16 Q All right. And 2009, 2010, you didn't have 16 have made in the last two years on verdicts nothing to 17 any of these accolades? 17 do with Epstein, gross verdicts, you won the money over 18 A I -- I agree with that. I think that's right. 18 at Jacksonville? 19 Q Okay. So that's evolved in the last two 19 A Over — over 20 million. 20 years, okay; would you agree with that? 20 Q Over 20 million. Let's see, again, okay. 21 A Yes. 21 That's more than probably 90 percent of the PI lawyers 22 Q All right. And then -- 22 in the state; wouldn't you agree? 23 A I think it has a lot to do with jury verdicts 23 A I would agree. 24 that I have received that have nothing to do with 24 Q That's probably more than Jon Krupnick made 25 Epstein but just to the extent that you are implying it 25 the last couple years? 12 (Pages 45 to 48) EMPIRE LEGAL SUPPORT, INC. (954) 241-1010 Electronically signed by Wendy Roberts Electronically signed by Wendy Roberts Electronically signed by Wendy Roberts eS6e17a7-3aa9.41cc-b5a9.1e7at3379799 EFTA01126121 Page 49 Page 51 1 A I don't know that. 1 A To some extent we are dependent and -- 2 Q Okay. How about Skip Campbell, you are 2 Q All right. 3 buddies with him? 3 A -- to some extent we are independent. 4 A I never talked to him in my life. 4 Q Do you own your own building over there? 5 Q Oh, you didn't, I thought you knew him. S A No, we don't own the building. 6 A No, I don't know him. 6 Q All right. Okay. Can -- let's go to 7 Q So you made 20 million in verdicts in the last 7 emotional distress. Tell me about the emotional 8 two, three years? 8 distress that you suffered. Well, let me back up by 9 A Right. 9 this. 10 Q Okay. And how many -- how much money has your 10 You were sued by abuse of process by some guy 11 firm had in gross verdicts in the last couple of years, 11 in the joint, weren't you, do you remember? 12 let's say the last since 2009, when you all split 12 A No. Are you talking about him? 13 with -- well, you didn't split with Rothstein when you 13 Q You, you were sued. 14 were, I want to say disemboweled, but, I guess, 14 A By who? 15 disengaged with that law firm, how much money has -- 15 Q Oh, my God, I got to go find it now. I guess 16 what's the name, Farmer, Jaffe, let me just use short 16 if you didn't know you were sued, you can't have a whole 17 for that? 17 lot of emotional distress. Where is it? 18 A I tried the vast majority of our cases at that 18 A I was — I know that I was sued by Jeffrey 19 firm. 19 Epstein, is that what you are talking about? 20 Q Okay. How much -- well, did Gary Farmer win a 20 Q No. He's — no, he is not in the joint. 21 big verdict recently or a settlement? 21 Excuse me -- 22 A Maybe that, but -- 22 A I understand that. 23 Q Settlement was how much? 23 Q — someone who is in Florida State Prison, an 24 A -- you know the difference. 24 individual has sued you along with Michael Gates. 25 Q Yeah. Do I know the difference? A little 25 A Really? Page 50 Page 52 1 bit, not much. 1 Q Yes. You weren't aware of that? 2 A Yeah. Exactly. 2 A No. 3 Q How much did Farmer settle for? 3 Q Okay. 4 A He has had a bunch of them. 4 A But I -- I -- definitely I am interested in 5 Q How much would you say he's settled for, he 5 seeing it. 6 has had some -- didn't he have a big qui tam suit, or 6 MS. HADDAD COLEMAN: Hollywood Police 7 whatever you call them? Department. 8 A He has had several of them, yes. 8 BY MR. HADDAD: 9 Q How much did he settle for? 9 Q See I -- 10 A Hundreds of millions of dollars. 10 A Oh, oh, okay. All right. Oh, Hollywood 11 Q More than that, no, didn't he settle one for a 11 Police Department? 12 billion? 12 MS. HADDAD COLEMAN: Yes. 13 A I think that predated our current firm though. 13 A I know that case. I don't know that we were 14 Q Oh, okay. So hundreds of millions of dollars 14 sued for abuse of process, I don't know what it was 15 coming into your firm from him in settlements? 15 but -- 16 A I mean, that's a different question that I'm 16 BY MR. HADDAD: 17 not willing to answer but--.—.--. 17 Q Okay. 18 Q Okay. 18 A I am aware generally that we were sued by 19 A And it has nothing to do with me, I mean, 19 Donald Baker. 20 it's -- 20 Q Were you a still a state attorney at the 21 Q And that was my next question. You guys are 21 time? 22 all independent, as far as your compensation? I'm not 22 A No, I had left the State Attorney's Office. I 23 going to get into how much you make right now. 23 think the AG's office covered it, that's why I've had 24 A Not necessarily. 24 zero involvement in it. But — 25 Q Okay. 25 Q I understand that. I'm sorry, let me -- let 13 (Pages 49 to 52) EMPIRE LEGAL SUPPORT, INC. (954) 241-1010 Electronically signed by Wendy Roberts Electronically signed by Wendy Roberts Electronically signed by Wendy Roberts e96.17a7-Saa9-4fee-b5a9-1e7af3379799 EFTA01126122 Page 53 Page 55 1 me let you finish your question. 1 doesn't exist, correct? 2 A Donald Baker, is that the -- 2 MR. KING: Objection. 3 MS. HADDAD COLEMAN: No, it's different. 3 BY MR. HADDAD: 4 THE WITNESS: Oh, different. 4 Q You concede that? 5 BY MR. HADDAD: 5 MR. KING: Objection, argumentative. 6 Q Oh, you got sued twice? 6 BY MR. HADDAD: 7 A Apparently. 7 Q Well, would you concede -- never mind, we went 8 Q All right. And then did — let me ask you 8 through it already. 9 about the — I had it right here. 9 A Yeah, we -- we talked about this. 10 A I convicted some guy, he went to prison and 10 Q I understand. Can you detail for me the 11 then sued the judge and every — all the police and 11 emotional distress, embarrassment, mental anguish and 12 everything else. 12 humiliation -- 13 MR. GOLDBERGER: Here you go. 13 A Okay. 14 MS. HADDAD COLEMAN: This guy's name is 14 Q -- that you have? 15 different. 15 A Where I was beginning before — 16 MR. HADDAD: Yeah, Shaarbay, Sharbasom. I 16 Q Yes, sir. 17 guess that must be -- 17 A -- when we were talking about reputation. I 18 MR. GOLDBERGER: Spell it. 18 do believe that I have always practiced with the utmost 19 MR. HADDAD: —the Arab guy. S-H-A-A-R-B-A-Y 19 honest, integrity. And when a lawsuit was filed against 20 versus - 20 me accusing me of being dishonest and being a criminal 21 A News to me. 21 or -- to truncate this — and I had to continue to go to 22 BY MR. HADDAD: 22 court and see lawyers who, for a period of time, and I 23 Q — various persons. Were you ever served with 23 do believe that once the case was dismissed against me, 24 a lawsuit? Among the persons sued was — 24 that window closed, but for a period of time they 25 A No. 25 believed the allegations against me. I think that there Page 54 Page 56 1 Q — Pete Weinstein, Michael Gates, Finkelstein, 1 was probably a point in time, based on some of the 2 Satz, Dan Callahan, Brad Edwards. 2 e-mails that I have seen, that your co-counsel Tonja 3 A No. I don't recognize that person's name. I 3 believed that, which in terms of hurt feelings type of 4 have never been served with that lawsuit, to my 4 things, yeah, that -- that wasn't -- that wasn't 5 recollection. 5 something that I appreciated either. But having to be 6 Q To your recollection, okay. 6 in a courtroom where lawyers believed that I had done 7 A No. 7 these things that I had not done, it was humiliating. 8 Q All right. But you said there was another Now there is another aspect of it which I 9 one, who else sued you? 9 consider to be much more significant, because as we've 10 A Donald Baker sued me and Mike Satz and Michael 10 discussed, the case was dismissed against me and I do 11 Gates and all of the Hollywood Police Department. 11 feel that separate and apart from any involvement that I 12 Q And what happened with that case? 12 have had prosecuting cases against Jeffrey Epstein, I 13 A It was dismissed. 13 have done a good job ofresurrecting my reputation from 14 Q All right. Would those predate the time that 14 the point in time where people initially believed, hey, 15 you were sued by Mr. Epstein? 15 where there is smoke there is fire or something -- this 16 A Yes. 16 guy must be guilty of something. And that was my 17 Q Okay. Now, tell me how -- 17 perception of things and that's a reasonable perception 18 A Well, I don't know about this new one that you 18 based on what was filed. 19 just told me about it, it may have been yesterday for 19 Q All right. And I don't want -- I am not going 20 all I know. 20 to be argumentative with you, obviously, but based upon 21 Q All right. 21 what the entirely of what the Ponzi scheme is, just 22 A I am unaware of it. 22 being involved in it, just being in that firm with your 23 Q Emotional distress, embarrassment, mental 23 cases there would give that perception to people, 24 anguish, humiliation, I will start with those, because 24 wouldn't you agree? 25 we know loss of reputation and standing in the community 25 A No. I think that most lawyers escaped fairly 14 (Pages 53 to 56) EMPIRE LEGAL SUPPORT, INC. (954) 241-1010 Electronically signed by Wendy Roberts Electronically signed by Wendy Roberts Electronically signed by Wendy Roberts e96.17a7-3aa9-4fcc-b5a9-1e7af3379799 EFTA01126123 Page 57 Page 59 1 unscathed and nobody thought that 60 lawyers were 1 about and who he doesn't care about and I know the kinds 2 involved in a Pont scheme. I -- me and your client, 2 of things that he has done in the past, how he lives his 3 Russ Adler, are two of the only that have been pinned as 3 life and what he is capable of doing to me and what I 4 co-conspirators of Scott Rothstein's. 4 believed that he would to do me. So yeah, it's all 5 Q No, I would say there have been others. 5 about him. 6 A Well, you would know better than I. 6 Q All right. And let's go there. So everything 7 Q Of course. 7 is about Jeffrey Epstein because he sued you, as opposed 8 A But publicly -- well, that was my perception. 8 to anyone else in the world? 9 Q And I noticed Adler is still out there trying 9 A Yeah. 10 cases, he just won three million bucks down in Miami 10 MR. KING: You know, I'm going to -- let me — 11 with some lawyer. 11 let me interject here. I was at a prior deposition 12 A He is a good lawyer. 12 where Mr. Epstein was here and it's the same facial 13 Q Okay. And you are a good lawyer. 13 expressions, the same unprofessional attitude that 14 A Right. 14 he is displaying here that he displayed then. So 15 Q All right. And I want to know exactly where 15 I'm just going to ask you to instruct him to 16 you were humil -- all right, I understand no one likes 16 maintain a poker face, to the extent he is able to 17 getting sued and no one likes being accused of anything, 17 do it. It is distracting. I don't know if it is 18 how did it impact you, this emotional distress, 18 distracting to the witness, but it is certainly 19 embarrassment and mental anguish, how did it manifest 19 distracting to me because I can hear it and I can 20 itself that we can put a -- a -- anything on it. Did 20 feel it and I can see it and it should not happen 21 you ever not go to court? 21 in deposition of a case of this magnitude or 22 A No, I -- I always fulfilled my obligations. 22 frankly in any case. 23 Q Did you seek -- did you seek mental -- uh, 23 MR. HADDAD: I'm sorry, I have no peripheral 24 what do they call those people, mental health helpers -- 24 vision so I don't see anything because I'm looking 25 A No. 25 to him. Page 58 Page 60 1 Q -- you know, like psychologists or anything 1 MR. KING: Well -- 2 like that? 2 MR. HADDAD: I'm sure somebody will suggest 3 A I did not. 3 something to plaintiff or counter-defendant, 4 Q Did you go to a doctor to get Xanax? 4 whatever he is, on what to do, okay. 5 A Nothing. 5 MR. KING: All right. Thank you. 6 Q Did you lose sleep? 6 BY MR. HADDAD: 7 A Of course I lost sleep. I mean, but you would 7 Q I don't have the same fears apparently that 8 lose sleep from getting these types of allegations 8 Mr. Edwards has. 9 anyway. But I will tell you that it was who was suing 9 A You don't know him. 10 me that caused the emotional distress. 10 Q Pardon me? 11 Q Because he's so rich or because of what? I 11 A You don't know him and he didn't sue you. You 12 mean, people sue people all the time. Are you going to 12 weren't a target of his. 13 say because it was Epstein as opposed to if I sued you 13 Q Do you know who I represent? Do you think 14 for some reason, for some God-known reason? 14 this bothers me? 15 MR. KING: Objection to form. 15 A I know who you represent now. 16 A That would cause a lot less emotional 16 Q Not him. Do you think this will bother me? 17 distress. 17 You have been a lawyer for how long? 18 BY MR. HADDAD: 18 A I think this is the fourth time we've gone 19 Q Okay. 19 through this. 20 MR. KING: Objection to form. 20 Q Well, I know that, and how many people -- when 21 BY MR. HADDAD: 21 you were a prosecutor, how many people did you put in 22 Q All right. Well -- 22 prison? 23 A Yes, I am saying it was because it was Jeffrey 23 A A lot. 24 Epstein who sued me, because I know him, I know who he 24 Q All right. And you got sued by people, 25 is, I know what he is capable of. I know who he cares 25 correct? 15 (Pages 57 to 60) EMPIRE LEGAL SUPPORT, INC. (954) 241-1010 Electronically signed by Wendy Roberts Electronically signed by Wendy Roberts Electronically signed by Wendy Roberts .96.17a7.3809-4fcc-b6a9-1e7af3378799 EFTA01126124 Page 61 Page 63 1 A Right. 1 A I —I know. You also told everybody in the 2 Q Did you get threatened by people when you were 2 courtroom that on that day, very, very loudly. I 3 putting them in prison? 3 remember. 4 A To some extent. 4 Q That's right, Marty Vanskyhawk. 5 Q Yeah, you were a prosecutor, you -- 5 A That was it. 6 A Yeah. 6 MS. HADDAD COLEMAN: He needs to stop paying 7 Q -- were threatened by criminals, correct? 7 my exterminator apparently. 8 A Right. 8 MR. HADDAD: He stuck dead fish down the eaves 9 Q People that were going to prison? 9 of the house when they went to throw him out? 10 A Yeah. 10 A Correct. 11 Q They threatened to kill you, they threatened 11 Q Barracudas and Wahoo? 12 to get even with you, all kind of stuff, correct? 12 A Exactly. 13 A Right 13 Q Yes. And If you were Norwegian, you would 14 Q And you were a --1 was going to slip again -- 14 have called it lutefisk and ate it. 15 you were a hard-nosed prosecutor? 15 A And you actually had it with Jody, but she 16 A That's true. 16 wasn't there that day, so I had to deal with you and him 17 Q All right. And you had the biggest --I can't 17 and the whole mess. 18 think of him without saying anything, the hardest 18 Q Well. 19 unyielding judge there was in Michael Gates, correct? 19 A So yes. 20 A Great judge. 20 Q Okay. So, let's face it, you -- you — 21 Q There was no amount of prison time that was 21 A And he went to prison for fish. 22 not enough for him, great judge as you said, correct? 22 Q He went to prison for fish. 23 A I don't know if that's correct, I don't agree 23 A Right. 24 with that. 24 Q So did Jerry Chilli when I represented him. 25 Q Well, he was worse than -- well, you don't 25 Of course, he was a Mob kingpin. Excuse me. Page 62 Page 64 1 remember Futch, you weren't born yet. He was the 1 (Thereupon, a discussion was had off the 2 toughest judge on the criminal bench at the time you sat 2 record.) 3 there and you were the toughest judge {sic} in his 3 MR. HADDAD: I can remember the point I was 4 division — toughest prosecutor in his division. 4 trying to make. I'm not your age yet. 5 A I'll agree with the second part. 5 THE VIDEOGRAPHER: Counsel. 6 Q Okay. And you were plainly considered by many 6 BY MR. HADDAD: 7 defense lawyers, which may be a compliment to you, as 7 Q All right. So — 8 unreasonable. You certainly didn't give any quarter if 8 MR. GOLDBERGER: Okay. Fred, five minutes 9 you didn't have to, correct? 9 until the tape change. 10 A I would agree with that. 10 MR. HADDAD: I'm sorry? 11 Q Okay. And I never had a case with you so I 11 MR. GOLDBERGER: Can you read? 12 can't say much. 12 MR. HADDAD: Oh, yeah, let's take a break now. 13 A You had one. 13 THE VIDEOGRAPHER: The time is I I:15 a.m. 14 Q Did l? 14 MR. HADDAD: I've got to take a glass of 15 A Yeah. 15 water. 16 Q It must have been unpleasant. 16 THE VIDEOGRAPHER: We are now coming off the 17 A It was ridiculous and stupid. 17 video record. This is the end of Tape No. I. 18 Q Who, me or you? 18 (Whereupon, a break was taken.) 19 A You were actually funny. 19 THE VIDEOGRAPHER: The time is now 11:27 a.m. 20 Q I'm making you laugh today. 20 We are now back on the video record. This is the 21 A You always do, Fred. Your client stuck some 21 start of Tape No. 2. 22 dead fish under someone's floorboards. I told you it 22 (Thereupon, a discussion was had off the 23 was funny. 23 record.) 24 Q Oh, yeah, I got an XKE and a Ferrari out of 24 BY MR. HADDAD: 25 the guy. 25 Q All right. Sir, let me ask you this: You 16 (Pages 61 to 64) EMPIRE LEGAL SUPPORT, INC. (954) 241-1010 Electronically signed by Wendy Roberts Electronically signed by Wendy Roberts Electronically signed by Wendy Roberts 06017a74sa94fcc-b5a9-197af3379799 EFTA01126125 Page 65 Page 67 1 talked about your firm has a PR department, correct? 1 Q Yeah, yeah. 2 A That's correct. 2 A We have filed suit against Jeffrey London 3 Q Which is not unusual, I guess, for personal 3 only. 4 injury lawyers, correct? 4 Q Only, no one else has been impleaded? 5 A That's correct. 5 A That's true. 6 Q All right. I don't know if it's -- how often 6 Q Or joined as defendant, okay. And that's how 7 does -- and the only reason I'm asking is I went through 7 many plaintiffs do you have in that case? 8 this stuff and I'm seeing this, what they call a PR log. 8 A We have one. 9 A Okay. 9 Q Okay. And does anyone else have other 10 Q Whatever it is, okay. And do you have -- I 10 plaintiffs? 11 guess you just what, hire somebody to do your PR? 11 A No. 12 A That's correct. 12 Q Okay. And of course, fortuitously, I have to 13 Q And does -- do you have a point person who 13 be in the courtroom on something else when I ran into 14 does it, like one of your lawyers? 14 you and Matt Weissing there. 15 A Yes. 15 A Right, at an Arthur hearing for Jeffrey 16 Q And who would that be? 16 London. 17 A Seth Lehrman. 17 Q At an Arthur hearing, correct. 18 Q Okay. And do you also use Facebook to promote 18 A Right. 19 the law firm? 19 Q And at that point, it was mentioned that 20 A I believe the law firm has a Facebook page, 20 Miss Buntrock had funded the church, funded monies and 21 but I can't say for certain. 21 done other certain things, correct? 22 Q All right. Do you actually do any of the 22 A I heard that when you heard that. 23 input yourself? 23 Q All right. And how did the plaintiff reach 24 A Zero. I never have. 24 you in that case, do you know? 25 Q Do you have the approval yourself of what's 25 MR. KING: I -- Page 66 Page 68 1 put in there, do you have to approve what's put in there 1 A Yes, I do know it. 2 or it's -- 2 MR. KING: Is this presumably going to 3 A No. 3 reputation? 4 Q Okay. All of the advertising that is done 4 MR. HADDAD: Oh, yeah. 5 about Bradley Edwards then, such as — I mean, I'm sure 5 A I do know. 6 you have seen them showing your face on channel — I am 6 MR. HADDAD: No, I'm doing it because I wanted 7 talking about the Huizenga thing now where, what's her 7 a cut of the fee, of course. 8 name, Buntrock? 8 A It was — 9 A I have never seen it. 9 MR. KING: I want to make sure we don't go 10 Q Okay. All of that's done by someone else? 10 afield, that's all. 11 A Yes. 11 Go ahead. 12 Q You are — you are presently involved in 12 A It was through a foster home that Matt 13 the -- are — have you filed suit in that case yet? 13 Weissing, my partner, he fostered a child through the 14 MR. GOLDBERGER: Identify the case for him. 14 home. 15 MR. HADDAD: Pardon? 15 BY MR. HADDAD: 16 MR. GOLDBERGER: Just so we have a record. 16 Q Umm-hmm. 17 MR. HADDAD: I will get to it in a second. If 17 A And the foster home where one of the child 18 he says he filed suit, I'll do it. 18 victims of Jeffrey London was placed contacted Jeff — 19 A You — you're talking about — 19 Matt Weissing. That was how it happened. 20 BY MR. HADDAD: 20 Q All right. Now, you are not familiar with 21 Q I'm talking about the pastor -- 21 your advertising, correct? 22 A I know what you're -- 22 A No. 23 Q -- you know exactly what I'm talking -- first 23 Q Okay. So if it says you are representing 24 time I saw — 24 several young men against Jeffrey London, you 25 A Talking about Jeffrey London? 25 wouldn't -- that would not be correct? 17 (Pages 65 to 68) EMPIRE LEGAL SUPPORT, INC. (954) 241-1010 Electronically signed by Wendy Roberts Electronically signed by Wendy Roberts Electronically signed by Wendy Roberts e96017a7-3aa9-4fcc-bSa9-1e7at3379799 EFTA01126126 Page 69 Page 71 1 A I hesitated because you asked how many 1 correct? 2 plaintiffs there are. And for you to be a plaintiff, 2 A I believe so. 3 there has to be a lawsuit. 3 Q And in your various advertisements, you have 4 Q How many potential plaintiffs are you 4 talked about suing billionaire Jeffrey Epstein, 5 representing? 5 obtaining judgments for victims against billionaire 6 A Let me describe what I do in that case and 6 Jeffrey Epstein, correct? 7 then you can take it from there. There are, I believe, 7 A Have I said that? 8 seven or eight victims that we have signed on to 8 Q Your PR people? 9 represent them through the criminal process as crime 9 A Do you have something that says that, maybe. 10 victims' rights attorneys. Some -- some may have civil 10 Q I'm asking you. 11 claims that still are viable and some may not. Right 11 A It's a true statement, so maybe it is -- maybe 12 now we have filed one. In the future, we may decide to 12 it was said. 13 file others. That's the best I can do. 13 Q I have not yet questioned your integrity about 14 I mean, there — obviously, we are dealing 14 a single thing, Mr. Edwards. 15 with a lot of issues that relate to abuse that happened 15 A I understand. 16 many, many years ago, which raises other issues that 16 Q I'm just asking you whether or not it's true. 17 everybody is probably familiar with so—.--.--. 17 A Yeah, I want to help you out and I think that 18 Q All right. Now, in that case, of course, 18 that - 19 there is, I suppose, some issue of whether or not -- 19 Q Well -- 20 well, obviously Mr. London would be what the -- they 20 A — was done, but I'm not sure. 21 used to say is an impossibility, judgment-proof, 21 Q You want to help me out? How can I thank you? 22 correct? He has got no -- 22 A Help me help you. 23 A 1 would hope that the guy goes to prison for 23 Q You start to look like Tom Cruise if I keep at 24 the rest of his life so -- 24 it. 25 Q Well, I understand that. 25 All right, now, you sought — you made it Page 70 Page 72 1 A -- that would probably make him 1 known that you were seeking victims of Mr. Edwards, 2 judgment-proof. 2 correct -- Mr. Epstein; did you not? 3 Q Well, I understand that, but the benefactor of 3 A Seeking victims? 4 that place where he was is far from judgment-proof, 4 Q Yeah, seeking to represent victims, you put it 5 correct? 5 out whether or not there were any victims that needed 6 A Benefactor of what place? 6 representation, for lack of a more professional way of 7 Q Of the -- of the place where he had these 7 putting it? 8 kids, would be far from judgment-proof, correct? 8 A I don't think that's right. 9 A The owner of the house I believe is Elizabeth 9 Q Huh? 10 Buntrock. 10 A I don't think that's right. 11 Q All right. And Miss Buntrock is Huizenga's 11 Q Okay. Now, during the time of these Epstein 12 sister or cousin? 12 suits and Epstein cases, you were quoted in the 13 A Some relative. 13 newspapers numerous times, correct? 14 Q All right. And she was married and had one of 14 A Yes. 15 the huge -- largest divorces in the history of Broward 15 Q You were quoted in the Daily Mail, I believe 16 County, correct, settlements? 16 over in London, Mail Online, whatever they call it, I 17 A I don't know. 17 guess the Daily Mail, correct? 18 Q All right. Okay. And -- 18 A I remember the publications but I was quoted 19 A I'll come to you for that information. 19 in several newspapers. 20 Q I'm sorry? 20 Q All right. And I don't want to go back over 21 A I will come to you for that information. 21 what's in your previous depo, so we don't have to go 22 Q You are talking about more people that don't 22 through that, but in a response to a discovery request 23 like me. 23 Mr. Scarola produced a packet, to say the least, of 24 All right. You have advertised, besides your 24 e-mails that you had with various reporters, correct? 25 victims' rights stuff, your lawsuits against Epstein, 25 A I don't know. 18 (Pages 69 to 72) EMPIRE LEGAL SUPPORT, INC. (954) 241-1010 Electronically signed by Wendy Roberts Electronically signed by Wendy Roberts Electronically signed by Wendy Roberts e96a17a7-3aa9-4fee-bSa9-107af3379799 EFTA01126127 Page 73 Page 75 1 Q Now I got to work. 1 Q Yeah. And you found a lot of witnesses by 2 A Sorry. 2 looking for witnesses in sex cases, Farmer, Jaffe? 3 Q That's okay. 3 A We have found witnesses that way too. 4 (Thereupon, a discussion was had off the 4 Q Okay. And I mean, that is advertising, isn't 5 record.) 5 it, looking for -- looking for witnesses in sexual abuse 6 I'm trying to truncate this because I know 6 cases? 7 most plaintiff's lawyers and civil lawyers would keep 7 A Yeah, I — 8 you here for six hours and probably -- 8 Q We support crime — we are looking for Jeffrey 9 A I feel like we're headed down that road. 9 Epstein, child molester, that's you guys wrote that out, 10 Q You're not going to be headed down that road 10 right? 11 with me. I am not staying that long. I'm just trying 11 A We got a lot of calls being based on various 12 to find it. See if I was a civil lawyer, I would have 12 things, including the things you — you are talking 13 all of this stuff nice and neat. Where is this stuff? 13 about now, so yeah. 14 There it is. 14 Q And then as recently as -- I don't have the 15 There is -- and this is why I am doing this — 15 date, but recently you got — you're looking for 16 is, Dear Miss Coleman, the accompanied — this is 16 witnesses for youth pastor, J. London, firm is actively 17 May 8th, 2012, are — in producing response to 17 investigating or representing victims claiming sexual 18 plaintiffs discovery request, subject to our agreement 18 abuse by former pastor, J. London, click video below. 19 that this production does not constitute or support a 19 And then you're looking for our law firm prosecuted 20 waiver of privilege asserted as to any other documents. 20 numerous cases against registered sex offender, Jeffrey 21 A Okay. 21 Epstein. And then you have big headlines, Jeffrey -- 22 Q And there arc hundreds of e-mails that 22 big print, Jeffrey Epstein, registered sex offender, 23 Mr. Scarola produced to Miss Coleman. 23 correct? 29 (Thereupon, a discussion was had off the 24 A I have never actually seen that but that's -- 25 record.) 25 Q Well, here, let me show that to you. Page 74 Page 76 1 BY MR. HADDAD: 1 A Where does this come from, the Web site? 2 Q Okay. 2 Q Your Web site. 3 A I have seen those. 3 (Thereupon, a discussion was had off the 4 Q Oh, can I see them, because I want to go 4 record.) 5 through every one of them? 5 A Okay. Okay. 6 A I can't wait. 6 Q And from your profile, you realize that you 7 Q Well, you're -- if Scarola was here I would do 7 guys did all that stuff, correct? 8 it just for the hell of it. 8 A Yeah, I realize that. 9 A I bet you would. 9 Q Looking for witnesses, looking for clients? 10 Q I would. 10 A I am holding it right now, so I realize it. 11 MR. KING: Thank you. 11 Q Yeah. Let me see, this is Farmer, Jaffe Web 12 MR. HADDAD: You're welcome. 12 site stuff. Would you agree that this has been 13 BY MR. HADDAD: 13 recently -- Fanner, Jaffe, Weissing, attorney Brad 14 Q All right. In looking through these, these 14 Edwards pursued victims' rights cases on behalf of 10 15 are all c-mails that you sent, correct? 15 women who were — and it gives between 12 and 15 years 16 A I think either I sent or received or was 16 of age -- were sexually molested and abused by Palm 17 copied on. I mean, I think that there are some — 17 Beach resident, Jeffrey Epstein. Epstein, now a 18 Q All right. And there is no questions you had 18 registered sex offender and his -- what is that, Edwards 19 any relationships with the press throughout this entire 19 proved that Epstein, now a registered sex -- pedophile 20 proceeding? 20 in its international sex trafficking criminal enterprise 21 A I agree. 21 exploited them and hundreds of under-age girls, correct? 22 Q I mean, most good lawyers do. The press can 22 A What's your question? 23 be your best friend in cases. 23 MR. KING: Form. 24 A Right. Yeah, we've got a lot of witnesses 24 BY MR. HADDAD: 25 that way, I -- I agree. 25 Q Is that -- is that -- is that what your firm 19 (Pages 73 to 76) EMPIRE LEGAL SUPPORT, INC. (954) 241-1010 Electronically signed by Wendy Robe Electronically signed by Wendy Robe Electronically signed by Wendy Robe e96e17a74aa94fcc-b5a9-1e7af3379799 EFTA01126128 Page 77 Page 79 1 put out? 1 in London papers regarding Jeffrey Epstein? 2 A I don't know, I haven't seen that. You are 2 A Right now, as I sit here right now, no, I 3 pulling it from ow firm Web site. I told you I haven't 3 don't remember ever seeing this or knowing this. 4 input anything, so the fact that it's here, it seems 4 Q Okay. And did you ever express to your law 5 like it's here. 5 firm that you are so afraid of Jeffrey Epstein not to go 6 Q Well, I -- 6 do things like this because you might get him mad? 7 A You are reading it, right? 7 A No, the opposite. I mean, I think that being 8 Q I want to ask you questions. I am reading it 8 public is what saves me so—.—.—. 9 right? 9 Q Okay. 10 A It seems that way. 10 A I don't — 11 Q Okay. You have never seen that? 11 Q So the more public you are, such as -- well, 12 A No. 12 let me ask you this. 13 Q So your firm is putting these things out and 13 A If something happened to me right now, I think 14 they do it without your knowledge or with your 14 that everybody will know he did it, so I think that 15 knowledge? 15 helps. 16 A They know about my cases so—.—.—. 16 Q Have you ever been married? 17 Q I understand that. I'm just asking you if you 17 A Yeah. 18 are consulted about the content of what your firm IT guy 18 Q If something happened to -- 19 or whoever it is puts out, that's all I'm asking, not a 19 A Not as many times as you. 20 hard question. 20 Q And -- I'm just looking at this. How did you 21 A I was not consulted. Here's the thing, has 21 get $735,000 for three toes? 22 there ever been a conversation where the PR person has 22 A Three toes were chopped offend there was a 23 asked me the truthfulness of this information and me say 23 little more to it but—.—.—. 24 yes, that possibly happened. Have I known that this was 24 Q Oh, I guess so, that's a lot of money. 25 on our Web site, no. I don't have a problem with it 25 Okay. Now, the input that you have, I read Page 78 Page 80 1 being there but I -- my role in the firm is just not 1 somebody's book. Who's Michael Isikoff? 2 inputter of information on a Web site. 2 A I don't know. 3 Q All right. Now, Mr. Edwards is currently 3 Q You don't know who it is? 4 pursuing a precedent-setting case on behalf of young 4 A (Witness shakes head.) The name doesn't sound 5 girls who were sexually molested by a well-connected 5 familiar to me. 6 billionaire. Is that the same case or a different case 6 Q Okay. And you don't recall e-mails with him, 7 against Mr. Edwards? 7 such as -- 8 A Sounds like the Crime Victim Rights Act case a A I don't remem I don't know -- or recognize 9 that we discussed earlier. 9 the name. 10 Q All right. And that would still be against 10 Q All right. A gentleman from Newsweek 11 this gentleman, correct, Mr. Epstein? 11 magazine. You don't remember? 12 A It's actually against the U.S. Attorney's 12 A I feel like I talked to so many people, I 13 Office. 13 don't -- I don't really remember that name particularly. 14 Q All right. Well, it says here, on behalf of 14 If you show me something, I -- you know, if it says I 15 young girls — okay, well — and it says WPTB, news 15 sent an e-mail or received an e-mail, then I'm not going 16 coverage, WPBF. Does that mean your groups send these 16 to quarrel with it. I -- that name does not sound 17 out to the different radio stations or TV stations? 17 familiar. 18 A I don't know what it means. I doubt that 18 Q How about Michele Dargan? 19 that's what it means though, but I don't know what -- 19 A Yes, I know Michele. 20 Q I don't know, I'm just asking -- 20 Q And who is she? 21 A I don't know. 21 A She works with the Palm Beach Daily News. 22 Q how PR works, l thought maybe you did. 22 Q Okay. And how about some Cochalla lady, 23 A I don't. 23 Cochaca, what -- how do you say it, do you know who I 24 Q Okay. Were you familiar with your law firm 24 mean? 25 putting out that kind of publicity that you were quoted 25 A Also at the Palm Beach Daily News? 20 (Pages 77 to 80) EMPIRE LEGAL SUPPORT, INC. (954) 241-1010 Electronically signed by Wendy Roberts Electronically signed by Wendy Roberts Electronically signed by Wendy Roberts 996017a7-3aa9-4fcc-b5a9-197af3379799 EFTA01126129 Page 81 Page 83 1 Q I don't know, I'm just asking you. It's a 1 Q And one of the ways a lawyer can sway, as it 2 lady that you guys were talking about when they picked 2 were, public opinion to his case is to have an informed 3 up, what's his name, Polanski, you guys thought about 3 public from which he would be near his children, 4 maybe using the Polanski case to help rake gear up 4 correct? 5 some things, you had a series of e-mails. Do you recall 5 A I don't know. 6 that? 6 Q Well, you give -- you don't give newspaper 7 A I don't remember that either. 7 reporters information because you like them, you do it 8 Q You don't, okay. You don't remember anything 8 because want something put out in the public. 9 about anything about -- any corn — communications, 9 A I do it because I want information back in 10 Polanski got arrested, what, two years ago? They -- 10 return. 11 A I don't remember either. 11 Q Okay. But also — 12 Q — picked him up in Switzerland and then they 12 A It's -- you give to get. 13 had to let him go? 13 Q I am not going to be argumentative with you, 14 A I don't remember any correspondence about — 14 but having stuff in the paper about Epstein serves your 15 Q Conchita? 15 benefit to try to get cases settled, doesn't it? 16 A Conchita, yeah, I know — 16 A It serves my benefit to get witnesses to call 17 Q Who is she? 17 and to -- 18 A A reporter somewhere up north. 18 Q Umm-hmm. 19 Q Okay. And do you know how many e-mails you 19 A -- retrieve other information that would help 20 may have exchanged with her? 20 me prove the cases against him, and in the end if 21 A No. 21 proving the case against him is going to cause a 22 Q Do you know how many telephones calls you had 22 settlement, then indirectly I guess your statement was 23 with her? 23 true. 24 A No. I have had telephone calls. I have had 24 Q And suggesting with Conchita or whatever her 25 e-mails. 25 name is, that perhaps the arrest of, I forgot his name Page 82 Page 84 1 Q All right. Did you ever give Michele the 1 already. 2 phone number for Epstein's probation officer down in 2 MS. HADDAD COLEMAN: Roman Polanski. 3 Virgin Islands or anything? 3 MR. HADDAD: Huh? 4 A I don't remember doing that, but I might have. 4 BY MR. HADDAD: 5 Q All right. And do you recall giving them 5 Q Roman Polanski might be an impetus to get 6 information about where to find Mr. Epstein at various 6 together a bunch of mothers to protest Jeff Epstein, 7 times to different reporters and what you were able to 7 that would help your benefit? 8 find out about him? 8 A I don't remember that. 9 A Specifically, what? There is certain 9 Q Okay. Just asking the questions. 10 information I may have given. I —I was -- I use my 10 A If you can show me something, I will help you 11 discretion I think pretty responsibly to get the 11 out. 12 information that I needed while also disseminating only 12 Q I don't need to be helped out, I'm just asking 13 the information that I thought would ultimately be 13 if you remember right now. I know how to help myself, 14 helpful. 14 thank you. 15 Q To whom? 15 Okay. And that was 2009. Hm. You don't 16 A To whatever reporters that we're talking 16 remember Conchita asking you maybe to create a video 17 about. 17 against men in power? 18 Q Oh, and -- 18 A No. 19 A If we are talking about Michele Dargan, then 19 Q I found it amusing. 20 to Michele Dargan. 20 A I find it amusing as well. 21 Q It would be fair to say that your methods 21 Q But it's amazing they pick you as the 22 of excuse me, let me back that up. 22 forepoint? 23 As a trial lawyer, you recognize that the 23 A It is? Why? Is that a shot at me? 24 press can be invaluable among jurors, correct? 24 Q I would never take a shot at you. 25 A I agree. 25 A I felt that. 21 (Pages 81 to 84) EMPIRE LEGAL SUPPORT, INC. (954) 241-1010 Electronically signed by Wendy Roberts Electronically signed by Wendy Roberts Electronically signed by Wendy Roberts o96e17a7.3aa9-4fcc-b5a9.1e7af3379799 EFTA01126130 Page 85 Page H' 1 Q I am too professional for that. 1 that's the date, correct? 2 A That is a shot at yourself. 2 A Yes, I would assume so too. 3 Q That's something no one would ever say about 3 Q Now, are you aware or did you participate or 4 me, so I figured I would do it. 4 have any involvement in the plea or the sentencing of 5 A Uh, I don't remember that e-mail, but I, like 5 Alfredo Rodriguez? 6 you, find it somewhat amusing. I mean, you see me 6 A No. 7 saying I -- the cases seem so different, not factually 7 MR. KING: Let me interpose an objection. No? 8 but procedurally, or I'm unsure as to how we can use one 8 A The answer is no. I'm just wondering if, you 9 to help in the other, so I mean, that's my answer -- 9 know, that's — I remember reading my deposition last 10 Q But -- but I -- 10 time and we discussed what of these matters is relevant 11 A --1agree with today. 11 and et cetera. But the answer is no. 12 Q I understand that's your answer, but what we 12 BY MR. HADDAD: 13 are talking about is there is a -- a -- it is a -- 13 Q All right. Let — well, let's -- what it 14 almost a circle of people involved in this case 14 boils down to, nobody called up any of the objections 15 involving you, the press and others. I mean, there is 15 that were raised. And I'm not going go through the 16 hundreds of e-mails there. 16 whole deposition. 17 A More people in this case -- 17 A Yeah. 18 MR. KING: Objection, form. 18 Q I assume you read your deposition in the last 19 A -- than any other case I have ever had. 19 couple of days, did you not? 20 MR. KING: Objection to form. 20 A I did. 21 BY MR. HADDAD: 21 Q All right. And I'm sure your counsel read it 22 Q All right. And that's involved with members 22 and Mr. Scarola has innumerable objections. 23 of the public also? 23 A Right. 24 A I think that you could say that no matter what 24 Q Actually, one or two were meritorious, but he 25 category we are talking about, just a lot of people. 25 had innumerable objections on economic privilege, on Page 86 Page 88 1 Q Did you ever meet Conchita face-to-face? 1 other things, correct? If I were to ask you each of 2 A I did. 2 those questions 3 Q Where? 3 A The same objection. 4 A In the Palm Beach Courthouse. 4 Q -- they would be the same objections, your 5 Q Okay. State Courthouse? 5 counsel would make the same objections, that way I don't 6 A Yeah. 6 have to redo for two and a half hours. 7 Q Okay. On one of the Epstein cases? 7 MR. KING: That's correct. B A She approached me telling me that she had 8 BY MR. HADDAD: 9 known him for 20 years, coming -- I was coming out of 9 Q So I get in front of the judge and — 10 the courtroom. And I think that I was at a hearing on 10 A Fair enough. 11 an Ep -- on a case against Jeffrey Epstein. 11 Q — were you the confidential informant in 12 Q All right. And -- okay, can I see that back 12 Alfredo Rodriguez, confidential witness? 13 for a second? There was something else I wanted to see 13 MR. KING: The same objection. I'm going to 14 and let me just give -- if you don't mind giving me one 14 object and instruct him not to answer. 15 second. 15 MR. HADDAD: Okay. Thank you. 16 Are you familiar with a 2010 case. Your 16 BY MR. HADDAD: 17 deposition was in March of 2010, correct? 17 Q Did you contact — did you have any contact 18 A That's what you told me previously. You told 18 with any persons who were listed in the book that was 19 me February and then I think you corrected it to March. 19 eventually produced by Mr. Rodriguez after he got 20 Q Yeah, I corrected myself. 20 arrested and the book was made public? 21 A But you are right. 21 MR. KING: Let me object. I don't see the 22 Q Okay. I am showing you a copy. 22 relevancy, immaterial. 23 A March 23rd, 2010. 23 MR. HADDAD: Oh, because he's getting more 24 Q I am not sophisticated enough to change the 24 clients and it goes to reputation as to whether 25 date on the front page of a deposition so I assume 25 they hired him or not based on his contact. 22 (Pages 85 to 88) EMPIRE LEGAL SUPPORT, INC. (954) 241-1010 Electronically signed by Wendy Roberts Electronically signed by Wendy Roberts Electronically signed by Wendy Roberts e96e17a7-3aa9-41cc-bSa9-1e7af3379799 EFTA01126131 Page 89 Page 91 1 MR. KING: Was the book published by somebody 1 product, it's — 2 else? 2 MR. KING: No, it is. 3 MR. HADDAD: No, he I am asking the 3 MR. HADDAD: I'm not --I'm not going to argue 4 questions, I don't know. I didn't hear what you 4 with you here today. 5 said, I'm sorry, Jack, what was that? 5 MR. KING: It goes to his mental process. 6 MR. KING: That's all right. I said as to a 6 MR. HADDAD: You raise your objections. 7 book published by somebody else. 7 That's fine, Mr. King. 8 MR. HADDAD: No, no, no, no. What happened in 8 BY MR. HADDAD: 9 this, I am sure you are not familiar, is Alfredo 9 Q And I take it you won't answer the question as 10 Rodriguez was his -- was his house manager. 10 to whether or not you were a confidential witness? 11 MR. KING: Right. 11 MR. KING: The same objection. 12 MR. HADDAD: He gave a deposition in the case. 12 MR. HADDAD: Thank you. All right. Since a 13 Brad was there, I believe, and a bunch of other 13 ton of this is -- 14 lawyers that were suing Mr. Epstein. 14 MS. HADDAD COLEMAN: Can you hand me those 15 MR. KING: Right. 15 pleadings so I can mark them as exhibits. 16 MR. HADDAD: After that deposition, 16 MR. HADDAD: Oh, it's this? 17 Mr. Rodriquez approached an individual and said, 17 BY MR. HADDAD: 18 have a book that contains a lot more than what I 18 Q Did you attend Mr. Rodriguez' sentencing? 19 said at my deposition. In essence, I withheld tons 19 A No. 20 of stuff at my deposition, I want 50 G's. The 20 Q Did you have any contact with Mr. Rodriquez 21 person he approached, I assume, is Mr. Edwards. 21 after his sentencing? 22 Mr. Edwards, being the lawyer that he is didn't get 22 MR. KING: Objection. The same instruction. 23 the book, he approached the police and said someone 23 MR. HADDAD: Okay. 24 is trying to commit a crime, and the book -- the 24 BY MR. HADDAD: 25 gentleman was arrested through a roundabout 25 Q Did you have any contact with Mr. Rodriguez' Page 90 Page 92 1 different sort of thing. And then I assume the 1 subsequent employer, Sid Goldman? 2 book was made public and the names were produced 2 MR. KING: The same objection, all based on 3 and I wanted to know whether or not Mr. -- 3 work product. 4 MR. KING: That book? 4 MR. HADDAD: I need a five-minute -- 5 MR. HADDAD: That book. Whether or not 5 two-minute break. 6 Mr. Edwards had contact with any persons that were 6 MR. KING: Okay. 7 listed in that book. 7 MR. HADDAD: All right. Or do you want to 8 MR. KING: Well, along the lines that were 8 break for lunch? 9 taken last time with regard to whatever work he 9 THE WITNESS: How long are you going to be? I 10 undertook, whatever work product was involved in 10 mean, I don't know. 11 the investigation ofhis cases, in light of the 11 MR. HADDAD: I'm not sure. I mean, I've got 12 current status of the case, in which the you 12 two other lawyers that have to decide how long I'm 13 know, pending claim is what it is -- 13 going to be. That's why I'm asking for a 14 MR. HADDAD: Umm-hmm. 14 two-minute -- five-minute break. 15 MR. KING: -- I think it's -- it's even more 15 THE WITNESS: Take it, and then let's figure 16 reinforced those objections are and will be raised. 16 out how long we are going to be and if we need to 17 MR. HADDAD: All right. That's fine, I 17 take a lunch, we will, and if not then -- you know, 18 just -- to let you object. 18 if you have another hour, then I will sit here and 19 BY MR. HADDAD: 19 we'll take a lunch later. 20 Q The reason I'm asking the question is, did you 20 MR. GOLDBERGER: Let's say — 21 initiate or attempt to initiate any new lawsuits based 21 MR. HADDAD: You don't call the shots, I do. 22 upon what you learned in there? 22 MR. KING: Do you want to take two minutes. 23 MR. KING: The same objection. Instruct him 23 Fred? 24 not to answer. 24 THE VIDEOGRAPHER: The time is 11:58 a.m. We 25 MR. HADDAD: That's not going into work 25 are now coming off the video record. 23 (Pages 89 to 92) EMPIRE LEGAL SUPPORT, INC. (954) 241-1010 Electronically signed by Wendy Roberts Electronically signed by Wendy Roberts Electronically signed by Wendy Roberts e95e17a7.3aa9-4fcc-b5a9.1e7313379799 EFTA01126132 Page 93 Page 95 1 (Whereupon, a break was taken.) 1 aside, did you -- get get ready -- did you ever have 2 (Thereupon, Defendant's Exhibit Nos. I - II 2 any contact with Kendall Coffey regarding the propriety 3 and 13 & 14 were marked for identification.) 3 or ask him for an opinion of the propriety of taking 4 THE VIDEOGRAPHER: The time is 12:08 p.m We 4 that book from Mr. Rodriquez? 5 are now back on the video record. 5 MR. KING: The same objections, work product. 6 MR. KING: And just —just before before 6 BY MR. HADDAD: 7 we go on, I understand that you all have marked 7 Q Okay. 8 various exhibits that were referenced during the 8 A And attorney-client privilege. 9 course of the testimony which hadn't been marked 9 MR. KING: And Government privilege. 10 earlier which you now marked I through what? 10 MR. FIADDAD: And what? 11 MS. HADDAD COLEMAN: I through II. and they 11. MR. KING: Government privilege. 12 were shown to coun -- to Mr. Edwards during the 12 MR. HADDAD: Kendall Coffey, neah, he was 13 course of this deposition. 13 already out. 14 MR. KING: Very good. 14 MR. KING: He was already out by then, okay. 15 MS. HADDAD COLEMAN: And not contemporaneously 15 MR. HADDAD: Yeah, that was after he — oh, I 16 re-referenced. 16 shouldn't — MR. KING: Very good. 17 MR. KING: No, don't say that. 18 THE WITNESS: It's — it's a little bit more 18 MR. HADDAD: I don't -- why -- 19 than that, I through II and then 13 and 14. 12 was 19 MR. KING: I know what you're talking about. 20 taken out of there so—.—.—. 20 MR. HADDAD: — I don't like him. 21 MS. HADDAD COLEMAN: Okay. 21 MR. KING: You must have dealt with him while 22 MR. KING: So just let's put on the record 22 he was there. 23 what we have then so the record is clear. 23 MR. FIADDAD: Please. I am dealing with him 24 THE WITNESS: Okay. Exhibit I was part of 24 still. 25 Fanner, Jaffe, Weissing Web site. Exhibit 2 is 25 Page 94 Page 96 1 from the Web site. Exhibit 3 from the Web site, 1 BY MR. HADDAD: 2 Exhibit 4 from the Web site. Exhibit 5 from 2 Q All right, Brad, let me ask, do you have any 3 National Trial Lawyers Web site. Exhibit 6 from 3 contact these days with Critton's firm? 4 AVVO, A-V-V-O. Exhibit 7 from the Farmer, Jaffe, 4 A No. 5 Weissing Web site. Exhibit 8 from lawyers.com. 5 Q Okay. Not recently, not -- not -- okay. 6 Exhibit 9 from for 40 under 40. Exhibits JO and I I 6 Also you asked for some release of the 7 are interrogatories directed to me and responses. 7 confidentiality agreements, didn't you, for purpose of 8 Exhibit 13 is the transcript of the sentencing 8 obtain -- ascertaining money? 9 proceedings for Alfredo Rodriguez. Exhibit 14 is a 9 MR. KING: Hold on a second. 10 plea agreement between the United States and 10 A I don't think so. 11 Alfredo Rodriguez. 11 MR. GOLDBERGER: In the discovery. 12 BY MR. HADDAD: 12 MR. KING: In the what? 13 Q Let me go back, if I may, just for a minute to 13 MR. GOLDBERGER: In the discovery. 14 the plea agreement so your counsel can object. Did 14 MR. HADDAD: In the discovery. 15 you -- did you have any input -- did you ever read the 15 MR. KING: Okay. 16 plea agreement, particularly the factual presentation on 16 A I don't know. 17 Page 4 and 5,1 believe it is? 17 BY MR. HADDAD: 18 A I think the answer is no, but let me see if 18 Q Okay. Have you ever discussed with 19 this refreshes my recollection, hold on. What, Page 4 19 Mr. Scarola? 20 and 5? 20 A Really, that's how you are going to start your 21 Q I think whatever the factual basis is where it 21 question? 22 talks about Rodriguez approaching someone about what 22 Q Oh, yeah, yeah, yeah, yeah. Any of the 23 information he had. 23 confidentiality agreements or anything that was obtained 24 A I don't think I have ever read this. 24 in the confidentiality agreements? 25 Q And -- and going back to that just as an 25 MR. KING: Objection. 24 (Pages 93 to 96) EMPIRE LEGAL SUPPORT, INC. (954) 241-1010 Electronically signed by Wendy Roberts Electronically signed by Wendy Roberts Electronically signed by Wendy Roberts e96017a7.3aa941fcc•b5a9-107af3379799 EFTA01126133 Page 97 Page 99 1 A Attorney-client privilege. 1 if they were made again today. 2 BY MR. HADDAD: 2 MR. HADDAD: Yeah, he said that already. 3 Q Okay. I just -- I just ask the questions, 3 A I want to make a clean record too. If you had 4 that's all. You can always say no. 4 asked the same questions, I would have asserted at least 5 A I've just never heard of an attorney 5 the same objections. 6 actually — 6 BY MR. HADDAD: 7 Q You -- you — well, I -- 7 Q If not more. 8 A -- ask it that way. 8 A If not more, correct. 9 Q -- well, let me put it this -- you were aware 9 Q You have read them and thought about it and 10 that Mr. Scarola's law firm represented other purported 10 you arc -- 11 victims of Mr. Epstein, correct? 11 A Right. 12 A I was aware that his law firm represented 12 Q -- much more acquainted now that you arc in 13 victims of Mr. Epstein, yes. 13 the Best Lawyers in America and all that other stuff, 14 Q And how many? 14 you have better objections than the old guys. 15 A How many victims? 15 A I have better objections. 16 Q Yeah. 16 Q You are much -- you are much better than the 17 A I'm not sure. 17 old people. 18 Q All right. And do you know which lawyers? 18 MR. KING: But he's not usurping our role 19 A I believe that Jack was one of them. I know 19 entirely with regard those objections. 20 Jack was one of then. He was the main lawyer that 20 MR. GOLDBERGER: Okay. Were good. 21 handled the cases over there. 21 MR. HADDAD: I'm just a poor lawyer who 22 Q Okay. 22 doesn't have all these PR people and all of this 23 A In fact, I don't remember the name of any of 23 great stuff going on. 24 the other lawyers from the firm that handled the cases. 24 MS. HADDAD COLEMAN: Everyone understands this 25 Q All right. 25 deposition will be continued after the Court rules Page 98 Page 100 1 MR. HADDAD: I don't think I have any other 1 on everything. 2 questions. Does anybody have anything they want 2 THE WITNESS: Everybody understands the Court 3 to -- Debbie? 3 is going to rule on things and order me back to a 4 MR. KING: As I understand it, what — well, 4 deposition or not order me back to a deposition, 5 go ahead, I didn't mean to cut you off. 5 whatever the Court's going to do. 6 MR. HADDAD: That's okay. 6 MS. HADDAD COLEMAN: I don't want another 7 BY MR. HADDAD: 7 nasty letter from Mr. Scarola, so I just wanted to 8 Q As you know, we still have -- as you said you 8 be clear that we may -- 9 would not answer any of the questions that were 9 MR. HADDAD: Why, that -- that's his purpose 10 propounded to you before and objected to. 10 in life. Will you relax. 11 A My objection to those previous questions would 11 MS. HADDAD COLEMAN: But I just want it clear 12 be my objection today. 12 on the record. 13 MR. HADDAD: All right. It was set for a 13 MR. HADDAD: That's what happens when you get 14 hearing April 12th of 2011 and then again reset for 14 old. 15 another time and no one ever went -- the hearing 15 MR. KING: From our -- from our perspective. 16 never went forward, so those questions are still 16 you understand we were not producing records here 17 objected to, unresolved. So well stop. We will 17 today, the financial records, because we were 18 go from there, sec whatever happens. 18 asserting the financial privacy privilege? 19 THE WITNESS: Okay. 19 MS. HADDAD COLEMAN: Of course. 20 MR. GOLDBERGER: Well, wait a minute. Just 20 MR. KING: So I gather that that would have 21 one thing. I just want to make sure we have a 21 put you in a position where you would not have been 22 clean record here. So if we had asked the same 22 able to, nor would you have proceed with questions 23 questions, he would have raised the same 23 today. 24 objections, so not only are we going to raise the 24 MR. HADDAD: We wouldn't even -- no, as long 25 previous objections, we are going to raise them as 25 as it's pending before the Court, I saw no purpose 25 (Pages 97 to 100) EMPIRE LEGAL SUPPORT, INC. (954) 241-1010 Electronically signed by Wendy Roberts Electronically signed by Wendy Roberts Electronically signed by Wendy Roberts e96e17a7-3aa9-4fcc-b5a9-1e7af3379799 EFTA01126134 Page 101 Page 103 1 in having to reestablish that you were objecting 1 2 and, you know 2 STATE OF FLORIDA 3 MR. GOLDBERGER: Obviously, if those records BROWARD COUNTY 3 4 had been produced, we would have had a ton of SUBSCRIBED AND SWORN to before me this 5 questions about that but—.--.--. 4 day of , 2013 at Broward County, 6 MR. KING: I understand, but my only concern Florida. 7 was I didn't know, because I was not there at the 5 8 hearing, I didn't participate in any way with 6 9 respect to that, so I don't know what the Court's Notary Public, State of Florida at Large 7 10 expectations were as to whether or not the Court 8 Commission No: 11 wanted you to ask any questions. If you don't 9 My Commission Expires: 12 proceed, that's the case. 10 13 MR. HADDAD: No, I don't think it was 11 14 necessary -- 12 15 MS. HADDAD COLEMAN: In his order, the Court 13 16 14 permitted the deposition to go forward. I said at 15 17 the hearing we wouldn't get into any questions that 16 18 were directly related to those documents, with the 17 19 express understanding once the Court rules we may 18 20 ask whatever the Court permits us to ask. 19 21 MR. KING: That's what I needed to know. 20 22 21 Thank you. All right. 22 23 MR. HADDAD: All right. We're -- do you 23 24 want -- do you want to read or waive this part of 24 25 it? 25 Page 102 1 THE WITNESS: I will read it. CERTIFICATE OF OATH 2 MR. GOLDBERGER: Okay. STATE OF FLORIDA 3 THE VIDEOGRAPHER: The time is 12:16 p.m. We COUNTY OF BROWARD 4 are now coming off the video record. This is the I, the undersigned authority, certify that BRADLEY 5 end of Tape No. 2. EDWARDS personally appeared before me and was duly SWOM 6 THE COURT REPORTER: Do you want this typed on the 15th day of May, 2013. 7 up? 8 MR. HADDAD: Do I want it typed up? I'd Witness my hand and official seal this 24th day of 9 like -- you got to make money. I represent the May, 2013. 10 richest guy in America. 11 THE V1DEOGRAPHER: Counsel, copy of the video? 12 MR. HADDAD: Huh? Wendy Roberts 13 THE VIDEOGRAPHER: Do you want a copy of the Registered Professional Reporter 14 video, sir? Notary Public, State of Florida at Large 15 MR. HADDAD: Sir? No. I don't know. Do we Commission No.: EE178268 16 want a copy of the video? My commission expires: March 29,2016 17 THE COURT REPORTER: Do you want a copy of 18 this? 19 MR. KING: Yes, please. 20 (Witness excused.) 21 (Deposition was adjourned at 12:16 p.m.) 22 AND FURTHER DEPONENT SAITH NOT 23 24 25 SIGNATURE OF WITNESS 26 (Pages 101 to 104) EMPIRE LEGAL SUPPORT, INC. (954) 241-1010 Electronically signed by Wendy Robe Electronically signed by Wendy Robe Electronically signed by Wendy Robe O6e17a7-3aa9-4fcc-b5a9-197af3379799 EFTA01126135 CERTIFICATE DEPOSITION ERRATA SHEET STATE OF FLORIDA, ) Our Assignment No. 10402 COUNTY OF BROWARD. ) Case Caption: JEFFREY EPSTEIN vs. SCOTT ROTHSTEIN I, WENDY ROBERTS, Registered Professional Reporter and Notary Public in and for the State of DECLARATION UNDER PENALTY OF PERJURY Florida at Large, do hereby certify that the I declare under penalty of perjury foregoing testimony was taken before me; that the that I have read the entire transcript of witness was duly sworn by me; and that the foregoing my Deposition taken in the captioned matter pages constitute a true record of the testimony given by said witness. or the same has been read to me, and I further certify that I am not a relative or the same is true and accurate, save and employee or attorney or counsel of any of the except for changes and/or corrections, if parties, or a relative or employee of such attorney any, as indicated by me on the DEPOSITION or counsel, nor financially interested in the ERRATA SHEET hereof, with the understanding action. that I offer these changes as if still under Under penalties of perjury, I declare that I oath. have read the foregoing certificate and that the Signed on the day of facts stated herein are true. , 2013. Signed this 24th day of May, 2013. BRADLEY EDWARDS / WENDY'I2DB RTS, Registered Professional Reporter EMPIRE LEGAL SUPPORT, INC. DEPOSITION ERRATA SHEET 401 EAST LAS OLAS BOULEVARD. STE 1400 FORT LAUDERDALE, FL 33301 Page No._Line No. Change to: To: BRADLEY EDWARDS, ESQUIRE Reason for change: Fanner Jaffe Weissing Edwards Fistos Lehrman 425 Noah Andrews Avenue. Suite 2 Page No. Line No. Change to: Fon Lauderdale. Florida 33301 Re: CASE NO.: 502009CA040800X)OCXMBAG Reason for change: / Page No. Line No. Change to: Dear BRADLEY EDWARDS. Reason for change: Your deposition taken in the above entitled cause is now ready for signature. Page No. Line No. Change to: Please come to this office and sign same. or if you with to waive the signing of the Reason for change: deposition. please so advise. If this deposition has not been signed Page No. Line No. Change to: within 30 days of todays date, May 24th. 2013, we shall consider your signature waised. Your prompt attention in this matter is Reason for change: appreciated. Page No. Line No. Change to: Sincerely, Reason for change: Wendy Page No. Line No. Change to: Reason for change: SIGNATURE: DATE: BRADLEY EDWARDS 27 (Pages 105 to 108) EMPIRE LEGAL SUPPORT, INC. (954) 241-1010 Electronically signed by Wendy Roberts Electronically signed by Wendy Roberts Electronically signed by Wendy Roberts e96e17a7.3aa9-4fee-b5a9-1e7af3379799 EFTA01126136 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 28 (Page 109) EMPIRE LEGAL SUPPORT, INC. (954) 241-1010 Electronically signed by Wendy Roberts Electronically signed by Wendy Roberts Electronically signed by Wendy Roberts e96et7a7.3ea9.4tcc-bga9.1e7af3379799 EFTA01126137