EFTA00599662.pdf

Page 1 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 50 2009CA040800XXXXMB AG Complex Litigation, Fla.R.Civ.Pro. 1201 JEFFREY EPSTEIN, Plaintiff, -vs- VOLUME I OF II SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and III. individually, Defendants. VIDEOTAPED DEPOSITION OF BRADLEY J. EDWARDS, ESQUIRE Tuesday, March 23, 20010 10:00 - 5:07 p.m. 2139 Palm Beach Lakes, Boulevard West Palm Beach, Florida 33401 Reported By: Cynthia Hopkins, RPR, FPR Notary Public, State of Florida Prose Court Reporting Job No.: 1333 PROSE COURT REPORTING AGENCY, INC. EFTA00599662 Page 2 1 APPEARANCES: 2 On behalf of the Plaintiff: 3 ROBERT D. CRITTON, JR., ESQUIRE BURMAN, CRITTON, LUTTIER & COLEMAN, LLP 4 Boulevard West Palm Beach, Florida 334O1 Phone: 7 and JACK ALAN GOLDBERGER, ESQUIRE ATTERBURY, GOLDBERGER & WEISS, P.A. 10 11 12 and West Palm Beach, Florida 33401-5012 Phone: 13 On behalf of the Plaintiff: 14 ALAN M. DERSHOWITZ, ESQUIRE HARVARD LAW SCHOOL 15 Cambridge, Massachusetts 02138 16 Phone: 17 On behalf of the Defendant: 18 JACK SCAROLA, ESQUIRE SEARCY, DENNEY, SCAROLA, 19 BARNHART & SHIPLEY, P.A. 20 West Palm Beach, F on a Phone: 21 22 ALSO PRESENT: 23 Jeffrey Epstein 24 Joseph Kozak, Videographer Prose Reporting Services 25 PROSE COURT REPORTING AGENCY, INC. EFTA00599663 Page 3 1 2 INDEX 3 _ _ 4 5 EXAMINATION DIRECT CROSS REDIRECT 6 BRADLEY J. EDWARDS, ESQUIRE 7 BY MR. CRITTON 5 8 9 10 11 EXHIBITS 12 13 14 EXHIBIT DESCRIPTION PAGE 15 PLAINTIFF'S EX. 1 ALFREDO RODRIGUEZ 211 16 CRIMINAL COMPLAINT PLAINTIFF'S EX. 2 COMPLAINT 239 17 PLAINTIFF'S EX. 3 JULY 22, 2009 276 FACSMILE 18 19 20 21 22 23 24 25 PROSE COURT REPORTING AGENCY, INC. EFTA00599664 Page 4 PROCEEDINGS 2 Deposition taken before Cynthia Hopkins, 4 Registered Professional Reporter and Florida 5 Professional Reporter, and Notary Public in and for 6 the State of Florida at Large, in the above cause. 7 8 9 THE VIDEOGRAPHER: We are now on video record. This is Media Number One in the 10 videotaped deposition of Bradley Edwards in the 11 matter of Jeffrey Epstein versus Scott 12 Rothstein, Bradley J. Edwards, and 13 Today is Tuesday, March 23rd, 2010 at 14 10:00 a.m. We're here in the law offices 15 of Searcy, Denney, Scarola, Barnhart & 16 Shipley, 17 West Palm Beach, Florida. 18 My name is Joe Kozak. I am the 19 videographer. The court reporter is Cindy 20 Hopkins from Prose, Prose Court Reporting 21 Agency. 22 Will counsel please introduce 23 yourselves, and then the court reporter 24 will swear in the witnesses. 25 MR. CRITTON: Bob Critton on behalf of the PROSE COURT REPORTING AGENCY, INC. EFTA00599665 Page 5 Plaintiff, Jeffrey Epstein. MR. GOLDBERG: Jack Goldberger on behalf of the Plaintiff, Jeffrey Epstein. 4 MR. DERSHOWITZ: Alan Dershowitz on behalf 5 of the Plaintiff, Jeffrey Epstein, of counsel. 6 MR. SCAROLA: The record should reflect that Mr. Epstein is also personally present. 8 My name is Jack Scarola. X am counsel on ° behalf of the Defendant/Counter-Plaintiff, Brad 10 Edwards. 11 Thereupon, 1.2 (BRADLEY J. EDWARDS, ESQUIRE) 1.3 having been first duly sworn or affirmed, was 14 examined and testified as follows: 15 THE WITNESS: Yes. 16 DIRECT EXAMINATION 17 BY MR. CRITTON: 1.8 Q. Would you please tell us your full name 19 and home your home address. 20 A. Bradley James Edwards, 21 22 Q. Date of birth, please. A. Q. Mr. Edwards, have you ever had your )4 25 deposition taken before? PROSE COURT REPORTING AGENCY, INC. EFTA00599666 Page 6 A. No. 2 Q. Okay. But you've counseled, you've 3 obviously taken a number of depositions both as a 4 Plaintiff and as a Defendant. You're familiar with 5 all the rules? 6 A. I know the rules. 7 Q. All right. Again if I ask you a question 8 you don't understand, if you would ask me or if you 9 want me to rephrase it, I will be happy to do that. 10 A. Yes. 1 MR. SCAROLA: Mr. Edwards, Mr. Edwards, knows the rules. You can skip the preliminaries. 14 MR. CRITTON: Is that a form objection? 15 MR. SCAROLA: No. 16 MR. CRITTON: Just a talk. 17 MR. SCAROLA: It's a, it's a request that 18 you not waste our time. 19 MR. CRITTON: I am not wasting your time. 20 And if we hadn't gone through that, we would 21 have been done with them, Jack. 22 BY MR. CRITTON: 23 Q. Mr. Edwards, are you currently employed? 24 A. Yes. 25 Q. And by whom are you currently employed? PROSE COURT REPORTING AGENCY, INC. EFTA00599667 Page 7 A. I don't understand the question. Q. For whom do you work at the current time? Are you an employee? A. I am a partner in the law firm of Farmer, 5 Jaffe, Weissing, Edwards, Fistos & Lehrman. 6 Q. Is that a professional association? 7 A. Yes. 8 Q. And you said you're a partner. Do you 9 have your own P.A. or is the only the Farmer -- what i0 was the second name, Jaffe? 11 A. Correct. '2 Q. And I will refer to it as Farmer, Jaffe, 13 if that's all right with you. Is Farmer, Jaffe itself a P.A.; that is, are you a partnership of P.A.'s? A. Yes. Q. Do you have your own professional It; 19 20 association? A. Yes. Q. Okay. What's it called? 21 A. Law Office of Brad Edwards, LLC. 22 Q. You are the sole member of that LLC? 23 A. Yes. 24 Q. And then your LLC is a partner of the 25 Farmer, Jaffe firm? PROSE COURT REPORTING AGENCY, INC. EFTA00599668 Page 8 1 A. Correct. 2 Q. And do you hold yourself out to the public 3 as being a partner of that firm; that is you 4 individually? 5 A. What do you mean by hold myself out to the 6 public? 7 Q. If I got your letter would your letter 8 say, if I received a letter from you would it say 9 Brad Edwards, partner, or something to that effect? 10 A. I don't think so. 11 Q. Okay. What does your card say? Do you 12 have a business card? 13 A. I do. 14 Q. Okay. What does your business card-- lb A. Attorney. 16 Q. -- reflect? And when you introduce 17 yourself to clients or other attorneys for the first 18 occasion, do you introduce yourself as a partner of 19 that firm if asked? 20 A. If asked are you a partner; is that your 21 question? 22 Q. Correct. 23 A. Would I say yes? The answer is yes. 24 Q. When did you start -- I want to strike 25 that. Do you consider yourself an employee of the PROSE COURT REPORTING AGENCY, INC. EFTA00599669 Page 9 1 partnership? 2 A. What do you mean by that? 3 Q. Do you understand what an employee is? 4 A. I work for the firm. 5 Q. You are certainly not -- 6 A. I am employed there, so, yes. 7 Q. When did you start your association with 8 the Farmer, Jaffe firm? 9 A. Sometime during the month of November, 2009. 10 Q. And is that when the firm was incorporated 11 as a professional association? 12 A. I believe so. 13 Q. The attorneys who are in the current firm, 14 are they all former Rothstein Rosenfeldt Adler 15 attorneys; that is, the professional staff? 16 A. Yes. 17 Q. Is there anyone -- Let me strike that. 18 Do you have paralegals as well that 19 work there? 20 A. Yes. 21 Q. Are any of the paralegals former, and if I 22 refer to Rothstein Rosenfeldt Adler as RRA, or RRA, 23 is that all right with you? 24 25 Q. Are there any other, are any of the A. I understand what you mean. PROSE COURT REPORTING AGENCY, INC. EFTA00599670 Page 10 1 2 3 4 paralegals that are currently employed by Farmer, Jaffe in any capacity whether they are independent contractors -- well, let me strike that. As employee's, I probably should ask this question: Does the firm, Farmer, Jaffe have 6 employees 7 A. Yes. 8 Q. -- separate and apart from the partners? A. Yes. 0 Q. And they are actually employed by the P.A., correct? I> A. Correct. 13 Q. Does the firm have any paralegals that 14 came over from the RRA firm, RRA? 15 A. Yes. 16 Q. Who are they? 11 A. Maria and Beth. 18 Q. Does Maria have a last name? 19 A. Yes. 20 Q. What is it, please? 21. A. I believe it's pronounced Kelljian. 22 Q. Can you spell it? 23 A. I can give it my best shot, K-E-L-L-J-I-A-N. 24 Q. And Beth's last name is what, please? 25 A. Williamson. PROSE COURT REPORTING AGENCY, INC. EFTA00599671 Page 11 Q. She's your current secretary/paralegal, or 2 do you have a secretary as well? 3 A. I don't understand your question. 4 Q. Do you have -- is Beth Williamson your 5 paralegal? 6 A. She's a paralegal at the law firm of Farmer, 7 Jaffe, Weissing, Edwards, Fistos & Lehrman. 8 Q. Does she primarily work for you? 9 A. No. 10 Q. Do you have a secretary as well? 11 A. The law firm? Yes. 12 Q. The secretary who works primarily for 13 you -- 14 A. No. 15 Q. You just use whoever is available from a 16 secretary standpoint? 17 A. No. 18 Q. Who do you primarily use for secretary 19 services? 20 A. There is nobody who could fall into the 21 category of who I primarily use. 22 Q. Ms. Williamson, who, by whom, who, who was 23 the attorney at RRA with whom she primarily worked? 24 A. I believe it was several attorneys, and I 25 can't tell you who the attorneys were that she worked PROSE COURT REPORTING AGENCY, INC. EFTA00599672 Page 12 for or with. 2 Q. Did she work with you at all at RRA? A. In some limited capacity, maybe. 4 Q. Did she ever work on any of the -- you 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 24 have three cases that you ever filed -- or let me strike that. There are three cases that are in existence at the current time. One is Jane Doe versus Mr. Epstein which is, is a federal court case and the Plaintiff's name is Jane Doe. That is one of your cases, correct? A. Correct. Q. Or one of the firm's cases at the current time? A. Correct. Q. There is another case versus . Versus Jeffrey Epstein and a third called III. versus Jeffrey Epstein, correct? A. Yes. Q. And as a result all three of those cases currently now are firm cases, the Farmer, Jaffe firm cases? A. Yes. Q. cases? Did Mrs. Williamson work on any of those PROSE COURT REPORTING AGENCY, INC. EFTA00599673 Page 13 1 A. In what time period? What's your question? 2 Q. I'm sorry. During the time that you were 3 associated with RRA, did Mrs. Williamson work on 4 those cases? 5 A. Without you needing to ask 20 different 6 questions to get to your answer, I will tell you her 7 involvement was that after federal motions were drafted, 8 she was the person to literally file the motion. That 9 is her only involvement with the cases while at RRA 10 Q. She basically filed them through the Pacer 11 system? 12 A. Exactly. 13 Q. Prior to you working at Farmer, Jaffe by 14 whom were you employed? And by employed I mean in, 15 in a broad sense. You could have been an 16 independent contractor. You could have been a 17 partner. You could have been an employee. 18 A. The law firm of Rothstein Rosenfeldt Adler. 19 Q. When did you start working for RRA? 20 A. I believe April of 2009. 21 Q. Beginning of April? 22 A. Yes. 23 Q. I saw a pleading that was filed yesterday 24 and it was either ., I am sorry, . or 25 that looked like there was a change of -- I'm sorry, PROSE COURT REPORTING AGENCY, INC. EFTA00599674 Page 14 1 notice of appearance or something by RRA Would 2 that, in any way, if I asked you to assume that 3 that's correct, would that refresh your recollection that it may have been at the end of March? A. I don't understand that question at all. 6 Q. I saw a pleading that was filed or -- 7 A. Yesterday you said. 8 Q. -- a paper that was filed. I was looking 9 at a pleading filed in either III. or III., and I 10 saw a paper that was basically a notice of 11 appearance on behalf of RRA And it looked like it 12 was dated around March 30 of 2009. 13 A. Okay. 14 Q. Is it possible that you started your 15 association with RRA at an earlier date than April 16 of '09? 17 A. Assuming that what you said is true, if that 18 document says that, then it's possible that is an 19 accurate reflection of when I began. 20 Q. Did you start working with RRA before you 21 filed any documents representing that RRA or that 22 you had now an affiliation with RRA? A. No. 24 Q. Where the -- again, I don't remember, F. whether there was a notice of additional counsel or PROSE COURT REPORTING AGENCY, INC. EFTA00599675 Page 1 1 substitution of counsel. Did you, were the 2 substitution of counsel's filed the exact date that 3 you started with RRA? 4 A. I don't remember. Q. When did your association with RRA 6 terminate or end? 7 A. The end of October 2009 or the beginning of 8 November 2009. 9 Q. And how did it terminate? How did your i t relationship with RRA terminate? A. The firm closed. i2 Q. Did you get, notification -- when you say 13 closed, meaning what? 14 A. Meaning what everybody in this entire room 15 knows is that the firm went from operating to no longer 16 operating. 1 / Q. And how did you receive notice; that is, 18 did you receive some sort of notice that told you 10 that RRA now is a defunct firm? Did you receive 20 notification that was in bankruptcy? What, if 2i anything, did you receive? 22 A. I didn't receive anything. 23 Q. And then how did your relationship with 24 RRA end? 25 A. Came to work on a Monday morning, and there PROSE COURT REPORTING AGENCY, INC. EFTA00599676 Page 16 1 was a meeting that was held informing all the employees including myself that the firm no longer was financially 3 able to survive and therefore would be immediately 4 closing down. 5 Q. Who was the spokesperson at the meeting, 6 the main individual who advised those assembled in 7 the room that that's what was going to occur? 8 A. I don't remember. 9 Q. Was it -- did Rosenfeldt speak at all at 10 that meeting? 11 A. I, I can't remember. 1.2 Q. Do you remember the date of the meeting? 13 A. I remember that it was a Monday. 14 Q. Do you remember it being in October or November? 16 A. Either the very end of October or the very t7 beginning of November. is Q. Did anyone -- well, let me strike that. I9 Do you remember whether the person -- let me strike 20 that. 21 At the meeting who was present, and I 22 don't mean individual names. Who did it, by groups, 23 who did it include? 24 A. The meeting was held in a cafeteria type room 25 in the building where RRA maintained its offices. And PROSE COURT REPORTING AGENCY, INC. EFTA00599677 '1 Page 17 the room was completely full to capacity with as many employees of the Rothstein, Rosenfeldt Adler firm as were in attendance at work that day. 4 Q. And included lawyers, paralegals, support 5 staff, investigators? 6 A. Literally -- 7 Q. -- everyone, I mean everyone who obviously 8 showed up at the meeting? 9 A. I don't know. 10 Q. Did you see other lawyers there? 11 A. Yes. 1.2 Q. Did you see staff there? 13 A. Yes. 14 Q. Did you see paralegals there? 15 A. Yes. 16 Q. Did you see investigators there? 17 A. I can't necessarily remember whether or not I 18 saw investor -- investigators there. 19 Q. And did more than one person speak at the 20 meeting? 21 A. I don't remember. 22 Q. Okay. What else were you advised at the 23 24 25 meeting, if anything? A. It was -- I stayed for very little of that meeting. I don't know what was advised to others, but PROSE COURT REPORTING AGENCY, INC. EFTA00599678 Page 18 1 what I heard was, firm is closing down. That's all I needed to hear and I left. 3 Q. Did you subsequent -- well, let me strike that. Did you, were you able to gain, gain access to the building that day? I am sorry, access to your, to the offices of the Rothstein firm that day? A. Yes. Q. And were you able to access any of your files or your e-mail at that time? o A. What time? Q. That same day, that Monday that you were advised that the firm was shutting down. 13 A. Yes. 14 Q. And were you able to print documents? 15 Well, let me strike that. Were you able to take 16 documents relating to matters on which you worked 17 from the firm? 18 A. What do you mean by was I able to? 19 Q. Were you able to access and take with you 20 21 22 23 24 25 documents that related to files on which you were working the preceding Friday when you were at RRA? A. I believe so. Q. Did you take, did you actually remove documents, papers that were related to files that you had on which you were working from RRA that day? PROSE COURT REPORTING AGENCY, INC. EFTA00599679 Pncin 1 A. I don't believe so. 2 Q. Okay. Was anyone preventing you from 3 taking anything? 4 A. No. 5 Q. Okay. Did you print out any documentation 6 from your server or from the firm's server that day 7 to take with you? 8 A. Not that I recall. 9 Q. Do you recall taking anything from 10 RRA'office that day, that day being that same 11 Monday? 12 A. No. 13 Q. Obviously Scott Rothstein was not there? A. Correct. Q. Have you ever spoken, excuse me, have you ever seen Mr. Rothstein since that Monday at the meeting? A. What do you mean have I seen him? Q. Seen him in person, I'm sorry. 20 A. No. 21 Q. Okay, have you spoken with him at any time 22 since the Monday meeting at which time you were 23 advised that the firm was shutting down? 24 A. No. 25 Q. Have you spoken on any, with anyone on his PROSE COURT REPORTING AGENCY, INC. EFTA00599680 Page 20 1 behalf; that is, who purports to represent 2 Mr. Rothstein since you left the firm that day? 3 A. No. 4 Q. Do you know Mr. Nurik? 5 A. Yes. 6 Q. Do you recog -- are you aware that he 7 represents Mr. Rothstein? A. Yes. 9 Q. Okay. Have you spoken with him since that 10 Monday? 11 A. He called me on a morning before a hearing to 12 ask me where Judge Crow's courtroom was. And I told J3 him, and that was the extent of that conversation. 4 Otherwise, I have had zero communication with Marc Nurik. I6 Q. With regard to the firm being advised that 17 the firm was shutting down on that Monday, did you 18 subsequently return to the firm's offices? Let me 79 strike that. How long did you stay at the firm that 20 day? 21 A. I don't remember. 22 Q. Did you stay all day? 23 A. I believe so. 24 Q. Were you able to work on your files? 25 A. I don't understand the question. PROSE COURT REPORTING AGENCY, INC. EFTA00599681 Page 21 5 6 9 10 Q. Were you able to do legal work on the matters that wherein you represent individuals? A. Was I able to? Yes, I was physically able to do that. Q. Did you work on legal matters that day? A. No. Q. Did you subsequently, after that date, did you return to the RRA offices? A. Yes. Q. And where are those offices or where were 1 1 those offices located? A. 3 Q. The address, please? 14 A. I don't remember. 15 Q. With regard to the -- 16 A. 17 Q. 18 A. (Witness nods head.) 19 Q. Did you, did you after that Monday did you 20 return to the offices at the RRA 21 offices? 22 A. Yes. 23 Q. And did you return every day thereafter 24 for a period of time? 25 A. No. PROSE COURT REPORTING AGENCY, INC. EFTA00599682 Page 22 Q. Was there a point in time that you were 2 prevented from entering your office or the offices of RRA? A. Yes. Q. At what point in time were you prevented from going into the offices? A. I don't remember. 8 Q. How many days were you able to access the 9 offices before you were prevented? 10 A. I don't remember. 11 Q. You don't know whether it was a day or 12 three days or five days that you were allowed to go 13 into the office? 14 A. The period of time that I was able to go into 15 the office encompasses all of those things that you just 16 said, one day, three days, five days, yes. I can 17 definitely say with certainty I was able to do that. 18 Q. During the month of October were you 19 allowed to go into the office more than ten days? 20 A. Yes. 21 Q. Did they put -- well, let me strike that 22 Did someone put restrictions on what your access was 2 , to the office, the RRA office? 24 A. Yes. Q. Okay. Who put the restrictions on the PROSE COURT REPORTING AGENCY, INC. EFTA00599683 Page 23 1 entry to the office? 2 A. I don't know. 3 Q. Well, who would, who would monitor whether 4 you came in or couldn't go into the office? 5 A. I don't know. 6 Q. Was there someone there? 7 A. Was there someone where? 8 Q. The impression I got is that there was 9 some limitation on your ability to access the RRA 10 offices after the Monday at which time you were 1.1 advised that the firm was shutting down. Did I 12 misunderstand you? 1.3 A. No, that's correct. 14 Q. Okay. Who then, if you know, or what, if 15 it was an entity, placed any restrictions on your 16 access to RRA offices? 17 A. I don't know. 18 Q. When you would go to the office well, 19 let me strike that. After how many days -- well, 20 let me strike that. 21 The very day, the same day that you 22 were advised that the office was closing down, were >3 there any individuals that were monitoring what, if 24 anything, was to be removed or not removed from the )f office, like a security force, Broward County PROSE COURT REPORTING AGENCY, INC. EFTA00599684 Page 24 1 Police, U.S. Marshals. A. From my recollection there were at some point 3 in time, there were people in the office monitoring 4 activity in the office. 5 Q. Was that the first week after the Monday? 6 A. I don't recall. 7 Q. Did you ever, did you receive any guidelines either at the Monday meeting or thereafter as to what you could or could not remove 10 from the file, from the, I'm sorry from the RRA 11 offices? 12 A. I believe so. 13 Q. And who put those guidelines out, do you 1.4 recall? 15 A. No. 16 Q. Were they in a written form? 17 A. No. 18 Q. Okay. Was given in what form, how did you 19 learn what you could and could not take from the 20 office? 21 A. More rumor than anything else is what I 22 remember. 23 Q. Did you discuss that with other 24 individuals or other attorneys who were working at 25 RRA? PROSE COURT REPORTING AGENCY, INC. EFTA00599685 Page 25 1 A. Possibly. 2 Q. Did you ever attempt to remove something 3 from the office of the RRA offices and someone prevented you? A. No. Q. Did you ever and when I say remove I mean in the sense of physically remove; that is, take out boxes or take out files or something of that nature. 10 A. I understand the definition of remove. 11 Q. With regard to, there were also, I 12 understand you had an e-mail server at the office? 13 A. Okay. 14 Q. Is that correct? 15 A. Yes. 16 Q. And I have seen something, there is 1% something that's called Qtask. Are you familiar 18 with Qtask? 19 A. Yes. 20 Q. And what do you understand Qtask or what 21 did you understand that Qtask did; that is, as an 22 electronic service? 23 A. A web based network to store files and other 24 materials. 25 Q. In terms of electronic storage, or ari PROSE COURT REPORTING AGENCY, INC. EFTA00599686 Page 26 2 3 4 electronic data at the RRA firm, in addition to, excuse me, the e-mail server was and Qtask, was there anything else from an electronic storage or communication means through RRA? 5 A. Yes. 6 Q. What else was there? 7 A. That stored electronic materials? 8 Q. Right, or that you could communicate with 9 someone else either inside or out of the firm. You 10 had the server, e-mail server. You had Qtask. What else did you have? 12 A. To communicate with others, e-mail and Qtask. 13 Q. And how about within the confines of the 14 firm, was there another electronic mail system or 15 electronic system either for storage or for 16 communication? 17 A. To the best of my recollection, none for 18 communication. Storage, yes. There were electronic 19 paperless storage case management systems in place. 20 Q. And with regard to the electronic case 21 management system, were your files, including the 22 three cases involving Mr. Epstein, were those cases 23 on the electronic case management system? 24 A. Yes. 25 Q. And could you access the electronic case PROSE COURT REPORTING AGENCY, INC. EFTA00599687 Page 27 management system; that is, did you utilize the 2 software that was available? A. Yes. 4 Q. And had you ever used a system like that before you came to the RRA firm, RRA? 6 A. I don't understand. Q. Okay. Had you ever used an electronic 8 case management software system before you came to 9 RRA? 10 A. Yes. 11 Q. Was yours the system that you had used 12 before was that were you able to integrate that with 1.3 RRA, with the RRA file or system when you got there, 14 or did your files have to be put on the new RRA 15 system? 16 A. The latter. 17 Q. In addition, so we had the e-mail server, 18 Qtask, and electronic case management system. Was 19 there any other type of electronic storage or system 20 that was available for communication or storage at 21 RRA? 22 A. Not that I recall. 23 Q. With regard to the e-mail system, well, 24 with regard to the e-mail system, Qtask, and 25 electronic case management, did you require, was PROSE COURT REPORTING AGENCY, INC. EFTA00599688 Page 28 1 there a password required to use or access each one? A. No. Q. Was there a password required to use any 4 of the three? 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. I don't believe so. Q. As I saw in an order that with the Qtask system that there was some sort of access code that was required to get into Qtask. A. I saw that too. Q. Did you ever have, did you ever have such a code or a password with regard to Qtask? A. I don't remember. Q. Has the receiver and/or it's, Mr. Seton or his attorneys asked for you to provide any passwords or information to access any of your files? A. I don't think so. Q. Do you understand that you have a requirement or you're required to give the password if requested by Mr. Seton? A. I don't know the password to give to anybody. I never knew there was a password. Q. Did you -- A. I don't believe. Q. Did you use Qtask? A. I have used Qtask. PROSE COURT REPORTING AGENCY, INC. EFTA00599689 Page 29 1 Q. With regard to your, the files 2 specifically, specifically the -- well, let me 3 strike that. During the time you were at RRA, of 4 the three files, Jane Doe, ill., and III. or in addition to those three files, did you represent any other individuals who were potential claimants against Mr. Epstein? A. I don't believe so. Q. All right. I received notification from you as to a Ms. 11 A. 12 Q. . and Ms. III. I believe is her name? 13 A. Correct. 14 Q. Were either of those individuals, had 15 either of those individuals contacted you prior to 16 leaving the RRA firm? 17 A. I don't believe so. 18 Q. Is it your testimony then that none, I9 neither Ms. III. nor Ms. III. would have had a fee '0 agreement or representation agreement with the RRA 21 firm because they hadn't contacted you prior to your departure from that firm; is that correct? 23 A. I'm not sure. 24 Q. Is it possible that Ms., either Ms. III. 25 or. Ms. III. contacted you before you left the RRA PROSE COURT REPORTING AGENCY, INC. EFTA00599690 Page 30 1 firm but you just didn't sign them up before you left? MR. SCAROLA: Objection, calls for speculation. THE WITNESS: Yes. 6 BY MR. CRITTON: 7 Q. Is there a reason that you would not have 8 signed them up during the time you were with -- or let me strike that. Prior to the implosion, prior, 10 prior to that Monday when you were advised that the 11 RRA firm was closing down, had you made any plans to 12 leave that firm, that is the RRA firm? 13 A. No. 14 Q. Okay. Had you discussed with any other 15 attorneys in RRA departing from RRA or the RRA firm 16 prior to that Monday meeting at which time you were L; advised that the firm was shutting down? I A. No. Q. You indicated it's possible that Ms. III. 20 or Ms. III. may have contacted you prior to your zi departure or prior to that Monday meeting. What 22 makes you believe that? 23 A. I don't remember exactly the timing of any 24 communications between myself and Ms. III. or Ms. III. 25 And it seems to me that it was around the time period PROSE COURT REPORTING AGENCY, INC. EFTA00599691 Page 31 1 either just before or just after I do believe I spoke with one or maybe both of them on at least one occasion 3 before the disbandment of RRA 4 And I know for a fact I signed each 5 one of the clients up after the disbandment of RRA 6 I can't tell you with any degree of certainty whether they signed a fee agreement with RRA prior 8 to the disbandment. 9 Q. Have you been able to do any transfers of 10 your, of -- let me strike that. With regard to the 11 e-mail server at RRA, have you had occasion to access that since that Monday; that is, the Monday 13 meeting that you referred to in either late October 14 or early November of '09? 15 A. Yes. 16 Q. All right. And have you had full access, 17 at some point did you get full access to all of your 18 e-mail that, that existed at least, that you had not 19 removed -- let me start again. 2.0 Under an e-mail server you, you have 21 the ability, obviously, to delete what you, what you 22 choose, correct? 23 A. As do you. 24 Q. As do I, right. And were you using like a 25 Microsoft Outlook program? PROSE COURT REPORTING AGENCY, INC. EFTA00599692 Page 32 A. I don't remember. Q. Okay. A. I am now. Q. Well, with the program that you did have, 5 could you delete it and then you would have to go 6 into the delete it and further delete it to clean it 7 out? 8 A. I don't remember. 9 Q. You don't remember back to October or lo September of '09 at this point? 11 A. That's just not what i do. I mean, I don't 12 just delete e-mails. So I don't know what you had to 13 do. You take me for somebody more e-mail savvy than I 14 am about that. 15 Q. Do you basically save all your e-mails or 16 had you in the past when you were at RRA? 17 A. I don't intentionally save or delete. They 18 are just there. 19 Q. And when you, when you, at some point 20 after the Monday meeting, were you able to transfer 21 whatever e-mails you had from RRA to your current 22 program? A. At Farmer, Jaffe, Weissing? Q. Correct. 21-) A. No. PROSE COURT REPORTING AGENCY, INC. EFTA00599693 Page 33 1 Q. Were you at some point given access to all 2 your e-mails so it could be downloaded either on a 3 disk, hard disc, floppy disk, or some other storage medium so that you had access to all your prior e-mails when you were at RRA? A. I don't know. Q. Did you ever make that request to someone, either the receiver or anyone else associated with RRA? 10 A. I don't remember if I made that request. 11 Q. I thought you indicated earlier, 12 Mr. Edwards, that you had access to some of your 13 e-mails. 14 A. I had access to all of my e-mails on that 15 Monday of the meeting, on the next day, on that Tuesday, 16 right, the immediately following the meeting. 32:46 at 17 some point in time it was cutoff and since that time, 18 when it was cutoff, I don't believe I have ever had 19 access back to my entire e-mail system. 20 Q. Okay. Have you had access to portions of 21 your e-mail system? 22 A. Not that I remember. 23 Q. Have you attempted to obtain access or 24 requested that you obtain access or information from 25 your e-mail, from the RRA e-mail server? PROSE COURT REPORTING AGENCY, INC. EFTA00599694 Page 34 1 A. I don't remember. 2 Q. You say you don't remember. Would there 3 have been a reason that you either requested or 4 didn't request access to your prior e-mail? When I 5 say prior I mean at RRA 6 A. Usually you read all of your e-mails and there 7 shouldn't be anything that I had not read. However, 8 there are some e-mails that you would like to keep 9 around. So there may have been reason for me to have 10 requested. However, I don't believe I was ever granted 1.1 access to those e-mails, and I can't specifically 12 remember requesting the e-mails. 13 Q. Within, within the e-mails you would have .4 corresponded with or communicated with people 5 outside of the firm and as well as people within the firm, true? A. Ever, yes. Q. During the time you were RRA A. Did I ever communicate with somebody outside? 20 I communicated with you. 21 Q. Correct. 22 A. So you know that to be true. Yeah, of course. 23 Q. I know that to be true. And my question 24 is as well within the server or e-mail system with 25 RRA, did you ever also communicate with other PROSE COURT REPORTING AGENCY, INC. EFTA00599695 Page 35 1 paralegals, other staff at RRA? 2 A. Yes. Q. And would you see, receive, if it was 4 something from one of the other partners at RRA 5 would you receive; that is, did you get firm-wide 6 e-mails from time to time about specific topics? 7 A. Yes. 8 Q. All right. When you, during the time that 9 you went back to RRA, did you printout, and up until 10 the time you were denied access to the e-mail 11 server, did you ever print, printout any e-mails or 12 transfer any e-mails that you can recall? L5 A. Not that I can recall. 14 Q. All right. With regard to the Qtask 5 system, have you been, since that Monday have you been able to use that system in any fashion? A. What do you mean by that? 18 Q. Have you been able to access Qtask either 19 to look to see what was there or in the alternative 20 pull information from so that you could printout 21 information from Qtask? 22 A. I don't know. Probably. 23 Q. Okay. Have you attempted since that 24 Monday -- well, after that Monday meeting -- let me 25 strike that. PROSE COURT REPORTING AGENCY, INC. EFTA00599696 Page 36 Since the meeting that occurred on that Monday at which time you were advised the firm was shutting down, have you accessed Qtask for any reason? A. I don't believe so. Q. What kind of -- you said, you described earlier that Qtask was a web based network of files for files and other materials. And in what fashion did you use Qtask during the time you were with RRA, RRA? 11 A. Qtask is a project centric web-based program. 12 So projects could be created. The project would 13 normally be a case, and that case discussed with lawyers 14 the way that you may gather around a table and discuss 15 it. And at times I was invited to projects on various 16 cases and utilized that system. 17 Q. Is that the only fashion that you would 18 have used Qtask during the time you were with RRA? 19 A. Yes. 20 Q. And when you say a project, as an example, 21 Jane Doe versus Jeffrey Epstein, if that had been 22 put, just this is hypothetically and then I will ask 23 you later whether that was in the system but if you 24 wanted or let me strike that. 25 Could Jane Doe versus Jeffrey Epstein PROSE COURT REPORTING AGENCY, INC. EFTA00599697 Page 37 been put in the Qtask program for, for purposes of 2 creating a project? A. Repeat it again. Q. Okay. Could a case like Jane Doe versus 5 Jeffrey Epstein been put in the Qtask system as a 6 project so that you and others could look at it? 1 A. You mean is, is, is the project capable of holding such a project? O. Yes, just generically. tu A. Yes, yes. 11 Q. And in terms of the RRA system, did the 12 RRA system ever have as, as a project Jane Doe 13 versus Jeffrey Epstein? 14 A. I don't believe so. 15 Q. Did you ever look in the Qtask, Qtask 16 system to determine whether you or anyone on your 17 behalf or any other person in the firm had ever put 18 Jane Doe versus Jeffrey Epstein into the Qtask 19 system? 20 A. Yes. 21 Q. Okay. And what did you find or not find? 22 A. I, I don't remember if that was the name of 23 any project in the system. It could have been, but it 24 may not have been. I don't remember that as a specific >5 project in the system. PROSE COURT REPORTING AGENCY, INC. EFTA00599698 Page 38 Q. When you say a specific project, if I 2 understand you correctly, Mr. Edwards, that would 3 have been, as an example, it could be any case. It 4 could be a real estate case, it could be a labor case, it could be Jane Doe versus Jeffrey Epstein, o but someone could, someone whether it was you or someone else could put in facts and information 8 about the case? 9 A. Similar to any case management system that's, 10 it just happens to be web based, but you have the right 11 concept. 12 Q. Is the concept the same concept for an 13 electronic, for the third electronic system, you had 14 the electronic case management system? 15 A. I suppose at full capacity it, it may. I just 16 wasn't that adept at Qtask to know all of the 17 capabilities of Qtask. 12 Q. With regard to the third item which I am t9 going to come back to Qtask in just a minute, Lhe >0 electronic case management software, what was the 21 name of that software? 22 A. I believe it's called Fortis. 23 Q. F-o-r-t-i-s? 24 A. I think so. 25 Q. I may have asked you, have you ever used a PROSE COURT REPORTING AGENCY, INC. EFTA00599699 Page 39 1. Fortis system before you came to Rothstein -- 2 A. Had I ever used Fortis before I came to RRA? 3 Q. Yes. 4 A. No. 5 Q. Now, back to Qtask. Did you, do you have 6 a recollection -- let me strike that. Did you ever 7 personally ever put any information into the Qtask S system for a project -- 9 A. Yes. 10 Q. -- on your cases? I t A. Yes. 12 Q. Did you ever put, and I think you just testified as to the best of your recollection, Jane 14 15 Qtask system, correct? 16 A. As the name of a project? 17 Q. Yes, sir. 18 A. No. I don't believe so. 19 Q. Well, was, when you say the name of a 20 21 22 23 24 25 Doe versus Jeffrey Epstein was never put into the project, could, could information about Jane Doe versus Jeffrey Epstein have gotten into the system but not identified as a, quote, unquote, project? MR. SCAROLA: Calls for speculation. MR. CRITTON: Do you understand the question, sir? PROSE COURT REPORTING AGENCY, INC. EFTA00599700 Page 40 THE WITNESS: I don't understand. MR. SCAROLA: Are you asking whether that, that capability existed? 4 MR. CRITTON: Sure. THE WITNESS: Did the capability exist? 6 MR. CRITTON: Right. Again Mr. Scarola 7 didn't want to let me go through the 8 explanation because he thought you understand 9 it and I know you did, Brad. I know you 1.0 understand. 11 THE WITNESS: I don't know that I 12 understand that question. I want to make sure 13 that I answer your question accurately. 14 MR. CRITTON: See, cut me off too early, 15 earlier. 16 MR. SCAROLA: No, too late. 1 / BY MR. CRITTON: 18 Q. Mr. Edwards, what I am trying to get is 19 you described the Qtask as being project centric. 20 And as I understood it, the project may be given a 21 label or a title? 22 A. Correct. 23 Q. So, it could be Jane Doe versus Epstein; 24 it could be Jane Doe; it could just be assault case; 25 is that correct, whatever you wanted to call or PROSE COURT REPORTING AGENCY, INC. EFTA00599701 Page 41 someone wanted to call the project? 2 A. You have the right idea. Q. And if I understand it correctly is in 4 terms of the project, is if it was, if it was as an 5 example the Jane Doe case, you could, you or anyone 6 else could put information in about Jane Doe, might 7 not call it Jane Doe, but whatever amount of 8 information you or anyone else wanted to put in, 9 could put it into the Qtask so that other attorneys, 10 staff, investigators, paralegals, anyone who could 11 access the Qtask system, could see that project; is 12 that correct? 13 A. So that the people that were invited to the 14 project could see the project and those people only. 15 Q. And when you say invited to the project, 16 is, would, would, assuming you're the person who 17 created the project -- 18 A. Okay. 19 Q. -- would you then set the parameters as 20 to, or the guidelines as to who could come into the 21 project? 22 A. Maybe. 23 Q. Okay. If, again, if it wasn't you, who 24 else could have set the parameters; that is, who 25 else can access the file? PROSE COURT REPORTING AGENCY, INC. EFTA00599702 Page 42 A. Let's say I am the lead on a project: I believe that is what it was called the, I believe that was the title given to the person that initiates the project, if I want to then invite one or two or three or 5 100 other attorneys to that project to help work on 6 various aspects, I could do that. 7 And if I didn't choose to add 8 somebody, and another attorney said make me a lead 9 so that I can add somebody, that's another way that 10 that other lead could have invited somebody else to 11 the project. 12 And when you open up the interphase 13 of Qtask, you're immediately shown a portfolio of or 14 a photograph of the people that are invited to the 15 specific project and those people can access it. 16 Q. So, if it was, as an example, if it was, 17 if you were the lead person and you invited 18 Mr. Adler and you invited Mr. Berger in and 19 Mr. Rothstein in, there, when you punched up the 20 Qtask on the screen, I would see Mr. Rothstein's 21 picture. I would see yours. I would see 22 Mr. Berger's and Mr. Adler's? 23 A. Correct. 24 Q. As an example. 25 A. Yes. PROSE COURT REPORTING AGENCY, INC. EFTA00599703 Page 43 1 Q. Would I only see pictures or would I see 2 names as well? 3 A. I don't remember that. 4 Q. Would it be a correct statement that 5 during the time you were at RRA, you did use Qtask? 6 A. Yes. 7 Q. And did you ever put projects; that is, 8 did you ever as the lead create projects through the 9 Qtask system? 10 A. Yes. 11 Q. Would someone else, would, assuming that 12 you were the lead and you created the project, would 13 only you be able to add information to Qtask? 14 A. No. 15 Q. Okay. Was, was any invitee or person 16 allowed access, was he or she allowed to add to 17 Qtask? 18 A. Correct. 19 Q. Okay. Would he or she also be able to 20 delete from Qtask if they were an invitee? 21 A. I don't know that. 22 Q. Were you ever, did you ever -- in any -- I 23 assume that you were not only the lead but from time 24 to time you were invited into Qtask; is that 25 correct? PROSE COURT REPORTING AGENCY, INC. EFTA00599704 Page 44 A. That's correct. 2 Q. And during the time that you did, you, 3 when you were the lead, are you the one who chose 4 what went into the file, to the Qtask file? A. No. 6 Q. Who would have made that decision? 7 A. Everybody in the, anybody that's invited can 8 add. I'm not the one that does it. Nobody has to come 9 to me to insert anything in the Qtask. You can add if 10 you're invited. 11 Q. Well, let's assume that you are, you're 12 the lead but you don't invite anyone; that is, you 13 create the 45:01 time project. You're the person 14 doing the adding, not staffwise but you're the 15 person that puts the information in. 16 A. I understood the question until you added the 17 segment about maybe some staff member helps you add the 18 Qtask. That just doesn't make sense with the program. 19 Q. Well, with Qtask, if you're the lead and 20 you don't invite anyone in because you're creating 21 the project itself, are you the person who chooses 22 exactly what goes in? 23 A. I am the person who puts in what goes in. 24 Q. All right. Are you, are you responding to 25 questions within Qtask where you put, you describe PROSE COURT COURT REPORTING AGENCY, INC. EFTA00599705 Page 45 1 the case. You describe the facts. You describe the 2 witnesses, things of that nature, or are you 3 actually, can you -- well, first of all can you do 4 that? A. Can you describe the case and describe the 6 facts? Yes, you can. Q. And is that, when you say project centric, is that what you're doing very much like the electronic, much like the Fortis program? A. It's not very much like the Fortis program in my mind, but it's, it is what you are doing, you're inputting information about a specific project. Q. Can you put in the facts about a case, 14 again just generically, can you put in facts about a 15 particular case and then ask someone in your 16 invitees to comment on what they think, might think 17 the value of the case is or is not and give iu suggestions as to discovery and things of that 19 nature? Is that all true? 20 A. Yes. 21 Q. And with regard to -- and once those 22 invitees show up and they're photographed, then each 23 of those individuals can have access to the file and 24 add their thoughts or opinions -- 25 A. Repeat it. PROSE COURT REPORTING AGENCY, INC. EFTA00599706 Page 46 1 Q. -- or suggestions. Let me strike that. 2 With regard to the Qtask, once, 3 once -- assuming that you're the lead, you create 4 the project and then you, you say, okay, now it's in 5 a form that I want to get some invitees involved. 6 Do you then send that project; that is, you then on 7 Qtask you list the invitees and those people would 8 be, get some sort of cue that they had been invited 9 to the project up to the Qtask system? 10 A. I don't remember the exact process for 11 inviting, but there is a way to invite. And to the best 12 of my recollection, they do receive a notification that 13 they have been invited so that they can accept. 14 Q. Okay. Can, can someone who has not been 15 invited also access the system? 16 A. No. 17 Q. Okay. And how do you know that? 18 A. That's just not how the system works. 19 Q. Well, it may not be how the system works, 20 but say if Mr. Rothstein wanted to access when he 21 was the head person at the RRA firm, he wanted to 22 access the Q, Qtask system, do you believe that he 23 would have been able to access the system whether 24 you invited him or not? 25 A. No. PROSE COURT REPORTING AGENCY, INC. EFTA00599707 Page 1 Q. And why do you believe that to be true? 2 A. It's not how the system works. 3 Q. Well, at least as you understand the 4 system? 5 A. Well, if you want to tell me that it works a 6 different way, then maybe you can persuade me but that's 7 how I understand the system. 8 O. I am not, I'm not arguing with you. 9 MR. SCAROLA: Actually you are. 0 THE WITNESS: Assuming you had been on _1 Qtask, it would help to get past all of these 2 questions. If you had been on Qtask it would 3 help to get past all of this and you would see 14 exactly what I am trying to describe to you. 5 MR. CRITTON: I would like to get on Qtask. 17 THE WITNESS: Qtask.com. 18 BY MR. CRITTON: 19 Q. Okay. I'll remember that. With regard 20 to, so as to whether or not Mr. Rothstein could have 21 accessed it or Mr. Rosenfeldt or anyone else who was 22 not an invitee at least from your knowledge, you 23 believe they cannot access it? l4 A. Correct. Q. Can you as well on Qtask, can you as well PROSE COURT REPORTING AGENCY, INC. EFTA00599708 Page 48 1 post documents like an attachment? 2 A. I believe it has that capability. I think the 3 answer is yes. 4 Q. Now, with regard to the three cases that 5 you -- well, with regard to Jane Doe versus Jeffrey 6 Epstein, I think you already told me you don't 7 recall whether you put that in Qtask; is that 8 correct? 9 A. I didn't tell you that. 10 Q. Okay. Let me ask you then: Did you ever 11 use Qtask, you personally create a project as it 12 related to Jane Doe's case against Mr. Epstein? A. No. 14 Q. To your knowledge did you direct anyone 15 well, let me strike that. Did you direct anyone to 16 create a project on Qtask for the Jane Doe case 17 against Mr. Epstein? 18 A. No. 19 Q. Okay. Do you know have you ever have 20 looked at the Qtask system -- let me strike that. 21 From what you were able to access of 22 the Qtask system, did you ever go online on the 23 Qtask system to determine whether anyone else had 24 ever put the Jane Doe case against Mr. Epstein on 25 Qtask? PROSE COURT REPORTING AGENCY, INC. EFTA00599709 Page 49 1 A. No. 2 Q. And therefore as you sit here today, you 3 don't know whether someone else, whether it was 4 another attorney, whether it was an investigator or 5 a staff person ever put the Jane Doe versus Epstein 6 case on Qtask? A. Or whether it was you, right. 8 Q. Right. As to III., did you ever put 9 .'s case or direct -- well, let me strike that. 10 Did you ever create a project for . on Qtask? 11 A. No. 12 Q. Did you ever direct that someone else 13 create a project in Qtask for the . case, 14 versus Jeffrey Epstein case? 15 A. No. 16 Q. Do you have any knowledge as to whether -- 17 let me strike that. Did you ever go on Qtask or 18 have you been able to determine whether anyone else 19 within the RRA firm put the . versus Jeffrey 20 Epstein case or any aspects of it on Qtask? Have 21 you looked or do you know? 22 A. I don't know. 23 Q. Has anyone told you that the . case 24 against Jeffrey Epstein was on Qtask? 25 A. No. PROSE COURT REPORTING AGENCY, 1NC. EFTA00599710 Page 50 1 Q. Okay. And so it's your testimony as far 2 as you know the versus Jeffrey Epstein case was 3 not ever on the Qtask system; is that correct? 4 A. To the best of my recollection today. 5 Q. When I describe both the Jane Doe versus 6 Jeffrey Epstein case and the III. versus Jeffrey Epstein case being on Qtask, I don't necessarily 8 mean just the pleadings. I mean any aspect of it, 9 not necessarily the pleadings or the fact that the 10 case was there but the factual circumstances 11 surrounding either case. 12 A. i am not going to get into what my 13 work-product privilege, I am not going to allow you to 14 pierce that privilege. I am not going to tell you what, 15 regarding those cases, was or was not on Qtask. 16 Q. Well, let me ask a specific question. So 17 if you want to claim some sort of privilege so the 18 record is clear. 19 A. Sure. 20 Q. With regard to, and let me go first to 21 the, finally to the III. case. With regard to the 22 versus Jeffrey Epstein case or any aspect of 23 it, did you ever put III. into the Qtask system? 24 MR. SCAROLA: Let us save you some time. 25 Why don't you ask whether the answers with PROSE COURT REPORTING AGENCY, INC. EFTA00599711 Page 51 regard to . would be any different than the answers given with respect to the other two cases. 4 MR. CRITTON: I would have rather have it 5 specific. Oftentimes judge want to see that. 6 So I understand that if I want something broad 7 later on, I would be glad to accept that, but 8 thank you. Do you remember my question, sir. 9 THE WITNESS: No. 10 BY MR. CRITTON: 1 Q. Okay. With regard MR. SCAROLA: For the record let me observe I believe that your insistence upon 14 asking the individual questions that you have l5 now asked twice with regard to the other 1L claims, and your refusal to ask the blanket I / question in the way in which I have suggested is an annoyance and embarrassment and a harassment of this witness which does nothing 20 but unnecessarily consume his time. 21 BY MR. CRITTON: 22 Q. Mr. Edwards, with regard to ., did you 23 ever put any aspects of that case; that is, not just 24 the pleadings but any aspects of the . versus 25 Jeffrey Epstein case onto Qtask? Did you ever PROSE COURT REPORTING AGENCY, INC. EFTA00599712 5 Page 52 1 create a project? MR. SCAROLA: You may answer. 3 THE WITNESS: There was never a project entitled to my recollection MI. versus Jeffrey Epstein, ill. versus Jeffrey Epstein, Jane Doe 6 versus Jeffrey Epstein. And you're asking was 7 any information about those cases ever put onto 8 Qtask? 9 MR. CRITTON: I didn't ask that question. 10 THE WITNESS: Okay. 11 MR. CRITTON: But I will in just a minute. 12 THE WITNESS: And my answer is no, those 13 titles are not, I don't believe were ever on 14 Qtask. BY MR. CRITTON: Q. Now, separate and apart from -- let me strike that. Let me just stay with with regard to . Did anyone else at your direction put any _9 information regarding . into the Qtask system, an 20 attorney, staff person, or secretary or another 21 lawyer? 22 A. What do you mean by information? 23 Q. Any information about . into the Qtask 24 system? 25 A. I don't remember. PROSE COURT REPORTING AGENCY, INC. EFTA00599713 Page 53 Q. Okay. So we don't -- you gave a broader response to a question or that is you rephrased the question. So, let me ask it in a broader sense. 1 Was any information about the, your three clients put into the Qtask, about your three 6 clients, Jane Doe, III., and III. versus Jeffrey Epstein, or against Jeffrey Epstein, was any 8 information ever put into the Qtask system? I don't, 9 want to know the information, just whether you put 10 information into the Qtask system. 11 A. Yes. 12 Q. Did you do it yourself or did you do it in 13 conjunction with someone else? 14 A. Explain to me what you mean by did I do it in 15 conjunction with somebody else. 16 Q. Well, is, you may have typed in the 17 information yourself. 18 A. I strike one key; somebody else strikes 19 another? 20 Q. No, you may have input all the information 21 you want, whatever information you want to put into 22 Qtask, you may have made the decision to do that. 23 All right. My question is someone else, a 24 secretary, or a paralegal may have helped you, an 25 investigator may have put some information in, at .Im.1.0.0,4•6U.4••••••F-Ial PROSE COURT REPORTING AGENCY, INC. EFTA00599714 Page 54 least at your direction regarding these three 2 individuals' claims against Mr. Epstein? 3 A. information that I put into Qtask is information that was inputted into Qtask by me. 5 Q. Did you ever direct anyone else to put any 6 additional information in with regard to those three 7 claims against Mr. Epstein? 8 A. I don't believe so. 9 Q. And what type of information did you put 10 into Qtask regarding the claims against Mr. Epstein? 11 MR. SCAROLA: Read that back, please. 12 (The requested portion of the record was 13 read by the reporter.) 14 MR. SCAROLA: We're going to object and 15 that I will instruct you not to answer on the 16 basis of both attorney-client and work-product 17 privileges. 18 MR. CRITTON: I assume if Mr. Scarola 19 asserts an objection, you're adopting that and 20 you would assert it. So, we don't have to do 21 that as A repetitious project here? 22 MR. SCAROLA: Correct. 23 MR. CRITTON: And that's correct. 24 MR. SCAROLA: You can, you can assume that 25 my instructions to Mr. Edwards will be followed PROSE COURT REPORTING AGENCY, INC. EFTA00599715 Page 55 1 by Mr. Edwards unless we expressly tell you 2 otherwise. 3 MR. CRITTON: All right. 4 MR. SCAROLA: So, when I instruct him not to answer, he will follow that instruction. 6 MR. CRITTON: And you will do that, correct? 8 THE WITNESS: That's correct. 9 BY MR. CRITTON: 10 Q. With regard to the, the generic, and it 1 11 understood you correctly that there was generic or 12 there was information put in on one, two, or three 13 of your clients' claims again Mr. Epstein, did you 14 have or identify individuals who were invitees to 15 that Qtask file? 16 A. I'm sorry, what's your question? 17 Q. Did you designate individuals who could be 18 invitees to that file? 19 A. Did I invite anybody into the project? 20 Q. Sure. 21 A. Yes. 22 Q. Okay. Who did you invite into the Qtask? 23 And let me ask you this first, Mr. Edwards: With 24 regard to the claims against Mr. Epstein, the only 25 three -- well, and I probably need to step back. PROSE COURT REPORTING AGENCY, INC. EFTA00599716 Page 1 Would it, would it be a correct 2 statement during the time that you with RRA that the 3 only claims that you had against Mr. Epstein were 4 Jane Doe, , and .? 5 A. The only clients I represented, yes. 6 Q. And not necessarily in a lawsuit but those 7 are the only people that, that you and RRA 8 represented in any, in any existing or potential 9 claims against Mr. Epstein during the time you were 10 with RRA? 11 A. I believe so. 12 Q. By the way, could, could an outside 13 person, that is a person outside the firm access 14 Qtask as well? 15 A. You can access it right now. 16 Q. Can -- did you ever allow someone who was 17 not associated with RRA to access the Qtask file 18 relating to Mr. Epstein? 19 A. No. 20 Q. Okay. Was there more than one file that 21 was created associated with the claims against 22 Mr. Epstein? 23 A. I don't remember. 24 Q. Did anyone to your knowledge -- well, let 25 me strike that. Did anyone other than you create a PROSE COURT REPORTING AGENCY, INC. EFTA00599717 Page 57 1 Qtask file relating to claims again Mr. Epstein? 2 A. To the best of my knowledge, no. I take that 3 back. I don't know who created the project, but I am 4 only aware of the project that I participated in related 5 to Mr. Epstein and his molestation of many children, 6 period. 7 Q. And what did you call the project; that is 8 how it was identified on the Qtask system? 9 A. I don't remember. 10 Q. Do you recall when it was created? 11 A. No. 12 Q. Do you recall whether it was created 13 within a month of your coming to RRA? 14 A. I don't remember. 15 Q. Do you recall whether it was, I think you 16 said approximately the beginning of April of '09 you 17 came to RRA, correct? 18 A. Correct. 19 Q. All right. And is it, just so the record 20 is clear it's, your testimony is you don't recall 21 whether you created the project in April, May, June, 22 July, August, September or October relating to the 23 claims against Mr. Epstein? 24 A. I don't remember if I created the project, 25 period. TIM •••••••...•••••M1 PROSE COURT REPORTING AGENCY, INC. EFTA00599718 Page 58 1 Q. Separate and apart from whether -- well, 2 let me strike that. If you didn't create the 3 project, who would have? 4 A. I don't know. 5 Q. Well, do you remember -- let me strike 6 that. Do you know whether with regard to the project, and for purposes of at least this question, 8 let me just call it the Epstein project, are you 9 okay with that designation? 10 A. Yes. 11 Q. Okay. With regard to the Epstein project 12 that was created in the Qtask system, if I am 13 understanding correctly, you don't remember whether 14 you created it or someone else did, correct? 15 A. Correct. 16 Q. Who would have had access to your files 17 that could have created the Epstein project other 18 than you? 39 A. That question makes no sense. 20 Q. Okay. 21 MR. SCAROLA: And it also assumes facts 22 not in evidence and does not have a prior 23 proper predicate. 24 THE WITNESS: That's why it doesn't make 25 sense. PROSE COURT REPORTING AGENCY, INC. EFTA00599719 Page Sq 1 BY MR. CRITTON: 2 Q. During the time that you were at RRA, did 3 a number of people have access to the Epstein files 4 either, either in a paper form or in an electronic 5 form? 6 A. Either/or, yes. Q • And maybe I should get a definition of, 8 with regard to the Epstein files, you had three 9 cases, Jane Doe, , and ., correct? 10 MR. SCAROLA: Excuse me. You used Epstein 11 file as a defined term earlier. Are you now 12 using it generically? 13 MR. CRITTON: I am going to use it 14 genically and when I come back to Qtask, I am 15 off Qtask for just a minute. So that I have an 16 understanding of how your filing was kept. And 17 I will come back to Qtask. So, right now I am 18 using the Epstein files in a generic form. Not 19 using Qtask. Okay. 20 MR. SCAROLA: Okay. 21 BY MR. CRITTON: 22 Q. With regard to the Epstein files or 23 matters, I know you had -- we know you have three 24 cases that were filed that we have already 25 identified, Jane Doe? II•emeillnwa, dneytat......MIArpeA).••••••1. PROSE COURT REPORTING AGENCY, INC. EFTA00599720 Page 60 1 4 A. That's good. Q. . and ., correct? A. Correct. Q. Were all materials relating to Jeffrey Epstein kept, kept under, at least for filing, for filing purposes at RRA, were they kept under the Epstein designation or, or some other designation? A. Yes. Q. Okay. And what was the designation? 10 A. I don't remember but it was either under 11 Epstein or some other designation. 12 Q. And at RRA, were there both paper files or 13 paper information as well as electronic information 14 that was stored or kept regarding the Epstein files? A. Correct. 16 Q. Was RRA supposed to be or at least 17 designed to be a paperless office? 18 A. Yes. 19 Q. And would every document that came that 20 was associated with the Epstein files, again in the 21 generic sense, was that scanned in or put into the 22 system in some fashion at RRA? 23 A. To the best of my knowledge. 24 MR. CRITTON: Just two minutes. 25 PROSE COURT REPORTING AGENCY, INC. EFTA00599721 Page 61 BY MR. CRITTON: Q. With regard to the scanned system; that 3 is, to store the electronic records, was that put in 4 through the, through the Fortis program? 5 A. Yes, I believe so. 6 Q. And did you as well -- let me strike that. 7 Prior to coming to RRA had you ever worked in a 8 paperless file or in a paperless office? 9 A. I don't understand. 10 Q. Had you ever been working in an office 11 prior to coming to RRA that was designed to be 12 paperless? 13 A. No, but as I mentioned earlier, I have worked 14 with case management software that stores electronic 15 versions of files, so therefore there is a paperless 16 system. 17 Q. Did you as well when you came to RRA with 18 regard to the Epstein related matters or the content 19 of your Epstein investigation and files, had you 20 placed any of that on a prior, a previous paperless 21 system or did you have the paper itself or both? 22 A. Both. 23 Q. And during the time that you operated at 24 RRA, did you operate both with a, you individually 25 with regard to the Epstein files, did you operate I I i bT .•• PROSE COURT REPORTING AGENCY, INC. EFTA00599722 Page 62 1 both in a paper and a paperless manner? 2 A. No. 3 Q. Did you operate only in a -- well, in what 4 way did you operate? 5 A. Paperless. 6 Q. Okay. So if, if as an example I sent you 7 correspondence or answers to interrogatories or a 8 response to a pleading and it came in the mail, 9 would that document be scanned and then you would 10 toss away the paper? 11 A. I don't know. 12 Q. So, you may well have had paper in 13 addition to -- well, let me strike that. Do you 14 even know whether the document was scanned? 15 A. If you're telling me you sent correspondence 16 in the mail and I would later see that correspondence in 17 my virtual mailbox, I make the logical assumption that 18 it was scanned. I never observed anything being 19 scanned. 20 Q. Okay. And do you, if something came to 21 you by mail, whether it was some form of discovery 22 or request, and I will be in the state cases, where, 23 which is not a paperless system and you don't file 24 through Pacer, would you ever see the paper that 25 actually came to your office or would you only see PROSE COURT REPORTING AGENCY, INC. EFTA00599723 Page 63 1 it electronically? 2 A. For the most part I would see it electronically, but I can't say that I have never seen a 4 piece of paper come in. MR. CRITTON: Okay. Let me take a few 6 minute break. 7 MR. SCAROLA: Well, wait a second. Do you 8 want to break at this point? 9 THE WITNESS: Not really. 10 MR. SCAROLA: Okay. We would like to keep 11 going. 12 MR. CRITTON: Can I just go to the rest 13 room for two minutes? 14 MR. SCAROLA: Yes. 15 THE VIDEOGRAPHER: We're now off video 16 record. The time is 11:21 a.m. 17 (A brief recess was held.) 18 THE VIDEOGRAPHER: We're now on video 19 record. The time is 11:28 a.m. 20 BY MR. CRITTON: 21 Q. Couple, few more questions in Qtask. Did 22 you ever allow Mr. Rothstein, was he an invitee on 23 the Epstein-related projects? 24 A. I don't believe so. 25 Q. With regard to the third electronic, the PROSE COURT REPORTING AGENCY, INC. EFTA00599724 Page 64 1 Fortis system where you, if I understand you 2 correctly, you input various information into that 3 Epstein regarding Epstein files; is that correct? 4 A. No. Q. You never used those systems with regard 6 to Epstein files? 7 A. I used the systems. I never input anything 8 into the system. I think it gets scanned in. 9 Q. And could anyone in the firm access the 10 Fortis system? 71 A. I don't know. 12 Q. Could you access other files that weren't 13 necessarily yours within the Fortis system if you 14 wanted to? 15 A. I don't know. 16 Q. Mr. Edwards, with regard to your 17 employment with RRA, did you know any of the RRA 18 partners prior to coming to that firm in 19 approximately April of '09? 20 A. What do you mean by know them? 21 Q. Did you know them? 22 A. Yes. 23 Q. As either an acquaintance or a friend? 24 A. Yes. 25 Q. Did you have any friends at the RRA firm PROSE COURT REPORTING AGENCY, INC. EFTA00599725 Page 65 1 before joining them? 2 A. People that I would consider to be my friend, yes. Q. Who. A. Russell Adler. 6 Q. And how did you know Mr. Adler? A. We worked out at the same gym for about, 8 approximately four or five years. 9 Q. What were you doing, prior to your 10 association with RRA, what was your employment? 11 A. What? 12 Q. Were you working as a solo practitioner? 13 Were you working with another firm prior to coming 14 to RRA in April of 09? 15 A. Solo practitioner. 16 Q. How long had you been a solo practitioner? 17 A. Approximately two years. 18 Q. During the time you were a solo 19 practitioner, did you ever have any associates 20 working for you, solo imply that you're the only 21 one, is that true, or did you have associates that 22 actually worked for you? 23 A. Various times I had clerks, law school clerks, 24 but that was it. 25 Q. But no other lawyers? PROSE COURT REPORTING AGENCY, INC. EFTA00599726 Page 66 Q. Right. Did you ever have an investigator work for you? 4 A. Yes. 5 Q. Okay. Do you know an individual by the 6 name of Fisten, F-i-s-t-e-n? A. I know an individual whose last name is 8 Fisten. 9 Q. All right. What's his first name, the one 10 you know? 11 A. Mike. 12 Q. Michael Fisten? 13 A. Yes. 14 Q. Mike Fisten ever do any work for you when 15 you worked as a solo practitioner at any time prior 1.6 to you joining RRA? 17 A. No. 18 Q. Did you know of Michael Fisten or Mike 19 Fisten prior to joining RRA? 20 A. No. 21 Q. With regard to the investigators that you 22 used prior to joining RRA, did you use, or were any 23 of those individuals ever employed by RRA during the 24 time you were there? 25 A. No. PROSE COURT REPORTING AGENCY, INC. EFTA00599727 Page 67 1 O. How did it, how did it happen that you 2 came to be employed by RRA? 3 A. I was offered a job. 4 Q. And how did that come, how did that come 5 about? 6 A. Talking with Russell Adler. 7 Q. Had you ever had a case against Mr. Adler 8 or with Mr. Adler, either you were on the same side 9 or against? 10 A. Yes. 11 Q. On how many occasions? 12 A. I can't recall. 1.3 Q. Okay. Did Mr. Adler approach you or did 14 you approach him? 15 A. We worked out at the same gym. It wasn't 16 about approaching somebody. 17 Q. How did the topic come up? 18 A. He works at this law firm Rothstein Rosenfeldt 19 Adler, and would talk about it in a positive way for 20 years before I joined the firm. 21 Q. And how did it come up that you would be 22 interested in possibly working there; that is did he 23 say gee, Brad, you should come talk to me or did you 24 say I am interested in working for the firm? 25 A. He would ask if I would be interested in PROSE COURT REPORTING AGENCY, INC. EFTA00599728 Page 68 ;oining the firm. 2 Q. Okay. And what happened then? What ultimately happened that you, that you went from 4 just having an interest to actually contemplating or 5 being offered a position? 6 A. I didn't say I had an interest. 7 Q. So, what happened? How did you then end 8 up at RRA? 9 A. Numerous conversations with Russell Adler and 10 him telling me about some of the other people there that 11 I believed to be good lawyers, respected, ethical 12 lawyers, and that this is a good place to work, great 13 comradery, you have a team, I know you handle big cases; 14 this will be something that will be good for you. And 15 that was something I talked to him about seriously for 16 four months maybe before joining RRA before finally 17 agreeing to meet Scott Rothstein. 18 Q. All right. Had, did Mr. Adler ever 19 discuss with you parameters or potential income or 20 salary or whatever the compensation package would 21 be -- 22 A. Not specifically. 23 Q. -- before you first met with 24 Mr. Rothstein? 25 A. Not specifically. PROSE COURT REPORTING AGENCY, INC. EFTA00599729 Mule 60 Q. How many times did you meet with Scott 2 Rothstein prior to accepting a position with RRA? A. Once. 4 Q. Where did the meeting take place? A. The restaurant BOVA. 6 Q. Did you understand Mr. Rothstein had an interest in BOVA? II A. At the time? 9 Q. Yes, sir. 10 A. No. 11 Q. Did you learn that during the time that 12 you worked for RRA 13 A. Yes. 14 Q. Okay. Who was present other than 15 Mr. Rothstein when you met with him at BOVA? 16 A. Nobody. 17 Q. Who had set up the meeting? 18 A. Russell. 19 Q. And had anything been discussed at least 20 as of that time with regard to what your opportunity 21 was or in terms of compensation? 22 A. Specifically, no. 23 Q. How long did the meeting with 24 Mr. Rothstein last? 25 A. Ten minutes. PROSE COURT REPORTING AGENCY, INC. EFTA00599730 Page 70 1 Q. Did you have lunch with him or you just sat down and talked with him at the table at the restaurant? A. Sat down and talked to him. Q. Had you submitted any kind of a resume to 6 Mr. Adler as to what your experience was? A. No. 8 Q. So, you, at that time you are a solo 9 practitioner. Mr. Adler calls you and says, or you 10 express an interest. Mr. Adler says we have an 11 interest in talking to you, and you set up a meeting l2 with Mr. Rothstein. Is that pretty much it? 13 A. You're now making things up that is totally 14 inaccurate, and doesn't reflect what I have been telling 15 you at all. I didn't express any interests. I wasn't 16 looking for a job. I wasn't seeking him out. In fact, 17 that is the exact opposite of what I have just gone 18 through explaining to you about conversations at the gym 19 that ultimately lead to him convincing me this is a good 20 place to come into and me agreeing to this meeting with 21 Scott Rothstein. 22 Q. Okay. When you went to meet with Mr! 23 Rothstein did you have any interest or was this just 24 a throw-away meeting. Maybe I misunderstood. What 25 did you -- let me strike that. What was the purpose PROSE COURT REPORTING AGENCY, INC. EFTA00599731 1 3 Page of the meeting if you had no interest in considering an opportunity with RRA? A. For the most part placate Russell Adler. Q. Did Mr. Adler know the type of cases you had? 6 A. Of course. 7 Q. And was he aware as of that date you had 8 filed the three cases against Mr. Epstein? 9 A. I don't believe so. 10 Q. Had you -- is it your belief that the 11 three cases against -- well, let me strike that. Do 12 you recall when the first meeting was or the only 13 meeting that you had with Mr. Rothstein prior to 14 joining the firm? 15 A. It was prior to joining the firm. 16 Q. All right. When was that? 17 A. I don't remember. 18 Q. Was it within a month of your joining RRA, 19 two months, three months, six months? 20 A. Definitely within six months of joining the 21 firm. Definitely within three months of joining the 22 firm. Within that three month period, I don't recall. 23 Q. So, sometime between January and April of 24 '09, you would have met with Mr. Rothstein for ten 25 minutes? 711 PROSE COURT REPORTING AGENCY, INC. EFTA00599732 Page 72 A. I believe so. 2 Q. Okay. What did you talk about; that is, 3 what was the substance of the meeting? 4 A. Russell says you would be an asset to the 5 firm. I will treat you fairly. Now, how much do you 6 expect to make? Okay. I can't do that, but as soon as 7 you show your worth here, your salary is exponentially 8 increased because at this firm we operate under a system 9 of fairness. That was the gist of the meeting. 10 Q. Did he ask you how much you were making at 11 that time or how much you had made the preceding 12 year, '08? 13 A. I believe so. 14 Q. What did you tell him? 15 MR. SCAROLA: Objection. Instruct you not 16 to answer on the basis of economic privacy. 17 BY MR. CRITTON: 18 Q. Did you tell him what you had made, total 19 compensation for the year 2008? 20 A. I don't remember. 21 Q. Well, if I, if I understood you correctly, 22 I thought he said is I can't meet that salary or 23 that level of compensation, so you must have told 24 him something. 25 A. Yeah. I answered his question, what did you PROSE COURT REPORTING AGENCY, INC. EFTA00599733 Page 73 1. expect. 2 Q. What did you tell him that you expected? 3 MR. SCAROLA: Objection, economic privacy. 4 BY MR. CRITTON: 5 Q. All I am interested now, not necessarily 6 what you were earning but what you told him, i.e., 7 Mr. Rothstein that you wanted to get or expected to 8 earn if you considered a job at RRA 9 MR. SCAROLA: Objection. Economic 10 privacy, instruct you not to answer. It's 11 neither relevant nor material nor reasonably 12 likely to lead to relevant material information 13 and invades the economic privacy of the 14 witness. 15 MR. CRITTON: Is that form? 16 BY MR. CRITTON: 17 Q. Mr. Edwards, you gave him a number, is 18 that correct? Him meaning Mr. Rothstein. 19 A. I believe so. 20 Q. And was the number that you gave him more 21 than you had earned for the year 2008 or less? 22 MR. SCAROLA: Same objection. 23 MR. CRITTON: Or the same? 24 MR. SCAROLA: Same objection, same 25 instruction. PROSE COURT REPORTING AGENCY, INC. EFTA00599734 Page 74 1. BY MR. CRITTON: 2 Q. Did you tell him that you -- did you tell 3 him that you wanted to make more money than you had 4 in the proceeding year? 5 MR. SCAROLA: Same objections and 6 instructions. 7 BY MR. CRITTON: 8 Q. Did he tell you how much you would be paid 9 if you came to work at RRA; that is, did he mention 10 a number: This is what your salary would be if you 11 come and work here? 12 A. I believe so. 13 Q. And what number did he say to you? 14 MR. SCAROLA: Objection and same 15 instruction. 16 BY MR. CRITTON: 17 Q. Did he also tell you that you would get an 18 economic incentive; that is, at the, at sometime 19 during the course of the year based upon your 2O production? 21 A. I would be compensated fairly. 22 Q. And that was it? 23 A. That was the gist. 24 Q. Okay. Did he talk about any benefits that 25 you would receive? PROSE COURT REPORTING AGENCY, INC. EFTA00599735 Page 75 1 A. Possibly. 2 Q. Do you recall what he said? 3 A. What do you mean by benefits? 4 Q. I mean would you get health insurance and 5 those types of things as well? 6 A. I believe that was discussed. I'm not sure. 7 I can't tell you I got them but I don't know. 8 Q. Did you discuss any of your cases that you 9 had with him? 10 A. No. 11 Q. Okay. Did you sign an employment 12 agreement at any time with RRA? 13 A. No. 14 Q. After the -- let me go back. Did you say 15 you did or did not discuss any of your current cases 16 with him? 17 A. Did not. 18 Q. Okay. Were you aware, had you discussed 19 your cases -- I think you said you had discussed 20 your cases or Russell Adler had an idea of the type 21 of cases you had? 22 A. Over the years Russ and I are friends; we 23 talked about cases. 24 Q. Did you say you had discussed the Epstein 25 cases with him? Him, meaning Adler. SIONMSISSIPI2W PAP la olf PROSE COURT REPORTING AGENCY, INC. EFTA00599736 Page 76 1 A. I, I don't believe I discussed the Epstein 2 cases with Russell Adler until after I was employed at 3 RRA 4 Q. Did you mention Mr. Epstein at your 5 meeting with Mr. Rothstein? 6 A. No. 7 Q. Did you mention any of your three clients 8 who were suing Mr. Epstein at the meeting with 9 Mr. Rothstein? 10 A. No. 11 Q. With regard to the, did you, did you 12 discuss with him if you came to work with RRA that 13 the cases -- well, let me strike that. Did he 14 mention that if, if you came and worked for the firm 15 that those cases would become the property of RRA? 16 A. No. 17 Q. Did you understand that to be true? 18 A. I mean, I suppose so. 19 Q. Okay. Did -- 20 A. I understood that I was going to be an 21 employee of the firm, of course. 22 Q. Well, did, did you, at the conclusion of 23 the meeting did you say, yes, I would like to work 24 here or how did you leave it? 25 A. Think about it. PROSE COURT REPORTING AGENCY, INC. EFTA00599737 Page 77 1 Q. And how long did you think about it? 2 A. I don't remember. 3 Q. Did you, and who did you contact? Well, 4 let me strike that. At some point did you make a 5 decision -- 6 A. Yes. 7 Q. -- to go work for RRA, correct? 8 A. Correct. 9 Q. Did Mr. Rothstein at the initial meeting 10 tell you whether you would be a partner? 11 A. No. 12 Q. Did he describe that you would be at least 13 to the public at large you would be described as a 14 partner? 15 A. No. 16 Q. Did you understand who the partners 17 were -- well, let me trick that. Is RRA, was RRA a 18 PA? 19 A. I don't know. 20 Q. Did you ever find out during, up through 21 today's date do you know whether RRA was a PA or an 22 LLC or an LLP? 23 A. No. 24 Q. Did you ever go online to look at who the 25 officers and directors were or had members if it was PROSE COURT REPORTING AGENCY, INC. EFTA00599738 Paqu "P-3 an LLP? 2 A. During the initial, initial meeting with Scott 3 Rothstein, he told me there are only two equity partners 4 of this law firm, and it will always be that way; myself 5 and Stuart Rosenfeldt, period. 6 Q. And did he say that they each own 7 50 percent, or did he say, they were just partners? 8 A. Did not say. 9 Q. Prior to your -- let me strike that. 10 think as you said at some point you made a decision 11 to join RRA? 12 A. Right. 13 Q. And who did you convey that to? 14 A. Russell. 15 Q. And what happened thereafter? That is, 16 how did you go from then being a solo practitioner 17 into RRA? How did you integrate yourself? What was 18 the timing and what did you do? 19 A. At some point in time I was no longer working 20 in my Hollywood office and was working at RRA on Las 21 Olas. So, physically 1 showed up to work at a different 22 location. 23 Q. And did someone -- well, let me strike 24 that. From the time that you announced that you 25 would go, you told Mr. Adler up until the time you Taus PROSE COURT REPORTING AGENCY, INC. EFTA00599739 Page 79 ended up at RRA, how much timed passed? A. I don't know. Q. Prior to starting at RRA, did you have any 4 further conversations with Mr. Rothstein; that is, 5 up until the day that you showed up at that office? 6 A. No. 7 Q. And in terms of the cases; that is, the cases with with .1 Jane Doe and . those 9 are cases that you had signed up when you were a 10 sole practitioner; is that correct? 11 A. Correct. 12 Q. And with each of those cases there was a, 13 there is also another lawyer that was involved -- 14 well, let me strike that. In one or more of those 15 cases is Mr. Howell involved, or was he at the time 16 you were a solo practitioner? 17 A. What do you mean by involved? 18 Q. Involved, was he a referring lawyer? 19 A. Yes. 20 Q. Was he the referring lawyer on all three 21 of those cases? 22 A. He was at least the referring lawyer directly 23 on one. 24 Q. Which one? I'm sorry. I didn't mean to 25 interrupt you. ['ROSE COURT REPORTING AGENCY, INC. EFTA00599740 Page 80 A. I'm finished. 2 Q. Which case was he the referring lawyer, Mr. Howell? 4 A. Q. And he may be the referring lawyer on Jane 6 Doe, and ., you just don't know as you sit here, 7 or he is? 8 A. He referred .'s case. 9 Q. And the other two cases is he is shown as 10 the referring lawyer? 11 A. Yes. 12 Q. There is also a person named Cassell who I 13 think is an attorney from Utah? 14 A. Okay. 15 Q. Do you recognize the name? 16 A. Yes. 17 Q. Okay. And what's his first name? 18 A. Paul. 19 Q. All right. Is he in any way a referring 20 lawyer, considered a referring lawyer with regard to 21 any of the three cases against Mr. Epstein? 22 A. No. 23 Q. What's his role? 24 A. Handles certain appellate issues. 25 Q. Okay. Is he, is he involved in as part PROSE COURT REPORTING AGENCY, INC. EFTA00599741 Si YLlcjr of, as a potential recipient of any contingency fee 2 or is he paid on an hourly basis, either when you were a sole practitioner during the RRA stages or at the current time? b A. Contingency. 6 Q. Does he get part, at least as it was set 7 up as a sole practitioner was Mr. Cassell also on 8 the contract with each of the three individuals? A. I don't believe so. 10 Q. You don't -- he is not on any of the 11 contracts, Mr. Cassell? 12 A. There is a contract that he is on but your 13 question is when the cases were first signed up, was he 14 on the initial contract. And I believe the answer to 15 that is no. 16 Q. Prior to the time or during the time that 17 you were in sole practice before you went to RRA was 18 Mr. Cassell ever on any of the contracts with the 19 three Plaintiffs? 20 A. Yes. 21 Q. Okay. When you moved to BRA, was a new 22 fee agreement signed with each of the individuals, 23 each of the three Plaintiffs? 2.4 A. No. 25 Q. Was there some form of an assignment? PROSE COURT REPORTING AGENCY, INC. EFTA00599742 Page 82 A. Well, not to my knowledge. I don't want to say no, but I don't know of any fee agreement that was signed with the client. 4 Q. As a -- from the time that the original -- 5 let me strike that. If I understood you correctly 6 is as an example . was your first case? A. First client. 8 Q. First client, right. Mr. Howell would 9 have referred the case, so he would have shown up as 10 a referring order. And at some point Mr. Cassell 11 also came on the contractor or a contract; is that 12 correct? 13 A. A contract, yes. 14 Q. So, there was at least two contracts with 15 regard to .7 16 A. That I remember. 17 Q. And with regard to ., Jane Doe, and 18 ., you don't recall any new contract being signed 19 between those individuals and RRA; is that correct? 20 A. That is correct. 21 Q. And with regard to the, whatever the 22 contingency fee was in each of those three 23 contracts, was that to be split? When you went to 24 RRA, how was it to be determined what RRA would 25 receive versus what you would receive or Mr. Cassell PROSE COURT REPORTING AGENCY, INC. EFTA00599743 Page R3 1 or Mr. Howell, assuming there had been some 2 resolution? 3 A. RRA would be standing in my shoes. 4 Q. And if I understand it correctly, there 5 was never an assignment of your contracts; that is, 6 as a solo practitioner to RRA; is that correct? 7 A. Correct. 8 Q. Okay. And it was your intent just 9 whatever the contract said when you went from solo 10 practitioner to RRA, if those cases had resolved 11 during that time period, RRA, you would have paid 12 RRA that portion to which you were been entitled and 13 Howell and a Cassell would have gotten their 14 percentage? 15 A. Correct. 16 Q. And with regard to, with the new firm, the 17 Farmer, Jaffe firm, where those new fee agreements 18 have been signed with your three clients? 19 A. Yes. 20 Q. And are Mr. Cassell and Mr. Howell still 21 on those contracts? 22 A. Yes. 23 Q. Has the receiver made a claim against the 24 proceeds of these three cases; that is, he filed, 25 Mr. Seton on behalf of or as trustee, has he filed a la•11•••!••••••••••o.k.l. • •.• PROSE COURT REPORTING AGENCY, INC. EFTA00599744 Pclge 84 1 lien again those cases? 2 A. No. Q. Has he sent you any correspondence 4 indicating that he intends to assert a lien against, 5 for attorney fees and/or costs that were incurred 6 during the time those cases were at RRA? 7 A. Not specifically related to those cases, but 8 in general, that concept is something that has been 9 communicated by a receiver or a trustee to us at Farmer, 10 Jaffe, Weissing. 11 Q. Have you at any time; that is, have you 12 acknowledged, has anyone at Farmer, Jaffe 13 acknowledged their responsibility to repay monies to 14 RRA? 15 A. I don't understand the question. 16 Q. If the case is settled, does Farmer, Jaffe 17 intend to repay the receiver a portion of the fees 18 at costs? 19 A. That issue has not been resolved. 20 Q. With regard to, with regard to the 21 third-party -- 22 (Interruption at the door.) 23 BY MR. CRITTON: 24 Q. Other than the attorneys is there -- with 25 regard to the, other than the attorneys, is there PROSE. COURT REPORTING AGENCY, INC. EFTA00599745 Page 85 anyone else other than, on any of these three cases; that is, potentially BRA, potentially your new firm, 3 Mr. Cassell, Mr. Howell and the Plaintiff, does 4 anyone else stand to benefit from a recovery in any 5 of those cases? 6 A. No. 7 Q. Has anyone, has any interest in any of the 8 three cases been assigned to a, to a third party 9 other than a law firm or a lawyer or a law firm; 10 that is, to an outside service? 11 A. No. 12 Q. Okay. Have any of the potential 13 settlements -- I'm sorry. Have any of the potential 14 proceeds from any settlement or verdict been 15 assigned or sold to anyone to your knowledge? 16 A. No. 17 Q. Has ., Jane Doe, or . sold, 18 assigned, exchanged for consideration, money, or 19 promises of money, any portion of their potential 20 settlements? 21 A. No. 22 Q. Or recoveries? 23 A. No. 24 Q. If I understood you correctly, 25 Mr. Edwards -- PROSE COURT REPORTING AGENCY, INC. EFTA00599746 Page 86 MR. SCAROLA: Let me interrupt for just a 2 moment. I don't know whether the circumstance applies but I want to be sure, does the scope of your question include a letter of protection 5 to a health care provider? 6 MR. CRITTON: No. 7 MR. SCAROLA: I don't know whether that 8 has occurred in any of these cases, but 9 assume that's not what you're looking for? 10 MR. CRITTON: I wasn't, but no, I'm 11 looking for -- I think it would not be applied 12 to any of the three. 13 You understand I wasn't talking about 14 health care providers. I am talking about 15 some independent person or entity that may 16 have purchased some interest or have been 17 assigned some interest in any of those 18 three lawsuits. Do you understand that? 19 THE WITNESS: I think I understood your 20 question, and my answer was responsive and I 21 was not thinking about letters of protection at 22 the time that I gave my answer. 23 BY MR. CRITTON: 24 Q. With -- if I understood you correctly, 25 . was your first case? PROSE COURT REPORTING AGENCY, INC. EFTA00599747 Page 87 1 4 A. You understood me correctly. Q. All right. And when did l". retain your services, please? A. And by first case, just to clarify, she was my first client -- Q• I will rephrase it. A. -- related to the matter that we're all 8 familiar with that relates to things that happened to 9 IIII. when she was young. 10 Q. Let me rephrase the question this way: If 11 I understand your testimony is ., and I'm 12 interested in Epstein cases; I am not interested in 13 other portions of your practice. You understand 14 that? 15 A. I do. And I think that you understand that 16 this case, .'s case and... case did not begin as a 17 case against Jeffrey Epstein. You know that and I know 18 that, and that's why it's difficult for me to ask, 19 answer these questions related to these clients because 20 this began as a case against the United States 21 Attorney's Office. 22 Q. All right. With regard to the, at least 23 your first representation of any of your three 24 clients that relate to Mr. Epstein in some fashion, 25 your first client was ; is that correct? PROSE COURT REPORTING AGENCY, INC. EFTA00599748 Page 88 A. That is correct. 2 Q. Do you recall when you first -- well, let me strike that. She was referred to you by 4 Mr. Howell? 5 A. That is correct. 6 Q. Okay. And how did Mr. Howell know you? 7 A. I have known him for a long time. 8 Q. Law school? 9 A. No. I have known him since, I'm from 10 Jacksonville Beach. He's from Jacksonville. I have 11 known him when I was probably ten years old. 12 Q. Okay. Has Mr. Howell, prior tole., h<ui 13 he ever referred to you any other client? 14 A. Yes. 15 Q. Did it involve some sort of a sexual 16 assault or battery? 17 A. Yes. 18 Q. How many clients prior to . had 19 Mr. Howell ever referred you? 20 A. I don't know. 21 Q. More than one? 22 A. Yes. 23 Q. When was referred to you, what was 24 your understanding as to the nature of the 25 representation, what would it be? PROSE COURT REPORTING AGENCY, INC. EFTA00599749 Page 89 A. I don't understand. Q. Why did come, why did she hire you in the first place? What was the purpose? 4 A. This is going to get into attorney-client 5 privileged information as to why she hired me which 6 would incorporate the things that she told me that 7 related to my representation, therefore, I am invoking 8 the privilege and not answering. 9 Q. With regard to . you filed a case -- 10 well, let me ask you this: Do you know how III came 11 to contact Mr. Howell? Did he ever relate that to 12 you? 13 MR. SCAROLA: If it's in information that 14 you obtained from your client, I instruct you 15 not to answer. If it's information that you 16 obtained from Mr. Howell, I also instruct you 17 not to answer. Both instructions are on the 18 basis of attorney-client and work-product 19 privileges. 20 THE WITNESS: Attorney-client and 21 work-product privilege. 22 BY MR. CRITTON: 23 Q. Did you, did Mr. Howell -- and I don't 24 want to know the information, at least right now -- 25 did Mr. Howell give you any information about PROSE COURT REPORTING AGENCY, INC. EFTA00599750 Page 90 1 prior to her coming to see you or your seeing her? 2 A. Yes. Q. Okay. And did . for the first, on the 4 first occasion come to your office or did you talk 5 to her by phone or did you go to her place? 6 A. First time I talked to 7 Q. Yes, sir. 8 A. Was over the telephone. 9 Q. All right. And how long, how much time 10 transpired before . retained your services; that 11 12 13 14 15 16 Q. And the initial conversation you had with 17 her, what did she relate to you? 18 A. That's attorney-client privilege information 19 that I am not going to divulge. 20 Q. During the time that you have been 21 involved in this case on behalf of , has 22 Mr. Howell participated in the case; that is, has he 23 done work on the case? 24 A. Yes. 25 Q. What kind of -- what has he done? is, how many conversations did you have with her before she ultimately retained your services? A. One conversation over the telephone and then the next meeting was in person at my office. That meeting culminated with her retaining my services. PROSE COURT REPORTING AGENCY, INC. EFTA00599751 Page. 91 MR. SCAROLA: Objection, attorney-client 2 privilege and work-product. Instruct you not to answer. BY MR. CRITTON: Q. Your second, your next client was whom 6 relating to Mr. Epstein or to the United States 7 Government? 8 A. I don't remember. 9 Q. You ultimately filed a case styled Jane 10 Doe 1 and 2 were petitioners versus the United 11 States of America in July of '08, correct? 12 A. That's correct. 13 Q. Okay. Who was Jane Doe 1? 14 A. 15 Q. Who was Jane Doe 2? 16 A. 17 Q. At the time that suit was filed, were you 18 representing Jane Doe--., I'm sorry, Jane Doe? 19 A. I believe so, but I'm not sure. 20 Q. In terms of the work that you did for, 21 that you have done for all three of the individuals 22 when you were a solo practitioner, did you keep 23 track of the time; that is, did you keep time 24 records? 25 A. What's your question? PROSE COURT REPORTING AGENCY, INC. EFTA00599752 Page 92 1 Q. During the time that you were a solo 2 practitioner working on Jane Doe, whichever of 3 the three cases that you had, did you keep time 4 records? 5 A. Some. 6 Q. Do you keep time records on contingency 7 cases generally, or did you during that time period? 8 A. It's my intent to. 9 Q. Okay. Same would be true with, when you 10 were at RRA, did they have a time program? 11 A. They did have a time program. 12 Q. Did you input your time that you spent on 13 the Epstein related cases? 14 A. That was a requirement of the firm. 15 Q. Okay. So, you would have been put down 16 whatever time you spent, whether it was a 17 contingency fee case or an hourly case; is that 18 correct? 19 A. For the most part; that's correct. 20 Q. During the time that Mr. Nowell has been 21 associated with the case, does he provide you with 22 time records as to the work or the amount of work 23 that he has done on the case? 24 A. No. 25 Q. Okay. Does he keep track of his time that PROSE COURT REPORTING AGENCY, INC. EFTA00599753 Page 93 he has spent on each of the cases? 2 A. I do not know. 3 Q. Did you -- has he prepared any pleadings or documents associated with the cases? MR. SCAROLA: You can answer that 6 question. 7 THE WITNESS: Define prepared. 8 BY MR. SCAROLA: 9 Q. All right. Prepared, prepared, start, 10 first of all, started from scratch; that is, has he 11 prepared any of the pleadings or papers that have 12 been filed in any of the three cases starting from 13 scratch that he would have been -- not because you 14 said this but he started with the complaint and you 15 may have changed it, but he started the preparation 16 of the document? 17 A. Your question is has he started the 18 preparation of a document now, right? 19 Q. Any document, any paper that's been filed 20 in the cases or I would say passed back and forth 21 between lawyers in any of the three cases? 22 A. Has he had edited revised, I mean what -- 23 Q. Right now I am just asking did he start 24 the document such as a complaint or a similar type 25 document? PROSE COURT REPORTING AGENCY, INC. EFTA00599754 Page 94 1 6 A. That was filed in the case? Q. Correct. A. No. Q. Okay. Has he worked on documents, whether it's editing, adding, deleting from pleadings that you, pleadings or papers that you have prepared? A. Yes. Bob, can you hand me that water? II Q. Yes. 9 A. Thanks. Appreciate it. 10 Q. You're welcome. Has he continued, did he 1.1 continued to be involved not only when you were a t2 solo practitioner but during the time that you were 13 with RRA with regard to editing or working on the 14 cases? 15 A. To an extent. 16 Q. Okay. Do you, how often on the cases have 17 you consulted with Mr. Howell? By that I mean 18 before a decision is made as to how you want to do 19 discovery or proceed with the filing of the pleading 20 or how you're going to respond, does Mr. Howell, do 21 you consult with Mr. Howell during the time you were 22 both solo practicer and were at RRA? 23 A. Is your question asking for the answer to be 24 in a percentage? How often do I consult? I am just not 25 sure how to quantify. PROSE COURT REPORTING AGENCY, INC. EFTA00599755 Page 95 Q. Sure. I am okay with that. How often do 2 you consult with Mr. Howell with regard to those three cases prior to the time that you started with 4 your current Farmer, Jaffe association? A. It is an impossible question for me to answer 6 accurately with a percentage that I have spoken with 7 Mr. Howell about any particular document or anything. 8 Q. As to pleadings, do you discuss, do you 9 send it to him for his review, editing, before you 10 file a pleading? 11 A. Typically no. 12 Q. How often do you consult or have you 13 consulted with Mr. Howell during the time you were 14 with RRA? 15 A. What type of an answer do you want in terms of 16 how often have I? 17 Q. Do you do it once a day? 18 A. Have I ever? I have. 19 Q. Is it a pretty common practice that when 20 you're going to file or do something that you would 21 contact Mr. Howell? 22 A. Not at all. 23 Q. So, do you -- 24 A. Not at all common I mean. 25 Q. So, during the course of the month, say PROSE COURT REPORTING AGENCY, INC. EFTA00599756 Page 96 during the time that you were at RRA, how often would you consult with Mr. Howell regarding the cases? And I recognize every day or every week might be different. Would you speak with him like once a month, or two or three times a month, or generally once every couple of months? A. Depending on what was going on in the cases at the time, at sometimes more than others. 9 Q. How did III. come to be a client of yours? 10 A. She called me. 11 Q. And how did she get your name? 1.2 MR. SCAROLA: To the extent that your 13 response to that question would require that 1 1 you reveal either work-product or 15 attorney-client privileged information, I 16 instruct you not to answer. 17 THE WITNESS: I simply don't know. BY MR. CRITTON: Q. Did Ms. III. hire you in the or I'm going to strike that. 21 How many conversations did you have 22 with and/or meetings did you have with Ms. 93 before you hired her, or before she hired you. I'm 24 sorry. 25 A. I don't remember. PROSE COURT REPORTING AGENCY, INC. EFTA00599757 Page 97 1 O. Did she ever come and meet you at your 2 office? 3 A. From the beginning of time until today? 4 Q. No. Back at the time prior to retaining 5 your services. 6 A. I don't remember. 7 Q. Did you ever meet her at her residence or 8 place of work? Let me ask you this: Have you ever 9 met her at her place of business or a place of 10 business? 11 A. No. 12 Q. Have you ever met her at her home, whether 13 it's an apartment or home, whatever? 14 A. Now, you're asking from the beginning of time 15 until now? 16 Q. No. Up until the time she hired you, did 17 you ever meet with her? 18 A. Okay. I9 Q. At her home or apartment. 20 A. To the best of my recollection, no. 71 Q. Did you -- did she sign, to the best of 22 your recollection did she sign a fee agreement? 23 Well, let me strike that. There is a, there is a )4 written fee agreement between III. and you and 25 then -- PROSE COURT REPORTING AGENCY, INC. EFTA00599758 PilelP 28 1 A. Correct. Q. -- her originally? 3 A. Correct. Q. Did you ever meet her prior to her signing 5 that fee agreement? 6 A. Yes. 7 Q. And do you remember where that meeting 8 took place? 9 A. Generally, yes. 0 Q. Okay. Where? A. A park. 12 Q. And what town? 13 A. I don't know. 14 Q. You don't know whether it was in Broward 1 1, County or Palm Beach County? 16 A. I do know. I Q. Which county? is? A. Palm Beach County. 1Y Q. Was that arranged by her to meet her 0 there? A. Yes. 22 Q. And what, for what purpose did Ms. 23 originally hire you? 24 25 MR. SCAROLA: I am going to object. That calls for attorney-client privilege PROSE COURT REPORTING AGENCY, INC. EFTA00599759 Page 99 information. 2 BY MR. CRITTON: Q. When you met Ms. in at the park was anyone else present? A. Yes. Q. Who? A. I don't know. Q. Male or female? 0 A. I presume both. It's a park. JO Q. No, no, no. In the meeting that you had 11 with her -- my guess is there were probably a lot of 12 people in the park? A. Correct. 14 Q. In the meeting that you had with Mill. was anyone else present? 16 A. For the conversations between myself and 17 Ms. III., no. 18 Q. When you first met with . was anyone 19 present for the conversations between that you and 20 Ms. 21 A. No. 22 Q. I think you told me at the time that the 23 complaint was filed or at the time that the Jane Doe 24 1 and 2 sued the United States Government which was 95 in early July, it was July 8th of '08, you don't PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA00599760 Page 100 recall whether you were representing Jane Doe at 2 that time? 3 A. I believe I was but I do not recall for sure. 4 Q. At the time do you know whether, at the time that you represented Jane Doe 1, do you know whether her name, whether she was considered a 7 victim by the United States Attorney's Office? 8 A. Ask your question again. 9 Q. All right. At the time you began 10 representing . or at any time prior to the filing 1 1 of the lawsuit against the United States Government in July of '08, did you learn whether she was listed as a, or deemed to be a victim by the United States 14 Attorney's Office? MR. SCAROLA: If that is information that 16 you obtained in the course of the performance 17 of your responsibilities in representation of si any client, I would instruct you not to answer. lq If that information was obtained 20 through some public source independent of 21 the work that you performed as counsel, 22 then you may respond. 23 THE WITNESS: I cannot respond. 24 BY MR. CRITTON: 25 O. With regard to the question, I am not PROSE COURT REPORTING AGENCY, INC. EFTA00599761 Page 101 1 interested in what you learned from All right. 2 Did you learn from either any correspondence or a 3 telephone call with any third party that whether 4 again prior to the -- let me start again. Prior to the filing of the lawsuit 6 against Jane Doe 1 and Jane Doe 2 against the United 7 States Government, did you learn from any source, 8 maybe a document, maybe a telephone call or a 9 conversation that you had with a third party 10 separate from your client, that . was a victim or 11 was deemed to be a victim by the United States 12 Government or the United States Attorney's Office? 13 MR. SCAROLA: Same objection and 14 instruction. 15 BY MR. CRITTON: 16 Q. Same question with regard to III. Miller. MR. SCAROLA: Same objection and 18 instruction. 19 BY MR. CRITTON: 20 0. And same question with regard to Jane Doe. 21 MR. SCAROLA: Same objection and 22 instruction. 23 BY MR. CRITTON: 24 Q. Prior to your filing the lawsuit with 25 United States Government, did you ever any PROSE COURT REPORTING AGENCY, INC. EFTA00599762 Page 102 1 conversations with the United States Attorney's 2 Office -- 3 MR. SCAROLA: I assume -- 4 BY MR. CRITTON: 5 Q. -- regarding, regarding, regarding the 6 subject of the lawsuit or Jeffrey Epstein? 7 MR. SCAROLA: Same objection and 8 instruction. 9 MR. CRITTON: These are third parties; 0 where is the work product? 1 MR. SCAROLA: Work product has to do with I / anything that was done in connection with the I3 representation of these three clients. If he I4 had such conversations independent of his 15 representation of those clients, then he can 16 respond to the question. 17 BY MR. CRITTON: 18 Q. Well, let me ask you a broader question. 19 After you filed the lawsuit against the United 20 States of America, were you aware that Marie 21 Villafana or the United States Attorney's Office 22 represented the USA, correct? 23 A. Yes. 24 Q. All right. Did you ever speak with Marie 25 Villafana during, during the pendency of that PROSE COURT REPORTING AGENCY, INC. EFTA00599763 Pan c 103 litigation which is still pending today? 2 MR. SCAROLA: And I assume that question is qualified by inquiring as to whether such a 4 conversation occurred with regard to any of the 5 three individuals who he is representing claims 6 against Mr. Epstein or the U.S. Attorney's Office, correct? 8 MR. CRITTON: Say that again? 9 MR. SCAROLA: Yes, sir. Are you asking 10 whether such conversations occurred that were 11 relevant to his prosecution of the claims on 12 behalf of his three clients? 13 MR. CRITTON: Sure. 14 MR. SCAROLA: Then, then the instruction 15 remains the same. The objection remains the 16 same. 17 BY MR. SCAROLA: 18 Q. So, even if, do you even if you talked 19 about it with Mrs. Villafana, even if your client 20 Mr. Edwards spoke with Mrs. Villafana about a 21 scheduling issue, it's your position that that is 22 what, work-product? 23 MR. SCAROLA: That's correct. We are not 24 going to discuss anything that Mr. Edwards did 25 in the course of the prosecution of his claims PROSE COURT REPORTING AGENCY, INC. EFTA00599764 Paqc 104 1 2 3 4 on behalf of his clients. MR. CRITTON: So, any question that I ask you with regard to conversations that Mr. Edwards had with the U.S.A.O.'S office, whether it was Mrs. Villafana or anyone else 6 from the time, with regard to the Jane Doe 1 7 and Jane Doe 2 versus U.S.A. case, you would 8 instruct Mr. Edwards not to answer those 9 questions? 10 MR. SCAROLA: That is correct. MR. CRITTON: So if I '2 MR. SCAROLA: Obviously pending -- 13 MR. CRITTON: -- let me just finish. 14 MR. SCAROLA: Obviously pending, obviously 15 pending some instructions or guidance from the 16 court with regard to how the court will 17 interpret the work-product privilege in this 18 context. I might also add that it is our 19 position that any such inquiry exerts a 20 chilling effect upon the work that Mr. Edwards 21 continues to do on behalf of his three clients. 22 It is intended as a means to obtain 23 discovery that would not otherwise be 24 available in those pending claims. It is 25 intended to annoy, harass, and embarrass PROSE COURT REPORTING AGENCY, INC. EFTA00599765 Page 105 Mr. Epstein in a lawsuit that has absolutely no foundation whatsoever, and was filed for purposes other than a legitimate claim against Mr. Edwards based 5 upon any good faith belief that he engaged 6 in any form of improper or tortious 7 conduct and -- II CRITTON: Done? 9 MR. SCAROLA: -- those inquires are not 1O reasonably calculated to lead to the discovery 11 of admissible and relevant evidence. So, for 12 all of those reasons, we object. 13 MR. CRITTON: And let me just put on the 14 record very briefly so at least at this point 15 in time this is all information that clearly is 16 relevant to the complaint as it's alleged. 17 I have received a, my client and I 18 have both received a letter from you 19 asserting a motion for fees and costs and 20 certain sanctions under 57.105, by not 21 allowing us to ask what are clearly, I 22 believe, relevant material, basic 23 discoverable information are preventing 24 our ability to get all of the facts here 25 such that we can make a reasonable PROSE COURT REPORTING AGENCY, INC. EFTA00599766 Page 106 1 decision as to whether or not the 57.105 motion and letter which you sent to me was filed in good faith or has any basis in it. We're unable then to, we'll be in large part unable to evaluate our o position. MR. SCAROLA: And our position is that those are decisions that should well have been made, could have been made, and should have been made before you ever filed the claim. MR. CRITTON: All right. Are we done? MR. SCAROLA: Yes. MR. CRITTON: All right. 14 MR. SCAROLA: At least for now. it MR. CRITTON: I'm shocked. IG BY MR. CRITTON: 17 Q. With regard to, with regard to the claim 18 Jane Doe 1 and Jane Doe 2 that is currently 19 pending -- or let me strike that. Jane Doe 2 -- 20 Jane Doe 1 and Jane Doe 2 against the U.S.A. that 21 was filed in July of '08, that case is still 22 pending. 23 A. Okay. 24 Q. Is that correct? 25 A. That was a question, yes. 1.4:•••ams- , t,. PROSE COURT REPORTING AGENCY, INC. EFTA00599767 Page 107 Q. All right. And have any, have you had any 2 discussions -- well, let me strike that. What's the 3 status of that case? 4 A. It's still pending. Q. Other than still pending is a, is there, 6 are there any outstanding motions? 7 A. No. Q. I want to ask, to get back to one question 9 with regard to both the Qtask and with regard to the 0 Fortis system -- well, let me strike that. 1 With regard to the hard copies of the 12 files that you had that is any paper files that you 13 had associated with the Epstein files, where would 1.4 they have been kept at RRA? 15 A. In a filing cabinet. 16 Q. And were the filing cabinets in your office or were they out in the general hallways? 8 A. They were filing cabinets in my office and in 9 other locations in the office. )0 Q. Okay. With regard to the Epstein related matters, where did you keep those if they were -- 22 and by that that is the hard copies, did you keep 23 those solely in your office or would they have been 24 both in your office and in other places throughout 25 RRA? PROSE COURT REPORTING AGENCY, INC. EFTA00599768 Page 108 1 A. There were times when they were in my office 2 and there were times when they were kept in filing 3 cabinets elsewhere on one of the RRA floors. I believe 4 there were five or six floors of RRA Q. Okay. Was there a central storage, say if 6 there were a number of files in this instance 7 relating to Mr. Epstein, could you send those to 8 basically central storage and if you wanted someone 9 could go down and pick them up and bring them up to 10 you? 11 A. I don't know. 12 Q. Well, if you wanted to access something 13 that was in an Epstein file, and it wasn't in your 14 office, how did you access it; that is, a hard copy? 15 A. You're speaking specifically about 16 Mr. Epstein's cases or hypothetically with any cases? L/ Q. No, Mr. Epstein's cases? 18 A. As I sit here right now, I can't say with 19 absolute certainty that I ever had a piece of the hard 20 copy file requested for it to be brought to me. 21 Q. Well, with regard to Mr. Epstein's files, 22 though, if they were in a location, would it be a 23 correct statement that those were not, wasn't a 24 locked location or a secure location within the 25 contents of within the confines of the firm? PROSE COURT REPORTING AGENCY, INC. EFTA00599769 Page 109 1 A. I don't know that that's a correct statement. 2 Q. You don't know one way or the other? 3 A. The law firm was constantly expanding and 4 constantly under construction. For the most part in the 5 beginning the cases were kept in a, in a filing cabinet 6 in my office and later were kept in a filing cabinet, I 7 believe, in a locked storage location in another area of 8 the office. 9 Q. And did any attorney have access to that 10 storage area or do you know? 11 A. I believe any attorney could have had access. 12 Q. And if the attorney could have access, you 13 wouldn't necessarily know about it, true? A. Correct. !'5 Q. In the trustee's filing that they made in 16 response to my motion to preserve evidence, they 17 indicated that 13 boxes relating to Jeffrey Epstein 18 had been removed by the FBI or the government when 19 they came into the RRA offices. Do you remember 20 seeing that pleading? ml A. No. 22 Q. Okay. Are you, were there, in fact, 13 23 boxes of material or at least 13 banker's boxes of 24 material that related to matters directed to, 25 whether, whatever the content related to Mr. Epstein PROSE COURT REPORTING AGENCY, INC. EFTA00599770 Page 110 1 that you were aware of; that is, hard copies? 2 A. I don't know. 3 Q. Okay. Could have been more, could have 4 been less; you just don't know? 5 A. Correct. 6 Q. If I understood your testimony, 7 Mr. Rothstein, Mr. Rosenfeldt, any other attorney or 8 investigator could have accessed those files 9 depending or where they were within the firm, true? 10 A. I am not sure exactly who could have accessed 11 it. You asked me if the attorneys could and the 12 attorneys had swipe cards for various locked areas. 13 Each attorney I believe had access to any area where 14 those files were located. I believe so. 15 Q. Okay. Well, during the time you were 16 there did an individual by the name of Ken Jenne 17 work there? 18 A. Yes. 19 Q. Okay. Did an individual by the name of 20 Mike Fisten work for the firm -- 21 A. Yes. 22 Q. -- for RRA? Were they employees of the 23 firm or were they independent contractors? 24 A. I don't know. 25 Q. Okay. During the time they were there, PROSE COURT REPORTING AGENCY, INC. EFTA00599771 Page 111 1 did they also have swipe cards so that they could access different areas in the firm? A. I believe so. Q. With regard to when you joined RRA, did you ever have any further meetings with 6 Mr. Rothstein; that is, from the day you started at 7 RRA, did you ever meet Mr. Rothstein again? 8 A. By meet him again -- 9 Q. Did you ever have a meeting with him again 10 regarding your position in the firm? 11 A. No. 12 Q. Okay. Did you ever meet with him and a 13 number of other individuals with regards to firm 1 1 business? 15 A. No. I I Q. Firm cases? 1 , A. I don't believe so. 18 Q. Was Mr. Rothstein ever present in any 19 meeting where any of your cases were discussed? Let 20 me strike that. Was Mr. Rothstein ever present 21 wherein at any meeting where any of the cases 22 against Jeffrey Epstein were discussed? Don't tell 23 me content; just was he ever present. 24 A. How would I know that? I don't know. He 25 could, he could be in a meeting right now where the case PROSE COURT REPORTING AGENCY, INC. EFTA00599772 Page 112 1 could be discussed for all X know. 2 Q. I'm sorry. Obviously, where you, where 3 you were present. Where you ever present at a 4 meeting where Mr. Rothstein was also present where 5 the Epstein cases were discussed? 6 A. No. 7 Q. Did he ever call you to communicate with 8 you, call you either by phone, video conference, in 9 any fashion to discuss any act aspect of the cases 10 that you had against Jeffrey Epstein? 11 MR. SCAROLA: You can answer that. 12 THE WITNESS: He has communicated about 13 various, about legal issues related to the case 14 as well as commented about the case to me on 15 very few occasions but I would say less than 16 three times. 17 BY MR. CRITTON: 18 Q. During the time that you, from April of 19 '09 through late October of '09, correct? 20 A. In that time period, where, is that when 21 these -- 22 Q. Correct. 23 A. -- things happened? 24 Q. Well, that's the time you were there; 25 that's what I am asking. PROSE COURT REPORTING AGENCY, INC. EFTA00599773 Page 113 1 A. When I was there. 2 Q. And do you, can you remember the date, any 3 specific date that you spoke with him? A. No. Q. Do you remember any specific month that you would have had one of the -- well, what did you say something less than five conversations? I don't want to misquote you. A. I said less than three conversations. 10 Q. All right. So, something less then three 11 conversations you had with Mr. Rothstein regarding 12 Epstein cases, either legal issue or a comment, some 13 comment about the case to you, correct? 14 A. Yes. 15 Q. All right. The first time that he ever 16 spoke to you, did he call you or did you call him? 17 A. I, I never called Scott Rothstein about 18 anything. Oh, take that back. About anything related 19 to Jeffrey Epstein. 20 Q. The first conversation that you can recall 21 where either a legal issue or a comment was made 22 about Jeffrey Epstein by Mr. Rothstein to you, he 23 obviously initiated the call? 24 A. It wasn't a call. 25 Q. What was it? PROSE COURT REPORTING AGENCY, INC. EFTA00599774 Page 114 A. A comment in passing. And I believe I was sitting at a table in BOVA when he walked over to my 3 table and commented about Jeffrey Epstein. Q. Okay. Who were you there with at the 5 time? A. I don't remember. 7 Q. Were you with some friends? Were you with 8 other lawyers? 9 A. All right. I am jogging my memory. I, I have 10 no idea. 11 Q. What did he say? 12 MR. SCAROLA: To the extent that you can 13 answer that question without disclosing any 14 mental impressions with regard to the lawsuit 5 or any attorney-client privileged communications, you can answer. To the extent that it might invade either the work-product or attorney-client I , privilege, you should not respond. /0 THE WITNESS: Can I talk to you? MR. SCAROLA: Sure. 22 (A brief recess was held.) 23 MR. SCAROLA: Are we on? 24 THE VIDEOGRAPHER: Yeah. 25 MR. SCAROLA: The record should reflect PROSE COURT REPORTING AGENCY, INC. EFTA00599775 Page 115 that we have had an opportunity to consult and I have advised Mr. Edwards that there is no privilege protection for the particular communications involved. BY MR. CRITTON: Q. What did he say? 7 A. He commented to me, I want you to get that U pedophile. Q. And your response was what? LO A. I didn't respond. 11 Q. All right. Second conversation that you 12 can remember, where were you? 13 A. I had just come out of the conference room on 14 the main floor after taking a deposition in another 15 case. And he walked by and said, did you get that F'ing 16 pedophile yet. 17 Q. And your response? 18 A. Again. 19 Q. No response. 20 A. Didn't respond. 21 Q. On the first occasion when he came over 22 and if I understand correctly, all he said was the 23 comment that you referenced and then he left. You 24 didn't respond and then he just made the comment and 25 then left? PROSE COURT REPORTING AGENCY, INC. EFTA00599776 Page 116 1 A. Right. He was walking by in his normal, loud, ostentatious kind of way, greeting everybody in the restaurant. Came over to my table and he feels, at least my impression was obliged to say something to everyone. And that's the comment he said to me. 6 And if you've ever seen him, he is 7 basically always just skipping around and he hoped 8 on over somewhere else. So, yes, it was in, 9 literally in passing. 10 Q. Okay. How, how, how did he even know you 11 had cases involving Mr. Epstein? 12 A. I don't know. 13 Q. Because I think you testified earlier that 14 you had never discussed an Epstein case with 15 Mr. Rothstein one-on-one, correct? 16 A. Absolutely, true. 17 Q. You never discussed an Epstein case or 18 either of your three clients with Mr. Rothstein even 19 with a group of people around, correct? 20 A. Correct. 21 Q. All right. Do you remember a third 22 occasion that he spoke to you regarding Epstein 23 related occasion, cases? 24 A. Anything else that he ever spoke with me about 25 related to Epstein related issues is attorney-client and PROSE COURT REPORTING AGENCY, INC. EFTA00599777 Page 117 work-product privileged information that I am not going to divulge. 3 Q. Okay. I am not -- I need to still ask the 4 last question though. I thought you said earlier is 5 that you never had any substantive conversations, 6 maybe I misunderstood, with Mr. Rothstein about the 7 Epstein cases. Did I misunderstand you? 8 A. I don't believe that that was -- I had 9 conversations at a point about legal issues related to 10 Jeffrey Epstein and that's, that's it. 11 Q. Was that a one conversation? Was that a 12 number of conversations that you had where legal 13 issues were discussed as to, separate and apart from 14 the two comments he made about the case to you which 15 you were, you waived any privilege, work-product or 16 attorney-client privilege? A. I, I can't tell you. If you and I this 18 morning had a conversation and then we took a bathroom 19 break, and we had the same continuing conversation, I 20 don't know if that's one conversation or two. But I can 21 tell you the, the only time I remember Scott Rothstein 22 participating in any way, shape, or form in any 23 conversation related to anything substantive dealing )4 with, and not dealing with any specific client but a 25 legal issue, was on a particular one-day event, one-day PROSE COURT REPORTING AGENCY, INC. EFTA00599778 Page 118 1 conversation, if you want to call it. 2 Q. And that's at what time? At that time 3 legal issues were discussed? 4 MR. SCAROLA: Legal issue was the 5 testimony, a particular legal issue. 6 MR. CRITTON: Correct. A legal issue. 7 BY MR. CRITTON: II Q. When did that occur; that is, this one-day 9 discussion or a day discussion occur regarding a 10 specific legal issue? 11 A. I don't know. 12 Q. Was he present, he Mr. Rothstein and you 13 present at the same time? 14 A. Yes. 15 Q. Okay. Was anyone else there with you? 16 A. Yes. 17 Q. Who else was present? 18 A. Russ Adler, someone was on the telephone. I'm 19 not remembering who that was. I can't remember. I will 20 tell you if I do remember. 21 Q. Was Bill Berger there? 22 A. No. 23 Q. And, you don't. 24 let me strike that. Where did the conversation take 25 place? So, there was you. Well, PROSE COURT REPORTING AGENCY, INC. EFTA00599779 Page 1,9 J. A. Scott Rothstein's office. 2 Q. Had you been called up to meet with 3 Mr. Rothstein? A. Yes. Q. Okay. And who contacted you and told you 6 that Mr. Rothstein wanted to see you? 7 A. His, his secretary or paralegal or something. 8 Q. And did you get a call saying Mr. 9 Rothstein would like to see you right now, or was it 10 something that was scheduled? 11 A. It was not scheduled. 12 Q. So, you got a call and somebody told you, 13 come up, Scott, Scott wants to see you. 14 A. I don't remember exactly what was used, but it 15 was I believe, Russell is discussing a legal issue with Scott Rothstein; come to his office. 17 Q. Okay. Was the legal issue, did it involve 18 one of the Epstein cases or the Epstein cases? 19 A. It, it was a legal issue related to -- ys: . 20 Q. Okay. How long, how much time did you 21 spend -- well, let me strike that. So, when you 22 went up to Mr. Rothstein's office, it's -- I 23 understand you had to go through some security to 24 get in? 25 A. You've seen the video? PROSE COURT REPORTING AGENCY, INC. EFTA00599780 Page 120 1 Q. I actually haven't. A. Oh, really. Okay. Yeah, it's -- 3 Q. In order to get into Mr. Rothstein's 4 A. It's like a compound. Q. Kind of concern you that this guy running 6 the firm had a compound? 7 A. I -- at the time, no. In retrospect, okay, 8 now that we all know how this whole thing unfolded, but 9 at the time, no. 10 Q. Had you ever worked in an office? And you 11 had worked at some big offices. You worked at the 12 State Attorney's office in Broward County? '3 A. True. 14 Q. You worked for, I think for Kubicki 5 Draper? ;6 A. Correct. 17 Q. Did Mr. Kubicki, Gene Kubicki ever have a 8 compound around his office that you had to go 19 through any type of security either people and/or 20 locked doors or secured doors in order to access 21 him? 22 A. No. 23 Q. Had you ever worked other than the Broward 24 County Sheriff's, at the Broward County State 25 Attorney's Office with, and with Kubicki Draper, had PROSE COURT REPORTING AGENCY, INC. EFTA00599781 Page 121 1 you ever worked for a large firm? 2 A. No. You just named all the places I have 3 worked. 4 Q. All right. Is this the first time then 5 that you had been to Mr. Rothstein's office that he 6 called you up there? 7 A. No. 8 Q. You had been in his office before? 9 A. One time. 10 Q. And what was that occasion? 11 A. I was having back surgery, and I went there to 12 tell him I am having back surgery. As you know I had 13 back surgery, and I was telling him I don't know how 14 long I'm going to be off because, you know, the recovery 15 time is different for everybody. 16 Q. Is that the only thing you talked about, 17 the back surgery? 18 A. That's the only thing we talked about. 19 Q. Did the meeting you had with Scott, when 20 you went up, when you were called up to his office 21 that day, did that occur before your back surgery 22 episode or meeting or after? 23 A. After. 24 Q. So, you would, you had back surgery. 25 think you were out two or three weeks and then you twaSt.da•MCCI , PROSE COURT REPORTING AGENCY, INC. EFTA00599782 Page 122 1 returned to the office, and then that meeting would 2 have occurred? 3 A. Yeah, that's correct. 4 Q. When you, in order to get into the office 5 just as you have described it as a bunker, how many, 6 did you have to go through any security people to 7 get into -- 8 MR. SCAROLA: No, I think the description 9 was a compound. 10 MR. CRITTON: I will use compound. Are 11 you more comfortable with compound or a bunker? 12 I have seen it described both ways. I haven't 13 seen the video, but I have seen it described 14 both ways. 15 THE WITNESS: I will describe it for you. 16 Well, first I will answer your question. 17 Security people, I don't know if there was ever 18 a time where one would have to go through 19 security people to get to his office. But on 20 the day or two days that I have been in his 21 office, I did not encounter any security 22 personnel. 23 BY MR. CRITTON: 24 25 Q• A. Did you have to be buzzed into the It was more complicated than that. office? PROSE COURT REPORTING AGENCY, INC. EFTA00599783 Page 123 1 Q. How many security, different security 2 levels did you have to go through in order to get, 3 to go have your meeting with Mr. Rothstein and 4 Mr. Adler? 5 A. Two. 6 Q. And to your recollection you don't 7 remember ever seeing a security person? 8 A. Right. 9 Q. Okay. Who was in the office? 10 A. Well -- 11 Q. I'm sorry. 12 A. I do not remember seeing a security person 13 manning the door or granting access to his office. I saw security people every day in the office of RRA Q. All right. And when you got into the "6 office, Mr. Rothstein was there? 17 A. Yes. 18 Q. Mr. Adler? 19 A. Yes. 20 Q. There was someone on the telephone who you 21 don't recall? 22 A. Yes. 23 Q. Okay. Was there anyone else present? 24 A. Not that I remember. 25 Q. Okay. Was, were there any investigators, PROSE COURT REPORTING AGENCY, INC. EFTA00599784 Page 124 1 was Mr. Jenne or Mr. Fisten present? 2 A. No. 3 Q. So, it was, you, Rothstein, Adler, and 4 someone on the phone; that's it? 5 A. From what I remember. 6 Q. How long did the meeting last? 7 A. I don't know how long the meeting lasted. B Q. Five minutes or was it a substantially 9 long meeting? 10 A. Do you want how long I was in the meeting, 1 11 can give you an answer. How long the meeting lasted, I 12 have no idea. 13 Q. How long did the meeting last while you 14 were present? 15 A. Less than five minutes. 16 Q. Was the value of any of the three cases 1 / discussed at all? £1 A. No. 19 Q. Did Mr. Rothstein, did Mr. Rothstein 20 appear to be knowledgeable about your cases? 21 A. No. 22 Q. Mr. Adler, was Mr. Adler someone that you 23 had discussed the cases with on a somewhat regular 24 basis -- 25 MR. SCAROLA: Objection, compound. PROSE COURT REPORTING AGENCY, INC. EFTA00599785 Page 125 1 BY MR. CRITTON: 2 Q. -- not content. Was Mr. Adler someone 3 that you had discussed these Epstein cases with 4 prior to that meeting? 5 A. Yes. 6 Q. Was he familiar with the cases, generally? 7 A. He attended Jeffrey Epstein's deposition, so 8 he heard the questions asked and heard the Fifth 9 Amendment invocation and so the adverse inferences and 10 was therefore informed -- 11 MR. CRITTON: Move to strike as 12 nonresponsive. 13 BY MR. CRITTON: 14 Q. My question is was he familiar generally 15 with the subject matter of the litigation against 16 Mr. Epstein? 17 A. In that he read the newspaper articles about 18 molesting a bunch of children, yes, he was familiar with 19 the subject matter. 20 Q. And he read -- did you provide him with 21 copies of the pleadings in these cases when they 22 came to RRA? 23 A. No. 24 Q. What was the topic? What was the legal 25 issue that you discussed -- well, let me strike PROSE COURT REPORTING AGENCY, INC. EFTA00599786 Page 126 1 that. Who raised the legal issue, did 2 Mr. Adler raise it or did Mr. Rothstein? 3 A. I don't know. 4 Q. Okay. Well, how did the, who started the, if you were there I think you said five minutes, who 6 did the talking? 7 A. When I came in the, in the office, it was in the middle of a discussion. Q. Was a question posed to you? A. The question was on the table at least from my 1 perspective coming into the room and was then directed 12 at me, what's the answer to this particular legal issue. 13 Q. And what was the legal issue? 14 MR. SCAROLA: Let's talk for just a 15 second. 16 THE VIDEOGRAPHER: Are we going off the 17 record? MR. SCAROLA: Actually, we don't even have 19 to go off the record. Stay right here. 20 If this was an issue that was 21 identified during the course of the legal 22 proceedings to opposing counsel, then I am 23 going to allow you to you identify the issue without getting into any of the substance of the discussion regarding that PROSE COURT REPORTING AGENCY, INC. EFTA00599787 Page 127 issue. If it was not an issue that was identified in the course of the proceedings to opposing counsel, I am going to object and instruct you not to 6 answer on the basis of the work-product 7 privilege. 8 THE WITNESS: Work-product privilege. 9 BY MR. CRITTON: 10 Q. Do you know an individual by the name of 11 Fandry, F-a-n-d-r-y? 12 A. That name doesn't ring a bell right now. 13 Q. Do you know him to be -- does that name 11 mean anything with regard to, as an investigator, 1' Fandry? r, A. That's a male? ii Q. Pardon? 18 A. That's a first name or a last name? 19 Q. Last name, Richard Fandry. 20 A. I know an investigator named Rick that did 21 work, was contracted out by RRA to do investigative 22 work. I don't know his last name but -- 23 Q. Did, did Rick ever do any work on any of 24 the Epstein cases to your knowledge? 25 A. I believe so. PROSE COURT REPORTING AGENCY, INC. EFTA00599788 Page 12.8 1 Q. Do you know what the name of his business 2 was? 3 A. No. 4 Q. Is Rick still being employed at the 5 current time by your firm to do investigation? 6 A. No. 7 Q. Is Mr. -- I asked you earlier if you knew 8 Ken Jenne and Michael Fisten and you said yes and 9 you knew that they had an association with RRA; is 10 that correct? 11 A. Yeah, that's correct. 12 Q. And do you know whether they were 13 employees or whether they were independent 14 contractors? 15 A. You asked me that and I still have no idea. 16 Q. Did they have offices within RRA, 17 Mr. Jenne and Mr. Fisten? 18 A. They, Mr. Jenne definitely had an office 19 within RRA Mr. Fisten was normally in the field and I 20 assume he had a place to go in RRA I don't know if you 21 call it an office. 22 Q. Did you ever go 23 A. That's it. 24 Q. Did you ever go meet with him within RRA? 25 A. Yes. PROSE COURT REPORTING AGENCY, INC. EFTA00599789 Page 129 1 Q. Where did you go -- did you go to an 2 office to meet him? 3 A. Well, I went to a particular area, a locked area that I could get in with my swipe card and there 5 was a, a room like this. Is this an office? 6 Q. Sure. 7 A. Okay. Then yes. 8 Q. If you wanted to contact Mr. Fisten, did 9 you, did you have a number; that is, an inside 10 number? 11 A. I don't know. 12 Q. Did Mr. Fisten do work on the Epstein 13 related cases? 14 A. Yes. 15 Q. Okay. What kind of work did he do? 16 A. Investigator. 17 Q. Meaning what? 18 A. Meaning investigative work. 19 Q. Okay. Has Mr. Fisten continued to do -- 20 let me strike that. When RRA imploded in early or 21 in late '09, in October of '09, did Mr. Fisten come 22 to work for your firm? 23 A. Yes. 24 Q. Farmer, Jaffe. Is he an employee of your 25 firm? PROSE COURT REPORTING AGENCY, INC. EFTA00599790 Page 130 1 A. Correct. 2 Q. How about Mr. Jenne, is he currently 3 employed by your firm? 4 A. No. 5 Q. Do Mr. Jenne and Mr. Fisten, to your 6 knowledge, have any association at the current time? 7 A. No. 8 Q. Have, has Mr. Fisten continued to do work 9 on behalf of your firm; that is, investigative work 10 relating to Mr. Epstein? 11 A. What do you mean has he continued to? 12 Q. Has he continued, has Mr. Fisten done, 13 continued to do investigative work since he had been '1 with Farmer Jaffe relating to the Epstein cases? 15 A. On, on many cases and Jeffrey Epstein's case 16 being one of them, yes, he's done some work. 17 Q. Has he, has he as well -- well, let me 18 strike that. Has Ken Jenne done any work for any 19 outside agency, investigative agency or entity, done 20 investigation work relating to Jeffrey Epstein here 21 in the State of Florida? 22 A. I don't, I don't know. I don't talk to him. 23 Q. Have you had any contact -- well, let me 24 strike that. Did you ever have any contact with 25 Mr. Jenne during the time you were at RRA? PROSE COURT REPORTING AGENCY, INC. EFTA00599791 Page 131 1 A. Yes. Q. Did he ever do any work, or did you ever 3 direct him to do any work with regard to the Epstein 4 cases? 5 A. No. 6 Q. Did he know about the Epstein cases? 7 A. Yes. 8 Q. Okay. And how did he know? How did you 9 know he knew? Well, let me strike that. I think 10 you said you never directed him to do any work? 11 A. Right. 12 Q. Okay. And how do you know he was 13 knowledgeable about the Epstein cases? 14 A. I talked to him about it before. 15 Q. Did you discuss the facts and 16 circumstances of the cases with him? 17 A. Of .1 ., and Jane Doe's specific 18 circumstances, no. In fact, I would say, I would 19 highly, it's highly unlikely that he would even know 20 their names. 21 Q. But you have discussed the Epstein cases 22 with him generically? )3 A. Right. 24 Q. And did he approach you about discussing 25 the Epstein cases or did you approach him? PROSE COURT REPORTING AGENCY, INC. EFTA00599792 Page 132 1 A. He would have approached me. I didn't know 2 him. 3 Q. Do you recall why -- let me strike that. 4 Do you recall how long you were at the firm, RRA 5 before he approached you to talk about the Epstein 6 cases? 7 A. My recollection is several months. 8 Q. Okay. On how many occasions did he 9 approach you to talk about the Epstein cases? 10 A. I don't know. 11 Q. More than once? 12 A. Yes. 13 Q. More than twice? 14 A. Yes. 15 Q. More than five times? 16 A. Yes. Q. More than ten times? A. Possibly. Q. Okay. And with regard to Mr. Jenne did '0 you ever give him, was he ever an invite person on your Qtask? A. I do not believe so. Q. Did, did you ever ask Mr. Jenne why he was interested in your Epstein cases? A. No. C) PROSE COURT REPORTING AGENCY, INC. EFTA00599793 Page 133 Q. Okay. And on each occasion he approached 2 you about talking about the Epstein cases? A. On the first I occasion, definitely. I can't 4 say on every occasion that we had a conversation. Q. And if I understood you correctly, you 6 never assigned Mr. Jenne any tasks, any task; is 7 that correct? 8 A. That's correct. 9 Q. Did you find it odd or strange that he 10 would want to talk to you about your Epstein cases? 11 A. No. 12 Q. Did you, did you -- Mr. Jenne reported to L3 whom as you understood? 14 A. I didn't understand anything. Q. Do you know what his position with the 16 firm was? 17 A. No idea. 18 Q. Did he ever offer to help you with the 19 Epstein cases? 20 A. In some respect, I guess so. Generally, you 21 know, I, I can help. This is basically a criminal 22 matter; I can help. You know, that kind of thing. I am 23 not saying those are his exact words but paraphrasing 24 the gist of it, that's what I remember. 25 Q. Okay. Mr. Edwards, did you ever contact PROSE COURT REPORTING AGENCY, INC. EFTA00599794 Page 134 1 the media or the press when, that's located in New 2 York City, the State of New York, about any of the Epstein cases? A. I may have returned telephone calls that were initiated by press to me. Q. My, my question to you was, did you 7 initiate any telephone calls; that is, without returning a call to the, to any member of the media 9 or press in New York regarding the Epstein cases? 0 A. Meaning the first conversation Q. Right. 2 A. -- between -- yeah. No, I did not. 13 Q. Who contacted you from New York with 14 regard to any Epstein related matter? 15 A. The press. 16 Q. Who? 17 A. I don't remember anybody's name. 18 Q. Give me anybody's name that you can 19 recall. 20 A. George Rush. 21 Q. What media, what did you understand his 22 association? 23 A. I believe New York Daily News. 24 Q. Do you remember when Mr. Rush contacted 25 you? PROSE COURT REPORTING AGENCY, INC. EFTA00599795 Page 135 I. A. No. 2 Q. When Mr. Rush contacted you, do you know 3 why he contacted you; that is, what -- well, let me 4 strike that. When he contacted you, did you take 5 his call right away or was his a call that you had 6 to return? A. I don't remember. Q. Do you remember speaking with a person 9 named John Canally? 10 A. Yes. 11 Q. Okay. What was Mr. Canally's association? 12 A. I don't know. 13 Q. Do you know who he was with at the time? 14 A. No. 15 Q. What did your discussion with Mr. Canally; 16 that is, what was Mr. Canally interested in and what 1.1 did you tell him? 18 MR. SCAROLA: Objection, compound. 19 THE WITNESS: I, I listened to him more 20 than told him anything. 21. BY MR. CRITTON: 22 Q. Did you provide him any information? 23 A. In the back and forth of the conversation, I, 24 you know, maybe general information that one could read 25 from the newspapers I talked to him about. PROSE COURT REPORTING AGENCY, :INC. EFTA00599796 Page 136 1 Q. Did you speak with, other than -- on how 2 many occasions did you speak with Mr. Canally? 3 A. I don't know. 4 Q. On how many occasion's have spoken with 5 Mr. Rush? 6 A. I don't know. 7 Q. More than once with Mr. Rush? 8 A. I would say so, yes. 9 Q. More than five times with Mr. Rush? 10 A. That's approximate, that's approximately 11 correct. 12 Q. Okay. Mr. Canally, did you speak with him 13 on more than one occasion? 14 A. Yes. 15 Q. On how many occasion's have you spoken 16 with him? 17 A. I don't know. 18 Q. Five, two, three, your best estimate? 19 A. More than five. 20 Q. When was the last time you spoke with 21 Mr. Canally? 22 A. 2009. 23 Q. Have you had any contacts with the media 24 or the press during the year 2010, January, 25 February, March, and we're almost, well, we're PROSE COURT REPORTING AGENCY, INC. EFTA00599797 Page 137 1 almost at the end of March. In the last three 2 months, starting in January 1st of 2010, have you 3 had any contact with the press? 4 A. Not that I recall. 5 Q. Has the press contacted you, but you have 6 not returned their calls? 7 A. On hundreds and hundreds of occasions. 8 Q. Well, my question is since the beginning 9 of, since January 1st of 2010 has the press 0 attempted to contact you? 11 A. Yes. 12 Q. And if I understand your testimony, you 13 have not returned any of those calls? 14 A. To the best of my recollection I, I do not 15 remember speaking with anybody from the press during 16 this year, 2010. 1.7 Q. In 2010, do you have a recollection of 18 having spoken with people but saying you can't quote 19 me, i.e., I have no comment or I will tell you off 20 the record? 21 A. I don't even remember having those 22 conversations with anybody in 2010. If you know of 23 something and can refresh my recollection, I, you may be 24 able to remind me, but I don't think in 2010 I have had 25 any of those conversations. PROSE COURT REPORTING AGENCY, INC. EFTA00599798 Page 138 1. Q. The conversations you had with George 2 Rush, when you returned his call, what did Mr. Rush 3 ask you? What was he inquiring about? 4 A. My response to Jeffrey Epstein's comments. 5 Q. Which comments? 6 A. A telephone conversation initiated by Jeffrey 7 Epstein to George Rush related to the various cases and claims against Mr. Epstein. C) Q. Did Mr. Rush call you -- I'm sorry, I will improve it. If I understand correctly when Mr. Rush called you, that's the first time you knew who he was? A. I didn't know who he was before he called me, correct. Q. What did Mr. Rush tell you what Jeffrey Epstein had said to him? A. And I'm not sure that that was the first conversation I had with, with George Rush. Like I said in I think I've talked to him three or four, five times. 20 Q. Okay. Well, let me see if I can place, )1 can you give me a point in time when you first spoke 22 to Mr. Rush and when you last spoke with him the 23 approximately five times that you related? 24 A. Each of those times were in 2009 between, 25 earliest possible, June, I think, yeah, latest possible, PROSE COURT REPORTING AGENCY, INC. EFTA00599799 Page 139 1 I believe, November. 2 Q. And the first time that Mr. Rush called you, what was the subject? A. Jeffrey Epstein. Q. Okay. I assume you never talked with Mr. Rush about any topic other than Mr. Epstein, 7 correct? A. That's a safe assumption. 9 Q. When he first contacted you, can you 10 differentiate what he said on the first occasion 11 versus a later occasion? 12 A. I, I, no, in chronological order I can't right 13 now. I haven't gone back and thought about this like 14 this before. 15 Q. Did you ever correspond with Mr. Rush or 16 Mr. Canally by e-mail? 17 A. Mr. Rush, I believe that answer is no. With 18 Mr. Canally, yes. 19 Q. And so do you have copies of the e-mails 20 that you and Mr. Canally exchanged? 21 A. No. 22 Q. Okay. Would they have been while you were 23 at RRA, RRA? 24 A. Correct. 25 Q. With regard to Mr. Rush, if you did PROSE COURT REPORTING AGENCY, INC. EFTA00599800 Page 140 1 communicate with him by e-mail, would it be during 2 the time you were with RRA? 3 A. That's correct. 4 Q. Did you communicate with any other member 5 of the press during the time, we'll come back to 6 Mr. Epstein. During the time when you were at RRA, 7 did you communicate with anybody else by, by either, 8 first of all, by e-mail? 9 A. What is your question again? I'm sorry. 10 Q. Okay. Did you -- other than Mr. Rush who 11 you're not sure you communicated by e-mail, 12 Mr. Canally who you are sure you communicated by 13 e-mail during the time you were at RRA, was there 14 any member of the press, TV, written news media, 15 television that you communicated with -- 16 A. I'm sure. 17 Q. -- by e-mail? 18 A. I am sure there is. 19 Q. Okay. Do you remember any of their names 20 21 22 23 24 25 A. I don't know who that is. other than Mr. Rush and Mr. Canally as you sit here today? A. Not as I sit here today, I do not. Q. Did you ever communicate with Jose Lambiet? PROSE COURT REPORTING AGENCY, INC. EFTA00599801 Page 141 1 Q. He does a Page 2 or something with the, 2 Page 1, Page 2 of the Palm Beach Post? 3 A. No. I'm not, no. 4 Q. Okay. Have you ever spoken with Jane 5 Muskrat (phonetic)? 6 A. Again, I don't know who that is. 7 Q. Have you ever -- did you ever give or 8 allow one of your clients to give an interview to 9 one of the local TV stations? 10 MR. SCAROLA: Objection, compound. THE WITNESS: One of my clients gave an interview to one of the local television stations. 4 BY MR. CRITTON: Q. Which of your clients gave the interview? A. Jane Doe. Q. And did you organize that? 18 A. I assisted. 19 Q. Which, which TV station was it? 20 A. I don't remember. 21 Q. Do you remember who the person was from 22 the TV station that contacted you? Let me strike 23 that. How did it come about that Jane Doe gave an 24 interview to the TV station? 25 A. Various television stations have been PROSE COURT REPORTING AGENCY, INC. EFTA00599802 Page 142 interested over the course of these cases in having the 2 clients talk. I was adamant that that was not going to 3 happen and Jane Doe wanted that to happen. Q. How did Jane Doe even know that that 5 opportunity existed? If you didn't want it to 6 happen when the news, when the news people, when the 7 TV stations called you why didn't you just say my 8 clients are not available for interview? 9 A. What's your question? ,0 Q. The question is, is, with regard to the 11 T.V. station, you said multiple TV stations wanted 12 to do interviews with your clients. Did I 13 understand you correctly? A. You did. Q. And you said you didn't want any of your ICS clients to do interviews, correct? A. Right. Q. Okay. So, why didn't you just say, no, I am not making any of my clients available? lc MR. SCAROLA: I am going to object to the 21 extent that that calls for either mental 22 impressions or attorney-client privileged 23 24 25 communications and instruct you not to answer. THE WITNESS: I'm not going to answer based on the privilege. loaasasmausr.I. PROSE COURT REPORTING AGENCY, INC. EFTA00599803 Page 143 BY MR. CRITTON: Q. Jane Doe, though, did give an interview, 3 correct 1 A. That is correct. 5 Q. -- on TV and they blocked out her face? 6 A. That is correct. 7 Q. Were you there, were you present when she 8 gave the interview? 9 A. Yes. I0 Q. Okay. Did you see the interview on TV? ll A. No. 12 Q. Did they give you a copy of the tape of 13 the interview? 14 A. I believe a copy of the tape was sent to me. 15 Q. Okay. Do you still have that in your possession? A. No. i8 Q. Who has it? A. I believe it was destroyed. 20 Q. Who destroyed it? 21 A. Nobody destroyed it. 22 Q. Okay. You said, I think you said you 23 believe it's destroyed. How did it come to be 24 destroyed? 25 A. It was sent to me and it was kept in my house PROSE COURT REPORTING AGENCY, INC. EFTA00599804 Page 144 1 as I didn't believe it was any portion of the file and 2 my house flooded and the tape was destroyed. 3 Q. And did you try to play the tape? 4 A. I have never watched the tape. 5 Q. You still have it. You just think it's 6 destroyed? 7 A. No, I don't even have it. 8 Q. You threw it away? 9 A. It wasn't a matter of throwing anything away. 10 My entire house was full with water, every square inch 11 for 12 inches up the wall, and everything was just in 12 mud and got thrown in these huge bins and trashed so -- 13 Q. All right. Have you ever spoken with 14 Michelle Daryan? 15 A. Yes. 16 Q. On how many occasions have you spoken with 17 her? 18 A. Several. 19 Q. Have you e-mailed, exchanged e-mails with )0 her? - 1 A. Yes. 22 Q. During the time you, only during the time 23 you were with RRA? 24 A. I believe so. There, there could have been, 25 there could have been an e-mail. Oh I only think at RRA PROSE COURT REPORTING AGENCY, INC. EFTA00599805 Page 145 1 I believe that's right. 2 Q. As a result of Jane Doe speaking with the 3 press, did she receive any compensation? 4 A. No. 5 Q. Have any interviews been given separate 6 and apart from the TV interview that Jane Doe gave? 7 Did any of the other, did either of your other two 8 clients, . or III., ever give an interview to, 9 written to, to the written media, not TV? 10 A. No. 11 Q. With regard to, back to George Rush, you 12 said that Mr. Rush, Mr. Rush contacted you. You 13 recontacted him, correct? 14 A. That's correct. 15 Q. Okay. And what was the subject matter? 16 What was Mr. Rush interested in talking with you 17 about? 18 A. Jeffrey Epstein. 19 Q. Okay. And what, what specifically about 20 Mr. Epstein? How did he even know you existed, did 21 he say? 22 A. I don't know. Or, or if I knew, I don't 23 remember how he knew that. 24 Q. Okay. Did you, did you talk to him? 25 A. Yes, I did talk to him. PROSE COURT REPORTING AGENCY, INC. EFTA00599806 Page 146 1 Q. Approximately, how many, how long have 2 your conversations been? 3 A. Short. 4 Q. And with regard to George Rush, what, you 5 said he was interested in talking about Jeffrey 6 Epstein. What was he interested in? 7 A. I don't remember specifically the issue, but 8 it seemed to me that he came to me with an issue each 9 time, something related to the case. 10 Q. Okay. The case being Mr. Epstein's case 11 or your three cases? 12 A. I think that it was typically in general 1.3 related to the various criminal acts committed by 14 Jeffrey Epstein against the large number of girls in 1 1, each of the states that Jeffrey Epstein has lived in. I 16 think that was like the gist of his communication to me. I / Q. Well, did he? A. Or why he was interested. lq Q. Did he indicate to you that someone had )0 told him that, that certain acts had occurred in 21 other states or locations other than the State of 22 Florida? 23 A. I can't say with any degree of specificity 24 what was said, but that certainly is the impression that 25 I have right now thinking back. So, I believe that that PROSE COURT REPORTING AGENCY, INC. EFTA00599807 Page 147 was something he was conveying to me. 2 3 5 6 Q • Okay. Did he tell you that he had any information that Mr. Epstein had been involved with any other individuals in any other states, females? A. I don't remember. Q. Did you tell him or did you disclose to 7 him that you were aware of Mr. Epstein having been, 8 having assaulted underage females in other states? 9 A. I don't remember. 10 MR. CRITTON: Need to take -- why don't 11 we, why don't you change the tape now? 12 THE VIDEOGRAPHER: We're now off the video 13 record. It's 1:02 p.m. 14 (A luncheon recess was held.) 15 * * * * * 16 17 18 19 20 21 22 23 24 25 PROSE COURT REPORTING AGENCY, INC. EFTA00599808