EFTA00611238.pdf

Page 148 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. $02009CA040800XXXXMB AO Complex Litigation, Fla.R.Civ.Pro. 1201 JEFFREY EPSTEIN, Plaintiff, ors- VOLUME110F II SCOTT ROTHSTELN, BRADLEY J. EDWARDS, individually, and 124. individually, Defendants. VIDEOTAPED DEPOSITION OF BRADLEY J. EDWARDS, ESQUIRE Tuesday, March 23, 20010 10:00 - 517 p.m 2139 Palm Bach Lakes. Boulevard West Palm Beach, Florida 33401 Reported By: Cynthia Hopkins, RPR, FPR Notary Public, State of Florida Prose Court Reportmg kb No.: 1333 1 2 3 4 5 6 7 8 Page 150 e<INDEX START» INDEX EXAMINATION DIRECT CROSS REDIRECT CONTINUED EXAMINATION OF BRADLEY J. EDWARDS, ESQUIRE BY MR. CRITTON 1S1 9 10 11 12 13 EXHIBITS 14 15 16 EXHIBIT DESCRIPTION PAGE 17 PLAINTIFFS EX. I ALFREDO RODRIGUEZ 21I 18 CRIMINAL COMPLAINT PLAINTIFFS EX. 2 COMPLAINT 239 19 PLAINTIFFS EX. 3 JULY 22, 2009 276 PACSMILE 20 21 22 23 24 25 . APPEARANCES: 2 0nd:halfoft& Ptaintilll ROBERT D. CRITTON. JR.. ESQUIRE COLDAAN. LLP S 9 10 11 12 0 14 15 16 17 IS 19 10 21 22 23 24 15 and JACK ALAN GOLDBERGER ESQUIRE SS, P A. and On behalf of the Plaine:I ALAN M. DERSHOW1TZ. ESQUIRE HARVARD LAW SCHOOL. JACK SCAROLA. ESQUIRE SEARCY. DENNEY. SCAROIA. MI Y ALSO PRESENT: Jcffivy Epstein Joseph Kcal, vsloormiss Prose Reporting Saviors Page 149 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 151 PROCEEDINGS THE VIDEOGRAPHER: We're now on the record at 1:54 p.m Volume 2. CONTINUED DIRECT EXAMINATION BY MR. CAPTION: Q. Mr. Edwards, when we broke, we were talking a little bit about, we were talking about George Rush and different, many people that you had spoken with and you said you had spoken with Mr. Rush approximately five times, correct? A. Contd. Q. With regard to Mr. Rush, did you ever provide him with any documents? A. I don't believe so. Q. Did you tell Mr. Rush, did you EVER advise or did Mr. Rush ever ask you who your clients were, I mean not by name but as to how your clients factored into any of the conversations that you were having? A. I don't remember that. Q. Do you recall discussing with Mr. Rush Ghislaine Maxwell? Or in fact, let me ask it this way: Did you talk with Mr. Rush about Ghislaine Maxwell in any way? 1 (Pages 148 to 151) PROSE COURT REPORTING AGENCY, INC. Electronically signori by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins 2d394112d.67f24170-9d82-0511f178c2eta EFTA00611238 Page 152 1 A. I'm not sure. 2 Q. Why would you -- did any of your clients 3 claim or have any of your clients claimed to have 4 any contact with Ohislaine Maxwell at all? 5 A. That is something that certainly calls for 6 attorney-client privilege and not something that I ant 7 going to be answering today. Q. With regard to at least you have attended 9 the deposition of both Jane Doe and o' correct? 10 A. Yes. 11 Q. Okay. And have you heard them reference 12 Ghislaine Maxwell during the course of those 13 depositions? 14 A. No. 15 Q. Would it be a correct statement that none 16 of the three of your clients — let's take a look at 17 the two that have testified. Bakof the two that 18 have testified, Jane Doe and M. have testified 19 that they did not ever take, travel with or were 20 transported in any ■ by Mr. Epstein, correct? 21 A. No, that is incorrect. 22 Q. Okay. Did, who, which? 23 A. I believe. 24 Q. I am sorry? 25 A. !guess the transcript will speak for itself. Page 154 1 A. I don't remember that subject coming up in the 2 conversations with Mr. Rush. Had he asked - I, i don't 3 remember that conversation. 4 Q. You're not denying it. You are just 5 saying you don't remember it or are you — 6 A. Correct. 7 Q. - saying it didn't happen? 8 A. No. I am saying I just don't remember. 9 Q. Did you, did you tell Mr. Rush that 10 Mr. Fruein had transported females on his plane for 11 the purposes of having sex with other individuals? 12 A. I don't know. 13 Q. Well, why -- 14 A. I just don't remember. 15 Q. If Mr. Rush would testify that you told 16 him that other females had traveled on Mr. Epstein's 17 plane and had had sex during the time they were on 18 the planes„ why would you have had that discussion 19 with him? 20 A. You're asking a hypothetical if i said that, 21 why would have i have said that? 22 Q. Well, let me rephrase it this way: With 23 Mr. Rush, if i asked you to assume that he would 24 testify that you, you told him about the 25 transportation, that Mr. Epstein transported other Page 153 1 1 don't remember their specific — 2 Q. is it your belief that Jane Doe ever 3 traveled with Mr. Epstein on his plane? 4 MR. SCAROLA: Excuse me, is the question 5 limited to the testimony — 6 MR. CRITTON: Correct. 7 MR. SCAROLA: — that has been given? 8 MR. CRITTON: Correct. 9 THE WITNESS: No. I do not believe she 10 testified that she traveled with Mr. Epstein on 11 his plane. 12 BY MR. CRITTON: 13 All right. And same would be true with 14 IE., she did not testify that she traveled with Mr. 15 Epstein on his plane, true? 16 A. 1 believe that's true as well. 17 Q. Okay. Are you aware of any other 18 infornAgga from any other source that either Jane 19 Doe or M. traveled on Mr. Epstein's plane? 20 A. No. 21 Q. Did you, did you indicate to — well, let 22 me strike that. Did you tell Mr. Rush that none of 23 your clients had ever traveled with Mr. Epstein on 24 his plane or any, on his plane or with him in any 25 fashion, in any other manner? Page 155 1 women on the plane to have sex with them, what 2 information did you have that was the basis for that 3 claim at that time? 4 MR. SCAROLA: I am going to object to the 5 form of the question. It assumes facts not in 6 evidence. It has no proper predicate. 7 BY MR. CRITTON: 8 Q. Mr. Edwards, did you have Ohislaine 9 Maxwell served in this case with a subpoena? 10 A. Yes. 11 Q. For what purpose? I mean, obviously to 12 take her deposition. 13 A. Exactly, to take her deposition. 14 Q. All right. Do you, is she nei would 15 you agree that neither Jane Doe nor M. have 16 testified to any, that they had any connection 17 whatsoever with Ghislaine Maxwell? 18 A. Yes, I would agree. 19 Q. And what, what was, what is the purpose; 20 that is, with regard to your three clients and only 21 your three clients is they — what connection if 22 any, did Ghislaine Maxwell have to those 23 individuals? 24 MR. SCAROLA: Objection, work-product. 25 Instruct you to not answer. PROSE zatetwe•am, avant-naV.eamtr•-•••••••....T.14.. 2 (Pages 152 to 155) COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins 2d39412d-67f2-4170-9d82-0511,178c2ea EFTA00611239 Page 156 Page 158 1 A. Directly to Scott Rothstein. 2 Q. Was that at the ten minute meeting that 3 you had? 4 A. Yes. 5 Q. At BOVA? 6 A. Yes. 7 Q. And what did he say? 8 A. No problem. 9 Q. He said he would reimburse you? 10 A. Correct. 11 Q. And did that, in fact, take place? 12 A. No. 13 Q. And how did you attempt to get reimbursed 14 for the costs that you had thus far incurred on your 15 personal injury cases including Mr. Epstein's case 16 when you went, when you started at RRA? 17 A. What do you mean? 18 Q. Well, you said that Mr. Rothstein agreed 19 in the ten minute conversation that RRA would 20 reimburse those costs? 21 A. Correct. 22 Q. You go to RRA in April of '09, and I 23 assume you had to ask someone and say, look, Iliad a 24 conversation with Scott Rothstein. He said he would 25 _ fr. 1 BY MR. CR1TTON: 2 Q. \Vhen you originally started working with 3 the Rothstein firm, did you have any discussions 4 with Mr. Rothstein regarding how your cases would be 5 funded; that is, your personal, your personal injury 6 cases and specifically the cases relating to 7 Mr. Epstein? 8 A. No. 9 Q. Okay. With regard to, prior to taking 10 your cases to prior to starting at RRA, you were 11 responsible for the funding of your personal injury 12 cases or any contingency fee case, correct? 13 A. Right. 14 Q. And I assume you had either your own 15 personal funds or you had a line of credit or both? 16 A. Right. 17 Q. And when you came to RRA and you brought 18 the cases with you; that is, the personal injury 19 cases and as well, the Epstein cases, were you 20 reimbursed for the costs that you had already 21 expended thus far on those cases? 22 A. No. 23 Q. Did you request that you be reimbursed? 24 A. Yes. 25 Q. And with, to whom was the request made? 1 A. I didn't do that. 2 Q. You didn't. Did you choose not to do 3 that? 4 A. No. 1,1, the statement was made to me by 5 Scott Rothstein that the costs would be reimbursed. And 6 I anticipated that the costs would be reimbursed. I was 7 there for a fairly short period of time and I didn't 8 know Scott Rothstein personally. So, I didn't go to him 9 additionally to tell him something that we already had a 10 meeting of the minds about. 11 Q. Well, how much in costs did you have 12 outstanding at the time from your cases, including 13 the Epstein cases when you went to the firm RRA, in 14 April of '09? 15 A. I don't know the total. 16 Q. Was it $1,000? Was it $50,000? Was it 17 $100,000? 18 A. More than 100. 19 Q. And did you have that both from, was it, 20 the debt, was that comprised of both your own money 21 and as well as LOC, line of credit money through a 22 bank? 23 A. Correct. 24 Q. Was it more than 150? 25 A. I'm not sure. Page 157 Page 159 1 Q. Was it someplace between 100 and $200,000 2 your best estimate? 3 A. That is my best estimate. 4 Q. Did you find that to be a significant 5 amount of money? 6 A. Of course. 7 Q. Okay. And you said you were at RRA for 8 only a short period of time. In fact, you were 9 there April, May, June, July, August, September, 10 October. You were there seven months, true? 11 A. Yes. 12 Q. Okay. And at no time, even though 13 Mr. Rothstein said he would reimburse those funds or 14 the finn would reimburse those funds to you, at no 15 time during those seven months which you have 16 described as a short period of time, did you ever 17 make a request that you be reimbursed; is that 18 correct? 19 A. I never made a, well, I don't know the process 20 for getting reimbursed, but I never made a formal 21 request. I said it to, at least to Russell Adler on 22 several occasions. And it was always told to me, don't 23 worry about it; the firm is growing; there is a lot of 24 things to deal with right now; he operates under the reimburse costs. system of fairness ; you will get reimbursed agassems.w 3 (Pages 156 to 159) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins 2d39412d47f2-4170-9082-0511ff76c2ea EFTA00611240 Page 160 Page 162 1 And obviously nobody expected the ending 1 A. Well, you've thrown a lot of things in there. 2 'to the law firm that ultimately occurred. 2 navel expenses come beck with your receipts, hand them 3 Q. With regard to the case, !assume you 3 over to, I would hand them over to my secretary. And 4 settled a couple of personal injury cases during the 4 she would get them to the appropriate place in the 5 seven months you were there, yes? 5 machine known as Rothstein Rosenfeldt Adler. And in my 6 A. Yes, you assume that. 6 next — and I would get a check, l believe. 7 Q. That's correct? Let me ask the question. 7 Q. All right. How about depositions, I mean 8 Did you settle any contingency fee cases during the 8 during the time that we, we took depositions from 9 sevens months that you were at the RRA firm? 9 the time you were at RRA, transcripts were ordered 10 A. Yes. 10 of depositions. They were expedited of various 11 Q. And when you settled those cases did you, 11 hearings. You took trips. You took a trip to New 12 and they closed, they were settled through, did you 12 York to take the deposition of Mark Epstein, 13 have any control of the trust account? 13 correct; all those things occurred? 14 A. No. 14 A. Yes, all of those things occurred. 15 Q. Okay. Settlement monies come in on a 15 Q. So, when you would get a bill in for the 1.6 personal injury case What did do with the 16 trip for to go up and see Mark Epstein. or to take you money once the, once the client had endorsed the 17 17 Mark Epstein's deposition, you had travel costs 18 check? 18 associated with that and you had plane fare, 19 A. i, I didn't personally do anything with the 19 taxicab, hotel, whatever else you had, correct? 20 money. It was not handled by me. 20 A. I had costs associated with that 21 Q. Okay. Were you there- 21 Q. All right. And when you met with Mr. 22 A. That's why I'm confused. Did i settle the 22 Rothstein initially, what was your understanding or 23 case? I mean, Rothstein Rosenfeldt Adler firm settled 23 did you have an understanding as to how costs would 24 personal injury cases while I was there. There were no 24 be handled; that is, how they would be paid on cases 25 eases that were solely my cases. They were firm cases. 25 that you brought to the firm? Page 161 Page 163 1 Q. Let me rephrase the question. You 1 A. It was unspoken but I had some understanding 2 brought, you brought cases to the firm, correct? 2 just based on logic. 3 A. That is correct. 3 Q. Separate and apart from logic, did anybody 4 Q. Of any of the cases that you brought, did 4 tell you that you had; that is, that RRA would pay S you settle those cases? 5 all of the costs associated with prosecution of the 6 A. No. 6 Epstein cases? 7 Q. Okay. So, you never had an instance — so 7 A. Did anybody tell me? No. 8 there was never a set of circumstances where you 8 Q. Okay. Were you ever required to draw 9 would have been reimbursed for costs as a result of 9 against either your personal funds or your personal 10 a settlement? 10 LOC after you started with RRA to fund the Epstein 11 A. That's correct. 11 cases? 12 Q. All right. And, and so during the seven 12 A. I don't know how to answer your question, 13 months that you were there, you were never 13 Mr. Critton, because if I were to go out of town and 14 reimbursed a nickel of the one to $200,000 that you 14 purchase a plane ticket, yeah, I would purchase that 16 had outstanding in costs? 15 personally and then I would be reimbursed. If I ordered 16 A. That is correct. 16 a deposition transcript, which is a totally different 17 Q. All right. With regard to the costs that 17 category, that gets billed to the firm. I never see the 18 were to be incurred for prosecuting the cases, 18 bill or anything else. So, you're just throwing a bunch 19 specifically the Epstein coign what was your 19 of things together that don't necessarily go together. 20 understanding — was that ever discussed with 20 I am trying my best for you. 23. Mr. Rothstein at the ten-minute meeting? 21 Q. No, that's fine. Commonly in a personal 22 A. Repeat that. I'm sorry. 22 injury closing, you would see the recover, you would 23 Q. Sure. How were, how were costs 23 see a list of the costs. The costs would include 24 investigation costs, deposition costs, travel 24 court reporters, investigation fees, subpoenas, 25 expenses to be reimbursed? 2 5 things of that nature, correct? 4 (Pages 160 to 163) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Cynthia hopkIns Electronically signed by cynthia hopidns Electronically signed by cynthia hopkins 2434412443724170441B241611M6ean EFTA00611241 Page 164 Page 166 1 A. I have seen them before, yes, sir. 1 responsibility to pay those bills. 2 Q. Okay. And as well there would be 2 Q. And is that what Russell Adler told you? 3 reimbursable expenses such as when you went to New 3 A. Yes. 4 York and took Mark Epstein's deposition. You, you 4 Q. Did you ever discuss that with anyone else 5 paid for the expense up front but, in fact, it was 5 in the firm or just Russell Adler? 6 then reimbursed by the firm, correct? 6 A. last Russell Adler. 7 A. Now we're specifically, specifically talking 7 Q. So, if the bill came in fix one of those 8 about Mark Epstein's deposition, yes, that, what you 8 types of costs, you would give to your secretary or 9 just said is correct. 9 would she handle it automatically? 10 Q. Okay. Not only was the, and if I 10 A. I never would see the bill. Why would it come 11 understand your testimony is the deposition was paid 11 into my name? It just didn't do — that never happened. 12 for directly by the firm. With regard to your 12 It was billed to Rothstein Rosenfeldt Adler. 13 travel, any hotel, other expenses that you had, you 13 Q. So, you would never see the bill that came 14 put in a request for reimbursement and the firm 14 in? 15 would reimburse you? 15 A. Correct. 16 A. Correct. 16 Q. — even if it was a RRA attention Brad 17 Q. All right And with regard to those 17 Edwards, you wouldn't see that? 18 costs, you said you and Mr. Rothstein never had a 18 A. Presuming that happened, attention, Brad 19 discussion about that; is that correct? 19 Edwards, I still never saw it. No, I never saw a bill 20 A. Correct 20 to my recollection right now the whole time I was at 21 Q. All right But you did speak with 21 Rothstein Rosenfeldt Adler. 22 Mr. Adler about how costs would be handled on your 22 Q. Did Mr. Rothstein ever discuss with you 23 cases including Mr. Epstein's case after you started 23 whether there would be a budget associated with how 24 with BRAT 24 much money you could spend on a particular case? 25 A. Correct. 25 A. No. Page 165 Page 167 1 Q. Okay. And is he the only one who 1 Q. Okay. Did anyone at the firm ever talk to 2 explained what the procedure was? 2 you about whether or not there would be a budget 3 A. Yes. 3 associated with how much you could spend on an 4 Q. And what did he tell you? Well, let me 4 Epstein case or any personal injury case? 5 ask you this: Did he tell you what; that is, that 5 A. No. 6 the firm would pay for all of the reimbursements 6 Q. In terms of authorization, if you wanted 7 either costs and/or reimbursements for costs that 7 to order a deposition expedited or if you wanted to 8 were incurred in prosecuting the Epstein files and 8 pay for a specific expense, whether it was an 9 any other files that you had? 9 outside investigator or to send an investigator to a 10 A. Can you split this question up so that we're 10 location, whose decision was that? Is that you and 11 not talking about reimbursement and costs and things 11 you alone to incur that cost? 12 like that 12 A. Which question do you want me to — you asked 13 Q. Sure. With regard to costs such as 13 a bunch of things there that some of them may have been 14 depositions .- 14 my decision. Other parts of that would obviously be 15 A. Okay. 15 somebody else's. But you're throwing five or six items 16 16 in there and you want me to give you an answer. Q. — court reporters, court tcputter fees, 17 video depositions, transcripts of hearing, whether 17 Q. Let me break it them down. With regard to 18 they were expedited or whether they were asked on a 18 any costs that you wanted to incur, incur relating 19 routine basis? 19 to a Jeffrey Epstein matter, was there an 20 A. Right. 20 authorization process; that is, did you have to get 21 Q. Where would the — who was responsible for 21 someone's okay before you could spend X amount of 22 paying those bills? 22 dollars? 2 3 A. The bills would, to my to the best of my 23 A. No. 24 knowledge would be billed to the law firm of Rothstein 24 Q Okay. It was, and who told you that you 2 5 Rosenfeldt Adler, and it would be their financial 25 never had to get an approval for any expense 5 (Pages 164 to 167) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins (601.051.976.2934) 2d39412d-6712-41704d82-05111176c2ea EFTA00611242 Page 168 1 associated with the Jeffrey Epstein case? 2 A. I didn't say that anybody did. So, no, 3 nobody, nobody. 4 Q. You could just spend whatever money you 5 wanted to in prosecuting your cases; is that 6 correct? 7 A. No, I didn't say that either. 8 Q. What was the procedure then? 9 A. That if I was at a deposition and there was a 10 need in my judgment for the transcript to be expedited 11 then i would order it expedited and nobody ever told me 12 that they had a problem with my judgment as to those 13 things. And not as to those things. As to that thing 14 which we were talking about which right now is 15 expediting deposition transcripts. 16 Q. With regard to — so any, how about an 17 expense associated with hiring, with either 18 directing -- well, let me strike that. With regard 19 to Epstein, did, were you ever required or did you 20 ever hire outside investigators to do work 21 associated with the Epstein case? 22 By outside i mean someone who was not an 23 employee of RRA and now i mean dealing with the time 24 that you were at RRA 25 A. Right. And your question is did I over hire Page 170 1 Q. Did you meet, did you know Mr. Fisten 2 before you started working at RRA? 3 A. Same answer, no. 4 Q. No. All right. And Mr. Fisten, did you 5 direct Mr. Piston to do investigations in Martha's 6 Vineyard? 7 A. No. 8 Q. Did you direct Mr. Eislen to do 9 investigations in California? 10 A. I directed Mr. Fisten to interview people and 11 ultimately it was learned that they lived in California. 12 Q. And did Mr. Fisten go to California to 13 interview those individuals? 14 A. To the best of my knowledge he did. 15 Q. Okay. And who did he go and interview? 16 MR. SCAROiA: That is work-product and I 17 instruct you not to answer. 18 BY MR. CRITIDN: 19 Q. Did Mr. Fisten interview a person by the 20 name of Michael Sanka (phonetic)? 21 MR. SCAROLA: That is work-product and I 22 instruct you not to answer. 23 MR. CRITTON: Did Mr. Fisten interview a 24 individual by the name of Michael Friedman 25 (phonetic)? Page 169 1 an outside investigator to perform work on Jeffrey 2 Epstein's case? 3 Q. Correct? 4 A. The answer is no. 5 Q. Were, were all the investigations that 6 were done during the time that you were employed by 7 RRA, were they done by in-house investigators? 8 A. I don't know. 9 Q. Well, if you wanted investigation done on 10 Mr. Epstein, how would you go about authorizing that 11 or directing that that be done? 12 A. I would ask one of the investigators to do it. 13 Q. So, you would direct the specific 14 investigator? 15 A. Yeah. There were plenty of times where I 16 directed the specific investigator. i want you to talk 17 to this witness or so-and-so, yes, just like you would 18 in any case. 19 Q. In this particular instance associated 20 with Mr. Epstein, what investigators worked on 21 Mr. Epstein's case during the time you were at RRA? 22 A. If you want an exclusive list, I don't know. 23 Q. I want to know? 24 A. I can tell you Michael Fisten did because I 25 communicated with him directly. Page 171 1 MR. SCAROLA: That is work-product and I 2 instruct you not to answer - 3 MR. CRITION: Mr. Fisten -- 4 MR. SCAROLA: — except to the extent as 5 may have already been disclosed to the defense 6 in any of the three cases that are currently 7 pending. Any and all questions about 8 investigative work will meet with the same 9 objection and same instruction. 10 BY MR. CRITTON: 11 Q. Did you direct Mr. Fisten that he could 12 represent that he was an agent of the FBI in 13 interviewing individuals in California? 14 A. Of course not 15 Q. Did you — and if in fact Mr. Piston 16 represented he was an agent of the FBi, you would 17 find that reprehensible, true? 18 A. This is some hypothetical question that I do 19 not believe exists. 20 Q. I'm asking you to assume that Mr. Fisten 21 represented that he was an agent of the FBI. You 22 would find that type of conduct by the investigator 23 to be inappropriate, correct? 24 A. I'm not going to render an opinion on a 25 hypothetical that doesn't exist 6 (Pages 168 to 171) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia bodkins Electronically signed by cynthia bodkins Electronically signed by cynthia bodkins 2d39412d-6112-4170-9d82-0511ff76c2ea EFTA00611243 Page 172 Page 174 1 Q. So, you're refusing to answer that 2 'question? 3 A. You're asking me about my definition of 4 reprehensible as it pertains to a specific hypothetical 5 that you've just created. 6 Q. Let me ask you -- 7 A. Now, you want me to try to analyze that 8 particular hypothetical and tell you whether it meets 9 the definition of reprehensible? 10 Q. I will let you — if Mr. Fisten, if l ask 11 you to assume that Mr. Fisten represented to a 12 witness out in California that he was an agent or 13 working for the FBI, would you find that conduct 14 appropriate by Mr. Fisten? 15 MR. SCAROLA: And I will tell you that you 16 are not obliged to answer hypothetical 17 questions. 18 THE WITNESS: And therefore I am not going 19 to answer that question. 2 0 BY MR. CRITTON: 21 Q. If Mr. Fisten represented that he was 22 associated with the Miami-Dade Police Department, 23 Miami-Dade County Police Department, would you find 24 that conduct inappropriate? 2 5 MR. SCAROLA: Same instruction and I would 3. 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. Could he -- is it your — A. How would I know associate, he may have been? Q. Let me ask you this, was he employed by the Miami-Dade Police Department in addition to RRA during the time he worked there? A. To the best of my knowledge, no. Q. Did -- with regard to Mr. Epstein's cases was there any type of cost account set up for, for them? A. I don't know. Q. Could you access any of the financial files within the RRA firm? A. No. Q. Could you access any files that were associated with your specific, excuse me, clients or your specific case such as if you wanted to know how much in costs had been incurred by Mr. Epstein -- on Jane Doe's case while at the RRA firm, could you request that, could you access that information? A. I don't know. Q. Did you ever try to rots that information? A. No. Q. At any time did you request that anybody provide you copies of what the costs were associatcd 3 Page 173 1 also observe with regard to each of the 2 hypothetical questions that you are asked that 3 they are incomplete. And without knowing all 4 of the surrounding circumstances, it would be 5 impossible for any witness to pass judgment 6 upon what may have occurred. 7 BY MR. CRITTON: 8 Q. So, Mr.-- would it be a correct statement 9 at least as you understood it, Mr. Edwards, that 10 Mr. Fisten was not an agent, was not an FBI agent 11 during the time that he worked for RRA? 12 A. You're asking me was he an FBI agent or did he 13 work for RRA He worked for RRA 14 Q. Correct. He was not an FBI agent, true, 15 to the best of your knowledge during the time he 16 worked for RRA 17 A. Okay. 18 Q. I am not talking about any other time 19 period right now. 20 A. Okay. Then the answer is he was not an FBI 21 agent at the time he was working for RRA 22 Q. During the time he worked for RRA he as 23 well was not associated with Miami-Dade Police 24 Department, comet? 25 A. Oh, I don't know that. Page 175 1 with Mr. Epstein's cases? 2 A No. 3 Q. Since you left the firm have you requested 4 any type of detailed billing or cost analysis such 5 as to the cost of any of the costs that were 6 incurred on any of Mr. Epstein's cases? 7 A. Of course. 8 Q. Okay. And did you receive those costs? 9 Did you receive that information? 10 A. Yes. 11 Q. And what costs have been incurred in the 12 cases, in the Epstein cases associated up — let me 13 strike that. What costs, what is the total amount 14 of costs that were incurred in the Epstein cases 15 during the time that those files existed in the RRA 16 firm? 17 MR. SCAROLA: If you're able to answer 18 that question with regard only as to amount 19 without specifying any of the specific cost 20 expenditures, then I think we can answer that 21 question only as to 8MOUnt. 22 THE WITNESS: And the question as to the 23 aggregate in the three cases? 24 MR. CRITTON: Correct. 25 THE WITNESS: Because I can't delineate 7 (Pages 172 to 175) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthla hopkins Electronically signed by cynthia Napkins Electronically signed by cynthla hopkins 2d39412d-6712-4170-9•182-0511t176c2ea EFTA00611244 Page 176 1 for you. 2 MR. CRITTON: Your best estimate. 3 THE WITNESS: Okay. I believe more than 4 $300,000. 5 BY MR. CRITTON: 6 Q. With regard to, if investigation was done 7 on, on a Epstein case, was the investigator charged, 8 that is for his time, as an example Mr. Fisten, if 9 he did work in California would his time, I'm not 10 talking about his expenses, would that be billed as 11 a cost to the file? 12 A. I don't know. 13 Q. On the cost that you received, well, let 14 me strike that. If I understood it, up to 300,000 15 approximately $300,000 that's been spent on the 16 Epstein file, were you able to look -- 17 A. It would be more than that. I am just saying 18 it's at least $300,000. 19 Q. Something between three and $400,000, 20 could it -- 21 A. Something that I would say is definitely 22 between 300 and $500,000, but I'm not sure. It could be 23 301. It could be 450. I really don't know. 24 Q. When was the last time that you looked at 25 that ledger or the printout associated with the Page 178 1 firm had you, you had spent some of your own money 2 and/or LLC money on the files; is that correct? 3 A. That's comet. 4 Q. Approximately how much is that amount? A. Fin, I'm not sure. I think as you're aware 6 most of the depositions and costly work that was done on 7 the files happened to have been done during that time 8 period for all of the respective cases or claims against 9 Mr. Epstein during that time period of last summer of 10 2009. 11 Q. All right. But in terms of your costs 12 prior to coming to RRA, what's your best estimate of 13 the costs that you have paid either out of pocket or 14 are responsible to a bank to repay? 15 I don't know. 16 More than 25,000, less than 25,000? 17 I'm not sure. 18 More than 100,000? 19 No. 20 More than 50,000? 21 I don't know. 22 Q. That's a record obviously you could pull 23 up, correct? 24 A. Correct 25 Q. All right. Now, with regard to, prior to A. Q. A. A. Q. A. Page 177 1 Epstein files? 2 A. I have never looked at the printout. 3 Q. Okay. How, how do you know what is amount 4 is then? That is how do you have the estimate of it 5 being between 350, I'm sorry between 300 and 6 $500,000, the cost associated with Epstein? 7 A. I asked a paralegal within my current fimi for 8 the total amount of costs on these three cases that is 9 being claimed by Rothstein Rosenfeldt Adler. And I 10 remember the cost number in the aggregate being given to 11 me reflecting an amount what I just told you. 12 Q. Have you requested a copy of the — let me 13 strike that. Did she say she had, that is did 14 she — did you actually receive a document that 15 reflects the breakdown of the costs from the 16 trustee? 17 A. I personally have not seen that 18 Q. Okay. Has your firm received it? 19 A. I don't know. 20 Q. I assume -- would it be a correct 21 statement that the three to S500,000 is, includes 22 only the time between April of '09 and October of 23 '09 when you were with the firm? 24 A. Ws a good question. I, I believe so. 25 Q. And approximately, prior to joining the Page 179 1 your coming to RRA, had there been any investigation 2 work that you had done on the Epstein files -- and 3 let me strike that. Had you hired or retained an 4 investigator to do any work for you on the Epstein 5 files prior to coming to RRA? 6 A. I don't think so. 7 Q. All right. 8 A. It would have been around that time. !don't 9 remember whether the initial investigator was hired by 10 me from my previous, from my solo firm or was hired by 11 Rothstein Rosenfeldt Adler. I can't say. 12 Q. Who was the first investigator that you 13 believe was involved in investigating the Epstein 14 cases? Just a name not topic? 15 MR. SCAROLA: Work-product, instruct you 16 not to answer. 17 BY MR. CRITTON: 18 Q. Was the first person that was retained as 19 an investigator someone who ultimately became 20 employed by RRA? 21 MR. SCAROLA: You can answer that. 22 THE WITNESS: No. 23 BY MR. CRITTON: 24 Q. The, the person who you hired to -- and by 25 investigation I mean something other than looking up 8 (Pages 176 to 179) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins ( Electronically signed by cynthla hopkInsr Electronically signed by cynthia hooking ( 2d39412d-67f2-4170-902-0511f176c2n EFTA00611245 Page 180 1 an address to serve a subpoena or, or doing some 2 minimal background. 3 A. lam glad you clarified because I am using 4 that same definition. Q. All right. So, it's, it's your best 6 recollection that you did or did not hire an 7 investigator to do real investigative work with, 8 associated with Mr. Epstein prior to joining RRA? 9 A. I believe I did, but it was after a time when 10 I had, I was contemplating or at least to myself had 11 committed to going to RRA So, it was within that time 12 period I believe that I hired that person prior to RRA 13 Q. When you then went to — now you had 14 committed to go to RRA or at least mentally 15 committed to go to RRA As soon as you started with 16 RRA, did you terminate the services of that 17 investigator? 18 A. No. 19 Q. Did that investigator continue to do work? 20 A. Yes. 21 Q. Okay. Has, does he or she or it continue 22 to do work today for you? 23 A. No. On Mr. Epstein's case you're asking, 24 right? 25 Q. Yes, sir. Page 182 1 MR. CRITTON: You are claiming 2 work-product? 3 MR. SCAROLA: Yes. 4 BY MR CRITTON: Q. The investigators, did you understand them 6 to be salaried employees of RRA? 7 A. I really have no idea. 8 Q. Did you ever ask them? 9 A. No. 10 Q. Do you know whether the, do you have any 11 knowledge as to whether the investigators kept tirrc 12 records? 13 A. I do not have that knowledge. 14 Q. In terms of when an investigator would 15 come back -- well, do you know how the investigators 16 were paid? 17 A. With money. 18 Q. From RRA? 19 A. I would presume. Totally speculation. 20 Q. Would the RRA -- were the investigators 21 for RRA bonused? 22 A. I have no idea. 23 Q. Did you ever discuss with Mr. Piston what 24 his financial compensation was associated with RRA? 25 A. No. Page 181 1 A. No. 2 Q. Okay. For how long a time period did that 3 person continue to do the work before it got 4 transferred to Mr. Fisten or other investigators? 5 A. Question doesn't make sense. 6 Q. Okay. How long did the investigator that 7 you may have hired prior to joining RRA work on the 8 Epstein files before you ceased that work after you 9 started working for Epstein in April of '09? I'M 10 sony, for RRA in '09. 11 A. The person was hired in either March or April 12 of 2009, which is why I can't say with absolute 1.3 certainty whether 1 was at RRA or not. And that person 1.4 continued to do investigative work in some capacity 15 probably throughout the entire time that I was at RRA 16 Q. Were all of the bills for that 17 investigator paid by RRA7 18 A. Yes. 19 Q. With regard to the payments for the 20 investigators -- well, let me strike that. Who 21 other than Mr. Fisten from an investigator, from an 22 internal investigator at RRA employee worked on 23 doing investigation on the Epstein files? 24 MR. SCAROLA: Same objection, same 25 instruction. Page 183 1 Q. Did, did you ever promise either 2 Mr. Fisten or any other investigator that when the 3 case settled, they would get a bonus from an Epstein 4 case? 5 A. No. 6 Q. Okay. Did Mr. Fisten ever inquire of you 7 as to whetter he would gm a bonus Cin fact, the 8 cases on which he worked including the Epstein cases 9 settled for a favorable verdict or result owe in? 10 A. No. 11 Q. Did you lave any understanding from either 12 your conversations from Mr. Rothstein whether 13 investigators were bonused based upon the work that 14 they did? 15 A. Excuse me? 16 Q. Did you ever have an understanding from 17 Mr. Rothstein that, that investigators would be 18 bonused from cases on which they worked based upon 19 their work product or their contribution? 20 A. No. I had no understanding. 23. Q. Did you, from I assume you've read a 22 number of the news reports associated with 23 Mr. Rothstein and the implosion of the firm? 24 A. Okay. 25 Q< I assume you have seen a number of them? 9 (Pages 180 to 183) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by Cynthia hopkins 2d39412d-8712-4170-94:182-0511ff78c2ea EFTA00611246 Page 184 Page 186 1 A. What do you mean by a number? 1 representing Mr. Epstein including myself? 2 . Q. Mon than one. 2 MR SCAROLA: Same objection, same 3 A. Yes, I have seen more than one. 3 instruction. 4 Q. Have you seen articles were it's alleged 4 BY MR. CRITTON: 5 that investigators that were employed by Rothstein, 5 Q. Did you ever? 6 by RRA would go through the garbage of prospective 6 MR. SCAROLA: Mr. Edwards will not answer 7 Defendants to search for incriminating or favorable, 7 any questions regarding what he did or didn't 8 incriminating evidence against the Defendant or 8 do. 9 favorable evidence for a Plaintiff who might be 9 MR. CRITIDN: I understand. I just want 10 working or who might be a client of the firm? 10 to make it certain it's for the court on some 11 A. I have not seen an article saying that. I 11 of these issues. 12 think I have heard your client say that before. 12 MR. SCAROLA: Well, for the court I am 13 Q. Separate and apart -- 13 telling you he is not going to answer any of 14 A. Right. 14 those questions. And continuing to ask them in 15 Q. You don't have to rely on anything my 15 light of the fact that we have told you and 16 client has said before, the testimony -- 16 made it clear the scope of our assertion of 17 MR. SCAROLA: I am sure we won't 17 privilege serves no useful purpose. 18 MR. CRITION: I am confident of that. 18 BY MR. CRTITON: 19 BY MR. CRITTON: 19 Q. Mr. Edwards, at any time, did you -- well, 20 Q. In terms of, were you aware from the 20 let me strike that. Did you ever direct the 21 articles, did you see in the article — let me 21 investigators to, during the time you were at RRA, 22 strike that. Did you ever direct your investigators 22 to conduct a surveillance on Mr. Epstein's property? 23 to go through Mr. Epstein's trash? 23 MR. SCAROLA: Same objection, same 24 MR. SCAROLA: I am going to object, 24 instruction. 25 work-product, attorney-client privilege. 25 Page 185 Page 187 1 BY MR. CRITTON: 1 BY MR. CRITTON: 2 Q. Have you directed, did you ever direct — 2 Q. Since the time you have left RRA in your 3 this is the investigators during the time you were 3 current firm, have you conducted surveillance on Mr. 4 at RRA and that's the question you're claiming the 4 Epstein's property? 5 privilege over, correct? 5 MR. SCAROLA: Same objection, same 6 MR. SCAROLA: I am claiming the privilege 6 instruction. 7 with respect to any action that was taken by 7 BY MR. CRITTON: B Mr. Edwards or at Mr. Edward's direction in — 8 Q. Have you instructed anyone, either of the 9 MR. CRITTON: Tell you what, I will 9 in-house investigators to conduct surveillance of 10 withdraw the last question. 10 Mr. Epstein's property? 11 MR. SCAROLA: — in connection with the 11 MR. SCAROLA: Same objection, same 12 investigation in prosecution of the claims 12 instruction. 13 against Mr. Epstein. 13 BY MR. CRTITON: 14 BY MR. CR1TTON: 14 Q. Have you authorized investigators employed 15 4 Let me make my question clear, 15 by RRA, either employees of the firm or an outside 16 Mr. Edwards. With regard to your investigators, you 16 investigation firm, to walk around the perimeter of 17 gave direction with regarding the Epstein cases, 17 Mr. Epstein's home on or about March 17th of 2010? 18 during the time you were with RRA did you ever tell 18 MR. SCAROLA: Same objection, same 19 them or direct them to go through Mr. Epstein's 19 instruction. 20 trash? 20 THE WITNESS: What's the date? 21 MR. SCAROLA: Same objection, same 21 MR. CRITTON: March 17th 2010. 22 instruction 22 MR. SCAROLA: St Patrick's Day. Did you 23 BY MR CRITTON: 23 employ any leprechauns? 24 Q. Did you ever direct the investigators to 24 THE WITNESS: Actually -- 25 go through the trash of the lawyers who were 25 10 (Pages 184 to 187) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins 2d39412d.6712-4170-9d82-0511t176c2ea EFTA00611247 1 Page 188 BY MR. CRITTON: 1 Page 190 Q. Okay. Well, if you could authorize any 2 ' Q. With regard to the, with regard to the 2 expenditure that you wanted and nobody ever told you 3 investigators, with regard to the investigation 3 not to, that you couldn't spend the particular 4 bills that would come in from outside investigators, 4 money, what controls, if any, existed with regard to 5 specifically the one that you — well, let me strike 5 monies spent on the Epstein cases? 6 that. 6 A. The presupposition that you just created is 7 The investigator that you hired before you 7 incorrect, so I cannot answer that question. You began 8 went to RRA, I think you testified that bill was 8 with I have no limit to how I can spend money and that 9 paid by RRA, correct? 9 there is no regulation. I mean, that's just not true, 10 A. Yes. 10 so I don't understand what to tell you. 11 Q. All right. And in terms of the 11 Q. What limits if any did you have in 12 investigators who were employed by RRA for whatever 12 spending money in prosecuting Mr. Epstein's case? 13 investigation you directed them to do, those 13 A. We went through expediting transcripts and I 14 individuals were also paid from funds from RRA, 14 used my own judgment. 15 correct? 15 Q. I understand that 16 A. During the time period when l was at RRA 16 A. If we have another specific example, I will 17 you're asking about specifically, correct? 17 address it and I will tell you whether I had that 18 Q. Correct. 18 authority or somebody else may have had that authority. 19 A. Then the answer is, yes. 19 But specifically related to expediting transcripts and 20 Q. Was there any specific cost account that 20 things involving depositions, ordering depositions, I 21 was set up for Mr. Epstein's cases? 21 used my judgment and it was never questioned. 22 A. I don't know. 22 Q. Separate and apart from transcripts, if, 23 Q. Did you ever speak with the — 23 if — you've testified that the expenditures for 24 A. Again we're talking about the tint period at 24 costs that the firm or the trustee is seeking back, 25 RRA? 25 at RRA is seeking bacic, is seeking relating to any Page 189 Page 191 1 Q. At RRA 1 recovery in any Epstein cases is between three and 2 A. Okay. 2 $500,000, correct? 3 Q. During the time you were at RRA did you 3 A. Correct. 4 ever speak with the accounting department or the 4 Q. All right. So, separate and apart from 5 accounting department ever call you to talk about 5 expedited transcripts or video depositions or 6 the amount of costs, assuming they were something 6 serving subpoenas, that, there has to he, you know, 7 between 300 and $500,000 that were being expended on 7 hundreds of thousands of dollars in additional 8 Mr. Epstein files? 8 expenses that were associated with prosecuting 9 A. No. 9 Mr. Epstein's cases, correct? 10 Q. Did, did anyone at the rum ever call you 10 A. Correct 11 to discuss the issue of the amount of costs between 11 Q. And with regard to those types of 12 300 and $500,000 that were being incurred to 12 expenditures that are in the hundreds of thousands 13 prosecute Mr. Epstein's cases? 13 of dollars, who authorized those types of 14 A. No. 14 expenditures? 15 Q. Okay. Who had checked — did you have any 15 A. I don't know. 16 check-signing authority at RRA? 16 Q. Well, you said that you used judgment 17 A. No. 17 certainly with regard to transcripts. So, who, if, 18 Q. Who did sign the checks? 18 if spending an extra two, three, $400,000 separate 19 A. I don't !mow. I was — 19 and apart from transcripts, serving subpoenas is not 20 Q. In terms of the, the work that was being 20 a limitless budget, how would you describe it; that 21 done or the, the work that was, that is the costs 21 is, what controls if any did you have in prosecuting 22 that were being incurred including reimbursable 22 the Epstein cases? 23 costs, did you understand that you had a, basically 23 A. First, I haven't seen the delineation of that 24 an unlimited budget to prosecute those cases? 24 amount and I don't know that we agree with Rothstein 25 A. No. 25 Rosenfeldt Adler as to their costs, but that is what 11 (Pages 188 to 191) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins ( 2d39412d.8712-4170-9d$2•0511ffitic2ea EFTA00611248 Page 192 1 they're claiming. I never juxtaposed that with what 1 2 believe should be the proper amount. But beginning with 3 the fact that I do recognize that as the amount that 4 they are claiming, I was not aware that the costs were 5 that high. 6 The cases were firm cases, paid for by the 7 firm. I was simply an employee and I made judgment 8 calls. If somebody had told me at any given time, 9 we shouldn't serve these subpoenas, or we shouldn't 10 take this deposition, I wouldn't have done it. 11 Q. In fact, with regard to -- well, let me 12 ask you this: Were any informants, did you 13 authorize your investigators to hire informant, 14 informants? 15 MR. SCAROLA: Same objection, same 16 instruction. 17 BY MR. CRJTTON: 18 Q. Did you authorize your investigators to do 19 electronic eve's dropping? 20 MR. SCAROLA: Same objection, same 21 instruction. 22 BY MR. CRITTON: 23 Q. You indicated that you were just an 24 employee, correct? 25 A. Yes. Page 194 1 suggests that those terms are mutually 2 exclusive. 3 THE WITNESS: That was apart of my answer 4 is that, I don't know 5 MR. CRITTON: I am shocked to hear that. 6 THE WITNESS: I don't know that being an 7 employee means that you can't also be a partner. There are equity partners and 9 non-equity partners to nearly every single 10 large firm, so I was a non-equity pastier 11 otherwise known as a salaried employee. That's 12 just the way it was. 13 BY MR. CRITTON: 14 Q. But your card just reflected partner as 15 did your -- 16 A. Rather than that whole script I just told you. 17 Q. Right. Rather than the qualifying 18 provisions. 19 A. Yes, you're right. The qualifying positions 20 didn't make the card. 21 Q. With regard to the monies that was, that 22 were being paid by, by Rothstein, I'm sorry, by the 23 RRA firm for the costs -- let me strike that. 24 During the time that you were at the RRA firm, the 25 seven months that you were there from April through 3. 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 193 Q. Okay. In fact, you, on various documents reflected that you were a partner of the firm, correct? A. Yes, document, documents do reflect that title, of course, yeah. Q. And if I had asked for a card during the time that you started at RRA up until the time of the implosion of the firm in late October of '09, would your card have also reflected that you were a partner of the firm? A. I think you did request a card. I think I gave it to you and I believe that it did say partner on it. Q. And you would agree that at least up until the time of the implosion of RRA you held yourself out to the public, and including other lawyers, as being a partner of RRA, true? A. What do you mean by held myself out to the public? Q. You called yourself a partner. You didn't say I'm an employee; I'm not a partner, correct? You held yourself out to the public as being a partner? MR. SCAROLA: Pm going to object to the form of the Question to the extent that it Page 195 1 the end of October, do you recall any significant 2 settlements that were coming into the firm; that is, 3 that were publicized? 4 A. Do I recall significant settlements — 5 Q. Correct 6 A. -- coming into the firm that were publicized? 7 Q. Correct? 8 A. lbelieve, I can't say with any degree of 9 specificity whether I remember anything that falls into 10 all of those categories. 11 Q. Now, I forgot my question fix a minute. 12 If I understand your answer, and assuming I remember 13 my question, Mr. Edwards, you don't recall any 14 significant settlements coming into the firm that 15 were, that were publicized either internally within 16 the from or within the newspapers; is that a fair 17 statement? 18 A. Fair statement. 19 Q. Where did you think all of the money that 20 was coming from — let me strike that. At that time 21 how many lawyers were there in the Fort Lauderdale 22 office; that is, during the time you were there? 23 A. I don't know. 24 Q. Best estimate? 25 A. Seventy. 12 (Pages 192 to 195) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cyrithis hopkins Electronically signed by Cynthia hopkins Electronically signed by cynthia hopkins 2d39412d-11712-4170-9d82-0511 ff76c2ea EFTA00611249 Page 196 1 Q. Okay. And the support, how many floors 2 did ERA occupy in the Fort Lauderdale -- 3 A. I believe six. 4 Q. And approximately how many square feet on 5 each floor? 6 A. I don't know. A lot. 7 Q. More than 10,000 square feet on each 8 floor? 9 A. I don't know. 10 Q. And what was the support staff at the time 11 that you were there approximately? 12 A. In quantity or quality? 13 Q. Quantity, the number of people. 14 A. I don't know. A lot of people. 15 Q. Did you do any hourly billing yourself at 16 all or were you strictly a contingency fee person? 17 A. 90 percent contingency. 18 Q. And with regard to the monies that were — 19 separate and apart from the Epstein, Epstein cases 20 where at least you now know that they cost between 21 three and $500,000, you were, I assume, incurring 22 other expenses on other cases, true? 23 A. True. 24 Q. All right. And where did you, where did 25 you think that the money was coming from; that is, Page 198 1 BY MR CRITTON: 2 Q. Where did you think the law firm -- let me 3 strike that. Did you ever discuss with anyone 4 whether it was from current cash that was being used 5 or whether they had a line of credit or both? 6 A. Didn't know. 7 Q. Mr. Edwards, did you come to learn that 8 investigators had, that investigators had gone to 9 Mr. Epstein's property on March 17th, 2010? 10 A. No. 11 Q. Did you ever authorize any investigators 12 to enter Mr. property (sic). Mr. Epstein's property 13 on March 17th, 2010? 14 MR. SCAROLA: Objection. Instruct you not 15 to answer on the basis of work-product 16 privilege. 17 BY MR. CRITTON: 18 Q. Let me just be clear. Are, are you aware 19 of any investigators who entered Mr. Epstein's 20 property on March 17th, 2010? 21 MR. SCAROLA: Same objection as well as 22 attorney-client privilege and instruct you not 23 to answer. 24 BY MR. CRITTON: 25 Q. Mr. Edwards, did you authorize any 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 197 the source of the money to pay the extensive bills that were being incurred on Epstein and other cases? MR. SCAROLA: I am going to object to the extent the question calls -- excuse me, Pm going to object because there is no proper predicate to the question, and that is that it was a matter that was ever given a thought by Mr. Edwards. MR. CRITTON: Is that form? Form is adequate so you don't have to instruct him. MR. SCAROLA: Thank you. THE WITNESS: What's thc question? BY MR CRITTON: Q. What did you consider, what did you believe was the cost; that is, the source of the money that was used to be paying these extensive costs that were being incurred in Epstein and other cases? MR. SCAROLA: Objection. MR. CRITTON: Just of yours and yours alone? MR. SCAROLA: Objection, form and compoluxl. THE WITNESS: The law firm. Page 199 1 investigators to trespass on Mr. Epstein's popcity 2 on March 17th of 2010? 3 MR. SCAROLA: Same objection and 4 instruction. 5 BY MR. CRITTON: 6 Q. Mr. Edwards, did you authorize 7 investigators to hide in the bushes at Mr. Epstein's 8 house in order to take photographs of either 9 Mr. Epstein or any associated objects on his 10 property? 11 MR. SCAROLA: Same objection and 12 instruction. 13 BY MR. CRITTON: 14 Q. Mr. Epstein -- Mr. Epstein. Mr. Edwards, 15 do you know a lady name Christina ICittaman? 16 A. Yes. 17 Q. Okay. And who - how do you know her? 18 A. She was a lawyer at Rothstein Rosenfeld( Adler 19 when I was a lawyer at Rothstein Rosenfeldt Adler. 20 Q. Did you have any dealings with her on any 21 of your cases? 22 A. None. 23 Q. What did you understand her area of 24 practice? 25 A. Never knew. •cumas•Zettsal‘amen elawawlin$SKIMIO,••••••• 13 (Pages 196 to 199) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins 2d3g4126,6712-4170-9032-0511tf76c2ea EFTA00611250 Page 200 Page 202 1 Q. Did you know an individual by the name of 1 instruction. 2 Patrick Roberts? 2 MR. CRITTON: Says he doesn't know them 3 A. Yes. 3 How can that be an instruction? 4 Q. Okay. And who is Mr. Roberts during; that 4 MR. SCAROLA: Well, because I am not going 5 is, what did iv1r. Roberts do for RRA? 5 ..) to tell you, we're not going to permit 6 A. He was an investigator. 6 Mr. Edwards to answer any questions about 7 Q. Did he ever perform investigation work on 7 either what he did or what he didn't do that 8 any of the Epstein files? 8 are part of the work product involved in his 9 MR. SCAROLA: Same objection, same 9 representation of the Plaintiffs with claims 10 instruction. 10 against Mr. Epstein whom Mr. Edwards is 11 BY MR. CRITTON: 11 representing. 12 Q. Did you ever authorize Mr. Roberts to 12 MR. CRITTON: Did you ever — 13 perform investigation on the Epstein files? 13 MR. SCAROLA: So, in light of that and 14 MR. SCAROLA: Same objection and 14 what i have attempted to make very clear with 15 instruction. 15 regard to the scope of our objections, if you 16 BY MR. CRITTON: 16 continue to ask questions which it is clear 17 Q. All right. I asked yo, earlier about 17 fall within the scope of my instructions to 18 Richard Fandrey, F-a-n-d-rl-y. I think you said 18 Mr. Edwards and my announced intention with 19 you don't know who that — you knew someone named 19 regard to the scope of those instructions, then 20 Rick; is that correct? 20 we will terminate this deposition so that i can 21 A. I know an investigator named Rick. 21 seek a protective order. 22 Q. Did Rick, did Rick perform any 22 My suggestion is that you move onto other 23 investigation on the Epstein, did you authorize Rick 23 areas that are outside the scope of that 24 to perform any investigation on the Epstein files? 24 instruction, if you have any other questions 25 MR. SCAROLA: Same objection and 25 outside the scope. Page 201. Page 203 1 instruction. 1 MR. CRiTTON: Oh, I have a lot of other 2 BY MR. CRITION: 2 questions. 3 Q. And 1 believe we talked a little bit 3 MR. SCAROLA: Okay. 4 about, we certainly talked about Mr. Jenne, did you 4 MR. CRITTON: Let me be clear with you 5 ever authorize or direct Mr. Jenne to perform any 5 with regard to any, for purposes of following, 6 investigation on the Epstein files? 6 asking any follow-up questions should the court 7 MR. SCAROLA: Same objection and 7 determine that I am entitled to this 8 instruction. 8 information, you would agree that should the 9 BY MR. CRITTON: 9 court determine I am entitled to ask the name 10 Q. Are you familiar with the company called 10 of these individuals and possibly other 11 Blue Line Research and Development? 11 questions is, is that by not asking questions l 12 A. No. 12 am in no way waiving my right to ask as many 13 Q. Are you, are you aware at the current time 13 questions as the court ultimately determines as 14 that there is an entity called Blue Line Research 14 appropriate, proper, and as the court allows, 15 and Development which is composed of Mr. Roberts, 15 correct? 16 Mr. Richard Fandrey, Mr. Michael Fisten and Ken 16 MR SCAROLA: I absolutely agree. 17 Jenne? 17 MR. CRITTON: All right 18 A. No. 18 BY MR. CRiTTON: 19 Q. If you're unaware of the existence of the 19 Q. Mr. Edwards, are you familiar with a 20 entity called Blue Line Research and Development, 20 person named Alfredo Rodriguez? 21 LLC, would it be a correct statement that you have 21 A. Yes. 22 22 Q. And how do you know Mr. Rodriguez? never authorized anyone from Blue Line Research and 23 Development, LLC, to conduct any investigation of 23 A. Who do I know him to be? How do I know him? 24 Jeffrey Epstein? 24 i met him the same — well, i met him after you did, 25 MR. SCAROLA: Same objection, same 25 after you and your investigators pre-depoed him on three 14 (Pages 200 to 203) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthla hopkine Electronically signed by cynthia hopkins Electronically signed by Cynthia hopkIns 2d39412d4M2-4170,9d82-05111176c2ea EFTA00611251 Page 204 Page 206 1 various occasions for a total of about 15 hours before 1 July 29th and August 7th? 2 we took this deposition. I met him for the first time 2 A. And if I did or if I didn't, either ■ that's 3 during that deposition. 3 going to be protected by the work-product privilege and 4 MR.. CRITTON: Let me move to stake as 4 Fin not going to give you that information because 5 nonresponsive. 5 you're not entitled to it. 6 BY MR CR1TTON: 6 Q. I disagree even in a simple 7 Q. My question to you is when did you first 7 attorney-client privilege you also, you identify the 8 meet Mr. Rodriguez? 8 date, you don't identify the subject, but you 9 MR. SCAROLA: And you have an answer to 9 identify the date, who may have been present 10 that question. 10 MR. SCAROLA: We understand your position 11 THE WITNESS: It's a very complete answer. 11 and it's not necessary to articulate it on the 12 l, the day of his deposition. 12 record. 13 BY MR. CRITTON: 13 MR. CRITTON: I just want to be clear. 14 Q. Had you ever spoken with Mr. Rodriguez 14 And your position is the same is you're not 15 before that time? 15 talking. 16 A. No. 16 MR. SCAROLA: Work-product. 17 Q. Okay. Had anyone on your behalf spoken 17 MR. CRITTON: Work-product, correct? 18 with Mr. Rodriguez? 18 MR. SCAROLA: That's correct. 19 A. No. 19 BY MR. CRITTON: 20 Q. Mr. Rodriguez's deposition occurred over a 20 Q. Mr. Rodriguez was requested to bring 21 twirday period; is that correct? Two separate days. 21 documents to his second deposition that he had 22 A. I believe that's right. 21 referenced that he might have. Do you recall that 23 Q. And you were present for both of those 23 from the first deposition, Mr. Edwards? 24 depositions; is that comet? 24 A. Id°. 25 A. Yes. 25 Q. And in fact when he came to the second Page 205 Page 207 1 Q. And the first one I believe at least in 1 deposition, he didn't bring any documents with him. 2 looking at the transcript the first one occurred on 2 did he? 3 January 29th of '09? 3 A. I don't remember. 4 A. I'm assuming. 4 Q. Well, do you lunenrber him producing any 5 Q. And the second, the follow-up was on 5 documents at the second, at his completion of his 6 August 7th, 2009, correct? 6 deposition? 7 A. When was the first, January you said? 7 A. I don't remember. 8 Q. Excuse me. Pm sorry. July 29th, 2009. 8 Q. Do you recall him saying that he might 9 A. Okay. 9 have some sort of book or some sort of list of names 10 Q. With the follow-up July, I'm sorry 10 and addresses and/or names, excuse me, of females 11 August 7th, 2009. 11 who may have come to Mr. Epstein's house along with 12 A. If you say so. I'm not quarreling with that. 12 phone numbers? 13 Q. And I will just represent that is what I 13 A. I don't remember if he said that or it says 14 read off the transcripts. Between those two dates, 14 that in the police report, but I remember that 15 that is July 29th and August 7th of '09, did you 15 inforniation at some point in time. 16 speak with Mr. Rodriguez at all? 16 Q. All right. And subsequent, at the 17 MR. SCAROLA: Same objection, same 17 conclusion — well, let me strike that. 18 instruction to the extent that any such 18 Do you recall receiving any documents from 19 conversation may have occurred in connection 19 Mr. Rodriguez that were produced at his deposition 20 with your representation of the Plaintiffs and 20 that had the names and addresses and/or phone 21 claims against Mr. Epstein. 21 numbers of any other females? 22 BY MR. CRITTON: 22 A I don't know. Do you? We were there together 23 Q. All I am asking right now, not the 23 I don't remember specifically. I think the answer is 24 substance but just so the record is clear I am just 24 no. 25 asking, did you speak with Mr. Rodriguez between 25 Q. And I think you're right. WI•aZ-{4.0.40. 15 (Pages 204 to 207) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins 2d39412d-67f2-4170.9d82.05111O6c2ca EFTA00611252 Page 208 Page 210 1 A. Okay. 2 ' Q. We agree on that. 3 A. Okay. 4 Q. Subsequent to the deposition; that is, 5 after Mr. Rodriguez's deposition, did Mr. Rodriguez 6 contact you? 7 MR. SCAROLA: Objection, instruct you not 8 to answer. 9 MR CRITTON: Well, this is — okay. This 10 is a third patty contacting Mr. Edwards. All 11 right. 12 MR. SCAROLA: It is not — 13 MR. CRITTON: It's just a yes or no I'm 14 looking for. 15 MR. SCAROLA: It is a witness in these 16 proceedings. 17 MR. CRITTON: So. 18 MR. SCAROLA: So, anything that 19 Mr. Edwards has done or may have done in 20 connection with his investigation and 21 prosecution of the claims against Mr. Rothstein 22 it is our position is not the appropriate 23 subject matter of inquiry in the context of 24 this lawsuit, and is an attempt to invade the 25 attorney-client and work-product privileges. I Page 209 1 am instructing him not to answer. 2 If the court, if the court determines that 3 the scope of the privilege permits a response 4 to these questions, we would be happy to s respond to them. 6 But we have an obligation to, to 7 Mr. Edward's clients to protect their rights to 8 a fair trial and their rights to 9 confidentiality, and for that reason we are 10 obliged to interpret those privileges in their 11 broadest sense unless and until the court 12 decides that a more restrictive interpretation 13 should be applied. 14 BY MR. CRITTON: 15 Q. BUNT - a the first and second deposition of 16 Mr. Rodriguez I think you, I think you indicated 17 that you did not speak with him; is that correct? 18 A. You're asking me if I indicated to you 19 previously during this deposition whether — 20 Q. Right. 21 A. — I spoke to him or not? I, I don't 22 remember. 23 Q. Did you speak with Mr. Rodriguez between 24 his first and second. 25 MR. SCAROLA: Same objection, same 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 23. 22 23 24 25 1 2 3 4 6 7 B 9 10 11 12 13 14 15 16 17 18 19 20 23. 22 23 24 25 instruction. BY MR. CRITTON: Q. Did Mr. Mr. Rodriguez ever make a request of you at any time for any type of monies for testimony, documents, or any other information associated with any existing or potential claimants directed to Mr. Epstein? MR. SCAROLA: Same objection and instruction. BY MR. CRITTON: Q. Subsequent, after Mr. Rodriguez or from the time that Mr. Rodriguez completed his deposition on August 7th of 2009, did you have an occasion to speak with either the FBI, well, with the FBI regarding Alfredo Rodriguez? MR SCAROLA: Same objection and instruction. BY MR. CRITTON: Q. Did you after Mr. Rodriguez's completion of his deposition on August 7th, 2009, did you have an occasion to speak with any representative, a professional attorney, professional slash attorney for the U.S. Attorney's Office? MR. SCAROLA: Same objection and instruction. Page 211 BY MR. CRITTON: Q. Mr. Edwards, are you familiar with the, the criminal complaint that was filed relating to Alfredo Rodriguez? MR CRITTON: Let me show you what I will mark as Exhibit i to the deposition. (Plaintiffs Exhibit No. I was marked for identification.) MR. SCAROLA: By that question, does that mean has he seen it before? MR. CRITTON: First, let me show you Exhibit I. Do you it's a criminal complaint, the United States of America versus Alfredo Rodriguez. MR. SCAROLA: Is your question has he seen it before? MR. CRITTON: Yes. MR. SCAROLA: I'm not sure what "are you familiar with it" means. BY MR CRITTON: Q. Have you seen this criminal complaint before today? A Yes. Q. When did you first see this document? A. I — I don't know. 16 (Pages 208 to 211) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins 2d39412d40,24170-90124511ftfleae EFTA00611253 Page 212 1. Q. Did you, did you see Exhibit I, the 2 criminal complaint, prior to the time that it was 3 filed in the United States District Court? 4 A. Did I see it prior to it being filed? 5 Q. Yes, sir. 6 A. No, no. 7 Q. Okay. Did you provide an affidavit to any 8 individual at the FBI or the U.S. Attorney's Office 9 in support of, although not attached to this, to 10 Exhibit I, the criminal complaint? 3.1 A. Repeat. 12 Q. Did you sign any affidavit or give, give 13 any sworn testimony associated with the criminal 14 complaint that was filed by the United States of 15 America versus Mr. Rodriguez? 16 A. Ifs obvious to me that you're trying to 17 circumvent the privileges that have been placed on the 18 record. I will answer that question that, no, I did 19 not, but i am not here to divulge anything that may 20 waive my attorney-client or work-product privilege or 21 otherwise jeopardize the claims that my three clients 22 are pursuing against Jeffrey Epstein for their being 23 sexually molested by him when they were underage minor 24 females. 25 Q. Mr. Edwards, are you the cooperating Page 214 3. during your years that you had worked as a State 2 Attorney? 3 A. No. 4 Q. Okay. Did you meet her only as a result 5 of Epstein related matters? 6 A. Yes, in its broadest sense I suppose. 7 Q. Did you did you have, before yineji 8 representing." did you know who 9 was? 10 A. I don't know. 13. Q. What, what was your first association or 12 what contact was, what was your first contact with 13 ever? 14 A. 'don't 15 Q. But if I understand correctly you only 16 know her through the context of the Jeffrey Epstein 17 matter, is that correct? 18 A. Her involvement with, yes. 19 Q. And that you only knew of her involvement 20 in the Jefficyalein matter after you began 21 representing OM? 22 A. I don't believe that to be accurate. 23 Q. What involvement could you possibla 24 involvement would you have had with Mrs. 25 before you became involved in representing someone 3 Page 213 1 witness who was tefcl2,R.d in the criminal 2 complaint, Exhibit I? 3 MR. SCAROLA: Could you explain to us for 4 the record, please, how that line of inquiry is 5 reasonably calculated to lead to admissible 6 evidence in this case? 7 MR. CRITTON: I am not prepared to do that 8 right now. 9 MR. SCAROLA: Then I am not prepared to 10 allow Mr. Edwards to answer that question 11 outside the presence of an Assistant United 12 States Attorney who can make a judgment as to 13 whether that is information that ought to be 14 disclosed. 15 BY MR. CRITTON: 16 I .,. Edwards, you knew or you first 17 through the complaint you filed on behalf 18 of Jane Doe 1 and Jane Doe 2 in July of 2008, 19 correct? 20 A. No. 21 Q. Had you spoken with her before that period 22 of time; that is, before the complaint was ever 23 filed? 24 A. Yes. 25 And I am now did‘ yoU !al?, Page 215 1 associated with the Epstein matter? 2 A. 'believe that i had read her name in the 3 newspaper related to some involvement with Jeffrey 4 Epstein's criminal investigation and/or cast I think 5 that's the first time 1 saw her name, I believe. 6 Q. Before, before you filed a lawsuit against 7 the United States of America, and i may have asked 8 you this earlier so 1 apologize, did you ever speak 9 with Mrs. a 10 A. I believe that any communications that I would 11 have had with respect to Mrs. would have only 12 been in the interest of pursuing claims on behalf of the 13 clients that I represented. And therefore i am going to 1.4 claim a work-product privilege as to those 15 communications. 16 Q. Okay. My, my question was is only did you 17 speak with her prior to filing that complaint? Just 18 a yes or a no, and I am looking, that question is 19 not asking for the substance. I am just asking for 20 ayes or no. 21 MR. SCAROLA: Same objection, same 22 instruction. 23 BY MR. CRITTON: 24 Q. During the course of the litigation with 25 the United States Attorney's Office, I assume you 17 (Pages 212 to 215) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins Electronically signed by cynthia bodkins 2d39412d-6712-4170-9082-0511f(76c2oa EFTA00611254 Page 216 1 had conversations with Mrs. from tint to 2 time? 3 A. Okay. 4 Q. Is that true? 5 A. Is your assumption true? 6 Q. Correct. A. I have spoken with Ms. B Q. And when you spoke with Ms. -- 9 let me strike that. Have the conversations 10 tha iik u have had with Mr. or have they only been in the context of 11 12 Jane Doe 1 and 2 versus United States of America, 13 only in the context of that case? 14 MR. SCAROLA: Same objection. 15 MR. CRITTON: And I will separate out to 16 the extent that you were at the June 12th, 17 2009, hearing in front of Judge Marra where she 18 was present. 19 MR. SCAROLA: Same objection, same 20 instruction. 21 BY MR. CRITTON: 22 Q. Has Ms.— have you Igtigajjave you had an 23 occasion to speak with Ms. with regard to 24 the criminal complaint, Exhibit No. 1, involving 25 Alfredo Rodriguez, Mr. Rodriguez? Page 217 1 MR. SCAROLA: Same objection, same 2 instruction. 3 BY MR. CRITTON: 4 Q. Mr. Edwards, have you ever been 5 interviewed by the FBI or the U.S. Attorney's office 6 with regard to any of your clients? 7 MR. SCAROLA: My of the three clients who 8 have claims against Mr. Epstein? 9 MR. CRITTON: Correct. 10 MR. SCAROLA: Sant objection, same 11 instructMn. 12 BY MR. CRITTON: 13 Q. Do you know .‘MIM sir? 14 A. Yes. 15 Q. And how do you know Agent from the 16 FBI? 17 A. I can answer if you want. 18 MR. SCAROLA: fine. 19 MR. CRITI'ON: 20 THE WITNESS: I don't know her last name 21 but I do know the first name is, the lust name 22 is obviously an unusual name, so I do ;mow who 23 that is. I met her outside of the courtroom 24 related to the Jane Doe 1 and 2 versus United 25 States of America case. PROSE Page 218 1 BY MR. CRITTON: 2 Q. Did you speak with Agent 3 dine? 4 A. Yes. 5 Q. Okay. And what did, what did, did she 6 initiate the conversation or did you? 7 A. The court initiated the conversation. 8 Q. Did the court say go outside and talk? 9 A. Right. 10 Q. The court being Judge Marra? 13. A. Correct 12 Q. And who else was present for that 13 conversation? 14 A. I don't mmember. 15 Q. Okay. What was the discussion about that 16 the court ordered? 17 A. The failure of the U.S. Attorney's Office to 18 meaningfully confer with the numerous victims of Jeffrey 19 Epstein's sexual abuse prior to negotiating a plea in 20 his criminal matter. 21 Q. How long did the conversation last? 22 A. Less than ten minutes. 23 Q. Was Agent a there as well? 24 A. There was a male agent there. I don't know 25 his name, but there was another FBI agent. at that Page 219 1 Q. Did Agent did she say 2 anything? Did she participate in the conversation? 3 A. No. 4 Q. Okay. Was it just Mrs. IIMI? 5 A. There was another U.S. Attorney there. 6 Q. A U.S.A.O. there? 7 A. Yes. 8 Q. Do you remember a he or a she? 9 A. He. 10 Q. ou remember his name? 11 12 Q. 13 A. I think that's hi la t i 14 Q. Did Mr. -- did is he the one 15 who conducted the conversation with you? 16 A. Yes. 17 Q. What was his response to your statement? 18 A. That this conversation is more complicated 19 than the time constraints that we have right now will 20 allow. We arc not going to come to a resolution at this 21 point on any issues that you or your clients believe are 22 pertinent to the case you filed. 23 Q. That was the end of the conversation? 24 A I mean, I am not quoting verbatim, but, yes 25 that was the 18 33 (Pages 216 to 219) COURT REPORTING AGENCY, INC. I Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins 2d39412d-6712-4170-9d82-0511ff76c2ea EFTA00611255 Page 220 1 Q. And did you go back in front of Judge 2 Main that same day? 3 A. I can't remember. 4 Q. Did he issue an order based upon that 5 hearing? 6 A. The, the record in the case will speak for 7 itself. I really, I don't remember right now. 8 ...had any other conversations with 9 other that? Well, I mean any 10 other face-to-face conversations with her other than 11 that one day back in July of, July or August of 12 2008? 13 A. No. 14 15 lave you seen , Agent since July, July or August of 2008 during 16 that short conference as physically seen her 17 someplace? 18 A. Unless she was at the hearing we all attended 1 9 on your motion to stay that day when there were a lot of 2 0 people in the courtroom, the answer is no. 21 Q. Okay. Have you seen ent , asstra nik! 22 the male agent's name was or 23 have you seen him since that yin July or AT,. 24 012008? 25 A. I do not believe I have. Page 221 1 e sir yet!) with either 2 m elating to any Epstein 3 related matter since July or August of 2008? 4 MR. SCAROLA: I am going to instruct you 5 not to answer on the basis of the privilege as 6 previously described. 7 BY MR. CRITTON: 8 Q. Mr. Edwards, have you spoken with any rep, 9 has any representative of the FBI attempted to speak 10 with you regarding your association with the RRA 11. firm? 12 A. No. 13 Q. Has any member of the U.S. Attorney's 14 Office discussed with you any aspect of your tenure 15 or employment at the RRA firm? 16 A. No. 3.7 Q. In any conversations that you, that you 18 had that you've had with the United States 19 Attorneys Office at any time, has anyone ever asked 20 you any questions about Scott Rothstein? 21 A. You're presupposing that I had conversations, 22 but I will answer the question whether !have or have 23 not had conversations. Nobody has asked me any 24 questions from the State Attorney's Office, U.S. 25 Attorney Office FBI? or other agency related to Scott Page 222 1 Rothstein. 2 Q. So, it would be a correct, and I am going 3 to expand it, would it be a correct statement that 4 no representative of the federal government and by 5 that I mean the Department of Justice, FBI, any 6 other law enforcement agency nor any state 7 governmental agency has ever asked you or quizzed 8 you or questioned you about your association with 9 Rothstein, Rosenfeldt, and Adler during the seven, 10 approximately seven months you were there; is that 11 correct? 12 A. That's correct. 13 Q. Mr. Edwards, has, has anyone from the 14 United States Attomey's Office discussed the 15 topic well, let me strike that Have you been 16 granted immunity with regard to any aspect of your 17 work associated with either the Epstein files or the 18 Rothstein prosecution? 19 A. I don't understand your question. 20 Q. Okay. You're aware that Mr. -- 21 A. I can answer, no. I haven't been granted 22 inununity to anything, so it doesn't matter what your 23 question is. 24 Q. Okay. Have you ever had any conversations 25 with any of the probation officers in Palm Beach Page 223 1 County regarding Mr. Epstein? 2 A. No. 3 Q. Have you directed that anyone have any 4 discussions with the probation officers in Palm 5 Beach County regarding Mr. Epstein? 6 A. That is clearly calling for work-product 7 privilege information. I'm not going to answer the 8 question. 9 Q. Have you had any discussion with any of 10 the other lawyers who represent clients in the 11 Epstein, in Epstein related matters regarding 12 Mr. Epstein's probation? 13 MR. SCAROLA: Same objection, same 14 instructions, and I would add to those 15 objections the objection based upon a joint 16 prosecution interest. 17 BY MR. CR1TTON: 18 Q. Mr. Edwards, among the Plaintiffs' 19 lawyers, is there any type of joint prosecution 20 agreement related to Mr. Epstein? 21 MR. SCAROLA: Same objection, same 22 instruction. 23 BY MR. CRITTON: 24 Q. Did you have — did you engage in weekly 25 or month meetings among the Plaintiffs' lawyer to 19 (Pages 220 to 223) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins I Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins ) 2dS9412d47124170-9632-0511ffridea EFTA00611256 Page 224 Page 226 1 share investigative material regarding, that you had 3. instnetion. 2 obtained regarding Mr. Epstein? 2 BY MR. CROTON: 3 MR. SCAROLA: Same objections and 3 Q. Mr. Edwards, do any of the 4 instructions. 4 investigators — let me strike that. Did any of the 5 BY MR. CRITTON: 5 investigators who worked for RRA refer any Epstein 6 Q. Did you provide any of the investigative 6 client to you? 7 materials that had been acquired by you to any other 7 A. What is an Epstein client? 8 person outside of the RRA firm and the Farmer, Jaffe 8 Q. I am sorry. Did any of the investigators 9 firm up through the current date? 9 who worked for RRA refer a perspective claimant 10 MR. SCAROLA: Would you read that question 10 against Mr. Epstein to you? 11 back? 11 A. No. 12 BY ta. CROTON: 12 Q. Did any of your, did any of the RRA 13 Q. Let me ask it. During the time that you 13 investigators ever meet with your three clients? 14 were with RRA, excuse me, and had investigation done 14 MR. SCAROLA: Same objection. Same 15 on Mr. Epstein, was any of your investigation that 15 instruction. 16 you had performed turned over to any person outside 16 MR. CROTON: Okay. And I'm looking for 17 of RRA or your clients? 17 is a yes/no. 18 MR. SCAROLA: Same objection, same 18 MR. SCAROLA: Correct. Same objection, 19 instruction to the extent that that would 19 same instruction. 20 encompass other attorneys with a shared 20 BY MR. CROTON: 21 interest in the prosecution of Mr. Epstein. 23. Q. Mr. Edwards, during the tine that you were 22 If any of those materials were turned over 22 with RRA, did you, your e-mail, was your only e-mail 23 to persons who did not have a direct interest 23 address bedward......... 24 24 A. I only had one e-mail address. to lawyers who did not have a direct interest 25 in the prosecution of the claims against 25 Q. All right. Did you ever receive any Page 225 Page 227 1 Mr. Epstein or to clients who did not have, to 1 information regarding your cases at your home 2 persons who did not have a direct interest in 2 e-mail? 3 the pursuit of their claims against 3 A. I don't tenadober. 4 Mr. Epstein, then you can answer to that 4 Q. Okay. What is your home e-mail address, 5 extent. 5 please. 6 THE WITNESS: Privileged. 6 THE WITNESS: Do I give this? 7 8 BY MR. CRITFON: Q. And i just want to be clear is, is there 7 8 MR. SCAROLA: . Sterols nods his head. THE WITNESS: 9 any written agreement and I know you, I want to make 9 BY MR. CROTON: 10 certain that the objection is there, is as we both 10 Q. Did you have a separate fax number at RRA 11 know there are a number of claims. There are a 11 when you were there; that is, just so a fax would 12 number of claims that are outstanding against 12 come directly to either yours or an area where you 13 Mr. Epstein brought by a number of different 13 were located? 14 lawyers. 14 A. No. 15 MR. SCAROLA: The objection extends to 15 Q. In any of the directions that you ever 16 both written agreements and oral agreements. 16 gave to the investigators, did you ever put that in 17 THE WITNESS: Yes. We both know that 17 the form of a memo; that is, would you give them 18 there are a lot of claims against Mr. Epstein 18 written directions? 19 for basically the sane conduct. 19 MR. SCAROLA: Same objection, same 20 BY MR. CRiTTON: 20 instruction. 21 Q. And my question to you is is, is there any 21 BY MR. CIUTTON: 22 written agreement between the Plaintiff lawyers who 22 Q. To your knowledge did any of the 23 have filed claims against Mr. Epstein regarding the 23 investigations that were done regarding Mr. Epstein, 24 sharing of information? 24 were they provided to any other person at RRA? 25 MR. SCAROLA: Same objection, same 25 A. Excuse me? 20 (Pages 224 to 227) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins (601-051.976.2934) 2d39412c1-67f2-4170-9d82.05111176c2oa EFTA00611257 Page 228 1 Q. You have testified that investigations 2 were done during the time, on Mr., relating to 3 Mr. Epstein during the time that you were at RRA 4 A. Right. 5 Q. My question to you is, did you -- first of 6 all did you receive written reports in addition to 7 oral reports? 8 A. From the investigators? 9 Q. Yes, sir. 10 THE WITNESS: Answcr? 11 MR. SCAROLA: Yeah. 12 THE WITNESS: The reports were — yes, I 13 did. 14 BY MR. CFUTTOIsk 15 Q. And were the reports provided by e-mail or 16 were they provided by, in the form of a memo that 17 would be sent from the investigator to you or both? 18 A. I,1 do not remember there being any in the 19 form of an e-mail. Does not mean that there was not. I 20 did communicate by e-mail with other members of the firm 21 and other members of the investigative team on all cases 22 as has been my practice all along practicing law. There 23 were memos, though, that were given to me that were not 24 e-mail form that were the standard nItI10.10 that I would 25 incorporate into a witness memo file. Page 230 1 and I'm using just as an example, is that he came in 2 or Scott Rothstein came in and looked at a 3 particular file of yours, whether it related to 4 Mr. Epstein or not, you don't know? 5 A. 1 can't answer that question accurately. 6 Q. Okay. Did you ever send investigative 7 reports to other lawyers regarding Mr. Epstein; that 8 is, if you got an investigative report from 9 Mr. Fisten or Mr. Jenne or whomever, would you send 10 those on to certain lawyers on a regular basis? 11 MR. SCAROLA: You can answer that 12 question. 13 THE WITNESS: No. 14 BY MR. CRITTON: 15 Q. What lawyers, other than yourself, were 16 involved in the Epstein cases during the time you 17 were associated with RRA? 18 A. What do you mean by "were involved? I guess 19 all. 20 Q. What, what lawyers actually worked on the 21 file? I know Mr. Berger worked on the Epstein 22 cases, correct? 23 A. In some limited capacity, correct. 24 Q. Okay. Mr. Adler I know attended 25 Mr. Epstein's deposition, correct? Page 229 1 Q. And again that would just be in your, 2 would that be in your electronic storage as well as 3 in the hard copies? 4 A. The version I saw was the electronic. 5 Q. So, that would be stored in the Fortis 6 program? 7 A. That's correct. B Q. All right. And again other individuals in 9 the firm, other lawyers in the firm might be able to 10 access that program, you just don't know? 11 A. Right. Well, the program, obviously that's 12 the program that the firm used. Now, whether they could 13 access, if you could go across cases that weren't cases 14 you worked on, I really just don't know. 15 Q. As an example could Mr. Fisten, on the, on 16 the Fortis, could he access your, your file on an 17 Epstein case? 18 A. I don't know. 19 Q. If someone accessed your file, accessed 20 your electronic file, would you necessarily know 21 that? 22 A. No. 23 Q. All right. So -- 24 A. I don't believe so. 25 Q. It wouldn't show up that Michael Fisten, Page 231 1 A. Correct. 2 Q. Did, did any other lawyers other than 3 Mr. Adler or Mr. Berger attend any depositions? 4 A. Your memory is going to be as good as mine 5 there. I'm thinking. Mark Epstein's deposition was 6 attend by Russell Adler. 7 Q. He went with you to New York? 8 A. No. He didn't go with me to New York. He 9 attended the deposition, and I also attended the 10 deposition. 11 Q. Both in person? 12 A. Right. 13 Q. Was he there for another file or did he 14 meet you there to specifically attend Mark Epstein's 15 deposition? 16 A. Coincidence that he was in New York during the 17 time when his deposition was being taken. 18 Q. Any other lawyer that you can recall being 19 at a deposition other than Adler, Berger and 20 yourself? 21 A. Not right now. If you remind me, I, 1 may 22 remember. I don't remember right now. 23 Q. Did other lawyers in the firm at RRA 24 perform services on the files; that is, and by that 25 I mean did they, were they involved in draft' 21 (Pages 228 to 231) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601451.9764934) Electronically signed by cynthia hopkins (601.051.976.2934) Electronically signed by cynthia hopkin► (601451.976.2934) 2d394126417f2-41704id82-0511078c2ea EFTA00611258 Page 232 1 motions, research, appeals, pleadings, papers that 2 were filed? 3 MR. SCAROLA: You can, you can answer 4 whether they were, there were other lawyers 5 involved in drafting tasks without identifying 6 what those may have been. 7 THE WITNESS: Other lawyers contributed to 8 some extent to the prosecution of those cases. 9 BY MR. CROTON: 10 Q. Who? Names. I'm not asking for tasks. 11 MR. SCAROLA: You can answer. 12 MR. CRITTON: I am asking for names. 13 THE WITNESS: Bill Hager, Judge Stone, 14 Russell Adler, Rob Buschel. 15 BY MR. C 16 Q. B-o-u-e-h 17 A. I dent know hug to spell it B-u, I don't 18 know how, B-u-s-c-h-klbelieve. 19 Q. All right. Is he currently with you now? 20 A. No. 21 Q. My other lawyers? 22 A. And you're asking for no matter how minimal, 23 just anything done by any lawyers? 24 Q. Correct. 25 A. Michael, I think his name is Michael. It was Page 233 1 another lawyer. That's, that's -- those are the ones 2 that I can remember right now. 3 Q. Wore them ever meetings that occurred, 4 well, not were there ever specific meetings that 5 were attended by various lawyers to discuss 6 Epstein's cases? 7 MR. SCAROLA: You can answer whether there 8 were meetings. 9 THE WITNESS: There were meetings to 10 discuss every case including Jeffrey Epstein's 11 Cases. 12 BY MR. CRITTON: 13 Q. And when you say there were meetings to 14 clictims every case, were there routine meetings that 15 were held to discuss your cases or cases in general? 16 A. It's how the firm worked. If you wanted to 17 discuss cases, or the case was a case that was thought 18 to need more than one or more than two attorneys, then a 19 meeting could easily be assembled within RRA to sit 20 around the table and discuss issues related to any case. 23. And yes, that happened with respect to cases filed 22 against Jeffrey Epstein. 23 Q. And so there could have been additional 24 lawyers in addition to Adler, Stone, Berger, and Rob 25 Buschel and yourself that would have commented on an Page 234 1 Epstein case? 2 A. When I was giving you that list of names, I 3 was picturing one of the couple meetings related to 4 Jeffrey Epstein's case. Could there have been other 5 lawyers in the room, yes, but J think that is the 6 exclusive list. 7 Q. Did Mr., did anyone ever attend by phone 8 meetings associated — 9 A. 'understand. 10 Q. — that involved Mr. Epstein? 11 A. !understand. No. 12 Q. Did Scott Rothstein ever attend any 13 meetings wherein strategy was discussed regarding 14 the Epstein cases? 15 A. No. 16 Q. The one meeting that you had in Mr., 17 Mr. Rothstein's office with Russell Adler and some 18 unknown person on the phone, were you given any 19 direction at that time that certain discovery should 20 be done or certain tactics should be used with 23. regard to prosecuting the Epstein cases? 22 MR. SCAROLA: Same objection, same 23 instructions. 24 BY MR. CRITTON: 25 Q. Did you ever receive any 'mail 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 235 correspondence from Scott Rothstein that detailed or that set forth discovery that would be, that should be undertaken with regard to the Epstein cases? MR. SCAROLA: You can answer that with a yes or no. THE WITNESS: No. BY MR. CRITTON: Q. Did you ever have, did you ever receive any correspondence directly, Mr., Mr. Rothstein to you, during the time that you were at RRA? A. Yes. Q. Did any of the correspondence ever involve Epstein or communication ever involve Epstein? MR. SCAROLA: You can answer that. THE WITNESS: To some extent, yes. BY MR. CRITTON: Q. Okay. And what did, what did, what information did Mr. Rothstein send you that involved Mr. Epstein? MR. SCAROLA: Same objection, same instruction. BY MR. CRTITON: Q. Is the information that you received or the communication you received from Mr. Rothstein regarding, that involved Mr. Epstein. was that by 22 (Pages 232 to 235) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins 2d39412d4M4170403241511Mkaa EFTA00611259 Page 236 Page 238 3. way of e-mail? 2 • A. Yes. 3 Q. Did you ever receive any memorandum from 4 hint that is, a typewritten memo that was then sent 5 to you through office mail that was not electronic 6 involving Mr. Epstein? 7 A. No. 8 Q. At the meetings that you, at the meetings 9 that occurred where these various lawyers, Berger, 10 Adler, Stone, Rob Buschel were present and Epstein 11 was discussed, was the discovery that, discovery 12 and/or investigation regarding Mr. Epstein was that 13 ever discussed? 14 MR. SCAROLA: Same objection, same 15 instruction. 16 BY MR. GLUTTON: 17 Q. Mr. Edwards, are you aware as a former 18 state prosecutor that there are laws against 19 conducting certain financial transactions in money 20 that's derived from a crime? 21 A. I don't understand your question. 22 Q. Okay. Well, you were a former state 23 prosecutor; is that correct? 24 A. Right. Yes. 25 Q. Right. Are you aware that there are Page 237 1 certain laws both state and federal that, that are, 2 that preclude conducting certain financial 3 transaction, transactions in money that is derived 4 from a crime? S A. Still don't understand your question. But 6 first before I try to answer your question, are you 7 taking me back to a time when I was a State Attorney and 8 asking back then did I know and then your question? 9 Q. Yes. 10 A. Back when I was a State Attorney did I know 11 that there are crimes related to money transactions? 12 Q. No. 13 MR. SCAROLA: Could I help you? Do you 14 want to ask him whether he was aware of the 15 existence of a state RICO statute? 16 MR. CRITTON: No. 17 MR. SCAROLA: Okay. 18 MR. CRITTON: I am okay with that first, 19 but I am still going to ask my question. 20 BY MR. CRITTON: 21 Q. I assume you're aware of the existence of 22 a state RICO statute, correct? 23 A. I don't know that I was aware of that back 24 then. I just can't remember whether I knew about RICO 25 back at the State Attorney's Office. I never prosecuted 1 RICO claims. 2 Q. But you certain have brought RICO claims 3 against Mr. Epstein? 4 A. I know about one now. 5 Q. Okay. At the time that you were at the 6 State Attorney's Office, what kind of — how long 7 were you there? 8 A. Three years. 9 Q. And what kind of crimes did you prosecute? 10 A. Beginning with Dill's through attempted murders 11 and everything in between. No — well, not no, very few 12 economic crimes, some insurance fraud cases but very 13 few, otherwise drugs, guns, robberies, burglaries 14 attempted murder, aggravated batteries, those types of 15 crimes, false imprisonment 16 Q. Well, were you ever, do you know what 17 money laundering means in a criminal context? 18 A. In some basic sense I do knew what money 19 laundering means. 20 Q. What do you understand that to be? 21 A. That you, that the criminal takes money and 22 through some illegal means attempts to make bad money 23 legitimate. 24 MR. cRrrroN: Let me show you what I will 25 mark as Exhibit 2 which is the complaint that Page 239 1 was filed against Mr. Rothstein, yourself, and 2 3 (Plaintiffs Exhibit No. 2 was marked for 4 identification.) 5 BY MR- CRITTON: 6 Q. You're familiar with this complaint, sir? 7 A. Unfortunately I have read this frivolous 8 complaint. 9 MR. CRITTON: Move to strike as 10 nonresponsive. You've seen -- all I want is a 11 yes or no. 12 Are you familiar with this document? 13 MR. SCAROLA: I am going to object to the 14 form of the question. It is vague and 15 ambiguous. I don't know what familiarity 16 means. He has seen it before. 17 BY MR. CRITTON: 18 Q. Mr. Edwards, you have seen and read the 19 entire complaint along with the attachments, 20 Exhibit 2? 21 A. I've read the complaint I have never read in 22 the entirety Exhibit 2. 23 Q. Are you familiar, do you know what an 24 information is? 25 A. Yes. 23 (Pages 236 to 239) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins ( - 76.2 Electronically signed by cynthia hopkins ( Electronically signed by cynthia hopkins (601-051-976-2934) 2d39412d437t2-4170-9a32-0511816c2ea EFTA00611260 Page 240 1 Q. And that's Exhibit I attached to the 2 complaint, correct? 3 A. Correct. 4 Q. And you're aware that, and this is the 5 information that was brought by the United States of 6 America, U.S.A. versus Scott Rothstein, correct? 7 A. Yes. 8 Q. And you're aware that within the — well 9 let me strike that. Are you aware that 10 Mr. Rothstein has pled guilty to, excuse me, the 11 information that was brought against him by the 12 U.S.A.? 13 A. I am aware that he pled guilty to something. 14 Q. With regard to the complaint brought by 15 the U.S.A., I am sony, the information brought by 16 U.S.A. against Mr. Rothstein, I assume you have read 17 the allegations associated with the racketeering 18 conspiracy, the pattern of racketeering activity, 19 correct? 20 A. !haven't. 21 Q. Okay. If you turn to Page 3, Paragraph 4, 22 were you aware, were you aware prior to coming in 23 here today that Mr. Rothstein was, that the charges 24 that were brought against him were for under, under 25 RICO but with regard to mail fraud, wire fraud, 1 2 3 4 5 6 7 B 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 241 1 laundering of monetary instruments, engaging in 1 2 monetary transactions, and conspiracy to launder 2 3 monetary instruments and engage in monetary 3 4 transactions? 4 5 A. I, I have read that in the newspapers. I have 5 6 been told that by numerous people. So, yes, I was aware 6 7 of that. 7 8 Q. And within the complaint at Paragraph 6 it 8 9 says the Defendant -- 9 10 A. The information or the complaint? 10 11 Q. Tin sony. Within the information, 13. 12 Exhibit I to the complaint, in Paragraph 6 where it 12 13 speaks in terms of the Defendant and his 13 14 co-conspirators, conspirators agreed, agreed to 14 15 engage in a pattern of racketeering activity through 15 16 its base of operation at the offices of RRA Do you 16 17 see that? 3.7 18 A. Yes. 18 19 Q. Okay. Do you know who the, do you know 19 20 any of the co-conspirators in addition who are 20 21 associated with Mr. Rothstein? 21 22 A. Assuming that they are former employees of 22 23 RRA, which I would presume several of them are, I am 23 24 sure that I probably know them. 24 25 Q. And you're aware that the government has 25 am100.1.0tat nis.001H/10.0 'moo. I el Smormw•-"WadlOW1•••••••••••.. Page 242 asserted that the firm was a racketeering enterprise, correct? A. Not necessarily — no. Q. Well, if you look in Paragraph 2, see where the firm is identified as the enterprise of the racketeering conspiracy? A. Law firm. Paragraph 2 of the information says Rothstein Rosenfeldt Adler, P.A., was a law firm with and elsewhere. The law firm employed approximately 70 attorneys and engaged in the practice of law involving a wide range of specialties including labor and employment law. Q. Are you in Paragraph 2? A. Of the information, yes. Q. Pm sorry. I am looking at my apologies. On Paragraph 2 under Count 1, my error. A. Okay. Q. See where the law firm is identified as the racketeering enterprise? A. I'm sorry. Your question is am I, do I recognize that the law firm is categorized as an enterprise. Yes, in that paragraph I see that. Q. Have you had an occasion to discuss with any, with either Mr. Adler or Mr. Rosenfeldt any of Page 243 the allegations directed to Mr. Rothstein — A No. Q. — in the criminal complaint? A. No. Q. Since the implosion at the firm have you had an oerasion to talk about or speak or discuss any firm business regarding Mr. Rothstein and the ponzi scheme that he was running at RRA? A. Have I had an occasion where I could have talked — Q. No, Pm sorry. Have you had an occasion to discuss with Mr. Adler since you left the firm or since the implosion any aspects of the, of the ponzi scheme that Mr. Rothstein and his co-conspirators were running through the firm? MR. SCAROLA: Are you asking whether he ' did have such a discussion or whether he had an occasion to have such a discussion? BY MR. CRII1ON: Q. Did you have such a discussion? A. No. Q. Okay. Have you discussed that or have you seen Mr. Adler at all other than hi, hello, since — A Yes. So, the occasion existed. We just have that discuss ra„ 24 (Pages 240 to 243) PROSE COURT REPORTING AGENCY, INC. Electronically signod by cynthla hopkins Electronically signed by Cynthia hopkins Electronically signed by cynthia hopkins 2d3941246712417046324511fMkgea EFTA00611261 Page 244 1 Q. Have you, and if I understand correctly 2 you haven't discussed any firm business with 3 Mr. Adler since the implosion; is that correct? 4 A. Firm business? 5 Q. Any firm RRA business? 6 A. Right, no. 7 Q. How about with Mr. Rosenfeldt, have you 8 had any discussions with him — 9 A. None. 10 Q. — since the implosion of the finn in late 11 October of '09? 12 A. No. 13 Q. If you wanted, if you had any, other than 14 your existing partners have you had an occasion to 15 speak with any other partners or former partners of 16 the firm regarding the implosion well, let me 17 strike that — regarding the ponzi scheme that was 18 being run by Mr. Rothstein through the firm? 19 A. I have spoken to my current partners about it. 20 Q. Are your current pinions, are you aware 21 of any of your current partners being a target of an 22 investigation as a potential co-conspirator with 23 Mr. Rothstein? 24 A. No, way. 25 Q. You're not aware of or no one has told you Page 246 1 THE VIDEOGRAPHER: We are now off video 2 record -- 3 MR. SCAROLA: That will be a refreshing 4 change. 5 THB VIDEOGRAPHER: We are now off video 6 retold at 3:44 p.m. 7 (A brief recess was held.). 8 MR. CRYTTON: Mr. Edwards -- 9 THE VIDEOGRAPHER: Were back on video 10 record. It is 3:59 p.m. 11 BY MR. CRITTON: 12 Q. Mr. Edwards, when you joined RRA, if I 13 understood your earlier testimony, with regard to 14 the Epstein cases and your other cases when you came 15 there as far as you were concerned is you had the 16 ability to spend whatever money was necessary to 17 prosecute the Epstein cases, fair statement? 18 A. I don't know that that's wile or ifs not true 19 I mean. 20 Q. Well — 21 A. My judgment was never questioned. 22 Q. Correct. And therefore whatever monies 23 you spent either in investigation, in doing 24 discovery, that was your decision and your decision 25 alone, true? I I Page 245 1 that, correct? 2 A. I am not aware of that and nobody has told me 3 that. 4 Q. Mr. Rothstein founded what was, what 5 ultimately became RRA in approximately 2002. Were 6 you aware of that fact? 7 A. No. B Q. How long did you think Mr. Rothstein had 9 been -- well, let me strike that. How long did you 10 think RRA had been in existence prior to your 11 joining the firm? What were you told? 12 A. I don't know what I was ever told. I think 13 that I learned that information when the implosion, as 14 you call it, occurred. 15 Q. And were you, in terms of what the 16 revenues of the firm were, were you ever advised 17 what the revenues of the firm were? 18 A. No. 19 Q. Okay. Were you, were you familiar with 20 what the expenses were associated with operating the 21 RRA firm? 22 A. No. 23 Q. Were you in anyway -- well, let me strike 24 that With regard to — let me take a five minute 25 break and let me collect any thoughts. Page 247 1 A. Whatever money that I spent was my decision -- 2 Q. No. Whatever money you spent on 3 investigators, on doing depositions, on requesting 4 transcripts, on doing what was necessary to 5 prosecute the Epstein cases, that was >our decision? 6 A. No. The actions were my decisions in terms of 7 how to prosecute the case. The amount of money to spend 8 per exercise was not my decision nor was I privy to that 9 information. 10 Q. Well, but, you were the one who directed 11 that the particular task be taken, correct? 12 MR. SCAROLA: This is, this is 13 repetitious. 14 MR. CRIITON: tarn setting a stage. 15 MR. SCAROLA: This is repetitious of areas 16 of examination that were covered thoroughly in 17 the earlier portions of this deposition. 18 THE WITNESS: If I wanted a witness 19 interviewed, l could ask an investigator to 20 interview. The investigator, how they were 21 paid, how much they were paid, whether they 22 were paid is not something that I had any 23 knowledge of at all. 24 BY MR. CRITION: 25 Q. y. When you ran mur own firm tu MOIN 25 (Pages 244 to 247) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins 2d39412c1-6712-41704082-051 lif76c2ea EFTA00611262 Page 248 1 obviously knew what, whether hiring an investigator 2 or what a particular cost was because you had to pay 3 it, correct? 4 A. Yes. 5 Q. Okay. And I think as you described 6 earlier is that there had been very little discovery 7 up until the time you started working for RRA in 8 your three cases, true? 9 A. Not very little discovery. Obviously we had 10 gone through interrogatories, responses, request for 11 production, responses or lack of responses, however, the 12 majority of the depositions that were taken, the cases 13 just happened to be right last summer for most of those 14 depositions to take place, and that's what happened. 15 Q. Not only depositions but as well the 16 investigation as you have described, your 17 investigator that you hired as an outside person 18 didn't really start until late March or early April 19 in conjunction with the other investigation that you 20 did during the time you were with RRA, correct? 21 A. Fair statement. 22 Q. All right. And when you were at RRA you 23 described earlier, and I won't belabor it, but you 24 described the compound I think is the word that you 25 used that Mr. Rothstein kept himself in when he was Page 250 3. Q. Okay. Were they all on the, were they, 2 were they -- 3 A. Some were B.S.O as well. Some were Broward 4 Sheriffs Office. Some were from Fort Lauderdale. It 5 was both. 6 Q. With, with regard to the police °Thetis 7 and the Sheriffs Deputy's that were present, where 8 they on every floor of RRA? 9 A. It seemed that way. 10 Q. And had you ever been in a, in a law firm 11 either as a visitor or as an employee or partner 12 where you had seen armed guards from either a 13 Sheriffs Office or a police department roaming the 14 halls? 15 A. No. 16 Q. Had you ever been to the KRA offices 17 before you accepted the job? 18 A. No. 19 Q. When you got there and you saw the anted 20 guards patrolling the floors, did you ever have a 21 convetsation with Russell Adler or anyone else as 22 like what in heaven's name is going on here? 23 A. I didn't see them when I first got there. 24 Q. How much time passed before you saw the 25 guards? Page 249 1 at the firm, correct? 2 A. Correct. 3 Q. Right. And he was not accessible to 4 everyone else, true? A. Right. 6 Q. And was he on your floor or was he on a 7 completely separate floor? 8 MR. SCAROLA: M opposed to a partly 9 separate floor. 10 THE WITNESS: For the most part he was on 11 a separate floor. 12 BY MR. CRITTON: 13 Q. Okay. And were there guards during the 14 time that you were at, at the RRA firm, RRA, were 15 there ever guards that patrolled the hallways? 16 k Yes. 17 Q. And was that from the day you started? 18 A. I believe so. 19 Q. And had you ever been in a firm where — 20 bless you. Had you ever been in a firm where 21 there -- well, let me strike that. The guards were 22 what, Broward County Sheriff's Officers? 23 A. I don't remember the agency but they were 24 armed uniformed police officers. I believe Fort 25 Lauderdale. Page 251 1 A. When I first started I believe that the people 2 patrolling, I'm not sure that they initially were 3 Broward Sheriffs or Fort Lauderdale police. I think 4 that may have been a month after I began. From what I 5 remember seeing, and I can envision the people in my 6 head, they were private security people. At least that 7 was the appearance or the interpretation that I had. 8 And I didn't question it at the time who they were. 9 Q. Within — 10 A. I don't think. 13. Q. Within a short period of time though you 12 recognized that they were either Sheriffs Deputies 13 or police officers? 14 A. At the point in time where I recognized that 15 they were armed uniformed police officers in the finn, 16 yes, I questioned it not only to Russell Adler but to 17 anybody else, anybody else, because all of the lawyers 18 in the finn thought it was strange. 19 Q. Okay. And what did Adler tell you? 20 A. That Scott Rothstein has a lot of money, prior 21 to you being here, a female attorney was murdered and he 22 wants to make sure that his friends and family are as 23 secured as possible, that while he has this extra money 24 to spend on security, he is going to do that for all of 25 our safety. 26 (Pages 248 to 251) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthla hopkins 2d39412d-8712.417043d82-0511876c2ea EFTA00611263 Page 252 1 Q. Did you understand as well that he had, 2 that the firm was paying for armed guards to guard 3 his house 24 hours a day? 4 A. No. 5 Q. When did you team that fact? 6 A. After the disbandment of RRA 7 Q. Did Mr. Adler tell you that Mr. Rothstein had amazing or substantial wealth? 9 A. I don't }mow in those words, but I, I 10 definitely understood that. 11 Q. Okay. In meeting Mr. Rothstein initially, 12 initially for the ten minutes as you were 13 contemplating taking a job and on the two other 14 occasions or the one other occasion when you saw him 15 out in the restaurant, I think you described him as 16 flamboyant? 17 A. I'm not sure I used that word but probably one 18 synonymous, and, yes, I would describe him as such. 19 Q. Was he someone that at least -- well, let 20 me strike that Were you aware that he had a, a 21 watch collection of hundreds of watches? 22 A. No. 23 Q. Did you see him wear expensive jewelry 24 when you saw him; that is, the few occasions that 25 you saw him? Page 254 1 A. I went there one time. 2 Q. For what occasion? 3 A. I don't remember the occasion, but it was a 4 gathering that he had at his house and he asked, during 5 the course of me working there were ten occasions where 6 everybody was invited to go to his house for various 7 events and on one occasion, I went. 8 Q. Oh, all right. And from being in his 9 house did you recognize immediately that this was a 10 multi-million dollar house? 11 A. Yes. 12 Q. Okay. Was it on the water? 13 A. Yes. 14 Q. And could you tell from the interior 15 design or the decorations that existed that this was 16 at least a man, a man that had significant wealth? 17 A. Yes. 18 Q. All right. And could you, did you have an 19 opportunity to see his collection of automobiles? 20 A. No. 21 Q. During the time that you were in the 22 house, did you have an opportunity, did, did you 23 walk around the house? 24 A. No. 25 Q. How many people were there, best estimate? Page 253 1 A. Never. I didn't take notice of that. 2 Q. Okay. When you saw him, was he dressed in 3 a suit or was he dressed in business, or in casual, 4 more casual clothes? 5 A. Always a suit. 6 Q. And looking like a million bucks? 7 A. Looking ridiculous. 8 Q. But something that looked very expense, 9 flashy, showy? 10 A. I couldn't tell how expensive it was, but 11 flashy and showy, yes. It may be a pink shirt with a 12 purple tie and a blue suit, something that you would 13 never expect a lawyer to be wearing, yes. 14 Q. And in terms of the, in terns of the, of 15 his personal wealth or his, his personal assets, 16 were you aware of where be lived? 17 A Was I aware when? 18 Q. During the time you worked for RRA 19 A. Yes. 20 Q. Okay. And were you aware that he was 21 living in a multi-million dollar house? 22 A When, when I went to the house!, 'recognized 23 it as such. 24 Q. You said you want to the house. Did you 25 fm to Mr. Rothstein's house? Page 255 1 Are we talking like ten or 12? 2 A. No, no, no. 250. 3 Q. Did you talk to Mr. Rothstein at all? 4 A. Not even fora second. 5 Q. Could you walk anyplace in the house that 6 you wanted? 7 A. The party, at least to the extent that I 8 participated in it, was outside. So I, I don't know if 9 I could have walked around the house, but I did not walk 10 around the house nor did I really walk inside the house 11 other than to go in the front door, straight out back, 12 and then leave the exact same pathway that I entered. 13 Q. What his property located on Castillo 14 Island? 15 A. I don't know. 16 Q. Were you aware or did you become aware 17 that Mr., during the time that you were there that 18 Mr. Rothstein had investments in multiple real 19 properties? 20 A. No. 21 Q. Were you aware at the time that you met 22 him first at the BOVA restaurant that he had an 23 interest in BOVA restaurant? 24 A. When I met him, no. 25 Q. Did he have an interest in BOVA restaurant 27 (Pages 252 to 255 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hooking Electronically signed by cynthia hopkins 2W9412&67f24170-9d82-0511076c2ea EFTA00611264 Page 256 Page 258 1 at that time? 2 A. I heard that sometime after I began working 3 there. He certainly acted like he did. 4 Q. Did you learn that he had investments in 5 other business entities, whether they were other 6 restaurants or other business entities -- 7 A. Through -- 8 Q. during the time that you worked at RRA? 9 A. Through minors. 10 Q. And rumor was he had his fingers in many 11 different businesses? 12 A. It sounded like hundreds. 13 Q. And did you understand that he had a 14 substantial collection of automobiles? 15 A. What do you mean by substantial selection or 16 collection? 17 Q. Well, were you, during the time that you 18 were at RRA were you aware that he had Ferraris? 19 A. No. 20 Q. Multiple Ferraris? 21 A. No. 22 Q. Were you aware that he had a Bentley? 23 A. Yes. 24 Q. Were you aware that he had a Bugatti? 2 5 A. I heard that. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. No. Q. skis? A. No. Ray? A. No. Q. Were you aware that he owned a Lamborghini? A. No. Q. Again during the time that you were at RRA? A. I understand that. The answer is no. Q. In addition to the, to the business of owning BOVA what other business ventures did you understand he had? I think you said you thought he was in hundreds of businesses. A. Through a nunor. Q. Right. A. I understood that he owned a Vodka. I understood generically that he owned or purchased various patents. I understood -- I didn't know what the patents were. I understood that he owned other restaurants. I understood that he owned or was partial owner of Cafe Iguana. Were you aware that he had multiple jet Were you aware that he had a 55-foot Sea Page 257 1 Q. Were you aware that he had a Rolls Royce? 2 A. No. 3 Q. Were you aware that he had multiple 4 Corvettes? 5 A. No. 6 Q. Either a Corvette or multiple Corvettes? 7 A. No. 8 Q. Were you aware that he had multiple 9 Mercedes Benz? 10 A. No. 13. Q. Were you aware that he owned a yacht? 12 A. Yes. 13 Q. Okay. And was that parked behind his 14 house? 15 A. Yes. 16 Q. Were you aware that he also — and did it, 17 if I was to say it was approximately an 85 to 18 90-foot yacht or, in fact, an 87-foot yacht? 19 A. I wouldn't quarrel with that. 20 Q. Did it also appear that he had a 21 substantial sport fisherman that was parked out 22 there as well? 23 A. I didn't see that. 24 Q. Were you aware that he had 33-foot Aqua, 25 A uaviva? 1 2 3 4 5 6 7 B 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 259 At some point in time I learned that he was owner or partial owner of the Versace mansion. And I think in general it was always explained to me or I overheard he had, he has his hands in all of these, this assortment of businesses and those business ventures have done very well, and that is the source of his apparent extreme amount of wealth. Q. Who told you that? A. I don't, I don't know. More, more than one person. I mean, that was just kind of the word around the campfire so to speak. Q. Did you inquire as to -- let me strike that. Did you ever see any documents that reflected or documents or read any information about Mr. Rothstein that preexisted 2002 which was kind of the start of the RRA firm? A. I don't understand. Q. Okay. Well, I think we established earlier that your understanding was that RRA kind of started as a film in the 2002 time frame. A. Well, you told me that and I have been told that after the implosion that that was the time period that RRA started. I didn't know anything about Scott Rothstein until the year 2009 at all. Did • do an research with re • d to 28 (Pages 256 to 259) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins 2d39412d-6712.4170-9d132-0511tflEic2oa EFTA00611265 Page 260 1 Mr. Rothstein prior to going to the firm and by 2 researchltnean people Google. Did you Google him? 3 A. No. 4 Q. Did you, did the fine have a brochure? 5 A. I don't know. 6 Q. Did you ever see brochures in the waiting 7 room or the reception rooms that described the finn 8 when it was founded, background of the firm, et 9 cetera? 10 A. No. 11 Q. Was it on your web site? 12 A. Was what on my web site? 13 Q. The history or the background of the firm. 14 Let me strike that. RRA had a website? 15 A. RRA had a website. 16 Q. That's no longer in existence, true? 17 A. True. 18 Q. And — 19 A. To my knowledge. 20 Q. Did you ever go on the website and 21 checkout the web site for the history or the 22 background of RRA and Mr. Rothstein? 23 A. I went on the website. I don't know that the 24 website even had a history. If it did, I don't remember 25 ever looking at it. 1 2 3 4 5 6 speaking inquiry- 7 a Page 262 matters with regard — MR. CRITTON: Form? MR. SCAROLA: — to these cases? MR. CRITION: Form? MR. SCAROLA: No, no. It's a, it's a 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 BY MR. CRITTON: Q. Mr. Edwards, did you ever have any dealings with Deborah Villegas? A. No. Q. Am I saying it right? A I don't know. Q. V441-e-g-a-s? A. I've seen the name. Q. Did you know who she was? A. In what way? Q. As it related A. I knew that she worked for the firm. Q. What did you understand her position was? A Rothstein's Q. Did you unoersi no ter robe the COO of the company, of the firm? A. Right. I don't know if COO or whatever, but his right-hand man; that's the person who gets him what he wants. That's at least in a broad term what I Page 261 1 Q. Did it, did, at least from what you saw 2 and observed of Mr. Rothstein, did it appear to you 3 that the, his wealth far exceeded the type of 4 business that it appeared to you that the firm was 5 doing? 6 A. I have no understanding whatsoever. No, 7 that's not something that ever crossed nw mind. 8 Q. Well, under these circumstances is, is 9 when you went to the firm, you had the ability to 10 your discretion to spend whatever monies you wanted 11 in prosecuting your personal injury and Epstein 12 cases. You, no one ever turned down a request 13 either fora reimbursement or told you not to expend 14 any money, true? 15 MR. SCAROLA: Objection, compound and 16 repetitious. 17 THE WITNESS: I don't understand the 18 question. 19 BY MR. CRITTON: 20 Q. No one, as to any expenditure that you 21 ever made on an Epstein case - 22 MR. SCAROLA: Isn't this about the fourth 23 time that you're eliciting exactly the same 24 testimony? isn't it very clear the extent to 25 which Mr. Edwards had control over financial Page 263 1 understood her position to be. 2 Q. Did you understand she was a financial 3 person? 4 A. it. 5 Q. Or an administrative person? 6 A. My understanding was administrative. 7 Q. With regard to Mr. Rothstein's; that is, 8 his real property, his vehicles, his boats, his 9 business interests, would it be a coned statement, 10 sir, that you weren't concerned about the source of 11 his wealth? 12 A. You went through a list of the things that i 13 knew or did not ;mow him to have in tennis of assets. 14 And i told you for the most part I didn't even know that 15 he had those things. In fact, while you were out of the 16 room, I just educated myself by reading the information 17 on some of the things he had and I didn't know until 18 right now that he had those things. But certainly while 19 I was working at RRA I didn't know that he had those 20 things. 21 Q. Then let me be specific. With regard to 22 the, with regard to the house that you ;mew he had, 23 with regard to the yacht that you knew he had, with 24 regard to the vehicles that you knew he had, with 25 re X d to the business interests, at least BOVA and 29 (Pages 260 to 263) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthla hopkins ( Electronically signed by cynthia hopkins Electronically signed by cynthla hopkins 20.412c187a41704d1124$11,178o2se EFTA00611266 Page 264 1 at least what was rumored to be his business 2 interest, did you believe that the source of his, of 3 his apparent wealth was as a result of the law firm? 4 A. I believe that the source of his wealth was 5 the law finn as well as the, what I have described as an 6 assortment of businesses that he had his hands in of 7 which only a fraction I was aware. 8 Q. Well, what did you understand to be the 9 source of the finding of the, of the Epstein cases 10 and the other lawsuits that you had? 11 A. The checks i believe were written by the law 12 firm. 13 Q. Okay. And what did you believe was the 14 source of the monies that the law firm got to expend 15 some, just on the three cases that you had with Mr. 16 Epstein, some three to $500,000, I mean separate and 17 apart from all of the, your other personal injury 18 cases and separate and apart from all of the other 19 69 lawyers who were in the law firm who also had 20 cases? 21 A. ;didn't have a belief at all as to the source 22 of any of the monies that were used for any of the case. 23 Q. Was it your position it really wasn't your 24 concern; that is, wherever the money cant from, it 25 didn't bother you; all you knew is that the Linn was 1 2 3 4 5 6 $ 7 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 266 things of that nature. Q. And that's my question to you: Did you hear these names before or during the time that you were at RRA as distinct from now? A Of that list you just read until right this second, Michael Szafranski is the only one that I have ever heard of and that was after implosion of RRA Q. And again this question is specific to the time frame — A. Sure. Q. — that you were there? Dominic Ponatchio, A. No. Q. Moto, M-o-t-o, Ban, B-a-n, Adon, A-d-o-n? A. No. Q. Ever heard of Benozon (phonetic) Varon, V-a-r-o-n? A. No. Q. Onyx Capital? A No. Q. Onyx Options Consultants? A. No. Q. BWS Investments? A. No. Q. Puulin, P-i-r-u44-n, Group? Page 265 1 funding your cases? 2 MR.. SCAROLA: Objection, argumentative. 3 THE WITNESS: Yeah. At the time I believe 4 that I am working at a well recognized law firm 5 with good people and that is a successful law 6 firm and this is the way that law limn at that 7 level operate, and right, I didn't — 8 BY MR. CRITTON: 9 Q. Didn't care? 10 A. Right, I didn't care. I didn't question it. 11 Q. With, with regard to, let me ask you some 12 mums and see if you recognize the names. Do you 13 lavw a person by the name of Barry Bekkadan, 14 15 A. Never heard the name until right now. 16 Q. Al Discala? 17 A. Again same answer. 18 Q. Clockwork Capital Advisers? 19 A. No, never heard of them. 20 Q. Razorback Funding? 23. A. Nerve heard of it 22 Q. Michael Szafranski, S-z-a-f-r-a-n-s-k-i? 23 A. Heard that name - 24 Q. And — 25 A. — only after implosion and thryili papers and Page 267 1 A. No. 2 Q. Shimone (phonetic) Levy, L-e-v-y? 3 A. No. 4 Q. Obidia Levy, Pm sorry, d-i-a? 5 A. No. 6 Q. Daniel Minkowitz, 7 A. No. 8 Q. Fortress, an entity know as Fortress 9 Investments or Fortress Capital? 10 A. No. li Q. Drawbridge? 12 A. No. 13 Q. Capital or finding? 14 A. No. 15 Q. Do you know an individual by the name of, 16 have you ever heard of, heard during that time 17 period, did you hear of or know a person named 18 George Levin, 19 A. No. 20 Q. Banyan Investment Fund? 21 A. No. 22 Q. Dickyoulmow or hear of the name Frank 23 Prove, P-r-1-v-I? 24 A. No. 25 0. Okay. Mr. Prevc is rtedl , was 30 (Pages 264 to 267) PROSE COURT REPORTING AGENCY, INC. Electronically signed by synth's hopkins Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by synth's hopkins (601.051-976.2934) 2d39412d-67t2.4170.9d82-0511M6c2ea EFTA00611267 Page 268 Page 270 1 purported to have an office within RRA's offices. 1 A. No. 2 'Have you seen that? 2 Q. Ed Morse? 3 A. Have I seen what? 3 A. No. 4 Q. Have you seen that in any of the news 4 Q. Richard Pearson, P-I-a-r-s-o-n? S media, that Mr. Preve had an office within RRA? 5 A. No. 6 A. That name doesn't sound familiar at all. So, 6 Q. Steven Levin, Ilv-i-n? 7 no, the answer to your question is no, I haven't seen 7 A. No. 8 that 8 Q. Ira Sochet? S-h or Sochet, S-o-c-hl-t? 9 Q. Bill Brock? 9 A. No. 10 A. Yes. 10 Q. Mark Melvin? 11 Q Okay. Who is Mr. Brock? 11 A. No. 12 A. In the law firm he went by the name Uncle 12 Q. !lack Samoney (phonetic)? 3.3 Bill. 13 A. No. 14 Q. Okay. All right. Who is Uncle Bill? 14 Q. Lawrence King? 15 A. Who do I tmderstand him to be? I don't know 15 A. No. 16 who he really was. At this point in time looking back, 16 Q. Steve Jackel? 17 there is no telling what anyone, what anyone or anything 17 A. No. 18 was. But at the time I believe that he was a relative 18 Q. Have you ever heard an attorney name 19 of Scott Rothstein's. 19 Michael Legamaro? 20 Q. What did he do? What did, what did Uncle 20 A. No. 21 Bill do — 21 Q. Kevin Draher, D-r-a-h-[r? 22 A. Some- 22 it No. 23 Q. - at the firm? 23 Q. David Boden, do you know David Boden? 24 A. Something with money. 24 A. Yes. 25 Q. Did behave an office at the firm? 25 Q. Okay. Who is Mr. Boden, an associate -- Page 269 Page 271 1 A. i think the trustees are still trying to 1 A. Are you asking me what I know now or what I 2 figure out what he exactly did do. 2 thought then? 3 Q. Did you have any dealings with him? 3 Q. Who did you understand Mr. Boden, David 4 A. Dealings, no, I didn't have dealings. 4 Boden to be when you became employed or associated 5 Q. Dealings of any kind? 5 with RRA in April of '09? 6 A. I talked to him 6 A. In Aptil of '09 i had not heard the name but 7 Q. Did you ever discuss any of your cases? 7 let's just skip to it. Sometime in let's say June or 8 Was he — he wasn't a lawyer? 8 July, I am guessing, sometime during the summer, I 9 A. Far from it. 9 understood him to be a lawyer at the firm. 10 Q. All right. Did you ever discuss any of 10 Q. Did you understand, did you understand he 11 your cases with him? 13. was a Florida lawyer or you just understood he was a :2 A. No. 12 lawyer? 13 Q. Just a hi, hello? 13 A. I understood he was a lawyer. I made the 14 A. Hi, hello, and 1 was one of the lawyers who 14 presumption or assumption at that time that since he was 15 would come in often and wodc on weekends and he would be 15 a lawyer for ARA that he was a Florida lawyer. i have 16 there. That's when i would see him, and he would kind 16 subsequently learned otherwise. 17 of, hey, how are you doing on a weekend. 17 Q. Did you know, did you ever have any 18 Qi And do you know a Dean ICretchmar, 18 business dealings with Mr. Boden? 19 K-44-c-h-m-a-r? 19 A. Never spoke a word to the guy. 20 A. No. 20 Q. What did you understand that he actually 21 Q. Same question again. do, these names 21 did at the firm? 22 dining the time period, Doug Van Allman, 22 A. Had no idea 23 A-I.1-m-a-n? 23 Q. How about Andrew Barnett? 24 A. No. 24 A. Don't know who that is. 25 Q. Ted Morse? 25 Q. There was an individual, he is described 31 (Pages 268 to 271) PROSE COURT REPORTING AGENCY, Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins 2d39412d.47f2-4170-9d82-0511,176c2ea EFTA00611268 Page 272 Page 274 1 as the director of Corporate Development for RRA 1 Fistos is my partner now. Marc Nurik is the lawyer who 2 . A. I don't know even know what that means. 2 represents Scott Rothstein now. I don't know which it 3 Q. Have you ever heard of the Centurion 3 was, but it was one of the two. 4 Credit Fund or the Platinum Management Fund? 4 Q. Okay. Were you ever present at a meeting 5 A. No. 5 where someone who you didn't know was present when 6 Q. Alan Sakowitz? 6 the Epstein case was discussed? 7 A. No. Wait. Alan Sakowitz. I have heard that 7 A. No. 8 name recently. I don't know why. I believe I actually 8 Q. Were you ever asked to get on a phone call 9 heard that name in a response. Never mind. In some 9 where the Epstein cases were discussed that you 10 nonresponsive answer that your client gave, I heard that 10 didn't, that you couldn't confirm who, you may have 11. name. 11 someone who may have said this is Joe Smith on the 12 MR. SCAROLA: Keep going. 12 other line, but where you discussed the Epstein case 13 BY MR. CRITTON: 13 over the phone with another lawyer from your firm? 14 Q. Mr. Edwards, with regard to your phone, 14 A. I don't understand that question. 15 did you have a direct line at RRA? 15 Q. Did you ever make a phone call or did you 16 A. Yes. 16 ever receive a phone call where you discussed the 17 Q. What was that phone number? 17 Epstein case with another lawyer in your firm; that 18 A. I don't remember. 18 is, that person — 19 Q. And is your cellphone today the same as it 19 A. Yes. 20 was back then? 20 Q. -- outside of the office? 21 A. Yes. 21 A. What? 22 Q. And what's that number, please? 22 Q. Okay. Obviously you would get calls 23 MR. SCAROLA: r? 23 within — 24 24 THE WITNESS: A. Even you. 25 25 Q. -- the confines of your office. Right. I Page 273 Page 275 1 BY MR. CRITTON: 1 understand that. 2 Q. Did You ever have a firm eellphone or just 2 A. You fall in that category. lam having a hard 3 your own personal cellphone? 3 time. 4 A. No. Just my own personal cellphone. 4 Q. The question is did you ever have, were 5 Q. During the time that you were at the firm, 5 you ever conferenced in on a call that was supposed 6 were you ever involved in making any type of a 6 to be among RRA lawyers regarding an Epstein case? 7 7 A. No. presentation to anyone regarding the Epstein cases? 8 A. Including other lawyers within the firm? 8 Q. Did anyone ever request that you prepare a 9 Q. Let me rephrase it I am going to 9 summary of any of Epstein cases that you in 10 rephrase. You already told us that you have talked 10 _your turn sent by either I -mail or memo to anyone else? 11 about the Epstein cases with other lawyers, correct? 11 A. I don't believe so. 12 A. Right. 12 Q. After you joined the RRA finn in April of 13 Q. Were you ever present in a meeting where 13 '09. did there come a point in time when you 14 there was a person whom you did not know wherein the 14 requested that, that you requested the depositions 15 Epstein, where the Epstein cases were discussed? 15 be taken out of state of a number of witness? Well, 16 A. No. 16 let me ask you this question. 17 Q. At the, ()when you met with Mr. Rothstein 17 MR. CRITTON: Let me, let make it easy. 18 in his office when Mr. Adler or whoever asked you to 18 Let me show what I will mark as Exhibit 3. 19 come up that one time and there was Adler, Rothstein 19 (Plaintiffs Exhibit No. 3 was marked for 20 and yourself; you said there was an individual on 20 identification.) 21 the phone? 21 BY MR. CRITTON: 22 A. Right. It was another lawyer with the firm 22 Q. Before I get to that, Mr. Edwards, were 23 Q. And how do you know it was another lawyer 23 you aware of any cases that Mr. Rothstein himself 24 with the firm? 24 settled for over $5 million while you were employed 25 A. It was either Marc Nurik or Mark Fistos, Mark 25 at the firm? 32 (Pages 272 to 275) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Cynthia hooking Electronically signed by cyntha hopkins Electronically signed by synth's hooking 2d3941264712-41704d82-0511f116c2ea EFTA00611269 1 Page 276 A. 1 was never aware of any cases that Rothstein 1 Page 278 Q. Do you recall sending or directing that 2 even handled much less settled. 2 this facsimile be sent. Or let me strike that. Who 3 Q. Were you aware of whether, did anyone ever 3 was your secretary at that time? Who is, well, WE 4 tell you whether Mr. Rothstein even did legal work 4 is you. Who is the MGL? 5 at the firm or whether he was just a rainmaker? 5 A. Who is the MGL? Let's see. 6 A. I — no, no one ever told me one way or the 6 Q. On Page 2. There are your initials, 7 other. 7 Brantley J. Edwards, BJE, and then MGL. Do you 8 Q. Would it be a correct statement that you 8 recognize that? 9 never saw him perform any legal work during the time 9 A. No. I mean, as you are very aware problems 10 you were at the fum? 10 with secretaries during that period of time, I, I had 13. A. That's a correct statement. 11 more than my share and that could have been a time 12 Q. Would it be a correct statement as far as 12 period where I did not have a legal assistant at all. 3.3 you knew he was kind of a gadfly going to his 13 And I do not recognize the initials MGL to identify 14 various business ventures and then he would hole 14 anybody that i know. 15 himself up in the office. 15 Q. With regard to the individuals who were 16 A. He was the guy on the billboards and at the 16 listed in Exhibit 3, specifically Donald Trump, 17 17 Leslie Wexner, Bill Clinton, with those individuals, Triple A arena and everything else marketing the firm 18 and bringing business in, and that's at least what I 18 you sent out this facsimile or at least your office 19 believe he did. If it's true or not, I don't !mow to 19 sent out the fax, Exhibit 3, requesting dates for 20 this day. 20 these individuals to be deposed, correct? 21 Q With regard to Exhibit 3, do you recognize 21 A. Yes. 22 this mail? 22 Q. All right. Prior to your joining RRA you 23 A. I, I don't recognize the 'mail. 23 had never requested either that the deposition of 24 Q. Do you recognize, and I will represent to 24 Mr. Trump be taken, Mr. Wexner, nor Bill Clinton, 25 you that I received the limit It was sent to me 25 correct? Page 277 Page 279 3. as well athough I am not shown as a recipient, I 1 A. I never requested a deposition to be taken 2 received Frail. 2 including any deposition of those three individuals. 3 THE WITNESS: Are you talking about the 3 Q. I understand but all tight. 4 fax? 4 A. The answer to your question is, yes. 5 MR. CRITTON: I am sorry, the fax 5 Q. All right Thank you. Paula Heil, do you 6 MR. SCAROLA: Exhibit, Exhibit 3. 6 know who that person is? 7 MR. CRI1TON: Exhibit 3. Let me start 7 A. Do I know who it is? I know that it's 8 again. Exhibit 3 is a fax. 8 somebody who was involved with Bear Sterns at some point 9 THE WITNESS: Correct 9 in time. 10 Iva. CRITTON: Dated July 22nd, 2009. 10 Q. You also requested dates, and in fact 11 THE WITNESS. I recognize that. 11 served a subpoena on Alan Dershowitz, the Harvard 12 BY MR. CRiTTON: 12 law professor, correct? 13 Q. And do you recognize on Page 2, it says 13 A. Correct. 14 very truly yours, Rothstein, Rosenfeld; Alder and 14 Q. And Mr. Dershowitz you were aware was one 15 then there is a, what appears to be a signature and 15 of Mr. Epstein's criminal defense lawyers, correct? 16 under that it says Bradley J. Edwards, Esquire, 16 A. At some point in time, I knew that in the past 17 partner fort (sic) the firm. Do you see that? 17 he had been an attorney of Mr. Epstein. 18 A. Yes, I see that. 18 Q. Well, you had, you had certain records 19 Q. Do you recognize the signature? 19 from the State Attorneys Office, didn't you, or 20 A. No. 20 from the police report? 23. Q. Is that how you sign your name? 21 A. And that's what I'm saying, yes, involved in 22 A. No. 22 the civil cases with us, no, l didn't ;mow that he had 23 Q. Do you know whose signature that is or 23 involvement. But, yes, I did know he was a former -- 24 purports to be? 24 Q. I'm sorry, go ahead - 25 A. I have absolutely no idea. 25 A. I did know that he was a former attorney of ....••••aMi•I•44 33 (Pages 276 to 279) PROSE COURT REPORTING AGENCY, INC. I= Electronically signed by cynthia hopkins ) Electronically signed by cynthia hopkins ) Electronically signed by Cynthia hopkins ( ) 2d39412d-87124170-9d82.0511078c2ea EFTA00611270 Page 280 Page 282 , 1 Jeff Epstein. 1 Tommy Mottola was listed. Do you know who 2 Q. Well, you also understood Mr. Epstein has 2 Mr. Mottola is? 3 had ongoing criminal law issues even during the time 3 A. Generally I think I know who that is. 4 of the civil case, correct? 4 Q. Who did you understand Mr. Mottola was? 5 A. No. 5 A. Something to do with the music industry. 6 Q. Sure. Well, you were aware that 6 Q. All right. And the name David Copperfield 7 Mr. Epstein was operating under the nonprosecution 7 was also referenced as a potential witness in the 8 agreement, that he was bound by the, a 8 case, correct? 9 nonprosecution agreement, coned? 9 A. That is correct. 10 A. I'm aware of the existence of a nonprosecution 10 Q. All right. And did you -- and you, in 11 agreement. 11 fact, attempted to coordinate a deposition for 12 Q. Well, and in fact you came into possession 12 Mr. Copperfield; is that correct? 13 of the nonprosecution agreement sometime in 2008 13 MR. SCAROLA: Are you asking about whether 14 because Judge Marra ordered that, ordered the United 14 communications occurred with you -- 15 States Government to turn over to all of the 15 MR. CRITTON: Sure. 16 attorneys and the clients who were listed as alleged 16 MR. SCAROLA: -- regarding such a 17 victims, correct? 17 deposition. 18 A. Yes. 18 BY MR. CRITTON: 19 Q. So, you had possession of the N.P.A. as of 19 Q. Let me rephrase it. With regard to the 20 sometime in the year 2008, correct? 20 lawyers in the case, including myself, you attempted 21 A. Right. 21 to coordinate a time for completing or taking the 22 Q. All right. And so you, and you were aware 22 deposition of Mr. Copperfield, Mr. Mottola, who I 23 that under the nonprosecution agreement Mr. Epstein 23 will represent is the former president of Sony 24 was required to meet certain requirements, that 24 Records, former president Bill Clinton, Alan 25 Mr. Epstein had a requirement to Inset certain 25 Dershowitz, Donald Trump, and Leslie Wexner, true? Page 281 Page 283 1 standards or certain provisions of the agreement 1 A. False. 2 otherwise the U.S.A. could potentially declare there 2 Q. Which of those, as to which one of those 3 was a breach of the agreement, true? 3 is that false? 4 A. I suppose. 4 A. Tommy Mottola. 5 Q. Well, you're a former prosecutors too, so 5 Q. So, but you did attempt to coordinate the 6 you knew what a nonprosecution agreement was, true? 6 depositions of Donald Trump, Mr. Dershowitz former 7 A. No, I had never seen a nonprosecution 7 president Clinton, David Copperfield, and Leslie 8 agreement in my life before this one. 8 Wexner, correct? 9 Q. When you got the nonprosecution agreement, 9 A. I believe so. 10 you reviewed it? 10 Q. And with regard to Mr., well, let me 11 A. Yes, l did. 11 strike that. In setting these depositions; that is, 12 Q. So, you were familiar with? 12 in requesting these deposition be taken sometime in 13 A. Right. 13 June and July of 2009 or requesting dates for them, 14 Q. And you understood from at least looking 14 did you have discussions with other attorneys in 15 at the police report that you had access to, that 15 your firm as to the benefits that would exist in 16 Mr. Dershowitz had represented Mr. Epstein with 16 your case, your three cases against Mr. Epstein by 17 regard to negotiating his plea that ultimately was 17 taking these individuals' depositions? 18 reached in negotiations with the federal government, 18 MR. SCAROLA: Objection. Same as grounds 19 true? 19 previously stated; instruct you not to answer. 2 0 A. I ;mew he played a role. 20 BY MR CRITION: 21 Q. Now, with few(' to Mr., with regard to 21 Q. Mr. Edwards, were you involved in the 22 the depositions of -- well, let me strike that. 22 discussions regarding the deposing of any of the 23 Also listed both on your, on Jane Doe's and 's 23 people of these individuals, Mr. Trump; that is, in 24 and .'s updated interrogatory answers which were 24 discussions with any other lawyers in your firm 25 provided during the year 2009, an individual named 25 including Scott Rothstein? •••••••••••••••••••• 34 (Pages 280 to 283) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkIns 2d39412d-87f2-4170-gd82-0511M6c2ea EFTA00611271 Page 284 Page 286 1 MR. SCAROLA: Same objection, same 1 BY MR. CRITTON: 2 instruction. 2 Q. Pint, my question in the broad sense. 3 BY MR. CRITTON: 3 Were you involved in the decision to pursue flight 4 Q. Same question with regard to 4 data associated with any planes Purportedly own by 5 Mr. Dershowitz, former president Clinton, Tommy 5 Mr. Epstein? 6 Mottola, David Copperfield, and Leslie Wexner. 6 MR. SCAROLA: My objection - 7 THE WITNESS: No. 7 MR. CRITTON: In tens of the discussions B MR. SCAROLA: Same objection, same 8 within your firm. 9 instruction? 9 MR. SCAROLA: My objection and my 10 THE WITNESS: And with respect to Tonally 10 insbuction stands. 11 Mottola, I, that was not my firm that was a 11 BY MR. CRITTON: 12 separate law firm that intended to take his 12 Q. Did you have discussions within your firm 13 deposition. 13 with regard to taking the depositions of celebrities 14 BY MR. CRITTON: 14 or famous people who were on, purportedly on 15 Q. Who was it that you understood was taking 15 Mr. Epstein's planes so that they could be deposed 16 Mr. Mottola's deposition? 16 such that that would be an inducement to Mr. Epstein 17 A. Searcy, Denney. 17 to settle his lawsuit? 18 Q. Did you ever discuss with Mr. Rothstein or 18 MR. SCAROLA: Same objection, same 19 anyone on his behalf the value of taking the 19 instruction. 20 depositions of Trump, Dershowitz, former president 20 BY MR. CRITTON: 21 Clinton, David Copperfield, and Leslie Wexner as an 21 Q. Isn't it true, Mr. Edwards, that in taking 22 inducement to get Mr. Epstein to settle his 22 the deposition or in attempting to take the 23 lawsuits? 23 deposition of Donald Trump, you had no information 24 MR. SCAROLA: You have already inquired of 24 that Mr. Trump had any knowledge of any female 25 Mr. Edwards about the communications that he 25 having; that is, underage female ever having been on Page 285 Page 287 1 had with Mr. Epstein. He has responded to 1 Mr. Epstein's plane and been, and having been 2 those questions previously. So, any further 2 assaulted by him? 3 questioning along those lines is entirely 3 MR. SCAROLA: What Mr. Edwards knew or 4 repetitious 4 didn't know in connection with this prosecution 5 BY MR CRITTON: 5 of pending claims is protected by a privilege. 6 Q. Can you answer that question, sir? Would 6 I instruct him not to answer. 7 you like it read back? 7 BY MR. CRITTON: 8 MR. SCAROLA: Beyond what he has already 8 Q. Mr. Edwards, did you know Officer Recarey? 9 responded, we would object on the basis of 9 I mean, I know you have meet him now because you 10 work-product and attorney-client privilege and 10 have seen him at his deposition, correct? 11 1 instruct you not to answer. 11 A. Correct. 12 THE WITNESS: Okay. 12 Q. Did you ever meet with, did you ever meet 13 BY MR. CRITTON: 13 Mr. or Officer Recarey at any time prior to his 14 Q. Were you involved in any of the decision 14 deposition in person? 15 to pursue obtaining flight data from Mr. Epstein? 15 A. No. 16 Well, let me strike that. Were you involved in the 16 Q. Have you ever spoken with Officer Recarey 17 decision to pursue flight data associated with any 17 at any time prior to his deposition, by phone or 18 planes that were purportedly owned by Mr. Epstein? 18 otherwise? 19 MR. SCAROLA: I will allow Mr. Edwards to 19 A. Yes. 20 acknowledge whether he did or did not 20 Q. Okay. And what context were you speaking 21 communicate about such matters with opposing 21 with Officer Recarey? 22 counsel. But beyond that I would assert 22 THE WITNESS: Answer? 23 attomey.client and work-product privileges and 23 BY MR. CRITTON: 24 instruct you not to answer. 24 Q. Well, first of all, let me withdraw that 25 25 question. Excuse me. On how many occasions have 35 (Pages 284 to 287) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins 2d30412d-6712-41704d82•0511ff713c2ea EFTA00611272 Page 288 1 you spoken with Officer Recarey prior to his 2 deposition? 3 A. Onetime. 4 Q. And when was that? 5 A. 2008. 6 Q. What was the purpose of the — let me 7 strike that Did you initiate the conversation or 8 did he? 9 THE WITNESS: Answer? 10 MR. SCAROLA: You can answer that. 11 THE WITNESS: I did. 12 BY MR. CRITTON: 13 Q. Okay. What was the purpose of your 14 conversation? 15 MR. SCAROLA: To the extent that the 16 purpose of your conversation was unrelated to 17 any pending legal matter, including in 18 particular the claims against Mr. Epstein, you 19 may answer. To the extent that it had anything 20 at all to do with Mr. Epstein, you should not 23. respond on the basis of privilege. 22 THE WITNESS: Privilege. 23 BY MIt CRITTON: 24 Q. Did you ever speak with Chief Reiter at 25 any time -- well, let me strike that. You were not Page 290 1 proceeding relating to any matter during the year 2 2008 or 2009? 3 MR. SCAROLA: You may answer. 4 THE WITNESS: No. 5 BY MR. CRITTON: 6 Q. Did Jane Doe ever come -- let me strike 7 that. Did Jane Doe ever come to your firm, the RRA 8 firm for any reason? 9 A. Yes. 10 Q. On how many occasions did she come to your 11 fimt, to RRA? 12 A. I believe one time. 13 Q. In addition to, I assume you met with her 14 on that occasion? 15 A. Right. 16 Q. Was anyone else present? 17 A. I don'Stelieve so. 18 Q. Did M. ever come to your firm at RRA? 19 A. No.. 20 Q. Did M. ever come to your firm at RRA? 23. A. Yes. 22 Q. On how many occasions? 23 A. Onetime. 24 Q. Did anyone meet with her other than 25 yourself? 4 Page 289 1 at his deposition, were you? 2 A. No. 3 Q. Okay. Have you ever spoken with Chief 4 Reiter at any time for any purpose as it relates to 5 Mr. Epstein? 6 THE WITNESS: Answer? 7 MR. SCAROLA: Only to the extent that 8 well, you asked specifically whether the 9 conversation related to Epstein? 10 THE WITNESS: Did the conversation occur 11 is the question. 12 MR. SCAROLA: Relating to Epstein. Read 13 the question back if you would, please. 14 MR. CRITTON: Let me rephrase it. 15 MR. SCAROLA: Okay. 16 BY MIt CRITTON: 17 Q. With regard to Chief Reiter, have you ever 18 spoken with Chief Reiter or now former Chief Reiter 19 from the Palm Beach Police Department for any 20 reason? 21 MR. SCAROLA: You can answer the "for any 22 reason" part. 23 THE WITNESS: No. 24 BY MR. CRITTON: 25 M Q. Have ou ever testified in a rand ury Page 291 1 A. Yes. 2 Q. Who was present? 3 A. Bill Berger. 4 Q. Did any RRA lawyer ever have an occasion 5 to meet with Jane Doe at, at a location other than 6 your office; that is, did you ever request that some 7 other lawyer meet with her, Jane Doe, for a specific 8 reason? Don't want to know the reason just whether 9 another lawyer met with her. 10 A. No. 11 Q. Did any other RRA lawyer meet with M. 12 separate, at any time? 13 A. No. 14 Q. Did any other lawyer ever met with M. 15 separate and apart from the one meeting that you had 16 with Bill Berger and yourself in 2000 — I'm sorry 17 did — 18 A. We're talking always about the time period at 19 RRA I understand that. 20 Q. Co= Did any lawyer from RRA ever 21 meet with In. separate from the single occasion 22 that you and Mr. Berger met with her at RRA's 23 office? 24 A. No. 25 Q. Did,, did ou ever veart i., 36 (Pages 288 to 291) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by Cynthia hopkins 2d39412d47t24170-9012-0511ffnic2ea EFTA00611273 1 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 292 communication, and by that I mean either a conversation or any writing with Mr. Scott Rothstein about the value of the J — of the Jeffrey Epstein cases? MR. SCAROLA: You can answer yes or no. THE WITNESS: No. BY MR. CRITTON: Q. Did you ever have a conversation or cormamication where Scott Rothstein was present and the value of the Epstein cases was discussed? A. No. Q. Did you ever have a conversation with other attorneys at RRA regarding the value of the J, of the Epstein cases that you had? A. Yes. Q. Okay. With whom? A. Russell Adler, Bill Berger. I believe that's it. Q. From, from your observations when you were at RRA, did it appear that certain individuals had access to Mr. Rothstein; that is, other lawyers in the firm had access to him? A. It appeared to me like nobody had access to hint Q. In the particular instance that you got Page 293 1 called up to his office, Mr. Adler was present along 2 with Mr. Rothstein and either Mr. Nurik or somebody 3 else who was on the phone, comet? We already 4 established that? 5 A. Correct 6 Q. From your observations and or your 7 conversations with Mr. Adler, did you get the 8 impression that Mr. Adler could have or would have 9 access to Mr. Rothstein? 10 MR. SCAROLA: By that I assume you mean 11 unfettered access? 12 MR. CRITTON: No, just easy access. 13 Unfettered suggests someone can walk in and out 14 of the office and you already told me it was a 15 compound. Let me reask my question. 16 BY MR. CRITTON: 17 Q. From what Mr. Adler told you, if you had a 18 conversation with Mr. Adler about a particular, 19 whether it was an Epstein case or another case, was 20 it your understanding that Mr. Adler had regular, 21 some form of regular communication with 22 Mr. Rothstein? 23 A. No. 24 Q. Okay. Did you understand that he didn't 25 have any communication with Mr. Rothstein or did you Page 294 1 not, just did you just not have an understanding? 2 A. I had an understanding. 3 Q. Okay. What was your understanding and 4 what was it based on? 5 A. Based on numerous conversations with Russell 6 Adler that even he had a very difficult time gaining 7 access to Scott Rothstein for any reason. 8 Q. Did Mr. Adler, did you ever ask Mr. Adler 9 to pass on information to Mr. Rothstein about the 10 Epstein cases? 11 A. No. 12 Q. Other than Mr. Jenne who would make, I 13 think you indicated earlier, on eight to ten 14 occasions ask you about the Rothstein, I am sorry, 15 asked you about the Epstein cases, did any other 16 person inquire on a somewhat regular basis or even 17 an irregular basis as to the status of the Epstein 18 cases? 19 A. Yes. 20 Q. Who? 21 MR. SCAROLA: Again I assume you're 22 talking about persons within the firm? 23 M t CRITTON: Correct I'm back to only 24 within RRA You understood that, didn't you, 25 Mr. Edwards? 2 3 4 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 295 THE WITNESS: No, i didn't. i thought you meant anybody. BY MR. CRITTON: Q. Okay. Then i am back within RRA because i had asked you about Mr. Jenne. A. Got it. Q. So, i wouldn't go out I want to stay within the firm. Did anyone ask you or inquire of you about the status of the RRA cases; it was either a lawyer or an investigator within the firm? A. Maybe but, but none that I can really picture as somebody who would do it regularly. If I was talking in some lawyer's office about any case or any issue, there were times where I remember generally how is this specific case going or that specific case, and at times it was Jeffrey Epstein case. Q. With regard to Mr. Jenne, what did you understand with regard to what his position was in the firm? A. Something to do with the investigative Q. Okay. What did you understand about Mr. Jenne's background. Let me strike that. Were you a State Attorney's when Mr. Jenne was a Broward County Sheriff? 37 (Pages 292 to 2 9 5) PROSE COURT REPORTING AGENCY, INC. 4 Electronically signed by cynthia hopkins ( Electronically signed by cynthia hopkins ( Electronically signed by cynthia hopkins ( 2d39412d-67f2-4170-9d82-0511ff76c2ea EFTA00611274 Page 296 Page 298 1 A. I believe so. 1 A. No. 2 Q. Were you still a State Attorney when 2 Q. Did you ever find it strange that 3 Mr. Jenne was indicted and then eventually ended up 3 Mr. Jenne was asking you questions about the Epstein 4 in jail? 4 cases? s A. No. 5 A. No. 6 Q. Were you in private practice at that 6 Q. Did you ever ask Russell Adler as to why 7 point? 7 Mr. Jenne would be asking you questions about the 8 A. Correct 8 Epstein cases? 9 Q. But you lived then in Broward County, so 9 A. No. 10 you followed the developments of Mr. Jenne's 10 Q. And I think you told me earlier, but I may 11 downfall in becoming a convicted felon? 11 be wrong so i want to clear this up. i don't want 12 A. I was aware. /2 to be repetitious here. Did Mr. -- 13 Q. All right. Was Mr. knne, would it be a 13 MR. SCAROLA: When did you change your 14 correct statement that Mr. Jenne and Mr. Fisten and 14 nand about that? 15 Mr. Roberts were all at the RRA firm when you 15 MIL CRITTON: Earlier. 16 started in April of '09? 16 BY Iva CRITTON: 17 A. I don't believe so. 17 Q. Did Mr. Jenne, did you ever direct 18 Q. Which one was there when you started? 18 Mr. Jenne to do any investigation on the Epstein 19 When hay "there." was already employed by RRA when 19 cases? 20 you started? 20 MR. SCAROLA: Objection, work-product. 21 A. lam not sure if any of the three were there 21 BY MR. CRTITON: 22 but perhaps all of them were there. 22 Q. Did Mr. Jenne ever do any investigation on 23 Q. All you know is at some point you came to 23 the Epstein files? 24 be involved with them as investigators? 24 MR. SCAROLA: Objection, work-product. 25 A. Correct. 25 Page 297 Page 299 1 Q. All right. With regent to Mr. Jenne, was 1 BY MR. GIRTON: 2 his office on the same floor as yours? 2 Q. Did Mr., were you aware that Mr. Jenne was 3 A. No. 3 attempting to shop the Epstein cases to investors 4 Q. Where, was his office in any way near 4 during the time you were at the RRA firm? 5 Mr. Rothstein's? 5 MR. SCAROLA: Objection, assumes facts. 6 MR. SCAROLA: What does any way near Mr. 6 THE WITNESS: No. 7 Rothstein's mean? 7 MR. SCAROLA: That% all right 8 MR. CRITTON: Same floor. 8 BY MR. CRITTON: 9 THE WITNESS: No. 9 Q. Do you know Bill Scherer, Attorney Sill 10 10 Scherer? BY MR. CRITTON: 1 1 Q. Did it appear to you that -- well, let me 11 A. No, I know of him. 12 strike that. You said that Mr. Jenne had something 12 Q. You are aware that he has a pending 13 to do with investigation, correct? 13 lawsuit against various individuals including ID 14 A. Correct 14 Bank and other Defendants on behalf of various 15 Q. Okay. Did he ever describe for you what 15 investors; is that a fair statement? 16 he did for the firm? 16 A. ;remember when that first came out. I have 17 A. No. 17 not followed it. I don't know if it's active, if it's 18 Q. And i third( you said, did you say what his 18 still pending, or what the status is at all. But i do 19 title was? 19 remember a lawsuit being filed on behalf of sorrrbody 2 0 A. I didn't know his title. I don't know what 20 against Scott Rothstein and others. 21 his title is now. 21 Q. All right. And do you remember, it's 22 Q. Did you ever ask Mr. Jenne why he was 22 within Paragraph 20 of the complaint it's a — 23 asking you questions about the Epstein case or 23 A. Of? 24 engaging you in a dialogue regarding the Epstein 24 Q. Of, rm sorry, of Exhibit No. 2. And it 25 cases? 25 states Fort Lauderdale attorney William Scherer 38 (Pages 296 to 299) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins 2d39412d-6712-4170-9d82-0511ff76c2ea EFTA00611275 Page 300 Page 302 1 represents multiple Rothstein related investors. He 1 A. No. 2 indicated in an article that RRA, slash, Rothstein 2 Q. Okay. Were you aware that Scott Rothstein 3 had used the Epstein ploy as a showpiece, as a 3 had represented to other individuals that be had 4 showpiece, as bait. That's, and the quote is, 4 multiple other cases, multiple other Jane Doe's 5 Epstein ploy, as a showpiece, as bait. That's the 5 which he was trying to market to investors? 6 way he raised all the money. 6 A. No. 7 He would use cases as bait for luring 7 Q. Were you aware that -- do you have any 8 investors into fictional cases. All the cases he 8 knowledge that Ken -- let me strike that. 9 allegedly structured were fictional. I don't 9 Were you aware that Ken Jenne was 10 believe there was a real one there. 10 attempting to market or shop non-existent Epstein 13. Okay. If I asked you to assume that that 11 cases to investors? 12 quote is accurate from Mr. Scherer, would it be a 12 A. I wasn't aware then nor am I aware of that 13 correct, would it be a correct statement -- well, 13 now, so, no. 14 let me strike that. 14 Q. Do you have any knowledge that Mr. Fisten 15 Were you aware that Rothstein and other 15 and/or Mr. Jenne would cart boxes of Epstein related 16 individuals were using the Epstein ploy, that is, 16 materials; that is, existing Epstein related 17 the Epstein cases in order to, as bait in order to 17 materials relating to Jane Doe and show those to 18 raise money for, for the firm and Mr. Rothstein? 18 other investors? 19 MR. SCAROLA: I am going to object to the 19 A. Do I have knowledge that somebody caned? 20 form of the question, but you can certainly 20 Q. Yeah, are you aware that Mr. Fisten or do 21 answer it. 21 you have any knowledge that Mr. Fisten brought boxes 22 THE WITNESS: Okay. I am going to answer 22 of Epstein-related materials to show perspective 23 it to the extent that I understand it. No, I 23 investors? 24 was not aware that the Epstein cases were being 24 A No. 25 used as a showpiece, as bait. But you are also 25 MR. SCAROLA: Objection, assumes, Assumes Page 301 Page 303 1 asked me to assume that the statement that you 1 facts not in evidence, no proper predicate. 2 have injected as Paragraph 20 of the complaint 2 BY MR. CRITTON: 3 is true and it begins with, or ends with I 3 Q. Do you have any knowledge that Mr. Jenne 4 don't believe there was a real one in there, 4 either directly or directed someone else to bring 5 talks, speaking as to all the cases. And you 5 boxes of Epstein-related materials to show 6 know and I know that that statement is 6 investors? 7 absolutely false in that you know each and 7 MR. SCAROLA: Objection, assumes facts not 8 every one of the claims that have been asserted 8 in evidence, no proper predicate. 9 against Mr. Epstein related to his molestation 9 THE WITNESS: No. 10 of children, they are all Ins including the 3.0 BY MR. CR1T'TON: 11 three that I have against Mr. Epstein. 11 Q. If, based on your earlier testimony, if 12 So, if you're asking me to assume that 12 there were boxes of Epstein materials on existing 13 this is it true, no, I did not know that they 13 cases, Jane Doe, . and M., again if I 14 were being used for anything. 14 understood your testimony, that information would 15 BY MR. CRITTON: 15 have been available someplace in the firm and 16 Q. Okay. Well, as to whether Mr. Scherer was 16 someone who had access to the room could have 17 aware as to whether there were three pending Cases 17 grabbed those files or taken those files and done 18 or he assumed that they were all just made-up cases, 18 whatever they wanted to them, with them, and then 19 neither you nor I know what he was thinking, 19 brought them back for storage, correct, and you 20 correct? 20 wouldn't know? 21 A. Yeah, I don't know. 21 A. As is the case with every case in every law 22 Q. All right. With regard to the Epstein 22 firm in America, yes. 23 ploy, with regard to Epstein cases, were you aware 23 Q. With regard to the three cases that you 24 that Scott Rothstein was trying to market Epstein 24 have now, does any law firm other than your current 25 cases; that is, three, three cases that existed? 25 firm, which is Fanner, Jaffe? 39 (Pages 300 to 303) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins (60145141 ) 2d39412d4712-4170-9482-0511076c2ea EFTA00611276 Page 3 0 4 1 A. Weissing. 2 Q. Or ERA, Mr. Howell, or Mr. Cassell have 3 any interest in those cases? 4 A. No. 5 Q. At any time — let me strike that. You 6 are aware that Mr. Alfredo Garcia has pled guilty to 7 an obstruction of justice charge based on the news? 8 A. I don't know Alfredo Garcia at all. 9 Q. Sorry about that The head of Alfredo 10 Garcia. With regard Mr. Rodriguez, Alfredo 11. Rodriguez, are you aware through news reports that 12 he pled guilty to obstruction of justice? 13 A. Yes. 14 Q. At any time have you been given access to 15 the pamphlet book and/or any of the yellow pages 16 that have been referenced in the criminal 17 indictment? 18 MR. SCAROLA: I am going to instruct you 19 not answer that question on the basis of 20 attorney-client and work-product privilege. 21 BY Mit CRITTON: 22 Q. Has the, have you been, have you had any 23 contact with the criminal defense lawyer for 24 Mr. Rodriguez? 25 MR. SCAROLA: You can answer yes or no. Page 305 1 THE WITNESS: No. 2 BY MR. CRITTON: 3 Q. Have you had any communication, not a 4 conversation but any oranniunication with the criminal 5 defense lawyer about obtaining a copy of the 6 pamphlet and/or the pamphlet book or the yellow 7 pages that are referenced in the criminal indictment 8 that were at one time in the possession of Mr. 9 Rodriguez and that he apparently was trying to sell 10 to the cooperating witness? 13. MR. SCAROLA: I am going to instruct you 12 not to answer any question about anything that 13 you may have done in connection with the 14 fulfillment of your responsibilities as counsel 15 for the Plaintiffs in the three pending cases. 16 BY Mit CRITTON: 17 Q. Again, of course you're going to continue 18 to follow Mr. Scarola's direction? 19 A. On what I have done or what I have not done, 20 all of that is work-product. 21 Q. Well, you have filed a motion to obtain a 22 copy of the pamphlet book and the yellow pages of 23 Mr. Rodriguez, correct? I am sorry, either a 24 motion — well, strike that. You have filed a 25 motion in federal court to obtain a co • of the, of Page 306 3. the information that is held by the FBI which would 2 include the pamphlet and the yellow, the pamphlet 3 and the yellow pages, true? 4 A. I have. Adam Horowitz has, and I may or may 5 not have piggybacked his motion. But as sitting here 6 right now, I, I don't remember drafting that motion. 7 Q. Are you sure he hasn't piggybacked your 8 motion? 9 A fm not sure. If you show ne my motion, l can 10 tell you whether I drafted it or not. 11 Q. Have you — 12 A. That, that was certainly an idea. 13 Q. Have, have you also you have also 14 served a motion to obtain FBI files that relate to 15 Mr. Epstein; is that correct? 16 A. Correct. 17 Q. Olcay. Have you spuktn as a result of the 18 motion that you filed, has the government, have you 19 spoken with the United States Attorney's Office or 20 representatives for the FBI with regard to the 21 motion which you filed? 22 MR. SCAROLA: Objection, privilege and 23 instruct you not to answer. 24 BY MR. CRITTON: 25 Q. Have you received any type of response Page 307 1 from the United States Attorney's Office or the FBI 2 with regard to the motion that you have filed? 3 MR. SCAROLA: You may answer that only 4 with respect to those matters that are matters 5 of public record; that is, if a response has 6 been filed with the court or provided to you in 7 the form of a pleading, you may respond. 8 THE WITNESS: I cannot respond to that 9 question. 10 MR. CRITTON: All right. We're going to 11 quit at 5. I don't want to go on. 12 MR. SCAROLA: You already, you already 13 missed that. 14 MR. CRITTON: All right. Well, let's, 15 Ill adjourn the deposition today, and I will 16 arrange with you fora time to finish. 17 MR. SCAROLA: Well, so that the record is 18 clear, it is our position that you have had 19 more than adequate time to conduct an 20 appropriate examination of Mr. Edwards, and we 21 will resist any further effort to depose him. 22 MR. CRITTON: I understand your position. 23 Disagree with it but understand it. 2 4 MR. SCAROLA: Thank you. 25 THE VIDEOGRAPHER: This concludes today's PROSE COURT REPORTING 40 (Pages 304 to 307) AGENCY, INC. Electronically signed by cynthia hopkins (601451476.2934) Electronically signed by cynthia hopkins (601451476.2934) Electronically signed by cynthia hopkins (6014514764934) 2d39412c1-6712-4170-9d82-0511f176c2oa EFTA00611277 Page 308 Page 310 I videotape deposition of Scott Rothstein. The 1 CERTIFICATE OF OATH 2 time is -- 2 THE STATE OF FLORIDA 3 THE WITNESS: Whoa whoa. 3 COUNTY OF PALM BEACH 4 THE COURT REPORTER: Yes. Bradley 4 5 5 Edwards. 6 1, the undersigned authority, certify that 6 THE WITNESS: Please don't lump me in with 7 BRADLEY1. EDWARDS, ESQUIRE personally appeared 7 that guy, num B before me and was duly sworn on the 23rd day of 8 MR. SCAROLA: This concludes the 9 March, 2010. 9 deposition of Mr. Bradley Edwards. 10 10 THE VIDEOGRAPHER: Oh, Pm sorry. This 11 Dated this 5Ih day of April, 2010. 11 concludes the deposition of Mr. Bradley 12 12 Edwards. The time is 5:07 p.m. 13 13 (A discussion was held off the record.) 14 15 14 THE COURT REPORTER: Did you want to order ' 5: c As 15 this? 16 16 MR. CRITTON: Ask me tomorrow. Cynthia Hopkins, RPR, FPR I? MR. SCAROLA: I will take a copy of it. 17 Notary Public - State of Florida 18 Let's stay on the record. We don't need to be My Commission Expires: February 25,2011 19 on the video record but I want to make the 18 My Commission No: DD 603788 20 statement that we would consider it entirely 19 20 21 inappropriate for any portion of this 21 22 deposition to be used for any reason whatsoever 22 23 that is not directly connected with the 23 24 prosecution of the pending claim against 24 25 Mr. Edwards or the defense of the 25 Page 309 Page 311 1. counterclaims. Thank you. I CERTIFICATE 2 THE STATEOFFLORIDA 2 MR. CRITTON: Bye. 3 COUNTY OF PALM BEACH 3 MR. SCAROLA: Bye. 4 S I, Cynthia Hopkins, Registered Prokssional 4 (Witness excused.) Reporter, Florida Professional Reporterand Notary 5 (Deposition was concluded.) 6 Public in and for the State of Florida at large. do 6 7 hereby cenily that I was authorized to and did report said deposition in stenotype, and that the 7 foregoing pages are a true and cottons transcription 8 a 9 ofmy shorthand notes of said deposition. I further certify that said deposition was 9 taken at the time and place hereinahme set forth 10 10 and that the taking of said deposition was commenced and completed as hereinabove set out. 11 11 12 1 funhcr certify Statism not attorney or 12 counsel of any of the panics, nor am l a relative 13 ix employee of any attorney or counsel of party 14 13 connected with the action, nor am I financially interested in the action. 15 10 16 The foregoing ceniflealion of this franc* 17 rs does na apply to any reproduction of the same by any means unless under the (hied C091901 andlor 18 16 direction of the certifying reporter. 19 17 re Dated this% day orApril, 20'0. 20 19 21 20 21 22 Ice J a, , 23 22 24 29 23 25 25 41 (Pages 308 to 311) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins ( ) 2d39412d-67f2-4170-9c182-0511E7622ea EFTA00611278 Page 312 Page 314 2 1 4 6 7 9 10 12 13 14 15 16 17 1$ 19 20 21 22 23 24 25 DATE Apt11990o10 TO BRADLEY J. EDWARDS. ESQUIRE do het Snob. ERuire NMI RI RR F;rwina Rotatin CASE NO, 50 MCMINN:0000UB AQ Pleabe et mkt Waco al 23n1 of Maid 2•314 dapcdom ia Sc it' nose. Mimi Una. Wr dd sot wive sjpsuie kis nos reosarpha snip yaw *indica Al Pita/ Cad I% OS NOW* 4.41 W As00441or>441Kwith War Cowed limo not the Colo.* Inurskr• caret* Mitt end oft traracrIpl •41 Wats outage. Al yeti read war depsilke. 4419 clews et *main Oal ma viol quake sheaf ix Dosed ca the allia sham disposed hoc riartxrdudd dot. DO NOT who ce Moab" stlt Noe r:a kn. real IS traBaipl acted any chime* te sure rip te4 daft anis sheer ad rya diem saw 9a If you 43rrx rod and wan the *mai/km wahl4 s MEWS* eiae.St Otioll. Vat. haS tsbody teen forsatod Rabe ado* focnty, ray 1:41114 wit the Clerk of Re Can Bye, wish b0.4h. Sag 60•11111‘ beyew ern: kg Oa Wok Sc6=m dais kilo awl mom ii toot Cydd I 4cOm. COIL FPR I 4:amet, vaMmysismort BACCW t UP.thWA aroma 1 ERRATA SHEET 2 IN RE: EPSTEIN VS. ROTHSTEIN CR: Cynthia Hopkins, RPR, FM 3 DEPOSITION OF: BRADLEY J. EDWARDS, ESQUIRE TAKEN: March 23, 2010 4 JOB NO.: 1333 5 DO NOT WRITE ON TRANSCRIPT - ENTER CHANGES HE PAGES UNE SI CHANGE REASON 6 7 8 10 11 12 13 14 15 16 17 Please forward the original signed arms sheet to this office so that copies may be distributed to all 18 parties, 19 Under penalty of pajury, I declare that I have read my deposition and that it is true and correct 20 subject to any changes in form or substance entered here. 21 22 DATE: 23 24 SIGNATURE OF DEPONENT: 25 3. 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 1.9 20 21 22 23 24 25 Page 313 CERTIFICATE THE STATE OF FLORIDA COUNTY OF PALM BEACH I hereby certify that I have read the foregoing deposition by me given, and that the statements contained herein are true and correct to the best of my knowledge and belief, with the exception of any corrections or notations made on the errata sheet, if one was executed. Dated this day of 2010. BRADLEY J. EDWARDS, ESQUIRE Job #1333 42 (Pages 312 to 314 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthla hopkins 2d3,41244.02-4110-00824$11ff76c2cta EFTA00611279