795 (1).pdf

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Filing# 9301301 Electronically Filed 01/17/2014 03:32:27 PM 
JEFFREY EPSTEIN, 
Plaintiff, 
vs. 
SCOTT ROTHSTEIN, individually, BRADLEY J. 
EDWARDS, individually, and L.M., individually, 
Defendant, 
I 
-----------------
IN THE CIRCUIT COURT OF THE FIFTEENTH 
JUDICIAL CIRCUIT, IN AND FOR PALM 
BEACH COUNTY, FLORIDA 
CASE NO.: 502009CA040800XXXXMBAG 
DEFENDANT/COUNTER-PLAINTIFF'S RESPONSE IN OPPOSITION TO 
PLAINTIFF/COUNTER-DEFENDANT'S MOTION FOR SUMMARY JUDGMENT ON 
DEFENDANT/COUNTER-PLAINTIFF'S FOURIB AMENDED COUNTERCLAIM 
Defendant/Counter-Plaintiff Bradley J. Edwards, by and through his undersigned counsel, hereby 
submits this Response in Opposition to Plaintiff/Counter-Defendant Jeffrey Epstein's Motion for 
Summary Judgment. Epstein seeks Summary Judgment on the claims of abuse of process and malicious 
prosecution set forth in Brad Edwards' Fomih Amended Counterclaim. Each of the grounds asserted in 
support of Epstein's Motion for Summary Judgment are without merit and must be denied. 
In Epstein's Amended Complaint he carries forth the essence of all claims asserted in his original 
Complaint. In that pleading Epstein essentially alleges that Edwards joined Rothstein in the abusive 
prosecution of sexual assault cases against Epstein to "pump" the cases to Ponzi scheme investors. The 
purported "proof' of the allegations against Edwards, as referenced in the Second Amended Complaint 
and in Epstein's Motion for Summary Judgment, includes Edwards' alleged contacts with the media, his 
attempts to obtain discovery from high profile persons with whom Epstein socialized, press rep01is of 
Rothstein's known illegal activities, the use of "ridiculously inflammatory" language and arguments in 
court. But as the evidence submitted in opposition to Epstein's Motion for Summary Judgment reflects, 
Epstein filed his claims and continued to pursue claims despite his lmowledge that his claims could never 
be successful because they were both false an...

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Case No.: 502009CA040800XXXXMBAG 
Edwards' Opposition to Epstein's Motion for Summary Judgment 
Page 2 of 15 
they were true. Epstein knew that he had in fact molested each of the minors represented by Brad 
Edwards. He also knew that each litigation decision by Brad Edwards was grounded in proper litigation 
judgment about the need to pursue effective discovery against Epstein, particularly in the face of 
Epstein's stonewalling tactics. 
Epstein also knew that he suffered no legally cognizable injury 
proximately caused by the falsely alleged wrongdoing on the part of Edwards. Moreover, Epstein had no 
intention of waiving his Fifth Amendment privilege against self-incrimination in order to avoid providing 
relevant and material discovery that Epstein would need in the course of prosecuting his claims and to 
which Edwards was entitled in defending those claims. Epstein knew that his prosecution of his claims 
would be barred by the sword-shield doctrine. 
Most significantly, the evidence submitted in the 
supporting papers would compel a fact finder to detennine that Epstein had no basis in law or in fact to 
pursue his claims against Edwards and that Epstein was motivated by a single ulterior motive to attempt 
to intimidate Edwards and his clients and others into abandoning or settling their legitimate claims for 
less than their just and reasonable value. The evidence demonstrates that Epstein did not file these claims 
for the purpose of collecting money damages since he knew that he never suffered any damage as a 
consequence of any alleged wrongdoing by Edwards but filed the claim to require Edwards to expend 
time, energy and resources on his own defense, to embarTass Edwards and impugn his integrity and deter 
others with legitimate claims against Epstein from pursuing those claims. 
Indeed, the evidence 
demonstrates that Epstein continued to pursue his claims by filing the Second Amended Complaint 
alleging abuse of process against ...

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Case No.: 502009CA040800XXXXMBAG 
Edwards' Opposition to Epstein's Motion for Summary Judgment 
Page 3 of 15 
The record reflects that on the eve of the hearing of Edwards' Motion for Summary Judgment 
directed to the Second Amended Complaint and in light of the compelling evidence of the lack of any 
wrongdoing on the part of Mr. Edwards, the sole remaining abuse of process claim was dismissed by 
Epstein. 
As discussed, infra each of the grounds asserted by Epstein in this Motion for Summary 
Judgment must be rejected. The litigation privilege does not serve as a bar to the prosecution of Edwards' 
claims against Epstein. Moreover, the evidence submitted by Edwards supports each of the elements of 
the claims asserted by Edwards against Epstein which are identified in Epstein's Motion. 
Response to Epstein's Statement of Undisputed Facts 
The evidence marshalled by Edwards in support of his claims against Epstein which are 
referenced in footnote 1 mandates the conclusion that, at a minimum, disputed facts exist with respect to 
the elements of each claim addressed by Epstein in his Motion. The facts presented in the various papers 
would allow the jury to make a determination that Epstein knew that Brad Edwards properly exercised his 
legitimate judgment regarding the need to pursue proper and effective discovery against him to support 
the claims which Epstein knew were legitimate. That evidence, referenced herein, further demonstrated 
that Epstein filed his claims without probable cause and further that there was a bonafide termination in 
favor of Edwards. That evidence further demonstrates that the elements of the claim of abusive process 
have been established. 
The following additional comments are directed at some of the key purported "undisputed" 
material facts asserted by Epstein, especially those referenced in his Memorandum of Law. Also set forth 
are key evidentiary matters which undermine Epstein's contentions and which support...

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Case No.: 502009CA040800XXXXMBAG 
Edwards' Opposition to Epstein's Motion for Summary Judgment 
Page 4 of 15 
None of the public materials identified by Epstein in his Motion make reference to any 
wrongdoing by Brad Edwards. Rather, Epstein seeks to pyramid one impermissible inference upon 
another from his citation to these materials to support his otherwise unsubstantiated and non-verifiable 
conclusion that he had sufficient evidence to proceed with claims of wrongdoing against Edwards. In 
truth, as reflected in Edwards' deposition and his supplemental affidavit, he has no involvement in any 
fraud perpetrated by Rothstein (Edwards' deposition of March 23, 2010 at 301-302; Edwards Affidavit 
attached to Statement of Undisputed Facts as Exhibit ''N" at paragraphs 8-10, paragraph 20, paragraphs 
22-23; Exhibit "H" - Deposition of Scott Rothstein at pp. 62-63, 114, and 121-124). Therefore, any 
allegations relating to Rothstein' s activities simply have no bearing on the legitimacy of any of the claims 
against Edwards. 
Edwards could not have possibly "pumped" cases to investors when he never 
participated in any communications with investors. Rather, Edwards had a duty to his clients to zealously 
pursue discovery to achieve a maximum recovery against Epstein. Edwards cannot be liable for taking 
appropriate action that his ethical duties as an attorney required. The evidence also reflects that Edwards 
filed all three of his cases almost a year before he was hired by RRA or even knew Scott Rothstein 
(Edwards' Affidavit, Exhibit "N" attached to Statement of Undisputed Facts). The language set fmih in 
his Complaints remain virtually unchanged from the first filing in 2008 and, as the evidence shows, the 
claims asserted against Epstein from the outset were true. 
The citation to public documents is a 
convenient ruse; Epstein was not only liable for the molestation of the clients of Brad Edwards, he was 
also a serial molester of minors - e...

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Case No.: 502009CA040800XXXXMBAG 
Edwards' Opposition to Epstein's Motion for Summary Judgment 
Page 5 of 15 
Federal Statute providing for compensation to victims of child abuse.. 
(Exhibit "A" -
Edwards' 
Statement of Undisputed Material Facts, paragraphs 41-43). 
On July 6, 2010 Epstein ultimately paid to settle all three of the cases Edwards had filed against 
him (Exhibit "A" - Edwards' Statement of Undisputed Material Facts, paragraphs 84-85). At Epstein's 
request, the terms of the settlement were kept confidential. The sum that he paid to settle all these cases 
in therefore not filed with this pleading and will be provided to the court for in camera review. Epstein 
chose to make this payment as a result of a Federal Court ordered mediation process which he himself 
sought. Epstein entered into the settlements in July 2010 more than seven months after he filed his 
lawsuit against Edwards and before he filed his Second Amended Complaint alleging abuse of process on 
August 22, 2011. 
Further, Epstein could not have been the victim of any scheme to pump the cases against him 
because he never paid to settle the cases until well after Edwards had left RRA and severed all connection 
with Rothstein in December 2009 (Edwards' Affidavit attached to Statement of Undisputed Facts as 
Exhibit "N," paragraph 20). Moreover, Epstein could not have suffered any damage as a result of the 
perpetration of the Ponzi scheme by Rothstein because he was not an investor in the scheme. 
Perhaps the most significant evidence presented in opposition to Epstein's Motion for Summary 
Judgment is the telephone interview of Virginia Roberts submitted in Support of Edwards' Motion for 
Punitive Damages (Exhibit "D''). In addition to the specious claims against Edwards relating to his 
alleged involvement in a Ponzi scheme, Epstein, in asserting his claims, primarily relied upon the pursuit 
by Edwards of testimony from his close friends and associates (See Second...

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Case No.: 502009CA040800:XXXXMBAG 
Edwards' Opposition to Epstein's Motion for Summary Judgment 
Page 6 of 15 
undisputed facts submitted by Mr. Edwards in support of his Motion for Summary Judgment, Edwards 
had a sound legal basis for believing that Donald Trump, Allen Dershowitz, Bill Clinton, Tommy 
Mattola, David Copperfield and Governor Bill Richardson had relevant and discoverable information 
(Exhibit "A" - Edwards' Statement of Undisputed Facts, paragraphs 69-81). That belief was reinforced 
by the testimony of Virginia Roberts (Exhibit "D" pp. 10-17, 21-23). Epstein's assertion of impropriety 
in the pursuit of this discovery clearly evidences his bad faith attempts to attribute wrongdoing to 
Edwards when he knew, in fact, that the pursuit of that discovery was entirely appropriate under the 
circumstances of this case. 
Finally, any attempt by Epstein to rely upon what he claims are undisputed facts to support his 
Motion for Summary Judgment are undennined by his refusal to provide any testimony on the key issues 
and evidence which would demonstrate the validity and strength of each of the claims brought against 
him by Brad Edwards. Epstein's depositions of March 17, 2010 and January 25, 2012 were replete with 
refusals of Epstein to testify based upon his Fifth Amendment privilege. Questions that Epstein refused 
to answer in his depositions and the reasonable inferences that a fact finder would draw and which would 
otherwise bear on the arguments submitted by Epstein in support of his Motion for Summary Judgment 
are as follows: 
• 
Question not answered: "I want to know whether you have any knowledge of evidence 
that Bradley Edwards personally ever participated in devising a plan through which were 
sold purported confidential assignments of a structured payout settlement?" Reasonable 
inference: No knowledge that Brad Edwards ever participated in the Ponzi scheme. 
• 
Question not answered: "Specifically what are the allegat...

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Case No.: 502009CA040800XXXXMBAG 
Edwards' Opposition to Epstein's Motion for Summary Judgment 
Page 7 of 15 
• 
Question not answered: "Did sexual assaults ever take place on a private airplane on 
which you were a passenger?" Reasonable inference: Epstein was on a private airplane 
while sexual assaults were taking place. 
• 
Question not answered: "How many minors have you procured for prostitution?" 
Reasonable inference: Epstein has procured multiple minors for prostitution. 
• 
Question not answered: "Is there anything in L.M.' s Complaint that was filed against 
you in September of2008 which you contend to be false?" Reasonable inference: 
Nothing in L.M.'s complaint filed in September of2008 was false -i.e., as alleged in 
L.M.' s complaint, Epstein repeatedly sexually assaulted her while she was a minor and 
she was entitled to substantial compensatory and punitive damages as a result. 
• 
Question not answered: "I would like to know whether you ever had any physical 
contact with the person referred to as Jane Doe in that [federal] complaint?" Reasonable 
inference: Epstein had physical contact with minor Jane Doe as alleged in her federal 
complaint. 
• 
Question not answered: "Did you ever have any physical contact with E.W.?" 
Reasonable inference: Epstein had physical contact with minor E.W. as alleged in her 
complaint. 
• 
Question not answered: "What is the actual value that you contend the claim of E.W. 
against you has?" Reasonable inference: E.W.'s claim against Epstein had substantial 
actual value. 
(See Exhibit "A" -Edwards' Statement of Undisputed Material Facts, paragraphs 93-120 
for page references.) 
A jury could conclude, therefore, from the adverse inferences drawn against Epstein that he was 
liable for the claims brought by Brad Edwards and that he had no basis for the pursuit of his efforts to 
intimidate and extort Edwards and his clients in the pursuit of those claims. 
The Litigation Privilege Does Not Bar the...

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Case No.: 502009CA040800XXXXMBAG 
Edwards' Opposition to Epstein's Motion for Summary Judgment 
Page 8 of 15 
on rehearing and, thus, is not a final opinion. As a result, it is not binding, nor persuasive. Moreover, 
Wolfe undercuts the long-standing recognition of the viability of a claim for malicious prosecution in its 
own District and other Florida state and federal courts. See, SCI Funeral Svs. of Fla., Inc. v. Henry, 839 
So. 2d 702, n.4 (Fla. 3d DCA 2002) ("As the Levin court cited Wright v. Yw·ko, 446 So. 2d 1162, 1165 
(Fla. 5th DCA, 1984), with approval, presumably the cause of action for malicious prosecution continues 
to exist and would not be barred by the litigation privilege."); Boca Investors Group, Inc. v. Potash, 835 
So. 2d 273, 275 (Fla. 3d DCA 2002) (Cope, J., concurring) (litigation privilege would not be a bar to a 
malicious prosecution action); North Star Capital Acquisitions, LLC v. Krig, 611 Fed. Supp. 2d 1324 
(M.D. Fla. 2009) ("However, not every event bearing any relation to litigation is protected by the 
privileged because, ... "if the litigation privilege applied to all actions preliminary to or during judicial 
proceedings, an abuse of process claim would never exist, nor would a claim for malicious prosecution"); 
Cruz v. Ange/ides, 574 So. 2d 278 (Fla. 3d DCA 1991)("the law is well settled that a witness in a judicial 
proceeding, ... is absolutely immune from any civil liability, save perhaps malicious prosecution, for 
testimony or other sworn statements which he or she gives in the course of the subject proceeding."); 
Johnson v. Libow, 2012 WL 4068409 (Fla. 15th Jud. Cir. March 1, 2012)(the purpose of the litigation 
privilege does not preclude the tort of malicious prosecution). 
In Wright v. Yurko supra, the Fifth District Court of Appeal rejected the application of the 
litigation privilege to a malicious prosecution action brought by a physician against his patients and an 
expert after he successful...

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Case No.: 502009CA040800XXXXMBAG 
Edwards' Opposition to Epstein's Motion for Summary Judgment 
Page 9 of 15 
which might otherwise apply to a defamation claim for statements made during the course of a judicial 
proceeding did not bar a malicious prosecution claim. 
In light of the implicit recognition by the Supreme Court in Levin that a claim of malicious 
prosecution is not barred by the litigation privilege - an implicit recognition acknowledged by the Third 
District itself - Epstein's reliance on Wolfe is misplaced. Wolfe is also factually distinguishable from 
Edwards' claims against Epstein. 
Wolfe involved a malicious prosecution action against attorneys. 
Separate policy considerations might serve to impose additional limitations on the assertion of malicious 
prosecution claims against attorneys - against whom alternative remedies exist such as bar disciplinary 
proceedings. See Taylor v. McNichols, 243 P.2d 642 (Idaho 2010). Moreover, in light of the decisions in 
W,·ight v. Yurko, supra and Olson v. Johnson, supra, the weight of authority supports the proposition that 
the litigation privilege would not apply to malicious prosecution claims. 
Both the Third and Fourth Districts have applied the litigation privilege to abuse of process 
claims. However, Wolfe itself, and the decisions of the Third and Fourth Districts cited in Wolfe, 
involved the litigation privilege as applied to claims of abuse of process by attorneys. None of the cases 
involved the extraordinary actions of an individual party like Epstein who carried out a course of action 
against Plaintiffs counsel with a singular purpose unrelated to any legitimate judicial goal. Under the 
compelling facts of this case, where the actions of Epstein are coupled with the elements of malice and 
absence of probable cause arising from the unfounded filing of the claims against Edwards, the litigation 
privilege should not have any applicability to the abuse of process claim ass...

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Case No.: 502009CA040800XXXXMBAG 
Edwards' Opposition to Epstein's Motion for Summary Judgment 
Page 10 of 15 
Flea Mkt., 36 So. 3d 909, 917 (Fla. 4th DCA 2010)(citation omitted). The case law is clear that on an 
abuse of process claim a "plaintiff must prove that the process was used for an immediate purpose other 
than that for which it was designed." Id. (citation omitted). Where the actions taken by a party in a 
particular lawsuit are designed to coerce another into taking some collateral action not properly involved 
in the proceeding a claim of abuse of process is stated. Miami Herald Publishing Company v. Ferre, 
8636 F. Supp. 970 (S.D. Fla. 1985). 
In a case for abuse of process, the question of whether the plaintiffs case satisfies the requisite 
elements is largely a question for a jury. See Patrick John McGinley, 21 Fla. Prac., Elements of an Action 
§ 50:1 (2013-2014 ed.)(citing Gatto v. Publix Supermarket, Inc., 387 So. 2d 377 (Fla. 3d DCA 1980)). 
The usual case of abuse of process involves some form of extortion. Scozari v. Barone, 546 So. 
2d 750, 751(Fla. 3d DCA 1989) (citing Rothmann v. Harrington, 458 So. 2d 1163, 1169 (Fla. 3d DCA 
1984)). That is exactly what has transpired here. Epstein employed the extraordinary financial resources at 
his disposal to intimidate his molestation victims and Edwards into abandoning their legitimate claims or 
resolving those claims for substantially less than their just and reasonable value. Consequently, since 
Epstein's sole purpose and ulterior motive for filing the complaint without probable cause was in an effort 
to extort, to wit: to force his molestation victims and Edwards to settle for minimal amounts, that filing 
and everything subsequently done to pursue the claims constitutes an abuse of process. See Exhs. A at 18-
27, C at 4-7. Because Edwards has conclusively demonstrated that Epstein's actions in pursuing his 
claims were designed to coerce Edwards (and his client) to take...

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Case No.: 502009CA040800XXXXMBAG 
Edwards' Opposition to Epstein's Motion for Summary Judgment 
Page 11 oflS 
claim for abuse of process have been satisfied. This case, then, falls within the parameters of the Third 
District's Decision in Scozari v. Barone, supra in which the court reversed the entry of summary 
judgment for the defendant on claims of malicious prosecution and abuse of process. With respect to the 
abuse of process claim, the court stated that "if there was no reasonable basis in law and fact to bring the 
action to impress a lien on property, and this was done without any reasonable justification under law and 
to force or compel the appellant to resolve some custody dispute, induce the appellant to pay money, or 
tie up the appellant's property, then there has been an abuse of process." Id at 752. 
There are Disputed Issues of Fact Precluding Summary Judgment on the Claim of 
Malicious Prosecution 
Here, Epstein's voluntary dismissal of his abuse of process claims against Edwards amounted to a 
bona fide tennination of the proceedings. He knew his allegations were unsupported by evidence (See 
discussion above at pages 3-6). Knowing he lacked any verifiable evidence against Edwards, on the eve 
of the summary judgment hearing, Epstein effectively conceded that fact by voluntarily dismissing his 
claims. Hence, it is evident that Epstein took volunta.ry dismissal of his claims because he knew he did 
not have probable cause or an evidentiary basis to support the allegations. See Cohen v. Corwin, 980 So. 
2d 1153 at 1156 (citing Union Oil of California, Amsco Division v. Watson, 468 So. 2d 349 at 354 
(stating that "where a dismissal is taken because of insufficiency of the evidence, the requirement of a 
favorable termination is met")). Accordingly, the manner of termination reflects on the merits of the case 
and there was a bona fide tennination of Epstein's civil proceeding against Edwards (See Judge Crow's 
Order of March ...

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Case No.: 502009CA040800XXXXMBAG 
Edwards' Opposition to Epstein's Motion for Summary Judgment 
Page 12 of15 
reliance on public filings, including the Scherer Complaint against Rothstein is unavailing. As discussed 
above, the evidence warrants the finding that Epstein knew that Edwards was legitimately pursuing the 
claims on behalf of his clients which included the effort to secure testimony from Epstein's close 
confidants. Therefore, Epstein cannot rely upon the referenced public documents to support his claims 
against Edwards given that he knows that information to be untrue and he refuses to answer questions 
about the veracity of the information. See Exh. G at pgs. 53:6-24; 78:16-24; 87:20-88:14. Consequently, 
Epstein had no good faith basis to rely on such infonnation. 
Epstein's Assertion of his Fifth Amendment Privilege Gives Rise to Adverse Inferences 
Pertinent to His Motion for Summary Judgment and Precludes His Reliance on Purported 
Undisputed Facts 
As discussed above, Epstein's multiple invocations of his Fifth Amendment Privilege results in 
adverse inferences which directly impact the issues advanced in his Motion for Summary Judgment. "It 
is well settled that the Fifth Amendment does not forbid adverse inferences against parties to civil actions 
when they refuse to testify in response to probative evidence offered against them." 
Baxter v. 
Palmigiano, 425 U.S. 308, 318 (1976); Accord, Vasquez v. State, 777 So. 2d 1200, 1203 (Fla. at 2001). 
The reason for this rule "is both logical and utilitarian. A party may not trample upon the rights of others 
and then escape the consequences by invoking a constitutional privilege - at least not in a civil setting." 
Fraser v. Security and INV. Corp, 615 So. 2d. 841, 842 (Fla. 4th DCA 1993). The adverse inferences 
drawn from Epstein's assertion of the Fifth Amendment undercut his claim of justifiable reliance based 
upon the purported undisputed material facts to support his Motio...

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Case No.: 502009CA040800:XXXXMBAG 
Edwards' Opposition to Epstein's Motion for Summary Judgment 
Page 13 ofl5 
arguments advanced in support of his Motion for Summary Judgment. Under the well-established "sword 
and shield" doctrine, Epstein could not seek damages from Edwards while at the same time asserting a 
Fifth Amendment privilege to block relevant discovery. See Exhs. Bat 14-21, Cat 18-25, G at 53:6-24; 
78:16-24; 87:20-88:14. The same policies which underlie the sword and shield doctrine as applied to the 
recovery of affirmative relief should also apply to attempts to advance positions with respect to a Motion 
for Summary Judgment which would have the effect of securing relief against certain claims. 
"[T}he law is well settled that a plaintiff is not entitled to both his silence and his lawsuit." Boys 
& Girls Clubs of Marion County, Inc. v. JA., 22 So. 3d 855, 856 (Fla. 5th DCA 2009)(Griffin, J., 
concurring specially). Thus, "a person may not seek affirmative relief in a civil action and then invoke the 
fifth amendment to avoid giving discovery, using the fifth amendment as both a 'sword and a shield."' 
DePalma v. DePalma, 538 So. 2d 1290, 1290 (Fla. 4th DCA 1989)(quoting Delisi v. Bankers Insurance 
Co., 436 So. 2d 1099 (Fla. 4th DCA 1983)). Put another way, "[a} civil litigant's fifth amendment right to 
avoid self-incrimination may be used as a shield but not a sword. This means that a plaintiff seeking 
affirmative relief in a civil action may not invoke the fifth amendment and refuse to comply with the 
defendant's discovery requests, thereby thwarting the defendant's defenses." Rollins Burdick Hunter of 
New York, Inc. v. Euroclassic Limited, Inc., 502 So. 2d 959 (Fla. 3d DCA 1983) .. For the same reasons, 
Epstein should be precluded from advancing arguments based on purported statements of undisputed fact 
which cannot be effectively challenged in light of his assertion of the Fifth Amendment. 
Epstein has 
done precisely...

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Case No.: 502009CA040800XXXXMBAG 
Edwards' Opposition to Epstein's Motion for Summary Judgment 
Page 14 of 15 
I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E-Serve to all 
. 
.,;. 
Counsel on the attached list, this 
/ / 
day ofc::;J f?-vlv, 
, 2014. 
WILLIAMB.KING / 
Florida Bar No.: 181773 
Attorney E-Mail: wbk@searcylaw.com and 
kar@searcylaw.com 
Primary E-Mail: eservice@searcylaw.com 
Secondary E-Mail: _ScarolaTeam@searcylaw.com 
Searcy Denney Scarola Barnhart & Shipley, P.A. 
2139 Palm Beach Lakes Boulevard 
West Palm Beach, Florida 33409 
Phone: (561) 686-6300 
Fax: 
(561) 383-9456 
Attorney for Bradley J. Edwards 

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Case No.: 502009CA040800:XXXXMBAG 
Edwards' Opposition to Epstein's Motion for Summary Judgment 
Page 15 ofl5 
COUNSEL LIST 
William Chester Brewer, Esquire 
wcblaw@aol.com; wcbcg@aol.com 
250 S Australian Avenue, Suite 1400 
West Palm Beach, FL 33401 
Phone: (561)-655-4777 
Fax: (561)-835-8691 
Attomeys for Jeffrey Epstein 
Jack A. Goldberger, Esquire 
jgoldberger@agwpa.com; 
smahoney@agwpa.com 
Atterbury, Goldberger & Weiss, P.A. 
250 Australian Avenue South, Suite 1400 
West Palm Beach, FL 33401 
Phone: (561)-659-8300 
Fax: (561)-835-8691 
Attomeys for Jeffrey Epstein 
Bradley J. Edwards, Esquire 
staff.efile@pathtojustice.com 
Fanner, Jaffe, Weissing, Edwards, Fistos & 
Lelmnan,FL 
425 North Andrews A venue, Suite 2 
Fort Lauderdale, FL 33301 
Phone: (954)-524-2820 
Fax: (954)-524-2822 
Attorneys for Jeffrey Epstein 
Fred Haddad, Esquire 
Dee@FredHaddadLaw .corn; 
haddadfm@aol.com; fred@fredhaddadlaw.com 
Fred Haddad, P.A. 
One Financial Plaza, Suite 2612 
Fort Lauderdale, FL 33394 
Phone: (954)-467-6767 
Fax: (954)-467-3599 
Attorneys for Jeffrey Epstein 
Marc S. Nurik, Esquire 
marc@nuriklaw.com 
Law Offices of Marc S. Nurik 
One E Broward Blvd., Suite 700 
Fort Lauderdale, FL 33301 
Phone: (954)-745-5849 
Fax: (954)-745-3556 
Attomeys for Scott Rothstein 
Tonja Haddad Coleman, Esquire 
tonja@tonjahaddad.com; 
Debbie@Tonjahaddad.com; 
efiling@tonjahaddad.com 
Tonja Haddad, P.A. 
315 SE 7th Street, Suite 301 
Fort Lauderdale, FL 3330 l 
Phone: (954)-467-1223 
Fax: (954)-337-3716 
Attorneys for Jeffrey Epstein 

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JEFFREY EPSTEIN, 
Plaintiff, 
vs. 
SCOTT ROTHSTEIN, individually, and 
BRADLEY J. EDWARDS, individually, 
Defendants, 
I 
--------------~ 
IN THE CIRCUIT COURT OF THE 15TH 
JUDICIAL CIRCUIT IN AND FOR PALM 
BEACH COUNTY, FLORIDA 
Case No.:50 2009 CA 040800XXXXMBAG 
STATEM:ENT OF UNDISPUTED FACTS 
Defendant Bradley J. Edwards, Esq., offers the following specific facts as the undisputed 
material facts in this case. Each of the following facts is numbered separately and individually to 
facilitate Epstein's required compliance with Fla. R. Civ. P. 1.510(c) ("The adverse party shall 
identify ... any _summary judgment evidence on which the adverse party relies."). 
All 
referenced exhibits and attachments have previously been filed with the Court and provided to 
Epstein. 
Sexual Abuse of Children By Epstein 
1. 
Defendant Epstein has a sexual preference for young children. Deposition of 
Jeffrey Epstein, Mar. 17, 2010, at 110 (hereinafter "Epstein Depa.") (Deposition Attachment 
#1).1 
1 When questioned about this subject at his deposition, Epstein invoked his Fifth Amendment right to 
remain silent rather than make an incriminating admission. Accordingly, Edwards is entitled to the 
adverse inference against Epstein that, had Epstein answered, the answer would have been unfavorable to 
him. "[I]t is well-settled that the Fifth Amendment does not o "d adverse inferences against parties to 
EXHIBIT 
A 

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2. 
Epstein repeatedly sexually assaulted more than forty (40) young girls on 
numerous occasions between 2002 and 2005 in his mansion in West Palm Beach, Florida. These 
sexual assaults incl:uded vaginal penetration. Epstein abused many of the girls dozens if not 
hundreds of times. Epstein Depo. at 109 ("Q: How many times have you engaged in oral sex 
with females under the age of 18?" A: [Invocation of the Fifth Amendment]); Deposition of Jane 
Doe, September 24, 2009 and continued March 11, 2010, at 527 (minor girl sexually abused at 
least 17 times by Epstein) (hereinafter "Jane Doe Depo") (Deposition Attachment #2); id. 564-67 
(vaginal penetration by Epstein with his finger), 568 (vaginal penetration by Epstein with a 
massager); Deposition of L.M., September 24, 2009, at 73 (hereinafter "L.M. Depo") 
(Deposition Attachment #3) ( describing the manner in which Epstein abused her beginning when 
LM was 13 years old, touching her vagina with his fingers and vibrator) at 74, line 12-13 (she 
was personally molested by Epstein more than 50 times), at 164, line 19-23 and 141, line 12-13 
and 605, line 3-6 (describing that in addition to being personally molested by Epstein she was 
paid $200 per underage girl she brought Epstein and she brought him more than seventy (70) 
underage girls - she told him that she did not want to bring him any more girls and he insisted 
that she continue to bring him underage girls); Deposition of E.W., May 6, 2010 (hereinafter 
"E.W. Depo") (Deposition Attachment #4) at 115-116, 131 and 255 (describing Epstein's abuse 
of her beginning at age 14 when he paid her for touching her vagina, inserting his fingers and 
civil actions when they refuse to testify in response to probative evidence offered against them." Baxter 
v. Palmigiano, 425 U.S. 308, 318 (1976); accord Vasquez v. State, 777 So.2d 1200, 1203 (Fla. App. 
2001). The reason for this rule "is both logical and utilitarian. A party may not trample upon the...

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using a vibrator and he also paid her $200 for each other underage female E.W. brought him to 
molest. She brought him between 20 and 30 underage females); Deposition of Jane Doe #4, date 
(hereinafter "Jane Doe #4 Depo") (Deposition Attachment #5) at 32-34, and 136 (she describes 
first being taken to Epstein at 15 years old, "Being fingered by him, having him use a vibrator on 
[me], grabbing my nipples, smelling my butt, jerking off in front ofme, licking my clit, several 
times."). 
3. 
At all relevant times Edwards has had a good faith basis to conclude and did 
conclude2 that Epstein was able to access a large number of underage girls through a pyramid 
abuse scheme in which he paid underage victims $200-$300 cash for each other underage victim 
that she brought to him. See Palm Beach Police Incident Report at 87 (hereinafter «Incident 
Report") (Exhibit "A").3 The Palm Beach Police Incident Report details Epstein's scheme for 
molesting underage females. Among other things, the Incident Report outlines some of the 
experiences of other Epstein victims. When S.G, a 14 year old minor at the time, was brought to 
Epstein's home, she was taken upstairs by a woman she believed to be Epstein's assistant. The 
woinan started to fix up the room, putting covers on the massage table and bringing lotions out. 
The "assistant" then left the room and told S.G. that Epstein would be up in a second. Epstein 
walked over to S.G. and told her to take her clothes off in a stem voice. S.G. states in the report 
she did not know what to do, as she was the only one there. S.G. took off her shirt, leaving her 
bra on. Epstein, then in a towel told her to take off everything. S.G. removed her pants leaving 
2 In support of all assertions concerning the actions Edwards took, what Edwards learned in the course of his 
representation of his clients, Edwards's good faith beliefs and the foundation for those beliefs, see Edwards 
Affidavit and specifically paragraph...

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on her thong panties. Epstein then instructed S.G to give him a massage. As S.G gave Epstein a 
massage, Epstein turned around and masturbated. S.G. was so disgusted, she did not say 
anything; Epstein told her she "had a really hot body." Id. at 14. In the report, S.G. admitted 
seeing Jeffrey Epstein's penis and stated she thought Epstein was on steroids because be was a 
"really built guy and his wee wee was very tiny." Id. at 15. 
4. 
The exact number of minor girls who Epstein assaulted is known only to Epstein. 
However, Edwards had a good faith basis to believe and did in fact believe that Epstein's victims 
were substantially more than forty ( 40) in number. In addition to the deposition excerpts from 
two of his many victims above about the number of underage girls brought to Epstein and the 
Palm Beach incident report, there is overwhelming proof that the number of underage girls 
molested by Epstein through his scheme was in the hundreds. See Complaint, Jane Doe 102 v. 
Epstein, (hereinafter Jane Doe 102 complaint) (Exhibit "B''); see also Deposition of Jeffrey 
Epstein, April 14, 2010, at 442, 443, and 444 (Epstein invoking the 5th on questions about his 
daily abuse and molestation of children) (Deposition Attachment #6). 
5. 
At all relevant times Edwards has had a good faith basis to believe and did in fact 
believe that Epstein and his attorneys knew of the seriousness of the criminal investigation 
against him and corresponded constantly with the United States Attorney's Office in an attempt 
to avoid the filing of numerous federal felony offenses, which effort was successful. 
See 
Correspondence from U.S. Attorney's Office to Epstein (hereinafter "U.S. Attorney's 
Correspondence") (Composite Exhibit "C) (provided in discovery during the Jane Doe v. Epstein 
case). 
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6. 
At all relevant times Edwards has had a good faith basis to believe and did in fact 
believe that, more specifically, Epstein's attorneys lmew of Epstein's scheme to recruit minors for 
sex and also lmew that these minors had civil actions that they could bring against him. In fact, 
there was much co:rnmunication between Epstein's attorneys and the United States Prosecutors in 
a joint attempt to minimize Epstein's civil exposure. For example, on October 3, 2007, Assistant 
U.S. Attorney Marie Villafana sent an email (attached hereto as Exhibit "D") to Jay Lefkowitz, 
counsel for Epstein, with attached proposed letter to special master regarding handling numerous 
expected civil claims against Epstein. The letter reads in pertinent part, 
"The undersigned, as counsel for the United States of America and 
Jeffrey Epstein, jointly write to you to provide information relevant to your 
service as a Special Master in the selection of an attorney to represent several 
young women who may have civil damages cli;iims against Mr. Epstein. The 
U.S. Attorney's Office and the Federal Bureau of Investigation (jointly referred 
to as the "United States") have conducted an investigation of Jeffrey Epstein 
regarding his solicitation of minor females in Palm Beach County to engage in 
prostitution. 
Mr. Epstein, through his assistants, would recruit underage 
females to travel to his home in Palm Beach to engage in lewd conduct in 
exchange for money. Based upon the investigation, the United States has 
identified forty ( 40) young women who can be characterized as victims 
pursuant to 18 USC 2255. Some of those women went to Mr. Epstein's home 
only once, some went there as much as 100 times or more. Some of the 
women's conduct was limited to performing a topless or nude massage while 
Mr. Epstein-masturbated himself. For other women, the conduct escalated to 
full sexual intercourse. As part of the resolution of the case, Epstein has 
agreed that he wo...

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minor females that the United States Attorney's Office recognized as a victim. L.M. 's sworn 
deposition testimony and the adverse inference drawn from Epstein's refusal to testify confirm 
that Epstein began sexually assaulting L.M. when she was 13 years old and continued to molest 
her on more than fifty (50) occasions over three (3) years. Epstein Depa., Attachment #1, at 17 
("Q: Did you ... ever engage in any sexual conduct with L.M.?" A: [Invocation of the Fifth 
Amendment].); see also Epstein Depa., April 14, 2010, Attachment #6, at 456 ("Q: LM was an 
underage female that you first abused when she was 13 years old; is that correct?" A: [Invocation 
of Fifth Amendment].) . 
8. 
Epstein was also given ample opportunity to explain why he engaged in sexual 
activity with L.M. beginning when L.M. was 13 years old and why he has molested minors on an 
everyday basis for years, and he invoked his 5th amendment right rather than provide 
explanation. 
See Epstein Deposition, February 17, 2010, at 11-12, 30-31 (Deposition 
Att~chment # 7). 
9. 
Epstein also sexually assaulted E.W., beginning when she was 14 years old and 
did so on numerous occasions. See E.W. Depa., Attaclnnent #4 at 215-216. 
10. 
Another of the minor girls Epstein sexually assaulted was Jane Doe; the abuse 
began when Jane Doe was 14 years old. Rather than incriminate himself, Epstein invoked the 
5th amendment to questions about him digitally penetrating Doe's vagina, using vibrators on her 
vagina and masturbating and ejaculating in her presence. 
Epstein Depa., April 14, 2010, 
Attachment #6, at 420, 464, 468. 
11. 
When Edwards's clients L.M., E.W., and Jane Doe were 13 or 14 years old, each 
was brought to Epstein's home multiple times by another underage victim. Epstein engaged in 
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one or more of the following acts with each of the then-minor girls at his mansion: receiving a 
topless or completely nude massage; using a vibrator on her vagina; masturbating in her 
presence; ejaculating in her presence; touching her breast or buttocks or vagina or the clothes 
covering her sexual organs; and demanding that she bring him other underage girls. Epstein and 
his co-conspirators used the telephone to contact these girls to entice or induce them into going 
to his mansion for sexual abuse. Epstein also made E.W. perform oral sex on him and was to 
perform sex acts on Nadia Marcinkova (Epstein's live-in sex slave) in Epstein's presence. See 
Plaintiff Jane Doe's Notice Regarding Evidence of Similar Acts of Sexual Assault, filed in Jane 
Doe v. Epstein, No. 08-cv-80893 (S.D. Fla. 2010), as DE 197, (hereinafter "Rule 413 Notice") 
(Exhibit "E"); Jane Doe Depa., Attachment #2, at 379-380; L.M. Depa., Attachment #3, at 416; 
E.W. Depa, Attachment #4, at 205. 
12. 
At all relevant times Edwards has had a good faith basis to believe and did in fact 
believe that yet another of the minor girls Epstein sexually assaulted was C.L. When she was 
approximately 15 years old, C.L. was brought to Epstein's home by another underage victim. 
While a minor, she was at Epstein's home on multiple occasions. Epstein engaged in one or 
more of the following acts with her while she was a minor at his house - topless or completely 
nude massage on Epstein; Epstein used a vibrator on her vagina; Epstein masturbated in her 
presence; Epstein ejaculated in her presence; Epstein also demanded that she bring him other 
underage girls. See Rule 413 Notice, Exhibit "E"; Incident Report, Exhibit "A." 
13. 
At all relevant times Edwards has had a good faith basis to believe and did in fact 
believe that yet another girl Epstein sexually assault was A.H. When she was approximately 16 
years old, she was brought to Epstein's home by another underage victim. While ...

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was at Epstein's home on multiple occasions. Epstein engaged in one or more of the following 
acts with her while she was a minor at his house - topless or completely nude massage on 
Epstein; Epstein used a vibrator on her vagina; Epstein masturbated in her presence; Epstein 
ejaculated in her presence; Epstein touched her breast or buttock or vagina or the clothes 
covering her sexual organs; was made to perform sex acts on Epstein; made to perform sex acts 
on Nadia Marcinkova in Epstein's presence. Epstein also forcibly raped this underage victim, as 
he held her head down against her will and pumped his penis inside her while she was screaming 
"No". See Rule 413 Notice, Exhibit "E"; Incident Repmi, Exhibit "A", at 41 (specifically 
discussing the rape): 
"[A.H.] remembered that she climaxed and was removing herself from the 
massage table. [A.H.] asked for a sheet of paper and drew the massage table in the 
master bathroom and where Epstein, Marcinkova and she were. Epstein turned 
[A.H.] on to her stomach on the massage bed and inserted his penis into her 
vagina. [A.H.] stated Epstein began to pump, his penis in her vagina. [A.H.] 
became upset over this. She said her head was being held against the bed forcibly, 
as he continued to pump inside her. She screamed no, and Epstein stopped .... " 
"[A.H.] advised there were times that she was so sore when she left Epstein's 
house. [A.H.] advised she was ripped, torn, in her vagina area. [A.H.] advised she 
had difficulty walking to the car after leaving the house because she was so sore." 
14. 
Without detailing each fact known about Epstein's abuse of the many underage 
girls, Edwards has had a good faith basis to believe and did in fact believe at all relevant times 
that Epstein also abused other victims in ways closely similar to those described in the preceding 
paragraphs. Epstein's additional victims include the following (among many other) young girls: 
S.G.; A.D.; V.A.; N.R.; J.S.;...

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15. 
One of Mr. Epstein's household employees, Mr. Alfredo Rodriguez, saw 
numerous underage girls coming into Epstein's mansion for purported "massages." 
See 
Rodriguez Depa. at 242-44 (Deposition Attachment #8). Rodriguez was aware that "sex toys" 
and vibrators were found in Epstein's bedroom after the purported massages. Id. at 223-28. 
Rodriguez thought what Epstein was doing was wrong, given the extreme youth of the girls he 
saw. Id. at 230-31.. 
16. 
Alfredo Rodriguez took a journal from Epstein's computer that reflected many of 
the names of underage females Epstein abused across the country and the world, including 
locations such as Michigan, California, West Palm Beach, New York, New Mexico, and Paris, 
France. See Journal (hereinafter "The Journal" or "Holy Grail") (Exhibit "F") (identifying, 
among other Epstein acquaintances, females that Rodriguez believes were underage under the 
heading labeled "Massages"). 
17. 
Rodriguez was later charged in a criminal complaint with obstruction of justice in 
connection with trying to obtain $50,000 from civil attorneys pursuing civil sexual assault cases 
against Epstein as payment for producing the book to the attorneys. See Criminal Complaint at 
2, U.S. v. Rodriguez, No. 9:10-CR-80015-KAM (S.D. Fla. 2010) (Exhibit "G"). Rodriguez 
stated he needed money because the journal was his "property" and that he was afraid that 
Jeffrey Epstein would make him "disappear" unless he had an "insurance policy" (i.e., the 
journal). Id. at 3. Because of the importance of the information in the journal to the civil cases, 
Mr. Rodriguez called it "The Holy Grail." 
18. 
In the "Holy Grail" or "The Journal," among the many names listed (along with 
the abused girls) are some of the people that Epstein alleges in his Complaint had "no connection 
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whatsoever" with the litigation in this case. See, e.g., Journal, Exhibit F, at 85 (Donald Trump); 
at 9 (Bill Clinton phone numbers listed under "Doug Bands"). 
Federal Investigation and Plea Agreement With Epstein 
19. 
In approximately 2005, the FBI and the U.S. Attorney's Office in the Southern 
District of Florida learned of Epstein's repeated sexual abuse of minor girls. They began a 
criminal investigation into federal offenses related to his crimes. 
See U.S. Attorney's 
Correspondence, Exhibit "C". 
20. 
At all relevant times Edwards has had a good faith basis to believe and did in fact 
believe that to avoid the Government learning about his abuse of minor girls, Epstein threatened 
his employees and demanded that they not cooperate with the government. Epstein's aggressive 
witness tampering was so severe that the United States Attorney's Office prepared negotiated 
plea agreements containing these charges. For example, in a September 18, 2007, email from 
AUSA Villafafia to Lefkowitz (attached hereto as Exhibit "H"), she attached the proposed plea 
agreement describing Epstein's witness tampering as follows: 
"UNITED STATES vs. JEFFREY EPSTEIN PLEA PROFFER" 
On August 21, 2007, FBI Special Agents E. Nesbitt Kuyrkendall and Jason 
Richards traveled to the home of Leslie Groff to serve her with a federal grand 
jury subpoena with an investigation pending in the Southern District of Florida. 
Ms. Groff works as the personal assistant of the defendant. Ms. Groff began 
speaking with the agents and then excused herself to go upstairs to check on her 
sleeping child. 
While upstairs, Ms. Groff telephoned the defendant, Jeffrey 
Epstein, and informed him that the FBI agents were at her home. Mr. Epstein 
instructed Ms. Groff not to speak with the agents and reprimanded her for 
allowing them into her home. Mr. Epstein applied pressure to keep Ms. Groff 
from complying with the grand jury subpoenas that the agents had served upon 
her. In pa...

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appearance before the grand jury in the Southern District of Florida. 
This 
conversation occurred when Mr. Epstein was aboard his privately owned civilian 
aircraft in Miami in the Southern District of Florida. His pilot had filed a flight 
plan showing the parties were about to return to Teterboro, NJ. 
After the 
conversation with Ms. Groff, Mr. Epstein became concerned that the FBI would 
try to serve his traveling companion, Nadia Marcinkova, with a similar grand jury 
subpoena. In fact, the agents were preparing to serve Ms. Marcinkova with a 
target letter when the flight landed in Teterboro. Mr. Epstein then redirected his 
airplane, making the pilot file a new flight plan to travel to the US Virgin Islands 
instead of the New York City area, thereby keeping the Special Agents from 
serving the target letter on Nadia Marcinkova., During the flight, the defendant 
verbally harassed Ms. Marcinkova, harassing and pressuring her not to cooperate 
with the grand jury's investigation, thereby hindering and dissuading her from 
reporting the commission of a violation of federal law to a law enforcement 
officer, namely, Special Agents of the FBI. Epstein also threatened and harassed 
Sarah Kellen against cooperating against hini as well. 
21. 
Edwards learned that the Palm Beach police department investigation ultimately 
led to the execution of a search warrant at Epstein's mansion in October 2005. See Police 
Incident Report, Exhibit "A". 
22. 
Edwards learned that at around the same time, the f alm Beach Police Department 
also began investigating Epstein's sexual abuse of minor girls. They also collected evidence of 
Epstein's involvement with minor girls and his obsession with training sex slaves, including 
pulling information'from Epstein's trash. Their investigation showed that Epstein ordered from 
Amazon.com on about September 4, 2005, such books as: SMlOl: A Realistic Introduction, by 
Jay Wiseman; SlaveCraft: Roadmaps for Erotic Ser...

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Edwards with some insight into how far-reaching Epstein's power was and how addicted Epstein 
was to sex with children. See Incident Report, Exhibit "A". 
24. 
The Palm Beach Police Department also collected Epstein's message pads, which 
provided other nariies of people that also knew Epstein's scheme to molest children. 
See 
Message Pads (Exhibit "J") (note: the names of underage females have been redacted to protect 
the anonymity of the underage sex abuse victims). Those message pads show clear indication 
that Epstein's staff was frequently working to schedule multiple young girls between the ages of 
12 and 16 years old literally every day, often two or three times per day. Id. 
25. 
In light of all of the information of numerous crimes committed by Epstein, 
Edwards learned that the U.S. Attorney's Office began preparing the filing of federal criminal 
charges against Epstein. 
For example, in addition to the witness tampering and money 
laundering charges the U.S. Attorney's Office prepared an 82-page prosecution memo and a 53-
page indictment of Epstein related to his sexual abuse of children. On September 19, 2007, at 
12:l4 PM, AUSA Villafana wrote to Epstein's counsel, Jay Lefkowitz, "Jay - I hate to have to be 
firm about this, but we need to wrap this up by Monday. I will not miss my indictment date 
when this has dragged on for several weeks already and then, if things fall apart, be left in a less 
advantageous position than before the negotiations. I have had an 82-page pros memo and 53-
page indictment sitting on the shelf since May to engage in these negotiations. There has to be 
an ending date, and that date is Monday." These and other communications are within the 
correspondence attached as Composite Exhibit "C." 
26. 
Edwards learned that rather than face the filing of federal felony criminal charges, 
Epstein (through his attorneys) engaged in plea bargain discussions. 
As a result of those 
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discussions, on September 24, 2007, Epstein signed an agreement with the U.S. Attorney's 
Office for the Southern District of Florida. Under the agreement, Epstein agreed to plead guilty 
to an indictment pending against him in the 15th Judicial Circuit in and for Palm Beach County 
charging him with solicitation of prostitution and procurement of minors for prostitution. 
Epstein also agreed that he would receive a thirty month sentence, including 18 months of jail 
time and 12 months of community control. In exchange, the U.S. Attorney's Office agreed not to 
pursue any federal charges against Epstein. See Non-Prosecution Agreement (Exhibit "K"). 
27. 
Part of the Non-Prosecution Agreement that Epstein negotiated was a provision in 
which the federal government agreed not to prosecute Epstein's co-conspirators. 
The co-
conspirators procured minor females to be molested by Epstein. One of the co-conspirators -
Nadia Marcink:ova -even participated in the sex acts with minors (including E.W.) and Epstein. 
See Incident Report, Exhibit "A", at 40-42, 49-51; Deposition of Nadia Marcink:ova, April 13, 
2010, (hereinafter "Marcink:ova Depo.") at 11 (Deposition attachment #9). 
28. 
Under the Non-Prosecution Agreement, Epstein was to use his "best efforts" to 
enter into his guilty pleas by October 26, 2007. However, Edwards learned that Epstein violated 
his agreement with the U.S. Attorney's Office to do so and delayed entry of his plea. See Letter 
from U.S. Attorney R. Alexander Acosta to Lilly Ann Sanchez, Dec. 19, 2007 (Exhibit "L"). 
29. 
On January 10, 2008 and again on May 30, 2008 E.W. and L.M. received letters 
from the FBI advising them that "[t]his case is currently under investigation. This can be a 
lengthy process and we request your continued patience while we conduct a thorough 
investigation." Letters attached at Composite Exhibit "M". This document is evidence that the 
FBI did not notify E.W. and L.M. that a plea agreement had al...

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block federal prosecution of Epstein. Nor did the FBI notify E.W. and L.M. of any of the parts of 
the plea agreement. Nor did the FBI or other federal authorities confer with E.W. and L.M. 
about the plea. See id. 
30. 
In 2008, Edwards believed in good faith that criminal prosecution of Epstein was 
extremely important to his clients E.W. and L.M. and that they desired to be consulted by the 
FBI and/ or other representatives of the federal government about the prosecution of Epstein. 
The letters that they had received around January 10, 2008, suggested that a criminal 
invesJigation of Epstein was on-going and that they would be contacted before the federal 
government reached any final resolution of that investigation. See id. 
Edwards Agrees to Serve as Legal Counsel for Three Victims of Epstein's Sexual 
Assaults 
31. 
In about April 2008, Bradley J. Edwards, Esq., was a licensed attorney in Florida, 
practicing as a sole practitioner. As a former prosecutor, he was well versed in civil cases that 
involved criminal acts, including sexual assaults. Three of the many girls Epstein had abused -
L.M., E.W., and Jane Doe - all requested that Edwards represent them civilly and secure 
appropriate monetary damages against Epstein for repeated acts of sexual abuse while they were 
minor girls. 
Two of the girls (L.M. and E.W.) also requested that Edwards represent them in 
connection with a concern that the Federal Bureau of Investigation (FBI) and U.S. Attorney's 
Office might be arranging a plea bargain for the criminal offenses committed by Epstein without 
providing them the _legal rights to which they were entitled (including the right to be notified of 
plea discussions and the right to confer with prosecutors about any plea arrangement). 
See 
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Affidavit of Bradley J. Edwards, Esq. at ifl - 2, if4 (hereinafter "Edwards Affidavit") (Exhibit 
"N"). 
32. 
On June 13, 2008, attorney Edwards agreed to represent E.W.; on July 2, 2008, 
attorney Edwards agreed to represent Jane Doe; and, on July 7, 2008, attorney Edwards agreed to 
represent L.M. in connection with the sexual assaults committed by Epstein and to insure that 
their rights as victims of crimes were protected in the criminal process on-going against Epstein. 
Mr. Edwards and his three clients executed written retention agreements. See id. at ,r2. 
33. 
In mid June of 2008, Edwards contacted AUSA Villafana to inform her that he 
represented Jane Doe #1 and, later, Jane Doe #2. AUSA Villafana did not advise that a plea 
agreement had already been negotiated with Epstein's attorneys that would block federal 
prosecution. 
To the contrary, AUSA Villafana mentioned a possible indictment. 
AUSA 
Villafana did indicate that federal investigators had concrete evidence and information that 
Epstein had sexually molested many underage minor females, including E.W., LM, and Jane 
Doe. See id. at if 4. 
34. 
Edwards also requested from the U.S. Attorney's Office the information that they 
had collected regarding Epstein's sexual abuse of his clients. However, the U.S. Attorney's 
Office, declined to provide any such information to Edwards. It similarly declined to provide 
any such information to the other attorneys who represented victims of Epstein's sexual assaults. 
At the very least, this includes the items that were confiscated in the search warrant of Epstein's 
home, including dildos, vibrators, massage table, oils, and additional message pads. 
See 
Property Receipt (Exhibit "O"). 
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35. 
On Friday, June 27, 2008, at approximately 4:15 p.m., AUSA Villafana received a 
copy of Epstein's proposed state plea agreement and learned that the plea was scheduled for 8:30 
a.m., Monday, June 30, 2008. AUSA Villafana called Edwards to provide notice to his clients 
regarding the hearing. AUSA Villafana did not tell Attorney Edwards that the guilty pleas in 
state court would bring an end to the possibility of federal prosecution pursuant to the plea 
agreement. See Edwards Affidavit, Exhibit "N", at i[6. 
36. 
Under the Crime Victims' Rights Act (CVRA), 18 U.S.C. § 3771, victims of 
federal crimes - including E.W. and L.M. - are entitled to basic rights during any plea 
bargaining process; including the right to be treated with fairness, the right to confer with 
prosecutors regarding any plea, and the right to be heard regarding any plea. The process that 
was followed leading to the non-prosecution of Epstein violated these rights of E.W. and L.M. 
See Emergency Petn. for Victim's Enforcement of Crime Victim's Rights, No. 9:08-CV-80736-
KAM (S.D. Fla. 2008) (Exhibit "P"). 
37. 
Because of the violation of the CVRA, on July 7, 2008, Edwards filed an action in 
the U.S. District Court for the Southern District of Florida, Case No. 9:08-CV-80736, seeking to 
enforce the rights of E.W. and L.M. That action alleged that the U.S. Attorney's Office had 
failed to provide E.W. and L.M. the rights to which they were entitled under the Act, including 
the right to be notified about a plea agreement and to confer with prosecutors regarding it. See 
id. 
38. 
On July 11, 2008, Edwards took E.W. and L.M. with him to the hearing on the 
CVRA action. It was only at this hearing that both victims learned for the first time that the plea 
deal was already done with Epstein and that the criminal case against Epstein had been 
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effectively terminated by the U.S. Attorney's office. See Hearing Transcript, July 11, 2008 
(Exhibit "Q"). 
39. 
Edwards learned that Jane Doe felt so strongly that the plea bargain was 
inappropriate that she made her own determination to appear on a television program and 
exercise her First Amendment rights to criticize the unduly lenient plea bargain Epstein received 
in a criminal case. 
40. 
The CVRA action that Edwards filed was recently administratively closed and 
Edwards filed a Motion to reopen that proceeding. See No. 9:08--CV-80736 (S.D. Fla.). 
Epstein's Enny of Guilty Pleas to Sex Offenses 
41. 
Ultimately, on June 30, 2008, in the Fifteenth Judicial Circuit in Palm Beach 
County, Florida, defendant Epstein, entered pleas of "guilty" to various Florida state crimes 
involving the solicitation of minors for prostitution and the procurement of minors for the 
purposes of prostitution. See Plea Colloquy (Exhibit "R"). 
42. 
As a condition of that plea, and in exchange for the Federal Government not 
prosecuting the Defendant, Epstein additionally entered into an agreement with the Federal 
Government aclmowledging that approximately thirty-four (34) other young girls could receive 
payments from hi~ under the federal statute providing for compensation to victims of child 
sexual abuse, 18 U.S.C. § 2255. As had been agreed months before, the U.S. Attorney's Office 
did not prosecute Epstein federally for his sexual abuse of these minor girls. See Addendum to 
Non-Prosecution Agreement (Exhibit "S") (in redacted form to protect the identities of the 
minors involved). . 
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43. 
Because Epstein became a convicted sex offender, he was not to have contact 
with any of his victims. During the course of his guilty pleas on June 30, 2008, Palm Beach 
Circuit Court Judge Deborah Dale Pucillo ordered Epstein "not to have any contact, direct or 
indirect" with any victims. She also expressly stated that her no-contact order applied to "all of 
the victims." 
Similar orders were eritered by the federal court handling some of the civil cases 
against Epstein. The federal court stated that it "finds it necessary to state clearly that Defendant 
is under this court's order not to have direct or indirect contact with any plaintiffs .... " Order, 
Case No. 9:08-cv-80119 (S.D. Fla. 2008), [DE 238] at 4-5 (emphasis added); see also Order, 
Case No. 9:08-cv-80893, [DE 193] at 2 (emphasis added). 
Edwards Files Civil Suits Against Epstein 
44. Edwards had a good faith belief that his clients felt angry and betrayed by the 
criminal system and wished to prosecute and punish Epstein for his crimes against them in 
whatever avenue remained open to them. On August 12, 2008, at the request of his client Jane 
Doe, Brad Edwards filed a civil suit against Jeffrey Epstein to recover damages for b,is sexual 
assault of Jane Doe. See Edwards Affidavit, "N" at if7. Included in this complaint was a RICO 
count that explained how Epstein ran a criminal conspiracy to procure young girls for him to 
sex~ally abuse. See Complaint, Jane Doe v. Epstein (Exhibit "T"). 
45 .. On September 11, 2008, at the request of his client E.W., Brad Edwards filed a civil 
suit against Jeffrey Epstein to recover damages for his sexual assault of E.W. See Complaint, 
E.W. v. Epstein (Exhibit "U"). 
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46. On September 11, 2008, at the request of his client L.M .. , Brad Edwards filed a civil 
suit against Jeffrey _Epstein to recover damages for his sexual assault of L.M. See Complaint, 
L.M. v. Epstein, (Exhibit "V"). 
47. 
Jane Doe's federal complaint indicated that she sought damages of more than 
$50,000,000. Listing the amount of damages sought in the complaint was in accord with other 
civil suits that were. filed against Epstein (before any lawsuit filed by Edwards). See Complaint, 
Jane Doe #4 v. Epstein (Exhibit "W") (filed by Herman and Mermelstein, PA). 
48. At about the same time as Edwards filed his three lawsuits against Epstein, other 
civil attorneys were filing similar lawsuits against Epstein. For example, on or about April 14, 
2008 another law firm, Herman and Mermelstein, filed the first civil action against Epstein on 
behalf of one of its seven clients who were molested by Epstein. The complaints that attorney 
Hennan filed on behalf of his seven clients were similar in tenor and tone to the complaint that 
Edwards filed on behalf of his three clients. See id. 
49. Over the next year and a half, more than 20 other similar civil actions were filed by 
various attorneys against Epstein alleging sexual assault of minor girls. These complaints were 
also similar in tenor and tone to the complaint that Edwards filed on behalf of his clients. These 
complaints are all public record and have not been attached, but are available in this Court's files 
and the files of the U.S. District Court for the Southern District of Florida. 
50. In addition to the complaints filed against Epstein in Florida, a female in New York, 
Ava Cordero, filed a lawsuit against Epstein in New York making similar allegations - that 
Epstein paid her for a massage then forced her to give him oral sex and molested her in other 
ways when she was only 16 years old. Cordero was born a male, and in her complaint she 
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alleges that Epstein told her during the "massage", "I love how young you are. You have a tight 
butt like a baby". See Jeff Epstein Sued for "Repeated Sexual Assaults" on Teen, New York 
Post, 
October 
17, 
2007, 
by 
Dareh 
Gregorian, 
link 
at: 
http:/ /www.nypost.com/p/news/regional/item 44zlWyL UFH7Rl OUtKYGPbP;j sessionid=6CA3 
EBF1BEF68F5DE14BFB2CAA5C37E0. See Article attached hereto as Exhibit "X". 
51. 
Edwards's three complaints against Epstein contained less detail about sexual 
abuse than (as one example) a complaint filed by attorney Robert Josephsberg from the law firm 
of Podhurst Orseck. See Complaint, Jane Doe 102 v. Epstein (Exhibit "B"). 
As recounted in 
detail in this Complaint, Jane Doe 102 was 15 years old when Ghislaine Maxwell discovered her 
and lured her to Epstein's house. Maxwell and Epstein forced her to have sex with both of them 
and within weeks Maxwell and Epstein were flying her all over the world. According to the 
Complaint, Jane Doe 102 was forced to live as one of Epstein's underage sex slaves for years 
and was forced to have sex with not only Maxwell and Epstein but also other politicians, 
businessmen, royalty, academicians, etc. She was even made to watch Epstein have sex with 
three 12-year-old French girls that were sent to him for his birthday by a French citizen that is a 
friend of Epstein's. Luckily, Jane Doe 102 escaped to Australia to get away from Epstein and 
Maxwell's sexual abuse. 
52. 
Edwards learned that inaddition to civil suits that were filed in court against 
Epstein, at around the same time other attorneys engaged in pre-filing settlement discussions 
with Epstein. Rather than face filed civil suits in these cases, Epstein paid money settlements to 
more than 15 other women who had sexually abused while they were minors. See articles 
regarding settlements attached hereto as Composite Exhibit "Y." 
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Epstein's Obstruction of Normal Discove,y and Attacks on His Victims 
53. 
Once Edwards filed bis civil complaints for bis three clients, be began the normal 
process of discovery for cases such as these. He sent standard discovery requests to Epstein 
about bis sexual abuse of the minor girls, including requests for admissions, request for 
production, and interrogatories. See Edwards Affidavit, Exhibit "N", at ,r,r11-19 and 25. 
Rather than answer any substantive questions about bis sexual abuse and bis conspiracy for 
procuring minor gi~ls for him to abuse, Epstein invoked bis 5th amendment right against self-
incrimination. An example of Epstein's refusal to answer is attached as Composite Exhibit "Z" 
( original discovery propounded to Epstein and bis responses invoking 5th amendment). 
54. 
During the discovery phase of the civil cases filed against Epstein, Epstein's 
deposition was tak~n at least five times. During all of those depositions, Epstein refused to 
answer any substantive questions about bis sexual abuse of minor girls. See, e.g., Deposition 
Attachments 1, 6 and 7. 
55. 
During these depositions, Epstein further attempted to obstruct legitimate 
questioning by inserting a variety of irrelevant information about bis case. 
As one of 
innumerable examples, on March 8, 2010, Mr. Horowitz, representing seven victims, Jane Doe's 
2-8, asked, "Q: In 2004, did you rub Jane Doe 3's vagina? A: Excuse me. I'd like to answer that 
question, as I would like to answer mostly every question you've asked me here today; however, 
upon advice of counsel, I cannot answer that question. They've advised me I must assert my 
Sixth Amendment, Fifth Amendment and Fourteenth Amendment Rights against self--excuse 
me, against--under the Constitution. And though your partner, Jeffrey Herman, was disbarred 
after filing this lawsuit [a statement that was untrue], Mr. Edwards' partner sits in jail for 
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fabricating cases of a sexual nature fleecing unsuspecting Florida investors and others out of 
millions of dollars for cases of a sexual nature with--I'd like to answer your questions; however if 
I--I'm told that if I do so, I risk losing my counsel's representation; therefore I must accept their 
advice." Epstein deposition, March 8, 2010, at 106 (Deposition attachment #10). 
56. 
Wben Edwards bad the opportunity to take Epstein's deposition, be only asked 
reasonable questions, all of which related to the merits of the cases against Epstein. 
All 
depositions of Epstein in which Mr. Edwards participated on behalf of bis clients are attached to 
this motion. See Edwards Affidavit, Exhibit "N" at if 11 and Deposition attachments # 1, 6, 7, 10, 
11, 12, and 13. Cf. with Deposition of Epstein taken by an attorney representing BB (one in 
which Edwards was not participating), http://www.youtube.com/watcb?v=V-dgoEyYXx4; and 
http://www.youtube.com/watcb?v=YCNiYltW-rO 
57. 
Edwards's efforts to obtain information about Epstein's organization for 
prncuring young girls was also blocked because Epstein's co-conspirators took the Fifth. 
Deposition of Sarah Kellen, March 24, 2010 (hereinafter "Kellen Depa.") (Deposition 
attachment #14); Deposition of Nadia Marcinkova, April 13, 2010, (Deposition attachment #9); 
Deposition of Adriana Mucinska Ross, March 15, 2010 (hereinafter "Ross Depa.") (Deposition 
attachment #15). Each of these co-conspirators invoked their respective rights against self-
incrimination as to all relevant questions, and the depositions have been attached. 
58. 
At all relevant times Edwards has had a good faith basis to believe and did in fact 
believe Sarah Kellen was an employee of Epstein's and had been identified as a defendant in at 
least one of the complaints against Epstein for her role in bringing girls to Epstein's mansion to 
be abused. At the deposition, she was represented by Bruce Reinhart. She invoked the Fifth on ...

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all substantive questions regarding her role in arranging for minor girls to come to Epstein's 
mansion to be sexually abused. 
Reinhart had previously been an Assistant United States 
Attorney in the U.S. Attorney's Office for the Southern District of Florida when Epstein was 
being investigated criminally by Reinhart's office. Reinhart left the United States Attorney's 
Office and was immediately hired by Epstein to represent Epstein's pilots and certain co-
conspirators during the civil cases against Epstein. See Edwards Affidavit, Exhibit ''N" at ~11. 
59. 
Edwards also had other lines of legitimate discovery blocked through the efforts 
of Epstein and others. For example, Edwards learned through deposition that Ghislaine Maxwell 
was involved in managing Epstein's affairs and companies. See deposition of Epstein's house 
manager Janusz Banziak, February 16, 2010 at page 14, lines 20-23 (Deposition Attachment 
#16); See deposition of Epstein's housekeeper Louella Rabuyo, October 20, 2009, page 9, lines 
17-25 (Deposition Attachment #17); • See deposition of Epstein's pilot Larry Eugene Morrison, 
October 6, 2009, page 102-103 (Deposition Attachment #18); See deposition of Alfredo 
Rodriguez, August 7, 2009, page 302-306 and 348 (Deposition Attachment #8); See also Prince 
Andrew's Friend, Ghislaine Maxwell, Some Underage Girls and A Very Disturbing Story, 
September 
23, 
2007 
by 
Wendy 
Leigh, 
link 
at 
http:/ /www.redicecreations.com/article.php?id= 1895OHANNA SJOBERG. Exhibit "AA". 
60. 
Alfredo Rodriguez testified that Maxwell took photos of girls without the girls' 
knowledge, kept the images on her computer, knew the names of the underage girls and their 
respective phone numbers and other underage victims were molested by Epstein and Maxwell 
together. See Deposition of Rodriguez, Deposition attachment# 8 at 64, 169-170 and 236. 
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61. 
In reasonable reliance on this and other information, Edwards served Maxwell for 
deposition in 2009. See Deposition Notice attached as Exhibit "BB." Maxwell was represented 
by Brett Jaffe of the New York firm of Cohen and Gresser, and Edwards understood that her 
attorney was paid for ( directly or indirectly) by Epstein. 
She was reluctant to give her 
deposition, and Edwards tried to work with her attorney to take her deposition on terms that 
would be acceptable to both sides. The result was the attached confidentiality agreement, under 
which Maxwell agreed to drop any objections to the deposition, attached hereto as Exhibit "CC." 
Maxwell, however, contrived to avoid the deposition. 
On June 29, 2010, one day before 
Edwards was to fly to NY to take Maxwell's deposition, her attorney informed Edwards that 
Maxwell's mother was deathly ill and Maxwell was consequently flying to England with no 
intention of returning to the United States. Despite that assertion, Ghislaine Maxwell was in fact 
in the country on July 31, 2010, as she attended the wedding of Chelsea Clinton (former 
President Clinton's _daughter) and was captured in a photograph taken for OK magazine. Photos 
from Issue 809 of the publication See US Weekly dated August 16, 2010 are attached hereto as 
Exhibit "DD" and Edwards Affidavit, Exhibit "N" at ,i12. 
62. 
Maxwell is not the only important witness to lie to avoid deposition by Edwards. 
Upon review of the.message pads that were taken from Epstein's home in the police trash pulls, 
see Exhibit "J" supra, many were from Jean Luc Brunel, a French citizen and one of Epstein's 
. 
. 
closest pals. He left messages for Epstein. One dated 4/1/05 said, "He has a teacher for you to 
teach you how to speak Russian. She is 2x8 years old, not blonde. Lessons are free and you can 
have your 1st today if you call." See Messages taken from Jean Luc Brunel are attached hereto as 
Exhibit "EE." 
In light of these circumstances of ...

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Edwards that Brunel might have been procuring two eight-year-old girls for Epstein to sexually 
abuse. According _to widely circulated press reports reviewed by Edwards, Brunel is in his 
sixties and has a reputation throughout the world (and especially in the modeling industry) as a 
cocaine addict that has for years molested children through modeling agencies while acting as 
their agent - conduct that has been the subject of critical reports, books, several news articles, 
and a 60 Minutes . documentary on Brunel's sexual exploitation of underage models. 
See 
http://bradmillershero.blogspot.com/2010/08/women-are-objects.html, attached hereto as Exhibit 
"FF." 
63. 
Edwards learned that Brunel is also someone that visited Epstein on 
approximately 67 o.ccasions while Epstein was in jail. See Epstein's jail visitor log attached as 
Exhibit "GG." 
64. 
Edwards learned that Brunel currently runs the modeling agency MC2, a company 
foTwhich Epstein provides financial support. See Message Pad's attached as Exhibit "J" supra 
and Sworn Statement of MC2 employee Maritza Vasquez, June 15, 2010, "Maritza Vasquez 
Sworn Statement" attached at Exhibit "llli" at 1-16. 
65. 
Employees of MC2 told Edwards that Epstein's numerous condos at 301 East 66 
Street in New York were used to house young models. Edwards was told that MC2 modeling 
agency, affiliated with Epstein and Brunel brought underage girls from all over the world, 
promising them modeling contracts. Epstein and Brunel would then obtain a visa for these girls, 
then would charge the underage girls rent, presumably to live as underage prostitutes in the 
condos. See Maritza Vasquez Sworn Statement, Exhibit "llli" at 7-10, 12-15, 29-30, 39-41, 59-
60 and 62-67. 
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66. 
In view of this information suggesting Brunel could provide significant evidence 
of Epstein's trafficking in young girls for sexual abuse, Edwards had Brunel served in New York 
for deposition. See Notice of Deposition of Jean Luc Brunel attached hereto as Exhibit "IT." 
Before the deposition took place, Brunel's attorney (Tama Kudman of West Palm Beach) 
contacted Edwards to delay the deposition date. Eventually Kudman informed Edwards in 
January 2009 that Brunel had left the country and was back in France with no plans to return. 
This information was untrue; Brunel was actually staying with Epstein in West Palm Beach. See 
Banasiak deposition, deposition attachment #16 at 154-160 and 172-175; see also pages from 
Epstein's probation file evidencing Jean Luc Brunel. (JLB) staying at his house during that 
relevant period of time attached Exhibit "JJ". As a result, Edwards filed a Motion for Contempt, 
attached hereto as Exhibit "KK" (Because Epstein settled this case, the motion was never ruled 
upon.) 
67. 
Edwards was also informed that Epstein paid for not only Brunel's representation 
during the civil process but also paid for legal representation for Sarah Kellen (Epstein's 
executive assistant and procurer of girls for him to abuse), Larry Visoski (Epstein's personal 
pilot), Dave Rogers (Epstein's personal pilot), Larry Harrison (Epstein's personal pilot), Louella 
Rabuyo (Epstein's housekeeper), Nadia Marcinkova (Epstein's live-in sex slave), Ghislaine 
Maxwell (manager of Epstein's affairs and businesses), Mark Epstein (Epstein's brother), and 
Janusz Banasiak (Epstein's house manager) It was nearly impossible to take a deposition of 
someone that would have helpful information that was not represented by an attorney paid for by 
Epstein. See Edwards Affidavit, Exhibit "N" at ,r11. 
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68. 
While Epstein and others were preventing any legitimate discovery into his sexual 
abuse of minor girls, at the same time he was engaging (through his attorneys) in brutal 
questioning of the girls who had filed civil suits against him, questioning so savage that it made 
local headlines. See Jane Musgrave, Victims Seeking Sex offender's Millions See Painful Pasts 
Used 
Against 
Them, 
Palm 
Beach 
Post 
News, 
Jan. 
23, 
2010, 
available 
at 
http://www. palmbeachpost. com/news/ crime/victims-seeking-sex-offenders-millions-see-painful-
pasts-192988 .html attached hereto as Exhibit "LL." 
Edwards Pursues Other Lines of Discove,y 
69. 
Because of Epstein's thwarting of discovery and attacks on Edwards's clients, 
Edwards was forced to pursue other avenues of discovery. 
Edwards only pursued legitimate 
discovery designed· to further the cases filed against Epstein. See Edwards Affidavit, Exhibit 
''N" at 'if l 1. 
70. 
Edwards notified Epstein's attorneys ofhis intent to take Bill Clinton's deposition. 
Edwards possessed a legitimate basis for doing so: (a) Clinton was friends with Ghislaine 
Maxwell who was Epstein's longtime companion and helped to run Epstein's companies, kept 
images of naked underage children on her computer, helped to recruit underage children for 
Epstein, engaged in lesbian sex with underage females that she procured for Epstein, and 
photographed underage females in sexually explicit poses and kept child pornography on her 
computer; (b) it was national news when Clinton traveled with Epstein aboard Epstein's private 
plane to Africa and the news articles classified Clinton as Epstein's friend. (c) the complaint 
filed on behalf of Jane Doe No. 102 stated generally that she was required by Epstein to be 
sexually exploited by not only Epstein but also Epstein's "adult male peers, including royalty, 
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politicians, academicians, businessmen, and/or other professional and personal acquaintances" -
categories Clinton and acquaintances of Clinton fall into. 
The flight logs showed Clinton 
traveling on Epstein's plane on numerous occasions between 2002 and 2005. See Flight logs 
attached hereto as Exhibit "MM." Clinton traveled on many of those flights with Ghislaine 
Maxwell, Sarah Kellen, and Adriana Mucinska, - all employees and/or co-conspirators of 
Epstein's that were closely connected to Epstein's child exploitation and sexual abuse. The 
documents clearly show that Clinton frequently flew with Epstein aboard his plane, then 
suddenly stopped - raising the suspicion that the friendship abruptly .ended, perhaps because of 
events related to Epstein's sexual abuse of children. Epstein's personal phone directory from his 
computer contains e-mail addresses for Clinton along with 21 phone numbers for him, including 
those for his assistant (Doug Band), his schedulers, and what appear to be Clinton's personal 
numbers. This information certainly leads one to believe that Clinton might well be a source of 
relevant information and efforts to obtain discovery from him were reasonably calculated to lead 
to admissible evidence. See Exhibits "B", "F" "AA", "DD", and "MM" and Edwards Affidavit, 
Exhibit ''N" at ~15. 
71. 
Bradley J. Edwards, Esq., provided notice that he intended to take the deposition 
of Donald Trump. Edwards possessed a legitimate basis for doing so: (a) The message pads 
confiscated from Epstein's home indicated that Trump called Epstein's West Palm Beach 
mansion on several occasions during the time period most relevant to my Edwards's clients' 
complaints; (b) Trump was quoted in a Vanity Fair article about Epstein as saying "I've known 
Jeff for fifteen years. Terrific guy," "He's a lot of fun to be with. It is even said that he likes 
beautiful women as much as I do, and many of them are on the younger side. No doubt about i...

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Jeffrey enjoys his social life." Jeffrey Epstein: International Moneyman of Mystery; He's pals 
with a passel of Nobel Prize-winning scientists, CEOs like Leslie Wexner of the Limited, 
socialite Ghislaine Maxwell, even Donald Trump. But it wasn't until he flew Bill Clinton, Kevin 
Spacey, and Chris Tucker to Africa on his private Boeing 727 that the world began to wonder 
who he is. By Landon Thomas Jr. (See article attached hereto as Exhibit "NN") (c) Trump 
allegedly banned Epstein from his Maralago Club in West Palm Beach because Epstein sexually 
assaulted an underage girl at the club; (d) Jane Doe No. 102's complaint alleged that Jane Doe 
102 was initially approached at Trump's Maralago by Ghislaine Maxwell and recruited to be 
Maxwell and Epstein's underage sex slave; (e) Mark Epstein (Jeffrrey Epstein's brother) testified 
that Trump flew on Jeffrey Epstein's plane with him (the same plane that Jane Doe 102 alleged 
was used to have sex with underage girls); (f) Trump had been to Epstein's home in Palm Beach; 
(g) Epstein's phone· directory from his computer contains 14 phone numbers for Donald Trump, 
including emergency numbers, car numbers, and numbers to Trump's security guard and 
houseman. Based on this information, Edwards reasonably believed that Trump might have 
relevant information to provide in the cases against Jeffrey Epstein and accordingly provided 
notice of a possible deposition. See deposition of Mark Epstein, September 21, 2009, at 48-50 
(Deposition Attachment #19); See Jane Doe 102 v. Epstein, Exhibit "B"; Exhibit "F"; 
"Exhibit"J"; "N" and See Edwards Affidavit, Exhibit ''N" at i[13. 
72. 
Edwards provided notice that he intended to depose Alan Dershowitz. Edwards 
possessed a legitimate basis for doing so: (a) Dershowitz is believed to have been friends with 
Epstein for many years; (b) in one news article Dershowitz comments that, "I'm on my 20th 
book ... The only person outside of my immediate family that I se...

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Talented Mr. Epstein, By Vicky Ward on January, 2005 in Published Work, Vanity Fair (See 
article attached as Exhibit "00"); (c) Epstein's housekeeper Alfredo Rodriguez testified that 
Dershowitz stayed at Epstein's house during the years when Epstein was assaulting minor 
females on a daily basis; (d) Rodriguez testified that Dershowitz was at Epstein's house at times 
when underage females where there being molested by Epstein (see Alfredo Rodriguez 
deposition at 278-280, 385, 426-427); (e) Dershowitz reportedly assisted in attempting to 
persuade the Palm Beach State Attorney's Office that because the underage females alleged to 
have been victims of Epstein's abuse lacked credibility and could not be believed that they were 
at Epstein's house, when Dershowitz himself was an eyewitness to their presence at the house; 
(f) Jane Doe No. 102 stated generally that Epstein forced her to be sexually exploited by not only 
Epstein but also Epstein's "adult male peers, including royalty, politicians, academicians, 
businessmen, and/or other professional and personal acquaintances" - categories that Dershowitz 
and acquaintances of Dershowitz fall into; (g) during the years 2002-2005 Alan Dershowitz was 
on Epstein's plane on several occasions according to the flight logs produced by Epstein's pilot 
and information ( described above) suggested that sexual assaults may have taken place on the 
plane; (h) Epstein ~onated $30 Million one year to the university at which Dershowitz teaches. 
Based on this information, Edwards had a reasonable basis to believe that Dershowitz might 
have relevant information to provide in the cases against Jeffrey Epstein and accordingly 
provided notice of a possible deposition. See Dershowitz letters to the State Attorney's office 
attached as Exhibi~ "PP"; Deposition of Alfredo Rodriguez at 278-280; Flight Logs Exhibit 
"MM"; Exhibits "B" and "00"; and Edwards Affidavit, Exhibit ''N" at ,Il4. 
30 

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73. 
Epstein's complaint alleges that Edwards provided notice that he wished to take 
the deposition of Tommy Mattola. That assertion is untrue. Mr. Mattola's deposition was set by 
the law firm of Searcy Denny Scarola Barnhart and Shipley. See Edwards Affidavit, Exhibit "N" 
at if16. 
74. 
Edwards gave notice that he intended to take David Copperfield's deposition. 
Edwards possessed a legitimate basis for doing so. Epstein's housekeeper and one of the only 
witnesses who did not appear for deposition with an Epstein bought attorney, Alfredo Rodriguez, 
testified that David Copperfield was a guest at Epstein's house on several occasions. His name 
also appears frequently in the message pads confiscated from Epstein's house. It has been 
publicly reported that Copperfield himself has had allegations of sexual misconduct made against 
hirri by women claiming he sexually abused them, and one of Epstein's sexual assault victims 
also alleged that Copperfield had touched her in an improper sexual way while she was at 
Epstein's house. Mr. Copperfield likely has relevant information and deposition was reasonably 
calculated to lead to the discovery of admissible evidence. See Edwards Affidavit, Exhibit "N" at 
75. 
Epstein also takes issue with Edwards identifying Bill Richardson as a possible 
witness. Richardson was properly identified as a possible witness because Epstein's personal 
pilot testified to Richardson joining Epstein at Epstein's New Mexico Ranch. There was 
information indicating that Epstein had young girls at his ranch which, given the circumstances 
of the case, raised the reasonable inference he was sexually abusing these girls as he had abused 
girls in West Palm Beach and elsewhere. Richardson had also returned campaign donations that 
were given to him by Epstein, indicating that he believed that there was something about Epstein 
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with which he did not want to be associated. Richardson was not called to testify nor was he ever 
subpoenaed to testify. See Edwards Affidavit, Exhibit ''N'' at ,r18. 
7 6. 
Edwards learned of allegations that Epstein engaged in sexual abuse of minors on 
his private aircraft. See Jane Doe 102 Complaint, Exhibit "B." Accordingly, Edwards pursued 
discovery to confirm these allegations: 
77. 
Discovery of the pilot and flight logs was proper in the cases brought by Edwards 
against Epstein. Jane Doe filed a federal RICO claim against Epstein that was an active claim 
through much of the litigation. The RICO claim alleged that Epstein ran an expansive criminal 
enterprise that involved and depended upon his plane travel. Although Judge Marra dismissed 
the RICO claim at some point in the federal litigation, the legal team representing 
Edwards' clients intended to pursue an appeal of that dismissal. Moreover, all of the subjects 
mentioned in the RICO claim remained relevant to other aspects of Jane Doe's claims against 
Epstein, including in particular her claim for punitive damages. See Edwards Affidavit, Exhibit 
"N" at ,rl9. 
78. 
Discovery of the pilot and flight logs was also proper in the cases brought by 
Edwards against Epstein because of the need to obtain evidence of a federal nexus. Edwards's 
client Jane Doe was proceeding to trial on a federal claim under 18 U.S.C. § 2255. Section 2255 
is a federal statute which (unlike relevant state statutes) established a minimum level of recovery 
for victims of the violation of its provisions. Proceeding under the statute, however, required a 
"federal nexus" to the sexual assaults. Jane Doe had two grounds on which to argue that such a 
nexus existed to her abuse by Epstein: first, his use of telephone to arrange for girls to be abused; 
and, second, his travel on planes in interstate commerce. During the course of the litigation, 
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Edwards anticipated that Epstein would argue that Jane Doe's proof of the federal nexus was 
inadequate. These fears were realized when Epstein filed a summary judgment motion raising 
this argument. In response, the other attorneys and Edwards representing Jane Doe used the 
flight log evidence to respond to Epstein's summary judgment motion, explaining that the flight 
logs demonstrated that Epstein had traveled in interstate commerce for the purpose of facilitating 
his sexual assaults .. Because Epstein chose to settle the case before trial, Judge Marra did not 
rule on the summary judgment motion. 
79. 
Edwards had further reason to believe and did in fact believe that the pilot and 
flight logs might contain relevant evidence for the cases against Epstein. Jane Doe No. 102's 
complaint outlined Epstein's daily sexual exploitation and abuse of underage minors as young as 
12 years old and alleged that Epstein's plane was used to transport underage females to be 
sexually abused by him and his friends. The flight logs accordingly were a potential source of 
information about either additional girls who were victims of Epstein's abuse or friends of 
Epstein who may· have witnessed or even participated in the abuse. 
Based on this 
information, Edwards reasonably pursued the flight logs in discovery. 
80. 
In the fall of 2009, Epstein gave a recorded interview to George Rush, a reporter 
with the New York Daily News about pending legal proceedings. In that interview, Epstein 
demonstrated an utter lack of remorse for his crimes (but indirectly admitted bis crimes) by 
stating: 
• 
People do not like it when people make good and that was one reason he (Epstein) 
was being targeted by civil suits filed by young girls in Florida; 
• 
He (Epstein) bad done nothing wrong; 
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• 
He (Epstein) had gone to jail in Florida _for soliciting prostitution for no reason; 
• 
If the same thing (i.e., sexual abuse of minor girls) had happened in New York, he 
(Epstein) would have received only a $200 fine; 
• 
Bradley J. Edwards was the one causing all of Epstein's problems (i.e., the civil 
suits brought by Jane Doe and other girls); 
• 
L.M. came to him as a prostitute and a drug user (i.e., came to Epstein for sex, 
rather than Epstein pursuing her); 
• 
AJl the girls suing him are only trying to get a meal ticket; 
111 
The only thing he might have done wrong was to maybe cross the line a little too 
closely; 
• 
He (Epstein) was very upset that Edwards had subpoenaed Ghisline Maxwell, that 
she was a good person that did nothing wrong (i.e., had done nothing wrong even 
though she helped procure young girls to satisfy Epstein's sexual desires); 
• 
With regard to Jane Doe 102 v. Epstein, which involved an allegation that Epstein 
had repeatedly sexually abused a 15-year-old girl, forced her to have sex with his 
friends, and flew her on his private plane nationally and internationally for the 
purposes of sexually molesting and abusing her, he (Epstein) flippantly said that 
the case was dismissed, indicating that the allegations were ridiculous and untrue. 
See Affidavit of Michael J. Fisten attached hereto as Exhibit "QQ." 
81. 
The Rush interview also demonstrated perjury ( a federal crime) on the part of 
Epstein. Epstein lied about not knowing George Rush. See Epstein Deposition, February 17, 
2010, taken in L.M. v. Jeffrey Epstein, case 50-2008-CA-028051, page 154, line 4 through 155 
line 9, (Deposition ·attachment #7), wherein Jeffrey Epstein clearly impresses that he does not 
recognize George Rush from the New York Daily News. This impression was given despite the 
fact that he gave a lengthy personal interview about details of the case that was tape recorded 
with George Rush. 
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Epstein's Harassment of Witnesses Against Him 
82. 
At all relevant times Edwards has a good faith basis to believe and did in fact 
believe that Epstein engaged in threatening witnesses. See Incident Report, Exhibit "A" at p. 82, 
U.S. Attorney's Correspondence, Exhibit "C" - Indictments drafted by Federal Government 
against Epstein; and Edwards Affidavit, Exhibit "N" at if l 1. 
83. 
Despite three no contact orders entered against Epstein (see Exhibit C, supra), 
Edwards learned that Epstein continued to harass his victims. For example, Jane Doe had a trial 
set for her civil case against him on July 19, 2010. As that trial date approached, defendant 
Epstein intimidated her in violation of the judicial no-contact orders. On July 1, 2010, he had a 
"private investigator" tail Jane Doe -c- following her every move, stopping when she stopped, 
driving when she drove, refusing to pass when she pulled over. When Jane Doe ultimately drove 
to her home, the "private investigator" then parked in his car approximately 25 feet from Jane 
Doe house and flashed his high beam lights intermittently into the home. 
Even more 
threateningly, at about 10:30 p.m., when Jane Doe fled her home in the company of a retired 
police officer employed by Jane Doe's counsel, the "private investigator" attempted to follow 
Jane Doe despite a request not to do so. The retired officer successfully took evasive action and 
placed Jane Doe in a secure, undisclosed location that night. Other harassing actions against 
Jane Doe also followed. See Motion for Contempt filed by Edwards in Jane Doe v. Epstein 
detailing the event, including Fisten Affidavit attached to Motion, Composite Exhibit "RR." 
Epstein Settlement of Civil Claims Against Him for Sexual Abuse of Children 
84. 
The civil cases Edwards filed against Epstein on behalf of L.M., E.W., and Jane 
Doe were reasonably perceived by Edwards to be very strong cases. Because Epstein had 
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sexually assaulted these girls, he had committed several serious torts against them and would be 
liable to them for appropriate damages. See Preceding Undisputed Facts. 
Because of the 
outrageousness of Epstein's sexual abuse of minor girls, Edwards reasonably expected that 
Epstein would also be liable for punitive damages to the girls. Because Edwards could show that 
Epstein had molested children for years and designed a complex premeditated scheme to procure 
different minors everyday to satisfy his addiction to sex with minors, the punitive damages 
would have to be sufficient to deter him from this illegal conduct that he had engaged in daily for 
years. 
Epstein was and is a billionaire. 
See Complaint, i[49 (referring to "Palm Beach 
Billionaire'.'); see also Epstein Deposition, February 17, 2010, at 172-176 (Deposition 
Attachment #7) (taking the Fifth when asked whether he is a billionaire). Accordingly, Edwards 
reasonably believed the punitive damages that would have to be awarded against Epstein would 
have been substantial enough to punish him severely enough for his past conduct as well as deter 
him from repeating his offenses in the future. See Edwards Affidavit, Exhibit ''N" at ,Il 9. 
85. 
On July 6, 2010, rather than face trial for the civil suits that had been filed against 
him by L.M., E.W., and Jane Doe, defendant Epstein settled the cases against him. The terms of 
the settlement are confidential. The settlement amounts are highly probative in the instant action 
as Epstein bases his claims that Edwards was involved in the Ponzi scheme on Epstein's inability 
to settle the L.M., E.W., and Jane Doe cases for "minimal value". His continued inability to 
settle the claims for "minimal value" after the Ponzi scheme was uncovered would be highly 
probative in discrediting any causal relationship between the Ponzi scheme and Edwards's 
settlement negotiations. See Edwards Affidavit, Exhibit ''N" at ,i21. 
Edwards Non-Involve...

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86. 
From in or about 2005, through in or about November 2009, Scott Rothstein 
appears to have run a giant Ponzi scheme at his law firm of Rothstein, Rosenfeldt and Adler P .A 
("RRA"). This Ponzi scheme involved Rothstein falsely informing investors that settlement 
agreements had been reached with putative defendants based upon claims of sexual harassment 
and/or whistle-blower actions. 
Rothstein falsely informed the investors that the potential 
settlement agreements were available for purchase. Plea Agreement at 2, United States v. Scott 
W. Rothstein, No. 9-60331-CR-COHN (S.D. Fla. Jan. 27, 2010) attached hereto as Exhibit "SS." 
87. 
It has been alleged that among other cases that Rothstein used to lure investors 
into his Ponzi scheme were the cases against Epstein that were being handled by Bradley J. 
Edwards, Esq. Edwards had no lmowledge of the fraud or any such use of the Epstein cases. See 
Edwards Affidavit, Exhibit ''N" at ,I9. 
88. 
Bradley J. Edwards, Esq., joined RRA in about April 2009 and left RRA in 
November 2009 - a period of less than one year. Edwards would not have joined RRA had he 
been aware that Scott Rothstein was running a giant Ponzi scheme at the firm. Edwards left 
RRA shortly after learning ofRothstein's fraudulent scheme. Id. at iJ8. 
89. 
At no time prior to the public disclosure ofRothstein's Ponzi scheme did Edwards 
lmow or have reason to believe that Rothstein was using legitimate claims that Edwards was 
prosecuting against Epstein for any fraudulent or otherwise illegitimate purpose. Id. at ,I20. 
90. 
Edwards never substantively discussed the merits of any of his three cases against 
Epstein with Rothstein. See Deposition of Bradley J. Edwards taken March 23, 2010, at 110-16. 
(hereinafter "Edwards Depa") (Deposition Attachment #22). 
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91. 
On July 20, 2010, Bradley Edwards received a letter from the U.S. Attorney's 
Office for the Southern District of Florida - the office responsible for prosecuting Rothstein's 
Ponzi scheme. The letter indicated that law enforcement agencies had determined that Edwards 
was "a victim (or potential victim)" of Scott Rothstein's federal crimes. The letter informed 
Edwards of his rights as a victim of Rothstein's fraud and promised to keep Edwards informed 
about subsequent developments in Rothstein's prosecution. See Letter attached hereto as Exhibit 
"TT." 
92. 
Jeffrey Epstein filed a ·complaint with the Florida Bar against Bradley Edwards, 
Esq., raising allegations that Edwards and others were involved in the wrongdoing of Scott 
Rothstein. After investigating the claim, the Florida Bar dismissed this complaint. See Edwards 
Affidavit, Exhibit "N" at i!23. 
Epstein Takes the Fifth When Asked Substantive Questions About His Claims Against Edwards 
93. 
On March 17, 2010, defendant Epstein was deposed about his lawsuit against 
Edwards. 
Rather than answer substantive questions about his lawsuit, Epstein repeatedly 
invoked his Fifth Amendment privilege. 
See Epstein Depa. taken 3/17 /10, Deposition 
Attachment # 1. 
94. 
In h1.s deposition, Epstein took the Fifth rather than answer the question: 
"Specifically what are the allegations against you which you contend Mr. Edwards ginned up?" 
Id. at 34. 
95. 
In his deposition, Epstein took the Fifth rather than name people in California that 
Edwards had tried to depose to increase the settlement value of the civil suit he was handling. Id. 
at 37. 
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96. 
In bis deposition, Epstein took the Fifth rather than answer the question: "Do you 
know former President Clinton personally." Id. 
97. 
In his deposition, Epstein took the Fifth rather than answer the question: '°Are you 
now telling us that there were claims against you that were fabricated by Mr. Edwards?" Id. at 
39 .. 
98. 
In his deposition, Epstein took the Fifth rather than answer the question, "Well, 
which of Mr. Edwards' cases do you contend were fabricated." Id. 
99. 
In his deposition, Epstein took the Fifth rather than answer the question: "What is 
the actual value that you contend the claim of E.W. against you bas?" Id. at 45. 
100. 
In his deposition, Epstein took the Fifth rather than answer a question about the 
actual value of the claim ofL.M. and Jane Doe against him. Id. 
101. 
In bis deposition, taken prior to the settlement of Edwards' s clients claims against 
Epstein, Epstein took the Fifth rather than answer the question: "Is there any pending claim 
aga:inst you which you contend is fabricated?" Id. at 71. 
102. 
In his deposition, Epstein took the Fifth rather than answer the question: '°Did you 
ever have damaging evidence in your garbage?" Id. at 74. 
103. 
In his deposition, Epstein took the Fifth rather than answer the question: "Did 
sexual assaults ever take place on a private airplane on which you were a passenger?" Id. at 88. 
104. 
In bis deposition, Epstein took the Fifth rather than answer the question: "Does a 
flight log kept for a private jet used by you contain the names of celebrities, dignitaries or 
international figures?" Id. at 89. 
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105. 
In his deposition, Epstein took the Fifth rather than answer the question: "Have 
you ever socialized-with Donald Trump in the presence of females under the age of 18?" Id. at 
89. 
106. 
In his deposition, Epstein took the Fifth rather than answer the question: "Have 
you ever socialized with Alan Dershowitz in the presence of females under the age of 18." Id. at 
90. 
107. 
In his deposition, Epstein took the Fifth rather than answer the question: "Have 
you ever socialized with Mr. Mottola in the presence of females under the age of 18?" Id. at 91-
92. 
108. 
In his deposition, Epstein took the Fifth rather than answer the question: "Did you 
ever socialize with David Copperfield in the presence of females under the age of 18?" Id. at 
109. 
In his deposition, Epstein took the Fifth rather than answer the question: "Have 
you ever socialized with Mr. Richardson [Governor of New Mexico and formerly U.S. 
Representative and Ambassador to the United Nations] in the presence of females under the age 
of 18." Id. at 94. 
110. 
In bis deposition, Epstein took the Fifth rather than answer the question: "Have 
you ever sexually abused children?" Id. at 95. 
111. 
In bis deposition, Epstein took the Fifth rather than answer the question: "Did you 
have staff members that assisted you in scheduling appointments with underage females; that is, 
females under the age of 18." Id. at 97-98. 
112. 
In bis deposition, Epstein took the Fifth rather than answer the question: "On how 
many occasions did.you solicit prostitution." Id. at 102. 
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113. 
In his deposition, Epstein took the Fifth rather than answer the question: "How 
many minors have you procured for prostitution?" Id. at 104. 
114. 
In his deposition, Epstein took the Fifth rather than answer the question: "Have 
you ever coerced, induced or enticed any minor to engage in any sexual act with you?" Id. at 
107. 
115. 
In his deposition, Epstein took the Fifth rather than answer the question: "How 
many times have you engaged in fondling underage females?" Id. at 108. 
116. 
In his deposition, Epstein took the Fifth rather than answer the question: "How 
many times have you engaged in oral sex with females under the age of 18?" Id. at 110. 
117. 
In his deposition, Epstein took the Fifth rather than answer the question: "Do you 
have a personal sexual preference for children?" Id. at 111-12. 
118. 
In his deposition, Epstein took the Fifth rather than answer the question: "Your 
Complaint at page 27, paragraph 49, says that 'RRA and the litigation team took an emotionally 
driven set of facts involving alleged innocent, unsuspecting, underage females and a Palm Beach 
billionaire, and sought to turn it into a goldmine,' end of quote. Who is the Palm Beach 
billionaire referred to in that sentence?" Id. at 112-13. 
119. 
In his deposition, Epstein took the Fifth rather than answer the question: "Who are 
the people who are authorized to make payment [to your lawyers] on your behalf?" Id. at 120. 
120. 
In his deposition, Epstein took the Fifth rather than answer the question: "Is there 
anything in L.M. 's Complaint that was filed against you in September of 2008 which you 
contend to be false?" Id. at 128. 
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CERTIFICATE OF SERVICE 
.~ 
I HEREBY CERTIFY that on November_~_, 2010 a copy of the foregoing has been 
served via Fax and U.S. Mail to all those on the attached service list. 
By: 
Jack Scarola 
Searcy, Denney, Scarola, Barnhart & Shipley 
2139 Palm Beach Lakes Blvd 
West Palm Beach, FL 33409 
(561) 686-
0 
(561 
84-581 (fax) 
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Christopher E. Knight, Esq. 
Joseph L. Ackerman, Esq. 
FOWLER WHITE BURNETT P.A. 
901 Phillips Point West 
777 South Flagler Drive 
West Palm Beach, FL 33401 
Jack Alan Goldberger, Esq. 
Atterbury Goldberger et al. 
25 0 Australian A venue South 
Suite 1400 
West Palm Beach, FL 33401 
Marc S. Nurik, Esq. 
Law Offices of Marc S. Nurik 
One E. Broward Blvd., Suite 700 
Fort Lauderdale, FL 33301 
Gary M. Farmer, Jr. 
Farmer, Jaffe, Weissing, 
Edwards, Fistos & Lehrman, P.L. 
425 N. Andrews Ave., Suite 2 
Fort Lauderdale, FL 33301 
SERVICE LIST 
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.. - ..... -
. -
. ·-- ....... •. 
.. --- ... __ ......_______ . -
.. -- . 
-
DEFENDANT BRADLEY 1 EDWARDS'S STATEMENT OF UNDISPUTED FACTS 
Epstein v. Edwards, et al. 
Case No.: 50 2009 CA 040800XXXXMBAG 
I I 

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- •••••·· 
. •. 
. -···-· ... -- . -·· -··-· 
·-
•--;·---·-- .. - ---····-·. 
AFFIDAVIT OF BRADLEY JAMES EDWARD§ 
1. 
I am an attorney in good standing with the Florida Bar and admitted to practice in the 
Southern District of Florida. I am currently a partner in the law firm of Fanner, Jaffe, 
Weissing, Edwards, Fistos & Lehrman. P .L. 
2. 
In 2008, I was a sole practitioner nmning a persomtl injury law finn in Hollywood,, FL. 
While a sole practitioner I was retained by three clients, L.M., E.W., and Jane Doe to 
pursue civil litigation against Jeffrey Epstein for sexually abusing them while they were 
minor girls. I agreed to. represent these girls, along with attorney Jay Howell (an 
attorney in Jacksonville, Florida with Jay Howell & Associates) and Professor Paw 
Cassell (a law professor at the Um.versity of Utah College Of Law). I filed state court 
actions on behalf of L.M. lill.d E.W. !illld a federal court action on behallf of Jane Doe. 
All of the cases were filed in the summer of 2008. 
3. 
My clients received correspondence from the U.S. Department of Justice regarding 
their rights as victims of Epstein's federal sex offenses. (True and accurate copies of 
the letters are attached to Statement of Undisputed Facts as Exhibit "M") 
4. 
In mid June 2008, I contacted Assistant United States Attorney Marie ViHa.fo.iia to 
inform her that I represented Jane Doe #l(E.W.) and, farer, Jane Doe #2(L.M.). I asked 
to meet to provide information regarding Epstein. AUSA Villafaiia did not advise me 
that a plea agreement had already been negotiated with Epstein's attorneys that would 
block federal prosecution. AUSA Villafana did indicate that federal investigators had 
concrete evidence and information that Epstein had sexwilly molested at least 40 
underage winor females. inclooing E.W., Jane Doe and L.M. 
5. 
I also requested from the U.S. Attorney's Office the information and evidence that they 
had collected regarding Epstein's sexual abus...

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. 
-- . -
" ... 
~•••.,..•••••••-w•~ •• 
•••• • •-••• -• ---•-•- ---••-• • 
• • •• 
•-
•• •-•- ••-
••• 
8. 
In the Spring of 2009 (approximately April), I joined the law firm of Rothstein, 
Rosenfeldt and Adler. lP .A. ("RRA"). I brought my existing clients with me when I 
joined RRA, including L.M., E.W., and Jane Doe. When I joined the furn, I was not 
aware that Scott Rothstein was running a Ponzi scheme at RRA. Had I known such a 
Ponzi scheme was in place, I would never have joined RRA. 
9. 
I am· now aware that it has been alleged that Scott Rothstein made fraudulent 
presentations ro invesrors about the lawsuits that I had filed on behalf of my clients 
against Epstein and that it has been alleged that these lawsuits were used to fraudulently 
lure investors into Rothstein's Ponzi scheme. I never met a single investor, had no part 
in any such presentations and had no knowledge any such fraud was occurring. If these 
allegations a.re true, I had no knowledge that any such fraudulent presentations were 
occurring and no knowledge of any such improper use of the case files. 
10. Epstein's Complaint against me alleges that Rothstein made false statements about 
cases filed against Epstein, i.e., that RRA had 50 ainonymous females who had filed swt 
against Epstein; that Rothstein sold an interest in personal injury lawsuits, reached 
agreements to share attorneys fees with non-lawyers, paid clients "up front" money; and 
that he used the judicial process to further his Ponzi scheme. If Rothstein did any of 
these things, I had no knowledge of his actions. Because I maintained close contact 
with my clients, EW, LM and Jane Doe, and Scott Rothstein never met any of them, I 
know for certain tlmt none of my clients were paid "up front" money by anyone. 
11. Epstein alleges that I attempted to take the depositiom of his "high pmfile friends md 
acquiai..11ttm.ces" for no legitimate litigation purpose. This is tmtJrue, as all of my actions 
in r...

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12. In light of information I received suggesting that British socialite Ghislaine Maxwell, 
former girlfriend and long-time friend of Epstein's, was involved in managing Epstein's 
affairs and companies I had her served for deposition for August 17, 2009. (Deposition 
Notice attached to Statement of Undisputed Facts as Exhibit BB). Maxwell was 
represented by Brett Jaffe of the New York furn. of Cohen and Gresser, and I 
understood that her attorney was paid for (directly or indirectly) by Epstein. She was 
reluctant. to give her deposition, and I tried ro work with her attorney to take her 
deposition on terms that would be acceptable tq both sides. 
Her attorney and I 
negotiated a confidentiality agreement, under whlch Maxwell agreed to drop any 
objections to the deposition. Maxwell, however, still avoided the deposition. On June 
29, 2010, one day before I was to fly to NY to take Maxwell's deposition, her attorney 
informed me that Maxwell's mother was deathly ill and Maxwell was consequently 
flying to Enghmd with no intention of reruming and certainly wowd not return. to the 
United States before the conclusion of Jane Doe's trial period (August 6, 2010). 
Despite that assertion, I later lea.med that Ghislaine Maxwell was in fact in the country 
on approximately July 31, 2010, as she attended the wedding of Chelsea Clinton 
(former President Clinton's daughter) and was captured in a photograph ta.ken for US 
Weekly magazine. 
13. Epstein alleges that there was something improper in the fact that I notified him that I 
intended to take DoMlld Trump's deposition in the civil suits against him. Trump was 
properly noticed because: (a) after review of the message pads confiscated :from 
Epstein's home, the legal. and investigative team :!l!Ssisting my clients learned that Trump 
called Epstein's West Palm Beach mansion on several occasions during the time period 
most relevant to my clients' complaints; (b) Trump was quoted in a Vanity Fair...

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.. -
--···-. ------------··-·---------· -----•-··· . ·--- ---------- -----
Tromp might have relevant information to provide in the cases against Jeffirey Epstein 
and accordingly provided notice of a possible deposition. 
14. Epstein alleges that there was something improper in the fact that I notified him that I 
intended to take Alan Dersbowitz' s deposition in the civil suits against him. Dershowitz 
was properly noticed because: (a) Dershowitz has been friends with Epstein for many 
years; (11>) in one news article Dershowitz comments mat, "i'm on my 20th book ... Toe 
only person outside of my immediate family that I send drafts to is Jeffrey" The 
Talented Mr. Epstein, By Vicky Ward on January, 2005 in Published Work, Vanity 
Fair; (c) Epstein's housekeeper Alfredo Rodriguez testified that Dershowitz stayed at 
Epstein's house during the years most relevmt to my clients; (d) Rodriguez testified 
that Dershowitz was at Epstein's house at times when underage females where there 
being molested by Epstein (see Alfredo Rodriguez deposition at 278-280, 385, 426-
427); (e) Dershowitz was reportedly involved in persuading the Palm Beach State 
Attorney's office not to file felony crimmal clrunrges against Epstein because the 
underage females lacked credibility and thus could not be believed that they were at 
Epstein's house, despite him being an eyewitness that the underage girls well."e actually 
there; (f) Jane Doe No. 102 stated generally that Epstein forced her to be sexoolly 
exploited by not only Epstein but also Epstein's "adult male peers, includin.g royalty, 
politicians, academicians, businessmen, and/or other professional and personal 
acquaintances" - categories that Dershowitz and acqwmitances of Dershowitz fall into; 
(g) during the years 2002-2005 Alan Dershowitz was on Epstein's plane on several 
occasions according to the flight logs produced by Epstein's pilot and information 
(described above) suggested that sexual assaults m...

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exploited by not only Epstein but also Epstein's "adult male peers, including royalty, 
politicians, academicians, businessmen, and/or other professional and personal 
acquaintances" - categories Clinton and acquaintances of Clinton fall into; (f) flight 
logs showed that Clinton took many flights with Epstein, Ghislaine Maxwell, Sarah 
Kellen, and Adriana Mucinska. -- all employees and/or co-conspirators of Epstein's that 
were closely .connected to Epstein's child exploitation and sexual abuse; (g) Clinton 
frequently flew with Epstein aboard his plane, then suddenly stopped - raising the 
suspicion that the friendship abruptly ended, perhaps because of events related to 
Epstein's sexual abuse of children; (b.) Epstein's personal phone directory from his 
computer contains e0 mail addresses for Clinton along with 21 phone numbeirs for him, 
including those for his assistant (Doug Band), his schedulers, and what appear to be 
Clinton's personal numbers. Based on this information, I believed that Clinton might 
have relevant information to provide in the cases against Jeffrey Epstein and 
accordingly provided notice of a possible deposition. 
16. Epstein alleges that Tommy Mottola was improperly noticed with a deposition. I did 
not notice Mattola for deposition. 
He was noticed for deposition by a law firm 
representing another one of Epstein's victims - not by me. 
17. Epstein alleges that there was something improper in the fact tlmt I notified him that I 
intended to take the illusionist David Copperfield's deposition. 
Copperfield was 
properly noticed because: (a) Epstein's housekeeper Alfredo Rodriguez testified that 
David Copperfield was a guest on several occasions at Epstein's house; (b) according to 
the message pads confiscated from Epstein's house, Copperfield called Epstein quite 
frequently and left messages that indicated they socialized together; (c) Copperfield 
himself has had similar allegations made against him by women cl...

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necessary because: (a) Jane Doe filed a federal RICO claim against Epstein that was an 
active claim through much of the litigation. Toe RICO claim alleged that Epstein ran an 
expansive criminal enterprise that involved and depended upon his plane travel. 
Although Judge Mana dismissed the RICO claim at some point in the federal litigation, 
the legal team representing my clients intended to pursue an appeal of that dismissal. 
Moreover, all of the subjects mentioned in the RICO claim remained relevant to other 
aspects of Jane Doe's claims against Epstein. including in particular he:r claim for 
punitive drunages; (b) Jane Doo also filed and was proceeding to trial on a federal claim 
under 18 U.S.C. § 2255. Section 2255 is a federal statute which (unlike other state 
statutes) guaranteed a minimum level of recovery for Jane Doe. Proceeding tmder the 
statute, however, required a "federal nexus" to the sexual assaults. Jane Doe had two 
grounds on which to argue that such a nexus existed to her abuse by Epstein: first, his 
use of the telephone to arrange for girls to be abused; and, second, his travel on planes 
in interstate commerce. During the course of the litigation, I anticipated that Epstein 
would argue that Jane Doe's proof of the federal nexus was inadequate. These fears 
were realized when Epstein filed a summruy judgment motion raising this rurgwnent. In. 
respo~nse, the other attorneys and I representing Jane Doe used the flight log evidence 
to respond to Epstein's summary judgment motion, explaining that the flight logs 
demonstrated that Epstein had traveled in interstate commerce for the purpose of 
facilitating his sexual assaults. Because Epstein chose to settle the case before trial, 
Judge Marra did not rule on the swnmary judgment motion. (c) Jane Doe No. 102's 
complaint outlined Epstein's daily sexual exploitation and abuse of underage minors as 
young as 12 years old and alleged that he used his plane to transport und...

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subsequent developments in his prosecution. A copy of this letter is attached to this 
Affidavit. (A copy of the letter is attached to Statement of Undisputed Facts as Exhibit 
UU) 
23. 
Jeffrey Epstein also filed a complaint with the Florida Bar against me. His complaint 
alleged that I had been involved in Rothstein's scheme and had the.rreby violated various 
rules of professional responsibility. The Florida Bar investigated and dismissed the 
complaint. 
24. I have reviewed the Statement of Undisputed Facts filed contemporaneously with tllis 
Affidavit. Each of the assertions concerning what I learned, what I did, a:nd the good 
faith beliefs formed by me in the course of my prosecutions of claims against Jeffrey 
Epstein as contained in the Statement of Undisputed Facts is true, and the foundations 
set out as support for my beliefs Bll!'e true and correct to the best of my knowledge. 
25. AU actions taken by me in the course of my prosecution of claims against Jeffrey 
Epstein were based upon a good faith belief that they were reasonable, necessscy, and 
ethically proper to fullfiU my obligation to zealously represent the interests of my 
clients. 
I declare under penalty of perjury that the foregoing is true and correct. 
Dated:~ 2010 
c.,.-f ~ = ~ 
2 
Bradley J. Edwards, Esq. 

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JEFFREY EPSTEIN, 
Plaintiff, 
vs. 
SCOTT ROTHSTEIN, individually, and 
BRADLEY J. EDWARDS, :individually, 
Defendants, 
_____________ 
_____,! 
IN THE CIRCUIT COURT OF THE 15TH 
nJDICIAL CIRCUIT IN AND FOR PALM 
BEACH COUNTY, FLORIDA 
Case No.: 50 2009CA 040800XXXXIY1BAG 
DEFENDANT BRADLEY J. EDW ARDS'S 
RENEWED MOTION FOR FINAL SUMMARY JUDGMENT 
Defendant, Bradley J. Edwards, Esq., by and through his undersigned counsel and 
pursuant to Rule 1.510, Florida Rules of Civil Procedure, hereby moves for Final Summary 
Judgment and in support thereof states as follows: 
I. INTRODUCTION 
The pleadings and discovery taken to date show that there is no genuine issue as to any 
material facts and that Bradley J. Edwards, Esq. is entitled to summary judgn1ent for all claims 
brought against him in Plaintiff Jeffrey Epstein's Second Amended Complaint. Not only is there 
an absence of competent evidence to demonstrate that Edwards participated in any fraud against 
Epstein, the evidence uncontrovertibly demonstrates the propriety of every aspect of Edwards' 
involvement in the prosecution of legitimate claims against Epstein. Epstein sexually abused 
three clients of Edwards - L.M., E.W., and Jane Doe - and Edwards properly and successfully 
EXHIBIT 

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represented them in a civil action against Epstein. Nothing in Edwards's capable and competent 
representation of his clients can serve as the basis for a civil lawsuit against him. Allegations 
about Edwards's participation in or knowledge of the use of the civil actions against Epstein in a 
"Ponzi Scheme" are not supported by any competent evidence and could never be supported by 
competent evidence as they are entirely false. 
A. 
Epstein's Complaint 
Epstein's Second Amended Complaint essentially alleges that Epstein was damaged by 
Edwards, acting in ~oncert with Scott Rothstein (President of the Rothstein Rosenfeldt Adler law 
firm ("RRA") where Edwards worked for a short period of time). Epstein appears to allege that 
Edwards joined Rothstein in the abusive prosecution of sexual assault cases against Epstein to 
"pump" the cases to Ponzi scheme investors. As described by Epstein, investor victims were 
told by Rothstein that three minor girls who were sexually assaulted by Epstein: L.M., E.W., and 
Jane Doe were to be paid up-front money to prevent those girls from settling their civil cases 
against Epstein. 
In Epstein's view, these child sexual assault cases had "minimal value" 
(Complaint & 42(h)), and Edwards's refusal to force his clients to accept modest settlement 
offers is claimed to breach some duty that Edwards owed to Epstein. Interestingly, Epstein never 
states that he actually made any settlement offers. 
The supposed "proof' of the Complaint's allegations against Edwards includes 
Edwards's alleged contacts with the media, his attempts to obtain discovery from high-profile 
persons with whom Epstein socialized, and use of "ridiculously inflammatory" language in 
arguments in court. Remarkably, Epstein has filed such allegations against Edwards despite the 
fact that Epstein had sexually abused each of Edwards' s clients and others while they were 
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minors. Indeed, in discovery Epstein has asserted his Fifth Amendment privilege rather than 
answer questions about the extent of the sexual abuse of his many victims. Even more 
ren:iarkably, since filing his suit against Edwards, Epstein has now settled the three cases 
Edwards handled for an amount that Epstein insisted be kept confidential. Without violating the 
strict confidentiality tenns required by Epstein, the cases did not settle for the "minimal value" 
that Epstein suggested in his Complaint. Because Epstein relies upon the alleged discrepancy 
between the "minimal value" Epstein ascribed to the claims and the substantial value Edwards 
sought to recover for his clients, the settlement an1ounts Epstein voluntarily agreed to pay while 
these claims against Edwards were pending will be disclosed to the court in-camera. 
B. Summary of the Argument 
Bradley J. Edwards, Esq., is entitled to summary judgment on Epstein's frivolous claim 
for at least three separate reasons. 
First, because Epstein has elected to hide behind the shield of his right against self 
incrimination to preclude his disclosing any relevant information about the criminal activity at 
the center of his claims, he is ban-ed from prosecuting this case against Edwards. Under the 
we11-established "sword and shield" doctrine, Epstein cannot seek daniages from Edwards while 
at the same time asserting a Fifth Amendment privilege to block relevant discovery. His case 
must therefore be dismissed. 
Second, all of Edwards' conduct in the prosecution of valid claims against Epstein is 
protected by the litigation privilege. 
Third, and most fundamentally, Epstein's lawsuit should be dismissed because it is not 
only unsupported by but is also directly contradicted by all of the record evidence. From the 
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beginning, Edwards diligently represented three victims of sexual assaults perpetrated by 
Epstein. As explained in detail below, each and every one of Edwards' s litigation decisions was 
grounded in prope1:" litigation judgment about the need to pursue effective discovery against 
Ep~tein, particularly in the face of Epstein's stonewalling tactics. 
Edwards's successful 
representation finally forced Epstein to settle and pay appropriate damages. Effective and proper 
representation of child victims who have been repeatedly sexually assaulted cannot form the 
basis of a separate, ~'satellite" lawsuit, and therefore Edwards is entitled to summary judgment on 
these grounds as well. 
The truth is the record is entirely devoid of any evidence to support Epstein's claims and 
is completely and consistently corroborative of Edwards' s sworn assertion of innocence. Put 
simply, Epstein has.made allegations that have no basis in fact. To the contrary, his lawsuit was 
merely a desperate measure by a serial pedophile to prevent being held accountable for 
repeatedly sexually abusing minor females. Epstein's ulterior motives in filing and prosecuting 
this lawsuit are blatantly obvious. Epstein's behavior is another clear demonstration that he feels 
he lives above the law and that because of his wealth he can manipulate the system and pay for 
lawyers to do his dirty work - even to the extent of having them assert baseless claims against 
other members of the Florida Bar. Epstein's Second Amended Complaint against Edwards is 
nothing short of a far-fetched fictional fairy-tale with absolutely no evidence whatsoever to 
support his preposterous claims. It was his last ditch effort to escape the public disclosure by 
Edwards and his clients of the nature, extent, and sordid details of his life as a serial child 
molester. Edwards's Motion for Summary Judgment should be granted without equivocation. 
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ARGUMENT 
II. 
EDWARDS IS ENTITLED TO SUMMARY JUDGMENT ON EPSTEIN'S 
CLAIM BECAUSE THERE ARE NO MATERIAL DISPUTED FACTS AND THE 
UNDISPUTED FACTS ESTABLISH THAT EDWARDS'S CONDUCT COULD 
NOT POSSIBLY FORM THE BASIS OF ANY LIABILITY IN FAVOR OF EPSTEIN 
A. The Summary Judgment Standard. 
Rule 1.510( c ), Florida Rules of Civil Procedure, provides that a court may enter summary 
judgment when the•pleadings, depositions and factual showings reveal that there is no genuine 
issue of material fact and that the moving party is entitled to judgment as a matter of law. See 
Snyder v. Cheezem Development C01p., 373 So. 2d 719, 720 (Fla. 2d DCA 1979); Rule 1.510(c), 
Fla. R. Civ. P. Once the moving party conclusively establishes that the nonmoving party cannot 
prevail, it is incumbent on the nonmoving party to submit evidence to rebut the motion for 
summary judgment. See Holl v. Talcott, 191 So. 2d 40, 43 (Fla. 1966). It is not enough for the 
opposing party merely to assert that an issue of fact does exist. Fisel v. VVjmns, 667 So.2d 761, 
764 (Fla.1996); Landers v. Milton, 370 So.2d 368,370 (Fla.1979) (same). 
Moreover, it is well-recognized that the non-moving party faced with a summary 
judgn1ent motion supported by appropriate proof may not rely on bare, conclusory assertions 
found in the pleadings to create an issue and thus avoid summary judgment. Instead, the party 
must produce counter~evidence establishing a genuine issue of material fact. See B1yant v. 
Shands Teaching Hospital and Clinics, Inc., 479 So.2d 165, 168 (Fla. 1st Dist. Ct. App. 1985); 
see also Lanzner v. City of North Miami Beach, 141 So.2d 626 (Fla. 3d Dist Ct. App. 1962) 
(recognizing that mere contrary allegations of complaint were not sufficient to preclude summary 
judgment on basis of facts established without dispute). Where the nonmoving party fails to 
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present evidence rebutting the motion for summary judgment and there is no genuine issue of 
material fact, then entry of judgment is proper as a matter of law. See Davis v. Hathaway, 408 
So. 2d 688,689 (Fla. 2d Dist. Ct. App. 1982); see also Holl, 191 So. 2d at 43. 
B. Epstein'·s Claim Regarding Edwards Have Absolutely No Factual Basis. 
This is not a complicated case for granting summary judgment. To the contrary, this is a 
simple case for summary judgment because each and every one of Epstein's claim against 
Edwards lacks any merit whatsoever.1 • 
1. 
Epstein's allegations regarding Edwards' involvement in Rothstein's "Ponzi 
Scheme" are unsupported and unsupportable because he was simply not 
involved in any such scheme. 
a. Edwards Had No Involvement in the Ponzi Scheme. 
The bulk of Epstein's claims against Edwards hinge on the premise that Edwards was 
involved in a Ponzi· scheme run by Scott Rothstein. Broad allegations of wrongdoing on the part 
of Edwards are scattered willy-nilly throughout the complaint. None of the allegations provide 
any substance as to how Edwards actually assisted the Ponzi scheme, and allegations that he 
"knew or should have known" of its existence are based upon an impennissible pyramiding of 
inferences. In any event, these allegations all fail for one straightforward reason: Edwards was 
simply not involved in any Ponzi scheme. He has provided sworn testimony and an affidavit in 
support of that assertion, and there is not ( and could never be) any contrary evidence. 
Edwards has now been deposed at length in this case. As his deposition makes crystal 
clear, he had no knowledge of any fraudulent activity in which Scott Rothstein may have been 
1 A decision by the Court to grant summary judgment on Epstein's claims against Edwards would not affect 
Epstein's claims against Scott Rothstein. Epstein has already chosen to dismiss all of his claims against L.M., the 
only other defendant named in the suit. 
...

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involved. See, e.g., ·Edwards Depo. at 301-02 (Q: " ... [W]ere you aware that Scott Rothstein 
was trying to market Epstein cases ... ?" A: "No."). 
Edwards has supplemented his deposition answers with an Affidavit that declares in no 
uncertain tern1s his lack of involvement in any fraud perpetrated by Rothstein. 
See, e.g., 
Edwards Affidavit attached to Statement of Undisputed Material Facts as Exhibit ''N" at if8-10, 
,r20, if22-23. Indeed, no reasonable juror could find that Edwards was involved in the scheme, as 
Edwards joined RRA well after Rothstein began his fraud and would have been already deeply in 
debt. In fact, the evidence of Epstein's crimes is now clear, and Edwards's actions in this case 
were entirely in keeping with his obligation to provide the highest possible quality of legal 
representation for his clients to obtain the best result possible. 
In view of this clear evidence rebutting all allegations against him, Epstein must now 
"produce counter-evidence establishing a genuine issue of material fact." See B1yant v. Shands 
Teaching Hospital and Clinics, Inc., 479 So.2d 165, 168 (Fla. 1st Dist. Ct. App. 1985). Epstein 
cannot do this. Indeed, when asked at his deposition whether he had any evidence of Edwards's 
involvement, Epstein declined to answer, purportedly on attorney-client privilege grounds: 
Q. I want to know whether you have any knowledge of evidence that Bradley 
Edwards personally ever participated in devising a plan through which were sold 
purported confidential assignments of a structured payout settlement? ... 
A. I'd like to answer that question by saying that the newspapers have reported 
that his firm was engaged in fraudulent structured settlements in order to fleece 
unsuspecting Florida investors. With respect. to my personal knowledge, I'm 
unfortunately going to, today, but I look forward to at some point being able to 
disclose it, today I'm going to have to assert the attorney/client privilege...

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b. 
Epstein's Allegations of Negligence by Edwards are Unfounded and Not 
Actionable in Any Event. 
In his Second Amended Complaint Epstein recognizes at least the possibility that 
Edwards was not involved in any Rothstein Ponzi scheme. Therefore, seemingly as a fallback, 
Epstein alleges without explanation that Edwards "should have known" about the existence of 
this concealed Ponzi scheme. Among other problems, this fallback negligence position suffers 
the fatal flaw that it does not link at all to the intentional tort of abuse of process alleged in the 
complaint. 
Epstein's negligence claim is also deficient because it simply fails to satisfy the 
requirements for a negligence cause of action: 
"Four elements are necessary to sustain a negligence claim: 1. A duty, or 
obligation, recognized by the law, requiring the [defendant] to conform to a 
certain standard of conduct, for the protection of others against unreasonable 
risks. 2. A failure on the [defendant's] part to confonn to the standard required: a 
breach of the duty . . . . 3. A reasonably close causal connection between he 
conduct and the resulting injury. This is what is commonly known as 'legal 
cause,' or 'proximate cause,' and which includes the notion of cause in fact. 4. 
Actual loss or damage. 
Curd v. Mosaic Fertilizer, LLC, _ 
So.2d _, 2010 WL 2400384 at *9 (Fla. 2010). Epstein 
does not allege a particular duty on the part of Edwards that has been breached. Nor does 
Epstein explain how any breach of the duty might have proximately caused him actual damages. 
Summary judgment is therefore appropriate for these reasons as well. 
Finally, for the sake of completeness, it is worth noting briefly that no reasonable jury 
could find Edwards to have been negligent in failing to anticipate that a managing partner at his 
law firm would be involved in an unprecedented Ponzi scheme. Scott Rothstein deceived not 
8 

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only Edwards but also more than 60 other reputable lawyers at a major law film. 
Cf. Sun 
Sentinel, Fort Lauderdale, Dec. 11, 2009, 2009 WLNR 25074193 at *1 ("Sure, some outlandish 
John Grisham murder plot[s] sound far-fetched. But if you asked me a few months ago if Scott 
Rothstein was fabricating federal court orders and forging a judge's signature on documents to 
allegedly fleece his friends, as federal prosecutors allege, I would have said that was far-fetched, 
too:"). No reasonable lawyer could have expected that a fellow member of the bar would have 
been involved in such a plot. Nobody seemed to know ofRothstein's Ponzi scheme, not even his 
best friends, or the people he did business with on a daily basis, or even his wife. Many of the 
attorneys at RRA h~d been there for years and knew nothing. Edwards was a lawyer at RRA for 
less than 8 months and had very few personal encounters with Rothstein during his time at the 
firn1, yet Epstein claims that he should have known of Rothstein's intricate Ponzi scheme. No 
doubt for this reason the U.S. Attorney's Office has now listed Edwards as a "victim" of 
Rothstein' s crimes .. See Statement of Undisputed Facts filed contemporaneously. 
Epstein's Complaint does not offer any specific reason why a jury would conclude that 
Edwards was negligent, and he chose not to offer any explanation of his claim at his deposition. 
Accordingly, Edwards is entitled to summary judgment to the extent the claim against him is 
somehow dependent upon his negligence in failing to discover Rothstein's Ponzi scheme. 
2. 
Edwards is Entitled to Summary Judgment to the Extent the Claim Against 
Him is Dependent on Allegations Regarding "Pumping the Cases" Because 
He Was Properly Pursuing the Interests of His Three Clients Who Had Been 
Sexually Abused by Epstein. 
Epstein alleges that Edwards somehow improperly enhanced the value of the three civil 
cases he had filed against Epstein. Edwards represented thre...

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mmors. Epstein purports to fmd a cause of action for this by alleging that Edwards somehow 
was involved in '"pumping' these three cases to investors." 
As just explained, to the extent that Epstein is alleging that Edwards somehow did 
something related to the Ponzi scheme, those allegations fail for the simple reason that Edwards 
was not involved in any such scheme. Edwards, for example, could not have possibly "pumped" 
the cases to investors when he never participated in any communication with investors. 
Epstein's "pumping" claims, however, fail for an even more basic reason: Edwards was 
entitled - indeed ethically obligated as an attorney - to secure the maximum recovery for his 
clients during the course of his legal representation. As is well lmown, "[a]s an advocate, a 
lawyer zealously asserts the client's position under the rules of the adversary system." Fla. Rules 
of Prof. Conduct, Preamble. 
Edwards therefore was required to pursue (unless otherwise 
instructed by his clients) a maximum recovery against Epstein. Edwards, therefore, cannot be 
liable for doing something that his ethical duties as an attorney required.2 
Another reason that Epstein's claims that Edwards was "pumping" cases for investors 
fails is that Edwards filed all three cases almost a year before he was hired by RR.A or even lmew 
of Scott Rothstein. 
Epstein makes allegations that the complaints contained sensational 
allegations for the purposes of luring investors; however, language in the complaints remained 
virtually unchanged from the first filing in 2008 and from the overwhelming evidence the Court 
cari see for itself that all of the facts alleged by Edwards in the complaints were true. 
Epstein ultimately paid to settle all three of the cases Edwards filed against him for more 
money than he paid to settle any of the other claims against him. At Epstein's request, the terms 
2 In a further effort to harass Edwards, Epstein also filed a bar complaint...

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of the settlement were kept confidential. The sum that he paid to settle all these cases is 
therefore not filed with this pleading and will be provided to the court for in-camera review. 
Epstein chose to make this payment as the result of a federal court ordered mediation process, 
which he himself sought ( over the objection of Jane Doe, Edwards' client in federal court) in an 
effort to resolve the case. 
See Defendant's Motion for Settlement Conference, or in the 
Alternative, Motion to Direct Parties back to Mediation, Doe v. Epstein, No. 9:08-CV-80893 
(S.D. Fla. J:une 28, 2010) (Marra, J.) (doc. #168) attached hereto as Exhibit "A". Notably, 
Epstein sought this settlement conference - and ultimately made his payments as a result of that 
conference - in July 2010, more than seven months after he filed this lawsuit against Edwards. 
Accordingly, Epstein could not have been the victim of any scheme to "pump" the cases against 
him, because he never paid to settle the cases until well after Edwards had left RRA and had 
severed all com1ection with Scott Rothstein (December 2009). 
In addition, if Epstein had thought that there was some improper coercion involved in, for 
example, Jane Doe's case, his remedy was to raise the matter before Federal District Court Judge 
Kenneth A. Marra who was presiding over the matter. Far from raising any such claim, Epstein 
simply chose to settle that case. He is therefore now barred by the doctrine of res judicata from 
somehow re-litigating what happened in (for example) the Jane Doe case. "The doctrine of res 
judicata makes a judgment on the merits conclusive 'not only as to every matter which was 
offered and received to sustain or defeat the claim, but as to every other matter which might with 
propriety have been litigated and determined in that action." AMEC Civil, LLC v. State Dept. of 
Transp., _ 
So.2d _, 2010 WL 1542634 at *2 (Fla. 1st Dist. Ct. App. 2010) (quoting Kimbrell 
v. Paige, 448 So....

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particular case could have been resolved in that ve,y case rather than now re-litigated in satellite 
litigation. 
3. 
Edwards is Entitled to Summary Judgment on the Claim of 
Abuse of Process Because He Acted Properly Within the Boundaries of the 
Law in Pursuit of the Legitimate Interests of his Clients. 
Epstein's Second Amended Complaint raises several claims of "abuse of process." An 
abuse of process claim requires proof of three elements: "(l) that the defendant made an illegal, 
improper, or perverted use of process; (2) that the defendant had ulterior motives or purposes in 
exercising such illegal, improper, or perverted use of process; and (3) that, as a result of such 
action on the part of the defendant, the plaintiff suffered damage." S & I Investments v. Payless 
Flea Market, Inc., 36 So.3d 909, 917 (Fla. 4th Dist. Ct. App. 2010) (internal citation omitted). In 
fact, this Court is very familiar with this cause of action, as Edwards has correctly stated this 
cause in his counterclaim against Epstein. Edwards is entitled to summary judgment because 
Epstein cam1ot prove these elements. 
The first element of an abuse of process claim is that a defendant made "an illegal, 
improper, or perverted use of process." On the surface, Epstein's Complaint appears to contain 
several allegations of such improper process. 
On examination, however, each of these 
allegations amounts to nothing other than a claim that Epstein was unhappy with some 
discovery proceedi~g, motion or argument made by Edwards. This is not the stuff of an abuse of 
pro'cess claim, particularly where Epstein fails to allege that he was required to do something as 
the'result of Edwards' pursuit of the claims against him. See Marty v. Gresh, 501 So.2d 87, 90 
(Fla. 1st Dist. Ct. App. 1987) (affirming summary judgment on an abuse of process claim where 
"appellant's lawsuit. caused appellee to do nothing against her will"). 
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In any event, none of the allegations of "improper" process can survive summary 
judgment scrutiny, because every action Edwards took was entirely proper and reasonably 
calculated to lead to the successful prosecution of the pending claims against Epstein as detailed 
in Edwards' Affidavit. 
Epstein also fails to meet the second element of an abuse of process claim: that Edwards 
had some sort of ulterior motive. The case law is clear that on an abuse of process claim a 
"plaintiff must prove that the process was used for an immediate purpose other than that for 
which it was designed." S&I Investments v. Payless Flea Market, Inc., 36 So.3d 909, 917 (Fla. 
4th Dist. Ct. App. 2010) (citing Biondo v. Powers, 805 So.2d 67, 69 (Fla. 4th Dist. Ct. App. 2002). 
As . a consequence, "[ w ]here the process was used to accomplish the result for which it was 
intended, regardless of an incidental or concurrent motive of spite or ulterior purpose, there is no 
abuse of process." Id. (internal quotation omitted). 
Here, Edwards has fully denied any 
improper motive, See Statement of Undisputed Facts, and Epstein has no evidence of any such 
motivation. Indeed, it is revealing that Epstein chose not to ask even a single question about this 
subject during the deposition of Edwards. In addition, all of the actions that Epstein complains 
about were in fact used for the immediate purpose of furthering the lawsuits filed by L.M., E.W., 
and Jane Doe. In other words, these actions all were both intended to accomplish and, in fact, 
successfully "accomplished the results for which they were intended" -- whether it was securing 
additional discovery or presenting a legal issue to the court handling the case or ultimately 
maximizing the recovery of damages from Epstein on behalf of his victims. Accordingly, 
Edwards is entitled to summary judgment on any claim that he abused process for this reason as 
well. 
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4. 
Edwards is Entitled to Summary Judgment to the Extent His Claim is Based 
On Pursuit of Discovery Concerning Epstein's Friends Because All Such 
Efforts Were Reasonably Calculated to Lead to Relevant and Admissible 
Testimony About Epstein's Abuse of Minor Girls. 
Epstein has ~lso alleged that Edwards improperly pursued discovery from some his close 
friends. 
Such discovery, Epstein claims, was improper because Edwards knew that these 
individuals lacked any discoverable information about the sexual assault cases against Epstein. 
Here again, Edwards is entitled to summary judgment, as each of the friends of Epstein 
were reasonably beFeved to possess discoverable information. The undisputed facts show the 
following with regard to each of the persons raised in Epstein's complaint: 
• 
With regard to Donald Trump, Edwards had sound legal basis for believing Mr. 
Trump had relevant and discoverable information. See Statement of Undisputed 
Facts. 
• 
With regard to Alan Dershowitz (Harvard Law Professor), Edwards had sound 
legal basis for believing Mr. Dershowitz had relevant and discoverable 
information. See Statement of Undisputed Facts. 
= With regard to fonner President Bill Clinton, Edwards had sound legal basis for 
believing former President Clinton had relevant and discoverable information. 
See Statement of Undisputed Facts. 
• 
With regard to fom1er Sony Record executive Tommy Mottola, Edwards was not 
the attorney that noticed Mr. Mottola's deposition. See Statement of Undisputed 
Facts. 
• 
With regard to illusionist David Copperfield, Edwards had sound legal basis for 
believing Mr. Copperfield had relevant and discoverable information. 
See 
Statement of Undisputed Facts. 
• 
With regard to former New Mexico Governor Bill Richardson, Edwards had 
sound legal basis for naming Forn1er New Mexico Governor Bill Richardson on 
his witness list. See Statement of Undisputed Facts. 
It is worth noting that the standard for discovery ...

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admissible evidence. Otherwise, every deposition that tumed out to be a false alarm would lead 
to an "abuse of process" claim. Moreover, the rules of discovery themselves provide that a 
deposition need only be "reasonably calculated to lead to the discovery of admissible evidence." 
Fla. R. Civ. P. 1.280(b) (emphasis added). 
Moreover, the discovery that Edwards pursued has to be considered against the backdrop 
of Epstein's obstructionist tactics. As the Court is aware, in both this case and all other cases 
filed against him, Epstein has asserted his Fifth Amendment privilege rather than answer any 
substantive questions. Epstein has also helped secure attomeys for his other household staff who 
assisted in the process of recruiting the minor girls, who in tum also asserted their Fifth 
Amendment rights rather than explain what happened behind closed doors in Epstein's mansion 
in West Palm Beach. See Statement of Undisputed Facts. It is against this backdrop that 
Edwards followed up on one of the only remaining lines of inquiry open to him: discovery aimed 
at Epstein's friends who might have been in a position to corroborate the fact that Epstein was 
sexually abusing young girls. 
In the context of the sexual assault cases that Edwards had filed against Epstein, any act 
of sexual abuse had undeniable relevance to the case - even acts of abuse Epstein committed 
against minor girls other than L.M., E.W., or Jane Doe. Both federal and state evidence rules 
make acts of child abuse against other girls admissible in the plaintiff's case in chief as proof of 
"modus operandi" or "motive" or "common scheme or plan." See Fed. R. Evid. 415 (evidence of 
other acts of sexual abuse automatically admissible in a civil case); Fla. Stat. Ann. 90.404(b) 
(evidence of common scheme admissible); Williams v. State, 110 So.2d 654 (Fla. 1959) (other 
acts of potential sexual misconduct admissible). 
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A second reason exists for making discovery of Epstein's acts of abuse of other minor 
girls admissible. Juries considering punitive damages issues are plainly entitled to consider "the 
existence and :frequency of similar past conduct." TXO Production C01p. v. Alliance Resources 
C01p., 509 U.S. 443, 462 n.28 (1993). This is because the Supreme Court recognizes "that a 
recidivist may be punished more severely than a first offender ... [because] repeated misconduct 
is more reprehensible than an individual instance of malfeasance." BMW of North America, Inc. 
v. Gore, 517 U.S. 559,577 (1996) (supporting citations omitted). In addition,juries can consider 
other similar acts evidence as part of the deterrence calculation in awarding punitive damages, 
because "evidence t.hat a defendant has repeatedly engaged in prohibited conduct while knowing 
... that it was unlawful would provide relevant support for an argument that strong medicine is 
required to cure the defendant's disrespect for the law." Id. at 576-77. In the cases Edwards 
filed against Epstein, his clients were entitled to attempt to prove that Epstein "repeatedly 
engaged in prohib~ted conduct" - i.e., because he was a predatory pedophile, he sexually 
assaulted dozens and dozens of minor girls. The discovery of Epstein's friends who might have 
haci direct or circumstantial evidence of other acts of sexual assault was accordingly entirely 
proper. Edwards is therefore entitled summary judgment to the extent his claim is based on 
efforts by Edwards to obtain discovery of Epstein's friends. 
m. 
EPSTEIN'S LA WSIDT MUST BE DISMISSED BECAUSE OF ms REFUSAL TO 
PARTICIPATE IN REASONABLE DISCOVERY. 
As is readily apparent from the facts of this case, Epstein has filed a lawsuit but then 
refysed to allow any real discovery about the merits of his case. Instead, when asked hard 
questions about whether he has any legitimate claim at all, Epstein has hidden behind the Fifth 
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Amendment. As a result, under the "sword and shield doctrine" widely recognized in Florida 
caselaw, his suit must be dismissed. 
"[T]he law is well settled that a plaintiff is not entitled to both his silence and his 
lawsuit." Boys & Girls Clubs of Marion County, Inc. v. J.A., 22 So.3d 855, 856 (Fla. 5th Dist. 
Ct. App. 2009) (Griffin, J., concurring specially). Thus, "a person may not seek affirmative 
relief in a civil action and then invoke the fifth amendment to avoid giving discovery, using the 
fifth amendment as both a 'sword and a shield."' DePalma v. DePalma, 538 So.2d 1290, 1290 
(Fla. 4th Dist. Ct. App. 1989) (quoting DeLisi v. Bankers Insurance Co., 436 So.2d 1099 (Fla. 4th 
Dist. Ct. App. 1983)). Put another way, "[a] civil litigant's fifth amendment right to avoid self-
incrimination may be used as a shield but not a sword. This means that a plaintiff seeking 
aff:irmative relief in a civil action may not invoke the fifth amendment and refuse to comply with 
the defendant's discovery requests, thereby thwarting the defendant's defenses." Rollins Burdick 
Hunter of New York, Inc. v. Euroclassic Limited, Inc., 502 So. 2d 959 (Fla. 3rd Dist. Court App. 
1983). 
Here, Epstein is trying to do precisely what the "well settled" law forbids. Specifically, 
he is trying to obtain "affirmative relief' - i.e., forcing Edwards to pay money damages -while 
simultaneously precluding Edwards from obtaining legitimate discovery at the heart of the 
allegations that form the basis for the relief Epstein is seeking. As recounted more fully in the 
statement of undisputed facts, Epstein has refused to answer such basic questions about his 
lawsuit as: 
• 
"Specifically what are the allegations against you which you contend Mr. 
Edw~rds ginned up?" 
111 
"Well, which of Mr. Edwards' cases do you contend were fabricated?" 
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11 
"Is there anything in L.M. 's Complaint that was filed against you in September of 
2008_ which you contend to be false?" 
11 
"I would like to lmow whether you ever had any physical contact with the person 
referred to as Jane Doe in that [federal] complaint?" 
• 
"Did you ever have any physical contact with E.W.?" 
• 
"What is the actual value that you contend the claim of E.W. against you has?" 
The matters addressed in these questions are the central focus of Epstein's claims against 
Edwards. Epstein's refusal to answer these and literally every other substantive question put to 
him in discovery has deprived Edwards of even a basic understanding of the evidence alleged to 
support claims against him. Moreover, by not offering any explanation of his allegations, 
Epstein is depriving Edwards of any opportunity to conduct third party discovery and 
opportunity to challenge Epstein's allegations. 
It is the clear law that "the chief purpose of our discovery rules is to assist the truth-
finding function of our justice system and to avoid trial by surprise or ambush," Scipio v. State, 
928 So.2d 1138 (Fla.2006), and "full and fair discovery is essential to these important goals," 
McFadden v. State, 15 So.3d 755, 757 (Fla. 4th Dist. Ct. App. 2009). Accordingly, it is important 
for the Court to insure "not only compliance with the technical provisions of the discovery rules, 
but also adherence to the purpose and spirit of those rules in both the criminal and civil context." 
McFadden, 15 So.3d at 757. Epstein has repeatedly blocked "full and fair discovery," requiring 
dismissal of his claim against Edwards. 
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IV. 
EDWARDS IS ENTITLED TO ADVERSE INFERENCES FROM 
EPSTEIN'S INVOCATION OF THE FIFTH AMENDMENT AND 
THEREFORE TO SUMMARY JUDGMENT ON EPSTEIN'S CLAIM. 
Edwards is entitled to summary judgment on the claim against him for a second and 
entirely independent reason: Epstein's repeated invocations of the Fifth Amendment raise 
adverse inferences against him that leave no possibility that a reasonable factfinder could reach a 
verdict in his favor. 
In ruling on a summary judgment motion, the court must fulfill a 
"ga:tekeeping function" and should ask whether "a reasonable trier of fact could possibly" reach 
a verdict in favor of the plaintiff. Willingham v. City of Orlando, 929 So.2d 43, 48 (Fla. 5th Dist. 
Ct. App. 2006) ( emphasis added). Given all of the inferences that are to be drawn against 
Epstein, no reasonable finder of fact could conclude that Epstein was somehow the victim of 
improper civil lawsuits filed against him. Instead, a reasonable finder of fact could only find that 
Epstein was a serial molester of children who was being held accountable through legitimate 
suits brought by Edwards and others on behalf of the minor girls that Epstein victimized. 
"[I]t is well-settled that the Fifth Amendment does not forbid adverse inferences against 
parties to civil actions when they refuse to testify in response to probative evidence offered 
against them." Baxter v. Palmigiano, 425 U.S. 308, 318 (1976); accord Vasquez v. State, 777 
So.2d 1200, 1203 (Fla. App. 2001). The reason for this rule "is both logical and utilitarian. A 
party may not trample upon the rights of others and then escape the consequences by invoking a 
constitutional privilege - at least not in a civil setting." Fraser v. Security and Inv. C01p., 615 
So.2d 841, 842 (Fla. 4th Dist. Ct. App. 1993). And, in the proper circumstances, '"Silence is 
often evidence of the most persuasive character."' Fraser v. Security and Inv. Co1p., 615 So.2d 
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841, 842 (Fla. 4th Dist. Ct. App. 1993) (quoting United States ex rel. Bilolaansky v. Tod, 263 U.S. 
149, 153-154 (1923) (Brandeis, J.). 
In the circumstances of this case, a reasonable finder of fact would have "evidence of the 
most persuasive character" from Epstein's repeated refusal to answer questions propounded to 
him. To provide but a few examples, here are questions that Epstein refused to answer and the 
reasonable inference that a reasonable fmder of fact would draw: 
• 
Question not answered: "Specifically what are the allegations against you which 
you contend Mr. Edwards ginned up?" Reasonable inference: No allegations 
against Epstein were ginned up. 
• 
Question not answered: "Well, which of Mr. Edwards' cases do you contend 
were fabricated?" Reasonable inference: No cases filed by Edwards against 
Epstein were fabricated. 
• 
Question not answered: "Did sexual assaults ever take place on a private airplane 
on which you were a passenger?" Reasonable inference: Epstein was on a private 
airplane while sexual assaults were taking place. 
• 
Question not answered: "How many minors have you procured for prostitution?" 
Reasonable inference: Epstein has procured multiple minors for prostitution. 
• 
Question not answered: "Is there anything in L.M. 's Complaint that was filed 
against you in September of 2008 which you contend to be false?" Reasonable 
inference: Nothing in L.M. 's complaint filed in September of 2008 was false -
i.e., as alleged in L.M. 's complaint, Epstein repeatedly sexually assaulted her 
while she was a minor and she was entitled to substantial compensatory and 
punitive damages as a result. 
• 
Question not answered: "I would like to know whether you ever had any physical 
contact with the person referred to as Jane Doe in that [federal] complaint?" 
Reasonable inference: Epstein had physical contact with minor Jane Doe as 
alleged in her federal complaint. 
• 
Question not answered: "Did you ever have any p...

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E.W. against you has?" Reasonable inference: E.W. 's claim against Epstein had 
substantial actual value. 
Without repeating each and every invocation of the Fifth Amendment that Epstein has 
made and the reasonable inferences to be drawn from those invocations of privilege, the big 
picture is unmistakably clear: No reasonable finder of fact could rule in Epstein's favor on his 
claims against Edwards. Accordingly, Edwards is entitled to summary judgment based on the 
Fifth Amendment inferences that the Jury would draw. 
The inferences against Epstein are not limited to those ansmg from his privilege 
assertions. Epstein's guilt is also reasonably infe1Ted from his harassment of, intimidation of, 
efforts to exercise control over, and limitation of access to witnesses who might testify against 
him. 
Epstein's efforts to intimidate his victims support the inference that Epstein knew that 
they were going to provide compelling testimony against him. 
The evidence that Epstein 
tampered with witnesses (later designated as his accomplices and co-conspirators) will be 
admissible to demonstrate his consciousness of guilt. "[I]t is precisely because of the egregious 
nature of such conduct that the law expressly permits the jury to make adverse inferences from a 
partJ's efforts to intimidate witnesses .... " Jost v. Ahmad, 730 So.2d 708, 711 (Fla. 2nd Dist. 
Ct. App. 1998) (internal quotation omitted). 
To be clear, Epstein's attempt to tamper with 
witnesses is "not simply admissible as impeachment evidence of the tampering party's 
credibility. The opposing party is entitled to introduce facts regarding efforts to intimidate a 
witness as substantive evidence." Id. at 711 (emphasis in original) (internal citation omitted). 
This substantive evidence of Epstein's witness intimidation provides yet another reason why no 
reasonable jury could find in favor of his claims against Edwards. 
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V. 
EDWARDS IS ENTITLED TO SUMMARY JUDGMENT ON THE BASIS 
OF ms AFFIRMATIVE DEFENSE OF PRIVILEGE 
Absolute immunity must be afforded any act occurring during course of judicial 
proceeding, regardless of whether act involves defamatory statement or other tortious behavior, 
such as tortious interference with business relationship, so long as act has some relationship to 
proceeding. See Levin, Middlebrooks, Mabie, Thomas, Mayes & Mitchell, P.A. v. U.S. Fire Ins. 
Co., 639 So. 2d 606 (Fla. 1994). The immunity afforded to statements made during the course of 
a judicial proceeding extends not only to the parties in a proceeding but to judges, witnesses, and 
counsel as well. Id. The litigation privilege applies in all causes of action, whether for common-
law torts or statutory violations. See Echevarria, McCalla, Raynier, Barrett & Frappier v. Cole, 
950 So. 2d 3 80 (Fla. 2007). Defamatory statements made by lawyer while interviewing a 
witness in preparation for and connected to pending litigation are covered by the absolute 
immunity conferred by the litigation privilege. See DelMonico v. Traynor, 50 So. 3d 4 (Fla. Dist. 
Ct. App. 4th Dist. 2010), review granted, 47 So. 3d 1287 (Fla. 2010). The privilege extends to 
statements in judicial proceedings or those "necessarily preliminary thereto. See Stewart v. Sun 
Sentinel Co., 695 So.2d 360 (Fla. 4th DCA 1997)(an attorney's delivery of a copy of a notice of 
claim to a reporter, which notice was a required filing prior to instituting suit, was protected by 
absolute immunity). 
CONCLUSION 
For all the foregoing reasons, defendant, the Court should grant defendant Bradley J. 
Edwards, Esq., summary judgment in his favor on the only remaining claim filed against him by 
plaintiff Jeffrey Epstein, and any other relief that the Court deems just and proper. 
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CERTIFICATE OF SERVICE 
/1).j)._/ 
I HEREBY CERTIFY that on November _V_, 2011 a copy of the foregoing has been 
served via Fax and U.S. Mail to all those on the attached service list. 
By: 
Jack Scarola 
Searcy, Dem1ey, Scarola, Barnhart & Shipley 
2139 Palm Beach Lakes Blvd 
West Palm Beach, FL 33409 
(561) 68 -
(561 
84-581 (fax) 
23 

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Christopher E. Knight, Esq. 
Joseph L. Ackerman, Esq. 
FOWLER WHITE BURNETT P.A. 
901 Phillips Point West 
777 South Flagler Drive 
W~st Palm Beach, FL 33401 
Jack Alan Goldberger, Esq. 
Atterbury Goldberger et al. 
250 Australian Avenue South 
Suite 1400 
West Palm Beach, FL 33401 
Mate S. Nurik, Esq. 
Law Offices of Marc S. Nurik 
One E. Broward Blvd., Suite 700 
Fort Lauderdale, FL 33301 
Gary M. Farmer, Jr: 
Farmer, Jaffe, Weissing, 
Edwards, Fistos & Lehi71lan, P .L. 
425 N. Andrews Ave., Suite 2 
Fort Lauderdale, FL 33301 
SERVICE LIST 
24 

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IN THE CIRCUIT COURT OF THE 
FIFTEENTH JUDICIAL CIRCUIT, IN AND 
FOR PALM BEACH COUNTY, FLORIDA 
CASE NO.: 502009CA040800XXXXMBAG 
JEFFREY EPSTEIN, 
Plaintiff( s), 
vs. 
SCOTT ROTHSTEIN, individually, 
BRADLEY J. EDWARDS, individually, and 
L.M., individually, 
Defendant( s ). 
__ 
__ ., _ :;COUNTER-PLAINTIFF; EDWARDS' SEC-OND RENEWED MOTI0.N--FOR.LEAVE TO • 
ASSERT CLAIM FOR PUNITIVE DAMAGES 
Counter-plaintiff, BRADLEY J. EDWARDS, moves this Honorable Court for entry of an 
Order granting him leave to assert a claim for punitive damages against the Counter-defendant, 
·JEFFREY EPSTEIN, and in support thereof would show that the evidence summarized herein 
satisfies the statutory prerequisites for the assertion of a punitive damage claim. Specifically, the 
. evidence establishes that EPSTEIN's Complaint against EDWARDS; 
1. 
was filed in the total absence of evidence to support any allegation of wrongdoing 
on the part of EDWARDS; 
2. 
was filed in the total absence of evidence that EPSTEIN had sustained damage as 
a consequence of any misconduct other than his own well-established criminal 
enterprise; 
3. 
was filed in the absence of any intention to meet his own obligation to provide 
relevant and material discovery; 
EXHIBIT 
C 

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Edwards adv. Epstein 
Case No.: 502009CA040800XXXXMBAG 
Second Renewed Motion for Leave to Assert Claim for Punitive Damages 
4. 
was filed for the sole purpose of attempting to intimidate both EDWARDS and 
EDWARDS' clients and others into abandoning their legitimate claims against 
EPSTEIN. 
APPLICABLE LAW 
To plead a claim for punitive damages, the claimant must show a "reasonable basis" for 
the recovery of such damages. See Fla.R.Civ.P. 1.190(£); see also Globe Newspaper Co. v. King, 
658 So.2d 518, 520 (Fla. 1995). The showing required to amend is minimal. As stated in State 
a/Wis. Inv. v. Plantation Squa_i:~-Assoc., 761 F. Supp. 15'?9, 1580 (S-.D. Fla.---1991):-
--·-· 
[T] he court:freli-lveslff'hiust ufrhiiately be-a iesset standard than that required for-
summary judgment. Though the burden is on [the plaintiff] to survive a §768. 72 
challenge of insufficiency, see Will v. Systems Engineering Consultants, 554 
So.2d 591, 592 (Fla. 3rd DCA 1989), the standard of proof required to assert 
Plaintiff's punitive claim must be lower than that needed to survive a summary 
adjudication on its m~pts. As the Florida courts have noted, a §768.72 challenge 
more closely resembles a motion to dismiss that additionally requires an 
evidentiary proffer and places the burden of persuasion on the plaintiff. Id. In 
considering a motion to dismiss, factual adjudication is inappropriate as all facts 
asserted-or here, reasonably established-by the plaintiff are to be taken as true. 
Conley v. Gibson, 355 U.S. 41, at 45-46, 78 S. Ct. 99, at 101-102, 2 L.Ed. 2d 80, 
1581 at 84. As such, the court has given recognition only to those assertions of 
the defendants which would show Plaintiff's factual bases to be patently false or 
irrelevant, and has paid no heed whatsoever to the defendants' alternative 
evidentiary proffers. 
State of Wis. Inv., 761 F. Supp. At 1580; see also Dolphin Cove Assn. v. Square D. Co., 616 So. 
2d 553 (Fla. 2d DCA 1993) ("Prejudgi...

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Edwards adv. Epstein 
Case No.: 502009CA040800XXXXMBAG 
Second Renewed Motion for Leave to Assert Claim for Punitive Damages 
Section 768.72 provides for the amendment of a complaint either through evidence in the 
record or "proffered by the claimant." As the statute suggests, a proffer of evidence in support 
of a punitive damage claim is sufficient and a formal evidentiary hearing is not required. See 
Strasser v. Yalmanchi, 677 So.2d 22, 23 (Fla. 4th DCA 1996), rev. dismissed, 699 So.2d 1372 
(Fla. 1997); Solis v. Calvo, 689 So.2d 366,369, n.2 (Fla. 3d DCA 1997). In fact, a hearing is not 
even required provided the trial court identifies the filings of the parties and indicates that its 
decision to grant the motion is based upon a review of the file and the respective documents 
-- filed. 
•-theUriitedBtiitesDistrictCourt for the Middle-District of Florida has spoken-clearly on_; 
the nature of a proffer in support of a motion to amend to assert a claim for punitive damages in 
Royal Marco Point I Condo. Ass'n, Inc. v. QBE Ins. Corp., 2010 WL 2609367 (M.D. Fla. June 
30, 2010). As the Court stated:''· 
It is important to emphasize, at the outset, the limited nature of the review a court 
may undertake in considering the sufficiency of an evidentiary proffer under Fla. 
Stat. §768.72. Courts reviewing such proffers have recognized that "a 'proffer' 
according to traditional notions of the term, connotes merely an 'offer' of 
evidence and neither the term standing alone nor the statute itself calls for an 
adjudication of the underlying veracity of that which is submitted, much less for 
countervailing evidentiary submissions." Estate of Despain v. Avante Group, 
Inc., 900 So.2d 63 7, 642 (Fla. 5th DCA 2005) ( quoting State of Wisconsin 
Investment Board v. Plantation Square Associates, Ltd., 761 F. Supp. 1569, 1581 
n. 21 (S.D. Fla. 1991)). 
Therefore, "an evidentiary hearing where witnesses testify and evidence is offered 
and scrutinized ...

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Edwards adv. Epstein 
Case No.: 502009CA040800XXXXMBAG 
Second Renewed Motion for Leave to Assert Claim for Punitive Damages 
It is thus neither necessary nor appropriate for a court to make evidentiary rulings, 
weigh rebuttal evidence, or engage in credibility determinations in considering the 
sufficiency of the proffer. 
" ... a proffer should be evaluated by standards akin to those governing a motion to 
dismiss, where the truth of the plaintiff's allegations are assumed, and not the 
more rigorous summary judgment standard, where the opposing party must show 
that there is sufficient admissible evidence in the record to support a reasonable 
jury finding in his favor." 
I. 
INTRODUCTION 
---
,;The pleadings and discovery taken to date as confirmed by Epstein's voluntary dismissal-
·of aH: ;claims bi-oughf"by him againsFBradleya: Edwards, show that there: is>an -absence of -
competent evidence to demonstrate that Edwards participated in any fraud against Epstein, show 
the propriety of every aspect of Edwards' involvement in the prosecution of legitimate claims 
against Epstein, and further support the conclusion that Epstein sued Edwards out of malice and 
for the purpose of intending to intimidate Edwards and Edwards' clients into abandoning or 
compromising their legitimate claims against Epstein. Epstein sexually abused three clients of 
Edwards -L.M., E.W., and Jane Doe- and Edwards properly and successfully represented them 
in a civil action against Epstein. Nothing in Edwards's capable and competent representation of 
his clients could serve as the basis for a civil lawsuit against him. Allegations about Edwards's 
participation in or knowledge of the use of the civil actions against Epstein in a "Ponzi Scheme" 
were never supported by probable cause or any competent evidence and could never be 
supported by competent evidence as they are entirely false. 
4 

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Edwards adv. Epstein 
Case No.: 502009CA040800XXXXMBAG 
Second Renewed Motion for Leave to Assert Claim for Punitive Damages 
A. 
Epstein's Complaint 
Epstein's Second Amended Complaint essentially alleged that Epstein was damaged by 
Edwards, acting in concert with Scott Rothstein (President of the Rothstein Rosenfeldt Adler law 
firm ("RR.A") where Edwards worked for a short period of time). Epstein appeared to allege that 
Edwards joined Rothstein in the abusive prosecution of sexual assault cases against Epstein to 
"pump" the cases to Ponzi scheme investors. As described by Epstein, investor victims were 
told by Rothstein that three minor girls who were sexually assaulted by Epstein: L.M., E.W., and 
Jane Doe were to be paid up-front money to prevent those girls• from settling their- ·civil cases 
, --,~" -
i:=•· , -.~:.,:,against· Epstein. 
In Epstein ':s: view, · these child sexual assaulFcases ~,.hacl ·"minimal value" -
- --
(Complaint & 42(h)), and Edwards's refusal to force his clients to accept modest settlement 
offers was claimed to breach some duty that Edwards owed to Epstein. Interestingly, Epstein 
• never states·that he actually made any settlement offers. 
The supposed "proof' of the Complaint's allegations against Edwards includes 
Edwards's alleged contacts with the media, his attempts to obtain discovery from high-profile 
persons with whom Epstein socialized, and use of "ridiculously inflammatory" language in 
arguments in court. Remarkably, Epstein has filed such allegations against Edwards despite the 
fact that Epstein had sexually abused each of Edwards' s clients and others while they were 
minors. Indeed, in discovery Epstein has asserted his Fifth Amendment privilege rather than 
answer questions about the extent of the sexual abuse of his many victims. Even more 
remarkably, since filing his suit against Edwards, Epstein settled the three cases Edwards 
handled for an amount that Epstein insisted be kept confident...

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Edwards adv. Epstein 
Case No.: 502009CA040800XXXXMBAG 
Second Renewed Motion for Leave to Assert Claim for Punitive Damages 
confidentiality terms required by Epstein, the cases did not settle for the "minimal value" that 
Epstein suggested in his Complaint. Because Epstein relies upon the alleged discrepancy 
between the "minimal value" Epstein ascribed to the claims and the substantial value Edwards 
sought to recover for his clients, the settlement amounts Epstein voluntarily agreed to pay while 
these claims against Edwards were pending will be disclosed to the court in-camera. 
B. Summary of the Argument 
The claims against Bradley J. Edwards, Esq., were frivolous for at least three separate 
•
0reasons.·· 
First, because -Ep·stei:ri:~elected- to ·hide behind the"--shield of his right against self-~. :; .. _ · 
incrimination to preclude his disclosing any relevant information about the criminal activity at 
the center of his claims, he was barred from prosecuting his case against Edwards. Under the 
well-established "sword and shield" ,doctrine, Epstein could not legitimately seek damages from 
Edwards while at the same time asserting a Fifth Amendment privilege to block relevant 
discovery. His case was therefore subject to summary judgment and on the eve of the hearing 
seeking that summary judgment Epstein effectively conceded that fact by voluntarily dismissing 
his claims. 
Second, all of Edwards' conduct in the prosecution of valid claims against Epstein was 
protected by the litigation privilege, a second absolute legal bar to Epstein's claims effectively 
conceded by his voluntary dismissal. 
Third, and most fundamentally, Epstein's lawsuit was not only unsupported by both the 
applicable law, it was based on unsupported factual allegations directly contradicted by all of the 
6 

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Edwards adv. Epstein 
Case No.: 502009CA040800XXXXMBAG 
Second Renewed Motion for Leave to Assert Claim for Punitive Damages 
record evidence. From the beginning, Edwards diligently represented three victims of sexual 
assaults perpetrated by Epstein. As explained in detail below, each and every one of Edwards's 
litigation decisions was grounded in proper litigation judgment about the need to pursue effective 
discovery against Epstein, particularly in the face of Epstein's stonewalling tactics. Edwards's 
successful representation finally forced Epstein to settle and pay appropriate damages. Effective 
and proper representation of child victims who have been repeatedly sexually assaulted cannot 
form the basis of a separate, "satellite" lawsuit, and therefore Edwards is entitled to summary 
judgment on these grounds as welL 
-·The truth-is the tecord·is entirely devoid,0f-any-evidence to support Epstein~s claims-and 
is completely and consistently corroborative of Edwards's sworn assertion of innocence. Put 
simply, Epstein made allegations that have no basis in fact. To the contrary, his lawsuit was 
merely a desperate measure by a serial pedophile to prevent being held accountable for 
repeatedly sexually abusing minor females. Epstein's ulterior motives in filing and prosecuting 
this lawsuit are blatantly obvious. Epstein's behavior is another clear demonstration that he feels 
he lives above the law and that because of his wealth he can manipulate the system and pay for 
lawyers to do his dirty work - even to the extent of having them assert baseless claims against 
other members of the Florida Bar. Every one of Epstein's Complaints against Edwards was 
nothing short of a far-fetched fictional fairy-tale with absolutely no evidence whatsoever to 
support his preposterous claims. It was his last ditch effort to escape the public disclosure by 
Edwards and his clients of the nature, extent, and sordid details of Epstein's life as a serial c...

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Edwards adv. Epstein 
Case No.: 502009CA040800XXXXMBAG 
Second Renewed Motion for Leave to Assert Claim for Punitive Damages 
ARGUMENT 
II. 
THE 
RECORD 
AND 
PROFFERED 
EVIDENCE ESTABLISHES 
THAT 
EDWARDS'S CONDUCT COULD NOT POSSIBLY FORM THE BASIS OF ANY 
LIABILITY IN FAVOR OF EPSTEIN 
A. The Summary Judgment Standard. 
Rule 1.510( c ), Florida Rules of Civil Procedure, provides that a court may enter summary 
judgment when the pleadings, depositions and factual showings reveal that there is no genuine 
issue of material fact and that the moving,,party is entitled to judgment as-a-matter of'law. See· 
• Snyder-1i,°Cheezem Development Co,p;, ·J7J-Su~ 2d 719; 720 (Fla. 2d DCA l 97-9)fRule:J .5 l·0( c); • 
Fla. R. Civ. P. Once the moving party conclusively establishes that the nonmoving party cannot 
prevail, it is incumbent on the nonmoving party to submit evidence to rebut the motion for 
summary judgment. See-Holl v. -Taicott;d91 So. 2d 40, 43 (Fla. 1966). It is not enough for the' 
opposing party merely to assert that an issue of fact does exist. Fisel v. Wynns, 667 So.2d 761, 
764 (Fla.1996); Landers v. Milton, 370 So.2d 368,370 (Fla.1979) (same). 
Moreover, it is well-recognized that the non-moving party faced with a summary 
judgment motion supported by appropriate proof may not rely on bare, conclusory assertions 
found in the pleadings to create an issue and thus avoid summary judgment. Instead, the party 
must produce counter-evidence establishing a genuine issue of material fact. See Bryant v. 
Shands Teaching Hospital and Clinics, Inc., 479 So.2d 165, 168 (Fla. 1st Dist. Ct. App. 1985); 
see also Lanzner v. City of North Miami Beach, 141 So.2d 626 (Fla. 3d Dist Ct. App. 1962) 
(recognizing that mere contrary allegations of complaint were not sufficient to preclude summary 
8 

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Edwards adv. Epstein 
Case No.: 502009CA040800XXXXMBAG 
Second Renewed Motion for Leave to Assert Claim for Punitive Damages 
judgment on basis of facts established without dispute). Where the norunoving party fails to 
present evidence rebutting the motion for summary judgment and there is no genuine issue of 
material fact, then entry of judgment is proper as a matter of law. See Davis v. Hathaway, 408 
So. 2d 688,689 (Fla. 2d Dist. Ct. App. 1982); see also Holl, 191 So. 2d at 43. Faced with these 
well-established legal principles, Epstein voluntarily dismissed his claims against Edwards on 
the eve of the hearing on Edwards Motion for Summary Judgment. 
B. Epstein's Claim Regarding Edwards Had Absolutely No Factual Basis. 
This was not a complicated case·for granting summary judgment; To the contrary; ·the 
-" a•'c-:.,c.uncontested • record clearly established that each and every one .. of""Epstein's-daims against 
-.""·· 
Edwards lacked any merit whatsoever.1 
1. 
Epstein's allegations regarding Edwards' involvement in Rothstein's "Ponzi 
Scheme" were unsupported and unsupportable because Edwards was simply 
not involved in any such scheme. 
a. Edwards Had No Involvement in the Ponzi Scheme. 
The bulk of Epstein's claims against Edwards hinged on the premise that Edwards was 
involved in a Ponzi scheme run by Scott Rothstein. Broad allegations of wrongdoing on the part 
of Edwards were scattered willy-nilly throughout the complaint. 
None of the allegations 
provided any substance as to how Edwards actually assisted the Ponzi scheme, and allegations 
that he "knew or should have known" of its existence are based upon an impermissible 
pyramiding of inferences. In any event, these allegations all fail for one straightforward reason: 
1 The dismfasal of Epstein's claims against Edwards did not affect Epstein's claims against Scott Rothstein. Epstein 
had already chosen to dismiss all of his claims against L.M., the only other defendant named ...

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Edwards adv. Epstein 
Case No.: 502009CA040800XXXXMBAG 
Second Renewed Motion for Leave to Assert Claim for Punitive Damages 
Edwards was simply not involved in any Ponzi scheme. He has provided sworn testimony and 
an affidavit in support of that assertion (attached), and there is not (and could never be) any 
contrary evidence. 
Edwards was deposed at length in this case. As his deposition makes crystal clear, he had 
no knowledge of any fraudulent activity in which Scott Rothstein may have been involved. See, 
e.g., Edwards Depa. at 301-02 (Q: " ... [W]ere you aware that Scott Rothstein was trying to 
market Epstein cases ... ?" A: "No."). 
-- ,.... . Edwards --supplemented his depositi0n answers -with an Affidavit that declares in nO'",-· .• - -
·uncertain terms his fackc'of--involvement in any fraud perpetrated. by 'Rothstein. -- -See,-- e.g:,-~-- "'~ -"-
Edwards Affidavit attached to Statement of Undisputed Material Facts as Exhibit "N" at if8-10, 
,r20, if22-23. Rothstein has also given sworn testimony (attached) in which he has clearly and 
--unequivocally sworn that Edwards had absolutely no knowledge of or participation in the Ponzi 
scheme. Indeed, no reasonable juror could find that Edwards was involved in the scheme, as 
Edwards joined RRA well after Rothstein began his fraud and would have been already deeply in 
debt. In fact, the evidence of Epstein's crimes is now clear, and Edwards' s actions in this case 
were entirely in keeping with his obligation to provide the highest possible quality of legal 
representation for his clients to obtain the best result possible. 
In view of this clear evidence rebutting all allegations against Edwards, Epstein was 
obliged to "produce counter-evidence establishing a genuine issue of material fact." See B1yant 
v. Shands Teaching Hospital and Clinics, Inc., 479 So.2d 165, 168 (Fla. 1st Dist. Ct. App. 1985) 
in order to avoid summary judgment. Epstein could not and did not even attempt to do t...

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Edwards adv. Epstein 
Case No.: 502009CA040800XXXXMBAG 
Second Renewed Motion for Leave to Assert Claim for Punitive Damages 
Indeed, when asked at his deposition whether he had any evidence of Edwards's involvement, 
Epstein declined to answer, purportedly on attorney-client privilege grounds: 
Q. I want to know whether you have any knowledge of evidence that Bradley 
Edwards personally ever participated in devising a plan through which were sold 
purported confidential assignments of a structured payout settlement? ... 
A. I'd like to answer that question by saying that the newspapers have reported 
that his firm was engaged in :fraudulent structured settlements in order to fleece 
unsuspecting Florida investors. With respect to my personal knowledge, I'm 
unfortunately going to, today, but I look forward to at some point being able to 
disclose it, today I'm going to have to assert the attorney/client privilege. 
See Deposition of Jeffrey Epstein, Mar. 17, 2010 (hereinafter "Epstein Depo.") at 67-68. 
Therefore summary judgment would clearly have been granted for Edwards on all ... claims : _-
involving any Ponzi scheme by Rothstein had the issue not been mooted by Epstein's dismissal 
of his claims. 
b. 
Epstein's Allegations of Negligence by Edwards Were Unfounded and Not 
Actionable in Any Event. 
In his Second Amended Complaint Epstein recognized at least the possibility that 
Edwards was not involved in any Rothstein Ponzi scheme. Therefore, seemingly as a fallback, 
Epstein alleged without explanation that Edwards "should have known" about the existence of 
this concealed Ponzi scheme. Among other problems, this fallback negligence position suffers 
the fatal flaw that it does not link at all to the intentional tort of abuse of process alleged in the 
complaint. 
Epstein's negligence claim was also deficient because it simply fails to satisfy the 
requirements for a negligence cause of action: 
11 

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Edwards adv. Epstein 
Case No.: 502009CA040800XXXXMBAG 
Second Renewed Motion for Leave to Assert Claim for Punitive Damages 
"Four elements are necessary to sustain a negligence claim: 1. A duty, or 
obligation, recognized by the law, requiring the [defendant] to conform to a 
certain standard of conduct, for the protection of others against unreasonable 
risks. 2. A failure on the [defendant's] part to conform to the standard required: a 
breach of the duty . . . . 3. A reasonably close causal connection between he 
conduct and the resulting injury. This is what is commonly known as 'legal 
cause,' or 'proximate cause,' and which includes the notion of cause in fact. 4. 
Actual loss or damage. 
Curd v. Mosaic Fertilizer, LLC, _ 
So.2d _, 2010 WL 2400384 at *9 (Fla. 2010). Epstein 
did not allege a particular duty on the part of Edwards that has been breached. Nor could Epstein 
explain how any breach of the duty might have proximately caused him actual damages. 
· Summary judgment was therefore appropriate for:these reasons as well. 
Finally, for the sake of completeness, it is worth noting briefly that no reasonable jury 
could find Edwards to have been negligent in failing to anticipate that a managing partner at his 
law firm would be involved in an unprecedented Ponzi scheme. Scott Rothstein deceived not 
only Edwards but also more than 60 other reputable lawyers at a major law ~firm including 
multiple respected former judges. Cf. Sun Sentinel, Fort Lauderdale, Dec. 11, 2009, 2009 
WLNR 25074193 at*l ("Sure, some outlandish John Grisham murder plot[s] sound far-fetched. 
But if you asked me a few months ago if Scott Rothstein was fabricating federal court orders and 
forging a judge's signature on documents to allegedly fleece his friends, as federal prosecutors 
allege, I would have said that was far-fetched, too."). No reasonable lawyer could have expected 
that a fellow member of the bar would have been involved in such a plot. Nobody ...

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Edwards adv. Epstein 
Case No.: 502009CA040800XXXXMBAG 
Second Renewed Motion for Leave to Assert Claim for Punitive Damages 
knew nothing. Edwards was a lawyer at RRA for less than 8 months and had very few personal 
encounters with Rothstein during his time at the firm, yet Epstein claims that he should have 
known of Rothstein's intricate Ponzi scheme. No doubt for this reason the U.S. Attorney's 
Office has now listed Edwards as a "victim" of Rothstein's crimes. See Statement of Undisputed 
Facts filed contemporaneously. 
Epstein's Complaint does not offer any specific reason why a jury would conclude that 
Edwards was negligent, and he chose not to offer any explanation of his claim at his deposition. 
Accordingly, Edwards was entitled to summary judgment to the extent the-claim against-himwas -
--somehow dependent upon his negligence -in failing to discover Rothstein' s 
0Pdnz:i scheme.· 
2. 
Edwards Was Entitled to Summary Judgment to the Extent the Claim 
Against Him Was Dependent on Allegations Regarding "Pumping the Cases" 
Because He Was Properly Pursuing the Interests of His Three Clients Who 
Had Been Sexually Abused by Epstein. 
Epstein alleges that Edwards somehow improperly enhanced the value of the three civil 
cases he had filed against Epstein. Edwards represented three young women- L.M., E.W., and 
Jane D9e - by filing civil suits against Epstein for his sexual abuse of them while they were 
minors. Epstein purported to find a cause of action for this by alleging that Edwards somehow 
was involved in "'pumping' these three cases to investors." 
As just explained, to the extent that Epstein is alleging that Edwards somehow did 
something related to the Ponzi scheme, those allegations fail for the simple reason that Edwards 
was not involved in and was entirely ignorant of the existence of any such scheme. Edwards, for 
13 

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Edwards adv. Epstein 
Case No.: 502009CA040800XXXXMBAG 
Second Renewed Motion for Leave to Assert Claim for Punitive Damages 
example, could not have possibly "pumped" the cases to investors when he never knew there 
were any investors and he never participated in any communication with investors. 
Epstein's "pumping" claims, however, fail for an even more basic reason: Edwards was 
entitled - indeed ethically obligated as an attorney - to secure the maximum recovery for his 
clients during the course of his legal representation. As is well known, "[ a ]s an advocate, a 
lawyer zealously asserts the client's position under the rules of the adversary system." Fla. Rules 
of Prof. Conduct, Preamble. 
Edwards therefore was required to pursue (unless otherwise 
· ·· 
instructed by ·his clients} a rnaximUh1:-recovery, against Epstein~--- Edwards, therefore,· cannot be·-·· 
,· .... ~•"" 
liable for doing somethingthathis.ethical·duties·as an attorney required} 
Another reason that Epstein's claims that Edwards was "pumping" cases for investors 
fails is that Edwards filed all three cases almost a year before he was hired by RRA or even knew 
of Scott Rothstein. 
Epstein makes allegations that the complaints contained sensational 
allegations for the purposes of luring investors; however, language in the complaints remained 
virtually unchanged from the first filing in 2008 and from the overwhelming evidence the Cami 
can see for itself that all of the facts alleged by Edwards in the complaints were true. 
Epstein ultimately paid to settle all three of the cases Edwards filed against him for more 
money than he paid to settle any of the other claims against him. At Epstein's request, the terms 
of the settlement were kept confidential. The sum that he paid to settle all these cases is 
therefore not filed with this pleading and will be provided to the court for in-camera review. 
2 In a further effort to harass Edwards, Epstein also filed a bar complai...

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Edwards adv. Epstein 
Case No.: 502009CA040800XXXXMBAG 
Second Renewed Motion for Leave to Assert Claim for Punitive Damages 
Epstein chose to make this payment as the result of a federal court ordered mediation process, 
which he himself sought (over the objection of Jane Doe, Edwards' client in federal court) in an 
effort to resolve the case. 
See Defendant's Motion for Settlement Conference, or in the 
Alternative, Motion to Direct Parties back to Mediation, Doe v. Epstein, No. 9:08-CV-80893 
(S.D. Fla. June 28, 2010) (Marra, J.) (doc. #168) attached hereto as Exhibit "A". Notably, 
Epstein sought this settlement conference - and ultimately made his payments as a result of that 
conference - in July 2010, more than seven months after he filed this lawsuit against Edwards. 
•• · ·• 
,._ 
-- '.i\:ceordingly, Epsteincould not have been the victim-ofanyscheme-to "pump:\the~cases against 
him, because ·he neverpaid tb settle the cases until well'·-after the Ponzi scheme had ·been· fully--
disclosed, and well after Edwards had left RRA and had severed all connection with Scott 
Rothstein (December 2009). 
• In addition, if Epstein had thought that there was some improper coercion involved in, for 
example, Jane Doe's case, his remedy was to raise the matter before Federal District Court Judge 
Kenneth A. Marra who was presiding over the matter. Far from raising any such claim, Epstein 
simply chose to settle that case. He was therefore barred by the doctrine of res judicata from 
somehow re-litigating what happened in (for example)the Jane Doe case. "The doctrine of res 
judicata makes a judgment on the merits conclusive 'not only as to every matter which was 
offered and received to sustain or defeat the claim, but as to every other matter which might with 
propriety have been litigated and determined in that action." AMEC Civil, LLC v. State Dept. of 
Transp., _ 
So.2d_, 2010 WL 1542634 at *2 (Fla. 1st Dist. Ct. App. 2010) (quoting Kimbrell 
v. ...

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Edwards adv. Epstein 
Case No.: 502009CA040800XXXXMBAG 
Second Renewed Motion for Leave to Assert Claim for Punitive Damages 
particular case could have been resolved in that ve1y case rather than now re-litigated in satellite 
litigation. 
3. 
Edwards is Entitled to Summary Judgment on the Claim of Abuse of Process 
Because He Acted Properly Within the Boundaries of the Law in Pursuit of 
the Legitimate Interests of his Clients. 
Epstein's Second Amended Complaint raised several claims of "abuse of process." An 
abuse of process claim requires proof of three elements: "(1) that the defendant made an illegal, 
improper, or perverted use of process; (2) that the defendant bad ulterior motives or purposes in 
exercising suah -illegal; improper:, ·or perverted~-use of process;· and -(3} that, ·as--aresult. of·such 
action ohAhe•part cif the defendant, the plaintiff suffered damage." S & I 1nvestment-s-v. -Payless··-
Flea Market, Inc., 36 So.3d 909, 917..(Fla. 4th Dist. Ct. App. 2010) (internal citation omitted). In 
fact, this Court is very familiar with this cause of action, as Edwards has correctly stated this 
cause in his counterclaim ,against Epstein. -Epstein could not prove these elements, a fact -
effectively conceded by his dismissal of the abuse of process claim on the eve of the Summary 
Judgment hearing challenging the propriety of that claim. 
The first element of an abuse of process claim is that a defendant made "an illegal, 
improper, or perverted use of process." On the surface, Epstein's Complaint appeared to contain 
several allegations of such improper process. 
On examination, however, each of these 
allegations amounted to nothing other than a claim that Epstein was unhappy with some 
discovery proceeding, motion or argument made by Edwards. This is not the stuff of an abuse of 
process claim, particularly where Epstein fails to allege that he was required to do something as 
the result of Edwards' pursuit of the claims agains...

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Edwards adv. Epstein 
Case No.: 502009CA040800XXXXMBAG 
Second Renewed Motion for Leave to Assert Claim for Punitive Damages 
(Fla. 1st Dist. Ct. App. 1987) (affirming summary judgment on an abuse of process claim where 
"appellant's lawsuit caused appellee to do nothing against her will"). 
In any event, none of the allegations of "improper" process can survive summary 
judgment scrutiny, because every action Edwards took was entirely proper and reasonably 
calculated to lead to the successful prosecution of the pending claims against Epstein as detailed 
in Edwards' Affidavit. 
Epstein also fails to meet the second element of an abuse of process claim: that Edwards 
-,had.'·some sort -of ulterior motive; --The case· law is dear that on an abuse of process claim a 
---- · - "plaintiff must prove that the process-=was :u·sed for an immediate purpose-other- than that -for 
which it was designed." S&J Investments v. Payless Flea Market, Inc., 36 So.3d 909, 917 (Fla. 
4th Dist. Ct. App. 2010) (citing Biondo v. Powers, 805 So.2d 67, 69 (Fla. 4th Dist. Ct. App. 2002). 
As a consequence, "[ w ]here the process was used to· accomplish the result for which it- was 
intended, regardless of an incidental or concurrent motive of spite or ulterior purpose, there is no 
abuse of process." 
Id. (internal quotation omitted). 
Here, Edwards has fully denied any 
improper motive, See· Statement of Undisputed Facts, and Epstein has no evidence of any such 
motivation. Indeed, it is revealing that Epstein chose not to ask even a single question about this 
subject during the deposition of Edwards. In addition, all of the actions that Epstein complains 
about were in fact used for the immediate purpose of furthering the lawsuits filed on behalf of 
L.M., E.W., and Jane Doe. In other words, these actions all were both intended to accomplish 
and, in fact, successfully "accomplished the results for which they were intended" -- whether it 
was securing additional disc...

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Edwards adv. Epstein 
Case No.: 502009CA040800XXXXMBAG 
Second Renewed Motion for Leave to Assert Claim for Punitive Damages 
ultimately maxumzmg the recovery of damages from Epstein on behalf of his victims. 
Accordingly, Edwards was entitled to summary judgment on any claim that he abused process 
for this reason as well-an argument which again was effectively conceded by Epstein's 
voluntary dismissal. 
4. 
Edwards Was Entitled to Summary Judgment to the Extent Epstein's Claim 
Was Based On Pursuit of Discovery Concerning Epstein's Friends Because 
All Such Efforts Were 
Reasonably Calculated to Lead to Relevant and 
Admissible Testimony About Epstein's Abuse of Minor Girls. 
Epstein alleged that Edwards improperly pursued discovery from some of Epstein's close 
friends. 
Such discovery, Epstein claims, was improper because Edwards -knew that these 
individuals lacked any discoverable information about the sexual assault cases against Epstein. 
Here again, Edwards was entitled to summary judgment, as each of the friends of Epstein 
were reasonably believed to possess discoverable information. The undisputed facts show the 
following with regard to each of the persons raised in Epstein's complaint: 
• 
With regard to Donald Trump, Edwards had sound legal basis for believing Mr. 
Trump had relevant and discoverable information. See Statement of Undisputed 
Facts. 
• 
With regard to Alan Dershowitz (Harvard Law Professor), Edwards had sound 
legal basis for believing Mr. Dershowitz had relevant and discoverable 
information. See Statement of Undisputed Facts. 
• 
With regard to former President Bill Clinton, Edwards had sound legal basis for 
believing former President Clinton had relevant and discoverable information. 
See Statement of Undisputed Facts. 
• 
With regard to former Sony Record executive Tommy Mottola, Edwards was not 
the attorney that noticed Mr. Mottola' s deposition. See Statement of Undisputed 
Facts. 
18 

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Edwards adv. Epstein 
Case No.: 502009CA040800XXXXMBAG 
Second Renewed Motion for Leave to Assert Claim for Punitive Damages 
• 
With regard to illusionist David Copperfield, Edwards had sound legal basis for 
believing Mr. Copperfield had relevant and discoverable information. 
See 
Statement of Undisputed Facts. 
• 
With regard to former New Mexico Governor Bill Richardson, Edwards had 
sound legal basis for naming Former New Mexico Governor Bill Richardson on 
his witness list. See Statement of Undisputed Facts. 
It is worth noting that the standard for discovery is a very liberal one. To notice someone 
for a deposition, of course, it is not required that the person deposed actually end up producing 
admissible evidence. Otherwise, every deposition that turned out to be a false alarm would lead 
• ·to an-·"abuse of process'' claim. Moreover; the rules of-discovery themselves provide that a 
deposition need onlybeo:'reasonably calculated to'·lead tothe-discovery ofadmissible evidence.-'',-•,: - • 
Fla. R. Civ. P. 1.280(b) (emphasis added). 
Moreover, the discovery that Edwards pursued has to be considered against the backdrop 
·of Epstein's obstructionist tactics. As the Court is aware, in both this case and all other cases 
filed against him, Epstein asserted his Fifth Amendment privilege rather than answer any 
substantive questions. Epstein also helped secure attorneys for his other household staff who 
assisted in the process of recruiting Epstein's minor victims. Those staff members in tum also 
asserted their Fifth Amendment rights rather than explain what happened behind closed doors in 
Epstein's mansion in West Palm Beach. See Statement of Undisputed Facts. It is against this 
backdrop that Edwards followed up on one of the only remaining lines of inquiry open to him: 
discovery aimed at Epstein's friends who might have been in a position to corroborate the fact 
that Epstein was sexually abusing young girls. 
19 

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Edwards adv. Epstein 
Case No.: 502009CA040800XXXXMBAG 
Second Renewed Motion for Leave to Assert Claim for Punitive Damages 
In the context of the sexual assault cases that Edwards filed against Epstein, any act of 
sexual abuse had undeniable relevance to the case - even acts of abuse Epstein committed 
against minor girls other than L.M., E.W., or Jane Doe. Both federal and state evidence rules 
make acts of child abuse against other victims admissible in the plaintiffs case in chief as proof 
of "modus operandi" or "motive" or "common scheme or plan." See Fed. R. Evid. 415 ( evidence 
of other acts of sexual abuse automatically admissible in a civil case); Fla. Stat. Ann. 90.404(b) 
(evidence of common scheme admissible); Williams v. State, 110 So.2d 654 (Fla. 1959) (other 
acts of potential sexual misconduct-admissible);··- . -•, -· 
A secondreason existed to support-the propriety of discovery of Epstein's-acts~ofa:buse· 
of other minor victims. 
Juries considering punitive damages issues are plainly entitled to 
consider ''the existence and frequency of similar past conduct." TXO Production C01p. v. 
Alliance Resources Corp., 509 U.S. 443, 462 n.28 (1993). This is·"because the Supreme Court 
recognizes "that a recidivist may be punished more severely than a first offender ... [because] 
repeated misconduct is more reprehensible than an individual instance of malfeasance." BMW of 
North America, Inc. v. Gore, 517 U.S. 559, 577 (1996) (supporting citations omitted). In 
addition, juries can consider other similar acts evidence as part of the deterrence calculation in 
awarding punitive damages, because "evidence that a defendant has repeatedly engaged in 
prohibited conduct while knowing ... that it was unlawful would provide relevant support for an 
argument that strong medicine is required to cure the defendant's disrespect for the law." Id. at 
576-77. In the cases Edwards filed against Epstein, his clients were entitled to attempt to pro...

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Edwards adv. Epstein 
Case No.: 502009CA040800XXXXMBAG 
Second Renewed Motion for Leave to Assert Claim for Punitive Damages 
pedophile, he sexually assaulted dozens and dozens of minor girls. The discovery of Epstein's 
friends who might have had direct or circumstantial evidence of other acts of sexual assault was 
accordingly entirely proper. Edwards was therefore entitled summary judgment to the extent 
Epstein's claim was based on efforts by Edwards to obtain discovery of Epstein's friends. This 
contention also went unchallenged when Epstein dismissed his claims against Edwards. 
III. 
EPSTEIN'S LAWSUIT MUST BE DISMISSED BECAUSE OF HIS REFUSAL TO 
PARTICIPATE IN REASONABLE DISCOVERY. 
As is readily apparent from the facts of this case, Epstein filed a lawsuit but then refused 
to allow·any real discovery about the merits. of his case. Instead, when -asked: direct- questions . 
about whether he had any legitimate claim at all, Epstein hid behind the Fifth Amendment. As a 
result, under the "sword and shield doctrine" widely recognized in Florida case law, his suit 
could not have been legitimately prosecuted. 
"[T]he law is well settled that a plaintiff is not entitled to both his silence and his 
lawsuit." Boys & Girls Clubs of Marion County, Inc. v. JA., 22 So.3d 855, 856 (Fla. 5th Dist. 
Ct. App. 2009) (Griffin, J., concurring specially). Thus, "a person may not seek affirmative 
relief in a civil action and then invoke the Fifth Amendment to avoid giving discovery, using the 
fifth amendment as both a 'sword and a shield."' DePalma v. DePalma, 538 So.2d 1290, 1290 
(Fla. 4th Dist. Ct. App. 1989) (quoting DeLisi v. Bankers Insurance Co., 436 So.2d 1099 (Fla. 4th 
Dist. Ct. App. 1983)). Put another way, "[a] civil litigant's fifth amendment right to avoid self-
incrimination may be used as a shield but not a sword. This means that a plaintiff seeking 
affirmative relief in a civil action may not invoke the Fifth Amendment and refuse to co...

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Edwards adv. Epstein 
Case No.: 50l009CA040800XXXXMBAG 
Second Renewed Motion for Leave to Assert Claim for Punitive Damages 
with the defendant's discovery requests, thereby thwarting the defendant's defenses." Rollins 
Burdick Hunter of New York, Inc. v. Euroclassic Limited, Inc., 502 So. 2d 959 (Fla. 3rd Dist. 
Court App. 1983). 
Here, Epstein's suit against Edwards purported to do precisely what the "well settled" 
law forbids. Specifically, he ostensibly sought to obtain "affirmative relief' - i.e., forcing 
Edwards to pay money damages - while simultaneously precluding Edwards from obtaining 
legitimate discovery at the heart of the allegations that formed the basis for the relief Epstein 
.. -.. ,. -· claimed to be seeking. As recounted more fully in the statement ofundisputed-facts,·Epstein 
.,, •• '"refused to answer such basic .questions about his lawsuit as: 
• 
"Specifically what are the allegations against you which you contend Mr. 
Edwards ginned up?" 
• 
"Well, which of Mr. Edwards' cases do you contend were fabricated?" 
• 
"Is there anything in L.M. 's Complaint that was filed aga1nst you in September of 
2008 which you contend to be false?" 
• 
"I would like to know whether you ever had any physical contact with the person 
ref erred to as Jane Doe 111 that [:federal]coinplaint?" • 
• 
"Did you ever have any physical contact with E.W.?" 
• 
"What is the actual value that you contend the claim of E.W. against you has?" 
The matters addressed in these questions were the central focus of Epstein's claims against 
Edwards. Epstein's refusal to answer these and literally every other substantive question put to 
him in discovery deprived Edwards of even a basic understanding of the evidence alleged to 
support claims against him. 
Moreover, by· not offering any explanation of his allegations, 
22 

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Edwards adv. Epstein 
Case No.: 502009CA040800XXXXMBAG 
Second Renewed Motion for Leave to Assert Claim for Punitive Damages 
Epstein deprived Edwards of any opportunity to conduct third party discovery and opportunity to 
challenge Epstein's allegations. 
It is the clear law that "the chief purpose of our discovery rules is to assist the truth-
finding function of our justice system and to avoid trial by surprise or ambush," Scipio v. State, 
928 So.2d 1138 (Fla.2006), and ""full and fair discovery is essential to these important goals," 
McFadden v. State, 15 So.3d 755, 757 (Fla. 4th Dist. Ct. App. 2009). Accordingly, it is important 
for the Court to insure "not only compliance with the technical provisions of the discovery rules, 
· but·also adherence to the purpose and spirit of those rules
0in·both the criminal-and civil context:"h .. • .,. 
·McFadden, 15 So.3d at-'?57>
0Epstein repeatedly blocked "full and fair·discovery," and clearly· 
never intended to provide the discovery that would have been essential to any intended 
legitimate, good faith prosecution of his claims. 
IV. 
EDWARDS IS ENTITLED TO ADVERSE INFERENCES FROM 
EPSTEIN'S INVOCATION OF THE FIFTH AMENDMENT 
Epstein's repeated invocations of the Fifth Amendment raise adverse inferences against 
him that leave no possibility that a reasonable fact finder could ever have reached a verdict in his 
favor. In mling on a summary judgment motion, the court was obliged to fulfill a ""gatekeeping 
function" and ask whether "a reasonable trier of fact could possibly" reach a verdict in favor of 
the plaintiff. Willingham v. City of Orlando, 929 So.2d 43, 48 (Fla. 5th Dist. Ct. App. 2006) 
(emphasis added). Given all of the inferences that are to be drawn against Epstein, no reasonable 
finder of fact could conclude that Epstein was somehow the victim of improper civil lawsuits 
23 

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Edwards adv. Epstein 
Case No.: 502009CA040800XXXXMBAG 
Second Renewed Motion for Leave to Assert Claim for Punitive Damages 
filed against him. Instead, a reasonable finder of fact could only find that Epstein was a serial 
molester of children who was being held accountable through legitimate suits brought by 
Edwards and others on behalf of the minor girls that Epstein victimized. 
"[I]t is well-settled that the Fifth Amendment does not forbid adverse inferences against 
parties to civil actions when they refuse to testify in response to probative evidence offered 
against them." Baxter v. Palmigiano, 425 U.S. 308, 318 (1976); accord Vasquez v. Staie, 777 
So.2d 1200, 1203 (Fla. App. 2001). The reason for this rule "is both logical and utilitarian. A 
-· party may- not trample ·upon the Tights of others and~then escape the consequences, by--invoking a 
constitutional-privilege - at least·not·in a civil- setting:11·-Fraser v. Security and Inv. ··Gorp.;" 615 
So.2d 841, 842 (Fla. 4th Dist. Ct. App. 1993). And, in the proper circumstances, "' Silence is 
often evidence of the most persuasive character."' Fraser v. Security and Inv. Corp., 615 So.2d 
841, 842 (Fla. 4th Dist. Ct. App. 1993) (quoting United States ex rel. Bilokumsky v. Tod, 263 U.S. 
149, 153-154 (1923) (Brandeis, J.). 
In the circumstances of this case, a reasonable finder of fact would have "evidence of the 
most persuasive character" from Epstein's repeated refusal to answer questions propounded to 
him. To provide but a few examples, here are questions that Epstein refused to answer and the 
reasonable inference that a reasonable finder of fact would draw: 
• 
Question not answered: "Specifically what are the allegations against you which 
you contend Mr. Edwards ginned up?" Reasonable inference: No allegations 
against Epstein were ginned up. 
• 
Question not answered: "Well, which of Mr. Edwards' cases do you contend 
were fabricated?" Reasonable inference: No cases filed by ...

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Edwards adv. Epstein 
Case No.: 502009CA040800XXXXMBAG 
Second Renewed Motion for Leave to Assert Claim for Punitive Damages 
........ ,· .. 
• 
Question not answered: "Did sexual assaults ever take place on a private airplane 
on which you were a passenger?" Reasonable inference: Epstein was on a private 
airplane while sexual assaults were taking place. 
• 
Question not answered: "How many minors have you procured for prostitution?" 
Reasonable inference: Epstein has procured multiple minors for prostitution. 
• 
Question not answered: "Is there anything in L.M.'s Complaint that was filed 
against you in September of 2008 which you contend to be false?" Reasonable 
inference: Nothing in L.M.'s complaint filed in September of 2008 was false -
i.e., as alleged in L.M.'s complaint, Epstein repeatedly sexually assaulted her 
while she was a minor and she was entitled to substantial compensatory and 
punitive damages as a result. 
• Question not answered: "I would like to know whether you ever had any physical· 
• contact with the person re:ferred~td as Jane Doe 'iii ·that [federal]. compfairit?" 
Reasonable inference: Epstein had physical contact with minor Jane Doe as 
alleged in her federal complaint. 
• 
Question not answered: "Did you ever have any physical contact with E.W.?" 
Reasonable inference: Epstein had physical contact with minor E.W. as alleged.in .. 
her complaint. 
• 
• 
• • 
• 
Question not answered: "What is the actual value that you contend the claim of 
E.W. against you has?" Reasonable inference: E.W.'s claim against Epstein had 
substantial actual value. 
Without repeating each and every invocation of the Fifth Amendment that Epstein has 
made and the reasonable inferences to be drawn from those invocations of privilege, the big 
picture is unmistakably clear: No reasonable finder of fact could rule in Epstein's favor on his 
claims against Edwards. Accordingly, Edwards was entitled to summary judgment based on the 
Fifth Ame...

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Edwards adv. Epstein 
Case No.: 502009CA040800XXXXMBAG 
Second Renewed Motion for Leave to Assert Claim for Punitive Damages 
The inferences against Epstein are not limited to those ansmg from his privilege 
assertions. Epstein's guilt is also reasonably inferred from his harassment of, intimidation of, 
efforts to exercise control over, and limitation of access to witnesses who might testify against 
him. 
Epstein's efforts to intimidate his victims support the inference that Epstein knew that 
they were going to provide compelling testimony against him. 
The evidence that Epstein 
tampered with witnesses (later designated as his accomplices and co-conspirators) will be 
•···• · 
·· admissible to demonstrate his consciousness of guilt. ''[I]t is precisely because of the egregious 
·'" nature of such conduct that the law expressly permits the jury to make aElvetse inferences from a 
party's efforts to intimidate witnesses .... " Jost V. Ahmad, 730 So.2d 708, 711 (Fla. 2nd Dist. 
Ct. App. 1998) (internal quotation omitted). 
To be clear, Epstein's attempt to tamper with 
..... 
- .. 
witnesses is "not simply admissible as impeachment evidence of the tampering ·party's· 
credibility. The opposing party is entitled to introduce facts regarding efforts to intimidate a 
witness as substantive evidence." Id. at 711 (emphasis in original) (internal citation omitted). 
This substantive evidence of Epstein's witness intimidation provides yet another reason why no 
reasonable jury could find in favor of his claims against Edwards. 
V. 
EDWARDS WAS ENTITLED TO SUMMARY JUDGMENT ON THE 
BASIS OF ms AFFIRMATIVE DEFENSE OF PRIVILEGE 
Absolute immunity must be afforded any act occurring during course of judicial 
proceeding, regardless of whether act involves defamatory statement or other tortious behavior, 
such as tortious interference with business relationship, so long as act has some relationship to 
26 

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Edwards adv. Epstein 
Case No.: 502009CA040800XXXXMBAG 
Second Renewed Motion for Leave to Assert Claim for Punitive Damages 
proceeding. See Levin, Middlebrooks, Mabie, Thomas, Mayes & Mitchell, P.A. v. US. Fire Ins. 
Co., 639 So. 2d 606 (Fla. 1994). The immunity afforded to statements made during the course of 
a judicial proceeding extends not only to the parties in a proceeding but to judges, witnesses, and 
counsel as well. Id. The litigation privilege applies in all causes of action, whether for common-
law torts or statutory violations. See Echevarria, McCalla, Raymer, Barrett & Frappier v. Cole, 
950 So. 2d 380 (Fla. 2007). Defamatory statements made by lawyer while interviewing a 
witness in preparation for and connected to pending litigation are covered by the absolute 
.... ·· -·· · 
·· immunity conferred-by-thelitigation privilege; SeeDelMonico'v. Traynor, 50 So; 3d-4 (Fla. Dist;- · · ".· · ,.·. , 
-... ,,. -~ 
Ct.App. 4th Dist. 2010); review,granted,47 So: 3d 1287' (Fla; :2010); The privilege extends to-·' ·""' ·' 
statements in judicial proceedings or those "necessarily preliminary thereto. See Stewart v. Sun 
Sentinel Co., 695 So.2d 360 (Fla. 4th DCA 1997)(an attorney's delivery of a copy of a notice of 
..... 
-
·-
- . 
claim to a reporter, which notice was a required filing prior to.0instituting suit, was protected by 
absolute immunity). · 
CONCLUSION 
The evidence and law described herein provide not only a reasonable basis, but a 
compelling and unrebutted foundation supporting the conclusion that Epstein never had 
legitimate grounds to sue Bradley Edwards. 
Every one of his now dismissed claims was 
factually baseless and legally barred. 
27 

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Edwards adv. Epstein 
Case No.: 502009CA040800XXXXMBAG 
Second Renewed Motion for Leave to Assert Claim for Punitive Damages 
The lack of foundation and legal impediments were so clearly obvious from the time the 
claims against Edwards were initiated that there could never have been a good faith belief in 
their propriety. 
Equally obvious from the surrounding circumstances is the improper motive behind the 
litigation. If Edwards and his client, L.M. could be intimidated by the need to defend themselves 
against the litigation assault of a billionaire opponent, Epstein stood the chance of avoiding or at 
least limiting his extremely embarrassing and enormously costly civil liability and protecting 
himself from further-criminal prosecution threatened .. by-Edwards' prnsecution -of an aetion-·in 
Federal Court-tirider:~the-CrimeVictims' Rights Ach This'calculated effort-at extortion is,0clearl-y-·-
supportive of punitive damage exposure. 
Bradley Edwards' Motion to Amend to Assert a Claim for Punitive Damages should be 
granted. 
I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E-Serve 
to all Counsel on the attached list, this fq~a 
Florid~ No.: 169440 
Prim 
-mail: jsx@searcylaw.com 
Se 
ary E-mail(s): mep@searcylaw.com 
S 
cy Denney Scarola Barnhart & Shipley, P.A. 
139 Palm Beach Lakes Boulevard 
West Palm Beach, Florida 33409 
Phone: (561) 686-6300 
Fax: 
(561) 383-9451 
Attorneys for Bradley J. Edwards 
28 

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Edwards adv. Epstein 
Case No.: 502009CA040800XXXXMBAG 
Second Renewed Motion for Leave to Assert Claim for Punitive Damages 
COUNSEL LIST 
Jack A. Goldberger, Esquire 
jgoldberger@agwpa.com; 
smahoney@agwpa.com 
Atterbury, Goldberger & Weiss, P.A. 
250 Australian A venue South, Suite 1400 
West Palm Beach, FL 33401 
Phone: (561)-659-8300 
Fax: (561)-835-8691 
Attorneys for Jeffrey Epstein 
Marc S. Nurik, Esquire 
marc@nuriklaw.com 
Law Offices of Marc S. Nurik 
One E Broward Blvd., Suite 700 
Fort Lauderdale, FL 33301 
Phone: (954)-745-5849 
Fax: (954)-745-3556 
Attorneys for Scott Rothstein 
Lilly Ann Sanchez, Esquire 
Bradley J. Edwards, Esquire 
bj e~efile@pathtojustice.com; 
staff.efile@pathtojustice.com 
---~,.,.-_ ,< - lsanchez@thelsfinn.com ---···'· 
·-' ,.·---- -· 
Farmer; Jaffe/Weissing, Edwards, Fistos & -•• , 
Lehrman, FL 
425 North Andrews Avenue, Suite 2 
Fort Lauderdale, FL 33301 
Phone: (954)=524-2820 
Fax: (954)-524-2822 
Fred Haddad, Esquire 
Dee@FredHaddadLaw.com; 
haddadfm@aol.com 
Fred Haddad, P.A. 
One Financial Plaza, Suite 2612 
Fort Lauderdale, FL 33394 
Phone: (954)-467-6767 
Fax: (954)-467-3599 
Attorneys for Jeffrey Epstein 
The L-S Law Firm 
· -·- ·· -- - -
,.,,,,,,;__ 1441 Brickell Avenue, 15th Floor"-> 
29 
Miami, FL 33131 
Phone: (305)-503-5503 
Fax: (305)-503-6801 
Attorneys for Jeffrey Epstein 
---·-
.. Tonja Haddad Coleman, Esquire 
tonja@tonjahaddad.com; 
Debbie@Tonjahaddad.com 
Tonja Haddad, P.A. 
315 SE 7th Street, Suite 301 
Fort Lauderdale,FL 33301 
Phone: (954)-467-1223 
Fax: (954)-337-3716 
Attorneys for Jeffrey Epstein 

NOT A CERTIFIED COPY
JEFFREY EPSTEIN, 
Plaintiff, 
vs. 
SCOTT ROTHSTEIN, individually, 
BRADLEY J. EDWARDS, individually, 
and L.M., individually, 
Defendants. 
I 
---------------
IN THE 
CIRCUIT 
COURT 
OF 
THE 
FIFTEENTH JUDICIAL CIRCUIT, IN AND 
FOR PALM BEACH COUNTY, FLORIDA 
CASE NO.: 502009CA040800XXXXMBAG 
NOTICE OF FILING 
COMES NOW the Defendant/CounterClaimant, BRADLEY EDWARDS, by and 
through his undersigned counsel, and hereby files the attached transcript of the telephone 
interview of Virginia Roberts to supplement the proffer made in support of Counter-Claimant's 
Motion for Leave to Amend to Assert Punitive Damages. 
I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by 
,,_.. 
U.S. Mail to all Counsel on the attached list on this ft day of May 2011. 
Jack Scarola 
Florida Bar No.: 16 440 
Searcy Denney Scarola Barnhart & Shipley, P.A. 
2139 Palm Beach Lakes Boulevard 
West Palm Beach, Florida 33409 
Phone: (561) 686-6300 
Fax:(561) 383-9451 
Attorney for Defendant/CounterClaimant 
Edwards 
EXHIBIT 

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Edwards adv. Epstein 
Case No.: 502009CA040800XXXXMBAG 
Notice of Filing Supplement 
COUNSEL LIST 
Jack A. Goldberger, Esquire 
jgoldberger@agwpa.com; 
smahoney@agwpa.com 
Atterbury, Goldberger & Weiss, P.A. 
250 Australian A venue South, Suite 1400 
West Palm Beach, FL 33401 
Phone: (561)-659-8300 
Fax: (561)-835-8691 
Attorneys for Jeffrey Epstein 
Farmer, Jaffe, Weissing, Edwards, Fistos & 
Lehrman,PL 
425 N. Andrews Avenue, Suite 2 
Fort Lauderdale, FL 33301 
Phone: (954)-524-2820 
Fax: (954)-524-2822 
Attorneys for Jeffrey Epstein 
Joseph L. Ackerman, Jr., Esquire 
jla@fowler-white.com 
Fowler White Burnett, P.A. 
901 Phillips Point West 
777 S Flagler Drive 
West Palm Beach, FL 33401-6170 
Phone: (561)-802-9044 
Fax: (561)-802-9976 
Attorneys for Jeffrey Epstein 
Marc S. Nurik 
marc@nuriklaw.com 
Law Offices of Marc S. Nurik 
One E Broward Blvd., Suite 700 
Fort Lauderdale, FL 33301 
Phone: (954)-745-5849 
Fax: (954)-745-3556 
Attorneys for Scott Rothstein 
2 
Martin Weinberg, Esquire 
Martin Weinberg, P.C. 
20 Park Plaza, Suite 1000 
Suffolk, MA 02116 
Attorneys for Jeffrey Epstein 

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Edwards adv. Epstein 
Case No.: 502009CA040800XXXXMBAG 
Notice of Filing Supplement 
3 

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NOT A CERTIFIED COPY
PRIVILEGED PURSUANT TO FS 766.205(4) and/or WORK PRODUCT 
TELECON 
PARTICIPANTS: 
JACK SCAROLA 
BRAD EDWARDS 
VIRGINIA ROBERTS. 
RE: 
Edwards adv. Epstein 
291874 
DATE: 
April 07, 2011 
JS: 
Virginia, Jack Scarola and Brad Edwards 
BE: 
Hi Virginia. 
V: 
Hi Jack! Hi Brad! How you guys doing? 
JS: 
We're doing fine, thank you. I'm sorry for all of the trouble and before we go any 
further, let me tell you, if I have your permission, I have started a tape recorder and I 
want to be able to tape this conversation from the very beginning. Is that alright with 
you? 
V: 
Sure, that's fine, Jack. No problem 
JS: 
Ok, good, thank you. I appreciate that. Let me start off by introducing myself. I know 
that Brad has spoken to you about me but I am Brad's lawyer, and I assume that you can 
confirm that you and I have never had any communication before. Is that right? 
V: 
That's correct. 
JS: 
Alright. I have, however, gotten some information from Brad about conversations that 
you have had with him, and that will enable me, hopefully, to make this a little bit more 
efficient and take up a minimum amount of your time while still getting the information 
that we think is going to be helpful to us and to any jury that might ultimately have to 
hear these facts. 
So, let me begin by asking you first to tell us what your full name is. 
V: 
Virginia Louise Roberts. That's my maiden name. My married name is Virginia Louise 
* 

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Edwards adv. Epstein 
Telephone interview with Virginia Roberts 
Page 2 of23 
JS: 
V: 
JS: 
V: 
JS: 
V: 
JS: 
V: 
JS: 
V: 
JS: 
V: 
JS: 
V: 
Could you spell your last name for us? That is your married last name: 
* 
Alright, thank you, and where are you living right now? 
I live in Australia. 
And how long have you resided in Australia. 
This is my 19th year. 
That is where you are right now, correct? We've reached you in Australia for this phone 
conversation? 
That is correct, yes. 
And what time is it in Australia right now? 
I think it's about 9:00 now. 
Ok. That's 9am, correct? 
That's correct. 
Alright. Virginia, the reason for this conversation is because it is our understanding that 
you know a man by the name Jeffrey Epstein, and I want to begin by asking you please to 
tell us about the circumstances of your first meeting Mr. Epstein. 
Ok. I was introduced to Mr. Epstein by Ghislaine Maxwell. I was working at Donald 
Trump's spa in Mar-a-Lago and I was prompted by Ghislaine to come to Jeffrey's 
mansion in Palm Beach that afternoon after work to make some extra money and to learn 
about massage. She met me at the spa, and I was reading a book about anatomy, so I was 
already interested in massage therapy as it was and not having any of the education or 
you know anything behind me, I thought this was a great opportunity to work for her and 
go. So, I went to Jeffrey's mansion about 5 or 6 in the afternoon. My dad drove me 
there. My dad worked at Mar-a-Lago with me, and he met Ghislaine and she seemed like 
a nice, proper English lady, and she knows, I mean, you know, one time then _ once 
before I left to travel overseas, she just seemed really nice and like she would like to help 
me out. So my dad left, and I had no problem getting home that night, one of her drivers 
would take me back after my trial. So she led me upstairs, and into Jeffrey's bedroom, 
and past that is Jeffrey's massage room, which has got his steam room and a sho...

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Telephone interview with Virginia Roberts 
Page 3 of23 
JS: 
When you say that the room was hidden, Virginia, how was the room concealed? 
V: 
It wasn't like a door that you would normally go into, like some kind of special opening, 
you open that and then a little door, so it looks like it's a little closet so-to-speak, but 
when you walk in there, it's obviously a lot bigger than just a closet. It wasn't too big, 
but it was bigger, you know. It wasn't a gigantic room, it was just like a small room, 
which you know, it probably could fit some shoes in there, _it had racks of shoes, boxes, 
some sweatshirts neatly folded, and the ceiling to the floor was covered in pornographic 
pictures of the girls that he had met. 
JS: 
When you say ... 
V: 
So anyways, that was getting there, and I was introduced to Jeffrey, he was laying naked 
on top of the massage table, and obviously for one, I'm a 15 year old girl and seeing him 
on the table was weird but, also learning about anatomy and massage, I thought this 
would be part of it. So obviously, I thought it was part of the massage program, so I said 
ok, this is fine. And, he then instructed me on how to touch the body, Jeffrey's body, 
how to massage him, and for the first hour, it was actually a real massage, maybe not an 
hour, maybe like 40 minutes or something, but of something like that _and that's when he 
turned over on the other side and to expose himself fully. So then Ghislaine told me that 
she wanted me to undress and began to take off my shirt and skirt, my white uniform 
from Mar-A-Lago, she also took off her shirt and got undressed, and so I was there with 
just my undies on, and she was completely bare, and made some kind of little flake about 
the underwear that I was wearing because it wasn't my normal sexy girl underwear and 
just like, I don't know, had red hearts on it or something like that; just your normal, you 
know, real cute underwear. Anyways, so du...

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Telephone interview with Virginia Roberts 
Page 4 of23 
V: 
I've got it written down. It's like - I'm not good with math-hold on-I thought I wrote 
it down but I didn't. I'm not too sure, I think it was 1998 off the top of my head and 
around June of 1998, I would say as I was turning 16 at the end of the summer. 
JS: 
Alright. You talked about the room where Jeffrey had the pornographic photographs. 
Did you actually see that room on the occasion of your first visit there? 
V: 
No, I got to see that room a few visits after but I was just trying to describe that room to 
you guys so you knew exactly what room I was talking about. 
JS: 
Another question for you, and I don't mean to be prying into your personal life, and if I 
ask you any questions at all that you're uncomfortable answering, then you just tell me 
that and we'll move on, because I appreciate your cooperation and the last I thing I want 
to do is impose upon that cooperation, but can you tell us please just generally what kind 
of sexual experience you had had prior to this confrontation with Jeffrey? 
V: 
Yeah, sure. A close family friend has sexually abused me, and I was on the streets at 13 
years old. I was picked up by a 67 year old man named Ron _Eppinger_ who did exactly 
what Jeffrey did with me abuse and violate my youthfulness _ & I was with him for 6 
months. So, he was gone and then I had this boyfriend who was like my school friend 
from young days but we just kept in contact with each other and we were on and off 
constantly, and that was Tony Figeroua_, and there was also another younger guy was 
near my age, Michael, I can't remember his last name, but yeah, there, I mean, there 
wasn't like a string of men or anything, but there was Ron, like I told you, and he was the 
first guy expecting me to do so-called disgusting affairs. Jeffrey actually knew Ron, 
which was quite weird when I told Jeffrey the story about Ron, and Jeffrey had actually 
...

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Edwards adv. Epstein 
Telephone interview with Virginia Roberts 
Page 5 of23 
had frames, some of them were out of frames, but they were all, like I said, they were all 
women, they were all sexual in nature. 
JS: 
Was it your impression that there were a hundred photos of a hundred different people or 
were there multiple photos of the same woman or girl? 
V: 
There was definitely a lot of different girls. I mean it wasn't easy to sit there and say, 
you weren't finding 5 girls out of some photos, no. Were there a hundred different ones? 
There could have been pictures of some girls, I really couldn't get close necessarily to 
actually recognize faces or anything like that. But if you, you know, the range of them 
were all different, majority of them were different, yeah. 
JS: 
Did there ever come a point in time when you became aware that a photograph of you 
had been added to the collection? 
V: 
Yes, there was. Ghislaine took several nude photographs of me for Jeffrey. So, yeah, 
there were pictures of me and there were pictures, he wasn't shy, that wasn't the only 
place in his house that he kept the photos. He liked photos all over his house. If you 
looked in his den or on his desk or in on the hall table, a giant hall table in his house, 
there were at least a hundred photos of girls in frames. Not all of them were naked, a lot 
of the ones that were all around his house were not naked girls posing pornographically, 
some were pictures of celebrities and politicians he had known_ or things like that or had 
pants on or whatever, but yeah, there was a lot of mixed photographs in the outside ones. 
JS: 
Were there any photographs of girls or young women that you knew or that you 
subsequently came to know that you saw in the house? 
V: 
• Yeah, yeah, there was. There was pictures of Nadia Bjoumik _____ , pictures 
Sarah Keller, pictures Emmy, pictures of me, pictures of the regulars, but a lot of the 
girls, sometimes Jeffrey could have li...

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Telephone interview with Virginia Roberts 
Page 6 of23 
a couple of weeks, maybe a week, I had quit Mar-a-Lago and I was working for Jeffrey 
full time. 
JS: 
Ok, let's talk about your job .at Mar-a-Lago, if we could. You said that your Dad was 
working there. What was his position at Mar-a-Lago? 
V: 
He was a maintenance supervisor I think is what it was called? He like managed the 
tennis courts and air conditioners and things like that. 
JS: 
What is your Dad's full name? 
V: 
Sky William Roberts. 
JS: 
And is he still living here in South Florida now? 
V: 
No, he's not, he's in California. 
JS: 
Ok. Is your Dad aware of what is currently going on with regard to your having made 
public statements about your relationship with Jeffrey? 
V: 
Yes, he is well aware of it. I told my family even before all this stuff came out, because 
they were the first ones contacted by the journalists from Mail on Sunday. I know that 
they the Mail on Sunday printed that I had gone out and tried to, I mean I think one of the 
photos said that I was angry that I saw Jeffrey and the Prince walking together and that is 
why I came out and went public with everything. Not true.. I mean, I am angry about 
how they are still up to their old ways together and that they're still hanging out but I 
didn't contact the Mail on Sunday and I didn't bring it out. I figured that everyone was 
going to bring it out anyway and I better bring it out the right way. He's known 
everything from the start, and my family is very supportive with everything going on. 
JS: 
I'm kind of going to jump around a little bit and I apologize for that, but since the subject 
has come up, tell me first of all why you are providing this cooperation to us, and I am 
certainly very appreciative of it, but I want you to tell us why it is you've chosen to spend 
time with us on the telephone and provide this information that you're now providing. 
V: 
I'm out to help the bigger ...

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Telephone interview with Virginia Roberts 
Page 7 of23 
JS: 
Just for the record, neither Brad, nor I, nor anyone representing that they have anything to 
do with us has made any promises to you. Is that correct? 
V: 
That is correct. I'll tell you, since this is our first conversation, that nobody has made me 
feel like I've been bribed or bought or had to say anything. I've told you anything that I 
know from my own self, not some things somebody told me. If anything, Brad's been 
extra careful not to tell me anything and let me do all the talking, so it's quite opposite I 
think. 
JS: 
Alright. Let's get back then to the story of your relationship with Jeffrey, and we've 
talked about your first encounter with him and how it evolved from that into your full 
time employment with Jeffrey, but what were you doing at Mar-a-Lago before you quit 
Mar-a-Lago? 
V: 
I was just a locker room attendant and sometimes I did babysitting for the rich and 
famous. So, I wasn't anything big. I worked in the spa area. That's why I was studying 
anatomy, because I was really really interested in becoming a _massage therapist_, and at 
the locker room, I didn't do much. I mean I was making tea for a living, I would, you 
know, make sure the toilet paper had a little triangle in it after everybody went to the 
toilet, or wipe down the water from the basin, you know, it was a very easy peasy job. 
JS: 
Did you get that job through your Dad? 
V: 
Yes, my Dad got me the job. 
JS: 
Ok, and you were only 15 years old at the time, were they aware of how old you were at 
Mar-a-Lago? 
V: 
Of course, definitely. We had to go through extensive, you know, we even had to get 
drug tested and id test and so on and so forth. I mean, Mantas (?) is very strict on 
employment, yeah, everybody knew. 
JS: 
Ok. Was there ever any conversation with Ghislaine about how old you were before you 
were taken to Jeffrey's mansion? 
V: 
No. She didn't ask me how old I...

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Telephone interview with Virginia Roberts 
Page 8 of23 
you know, I was actually interested in making my life better by studying so what they 
were offering me was a chance to become a legitimate masseuse but it was getting 
trained. They would have people show me how to work the body and be called a 
massage therapist and get me books on it, and you know, keep me interested, and every 
time, you know, I was with Jeffrey, literally was about massages, I don't mean just going 
in and have sex with him. I mean massage, because it would always start out with 
massage and then it would lead into sometimes other things. 
JS: 
Alright, once this evolved. into full time employment, what did full time employment 
mean? 
V: 
That was entirely having to travel with Jeffrey in every city. When he was in Palm 
Beach, I stayed at my apartment, and he would call me to his house once or twice a day 
sometimes, and that's, you know, do things with him. Sometimes we'd go out shopping, 
sometimes we'd go out and watch a movie. You know, simple things like that, go to an 
expo or a fair, whatever it was. 
But when we were in other cities, I was at my 
apartment_, I lived with him full time. What I mean by full time is even in the middle of 
the night, I could get a ring on my phone next to me and tell me to come in bis room, you 
know, so it was literally full time. 
JS: 
When you say that when you were in Palm Beach you were living in your apartment, 
were you living on your own or were you living with members of your family at that 
time? 
V: 
No, after I quit Mar-a-Lago, Jeffrey offered to get me an apartment in Palm Beach 
somewhere, Royal Palm Beach, and it was a nice apartment. He furnished it for me, it 
was absolutely beautiful, but yeah, that's the only time I would spend time away from 
him really. 
JS: 
This apartment was on Royal Palm Beach Boulevard or out in the Village of Royal Palm 
Beach? 
V: 
I so honestly don't remember. I'...

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Telephone interview with Virginia Roberts 
Page 9 of23 
JS: 
Yes, I was talking about a street. Royal Palm Drive is on the island of Palm Beach, and 
it's a street that is lined with large royal palm trees, and I'm wondering if this was an 
apartment on the island or was this an apartment out west of town ... 
V: 
No, it was actually in Royal Palm Beach, not on the island. 
JS: 
Alright. 
V: 
I would be driven, it was closer to my family than it was closer to him. I wanted to be 
close enough to everybody else so that when I was in town, I could just go see them 
quickly. 
JS: 
Ok. So we're not talking about Royal Palm Boulevard. We're talking about the town of 
Royal Palm west of town. Jeffrey got you an apartment out there. 
V: 
That's correct. 
JS: 
When he was in Palm Beach, you were generally not staying at the mansion, you were 
staying at the apartment that he got for you out west of town. 
V: 
That's correct. 
JS: 
Ok. 
V: 
I mean then there was times, I don't wanna say that every time I stayed at my apartment. 
There was times we'd fly back from some city maybe too late at night to really want to 
go back home, so you know, it's like 12:00 at night or 1 :00 in the morning. I was just 
staying in the yellow room, or something like that; one of the guest rooms in Palm Beach. 
But majority of the time, I would definitely want to get back to my own apartment. 
JS: 
Alright. What were the general hours of your full time employment when ... ? 
V: 
There was not set hours. It wasn't like logging, and you know, bitting the shift button, 
nothing like that. The way I would get paid would be, ok, if I was in Palm Beach, I 
would get $200 an hour to massage Jeffrey or some of bis friends and then go home. So 
it would be like that. If I was traveling with him, it would be per massage, so I would be 
getting paid per day. So I wouldn't be getting paid on an hourly rate. He wouldn't say 
ok, today you're going to work for me fr...

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Telephone interview with Virginia Roberts 
Page 10 of23 
JS: 
From the time the massage started. Ok. 
V: 
Sometimes we'd go there and I would wait for a while or talk with Ghislaine and Jeffrey 
about something or we'd meet somewhere and talk about something. A lot of times, I'd 
meet him upstairs in his room where he was ready for me. But then there was a lot of 
times where it didn't start right away, so he couldn't really pay me from the time I got 
there sometimes unless it was just paid from the time I massaged him til the time the 
massage was over. 
JS: 
Alright. Did your duties for Jeffrey ever include anything other than providing him 
massages and sex in connection with the massages? Did he ever give you any other 
responsibilities to perform? 
V: 
I was asked to do the same things that I did to Jeffrey to a few of his fellow colleagues as 
well. Those were my duties. He looked at it this way is that I was going to be a 
professional massage therapist, and maybe I needed some clientele, so he had me perform 
erotic massages on a few people. 
JS: 
Did that start here in Palm Beach County? 
V: 
It did. The first one did. 
JS: 
Ok, and how long after you first met Jeffrey did he first ask you to provide services for 
one of his friends? 
V: 
About 9 months, I think it was. It wasn't a full year, it wasn't 6 months, but between 6 
months and a year, which is why I'm saying 9 months. 
JS: 
And when you provided services to a friend of Jeffrey's, who paid you for those services? 
V: 
Jeffrey would. I would get paid the next time I saw Jeffrey, so if I was invited to the 
Breakers Hotel to give a massage, I would give a massage, I would go home, and the next 
day when I saw Jeffrey, he would pay me for what I did. So, it was paid always by him, 
it was set up by him, so he always knew what to pay me. I did get tips and things like 
that, if you call it that, you know, like a hundred dollar tip or something from a few of ...

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Telephone interview with Virginia Roberts 
Page 11 of23 
V: 
In a roundabout way, yes. In so many ways, Jeffrey really really had to train me, and that 
was why Ghislaine said that she and Jeffrey enjoyed me so much was because they never 
really had to speak much to me to tell me what they wanted me to do. You know, I 
wasn't waiting for you know, their directions. Jeffrey would tell me to go give an erotic 
massage to friends. He wouldn't give me much detail about it, but he would say to treat 
them like you treat me. 
JS: 
Did he refer to it as an erotic massage or are those your words? 
V: 
Erotic massage is my words. That's exactly what it was, but he would tell me to treat 
them how he wanted it, so I'd do what he wanted without having to say to me words 
more. I mean, I complied with what he wanted because it was somewhat of a, I don't 
know, I don't know how to say it, it was just very mindboggling how I let him have so 
much control or power over me basically. The massages would be routine to what Jeffrey 
wanted with my so called new clientele, and with their own words would ask me to 
provide them with sexual pleasure after the massage. 
JS: 
Did you ever report back to Jeffrey about what happened when you provided massages to 
his friends? 
V: 
Of course, of course, and I knew that his friends were reporting back to him as well 
because there were times where he would instigate conversation by saying you know, so 
and so had a great time, you did wonderful, you know so and so gave me a call and told 
J.E how it went ... 
JS: 
Did Jeffrey ever elicit details from you? "Tell me what happened, describe in detail what 
went on?" 
V: 
No, but he would have a laugh, he had a laugh with me a few times about some of their 
different mannerisms, I guess you would say, like some of them, one guy had a foot 
fetish and that was really weird and I mentioned it to Jeffrey, and we would have a laugh 
over it. He didn't want t...

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Telephone interview with Virginia Roberts 
Page 12 of23 
V: 
No, not at this stage. I just, some of these people are really influential in power, and I 
don't want to start another shitstorm with a few of them. I'll tell you that there was some 
erotic massages given to, I'm just afraid to say it to you. 
JS: 
Ok, Virginia. 
V: 
It's like geez, I don't know ifl want to, I'm really scared of where this is gonna go. 
JS: 
Alright. I understand that, and as I told you from the beginning, if I ask you a question 
that you are uncomfortable answering, you just tell me that, and I will move on, and I 
understand that at least right now, you are uncomfortable answering, and I am certainly 
going to respect that. 
V: 
Thank you so much, Jack. 
JS: 
No, that's quite alright. I am very appreciate of the cooperation you are providing, and I 
don't want you at any time to feel that we are talcing unfair advantage of that cooperation, 
so give me the information that you're comfortable giving me, and if we get to a point 
where you're uncomfortable, I will respect that and we'll move on from there. 
V: 
Ok. 
JS: 
I want to talk a little bit about the traveling that you did with Jeffrey. About how long 
into your relationship with him did that first start? 
V: 
Immediately. I started traveling immediately. Not internationally until I think about, 
Gosh, I can't remember even, I think it was a year later that we started doing international 
travel. Maybe like 9 months to a year again. Not too sure to be honest. 
JS: 
So that would have been approximately the summer of 1999? Somewhere around there? 
V: 
Yes. Somewhere around there. Somewhere around a year, somewhere around there, I 
can't pinpoint it exactly. 
But like I said, we started doing domestic traveling 
immediately, so my first destination with him was New York and Santa Fe and the 
Carribean, California, I would take trips with him occasionally. Sometimes we would go 
to St. Lou...

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Telephone interview with Virginia Roberts 
Page 13 of23 
V: 
Yes. Just a normal flight, an e-ticket. 
JS: 
Like the rest ofus common folk. 
V: 
But when I was traveling with Jeffrey, the majority of the time would be on the black jet. 
JS: 
Now, when you say there would be times when you would travel by yourself because he 
was sending you somewhere, tell me about that. How did that come about? 
V: 
So, one of his colleagues would be at the Carribean or Santa Fe or even New York, or 
wherever, and he would call me up on those days where I am not working with him or in 
Palm Beach with him, and he would ask me to get on the next plane to so and so and go 
meet so and so, and that's when I would take e-tickets. His secretary or special assistant, 
whatever, would organize it for me and give me the details and I would just walk up the 
line and they'd let me right through. 
JS: 
Can you give me any ideas as to how many times it happened that Jeffrey would send 
you off to meet some friend of his at some location outside of Palm Beach? 
V: 
How many times it happened? I'm not too sure. Probably about 10-15 times. 
JS: 
Ok. And on those occasions, how much time would you spend with one of Jeffrey's 
friends when you were sent to a location that you would have to travel to? 
V: 
Only a couple of days. Only 2 days, that's it. 
JS: 
And how were you paid for those trips? 
V: 
I would be paid in cash upon my arrival back with Jeffrey. So, whenever I was back with 
Jeffrey, he would count up how many days I've had, sometimes give me even more than 
what I deserved, not deserved, but what I earned and give me a little extra. 
JS: 
Was there a daily rate for those trips or was that per massage also? 
V: 
Per massage. With Jeffrey, I would be honest. I wouldn't tell him I did 15 massages if I 
didn't. He knew he could trust me. He could always come back to the other person that 
he sent me to give massages and ask them as well, so you k...

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Telephone interview with Virginia Roberts 
Page 14 of23 
I'd start with his feet, go up to his calves, up his legs, buttocks, back, his neck, his head, 
his arms, yada yada, and then it would be time to flip over, and some of the men would 
want me to continue on massaging the front side of them and they would instigate me to 
begin having sex with them or foreplay, whatever you want to call it. 
JS: 
So routinely, these massages involved sexual activity. Is that accurate? 
V: 
That is accurate. 
JS: 
Ok. Let's talk about the travel that you were involved in when you were on Jeffrey's 
private plane. Generally speaking, who were the passengers on the plane when you 
traveled. 
V: 
Well, Larry was the pilot, and then there was a short, small solid guy, I don't know his 
name, but he was a co-pilot, and then he changed and there was another guy brought in 
later on. Generally spealcing, there was always Jeffrey, sometimes Ghislaine, sometimes 
Emmy, sometimes a whole bunch of other girls, sometimes famous people, sometimes 
some politicians or yeah, just about anybody could fly on his plane. There was never no 
any set routine who would come and who would go. It was an influx of people on 
Jeffrey's airplane. 
JS: 
I want to deal with these things separately in order to respect some of the reservations 
that you have, so I'm going to ask you who the people were that you remember flying 
with Jeffrey on his plane when you were personally present without regard to whether 
there was any sexual activity that occurred on the plane or not. So I'm not asking you to 
implicate any of these famous people in improper conduct, but just tell me what the 
names of the people are that you remember that you consider to be famous people. 
V: 
Ok, there was Naomi Campbell, Heidi K.lurn, there was Bill Clinton. There was Al(?) 
Gore, there was a whole bunch of models, I wouldn't really honestly be able to give their 
names. There was Matt Gro...

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Telephone interview with Virginia Roberts 
Page 15 of23 
what was happening in the house. It would start off with massaging or we would start off 
with foreplay, sometimes it would lead to, you know, orgies. 
JS: 
Were there occasions when you were in Jeffrey's company, whether on the ground or in 
the air, where there were other girls present whom you knew to be under age 18? 
V: 
Yes. There was a constant influx of girls coming in and going out. And we were all very 
young. On occasion, there was some older girls, and I don't mean older as in like in their 
30s or anything, I mean like 28, 29, something like that, just very rarely. The majority of 
the girls that Jeffrey actually met or had on his plane or in his house were under age. 
JS: 
Do you know how it is that Jeffrey established with any of these underage girls? 
V: 
Yes, I do. He would send me personally or with other girls to clubs or shops, to _pick up 
anywhere, I mean we were constantly on the look for other girls that might satisfy 
Jeffrey. 
JS: 
What instructions were you given about what to look for? 
V: 
Young, pretty, you know, a fun personality. They couldn't be black. If they were any 
other descent other than white, they had to be exotically beautiful. That was just about it. 
JS: 
Who gave you those criteria? 
V: 
They both gave us the instructions, and it wasn't just me, Jeffrey asked most girls to bring 
a friend and make extra money. They would use us young girls So that way it probably 
looked a lot more safer to a girl that we were procuring to younger girls that were already 
doing it. That was the way that Jeffrey had it. 
JS: 
Were you given any instruction at all on how to approach these girls? 
V: 
Yes. 
Jeffrey and Ghislaine both taught me to, depending on the circumstances, 
depending on the girl, you could offer them a job as a massage therapist or you could tell 
them you have a really rich friend with, you know, great contacts in the ...

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Telephone intemew with Virginia Roberts 
Page 16 of23 
JS: 
Let me see if we can try to narrow it down a little bit. Is there any doubt in your mind 
that it was more than 1 0? 
V: 
Yes, there was definitely more than 10. 
JS: 
Ok, what I want you to do is to give me the highest number that you are comfortable in 
saying there were definitely more than X number of underage girls that I know Jeffrey 
Epstein engaged in sex with while I had a relationship with him. How would you fill ii, 
that blank? Definitely more than how many? 
V: 
I'd say definitely more than a hundred. 
JS: 
Alright. Did Jeffrey ever help to pick out your clothes? 
V: 
Oh yes. I mean he wasn't out to dress me like a porn star or anything. He would always 
dress me very classy, but·we'djust go shopping all the time together. 
JS: 
Did he ever express any style preferences in terms of how he wanted you to dress? 
Besides dressing classy, I'm, you know, any other suggestion to you about how he 
wanted you dressed? 
V: 
He didn't, like I said, wasn't trying to dress me in any prostitute way or anything like 
that. It was nice, classy outfits I was wearing like Gucci, Dolce Gabbana, Chanel, things 
like that. He was buying me a lot of very, very nice clothing. It was provocative. I mean 
I was wearing miniskirts, and tight short shorts and little shirts that showed my belly and 
my cleavage and everything, but they were very expensive clothes. 
JS: 
Was there every any dress up role playing? 
V: 
Yes. There was. Lots of it. Jeffrey loved the latex outfits Ghislane had for us girls, he 
had bondage outfits, he had all different kinds of outfits; but his favorite was the 
schoolgirl. 
JS: 
Tell me about that. 
V: 
Well, you know, Ghislaine would talce me to dress me up to surprise J.E or Jeffrey would 
ask me to get dressed up, that would include wearing a tiny little skirt with nothing 
underneath, a white collared shirt that you would be wearing to school wi...

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Telephone interview with Virginia Roberts 
Page 17 of23 
V: 
Yes, he did. He did all the time. The worst one that I heard from his own mouth was this 
pretty 12 year old girls he had flown in for his birthday. It was a surprise birthday gift 
from one of his friends and they were from France. I did see them, I did meet them. 
Jeffrey bragged afterwards after he met them that they were 12 year olds and flown over 
from France because they're really poor over there, and their parents needed the money 
or whatever the case is and they were absolutely free to stay and flew out. Those were 
the worst ones. He was constantly bragging about girls' ages or where he got them from 
or their past and how terrible their past was and good he is making it for them. 
JS: 
Where were the 12 year old girls flown to from France? Where did they come to? 
V: 
Palm Beach. 
JS: 
And were they flown in on Jeff's private plane or did they get transported? 
V: 
No. They were transported by somebody else. 
JS: 
Ok. Was the sexual activity that went on on the airplane conducted in such a way so that 
any of the crew was aware of what was going on? 
V: 
They were told to knock if they had to come out, if the crew had to come out. They were 
told, you know, to come out as little as possible, so they weren't out there hanging out 
watching everything, no, but it doesn't talce an idiot to put two and two together to say 
well there's a whole bunch of half dressed teenagers on board with this old man who is 
constantly being massaged by them and he wants me to keep the door shut for what 
reason? I mean, only they could put that together, but yeah, they knew. 
JS: 
Did Mr. Epstein ever talk to you about people of power and influence owing him favors? 
V: 
He would laugh about it, you know, I never really knew what to talce serious from Je:ffrey 
because he was such a funny character at times. You never knew if what he was saying 
was true or not. Yeah, lo...

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Edwards adv. Epstein 
Telephone interview with Virginia Roberts 
Page 18 of23 
JS: 
Ok, well let's back up before we get to those conversations and tell me approximately 
when it was that you were contacted by the person who you believe was with the FBI. 
V: 
Ok. It's hard for me to pinpoint, ifl had to pinpoint it, it would be in 2007 sometime. 
JS: 
Alright. And you were living in Australia at that time, correct? 
V: 
Correct. 
JS: 
You were contacted by telephone? 
V: 
That's correct, by my cell phone. 
JS: 
Ok and do you have any idea how your name came up leading to that contact. 
V: 
No idea. No idea whatsoever. When I did ask, I was told that some girls had revealed 
my name, I guess, and that's how everybody, the FBI knew to contact me. 
JS: 
OK. 
V: 
But I don't know offhand or sorry, I just walked into the wrong room. 
JS: 
Ok. 
V: 
Sorry go on. 
JS: 
Yes & I'll never tell her you said that. Virginia, how long was it after that phone call 
from the FBI person were you contacted by Mr. Epstein's lawyers. 
V: 
Like a week. It was back to back to each other, I remember being so scared after talking _ 
to the FBI thinking what's happening, what's going on. It's been like 6 years, 7 years at 
that stage, how did they find me & what do I have to do with this? So yeah, I do 
remember that very well, and it was only about a week later I was called by his attorney. 
JS: 
Who was it that contacted you, do you remember? 
V: 
I want to say Bill Riley, but he might have been from the FBI. No, it was Bill Riley. Bill 
Riley. Not sure if that's his correct name, but that's what is coming to mind 
JS: 
What do you remember about that conversation? 
V: 
I remember a Mr. Goldberger as well, I remember, there might have been two of them. 
JS: 
Alright. 

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Edwards adv. Epstein 
Telephone intervfow with Virginia Roberts 
Page 19 of23 
V: 
I can't remember which one it was. I want to say Bill Riley is the good one. 
JS: 
Alright, so either Bill Riley or a Mr. Goldberger or both of them contacted you, and what 
do you remember about that? 
V: 
I don't know if it was the same guy who contacted me that week later who put me in 
touch with Jeffrey. I think he was on the phone and he put speakerphone on with Jeffrey. 
So he connected me with Jeffrey. I don't lmow if it was the same guy or different, but I 
definitely know that Bill Riley was the first guy to contact me. I'm pretty sure about that. 
JS: 
Ok. Tell me about that conversation. 
V: 
He asked me what I knew about what's going on with Jeffrey and apparently, there was 
an investigation being held about some of the girls who had come out and said that 
Jeffrey had sexual contact with them under the age of a minor and that he was 
discrediting lot of these girls and making them out to be drug addicts and prostitutes and 
what have you so they wouldn't be looked upon as worthy in the court's eyes so to speak. 
And you know, he told me in the first five minutes that, you know, if I stay quiet, that 
"I'll be looked after" . And that was the exact way it was said. It wasn't like you know, 
I'm gonna pay you a zillion dollars or anything if you be quiet, but if I stay quiet~ I would 
"looked after". And I remember saying I don't want any part to do with this. You know, 
this is not something I want to be a part of, I've got a young family. I wish the best for 
everybody in this, you know, take care kind of thing. A week later, I was called after the 
hearing by one of Jeffrey's lawyers. I can't tell you exactly which one it was but he had 
Jeffrey on the other line and he connected Jeffrey and I, and Jeffrey tried to make some 
simple conversation, "How are you? How have things been?" You know what I mean, 
catching up. 
JS: 
Do you know if the lawye...

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Edwards adv. Epstein 
Telephone interview with Virginia Roberts 
Page 20 of23 
next thing I knew, I was sent my victim's letter, my notification of being a victim through 
the US Attorney's Office and that's when I knew it was well out there enough not to have 
Jeffrey's lawyers come back on me and discredit me in the same way he had done to all 
the other girls. So, I called up Joseph Bird who was the recommended lawyers on my 
paperwork that they had given me and started going from there. 
JS: 
So you contact Mr. Joseph Bergs' office and then you were dealing with his office from 
that point forward. 
V: 
That's correct. 
JS: 
Tell me about the ending of your relationship with Jeffrey. That is, at what point in time 
did your full time employment end and how did that happen? 
V: 
Ok. So, it hadn't really ended. I walked away from it all. Jeffrey sent me to Thailand 
where I met my husband and escaped to Australia, never to return back to the states. 
About 6 · months prior to that, he came up with a proposition that I thought was really 
disgustingly sick. And it really showed me for the first time in 4 years I had been with 
him that nothing was going to change and I was always just going to be used by him(?) 
which I did not like. He offered me a mansion and some of his money every month, I 
forget what he called it, a monthly income of what he made to bear one of his children. 
The proposition was that if anything ever happened between Jeffrey and I, that I would 
have to sign my child over to him basically and that the child would be his and 
Ghislaine's, and I would be looking after it as long as nothing happened between Jeffrey 
and I. So, I was kind of freaked out by all of that. I pushed Jeffrey more to please get me 
some more training, you know, and I was getting older and not of as much interest to 
Jeffrey anyways. I was 19 now, and he likes a female a lot younger. So he sent me to 
Thailand, in September 2002 _. I was first suppos...

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Edwards adv. Epstein 
Telephone interview with Virgirua Roberts 
Page 21 of23 
law and that there is people that still believe in it. So that's it. Thank you guys for 
listening to me, hearing me out and helping me. It's kind of hard to get through. 
JS: 
Thank you very much. Yes, I'm sure it has been very difficult and I am very appreciative 
of the courage you have shown in doing what you have done, which really brings me to 
the last subject, and that is what was it that motivated you to go public with all of this? 
V: 
Sharon Richard contacted me. I like her, I do, I like her a lot. I know she's a journalist, 
and journalists are normally bloodsucking leeches, but I like her for that, but she is an 
honest bloodsucking leech. She told me a lot about what was still going on, and she 
showed me a picture of Jeffrey with a little girl who looks like she could have been 12 
years old. I mean it was disgusting. I agreed to talk with her, I never agreed to do 
anything until she showed me some pictures, and at that stage, being a mother of 3 
children and having a daughter who I would do anything for to protect, I would put my 
neck on the line to make sure she never has to go through what I had to go through, and 
knowing all of this, and knowing that he's still out there doing the same exact thing with 
no regrets, no remorse, no worry about what he's doing to those girls, and all those girls 
feeling the same way that I did, so I, you know, I'm doing it because I believe in my heart 
of hearts it's the right thing to do. It's what I would want somebody to do for my 
daughter or my sister or my friend, and it saddens me to know that it's still going on right 
now. It's like the seashell story. I don't know if you're heard the story about the little kid 
who throws back a starfish, you know, the little brother tries to ask his sister, "why do 
you throw them in, they're all gonna die anyways, the little girl says "well, it's this one 
that I can ...

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Edwards adv. Epstein 
Telephone interview with Virginia Roberts 
Page 22 of23 
V: 
He told me a long time ago that everyone owes him favors. They're all in each other's 
pockets. 
JS: 
When you say you asked him why is Bill Clinton here, where was here? 
V: 
On the island. 
JS: 
When you were present with Jeffrey Epstein and Bill Clinton on the island, who else was 
there? 
V: 
Ghislaine, Emmy, and there was 2 young girls that I could identify. I never really knew 
them well anyways. It was just 2 girls from New York. 
JS: 
And were all of you staying at Jeffrey's house on the island including Bill Clinton? 
V: 
That's correct. He had about 4 or 5 different villas on his island separate from the main 
house, and we all stayed in the villas. 
JS: 
Were sexual orgies a regular occurrence on the island at Jeffrey's house? 
V: 
Yes. 
JS: 
If we were to take sworn testimony from the people I am going to name, and if those 
people were to tell the truth about what they knew, do you believe that any of the 
following people would have relevant information about Jeffrey's taking advantage of 
underage girls? So I'll just name a name, and you tell me yes if they told the truth, I 
think they'd have relevant information or no, I don't think they would, or I don't know 
whether they would or not. Ok? You understand? 
V: 
Yes. 
JS: 
Ok. Les Wexner. 
V: 
I think he has relevant information, but I don't think he'll tell you the truth. 
JS: 
Ok. Alan Dershowitz. 
V: 
Yes. 
JS: 
David Copperfield. 
V: 
Don't know. 
JS: 
Tommy Matola. 

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Edwards adv. Epstein 
Telephone interview wHb Virginia Roberts 
Page 23 of23 
V: 
Don't know. 
JS: 
Prince Andrew. 
V: 
Yes, he would know a lot of the truth. Again, I don't know how much he would be able 
to help you with, but seeing he's in a lot of trouble himself these days, I think he might, 
so I think he may be valuable. I'm not too sure of him. 
JS: 
Ok. Virginia, I think that's all I have for you. Let me tell you what I would like to do. 
As I told you in the beginning of th.is conversation, we've been recording it, and 
hopefully, we've got a clear enough recording so that we've taken down everything 
accurately and when it's transcribed, it will be clear and accurate, but what I would like 
to do is transcribe it, send it to you, have you take a look at it, and if there's anything that 
we got wrong in the statement, you can write back and you can make changes in the 
transcript so that the transcript is accurate. Is that fair? 
V: 
No worries. That is fair. No problem. 
JS: 
Alright, great. 1 really do appreciate that and tell me what the best way is to send the 
transcript to you. 
V: 
Email. If you just want to send it by email or if you want to send it by mail, either or. 
JS: 
Ok. Give me your email address if you would please. 
JS: 
Let me read that back to you: 
V: 
Yep that's it. 
BE: 
Thank you Jenna, appreciate it. 
V: 
No problem, Brad. 
JS: 
Thank you very very much. Bye Bye now. 
V: 
Take care Jack. Nice meeting you. 
JS: 
You too. 
*Redaction has been made at the request of the witness. 

NOT A CERTIFIED COPY
IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT 
IN AND FOR PALM BEACH COUNTY, FLORIDA 
CASE NO. 502009CA040800XXXXMBAG 
JEFFREY EPSTEIN, 
Plaintiff(s), 
vs. 
SCOTT ROTHSTEIN, individually, 
BRADLEY J. EDWARDS, individually, 
and L.M., individually, 
Defendant(s). 
------------------------------
VIDEOTAPED DEPOSITION OF JEFFREY EPSTEIN 
January 25, 2012 
9:34 a.m. - 10:03 a.m. 
SEARCY, DENNEY, SCAROLA, BARNHART & SHIPLEY, PA 
2139 Palm Beach Lakes Boulevard 
West Palm Beach Florida 33409 
Stenographically Reported By: 
Tammy Nestor, RPR 
EXHIBIT 
ui 
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C 
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I 

NOT A CERTIFIED COPY
APPEARANCES: 
ON BEHALF OF PLAINTIFF: 
JACK SCAROLA, ESQUIRE 
SEARCY, DENNEY, SCAROLA 
BARNHART & SHIPLEY, PA 
2139 Palm Beach Lakes Boulevard 
West Palm Beach, Florida 33409 
ON BEHALF OF DEFENDANT: 
CHRISTOPHER E. KNIGHT, ESQUIRE 
JOSEPH L. ACKERMAN, JR., ESQUIRE 
FOWLER WHJTE BURNETT, PA 
Espirito Santo Plaza 
1395 Brickell Avenue, 14th Floor 
Miami, Florida 33131 
2 
JACK A. GOLDBERGER, ESQUIRE 
ATTERBURY, GOLDBERGER & WEISS, PA 
One Clearlake Centre, Suite 1400 
250 Australian Avenue South 
West Palm Beach, Florida 33401 
DARREN K JNDYKE, ESQUIRE 
301 East 66th Street, #JOB 
New York, New York 10065 
INDEX 
EXAMINATION: 
PAGE 
By Mr. Scarola 
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EXHIBITS 
EXHIBIT 
DESCRIPTION 
PAGE 
3 
1 Third Amended Complaint in LM v. Epstein 
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THE V1DEOGRAPHER: Today's date is 
January 25, 2012. The time is approximately 
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9:34 a.m. This is the videotaped deposition of 
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Jeffrey Epstein in the matter of Epstein versus 
Edwards. 
This deposition is being conducted at 2139 
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Palm Beach Lakes Boulevard, West Palm Beach, 
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Florida. 
The court reporter is Tammy Nestor of 
Phipps Reporting. The videographer is Chris 
Kennedy of Legal Video Services, Inc. in 
association with Phipps Reporting. 
And will the counsel please announce 
appearances for the record. 
MR. SCAROLA: My name is Jack Scarola. 
I'm counsel for Brad Edwards. Brad is also 
present. 
MR. KNIGHT: Christopher Knight on behalf 
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of Jeffrey Epstein. 
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MR. GOLDBERGER: Jack Goldberger on behalf 
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of Jeffrey Epstein. 
MR. INDYKE: Darren lndyke on behalf of 
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Jeffrey Epstein. 
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MR. ACKERMAN: Joseph Ackerman on behalf 
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of Jeffrey Epstein. 
JEFFREY EPSTEIN 
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Was called as a witness and after being duly sworn on oath was 
examined and iesiified as ioiiows: 
EXAMINATION 
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BY MR SCAROLA: 
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Q Would you please state your full name and 
your current residence address? 
A I'm Jeffrey Edward Epstein. A...

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BY MR. SCAROLA: 
Q Do you now or have you ever had a sexual 
addiction? 
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MR. KNIGHT: I'm going to instruct him not 
to answer the question. That's outside of the 
area of this abuse of process lawsuit. 
And just to let you know, he's here to 
answer all the questions you want relative to 
the abuse of process. The judge has been pretty 
clear relative to the discovery regarding any of 
the prior sexual allegations, et cetera. And 
just so we don't waste your time or our time, 
I'll be consistent on that per what the judge 
has previously discussed regarding discovery. 
MR. SCAROLA: Well, you and l have a very 
different understanding of what the court's 
prior rulings have been. But we'll let the 
court deal with that. 
BY MR. SCAROLA: 
Q 
Do you now or have you ever had a sexual 
preference for minors? 
MR. KNIGHT: Same. 
BY MR. SCAROLA: 
Q 
Have you ever acted on a sexual preference 
for minors? 
MlR. KN]GHT: Same. 
BY MR. SCAROLA: 
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Q Have you ever informed anyone other than 
your legal counsel that you have a sexual preference 
for minors? 
MR. KNIGHT: Same. 
BY MR. SCAROLA: 
Q 
Have you ever informed anyone other than 
your legal counsel that you have acted on a sexual 
preference for minors? 
MR. KNIGHT: Same. 
BY MR. SCAROLA: 
Q Have you ever sought or received 
evaluation, counseling, or treatment for any form of 
sexual addiction? 
MR. KNIGHT: Same. 
BY MR. SCAROLA: 
Q Have you ever sought or received 
evaluation, counseling, or treatment for any 
sex-related issue? 
MR. KNIGHT: Same. 
BY MR. SCAROLA: 
Q 
Have you ever retained the services of a 
consultant to assist in changing your public image 
following your arrest on sex-related charges? 
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intention to ask any questions, and you may be, 
any questions outside of this clearly harassing 
area relative to issues that are outside of the 
four corners of the complaint or whether this 
is just going to be a continuance of questions 
of this witness that have no other means of 
advancing this lawsuit but only have means of 
doing other things of which I won't - I don't 
care to list them here. Do you plan to go into 
other areas? 
MR. SCAROLA: l am - I am planning on 
taking a very thorough and comprehensive 
deposition of Mr. Epstein. 
MR KNIGHT: Are you asking - planning to 
ask any questions that are not sexual or 
criminal in nature? 
MR. SCAROLA: Oh, I'm sure there will be 
many that you would probably not consider 
sexual or criminal in nature, but J don't know. 
MR. KNJGHT: !Let's proceed for a little 
while, see what we can do, because certainly we 
have taken the time out to come up here, 
people's schedules have been made, et cetera, 
people have traveled long distances, but we may 
have to quit and go to the court. 
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for prostitution with respect to the clan m on which 
you were convicted? 
A Same answer. 
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Q Who is the minor that }'OU solicited for 
prostitution with respect to the claim on which you 
pied guilt,•? 
A Same answer. 
Q Did you, in fact, plead guilty to 
soliciting for prostitution? 
MR KNIGHT: Asked and answered. 
THE WITNESS: Yes, sir. 
BY MR. SCAROLA: 
Q Did you, in fact, plead guilty to 
soliciting a minor for prostitution? 
A No. 
Q Where was it that you solicited for 
prostitution in the manner - in the matter in which 
you pied guilty? 
A Sarne answer. 
Q When was it that you solicited for 
prostitution in the matter in which you pied guilty? 
A Same answer. 
Q Have you ever discussed your sex-related 
arrest or conviction ...

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going to take a quick break ifwe can go off 
the record. 
THE VIDEOGRAPHER: The time is 9:30 -
9:40. We are going off the record. 
(Thereupon, a recess was taken at 
9:43 a.m.) 
THE VIDEOGRAPHER: The time is 9:50 a.m. 
We are back on the record. 
MR. KNIGHT: As 1 mentioned earlier, we 
are here to answer questions relevant lo the 
lawsuit that is at issue. 
Relative to your question earlier and the 
instruction not to answer,] do believe it was 
appropriate, but I'm going to have 
Mr. Goldberger address what be believes the -
is the - our client is entitled to, but at the 
same time, there are other issues we want to put 
on the record. 
l will allow you to ask more questions, but 
if it's going to stay on this line, we may have 
to adjourn. 
MR. GOLDBERGER: Okay. This is Jack 
Goldberger. A couple issues. First, as to the 
questions that, Mr. Scarola, you asked 
concerning conversations that Mr. Epstein may 
or may not have had with, 1 believe you couched 
it as news reporters or news media, he would be 
invoking Fiith Amendment privileges as to those 
questions in addition to the objection raised 
by Mr. Knight 
MR. KNIGHT: I'm withdrawing the 
instruction. 
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MR. GOLDBERGER; Okay. All right Anyhow 
he's invoking Fifth Amendment privileges as to 
that line of questioning. 
As to the total line of questioning where 
you are asking Mr. Epstein about sex-related 
issues, as you know, your client, Mr. Edwards, 
has filed a lawsuit in federal court where he is 
seeking to overturn the non-prosecution 
agreement that Mr. Epstein is a party to. 
I believe that you are aslting these 
questions in an effort to further Mr. Edwards' 
attempts to set aside that non-prosecution 
agreement, and I think it serves no purpose 
other than to assist your client in that 
lawsuit...

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A Correct. 
Q All right. Now, is it your -
A I believe that's --
Q 
Is it your contention -
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MR. KNIGHT: Finish your answer. Did you 
finish your answer? 
THE WITNESS: That's all right. 
BY MR. SCAROLA: 
Q Is it your contention that Bradley -
MR. KNJGHT: And any time you want to 
finish your answer, please do so. 
THE WITNESS: Sure. 
BY MR SCAROLA: 
Q Is it your contention that Bradley Edwards 
abusively prosecuted the state court case on behalf 
ofLM? 
A I don't know. Sorry. 
Q Is it your contention that Bradley Edwards 
abusively prosecuted the federal court case on 
behalf ofLM? 
MR. KNIGHT: Objection, asks for legal 
conclusions. Obviously there were lawsuits 
that were raised in this case. 
MR. SCAROLA: You don't need to make a 
speaking objection -
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MR KNIGHT: Okay. 
MR SCAROLA: -- that's intended to coach 
the witness, Mr. Knight. 
MR KNIGHT: I'm going to object. 
MR SCAROLA: So if you say yon are 
objecting on the basis that it calls for a 
legal conclusion, that's fine. And now I would 
like the witness's answer unless yon are 
instructing him not to answer. 
MR. KNIGHT: I'm not instructing him not 
to answer. 
lBY MR SCAROLA: 
Q 
Okay. Then would you please answer the 
question? 
A I'm sorry. Would you repeat it? 
Q Yes, sir. Is it your contention that 
Bradley Edwards abusively prosecuted the federal 
court action on behalf ofLM? 
A Yes, sir. 
Q 
How? 
A Bradley Edwards filed a 234-count federal 
complaint in conjunction with his partner Scott 
Rothstein to enable his partners at RRA to defraud 
south Florida investors of millions of dollars. 
His partner Scott Rothstein and his partner 
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are going off the record. 
(Thereupon, a recess was taken at 
9:58 a.m.) 
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THE VIDEOGRAPHER: The time is 10:00. We 
are on the record. 
MR KNIGHT: Okay. We have asked on 
several occasions that you ask questions that 
are relevant to the lawsuit at bar. There have 
been some questions that were getting to it 
You are back into the sexual stuff which we 
feel is inappropriate, and also relative to the 
issues that were rnised by Mr. Goldberger. 
As such, we are going to recess and ask 
further direction from the court on what is 
allowable and what is not allowable in this 
deposition. 
MR SCAROLA: So you are terminating the 
deposition at this time? 
MR KNIGHT: We are recessing the 
deposition to get direction from the court 
MR SCAROLA: Until when? 
MR. KNIGHT: We will find out what the 
court says. 
MR SCAROLA: When? Are you contacting 
the judge right now? 
MR. KNIGHT: I am not We are going to 
file an appropriate motion and we are going to 
take it to the judge and see what be cioes. 
Thank you. 
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MR SCAROLA: So that the record is clear, 
ii is my intention to ask very specific 
questions about every factual allegation 
included in every claim brought by Mr. Edwards 
on behalf of every victim in every case in 
which it is alleged that Mr. Edwards has 
abusively prosecuted that claim. 
I want to know about the connection between 
Mr.Epstein and each one of those alleged 
victims. I want to know about every individual 
who had information concerning the events that 
are alleged in those complaints, every 
individual who was in a position to have 
possibly had information about the events 
alleged in those complaints. 
I want to ask this witness about every 
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person whose deposition was taken and scheduled 
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to be taken, the relationship of those persons 
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to Mr. Eps...

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CERTIFlCATE OF OATH 
ST A TE OF FLORJDA 
COUNTY OF BROWARD 
I, the undersigned authority, certify that 
26 
JEFFREY EPSTEIN personally appeared before me and was 
duly sworn. 
Witness my hand and official seal this 25th 
day ofJanuary 2012_ 
Tam~y N~ , Court Reporter 
Notary Public, State ofFlorida 
Commission No_: EE 133933 
Commission Exp_ Date: 10/23/2015 
January 25, 2012 
FOWLER WHITE BURNETT, PA 
1395 Brickell Avenue, 14th Floor 
Miami. Florida 33131 
ATTN: CHRJSTOPHER E. KNIGHT, ESQUIRE 
Re: Epstein v Edwards 
Case No. 502009CA040800XXXXMBAG 
Please take notice that on the January 25, 2012, you 
gave your deposition in the above cause. At that time 
you did not waive your signature. The transcript is now 
available for your review. 
Please call (888)811-3408 or email 
production@phippsreporting.com to schedule and 
appointment between the hours of9:00 a.m. and 4:00 
p.m., Monday through Friday. for you to have access on 
your computer to a read-only version of the transcript. 
Jfyou are a party in this action and your attorney has 
ordered a copy of this transcript, you may wish to read 
their copy of the transcripL In that event, please 
execute the Errata Sheet, which can be found at the back 
of the transcript and return it to us for distnbution 
to all parties. 
If you do not read and sign the deposition within thirty 
(30) days, the original, which has already been 
forwarded to the ordering attorney, may be filed with 
the Clerk of the Court. 
lfyou wish to waive your sib'llalure now, please sign 
your name in the blank at the bottom of this letter and 
return it to us_ 
Very truly yours, 
TAMMY NESTOR, RPR 
Phipps Reporting, Inc. 
1615 Forum Place, Suite 500 
West Palm Beach, Florida 3340 J 
I do hereby waive my signature. 
JEFFREY EPSTEIN 
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DO NOT WRJTE ON TRANSCRJPT 
ENTER CHANGES ON THIS PAGE 
ln Re: Epstein v Edwards 
Case No_ 502009CA040800X\.."C...

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IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL 
C!RCUJT IN AND FOR PALM BEACH COUNTY, FLORIDA 
CASE NO. 50 2009CA040800XXXXMB AG 
Complex Litigation, Fla.R.Civ.Pro. 120 I 
.JEFFREY EPSTEIN, 
Plaintiff, 
-vs-
VOLUME I OF 11 
SCOTT ROTHSTEIN, individually, 
BRADLEY J. EDWARDS, 
individually, and L.M. individually, 
Defendants. 
VIDEOTAPED DEPOSITION OF BRADLEY J. EDWARDS, ESQUIRE 
Tuesday, March 23, 200 IO 
10:00 - 5:07 p.m. 
2139 Palm Beach Lakes, Boulevard 
West Palm Beach, Florida 33401 
Reported By: 
Cynthia Hopkins, RPR, FPR 
Notary Public, State of Florida 
Prose Court Reporting 
Job No.: 1333 
Page 2 
APPEARANCES: 
On behalf of the Plaintiff: 
ROBERT D. CRITTON, JR., ESQUIRE 
BUR1v1AJ\J, CR1TT01~, LUTTIER & COLEivl.AJ...J, LLP 
303 Banyan Boulevard 
Suite 400 
West Palm Beach, Florida 33401 
Phone: 561.842.2820 
and 
JACK ALAN GOLDBERGER, ESQUIRE 
ATTERBURY, GOLDBERGER & WEISS, P.A. 
250 Australian Avenue South 
Suite 1400 
West Palm Beach, Florida 33401-5012 
Phone: 561.659 .8300 
and 
On behalf of the Plaintiff: 
ALAN M. DERSHOWITZ, ESQU1RE 
HARVARD LAW SCHOOL 
Hauser 520 
Cambridge, Massachusetts 02138 
Phone: 617.496.2020 
On behalf of the Defendant: 
JACK SCAROLA, ESQUIRE 
SEARCY, DENNEY, SCAROLA, 
BARNHART & SHIPLEY, P.A. 
2139 Palm Beach Lakes Boulevard 
West Palm Beach, Florida 33409 
Phone: 561 .686.6300 
ALSO PRESENT: 
Jeffrey Epstein 
Joseph Kozak, Videographer 
Prose Reporting Services 
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EXHIBIT 
F 
Page 3 
INDEX 
EXAMINATION 
DIRECT 
CROSS REDIRECT 
BRADLEY J. EDWARDS, ESQUIRE 
BY IvIB.. CRITTON 
5 
EXHIBITS 
EXHIBIT 
DESCRIPTION 
PAGE 
PLAINTIFF'S EX. 1 ALFREDO RODRIGUEZ 
CRIMINAL COMPLAINT 
PLAINTIFF'S EX. 2 COMPLAINT 
PLAINTIFF'S E...

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Plaintiff, Jeffrey Epstein. 
MR. GOLDBERG: Jack Goldberger on behalf 
of the Plaintiff, Jeffrey Epstein. 
MR. DERSHOWITZ: Alan Dershowitz on behalf 
of the Plaintiff, Jeffrey Epstein, of counsel. 
MR. SCAROLA: The record should reflect 
that Ivlr. Epstein is also personally present. 
My name is Jack Scarola. I am counsel on 
behalf of the Defendant/Counter-Plaintiff, Brad 
Edwards. 
Thereupon, 
(BRADLEY J. EDWARDS, ESQUIRE) 
having been first duly sworn or affirmed, was 
examined and testified as follows: 
THE WITNESS: Yes. 
DIRECT EXAiv1INATION 
BY MR. CRITTON: 
Q. Would you please tell us your full name 
and home your home address. 
A. Bradley James Edwards, 1109 Northeast Second 
Street, Hallandale Beach, Florida, 33009. 
Q. Date ofbirth, please. 
A. 
Q. Ivlr. Edwards, have you ever had your 
deposition taken before? 
Page 6 
A. No. 
Q. Okay. But you've counseled, you've 
obviously taken a number of depositions both as a 
Plaintiff and as a Defendant. You're familiar with 
all the rules? 
A. I know the rules. 
Q. All right. Again ifl ask you a question 
you don't understand, if you would ask me or if you 
want me to rephrase it, I will be happy to do that. 
A. Yes. 
MR. SCAROLA: Mr. Edwards, Mr. Edwards, 
knows the rules. You can skip the 
preliminaries. 
MR. CRITTON: Is that a form objection? 
IVlR. SCAROLA: No. 
MR. CRITTON: Just a talk. 
MR. SCAROLA: It's a, it's a request that 
you not waste our time. 
MR. CRITTON: I am not wasting your time. 
And ifwe hadn't gone through that, we would 
have been done with them, Jack. 
BY MR. CRITTON: 
Q. Mr. Edwards, are you currently employed? 
A. Yes. 
Q. And by whom are you currently employed? 
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partnership? 
A. What do you mean by that? 
Q. Do you understand what an employee is? 
A. I work for the finn. 
Q. You are certainly not --
A. I am employed there, so, yes. 
Q. When did you start your association with 
the Fanner, Jaffe finn? 
A. Sometime during the month of November, 2009. 
Q. And is that when the firm was incorporated 
as a professional association? 
A. I believe so. 
Q. The attorneys who are in the current finn, 
are they all former Rothstein Rosenfeldt Adler 
attorneys; that is, the professional staff? 
A. Yes. 
Q. Is there anyone -- Let me strike that. 
Do you have paralegals as well that 
work there? 
A. Yes. 
Q. Are any of the paralegals fonner, and ifl 
refer to Rothstein Rosenfeldt Adler as RR.A, or RRA, 
is that all right with you? 
A. I understand what you mean. 
Q. Are there any other, are any of the 
Page 10 
paralegals that are currently employed by Farmer, 
Jaffe in any capacity whether they are independent 
contractors -- well, let me strike that. 
As employee's, I probably should ask 
this question: Does the firm, Fanner, Jaffe have 
employees --
A. Yes. 
Q. -- separate and apart from the partners? 
A. Yes. 
Q. And they are actually employed by the 
P.A., correct? 
A. Correct. 
Q. Does the firm have any paralegals that 
came over from the RRA firm, RRA? 
A. Yes. 
Q. Who are they? 
A. Maria and Beth. 
Q. Does Maria have a last name? 
A. Yes. 
Q. What is it, please? 
A. I believe it's pronounced Kelljian. 
Q. Can you spell it? 
A. I can give it my best shot, K-E-L-L-J-I-A-N. 
Q. And Beth's last name is what, please? 
A. Williamson. 
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Page 11 
Q. She'...

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1 
A. In what time period? What's your question? 
1 
substitution of counsel. Did you, were the 
2 
Q. I'm sorry. During the time that you were 
2 
substitution of counsel's filed the exact date that 
3 
associated with RRA, did Mrs. Williamson work on 
3 
you started with RRA? 
4 
those cases? 
4 
A. I don't remember. 
5 
A. Without you needing to ask 20 different 
5 
Q. When did your association with RRA 
6 
questions to get to your answer, I will tell you her 
6 
terminate or end? 
7 
involvement was that after federal motions were drafted, 
7 
A. The end of October 2009 or the beginning of 
8 
she was the person to literally file the motion. That 
8 
November 2009. 
9 
is her only involvement with the cases while at RRA 
9 
Q. And how did it tenninate? How did your 
I 
10 
Q. She basically filed them through the Pacer 
10 
relationship with RRA terminate? 
11 
system? 
11 
A. T11e firm closed. 
12 
A. Exactly. 
12 
Q. Did you get, notification -- when you say 
13 
Q. Prior to you working at Farmer, Jaffe by 
13 
closed, meaning what? 
14 
whom were you employed? And by employed I mean in, 
14 
A. Meaning what everybody in this entire room 
15 
in a broad sense. You could have been an 
15 
knows is that the firm went from operating to no longer 
16 
independent contractor. You could have been a 
16 
operating. 
17 
partner. You could have been an employee. 
17 
Q. And how did you receive notice; that is, 
I, 
18 
A. The law firm of Rothstein Rosenfeldt Adler. 
18 
did you receive some sort of notice that told you 
19 
Q. When did you start working for RRA? 
19 
that RRA now is a defunct firm? Did you receive 
I 
I 
20 
A. I believe April of 2009. 
20 
notification that was in bankruptcy? What, if 
I 
21 
Q. Beginning of April? 
21 
anything, did you receive? 
22 
A. Yes. 
22 
A. I didn't receive anything. 
I 
23 
Q. I saw a pleading that was filed yesterday 
23 
Q. And then how did your relationship with 
I 
24 
and it was e...

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Page 17 
the room was completely full to capacity with as many 
employees of the Rothstein, Rosenfeldt Adler fim1 as 
were in attendance at work that day. 
Q. And included lawyers, paralegals, support 
staff, investigators? 
A. Literally --
Q. -- everyone, I mean everyone who obviously 
showed up at the meeting? 
A. I don't know. 
Q. Did you see other lawyers there? 
A. Yes. 
Q. Did you see staff there? 
A. Yes. 
Q. Did you see paralegals there? 
A. Yes. 
Q. Did you see investigators there? 
A. I can't necessarily remember whether or not I 
saw investor -- investigators there. 
Q. And did more than one person speak at the 
meeting? 
A. I don't remember. 
Q. Okay. What else were you advised at the 
meeting, if anything? 
A. It was -- I stayed for very little of that 
meeting. I don't know what was advised to others, but 
Page 18 
what l heard was, firm is closing down. That's al1 l 
needed to hear and I left. 
Q. Did you subsequent -- weii, iet me strike 
that. Did you, were you able to gain, gain access 
to the building that day? I am sorry, access to 
your, to the offices of the Rothstein finn that day? 
A. Yes. 
Q. And were you able to access any of your 
files or your e-mail at that time? 
A. What time? 
Q. That same day, that Monday that you were 
advised that the firm was shutting down. 
A. Yes. 
Q. And were you able to print documents? 
Well, let me strike that. Were you able to take 
documents relating to matters on which you worked 
from the firm? 
A. What do you mean by was I able to? 
Q. Were you able to access and take with you 
documents that related to files on which you were 
working the preceding Friday when you were at RRA? 
A. I believe so. 
Q. Did you take, did you actually remove 
documents, papers that were related to files that 
you had on which ...

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Page 23 
1 
Q. Were you able to do legal work on the 
1 
entry to the office? 
2 
matters that wherein you represent individuals? 
2 
A. I don't know. 
3 
A. Was I able to? Yes, I was physically able to 
3 
Q. Well, who would, who would monitor whether 
4 
do that. 
4 
you came in or couldn't go into the office? 
5 
Q. Did you work on legal matters that day? 
5 
A. I don't know. 
6 
A. No. 
6 
Q. Was there someone there? 
; 
7 
Q. Did you subsequently, after that date, did 
7 
A. Was there someone where? 
8 
you return to the RRA offices? 
8 
Q. The impression I got is that there was 
I: 
9 
A. Yes. 
9 
some limitation on your ability to access the RRA 
ll 
10 
Q. And where are those offices or where were 
10 
offices after the Monday at which time you were 
I' 
11 
those offices located? 
11 
advised that the finn was shutting down. Did I 
; 
12 
l" .. Las Olas. 
12 
misunderstand you? 
13 
Q. The address, please? 
13 
A. No, that's correct. 
' 
14 
A. I don't remember. 
14 
Q. Okay. Who then, if you !mow, or what, if 
1: 
15 
Q. With regard to the --
15 
it was an entity, placed any restrictions on your 
1, 
16 
A. 401. 
16 
access to RRA offices? 
1, 
' 
17 
Q. Las Olas? 
17 
A. I don't know. 
;,, 
18 
A. (Witness nods head.) 
18 
Q. When you would go to the office -- well, 
,, 
19 
Q. Did you, did you after that Monday did you 
19 
let me strike that. After how many days -- well, 
20 
return to the offices at 401 Las 01as, the RRA 
20 
let me strike that. 
; 
21 
offices? 
21 
The very day, the same day that you 
' " 
22 
A. Yes. 
22 
were advised that the office was closing down, were 
:: 
i", 
23 
Q. And did you return every day thereafter 
23 
there any individuals that were monitoring what, if 
24 
for a period of time? 
24 
anything, was to be removed or not removed from the I' 
25 
A. No. 
25 
office, like a security force, Broward County 
,, 
,, 
1, 
Page 22 
Page 24 
: 
:: 
1 
Q. Was there a point in time that you were 
1 
P...

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Page 25 
Page 27 
1 
A. Possibly. 
1 
management system; that is, did you utilize the 
2 
Q. Did you ever attempt to remove something 
2 
software that was available? 
3 
from the office of the RRA offices and someone 
3 
A. Yes. 
4 
prevented you? 
4 
Q. And had you ever used a system like that 
5 
A. No. 
5 
before you came to the RRA firm, RRA? 
6 
Q. Did you ever -- and when I say remove I 
6 
A. I don't understand. 
. 
7 
mean in the sense of physically remove; that is, 
7 
Q. Okay. Had you ever used an electronic 
8 
take out boxes or take out files or something of 
8 
case management software system before you came to 
I 
9 
that nature. 
9 
RRA? 
I 
10 
A. I understand the definition ofremove. 
10 
A. Yes. 
11 
Q. With regard to, there were also, I 
11 
Q. Was yours the system that you had used 
12 
understand you had a.11 e-mail server at the office? 
12 
befme was that were you able to integrate that with 
13 
A. Okay. 
13 
RRA, with the RRA file or system when you got there, 
14 
Q. Is that correct? 
14 
or did your files have to be put on the new RRA 
L 
15 
A. Yes. 
15 
system? 
16 
Q. And I have seen something, there is 
16 
A. The latter. 
Ii 
17 
something that's called Qtask. Are you familiar 
17 
Q. In addition, so we had the e-mail server, 
I' 
18 
with Qtask? 
18 
Qtask, and electronic case management system. Was 
19 
A. Yes. 
19 
there any other type of electronic storage or system 
I 
20 
Q. And what do you understand Qtask or what 
20 
that was available for communication or storage at 
21 
did you understand that Qtask did; that is, as an 
21 
RRA? 
I:., 
22 
electronic service? 
22 
A. Not that I recall. 
I, 
23 
A. A web based network to store files and other 
23 
Q. With regard to the e-mail system, well, 
I, 
24 
materials. 
24 
with regard to the e-mail system, Qtask, and 
25 
Q. In tenns of electronic storage, or 
25 
electronic case management, did you require, was 
,. 
I 
Page 26 
Page 28 
1, 
1 
electronic data a...

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Q. With regard to your, the files 
specifically, specifically the -- well, let me 
Page 29 
strike that. During the time you were at RRA, of 
the three files, Jane Doe, L.M., and E.W. or in 
addition to those three files, did you represent any 
other individuals who were potential claimants 
against Mr. Epstein? 
A. I don't believe so. 
Q. All right. I received notification from 
you as to a Ms. N.R.? 
A. N.R. 
Q. N.R. and Ms. D.F. I believe is her name? 
A. Correct. 
Q. Were either of those individuals, had 
either of those individuals contacted you prior to 
leaving the RRA firm? 
A. I don't believe so. 
Q. Is it your testimony then that none, 
neither Ms. N.R. nor Ms. D.F. would have had a fee 
agreement or representation agreement with the RRA 
firm because they hadn't contacted you prior to your 
departure from that firm; is that correct? 
A. I'm not sure. 
Q. Is it possible that Ms., either Ms. N.R. 
or Ms. D.F. contacted you before you left the RRA 
Page 30 
firm but you just didn't sign them up before you 
left? 
MR. SCAROLA: Objection, caiis for 
speculation. 
THE WITNESS: Yes. 
BY MR. CRITTON: 
Q. Is there a reason that you would not have 
signed them up during the time you were with •· or 
let me strike that. Prior to the implosion, prior, 
prior to that Monday when you were advised that the 
RRA firm was closing down, had you made any plans to 
leave that firm, that is the RRA firm? 
A. No. 
Q. Okay. Had you discussed with any other 
attorneys in RRA departing from RRA or the RRA firm 
prior to that Monday meeting at which time you were 
advised that the firm was shutting down? 
A. No. 
Q. You indicated it's possible that Ms. N.R. 
or Ms. D.F. may have contacted you prior to your 
departure or prior to that Monday meeting. What 
makes you believe that? 
A...

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Page 33 
1 
Q. Were you at some point given access to all 
2 
your e-mails so it could be downloaded either on a 
3 
disk, hard disc, floppy disk, or some other storage 
4 
medium so that you had access to all your prior 
5 
e-mails when you were at RRA? 
6 
A. I don't know. 
7 
Q. Did you ever make that request to someone, 
8 
either the receiver or anyone else associated with 
9 
RRA? 
10 
A. I don't remember ifl made that request. 
11 
Q. I thought you indicated earlier, 
12 
IvfJ. Edwards, that you had access to some of your 
13 
e-mails. 
14 
A. I had access to all of my e-mails on that 
15 
Monday of the meeting, on the next day, on that Tuesday, 
16 
right, the immediately following the meeting. 32:46 at 
17 
some point in time it was cutoff and since that time, 
18 
when it was cutoff, I don't believe I have ever had 
19 
access back to my entire e-mail system. 
20 
Q. Okay. Have you had access to portions of 
21 
your e-mail system? 
22 
A. Not that I remember. 
23 
Q. Have you attempted to obtain access or 
24 
requested that you obtain access or information from 
25 
your e-mail, from the RRA e-mail server? 
Page 34 
1 
A. I don't remember. 
2 
Q. You say you don't remember. Would there 
3 
have been a reason that you either requested Di 
4 
didn't request access to your prior e-mail? When I 
5 
say prior I mean at RRA 
6 
A. Usually you read all of your e-mails and there 
7 
shouldn't be anything that I had not read. However, 
8 
there are some e-mails that you would like to keep 
9 
around. So there may have been reason for me to have 
10 
requested. However, I don't believe I was ever granted 
11 
access to those e-mails, and I can't specifically 
12 
remember requesting the e-mails. 
13 
Q. Within, within the e-mails you would have 
14 
corresponded with or communicated with people 
15 
outside of the finn and as well as people within the 
16 
firm, true? 
17 
A. Ever, yes. 
18 
Q. During the time you were RRA 
19 
A. Did I ever c...

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Page 37 
been put in the Qtask program for, for purposes of 
creating a project? 
A. Repeat it again. 
Q. Okay. Could a case like Jane Doe versus 
Jeffrey Epstein been put in the Qtask system as a 
project so that you and others could look at it? 
A. You mean is, is, is the project capable of 
holding such a project? 
Q. Yes,just generically. 
A. Yes, yes. 
Q. And in terms of the RRA system, did the 
RRA system ever have as, as a project Jane Doe 
versus Jeffrey Epstein? 
A. I don't believe so. 
Q. Did you ever look in the Qtask, Qtask 
system to determine whether you or anyone on your 
behalf or any other person in the firm had ever put 
Jane Doe versus Jeffrey Epstein into the Qtask 
system? 
A. Yes. 
Q. Okay. And what did you find or not find? 
A. I, I don't remember if that was the name of 
any project in the system. It could have been, but it 
may not have been. I don't remember that as a specific 
project in the system. 
Page 38 
Q. When you say a specific project, ifl 
understand you correctly, Mr. Edwards, that would 
have been, as an example, it could be any case. It 
could be a real estate case, it could be a labor 
case, it could be Jane Doe versus Jeffrey Epstein, 
but someone could, someone whether it was you or 
someone else could put in facts and information 
about the case? 
A Similar to any case management system that's, 
it just happens to be web based, but you have the right 
concept. 
Q. Is the concept the same concept for an 
electronic, for the third electronic system, you had 
the electronic case management system? 
A. I suppose at full capacity it, it may. I just 
wasn't that adept at Qtask to !mow all of the 
capabilities of Qtask. 
Q. With regard to the third item which I am 
going to come back to Qtask in just a minute, the 
electronic case...

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Page 41 
someone wanted to call the project? 
A. You have the right idea. 
Q. And ifl understand it correctly is in 
terms of the project, is if it was, if it was as an 
example the Jane Doe case, you could, you or anyone 
else could put information in about Jane Doe, might 
not call it Jane Doe, but whatever amount of 
information you or anyone else wanted to put in, 
could put it into the Qtask so that other attorneys, 
staff, investigators, paralegals, anyone who could 
access the Qtask system, could see that project; is 
that correct? 
A. So that the people that were invited to the 
project could see the project and those people only. 
Q. And when you say invited to the project, 
is, would, would, assuming you're the person who 
created the project --
A. Okay. 
Q. -- would you then set the parameters as 
to, or the guidelines as to who could come into the 
project? 
A. Maybe. 
Q. Okay. If, again, if it wasn't you, who 
else could have set the parameters; that is, who 
else can access the file? 
Page 42 
A. Let's say I am the lead on a project: I 
believe that is what it was called the, I believe that 
was the titie given to the person that initiates the 
project, ifl want to then invite one or two or three or 
100 other attorneys to that project to help work on 
various aspects, I could do that. 
And ifl didn't choose to add 
somebody, and another attorney said make me a lead 
so that I can add somebody, that's another way that 
that other lead could have invited somebody else to 
the project. 
And when you open up the interphase 
of Qtask, you're immediately shown a portfolio of or 
a photograph of the people that are invited to the 
specific project and those people can access it. 
Q. So, if it was, as an example, if it was, 
if you were the lead person and you...

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Page 45 
1 
the case. You describe the facts. You describe the 
2 
witnesses, things of that nature, or are you 
3 
actually, can you -- well, first of all can you do 
4 
that? 
5 
A. Can you describe the case and describe the 
6 
facts? Yes, you can. 
7 
Q. And is that, when you say project centric, 
8 
is that what you're doing very much like the 
9 
electronic, much like the Fortis program? 
10 
A. It's not very much like the Fortis program in 
11 
my mind, but it's, it is what you are doing, you're 
12 
inputting information about a specific project. 
13 
Q. Can you put in the facts about a case, 
14 
again just generically, can you put in facts about a 
15 
particular case and then ask someone in your 
16 
invitees to comment on what they think, might think 
17 
the value of the case is or is not and give 
18 
suggestions as to discovery and things of that 
19 
nature? Is that all true? 
20 
A. Yes. 
21 
Q. And with regard to -- and once those 
22 
invitees show up and they're photographed, then each 
23 
of those individuals can have access to the file and 
24 
add their thoughts or opinions --
25 
A. Repeat it. 
Page 46 
1 
Q. -- or suggestions. Let me strike that. 
2 
With regard to the Qtask, once, 
') 
once -- assuming that you're the lead, you create 
_J 
4 
the project and then you, you say, okay, now it's in 
5 
a form that I want to get some invitees involved. 
6 
Do you then send that project; that is, you then on 
7 
Qtask you list the invitees and those people would 
8 
be, get some sort of cue that they had been invited 
9 
to the project up to the Qtask system? 
10 
A. I don't remember the exact process for 
11 
inviting, but there is a way to invite. And to the best 
12 
of my recollection, they do receive a notification that 
13 
they have been invited so that they can accept. 
14 
Q. Okay. Can, can someone who has not been 
15 
invited also access the system? 
16 
A. No. 
17 
Q. Okay. And how do you know that? 
18 
A. That'...

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Page 49 
A. No. 
Q. And therefore as you sit here today, you 
don't know whether someone else, whether it was 
another attorney, whether it was an investigator or 
a staff person ever put the Jane Doe versus Epstein 
case on Qtask? 
A. Or whether it was you, right. 
Q. Right. As to L.M., did you ever put 
L.M.'s case or direct -- well, let me strike that. 
Did you ever create a project for L.M. on Qtask? 
A. No. 
Q. Did you ever direct that someone else 
create a project in Qtask for the L.M. case, L.M. 
versus Jeffrey Epstein case? 
A No. 
Q. Do you have any knowledge as to whether --
let me strike that. Did you ever go on Qtask or 
have you been able to determine whether anyone else 
within the RRA firm put the L.M. versus Jeffrey 
Epstein case or any aspects of it on Qtask? Have 
you looked or do you know? 
A. I don't know. 
Q. Has anyone told you that the L.M. case 
against Jeffrey Epstein was on Qtask? 
A. No. 
Page 50 
Q. Okay. And so it's your testimony as far 
as you know the L.M. versus Jeffrey Epstein case was 
not ever on the Qtask system; is that correct? 
A. To the best ofmy recollection today. 
Q. When I describe both the Jane Doe versus 
Jeffrey Epstein case and the L.M. versus Jeffrey 
Epstein case being on Qtask, I don't necessarily 
mean just the pleadings. I mean any aspect ofit, 
not necessarily the pleadings or the fact that the 
case was there but the factual circumstances 
surrounding either case. 
A. I am not going to get into what my 
work-product privilege, I am not going to allow you to 
pierce that privilege. I am not going to tell you what, 
regarding those cases, was or was not on Qtask. 
Q. Well, let me ask a specific question. So 
if you want to claim some sort of privilege so the 
record is cl ear. 
A. Sure. 
Q. With regard to, and le...

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Page 53 
Q. Okay. So we don't -- you gave a broader 
response to a question or that is you rephrased the 
question. So, let me ask it in a broader sense. 
Was any information about the, your 
three clients put into the Qtask, about your three 
clients, Jane Doe, E.W., and L.M. versus Jeffrey 
Epstein, or against Jeffrey Epstein, was any 
information ever put into the Qtask system? I don't 
want to know the information, just whether you put 
information into the Qtask system. 
A. Yes. 
Q. Did you do it yourself or did you do it in 
conjunction with someone else? 
A. Expiain to me what you mean by did I do it in 
conjunction with somebody else. 
Q. Well, is, you may have typed in the 
information yourself. 
A. I strike one key; somebody else strikes 
another? 
Q. No, you may have input all the information 
you want, whatever information you want to put into 
Qtask, you may have made the decision to do that. 
All right. My question is someone else, a 
secretary, or a paralegal may have helped you, an 
investigator may have put some information in, at 
Page 54 
1 
least at your direction regarding these three 
2 
individuals' claims against Mr. Epstein? 
3 
A. Infonnation that I put into Qtask is 
4 
information that was inputted into Qtask by me. 
5 
Q. Did you ever direct anyone else to put any 
6 
additional information in with regard to those three 
7 
claims against Mr. Epstein? 
8 
A. I don't believe so. 
9 
Q. And what type of information did you put 
10 
into Qtask regarding the claims against Mr. Epstein? 
11 
MR. SCAROLA: Read that back, please. 
12 
(The requested portion of the record was 
13 
read by the reporter.) 
14 
MR. SCAROLA: We're going to object and 
15 
that I will instruct you not to answer on the 
16 
basis of both attorney-client and work-product 
1 7 
privileges. 
18 
MR. CRITTON: I assume ifMr. Scarola 
19 
asserts an objection, you...

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Page 57 
Qtask file relating to claims again Mr. Epstein? 
A. To the best ofmy knowledge, no. I take that 
back. I don't know who created the project, but I am 
only aware of the project that I participated in related 
to Mr. Epstein and his molestation of many children, 
period. 
Q. And what did you call the project; that is 
how it was identified on the Qtask system? 
A. I don't remember. 
Q. Do you recall when it was created? 
A. No. 
Q. Do you recall whether it was created 
within a month of your coming to RRA? 
A. I don't remember. 
Q. Do you recall whether it was, I think you 
said approximately the beginning of April of'09 you 
came to RRA, correct? 
A. Correct. 
Q. All right. And is it, just so the record 
is clear it's, your testimony is you don't recall 
whether you created the project in April, May, June, 
July, August, September or October relating to the 
claims against Mr. Epstein? 
A. I don't remember ifl created the project, 
period. 
Page 58 
Q. Separate and apart from whether -- well, 
iet me strike that. If you didn't create the 
project, who would have? 
A. I don't know. 
Q. Well, do you remember -- let me strike 
that. Do you know whether with regard to the 
project, and for purposes of at least this question, 
let me just call it the Epstein project, are you 
okay with that designation? 
A. Yes. 
Q. Okay. With regard to the Epstein project 
that was created in the Qtask system, ifl am 
understanding correctly, you don't remember whether 
you created it or someone else did, correct? 
A Correct. 
Q. Who would have had access to your files 
that could have created the Epstein project other 
than you? 
A That question makes no sense. 
Q. Okay. 
MR. SCAROLA: And it also assumes facts 
not in evidence and does not have a prior 
proper predicate. 
THE ...

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Page 61 
BY MR. CRITTON: 
Q. With regard to the scanned system; that 
is, to store the electronic records, was that put in 
through the, through the Fortis program? 
A. Yes, I believe so. 
Q. And did you as well -- let me strike that. 
Prior to coming to RRA had you ever worked in a 
paperless file or in a paperless office? 
A. I don't understand. 
Q. Had you ever been working in an office 
prior to coming to RRA that was designed to be 
paperless? 
A. No, but as I mentioned earlier, I have worked 
with case management software that stores electronic 
versions of files, so therefore there is a paperless 
system. 
Q. Did you as well when you came to RRA with 
regard to the Epstein related matters or the content 
of your Epstein investigation and files, had you 
placed any of that on a prior, a previous paperless 
system or did you have the paper itself or both? 
A. Both. 
Q. And during the time that you operated at 
RRA, did you operate both with a, you individually 
with regard to the Epstein files, did you operate 
Page 62 
both in a paper and a paperless manner? 
A. No. 
Q. Did you operate oniy in a -- weii, in what 
way did you operate? 
A. Paperless. 
Q. Okay. So if, if as an example I sent you 
correspondence or answers to interrogatories or a 
response to a pleading and it came in the mail, 
would that document be scanned and then you would 
toss away the paper? 
A. I don't know. 
Q. So, you may well have had paper in 
addition to -- well, let me strike that. Do you 
even !mow whether the document was scanned? 
A. If you're telling me you sent correspondence 
in the mail and I would later see that correspondence in 
my virtual mailbox, I make the logical assumption that 
it was scanned. I never observed anything being 
scanned. 
Q. Okay. And do you, if somethin...

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Page 65 
before joining them? 
A. People that I would consider to be my friend, 
yes. 
Q. Who. 
A. Russell Adler. 
Q. And how did you know Mr. Adler? 
A. We worked out at the same gym for about, 
approximately four or five years. 
Q. What were you doing, prior to your 
association with RRA, what was your employment? 
A. What? 
Q. 'Nere you working as a solo practitioner? 
Were you working with another firm prior to coming 
to RRA in April of09? 
A. Solo practitioner. 
Q. How long had you been a solo practitioner? 
A. Approximately two years. 
Q. During the time you were a solo 
practitioner, did you ever have any associates 
working for you, solo imply that you're the only 
one, is that true, or did you have associates that 
actually worked for you? 
A. Various times I had clerks, law school clerks, 
but that was it. 
Q. But no other lawyers? 
Page 66 
A. Right. 
Q. Did you ever have an investigator work for 
you? 
A. Yes. 
Q. Okay. Do you !mow an individual by the 
name ofFisten, F-i-s-t-e-n? 
A. I know an individual whose last name is 
Fisten. 
Q. All right. What's his first name, the one 
you !mow? 
A. Mike. 
Q. Michael Fisten? 
A. Yes. 
Q. Mike Fisten ever do any work for you when 
you worked as a solo practitioner at any time prior 
to you joining RRA? 
A. No. 
Q. Did you know of Michael Fisten or Mike 
Fisten prior to joining RRA? 
A. No. 
Q. With regard to the investigators that you 
used prior to joining RRA, did you use, or were any 
of those individuals ever employed by RRA during the 
time you were there? 
A. No. 
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Page 67 
Q. How did it, how did it happen that you 
came to be e...

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Page 69 
1 
Q. How many times did you meet with Scott 
2 
Rothstein prior to accepting a position with RRA? 
3 
A. Once. 
4 
Q. Where did the meeting take place? 
5 
A. The restaurant BOVA. 
6 
Q. Did you understand Mr. Rothstein had an 
7 
interest in BOVA? 
8 
A. At the time? 
9 
Q. Yes, sir. 
10 
A. No. 
11 
Q. Did you learn that during the time that 
12 
you worked for RR.A 
13 
A. Yes. 
14 
Q. Okay. Who was present other than 
15 
Mr. Rothstein when you met with him at BOVA? 
16 
A. Nobody. 
17 
Q. Who had set up the meeting? 
18 
A. Russell. 
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Q. And had anything been discussed at least 
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as of that time with regard to what your opportunity 
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was or in te1ms of compensation? 
22 
A. Specifically, no. 
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Q. How long did the meeting with 
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Mr. Rothstein last? 
25 
A. Ten minutes. 
Page 70 
1 
Q. Did you have lunch with him or you just 
2 
sat down and talked with him at the table at the 
3 
restaurant? 
4 
A. Sat down and talked to him. 
5 
Q. Had you submitted any kind of a resume to 
6 
Mr. Adler as to what your experience was? 
7 
A. No. 
8 
Q. So, you, at that time you are a solo 
9 
practitioner. Mr. Adler calls you and says, or you 
10 
express an interest. Mr. Adler says we have an 
11 
interest in talking to you, and you set up a meeting 
12 
with Mr. Rothstein. Is that pretty much it? 
13 
A. You're now making things up that is totally 
14 
inaccurate, and doesn't reflect what I have been telling 
15 
you at all. I didn't express any interests. I wasn't 
16 
looking for a job. I wasn't seeking him out. In fact, 
17 
that is the exact opposite of what I have just gone 
18 
through explaining to you about conversations at the gym 
19 
that ultimately lead to him convincing me this is a good 
20 
place to come into and me agreeing to this meeting with 
21 
Scott Rothstein. 
22 
Q. Okay. When you went to meet with Mr! 
23 
Rothstein did you have any interest or was this just 
24 
a throw-away meeting. Maybe I misunderstood...

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Page 73 
Page 75 
1 
expect. 
1 
A. Possibly. 
2 
Q. What did you tell him that you expected? 
2 
Q. Do you recall what he said? 
3 
MR. SCAROLA: Objection, economic privacy. 
3 
A. What do you mean by benefits? 
4 
BY MR. CRITTON: 
4 
Q. I mean would you get health insurance and 
5 
Q. All I am interested now, not necessarily 
5 
those types of things as well? 
6 
what you were earning but what you told him, i.e., 
6 
A. I believe that was discussed. I'm not sure. 
7 
Mr. Rothstein that you wanted to get or expected to 
7 
I can't tell you I got them but I don't know. 
8 
earn if you considered a job at RRA 
8 
Q. Did you discuss any of your cases that you 
I! 
9 
MR. SCAROLA: Objection. Economic 
9 
had with him? 
I••. 
10 
privacy, instruct you not to answer. It's 
10 
A. No. 
11 
neither relevant nor material nor reasonably 
11 
Q. Okay. Did you sign an employment 
,,. 
12 
likely to lead to relevant material infomrntion 
12 
agreement at any time with RRA? 
13 
and invades the economic privacy of the 
13 
A. No. 
14 
witness. 
14 
Q. After the -- let me go back. Did you say 
15 
MR. CRITTON: Is that fmm? 
15 
you did or did not discuss any of your current cases 
16 
BY MR. CRITTON: 
16 
with him? 
: 
17 
Q. Mr. Edwards, you gave him a number, is 
17 
A. Did not. 
h 
18 
that correct? Him meaning Mr. Rothstein. 
18 
Q. Okay. Were you aware, had you discussed 
19 
A. I believe so. 
19 
your cases -- I think you said you had discussed 
E 
20 
Q. And was the number that you gave him more 
20 
your cases or Russell Adler had an idea of the type , 
.. 
21 
than you had earned for the year 2008 or less? 
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of cases you had? 
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MR. SCAROLA: Same objection. 
22 
A. Over the years Russ and I are friends; we 
ii 
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MR. CRITTON: Or the same? 
23 
talked about cases. 
24 
MR. SCAROLA: Same objection, same 
24 
Q. Did you say you had discussed the Epstein 
F· 
25 
instruction. 
25 
cases with him? Him, meaning Adler. 
11 
Page 74 
Page 76 
1: 
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B...

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Page 77 
Q. And how long did you think about it? 
A. I don't remember. 
Q. Did you, and who did you contact? Well, 
let me strike that. At some point did you make a 
decision --
A. Yes. 
Q. -- to go work for RRA, correct? 
A. Correct. 
Q. Did Mr. Rothstein at the initial meeting 
tell you whether you would be a partner? 
A. No. 
Q. Did he describe that you would be at least 
to the public at large you would be described as a 
partner? 
A. No. 
Q. Did you understand who the partners 
were -- well, let me trick that. Is RRA, was RRA a 
PA? 
A. I don't !mow. 
Q. Did you ever find out during, up through 
today's date do you lmow whether RRA was a PA or an 
LLC or an LLP? 
A. No. 
Q. Did you ever go online to look at who the 
officers and directors were or had members if it was 
Page 78 
anLLP? 
A. During the initial, initial meeting with Scott 
Rothstein, he toid me there are oniy two equity panners 
of this law finn, and it will always be that way; myself 
and Stuart Rosenfeldt, period. 
Q. And did he say that they each own 
50 percent, or did he say, they were just partners? 
A. Did not say. 
Q. Prior to your -- let me strike that. I 
think as you said at some point you made a decision 
to join RRA? 
A. Right. 
Q. And who did you convey that to? 
A. Russell. 
Q. And what happened thereafter? That is, 
how did you go from then being a solo practitioner 
into RRA? How did you integrate yourself? What was 
the timing and what did you do? 
A. At some point in time I was no longer working 
in my Hollywood office and was working at RRA on Las 
Olas. So, physically I showed up to work at a different 
location. 
Q. And did someone -- well, let me strike 
that. From the time that you announced that you 
would go, you told Mr. Adler up until the time you 
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Page 81 
of, as a potential recipient of any contingency fee 
or is he paid on an hourly basis, either when you 
were a sole practitioner during the RRA stages or at 
the current time? 
A. Contingency. 
Q. Does he get part, at least as it was set 
up as a sole practitioner was Mr. Cassell also on 
the contract with each of the three individuals? 
A. I don't believe so. 
Q. You don't-- he is not on any of the 
contracts, Mr. Cassell? 
,1i.. There is a contract that he is on but your 
question is when the cases were first signed up, was he 
on the initial contract. And I believe the answer to 
that is no. 
Q. Prior to the time or during the time that 
you were in sole practice before you went to RRA was 
Mr. Cassell ever on any of the contracts with the 
three Plaintiffs? 
A. Yes. 
Q. Okay. When you moved to RRA, was a new 
fee agreement signed with each of the individuals, 
each of the three Plaintiffs? 
A. No. 
Q. Was there some form of an assignment? 
Page 82 
A. Well, not to my lmowledge. I don't want to 
say no, but I don't know of any fee agreement that was 
signed with the ciient. 
Q. As a -- from the time that the original --
let me strike that. Ifl understood you correctly 
is as an example E.W. was your first case? 
A First client. 
Q. First client, right. Mr. Howell would 
have referred the case, so he would have shown up as 
a referring order. And at some point Mr. Cassell 
also came on the contractor or a contract; is that 
correct? 
A. A contract, yes. 
Q. So, there was at least two contracts with 
regard to E.W.? 
A. That I remember. 
Q. And with regard to E.W., Jane Doe, and 
L.M., you don't recall any new contract being signed 
between those individuals and RRA; is that con-ect? 
A. That is correct. 
Q. And with regard to the, whatever the 
contingency...

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Page 85 
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anyone else other than, on any of these three cases; 
2 
that is, potentially RRA, potentially your new fom, 
3 
Mr. Cassell, Mr. Howell and the Plaintiff, does 
4 
anyone else stand to benefit from a recovery in any 
5 
of those cases? 
6 
A. No. 
7 
Q. Has anyone, has any interest in any of the 
8 
three cases been assigned to a, to a third party 
9 
other than a law firm or a lawyer or a law firm; 
10 
that is, to an outside service? 
11 
A. No. 
12 
("\ 
Okay. Have any of the potential 
'<· 
13 
settlements -- I'm sorry. Have any of the potential 
14 
proceeds from any settlement or verdict been 
15 
assigned or sold to anyone to your knowledge? 
16 
A. No. 
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Q. Has E.W., Jane Doe, or L.M. sold, 
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assigned, exchanged for consideration, money, or 
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promises of money, any portion of their potential 
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sett! ements? 
21 
A. No. 
22 
Q. Or recoveries? 
23 
A. No. 
24 
Q. IfI understood you conectly, 
25 
Mr. Edwards --
Page 86 
1 
MR. SCAROLA: Let me interrupt for just a 
2 
moment. I don't know whether the circumstance 
3 
applies but I want to be sure, does the scope 
4 
of your question include a letter of protection 
5 
to a health care provider? 
6 
MR. CRITTON: No. 
7 
MR. SCAROLA: I don't know whether that 
8 
has occuned in any of these cases, but I 
9 
assume that's not what you're looking for? 
10 
MR. CRITTON: I wasn't, but no, I'm 
11 
looking for -- I think it would not be applied 
12 
to any of the tln·ee. 
13 
You understand I wasn't talking about 
14 
health care providers. I am talking about 
15 
some independent person or entity that may 
16 
have purchased some interest or have been 
17 
assigned some interest in any of those 
18 
three lawsuits. Do you understand that? 
19 
THE WITNESS: I think I understood your 
20 
question, and my answer was responsive and I 
21 
was not thinking about letters of protection at 
22 
the time that I gave my answer. 
23 
BY MR. CRITTON: 
24 
Q. With -- ifI understood yo...

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Page 89 
A. I don't understand. 
Q. Why did E.W. come, why did she hire you in 
the first place? What was the purpose? 
A. This is going to get into attorney-client 
privileged information as to why she hired me which 
would incorporate the things that she told me that 
related to my representation, therefore, I am invoking 
the privilege and not answering. 
Q. With regard to E.W. you filed a case --
well, let me ask you this: Do you know how E.W came 
to contact Mr. Howell? Did he ever relate that to 
you? 
MR. SCAROLA: If it's in information that 
you obtained from your client, I instruct you 
not to answer. If it's information that you 
obtained from Mr. Howell, I also instruct you 
not to answer. Both instructions are on the 
basis of attorney-client and work-product 
privileges. 
Tiffi WITNESS: Attorney-client and 
work-product privilege. 
BY MR. CRITTON: 
Q. Did you, did Mr. Howell -- and I don't 
want to know the information, at least right now --
did Mr. Howell give you any information about E.W. 
Page 90 
prior to her coming to see you or your seeing her? 
A. Yes. 
Q. Okay. And did E.W. for the first, on the 
first occasion come to your office or did you talk 
to her by phone or did you go to her place? 
A First time I talked to E.W? 
Q. Yes, sir. 
A. Was over the telephone. 
Q. All right. And how long, how much time 
transpired before E.W. retained your services; that 
is, how many conversations did you have with her 
before she ultimately retained your services? 
A. One conversation over the telephone and then 
the next meeting was in person at my office. That 
meeting culminated with her retaining my services. 
Q. And the initial conversation you had with 
her, what did she relate to you? 
A. That's attorney-client privilege infonnation 
that 1 am not goi...

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Page 93 
he has spent on each of the cases? 
A. I do not know. 
Q. Did you -- has he prepared any pleadings 
or documents associated with the cases? 
MR. SCAROLA: You can answer that 
question. 
THE WITNESS: Define prepared. 
BY MR. SCAROLA: 
Q. All right. Prepared, prepared, start, 
first of all, started from scratch; that is, has he 
prepared any of the pleadings or papers that have 
been filed in any of the three cases starting from 
scratch that he would have been -- not because you 
said this but he started with the complaint and you 
may have changed it, but he started the preparation 
of the document? 
A. Your question is has he started the 
preparation of a docwnent now, right? 
Q. Any document, any paper that's been filed 
in the cases or I would say passed back and forth 
between lawyers in any of the three cases? 
A Has he had edited revised, I mean what --
Q. Right now I am just asking did he start 
the document such as a complaint or a similar type 
document? 
Page 94 
A. That was filed in the case? 
Q. Correct. 
A. No. 
Q. Okay. Has he worked on documents, whether 
it's editing, adding, deleting from pleadings that 
you, pleadings or papers that you have prepared? 
A. Yes. Bob, can you hand me that water? 
Q. Yes. 
A. Thanks. Appreciate it. 
Q. You're welcome. Has he continued, did he 
continued to be involved not only when you were a 
solo practitioner but during the time that you were 
with RRA with regard to editing or working on the 
cases? 
A. To an extent. 
Q. Okay. Do you, how often on the cases have 
you consulted with Mr. Howell? By that I mean 
before a decision is made as to how you want to do 
discovery or proceed with the filing of the pleading 
or how you're going to respond, does Mr. Howell, do 
you consult with Mr. Howell during the time...

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Page 97 
Q. Did she ever come and meet you at your 
office? 
A. From the beginning of time until today? 
Q. No. Back at the time prior to retaining 
your services. 
A. I don't remember. 
Q. Did you ever meet her at her residence or 
place of work? Let me ask you this: Have you ever 
met her at her place of business or a place of 
business? 
A. No. 
Q. Have you ever met her at her home, whether 
it's an apartment or home, whatever? 
A. Now, you're asking from the beginning of time 
until now? 
Q. No. Up until the time she hired you, did 
you ever meet with her? 
A. Okay. 
Q. At her home or apartment. 
A. To the best of my recollection, no. 
Q. Did you -- did she sign, to the best of 
your recollection did she sign a fee agreement? 
Well, let me strike that. There is a, there is a 
written fee agreement between L.M. and you and 
then --
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Page 99 
information. 
BY MR. CRITTON: 
Q. When you met Ms. L.M. at the park was 
anyone else present? 
A. Yes. 
Q. Who? 
A. I don't know. 
Q. Male or female? 
A. I presume both. It's a park. 
Q. No, no, no. In the meeting that you had 
with her -- my guess is there were probably a lot of 
people in the park? 
A. Correct. 
Q. In the meeting that you had with Ms.L.M. 
was anyone else present? 
A. For the conversations between myself and 
Ms. L.M., no. 
Q. When you first met with E.W. was anyone 
present for the conversations between that you and 
Ms.E.W.? 
A. No. 
Q. I think you told me at the time that the 
complaint was filed or at the time that the Jane Doe 
1 and 2 sued the United States Government which was 
in early July, it was July 8th of'08, you don't 
I 
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Page 98 
A. Correct. 
Q. -- ...

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Page 101 
interested in what you learned from E.W. All right. 
Did you learn from either any correspondence or a 
telephone call with any third party that whether 
again prior to the -- let me start again. 
Prior to the filing of the lawsuit 
against Jane Doe 1 and Jane Doe 2 against the United 
States Government, did you learn from any source, 
maybe a document, maybe a telephone call or a 
conversation that you had with a third party 
separate from your client, that E.W. was a victim or 
was deemed to be a victim by the United States 
Government or the United States Attorney's Office? 
MR. SCAROLA: Same objection and 
instruction. 
BY MR. CRITTON: 
Q. Same question with regard to L.M. Miller. 
MR. SCAROLA: Same objection and 
instruction. 
BY MR. CRITTON: 
Q. And same question with regard to Jane Doe. 
MR. SCAROLA: Same objection and 
instruction. 
BY MR. CRITTON: 
Q. Prior to your filing the lawsuit with 
United States Government, did you ever any 
Page 102 
conversations with the United States Attorney's 
Office --
MR. SCAROLA: I assume --
BY MR. CRITTON: 
Q. -- regarding, regarding, regarding the 
subject of the lawsuit or Jeffrey Epstein? 
MR. SCAROLA: Same objection and 
instruction. 
MR. CRITTON: These are third parties; 
where is the work product? 
MR. SCAROLA: Work product has to do with 
Emything that was done in connection with the 
representation of these three clients. Ifhe 
had such conversations independent of his 
representation of those clients, then he can 
respond to the question. 
BY MR. CRITTON: 
Q. Well, let me ask you a broader question. 
After you filed the lawsuit against the United 
States of America, were you aware that Marie 
Villafana or the United States Attorney's Office 
represented the USA, cOITect? 
A. Yes. 
Q. All right. Did you ev...

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Page 105 
lv1r. Epstein in a lawsuit that has 
absolutely no foundation whatsoever, and 
was filed for purposes other than a 
legitimate claim against Mr. Edwards based 
upon any good faith belief that he engaged 
in any fonn of improper or tortious 
conduct and --
MR. CRITTON: Done? 
MR. SCAROLA: -- those inquires are not 
reasonably calculated to lead to the discovery 
of admissible and relevant evidence. So, for 
all of those reasons, we object. 
MR. CRITTON: And let me just put on the 
record very briefly so at least at this point 
in time this is all infonnation that clearly is 
relevant to the complaint as it's alleged. 
I have received a, my client and I 
have both received a letter from you 
asserting a motion for fees and costs and 
ce1iain sanctions under 57 .105, by not 
allowing us to ask what are clearly, I 
believe, relevant material, basic 
discoverable infonnation are preventing 
our ability to get all of the facts here 
such that we can make a reasonable 
Page 106 
decision as to whether or not the 57 .105 
motion and letter which you sent to me was 
filed in good faith or has any basis in 
it. We're unable then to, we'll be in 
large part unable to evaluate our 
position. 
MR. SCAROLA: And our position is that 
those are decisions that should well have been 
made, could have been made, and should have 
been made before you ever filed the claim. 
MR. CRITTON: All right. Are we done? 
MR. SCAROLA: Yes. 
MR. CRITTON: All right. 
MR. SCAROLA: At least for now. 
MR. CRITTON: I'm shocked. 
BY MR. CRITTON: 
Q. With regard to, with regard to the claim 
Jane Doe 1 and Jane Doe 2 that is currently 
pending -- or let me strike that. Jane Doe 2 --
Jane Doe 1 and Jane Doe 2 against the U.S.A. that 
was filed in July of'08, that case is still 
pending. 
A. Okay. ...

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Page 109 
A. I don't know that that's a correct statement. 
Q. You don't know one way or the other? 
A. The law firm was constantly expanding and 
constantly under construction. For the most part in the 
beginning the cases were kept in a, in a filing cabinet 
in my office and later were kept in a filing cabinet, I 
believe, in a locked storage location in another area of 
the office. 
Q. And did any attorney have access to that 
storage area or do you know? 
A. I believe any attorney could have had access. 
Q . .AJ1d if the attorney could have access, you 
wouldn't necessarily know about it, true? 
A. Correct. 
Q. In the trustee's filing that they made in 
response to my motion to preserve evidence, they 
indicated that 13 boxes relating to Jeffrey Epstein 
had been removed by the FBI or the government when 
they came into the RRA offices. Do you remember 
seeing that pleading? 
A. No. 
Q. Okay. Are you, were there, in fact, 13 
boxes of material or at least 13 banker's boxes of 
material that related to matters directed to, 
whether, whatever the content related to Mr. Epstein 
Page 110 
that you were aware of; that is, hard copies? 
A. I don't know. 
Q. Okay. Couid have been more, couid have 
been less; you just don't know? 
A. Correct. 
Q. Ifl understood your testimony, 
Mr. Rothstein, Mr. Rosenfeldt, any other attorney or 
investigator could have accessed those files 
depending or where they were within the firm, true? 
A. I am not sure exactly who could have accessed 
it. You asked me if the attorneys could and the 
attorneys had swipe cards for various locked areas. 
Each attorney I believe had access to any area where 
those files were located. I believe so. 
Q. Okay. Well, during the time you were 
there did an individual by the name ofKen Jenne 
work there?...

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Page 113 
A. When I was there. 
Q. And do you, can you remember the date, any 
specific date that you spoke with him? 
A. No. 
Q. Do you remember any specific month that 
you would have had one of the -- well, what did you 
say something less than five conversations? I don't 
want to misquote you. 
A. I said less than three conversations. 
Q. All right. So, something less then three 
conversations you had with Mr. Rothstein regarding 
Epstein cases, either legal issue or a comment, some 
comment about the case to you, correct? 
A. Yes. 
Q. All right. The first time that he ever 
spoke to you, did he call you or did you call him? 
A. I, I never called Scott Rothstein about 
anything. Oh, take that back. About anything related 
to Jeffrey Epstein. 
Q. The first conversation that you can recall 
where either a legal issue or a comment was made 
about Jeffrey Epstein by Mr. Rothstein to you, he 
obviously initiated the call? 
A. It wasn't a call. 
Q. What was it? 
Page 114 
A. A comment in passing. And I believe I was 
sitting at a table in BOVA when he walked over to my 
tabie and commented about Jeffrey Epstein. 
Q. Okay. Who were you there with at the 
time? 
A I don't remember. 
Q. Were you with some friends? Were you with 
other lawyers? 
A All right. I am jogging my memory. I, I have 
no idea. 
Q. What did he say? 
MR. SCAROLA: To the extent that you can 
answer that question without disclosing any 
mental impressions with regard to the lawsuit 
or any attorney-client privileged 
communications, you can answer. 
To the extent that it might invade 
either the work-product or attorney-client 
privilege, you should not respond. 
Tiffi WITNESS: Can I talk to you? 
MR. SCAROLA: Sure. 
(A brief recess was held.) 
MR. SCAROLA: Are we on? 
THE VIDEOGRAPHER: Yeah. 
MR. SCAR...

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Page 117 
work-product privileged inforn1ation that I am not going 
to divulge. 
Q. Okay. I am not -- I need to still ask the 
last question though. I thought you said earlier is 
that you never had any substantive conversations, 
maybe I misunderstood, with Mr. Rothstein about the 
Epstein cases. Did I misunderstand you? 
A. I don't believe that that was -- I had 
conversations at a point about legal issues related to 
Jeffrey Epstein and that's, that's it. 
Q. Was that a one conversation? Was that a 
number of conversations that you had where legal 
issues were discussed as to, separate and apart from 
the two comments he made about the case to you which 
you were, you waived any privilege, work-product or 
attorney-client privilege? 
A. I, I can't tell you. If you and I this 
morning had a conversation and then we took a bathroom 
break, and we had the same continuing conversation, I 
don't know if that's one conversation or two. But I can 
tell you the, the only time I remember Scott Rothstein 
participating in any way, shape, or form in any 
conversation related to anything substantive dealing 
with, and not dealing with any specific client but a 
legal issue, was on a particular one-day event, one-day 
Page 118 
conversation, if you want to call it. 
Q. And that's at what time? At that time 
legai issues were discussed? 
MR. SCAROLA: Legal issue was the 
testimony, a particular legal issue. 
MR. CRITTON: Correct. A legal issue. 
BY MR. CRITTON: 
Q. When did that occur; that is, this one-day 
discussion or a day discussion occur regarding a 
specific legal issue? 
A. I don't know. 
Q. Was he present, he Mr. Rothstein and you 
present at the same time? 
A. Yes. 
Q. Okay. Was anyone else there with you? 
A. Yes. 
Q. Who else was present? 
A. Russ Adler, someone wa...

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Page 121 
you ever worked for a large finn? 
A. No. You just named all the places I have 
worked. 
Q. All right. Is this the first time then 
that you had been to Mr. Rothstein's office that he 
called you up there? 
A. No. 
Q. You had been in his office before? 
A. Onetime. 
Q. And what was that occasion? 
A. I was having back surgery, and I went there to 
tell him I am having back surgery. As you !mow I had 
back surgery, and I was telling him I don't know how 
long I'm going to be off because, you !mow, the recovery 
time is different for everybody. 
Q. Is that the only thing you talked about, 
the back surgery? 
A. That's the only thing we talked about. 
Q. Did the meeting you had with Scott, when 
you went up, when you were called up to his office 
that day, did that occur before your back surgery 
episode or meeting or after? 
A. After. 
Q. So, you would, you had back surgery. I 
think you were out two or three weeks and then you 
Page 122 
returned to the office, and then that meeting would 
have occurred? 
A. Yeah, that's correct. 
Q. When you, in order to get into the office 
just as you have described it as a bunker, how many, 
did you have to go through any security people to 
get into --
MR. SCAROLA: No, I think the description 
was a compound. 
MR. CRITTON: I will use compound. Are 
you more comfortable with compound or a bunker? 
I have seen it described both ways. I haven't 
seen the video, but I have seen it described 
both ways. 
THE WITNESS: I will describe it for you. 
Well, first I will answer your question. 
Security people, I don't know if there was ever 
a time where one would have to go through 
security people to get to his office. But on 
the day or two days that I have been in his 
office, I did not encounter any security 
personnel. 
BY MR...

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Page 125 
BY MR. CRJTTON: 
Q. -- not content. Was Mr. Adler someone 
that you had discussed these Epstein cases with 
prior to that meeting? 
A. Yes. 
Q. Was he familiar with the cases, generally? 
A. He attended Jeffrey Epstein's deposition, so 
he heard the questions asked and heard the Fifth 
Amendment invocation and so the adverse inferences and 
was therefore informed --
MR. CRJTTON: Move to strike as 
nonresponsive. 
BY MR. CRJTTON: 
Q. My question is was he familiar generally 
with the subject matter of the litigation against 
Mr. Epstein? 
A. In that he read the newspaper articles about 
molesting a bunch of children, yes, he was familiar with 
the subject matter. 
Q. And he read -- did you provide him with 
copies of the pleadings in these cases when they 
came to RRA? 
A. No. 
Q. What was the topic? What was the legal 
issue that you discussed -- well, let me strike 
Page 126 
that. Who raised the legal issue, did 
Mr. Adler raise it or did IVlr. Rothstein?.-
A. I don't know. 
Q. Okay. Well, how did the, who started the, 
if you were there I think you said five minutes, who 
did the talking? 
A. When I came in the, in the office, it was in 
the middle ofa discussion. 
Q. Was a question posed to you? 
A. The question was on the table at least from my 
perspective coming into the room and was then directed 
at me, what's the answer to this particular legal issue. 
Q. And what was the legal issue? 
MR. SCAROLA: Let's talk for just a 
second. 
THE VIDEOGRAPHER: Are we going off the 
record? 
MR. SCAROLA: Actually, we don't even have 
to go off the record. Stay right here. 
If this was an issue that was 
identified during the course of the legal 
proceedings to opposing counsel, then I am 
going to allow you to you identify the 
issue without getting into any of...

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Page 129 
1 
Q. Where did you go -- did you go to an 
2 
office to meet him? 
3 
A. Well, I went to a particular area, a locked 
4 
area that I could get in with my swipe card and there 
5 
was a, a room like this. Is this an office? 
6 
Q. Sure. 
7 
A. Okay. Then yes. 
8 
Q. If you wanted to contact Mr. Fisten, did 
9 
you, did you have a number; that is, an inside 
10 
number? 
11 
A. I don't know. 
12 
n 
Did l\1r. Fisten do \Vork on the Epstein 
'<· 
13 
related cases? 
14 
A. Yes. 
15 
Q. Okay. What kind of work did he do? 
16 
A. Investigator. 
17 
Q. Meaning what? 
18 
A. Meaning investigative work. 
19 
Q. Okay. Has Mr. Fisten continued to do --
20 
let me strike that. When RRA imploded in early or 
21 
in late '09, in October of'09, did Mr. Fisten come 
22 
to work for your firm? 
23 
A. Yes. 
24 
Q. Farmer, Jaffe. Is he an employee of your 
25 
firm? 
Page 130 
1 
A. Correct. 
2 
Q. How about Mr. Jenne, is he currently 
3 
employed by your firm? 
4 
A. No. 
5 
Q. Do Mr. Jenne and Mr. Fisten, to your 
6 
knowledge, have any association at the current time? 
7 
A. No. 
8 
Q. Have, has Mr. Fisten continued to do work 
9 
on behalf of your firm; that is, investigative work 
10 
relating to Mr. Epstein? 
11 
A. What do you mean has he continued to? 
12 
Q. Has he continued, has Mr. Fisten done, 
13 
continued to do investigative work since he had been 
14 
with Farmer Jaffe relating to the Epstein cases? 
15 
A. On, on many cases and Jeffrey Epstein's case 
16 
being one of them, yes, he's done some work. 
17 
Q. Has he, has he as well -- well, let me 
18 
strike that. Has Ken Jenne done any work for any 
19 
outside agency, investigative agency or entity, done 
20 
investigation work relating to Jeffrey Epstein here 
21 
in the State of Florida? 
22 
A. I don't, I don't know. I don't talk to him. 
23 
Q. Have you had any contact -- well, let me 
24 
strike that. Did you ever have any contact with 
25 
Mr. Jenne during the time you were at ...

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Page 133 
Q. Okay. And on each occasion he approached 
you about talking about the Epstein cases? 
A. On the first I occasion, definitely. I can't 
say on every occasion that we had a conversation. 
Q. And ifl understood you correctly, you 
never assigned Mr. Jenne any tasks, any task; is 
that correct? 
A. That's correct. 
Q. Did you find it odd or strange that he 
would want to talk to you about your Epstein cases? 
A. No. 
Q. Did you, did you -- I\/1,r. Jenne reported to 
whom as you understood? 
A. I didn't understand anything. 
Q. Do you know what his position with the 
firm was? 
A. No idea. 
Q. Did he ever offer to help you with the 
Epstein cases? 
A. In some respect, I guess so. Generally, you 
know, I, I can help. This is basically a criminal 
matter; I can help. You know, that kind of thing. I am 
not saying those are his exact words but paraphrasing 
the gist ofit, that's what I remember. 
Q. Okay. Mr. Edwards, did you ever contact 
Page 134 
the media or the press when, that's located in New 
York City, the State of New York, about any of the 
Epstein cases? 
A. I may have returned telephone calls that were 
initiated by press to me. 
Q. My, my question to you was, did you 
initiate any telephone calls; that is, without 
returning a call to the, to any member of the media 
or press in New York regarding the Epstein cases? 
A. Meaning the first conversation --
Q. Right. 
A. -- between -- yeah. No, I did not. 
Q. Who contacted you from New York with 
regard to any Epstein related matter? 
A. The press. 
Q. Who? 
A. I don't remember anybody's name. 
Q. Give me anybody's name that you can 
recall. 
A. George Rush. 
Q. What media, what did you understand his 
association? 
A. I believe New York Daily News. 
Q. Do you remember when Mr. Rush contacted 
you? 
1 ...

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Page 137 
almost at the end of March. In the last three 
months, starting in January 1st of 2010, have you 
had any contact with the press? 
A. Not that I recall. 
Q. Has the press contacted you, but you have 
not returned their calls? 
A. On hundreds and hundreds of occasions. 
Q. Well, my question is since the beginning 
of, since January I st of2010 has the press 
attempted to contact you? 
A. Yes. 
Q. And ifI understand your testimony, you 
have not returned any of those calls? 
A. To the best ofmy recollection I, I do not 
remember speaking with anybody from the press during 
this year, 2010. 
Q. In 2010, do you have a recollection of 
having spoken with people but saying you can't quote 
me, i.e., I have no comment or I will tell you off 
the record? 
A. I don't even remember having those 
conversations with anybody in 2010. If you know of 
something and can refresh my recollection, I, you may be 
able to remind me, but I don't think in 2010 I have had 
any of those conversations. 
Page 138 
Q. The conversations you had with George 
Rush, when you returned his call, what did Mr. Rush 
ask you? What was he inquiring about? 
A. My response to Jeffrey Epstein's comments. 
Q. Which comments? 
A. A telephone conversation initiated by Jeffrey 
Epstein to George Rush related to the various cases and 
claims against Mr. Epstein. 
Q. Did Mr. Rush call you -- I'm sorry, I will 
improve it. Ifl understand correctly when Mr. Rush 
called you, that's the first time you knew who he 
was? 
A. I didn't !mow who he was before he called me, 
correct. 
Q. What did Mr. Rush tell you what Jeffrey 
Epstein had said to him? 
A. And I'm not sure that that was the first 
conversation I had with, with George Rush. Like I said 
I think I've talked to him three or four, five times. 
Q. Ok...

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Page 141 
Q. He does a Page 2 or something with the, 
Page 1, Page 2 of the Palm Beach Post? 
A. No. I'm not, no. 
Q. Okay. Have you ever spoken with Jane 
Muskrat (phonetic)? 
A. Again, I don't know who that is. 
Q. Have you ever -- did you ever give or 
allow one of your clients to give an interview to 
one of the local TV stations? 
MR. SCAROLA: Objection, compound. 
THE WITNESS: One ofmy clients gave an 
intervie\V to one of the local television 
stations. 
BY lvIR. CRITTON: 
Q. Which of your clients gave the interview? 
A. Jane Doe. 
Q. And did you organize that? 
A. I assisted. 
Q. Which, which TV station was it? 
A. I don't remember. 
Q. Do you remember who the person was from 
the TV station that contacted you? Let me strike 
that. How did it come about that Jane Doe gave an 
interview to the TV station? 
A. Various television stations have been 
Page 142 
interested over the course of these cases in having the 
clients talk. I was adamant that that was not going to 
happen and Jane Doe wanted that to happen. 
Q. How did Jane Doe even know that that 
opportunity existed? lfyou didn't want it to 
happen when the news, when the news people, when the 
TV stations called you why didn't you just say my 
clients are not available for interview? 
A. What's your question? 
Q. The question is, is, with regard to the 
T.V. station, you said multiple TV stations wanted 
to do interviews with your clients. Did I 
understand you correctly? 
A. You did. 
Q. And you said you didn't want any of your 
clients to do interviews, correct? 
A. Right. 
Q. Okay. So, why didn't you just say, no, I 
am not making any of my clients available? 
MR. SCAROLA: I am going to object to the 
extent that that calls for either mental 
impressions or attorney-client privileged 
communications a...

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Page 145 
I believe that's 1ight. 
Q. As a result of Jane Doe speaking with the 
press, did she receive any compensation? 
A. No. 
Q. Have any interviews been given separate 
and apart from the TV interview that Jane Doe gave? 
Did any of the other, did either of your other two 
clients, E.W. or L.M., ever give an interview to, 
written to, to the written media, not TV? 
A. No. 
Q. With regard to, back to George Rush, you 
said that }Ar. Rush, :t'Ar. Rush contacted you. You 
recontacted him, correct? 
A. That's correct. 
Q. Okay. And what was the subject matter? 
What was Mr. Rush interested in talking with you 
about? 
A. Jeffrey Epstein. 
Q. Okay. And what, what specifically about 
Mr. Epstein? How did he even know you existed, did 
he say? 
A. I don't know. Or, or ifI knew, I don't 
remember how he knew that. 
Q. Okay. Did you, did you talk to him? 
A. Yes, I did talk to him. 
Page 146 
1 
Q. Approximately, how many, how long have 
2 
your conversations been? 
3 
4 
5 
A. Short. 
Q. And with regard to George Rush, what, you 
said he was interested in talking about Jeffrey 
6 
Epstein. What was he interested in? 
7 
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A. I don't remember specifically the issue, but 
it seemed to me that he came to me with an issue each 
time, something related to the case. 
Q. Okay. The case being Mr. Epstein's case 
or your three cases? 
A. I think that it was typically in general 
related to the various criminal acts committed by 
Jeffrey Epstein against the large number of girls in 
each of the states that Jeffrey Epstein has lived in. I 
think that was like the gist of his communication to me. 
Q. Well, did he? 
A. Or why he was interested. 
Q. Did he indicate to you that someone had 
2 O 
told him that, that certain acts had occurred in 
21 
22 
23 
24 
25 
other states or locations other than the State of 
Florida? 
A. I ...

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Page 148 
IN THE CJRCUJT COURT OF THE FIFTEENTH JUDJCJAL 
CJRCUJT IN AND FOR PALM BEACH COUNTY, FLORJDA 
CASE NO. 50 2009CA040800XXXXMB AG 
Complex Litigation, Fla.R.Civ.Pro. J'.101 
JEFFREY EPSTEIN, 
Plaintiff, 
-vs-
VOLUMEll OFII 
SCOTT ROTHSTEJN, individually, 
BRADLEY .1. EDWARDS, 
individually, and L.M. individually, 
Defendants. 
VlDtOT APED DEPOSlTJON OF BRADLEY J. EDWARDS, ESQUIRE 
Tuesday, March 23, 20010 
10:00 - 5:07 p.m. 
2 J 39 Palm Beach Lakes, Boulevard 
West Palm Beach, Florida 3340 J 
Reported By: 
Cynthia Hopkins, RPR, FPR 
Notary Public, State of Florida 
Prose Court Reporting 
Job No.: J 333 
APPEARANCES: 
On behalfof the Plaintiff: 
ROBERT D. CRJTTON, JR., ESQUIRE 
Page 
BURMAN, CRJTTON, LUTTIER & COLEMAN, LLP. 
303 Banyan Boulevard 
Suite 400 
West Palm Beach, Florida 33401 
Phone: 561.842.2820 
and 
JACK ALAN GOLDBERGER, ESQUIRE 
ATTERBURY, GOLDBERGER & WElSS, P.A 
250 Australian Avenue South 
Suite 1400 
West Palm Beach, Florida 33401-5012 
Phone: 561.659.8300 
and 
On behalfofthe Plaintiff: 
ALAN M. DERSHOWITZ, ESQillRE 
HARVARD LAW SCHOOL 
Hauser 520 
Cambridge, Massachusetts 02 I 38 
Phone: 617.496.2020 
On behalf of the Defendant: 
JACK SCAROLA, ESQUIRE 
SEARCY, DENNEY, SCAROLA, 
BARNHART & SHJPLEY, P.A 
2139 Palm Beach Lakes Boulevard 
West Palm Beach, Florida 33409 
Phone: 561.686.6300 
ALSO PRESENT: 
Jeffrey Epstein 
Joseph Kozak, Videographer 
Prose Reporting Services 
149 
Electronically signed by cynthia hopkins (601-051-976-2934) 
Electronically signed by cynthia hopkins (601-051-976-2934) 
Electronically signed by cynthia hopkins (601-051-976-2934) 
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Page 150 
«INDEX START>> 
INDEX 
EXAMINATION 
DIRECT CROSS REDIRECT 
CONTJNUED EXAM INA Tl ON ...

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Page 152 
A 
I'm not sure. 
Q. Why would you -- did any of your clients 
claim or have any of your clients claimed to have 
any contact with Ghislaine Maxwell at all? 
A 
That is something that certainly calls for 
attorney-client privilege and not something that I am 
going to be answering today. 
Q. With regard to at least you have attended 
the deposition of both Jane Doe and ofL.M, correct? 
A 
Yes. 
Q. Okay. And have you heard them reference 
Ghislaine Maxwell during the course of those 
depositions? 
A No. 
Q. Would it be a correct statement that none 
of the three of your clients -- Jet's take a look at 
the two that have testified. Both of the two that 
have testified, Jane Doe and L.M. have testified 
that they did not ever take, travel with or were 
transported in any way by Mr. Epstein, correct? 
A 
No, that is incorrect. 
Q. Okay. Did, who, which? 
A. I believe. 
Q. I am sorry? 
A I guess the transcript will speak for itself. 
Page 153 
I don't remember their specific -
Q. Is it your belief that Jane Doe ever 
traveled with Mr. Epstein on his plane? 
MR. SCAROLA: Excuse me, is the question 
limited to the testimony --
MR. CRITTON: Correct. 
MR. SCAROLA: -- that has been given? 
MR. CRITTON: Correct. 
THE WITNESS: No. I do not believe she 
testified that she traveled with Mr. Epstein on 
his plane. 
BY MR. CRITTON: 
Q. All right. And same would be true with 
L.M., she did not testify that she traveled with Mr. 
Epstein on his plane, true? 
A. I believe that's true as well. 
Q. Okay. Are you aware of any other 
information from any other source that either Jane 
Doe or L.M. traveled on Mr. Epstein's plane? 
A. No. 
Q. Did you, did you indicate to -- well, let 
me strike that. Did you tell Mr. Rush that none of 
your clients had ever traveled with Mr. Epstei...

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Page 156 
BY MR. CRJTTON: 
Q. When you originally started working with 
the Rothstein fim1, did you have any discussions 
with Mr. Rothstein regarding how your cases would be 
funded; that is, your personal, your personal injury 
cases and specifically the cases relating to 
Mr. Epstein? 
A. No. 
Q. Okay. With regard to, prior to taking 
your cases to, prior to starting at RRA, you were 
responsible for the funding of your personal injury 
cases or any contingency fee case, correct? 
A. Right. 
Q. And l assume you had either your own 
personal funds or you had a line of credit or both? 
A. Right. 
Q. And when you came to RRA and you brought 
the cases with you; that is, the personal injury 
cases and as well, the Epstein cases, were you 
reimbursed for the costs that you had already 
expended thus far on those cases? 
A. No. 
Q. Did you request that you be reimbursed? 
A. Yes. 
Q. And with, to whom was the request made? 
Page 157 
A. Directly to Scott Rothstein. 
Q. Was that at the ten minute meeting that 
you had? 
A. Yes. 
Q. AtBOVA? 
A. Yes. 
Q. And what did he say? 
A. No problem. 
Q. He said he would reimburse you? 
A. Correct. 
Q. And did that, in fact, take place? 
A. No. 
Q. And how did you attempt to get reimbursed 
for the costs that you had thus far incurred on your 
personal injury cases including Mr. Epstein's case 
when you went, when you started at RRA? 
A. What do you mean? 
Q. Well, you said that Mr. Rothstein agreed 
in the ten minute conversation that RRA would 
reimburse those costs? 
A. Correct. 
Q. You gotoRRA in April of'09, and I 
assume you had to ask someone and say, look, I had a 
conversation with Scott Rothstein. He said he would 
reimburse my costs. 
Electronically signed by cynthia hopkins (601-051-976-2934) 
Electronically signed by cy...

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Page 160 
And obviously nobody expected the ending 
to the Jaw firm that ultimately occurred. 
Q. With regard to the case, l assume you 
settled a couple of personal injury cases during the 
seven months you were there, yes? 
A. Yes, you assume that. 
Q. That's correct? Let me ask the question. 
Did you settle any contingency fee cases during the 
sevens months that you were at the RRA firm? 
A. Yes. 
Q. And when you settled those cases did you, 
and they closed, they were settled through, did you 
have any control of the trust account? 
A. No. 
Q. Okay. Settlement monies come in on a 
personal injury case. What did you do with the 
money once the, once the client had endorsed the 
check? 
A. I, I didn't personally do anything with the 
money. 1t was not handled by me. 
Q. Okay. Were you there --
A. That's why l'm confused. Did 1 settle the 
case? l mean, Rothstein Rosenfeldt Adler firm settled 
personal injury cases while l was there. There were no 
cases that were solely my cases. They were firm cases. 
Page 161 
Q. Let me rephrase the question. You 
brought, you brought cases to the fnm, correct? 
A. That is correct. 
Q. Of a11y of the cases that you brcugl1t, did 
you settle those cases? 
A. No. 
Q. Okay. So, you never had an instance -- so 
there was never a set of circumstances where you 
would have been reimbursed for costs as a result of 
a settlement? 
A. That's correct. 
Q. All right. And, and so during the seven 
months that you were there, you were never 
reimbursed a nickel of the one to $200,000 that you 
had outstanding in costs? 
A. That is correct. 
Q. All right. With regard to the costs that 
were to be incurred for prosecuting the cases, 
specifically the Epstein cases, what was your 
understanding -- was that ever discussed with 
Mr. Rothstein at ...

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Page 164 
A. I have seen them before, yes, sir. 
Q. Okay. And as well there would be 
reimbursable expenses such as when you went to New 
York and took Mark Epstein's deposition. You, you 
paid for the expense up front but, in fact, it was 
then reimbursed by the firm, correct? 
A. Now we're specifically, specifically talking 
about Mark Epstein's deposition, yes, that, what you 
just said is correct. 
Q. Okay. Not only was the, and ifI 
understand your testimony is the deposition was paid 
for directly by the firm. With regard to your 
travel, any hotel, other expenses that you had, you 
put in a request for reimbursement and the firm 
would reimburse you? 
A. Correct. 
Q. All right. And with regard to those 
costs, you said you and Mr. Rothstein never had a 
discussion about that; is that correct? 
A. Correct. 
Q. All right. But you did speak with 
Mr. Adler about how costs would be handled on your 
cases including Mr. Epstein's case after you started 
withRRA? 
A. Correct. 
Page 165 
Q. Okay. And is he the only one who 
explained what the procedure was? 
A. Yes. 
Q. 
Anrl u,1-,,at rlid hP tPll ynu? Well, !Pt n,p 
ask you this: Did he tell you what; that is, that 
the firm would pay for all of the reimbursements 
either costs and/or reimbursements for costs that 
were incurred in prosecuting the Epstein files and 
any other files that you had? 
A. Can you split this question up so that we're 
not talking about reimbursement and costs and things 
like that. 
Q. Sure. With regard to costs such as 
depositions --
A. Okay. 
Q. -- court reporters, court reporter fees, 
video depositions, transcripts ofhearing, whether 
they were expedited or whether they were asked on a 
routine basis? 
A. Right. 
Q. Where would the -- who was responsible for 
paying those bills? 
A. Th...

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Page 168 
associated with the Jeffrey Epstein case? 
A. I didn't say that anybody did. So, no, 
nobody, nobody. 
Q. You could just spend whatever money you 
wanted to in prosecuting your cases; is that 
correct? 
A. No, l didn't say that either. 
Q. What was the procedure then? 
A. That ifl was at a deposition and there was a 
need in my judgment for the transcript to be expedited 
then l would order it expedited and nobody ever told me 
that they had a problem with my judgment as to those 
things. And not as to those things. As to that thing 
which we were talking about which right now is 
expediting deposition transcripts. 
Q. With regard to - so any, how about an 
expense associated with hiring, with either 
directing -- well, let me strike that. With regard 
to Epstein, did, were you ever required or did you 
ever hire outside investigators to do work 
associated with the Epstein case? 
By outside I mean someone who was not an 
employee ofRRA and now I mean dealing with the time 
that you were at RRA 
A. Right. And your question is did l ever hire 
Page 169 
an outside investigator to perform work on Jeffrey 
Epstein's case? 
Q. Correct? 
.,.A,,,__ The ans\'-Jer is no. 
Q. Were, were all the investigations that 
were done during the time that you were employed by 
RRA, were they done by in-house investigators? 
A. I don't know. 
Q. Well, if you wanted investigation done on 
Mr. Epstein, how would you go about authorizing that 
or directing that that be done? 
A. I would ask one of the investigators to do it. 
Q. So, you would direct the specific 
investigator? 
A. Yeah. There were plenty of times where I 
directed the specific investigator. I want you to talk 
to this witness or so-and-so, yes, just like you would 
in any case. 
Q. In this particular instance ass...

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Page 172 
Q. So, you're refusing to answer that 
question? 
A. You're asking me about my definition of 
reprehensible as it pe1tains to a specific hypothetical 
that you've just created. 
Q. Let me ask you --
A. Now, you want me to try to analyze that 
particular hypothetical and tell you whether it meets 
the definition ofreprehensible? 
Q. l will let you -- if Mr. Fisten, ifl ask 
you to assume that Mr. Fisten represented to a 
witness out in California that he was an agent or 
working for the FBI, would you find that conduct 
appropriate by Mr. Fisten? 
MR. SCAROLA: And I will tell you that you 
are not obliged to answer hypothetical 
questions. 
THE WlTNESS: And therefore I am not going 
to answer that question. 
BY MR. CRITTON: 
Q. If Mr. Fisten represented that he was 
associated with the Miami-Dade Police Department, 
Miami-Dade County Police Department, would you find 
that conduct inappropriate? 
MR. SCAROLA: Same instruction and I would 
Page 173 
also observe with regard to each of the 
hypothetical questions that you are asked that 
they are incomplete. And without ]mowing all 
of the surrounding circumsta11ces, it would be 
impossible for any witness to pass judgment 
upon what may have occurred. 
BY MR. CRITTON: 
Q. So, Mr.-- would it be a correct statement 
at least as you understood it, Mr. Edwards, that 
Mr. Fisten was not an agent, was not an FBI agent 
during the time that he worked for RRA? 
A. You're asking me was he an FBl agent or did he 
work for RRA He worked for RRA 
Q. Correct. He was not an FBl agent, true, 
to the best of your knowledge during the time he 
worked for RRA 
A. Okay. 
Q. I am not talking about any other time 
period right now. 
A. Okay. Then the answer is he was not an FBI 
agent at the time he was working for RR.A 
Q. Durin...

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Page 176 
for you. 
MR. CRJTTON: Your best estimate. 
THE WJTNESS: Okay. 1 believe more than 
$300,000. 
BY MR. CRJTTON: 
Q. With regard to, if investigation was done 
on, on a Epstein case, was the investigator charged, 
that is for his time, as an example Mr. Fisten, if 
he did work in California would his time, I'm not 
talking about his expenses, would that be billed as 
a cost to the file? 
A. I don't know. 
Q. On the cost that you received, well, let 
me strike that. If] understood it, up to 300,000 
approximately $300,000 that's been spent on the 
Epstein file, were you able to look --
A. It would be more than that. I am just saying 
it's at least $300,000. 
Q. Something between three and $400,000, 
could it --
A. Something that I would say is definitely 
between 300 and $500,000, but I'm not sure. It could be 
301. It could be 450. I really don't know. 
Q. When was the last time that you looked at 
that ledger or the printout associated with the 
Page 177 
Epstein files? 
A. I have never looked at the printout. 
Q. Okay. How, how do you know what is amount 
is then? That is how do you have the estimate ofit 
being between 350, I'm sorry between 300 and 
$500,000, the cost associated with Epstein? 
A. I asked a paralegal within my current firm for 
the total amount of costs on these three cases that is 
being claimed by Rothstein Rosenfeldt Adler. And I 
remember the cost number in the aggregate being given to 
me reflecting an amount what I just told you. 
Q. Have you requested a copy of the -- let me 
strike that. Did she say she had, that is did 
she -- did you actually receive a document that 
reflects the breakdown of the costs from the 
trustee? 
A. I personally have not seen that. 
Q. Okay. Has your firm received it? 
A. I don't know. 
Q. I assume -- wo...

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Page 180 
an address to serve a subpoena or, or doing some 
minimal background. 
A. l am glad you clarified because I am using 
that same definition. 
Q. All right. So, it's, it's your best 
recollection that you did or did not hire an 
investigator to do real investigative work with, 
associated with Mr. Epstein prior to joining RRA? 
A. l believe I did, but it was after a time when 
1 had, l was contemplating or at least to myself had 
committed to going to RRA So, it was within that time 
period l believe that l hired that person prior to RRA 
Q. When you then went to -- now you had 
committed to go to RRA or at least mentally 
committed to go to RRA As soon as you started with 
RRA, did you terminate the services of that 
investigator? 
A. No. 
Q. Did that investigator continue to do work? 
A. Yes. 
Q. Okay. Has, does he or she or it continue 
to do work today for you? 
A. No. On Mr. Epstein's case you're asking, 
right? 
Q. Yes, sir. 
Page 181 
A. No. 
Q. Okay. For how long a time period did that 
person continue to do the work before it got 
transfPrrPil to l\/lr. FistPn or oth.,r invPstigatnrs? 
A. Question doesn't make sense. 
Q. Okay. How long did the investigator that 
you may have hired prior to joining RRA work on the 
Epstein files before you ceased that work after you 
started working for Epstein in April of '09? I'm 
sorry, for RRA in '09. 
A. The person was hired in either March or April 
of 2009, which is why l can't say with absolute 
certainty whether l was at RRA or not. And that person 
continued to do investigative work in some capacity 
probably throughout the entire time that I was at RRA 
Q. Were all of the bills for that 
investigator paid by RRA? 
A. Yes. 
Q. With regard to the payments for the 
investigators -- well, let me strike that. Wh...

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Page 184 
A. What do you mean by a number? 
Q. More than one. 
A. Yes, I have seen more than one. 
Q. Have you seen articles were it's alleged 
that investigators that were employed by Rothstein, 
by R..RA would go through the garbage of prospective 
Defendants to search for incriminating or favorable, 
incriminating evidence against the Defendant or 
favorable evidence for a Plaintiff who might be 
working or who might be a client of the firm? 
A. I have not seen an article saying that. I 
think I have heard your client say that before. 
Q. Separate and apart --
A. Right. 
Q. You don't have to rely on anything my 
client has said before, the testimony --
MR. SCAROLA: I am sure we won't. 
MR. CRITTON: I am confident of that. 
BY MR. CRITTON: 
Q. In terms of, were you aware from the 
articles, did you see in the article -- let me 
strike that. Did you ever direct your investigators 
to go through Mr. Epstein's trash? 
MR. SCAROLA: I am going to object, 
work-product, attorney-client privilege. 
Page 185 
BY MR. CRITTON: 
Q. Have you directed, did you ever direct --
this is the investigators during the time you were 
at RRA and t½at's t½e question you're claiming the 
privilege over, cmTect? 
MR. SCAROLA: I am claiming the privilege 
with respect to any action that was taken by 
Mr. Edwards or at Mr. Edward's direction in --
MR. CRITTON: Tell you what, I will 
withdraw the last question. 
MR. SCA.ROLA: -- in connection with the 
investigation in prosecution of the claims 
against Mr. Epstein. 
BYMR. CRITTON: 
Q. Let me make my question clear, 
Mr. Edwards. With regard to your investigators, you 
gave direction with regarding the Epstein cases, 
during the time you were with RRA did you ever tell 
them or direct them to go through Mr. Epstein's 
trash? 
MR. SCAROLA: Sam...

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Page 188 
BY MR. CRJTTON: 
Q. With regard to the, with regard to the 
investigators, with regard to the investigation 
bills that would come in from outside investigators, 
specifically the one that you -- well, let me strike 
that. 
The investigator that you hired before you 
went to RRA, I think you testified that bill was 
paid by RRA, correct? 
A. Yes. 
Q. All right. And in terms of the 
investigators who were employed by RRA for whatever 
investigation you directed them to do, those 
individuals were also paid from funds from RRA, 
correct? 
A. During the time period when I was at RRA 
you're asking about specifically, correct? 
Q. Correct. 
A. Then the answer is, yes. 
Q. Was there any specific cost account that 
was set up for Mr. Epstein's cases? 
A. 1 don't know. 
Q. Did you ever speak with the --
A. Again we're talking about the time period at 
RRA? 
Page 189 
Q. AtRRA 
A. Okay. 
Q. During the time you were at RRA did you 
ever speak v~~t.l-i the accounting department or the 
accounting department ever call you to talk about 
the amount of costs, assuming they were something 
between 300 and $500,000 that were being expended on 
Mr. Epstein files? 
A. No. 
Q. Did, did anyone at the firm ever call you 
to discuss the issue of the amount of costs between 
300 and $500,000 that were being incurred to 
prosecute Mr. Epstein's cases? 
A. No. 
Q. Okay. Who had checked -- did you have any 
check-signing authority at RRA? 
A. No. 
Q. Who did sign the checks? 
A. I don't know. I was --
Q. In terms of the, the work that was being 
done or the, the work that was, that is the costs 
that were being incurred including reimbursable 
costs, did you understand that you had a, basically 
an unlimited budget to prosecute those cases? 
A. No. 
Electronically signed by cynthia...

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Page 192 
they're claiming. J never _juxtaposed that with what I 
believe should be the proper amount. But beginning with 
the fact that J do recognize that as the amount that 
they are claiming, I was not aware that the costs were 
that high. 
The cases were firm cases, paid for by the 
firm. I was simply an employee and I made judgment 
calls. If somebody had told me at any given time, 
we shouldn't serve these subpoenas, or we shouldn't 
take this deposition, J wouldn't have done it. 
Q. In fact, with regard to -- welL let me 
ask you this: Were any informants, did you 
authorize your investigators to hire informant, 
informants? 
MR. SCAROLA: Same objection, same 
instruction. 
BY MR. CRJTTON: 
Q. Did you authorize your investigators to do 
electronic eve's dropping? 
MR. SCAROLA: Sarne objection, same 
instruction. 
BY MR. CRJTTON: 
Q. You indicated that you were just an 
employee, correct? 
A. Yes. 
Page 193 
Q. Okay. In fact, you, on various documents 
reflected that you were a partner of the finn, 
cmyect? 
/ 11.·. Yes, docUt111ent, documents do reflect that 
title, of course, yeah. 
Q. And ifl had asked for a card during the 
time that you started at RRA up until the time of 
the implosion of the finn in late October of'09, 
would your card have also reflected that you were a 
partner of the finn? 
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 ofRRA you held yourself 
out to the public, and including other lawyers, as 
being a partner ofRRA, 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 t.h...

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Page 196 
Q. Okay. And the support, how many floors 
did RRA occupy in the Fort Lauderdale --
A. l believe six. 
Q. And approximately how many square feet on 
each floor? 
A. 1 don't know. A lot. 
Q. More than 10,000 square feet on each 
floor? 
A. I don't know. 
Q. And what was the support staff at the time 
that you were there approximately? 
A. In quantity or quality? 
Q. Quantity, the number of people. 
A. I don't know. A lot of people. 
Q. Did you do any hourly billing yourself at 
all or were you strictly a contingency fee person? 
A. 90 percent contingency. 
Q. And with regard to the monies that were --
separate and apart from the Epstein, Epstein cases 
where at least you now !mow that they cost between 
three and $500,000, you were, l assume, incurring 
other expenses on other cases, true? 
A. True. 
Q. All right. And where did you, where did 
you think that the money was coming from; that is, 
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, I'm 
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 the 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 
compound. 
THE WITNESS: The law firm. 
Electronically signed...

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Page 200 I 
Q. Did you know an individual by the name of 
Patrick Roberts? 
A. Yes. 
Q. Okay. And who is Mr. Roberts during; that 
is, what did Mr. Roberts do for RRA? 
A. He was an investigator. 
Q. Did he ever perform investigation work on 
any of the Epstein files? 
MR. SCAROLA: Same objection, same 
instruction. 
BY MR. CRITTON: 
Q. Did you ever authorize Mr. Roberts to 
perform investigation on the Epstein files? 
MR. SCAROLA: Same objection and 
instruction. 
BY MR. CRITTON: 
Q. All right. I asked you earlier about 
Richard Fandrey, F-a-n-d-r-e-y. I think you said 
you don't know who that -- you knew someone named 
Rick; is that correct? 
A. I know an investigator named Rick. 
Q. Did Rick, did Rick perform any 
investigation on the Epstein, did you authorize Rick 
to perform any investigation on the Epstein files? 
MR. SCAROLA: Same objection and 
Page 201 
instruction. 
BY MR. CRITTON: 
Q. And I believe we talked a little bit 
about, we certainly talked about l\A..r. Jem1e, did you 
ever authorize or direct Mr. Jenne to perform any 
investigation on the Epstein files? 
MR. SCAROLA: Same objection and 
instruction. 
BY MR. CRITTON: 
Q. Are you familiar with the company called 
Blue Line Research and Development? 
A. No. 
Q. Are you, are you aware at the current time 
that there is an entity called Blue Line Research 
and Development which is composed of Mr. Roberts, 
Mr. Richard Fandrey, Mr. Michael Fisten and Ken 
Jenne? 
A. No. 
Q. If you're unaware of the existence of the 
entity called Blue Line Research and Development, 
LLC, would it be a correct statement that you have 
never authorized anyone from Blue Line Research and 
Development, LLC, to conduct any investigation of 
Jeffrey Epstein? 
MR. SCAROLA: Same objection, same 
Electronically signed by cynth...

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Page 204 
various occasions for a total of about 15 hours before 
we took this deposition. I met him for the first time 
during that deposition. 
MR CRJTTON: Let me move to strike as 
nonresponsive. 
BY MR. CRITTON: 
Q. My question to you is when did you first 
meet Mr. Rodriguez? 
MR. SCAROLA: And you have an answer to 
that question. 
THE WITNESS: It's a very complete answer. 
I, the day of his deposition. 
BY MR. CRITTON: 
Q. Had you ever spoken with Mr. Rodriguez 
before that time? 
A. No. 
Q. Okay. Had anyone on your behalf spoken 
with Mr. Rodriguez? 
A. No. 
Q. Mr. Rodriguez's deposition occurred over a 
two-day period; is that correct? Two separate days. 
A. I believe that's right. 
Q. And you were present for both of those 
depositions; is that correct? 
A. Yes. 
Page 205 
Q. And the first one I believe at least in 
looking at the transcript the first one occurred on 
January 29th of'09? 
/1.. I'm assu.Ti..11g. 
Q. And the second, the follow-up was on 
August 7th, 2009, correct? 
A. When was the first, January you said? 
Q. Excuse me. I'm sorry. July 29th, 2009. 
A. Okay. 
Q. With the follow-up July, I'm sorry 
August 7th, 2009. 
A. If you say so. I'm not quarreling with that. 
Q. And I will just represent that is what I 
read off the transcripts. Between those two dates, 
that is July 29th and August 7th of '09, did you 
speak with Mr. Rodriguez at all? 
MR. SCAROLA: Same objection, same 
instruction to the extent that any such 
conversation may have occurred in connection 
with your representation of the Plaintiffs and 
claims against Mr. Epstein. 
BY MR. CRITTON: 
Q. All I am asking right now, not the 
substance but just so the record is clear I am just 
asking, did you speak with Mr. Rodriguez between 
Electronically signed by cynthla hopkins {601-051-97...

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Page 208 
A. Okay. 
Q. We agree on that. 
A. Okay. 
Q. Subsequent to the deposition; that is, 
after Mr. Rodriguez's deposition, did Mr. Rodriguez 
contact you? 
MR. SCAROLA: Objection, instruct you not 
to answer. 
MR. CRITTON: Well, this is -- okay. This 
is a third party contacting Mr. Edwards. All 
right. 
MR. SCAROLA: It is not --
ivlR. CRITTON: It's just a yes orno I'm 
looking for. 
MR. SCAROLA: It is a witness in these 
proceedings. 
MR. CRITTON: So. 
MR. SCAROLA: So, anything that 
Mr. Edwards has done or may have done in 
connection with his investigation and 
prosecution of the claims against Mr. Rothstein 
it is our position is not the appropriate 
subject matter of inquiry in the context of 
this lawsuit, and is an attempt to invade the 
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 pennits a response 
4 
to these questions, we would be happy to 
5 
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 
1 0 
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 
BYMR. CRITTON: 
15 
Q. Between the first and second deposition of 
16 
Mr. Rodriguez, I think you, I think you indicated 
1 7 
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 --
2 0 
Q. Right. 
2 1 
A. -- I spoke to him or not? I, I don't 
2 2 
remember. 
2 3 
Q. Did you speak with Mr. Rodriguez between 
2 4 
his first and second. 
2 5 
MR. SCAROLA: Same objection, same 
Electronically signed by cynthia hopkins (60...

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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 l 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 
1 0 
Exhibit 1, the criminal complaint? 
11 
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. It's obvious to me that you're trying to 
1 7 
circumvent the privileges that have been placed on the 
18 
record. I will answer that question that, no, I did 
1 9 
not, but I am not here to divulge anything that may 
2 0 
waive my attorney-client or work-product privilege or 
21 
otherwise jeopardize the claims that my three clients 
2 2 
are pursuing against Jeffrey Epstein for their being 
23 
sexually molested by him when they were underage minor 
24 
females. 
2 5 
Q. Mr. Edwards, are you the cooperating 
Page 213 
1 
witness who was referenced in the criminal 
2 
complaint, Exhibit 1? 
3 
MR. SCAROLA: Could you explain to us for 
4 
the record, please, how that line of inquiry is 
5 
reasonably calculated to iead 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 
1 0 
allow Mr. Edwards to answer that question 
11 
outside the presence of an Assistant United 
1 2 
States Attorney who can make a judgment as to 
1 3 
whether that is information that ought to be 
14 
disclosed. 
15 
BYMR. CRITTON: 
1 6 
Q. Mr. Edwards, you knew or you first Marie 
1 7 
Villafana 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 ...

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Page 216 
had conversations with Mrs. Villafana from time to 
time? 
A. Okay. 
Q. ls that true? 
A. ls your assumption true? 
Q. Correct. 
A. I have spoken with Ms. Villafana. 
Q. And when you spoke with Ms. Villafana --
let me strike that. Have the only conversations 
that you have had with Mr. Marie Villafana or 
Villafana, have they only been in the context of 
Jane Doe 1 and 2 versus United States of America, 
only in the context of that case? 
MR. SCAROLA: Sarne objection. 
MR. CRITTON: And I will separate out to 
the extent that you were at the June 12th, 
2009, hearing in front of Judge Marra where she 
was present. 
MR. SCAROLA: Sarne objection, same 
instruction. 
BY MR. CRITTON: 
Q. Has Ms.-- have you spoken, have you had an 
occasion to speak with Ms. Villafana with regard to 
the criminal complaint, Exhibit No. 1, involving 
Alfredo Rodriguez, Mr. Rodriguez? 
Page 217 
MR. SCAROLA: Same objection, same 
instruction. 
BY MR. CRITTON: 
Q. M_r. Edwards, have you ever been 
interviewed by the FBI or the U.S. Attorney's office 
with regard to any of your clients? 
MR. SCAROLA: Any of the three clients who 
have claims against Mr. Epstein? 
MR. CRITTON: Correct. 
MR. SCAROLA: Sa.me objection, same 
instruction. 
BY MR. CRITTON: 
Q. Do you know Agent Nesbitt, sir? 
A. Yes. 
Q. And how do you know Agent Nesbitt from the 
FBI? 
A. I can answer if you want. 
MR. SCAROLA: Okay. That's fine. 
MR. CRITTON: Nesbitt Kirkendahl. 
1HE WITNESS: I don't know her last name 
but I do !mow the first name is, the first name 
is obviously an unusual name, so I do !mow who 
that is. I met her outside of the courtroom 
related to the Jane Doe l and 2 versus United 
States of America case. 
Electronically signed by cynthia hopkins (601-051-976-2934) 
Electronically signed by cynthi...

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Page 220 
Q. And did you go back in front of Judge 
Marra that same day? 
A. l can't remember. 
Q. Did he issue an order based upon that 
hearing? 
A. The, the record in the case will speak for 
itself. I really, I don't remember right now. 
Q. Have you had any other conversations with 
Nesbitt Kirkendahl other that? Well, 1 mean any 
other face-to-face conversations with her other than 
that one day back in July of, July or August of 
2008? 
A. No. 
Q. Have you seen Nesbitt, Agent Nesbitt 
Kirkendahl since July, July or August of2008 during 
that short conference as physically seen her 
someplace? 
A. Unless she was at the hearing we all attended 
on your motion to stay that day when there were a lot of 
people in the courtroom, the answer is no. 
Q. Okay. Have you seen Agent Jason, assmrung 
the male agent's name was Jason Richards or Richard, 
have you seen him since that day in July or August 
of2008? 
A. I do not believe I have. 
Page 221 
Q. Have you spoken with either Nesbitt 
Kirkendahl or Jason Richard relating to any Epstein 
related matter since July or August of 2008? 
MR. ~rA ROl .A· l :im going tn irn:tnir.t yon 
not to answer on the basis of the privilege as 
previously described. 
BY MR. CRITTON: 
Q. Mr. Edwards, have you spoken with any rep, 
has any representative of the FBI attempted to speak 
with you regarding your association with the RRA 
firm? 
A. No. 
Q. Has any member of the U.S. Attorney's 
Office discussed with you any aspect of your tenure 
or employment at the RRA firm? 
A. No. 
Q. In any conversations that you, that you 
had that you've had with the United States 
Attorney's Office at any time, has anyone ever asked 
you any questions about Scott Rothstein? 
A. You're presupposing that I had conversations, 
but I will answer the questio...

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Page 224 
share investigative material regarding, that you had 
obtained regarding Mr. Epstein? 
MR. SCAROLA: Same objections and 
instructions. 
BY MR. CRITTON: 
Q. Did you provide any of the investigative 
materials that had been acquired by you to any other 
person outside of the RRA firm and the Farmer, Jaffe 
firm up through the current date? 
MR. SCAROLA: Would you read that question 
back? 
BY MR. CRITTON: 
Q. Let me ask it. During the time that you 
were v.~th RRA, excuse me, and had investigation done 
on Mr. Epstein, was any of your investigation that 
you had performed turned over to any person outside 
ofRRA or your clients? 
MR. SCAROLA: Same objection, same 
instruction to the extent that that would 
encompass other attorneys with a shared 
interest in the prosecution of Mr. Epstein. 
lf any of those materials were turned over 
to persons who did not have a direct interest 
to lawyers who did not have a direct interest 
in the prosecution of the claims against 
Page 225 
Mr. Epstein or to clients who did not have, to 
persons who did not have a direct interest in 
the pursuit of their claims against 
Mr. Fpstein, thP.n you c:an :an~w"r to that 
extent. 
·•s-
THE WI1NESS: Privileged. 
BY MR. CRJTTON: 
Q. And I just want to be clear is, is there 
any written agreement and I know you, I want to make 
certain that the objection is there, is as we both 
know there are a number of claims. There are a 
number of claims that are outstanding against 
Mr. Epstein brought by a number of different 
lawyers. 
MR. SCAROLA: The objection extends to 
both written agreements and oral agreements. 
THE WI1NESS: Yes. We both know that 
there are a lot of claims against Mr. Epstein 
for basically the same conduct. 
BY MR. CRITTON: 
Q. And my question to you is is, is the...

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Page 228 
Q. You have testified that investigations 
were done during the time, on Mr .. relating to 
Mr. Epstein during the time that you were at RR.A 
A. Right. 
Q. My question to you is. did you -- first of 
all did you receive written reports in addition to 
oral reports? 
A. From the investigators? 
Q. Yes, sir. 
THE WITNESS: Answer? 
MR. SCAROLA: Yeah. 
THE WITNESS: The reports were --yes, 1 
did. 
BY MR. CRJTTON: 
Q. And were the reports provided by e-mail or 
were they provided by, in the form of a memo that 
would be sent from the investigator to you or both? 
A. l, I do not remember there being any in the 
form of an e-mail. Does not mean that there was not. l 
did communicate by e-mail with other members of the firm 
and other members of the investigative team on all cases 
as has been my practice all along practicing law. There 
were memos, though, that were given to me that were not 
e-mail form that were the standard memos that l would 
incorporate into a witness memo file. 
Page 229 
Q. And again that would just be in your, 
would that be in your electronic storage as well as 
in the hard copies? 
A. The version I saw was tlie electronic. 
Q. So, that would be stored in the Fortis 
program? 
A. That's correct. 
Q. All right. And again other individuals in 
the firm, other lawyers in the firm might be able to 
access that program, you just don't know? 
A. Right. Well, the program, obviously that's 
the program that the firm used. Now, whether they could 
access, if you could go across cases that weren't cases 
you worked on, I really just don't know. 
Q. As an example could Mr. Fisten, on the, on 
the Fortis, could he access your, your file on an 
Epstein case? 
A. I don't !mow. 
Q. If someone accessed your file, accessed 
your electronic file, would you necessarily know 
that? 
A. No. 
Q. All right. So --
A. l don'...

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Page 232 
motions, research, appeals, pleadings, papers that 
were filed? 
MR. SCAROLA: You can, you can answer 
whether they were, there were other lawyers 
involved in drafting tasks without identifying 
what those may have been. 
TI-IE WITNESS: Other lawyers contributed to 
some extent to the prosecution of those cases. 
BY MR. CRITTON: 
Q. Who? Names. I'm not asking for tasks. 
MR. SCAROLA: You can answer. 
MR. CRITTON: I am asking for names. 
TI-IE WITNESS: Bill Berger, Judge Stone, 
Russell Adler, Rob Busche!. 
BY MR. CRITTON: 
Q. B-o-u-c-h-e-1? 
A. I don't know how to spell it. B-u, I don't 
know how, B-u-s-c-h-e-1, I believe. 
Q. All right. Is he currently with you now? 
A. No. 
Q. Any other lawyers? 
A. And you're asking for no matter how minimal, 
just anything done by any lawyers? 
Q. Correct. 
A. Michael, I think his name is Michael. It was 
Page 233 
another lawyer. That's, that's -- those are the ones 
that I can remember right now. 
Q. Were there ever meetings that occurred, 
v,;eH, not -- ,vere there ever specific meetings that 
were attended by various lawyers to discuss 
Epstein's cases? 
MR. SCAROLA: You can answer whether there 
were meetings. 
TI-IE WITNESS: There were meetings to 
discuss every case including Jeffrey Epstein's 
cases. 
BY MR. CRITTON: 
Q. And when you say there were meetings to 
discuss every case, were there routine meetings that 
were held to discuss your cases or cases in general? 
A. It's how the firm worked. If you wanted to 
discuss cases, or the case was a case that was thought 
to need more than one or more than two attorneys, then a 
meeting could easily be assembled within RRA to sit 
around the table and discuss issues related to any case. 
And yes, that happened with respect to cases filed 
against Jeffrey Epstein. 
...

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Page 236 
way of e-mail? 
A. Yes. 
Q. Did you ever receive any memorandum from 
him; that is, a typewritten memo that was then sent 
to you through office mail that was not electronic 
involving Mr. Epstein? 
A. No. 
Q. At the meetings that you, at the meetings 
that occurred where these various lawyers, Berger, 
Adler, Stone, Rob Busche! were present and Epstein 
was discussed, was the discovery that, discovery 
and/or investigation regarding Mr. Epstein was that 
ever discussed? 
MR. SCAROLA: Same objection, same 
instruction. 
BY MR. CRITTON: 
Q. Mr. Edwards, are you aware as a former 
state prosecutor that there are laws against 
conducting certain financial transactions in money 
that's derived from a crime? 
A. l don't understand your question. 
Q. Okay. Well, you were a former state 
prosecutor; is that correct? 
A. Right. Yes. 
Q. Right. Are you aware that there are 
Page 237 
certain Jaws both state and federal that, that are, 
that preclude conducting certain financial 
transaction, transactions in money that is derived 
from a crime? 
A. Still don't understand your question. But 
first before I try to answer your question, are you 
taking me back to a time when I was a State Attorney and 
asking back then did 1 lmow and then your question? 
Q. Yes. 
A. Back when I was a State Attorney did I know 
that there are crimes related to money transactions? 
Q. No. 
MR. SCAROLA: Could I help you? Do you 
want to ask him whether he was aware of the 
existence of a state RJCO statute? 
MR. CRJTION: No. 
MR. SCAROLA: Okay. 
MR. CRJTION: I am okay with that first, 
but I am still going to ask my question. 
BY MR. CRJTION: 
Q. I assume you're aware of the existence of 
a state RJCO statute, correct? 
A. I don't know that I was aware of that back 
then. I just can't reme...

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Page 240 
Q. And that's Exhibit 1 attached to the 
complaint, correct? 
A. Correct. 
Q. And you're aware that, and this is the 
information that was brought by the United States of 
America, U.S.A. versus Scott Rothstein, correct? 
A. Yes. 
Q. And you're aware that within the -- well 
let me strike that. Are you aware that 
Mr. Rothstein has pied guilty to, excuse me, the 
information that was brought against him by the 
U.S.A.? 
A. lam aware that he pied guilty to something. 
Q. With regard to the complaint brought by 
the U.S.A., 1 am sorry, the information brought by 
U.S.A. against Mr. Rothstein, I assume you have read 
the allegations associated with the racketeering 
conspiracy, the pattern of racketeering activity, 
correct? 
A. 1 haven't. 
Q. Okay. If you tum to Page 3, Paragraph 4, 
were you aware, were you aware prior to coming in 
here today that Mr. Rothstein was, that the charges 
that were brought against him were for under, under 
RICO but with regard to mail fraud, wire fraud, 
Page 241 
laundering of monetary instruments, engaging in 
monetary transactions, and conspiracy to launder 
monetary instruments and engage in monetary 
transactions? 
A. I, I have read that in the newspapers. l have 
been told that by numerous people. So, yes, l was aware 
of that. 
Q. And within the complaint at Paragraph 6 it 
says the Defendant --
A. The information or the complaint? 
Q. J'm sorry. Within the information, 
Exhibit l to the complaint, in Paragraph 6 where it 
speaks in terms of the Defendant and his 
co-conspirators, conspirators agreed, agreed to 
engage in a pattern of racketeering activity through 
its base of operation at the offices ofRRA Do you 
see that? 
A. Yes. 
Q. Okay. Do you know who the, do you know 
any of the co-conspirators in addition who a...

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Page 244 
Q. Have you, and ifl understand correctly 
you haven't discussed any firm business with 
Mr. Adler since the implosion; is that correct? 
A. Firm business? 
Q. Any firm RRA business? 
A. Right, no. 
Q. How about with Mr. Rosenfeldt, have you 
had any discussions with him --
A. None. 
Q. -- since the implosion of the firm in late 
October of'09? 
A. No. 
Q. If you wanted, if you had any, other than 
your existing partners have you had an occasion to 
speak with any other partners or former partners of 
the firm regarding the implosion -- well, let me 
strike that -- regarding the ponzi scheme that was 
being run by Mr. Rothstein through the firm? 
A. I have spoken to my current partners about it. 
Q. Are your current partners, are you aware 
of any of your current partners being a target of an 
investigation as a potential co-conspirator with 
Mr. Rothstein? 
A. No, way. 
Q. You're not aware of or no one has told you 
Page 245 
that, correct? 
A. I am not aware of that and nobody has told me 
that. 
Q. l\1r. Rothstein founded what was, what 
ultimately became RRA in approximately 2002. Were 
you aware of that fact? 
A. No. 
Q. How long did you think Mr. Rothstein had 
been -- well, let me strike that. How long did you 
think RRA had been in existence prior to your 
joining the firm? What were you told? 
A. I don't know what I was ever told. I think 
that I learned that information when the implosion, as 
you call it, occurred. 
Q. And were you, in terms of what the 
revenues of the firm were, were you ever advised 
what the revenues of the firm were? 
A. No. 
Q. Okay. Were you, were you familiar with 
what the expenses were associated with operating the 
RRA firm? 
A. No. 
Q. Were you in anyway -- well, let me strike 
that. With regard to -- let me take a fi...

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Page 248 
obviously knew what, whether hiring an investigator 
or what a particular cost was because you had to pay 
it, correct? 
A. Yes. 
Q. Okay. And l think as you described 
earlier is that there had been very little discovery 
up until the time you started working for RRA in 
your three cases, true? 
A. Not very little discovery. Obviously we had 
gone through interrogatories, responses, request for 
production, responses or lack ofresponses, however, the 
majority of the depositions that were taken, the cases 
just happened to be right last summer for most of those 
depositions to take place, and that's what happened. 
Q. Not only depositions but as well the 
investigation as you have described, your 
investigator that you hired as an outside person 
didn't really start until late March or early April 
in conjunction with the other investigation that you 
did during the time you were with RRA, correct? 
A. Fair statement. 
Q. All right. And when you were at RRA you 
described earlier, and I won't belabor it, but you 
described the compound l think is the word that you 
used that Mr. Rothstein kept himself in when he was 
Page 249 
at the finn, correct? 
A. Correct. 
Q. Right. And he was not accessible to 
everyone else, true? 
A. Right. 
Q. And was he on your floor or was he on a 
completely separate floor? 
MR. SCAROLA: As opposed to a partly 
separate floor. 
THE WITNESS: For the most part he was on 
a separate floor. 
BY Jv1R. CRITTON: 
Q. Okay. And were there guards during the 
time that you were at, at the RRA finn, RRA, were 
there ever guards that patrolled the hallways? 
A. Yes. 
Q. And was that from the day you started? 
A. I believe so. 
Q. And had you ever been in a finn where --
bless you. Had you ever been in a fo-m where 
there -- well, let me st...

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Page 252 l 
Q. Did you understand as well that he had, 
that the fim1 was paying for armed guards to guard 
his house 24 hours a day? 
A. No. 
Q. When did you learn that fact? 
A. After the disbandment ofRRA 
Q. Did Mr. Adler tell you that Mr. Rothstein 
had amazing or substantial wealth? 
A. I don't know in those words, but I, l 
definitely understood that. 
Q. Okay. ln meeting Mr. Rothstein initially, 
initially for the ten minutes as you were 
contemplating taking a job and on the two other 
occasions or the one other occasion when you saw him 
out in the restaurant, I think you described him as 
flamboyant? 
A. I'm not sure I used that word but probably one 
synonymous, and, yes, I would describe him as such. 
Q. Was he someone that at least -- well, let 
me strike that. Were you aware that he had a, a 
watch collection of hundreds of watches? 
A. No. 
Q. Did you see him wear expensive jewelry 
when you saw him; that is, the few occasions that 
you saw him? 
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Page 254 
A. l went there one time. 
Q. For what occasion? 
A. I don't remember the occasion, but it was a 
gathering that he had at his house and he asked, during 
the course ofme working there were ten occasions where 
everybody was invited to go to his house for various 
events and on one occasion, l went. 
Q. Oh, all right. And from being in his 
house did you recognize immediately that this was a 
multi-million dollar house? 
A. Yes. 
Q. Okay. Was it on the water? 
A. Yes. 
Q. And could you tell from the interior 
design or the decorations that existed that this was 
at least a man, a man that had significant wealth? 
A. Yes. 
Q. All right. And could you, did you have an 
opportunity to see his collection of automobiles? 
A. No. 
Q. During the time that you were in the 
house, did you have an opportunity...

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Page 256 
at that time? 
A. I heard that sometime after I began working 
there. He certainly acted like he did. 
Q. Did you learn that he had investments in 
other business entities, whether they were other 
restaurants or other business entities --
A. Through --
Q. -- during the time that you worked at RRA? 
A. Through rumors. 
Q. And rumor was he had his fingers in many 
different businesses? 
A. It sounded like hundreds. 
Q. And did you understand that he had a 
substantial collection of automobiles? 
A. What do you mean by substantial selection or 
collection? 
Q. Well, were you, during the time that you 
were at RRA were you aware that he had Ferraris? 
A. No. 
Q. Multiple Ferraris? 
A. No. 
Q. Were you aware that he had a Bentley? 
A. Yes. 
Q. Were you aware that he had a Bugatti? 
A. I heard that. 
Page 257 
Q. Were you aware that he had a Rolls Royce? 
A. No. 
Q. Were you aware that he had multiple 
rnn1PttPo? 
A. No. 
Q. Either a Corvette or multiple Corvettes? 
A. No. 
Q. Were you aware that he had multiple 
Mercedes Benz? 
A. No. 
Q. Were you aware that he owned a yacht? 
A. Yes. 
Q. Okay. And was that parked behind his 
house? 
A. Yes. 
Q. Were you aware that he also -- and did it, 
ifl was to say it was approximately an 85 to 
90-foot yacht or, i.-i fact, an 87-foot yacht? 
A. I wouldn't quarrel with that. 
Q. Did it also appear that he had a 
substantial sport fisherman that was parked out 
there as well? 
A. I didn't see that. 
Q. Were you aware that he had 33-foot Aqua, 
Aquaviva? 
Electronically signed by cynthia hopkins (601-051-976-2934) 
Electronically signed by cynthia hopkins (601-051-976-2934} 
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Page 260 
Mr. Rothstein prior to going to the firm and by 
research I mean people Google. Did you Google him? 
A. No. 
Q. Did you, did the firm have a brochure? 
A. I don't know. 
Q. Did you ever see brochures in the waiting 
room or the reception rooms that described the firm 
when it was founded, background of the firm, et 
cetera? 
A. No. 
Q. Was it on your web site? 
A. Was what on my web site? 
Q. The history or the background of the firm. 
Let me strike that. RRA had a website? 
A. RRA had a website. 
Q. That's no longer in existence, true? 
A. True. 
Q. And --
A. To my knowledge. 
Q. Did you ever go on the website and 
checkout the web site for the history or the 
background ofRRA and Mr. Rothstein? 
A. I went on the website. I don't know that the 
website even had a history. Ifit did, I don't remember 
ever looking at it. 
Page 261 
Q. Did it, did, at least from what you saw 
and observed of Mr. Rothstein, did it appear to you 
that the, his wealth far exceeded the type of 
hu"iP""" th,it it ,ippe,irerl tn ynn th,it the firm w,i" 
doing? 
A. I have no understanding whatsoever. No, 
that's not something that ever crossed my mind. 
Q. Well, under these circumstances is, is 
when you went to the firm, you had the ability to 
your discretion to spend whatever monies you wanted 
in prosecuting your personal injury and Epstein 
cases. You, no one ever turned down a request 
either for a reimbursement or told you not to expend 
any money, true? 
MR. SCAROLA: Objection, compound and 
repetitious. 
THE Wl1NESS: I don't understand the 
question. 
BY MR. CRJTTON: 
Q. No one, as to any expenditure that you 
ever made on an Epstein case --
MR. SCAROLA: Isn't this about the fourth 
time that you're eliciting exactly the san1e 
testimony? Isn't it very clear the extent to 
...

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Page 264 
at least what was rumored to be his business 
interest, did you believe that the source of his, of 
his apparent wealth was as a result of the law firm? 
A. I believe that the source of his wealth was 
the law firm as well as the, what l have described as an 
assortment of businesses that he had his hands in of 
which only a fraction l was aware. 
Q. Well, what did you understand to be the 
source of the funding of the, of the Epstein cases 
and the other lawsuits that you had? 
A. The checks l believe were written by the law 
firm. 
Q. Okay. And what did you believe was the 
source of the monies that the law firm got to expend 
some, just on the three cases that you had with Mr. 
Epstein, some three to $500,000, I mean separate and 
apart from all of the, your other personal injury 
cases and separate and apart from all of the other 
69 lawyers who were in the law firm who also had 
cases? 
A. I didn't have a belief at all as to the source 
of any of the monies that were used for any of the case. 
Q. Was it your position it really wasn't your 
concern; that is, wherever the money came from, it 
didn't bother you; all you !mew is that the firm was 
Page 265 
funding your cases? 
MR. SCAROLA: Objection, argumentative. 
THE WITNESS: Yeah. At the time I believe 
that ! a.111 worbng at a we!! recognized law firm 
with good people and that is a successful law 
firm and this is the way that law firms at that 
level operate, and right, I didn't --
BY MR. CRITTON: 
Q. Didn't care? 
A. Right, I didn't care. I didn't question it. 
Q. With, with regard to, let me ask you some 
names and see if you recognize the names. Do you 
know a person by the name of Barry Bekkadan, 
B-e-k-k-a-d-a-n? 
A. Never heard the name until right now. 
Q. A.J. Discala? 
A. Again same answer...

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Page 268 
purported to have an office within RRA's offices. 
Have you seen that? 
A. Have l seen what? 
Q. Have you seen that in any of the news 
media, that Mr. Preve had an office within RRA? 
A. That name doesn't sound familiar at all. So, 
no, the answer to your question is no, l haven't seen 
that. 
Q. Bill Brock? 
A. Yes. 
Q. Okay. Who is Mr. Brock? 
A. ln the law finn he went by the name Uncle 
Bill. 
Q. Okay. All right. Who is Uncle Bill? 
A. Who do l understand him to be? l don't know 
who he really was. At this point in time looking back, 
there is no telling what anyone, what anyone or anything 
was. But at the time l believe that he was a relative 
of Scott Rothstein's. 
Q. What did he do? What did, what did Uncle 
Bill do --
A. Some --
Q. -- at the finn? 
A. Something with money. 
Q. Did he have an office at the finn? 
Page 269 
A. I think the trustees are still trying to 
figure out what he exactly did do. 
Q. Did you have any dealings with him? 
A. Dealings, no, l didn't have dealings. 
Q. Dealings of any kind? 
A. I talked to him. 
Q. Did you ever discuss any of your cases? 
Was he -- he wasn't a lawyer? 
A. Far from it. 
Q. All right. Did you ever discuss any of 
your cases with him? 
A. No. 
Q. Just a hi, hello? 
A. Hi, hello, and I was one of the lawyers who 
would come in often and work on weekends and he would be 
there. That's when l would see him, and he would kind 
of, hey, how are you doing on a weekend. 
Q. And do you know a Dean K.retclm1ar, 
K-r-e-t-c-h-m-a-r? 
A. No. 
Q. Same question again, do, these names 
during the time period, Doug Van Allman, 
A-l-1-m-a-n? 
A. No. 
Q. Ted Morse? 
Electronically signed by cynthia hopkins {601-051-976-2934) 
Electronically signed by cynthia hopkins {601-051-976-2934) 
Electronically signed by cynthia ...

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Page 27 2 l 
as the director of Corporate Development for RRA 
A. I don't know even know what that means. 
Q. Have you ever heard of the Centurion 
Credit Fund or the Platinum Management Fund? 
A. No. 
Q. Alan Sakowitz? 
A. No. Wait. Alan Sakowitz. I have heard that 
name recently. I don't know why. I believe I actually 
heard that name in a response. Never mind. In some 
nonresponsive answer that your client gave, l heard that 
name. 
MR. SCAROLA: Keep going. 
BY MR. CRITTON: 
Q. Mr. Edwards, with regard to your phone, 
did you have a direct line at RRA? 
A. Yes. 
Q. What was that phone number? 
A. I don't remember. 
Q. And is your cellphone today the same as it 
was back then? 
A. Yes. 
Q. And what's that number, please? 
MR. SCAROLA: Cellphone number? 
THE WITNESS: 954-294-9544. 
Page 273 
BY MR. CRITTON: 
Q. Did you ever have a firm cellphone or just 
your own personal cellphone? 
A. No. Just my own personal cellphone. 
Q. During the time that you were at the firm, 
were you ever involved in making any type of a 
presentation to anyone regarding the Epstein cases? 
A. Including other lawyers within the firm? 
Q. Let me rephrase it. I am going to 
rephrase. You already told us that you have talked 
about the Epstein cases with other lawyers, correct? 
A. Right. 
Q. Were you ever present in a meeting where 
there was a person whom you did not know wherein the 
Epstein, where the Epstein cases were discussed? 
A. No. 
Q. At the, 0when you met with Mr. Rothstein 
in his office when Mr. Adler or whoever asked you to 
come up that one time and there was Adler, Rothstein 
and yourself, you said there was an individual on 
the phone? 
A. Right. It was another lawyer with the firm. 
Q. And how do you know it was another lawyer 
with the firm? 
A. It was either Marc Nurik ...

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Page 27 6 
A. I was never aware of any cases that Rothstein 
even handled much less settled. 
Q. Were you aware of whether, did anyone ever 
tell you whether Mr. Rothstein even did legal work 
at the firm or whether he was just a rainmaker? 
A. I -- no, no one ever told me one way or the 
other. 
Q. Would it be a correct statement that you 
never saw him perform any legal work during the time 
you were at the firm? 
A. That's a correct statement. 
Q. Would it be a correct statement as far as 
you knew he was kind of a gadfly going to his 
various business ventures and then he would hole 
himself up in the office. 
A. He was the guy on the billboards and at the 
Triple A arena and everything else marketing the firm 
and bringing business in, and that's at least what l 
believe he did. If it's true or not, I don't know to 
this day. 
Q. With regard to Exhibit 3, do you recognize 
this e-mail? 
A. I, l don't recognize the e-mail. 
Q. Do you recognize, and I will represent to 
you that I received the e-mail. It was sent to me 
Page 277 
as well although I am not shown as a recipient, I 
received e-mail. 
1HE WITNESS: Are you talking about the 
fa-x? 
MR. CRITTON: I am sorry, the fax. 
MR. SCAROLA: Exhibit, Exhibit 3. 
MR. CRITTON: Exhibit 3. Let me start 
again. Exhibit 3 is a fax. 
1HE WITNESS: Correct. 
MR. CRITTON: Dated July 22nd, 2009. 
1HE WITNESS: I recognize that. 
BY MR. CRITTON: 
Q. And do you recognize on Page 2, it says 
very truly yours, Rothstein, Rosenfeldt, Alder and 
then there is a, what appears to be a signature and 
under that it says Bradley J. Edwards, Esquire, 
partner fort (sic) the firm. Do you see that? 
A. Yes, I see that. 
Q. Do you recognize the signature? 
A. No. 
Q. Is that how you sign your name? 
A. No. 
Q. Do you know whose signature tha...

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Page 280 
Jeff Epstein. 
Q. Well, you also understood Mr. Epstein has 
had ongoing criminal law issues even during the time 
of the civil case, correct? 
A. No. 
Q. Sure. Well, you were aware that 
Mr. Epstein was operating under the nonprosecution 
agreement, that he was bound by the, a 
nonprosecution agreement, correct? 
A. I'm aware of the existence of a nonprosecution 
agreement. 
Q. Well, and in fact you came into possession 
of the nonprosecution agreement sometime in 2008 
because Judge Marra ordered that, ordered the United 
States Government to tum over to all of the 
attorneys and the clients who were listed as alleged 
victims, correct? 
A 
Yes. 
Q, So, you had possession of the N.P.A. as of 
sometime in the year 2008, correct? 
A 
Right. 
Q. All right. And so you, and you were aware 
that under the nonprosecution agreement Mr. Epstein 
was required to meet certain requirements, that 
Mr. Epstein had a requirement to meet certain 
Page 281 
standards or certain provisions of the agreement 
otherw:ise the U.S.A. could potentially declare there 
was a breach of the agreement, true? 
A. ! suppose. 
Q. Well, you're a former prosecutors too, so 
you knew what a nonprosecution agreement was, true? 
A No, I had never seen a nonprosecution 
agreement in my life before this one. 
Q. When you got the nonprosecution agreement, 
you reviewed it? 
A. Yes, I did. 
Q. So, you were familiar w:ith? 
A. Right. 
Q. And you understood from at least looking 
at the police report that you had access to, that 
Mr. Dershow:itz had represented Mr. Epstein with 
regard to negotiating his plea that ultimately was 
reached in negotiations w:ith the federal government, 
true? 
A. I knew he played a role. 
Q. Now, with regard to Mr., with regard to 
the depositions of -- well, let me ...

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Page 284 
MR SCAROLA: Same objection, same 
instruction. 
BY MR. CRJTTON: 
Q. Same question with regard to 
Mr. Dershowitz, former president Clinton, Tommy 
Mottola, David Copperfield, and Leslie Wexner. 
THE WITNESS: No. 
MR. SCAROLA: Same objection, same 
instruction? 
TI-ffi WITNESS: And with respect to Tommy 
Mottola, 1, that was not my firm that was a 
separate law firm that intended to take his 
deposition. 
BY MR. CRJTTON: 
Q. Who was it that you understood was taking 
Mr. Mottola's deposition? 
A. Searcy, Denney. 
Q. Did you ever discuss with Mr. Rothstein or 
anyone on his behalf the value of taking the 
depositions of Trump, Dershowitz, former president 
Clinton, David Copperfield, and Leslie Wexner as an 
inducement to get Mr. Epstein to settle his 
lawsuits? 
MR. SCAROLA: You have already inquired of 
Mr. Edwards about the communications that he 
Page 285 
had with Mr. Epstein. He has responded to 
those questions previously. So, any further 
questioning along those lines is entirely 
repetitious. 
BY MR CRJTTON: 
Q. Can you answer that question, sir? Would 
you like it read back? 
MR. SCAROLA: Beyond what he has already 
responded, we would object on the basis of 
work-product and attorney-client privilege and 
I instruct you not to answer. 
THE WITNESS: Okay. 
BY MR. CRITTON: 
Q. Were you involved in any of the decision 
to pursue obtaining flight data from Mr. Epstein? 
Well, let me strike that. Were you involved in the 
decision to pursue flight data associated with any 
planes that were purportedly owned by Mr. Epstein? 
MR. SCAROLA: I will allow Mr. Edwards to 
acknowledge whether he did or did not 
communicate about such matters with opposing 
counsel. But beyond that I would assert 
attorney-client and work-product privileges and 
instruct you not...

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you spoken with Officer Recarey prior to his 
deposition? 
A. One time. 
Q. And when was that? 
A. 2008. 
Q. What was the purpose of the -- let me 
strike that. Did you initiate the conversation or 
did he? 
THE WITNESS: Answer? 
MR. SCAROLA: You can answer that. 
THE WITNESS: I did. 
BY MR. CRITTON: 
Q. Okay. What was the purpose of your 
conversation? 
MR. SCAROLA: To the extent that the 
purpose of your conversation was unrelated to 
any pending legal matter, including in 
particular the claims against Mr. Epstein, you 
may answer. To the extent that it had anything 
at all to do with Mr. Epstein, you should not 
respond on the basis of privilege. 
THE WITNESS: Privilege. 
BY MR. CRITTON: 
Q. Did you ever speak with Chief Reiter at 
any time -- well, let me strike that. You were not 
Page 289 
at his deposition, were you? 
A. No. 
Q. Okay. Have you ever spoken with Chief 
F ... eiter at any time for any purpose as !t relates to 
Mr. Epstein? 
TIIE WITNESS: Answer? 
MR. SCAROLA: Only to the extent that --
well, you asked specifically whether the 
conversation related to Epstein? 
TIIE WITNESS: Did the conversation occur 
is the question. 
MR. SCAROLA: Relating to Epstein. Read 
the question back if you would, please. 
MR. CRITTON: Let me rephrase it. 
MR. SCAROLA: Okay. 
BY MR. CRITTON: 
Q. With regard to Chief Reiter, have you ever 
spoken with Chief Reiter or now former Chief Reiter 
from the Palm Beach Police Department for any 
reason? 
MR. SCAROLA: You can answer the "for any 
reason" part. 
TIIE WITNESS: No. 
BY MR. CRITTON: 
Q. Have you ever testified in a grand jury 
Electronically signed by cynthia hopkins {601-051-976-2934) 
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Electronically signed by cynthia hopkins (601-051-976-2934) 
...

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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. CRJTTON: 
Q. Did you ever have a conversation or 
communication 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. J 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 
him. 
Q. In the particular instance that you got 
Page 293 
called up to his office, Mr. Adler was present along 
with Mr. Rothstein and either Mr. Nurik or somebody 
else who was.on the phone, correct? We already 
e,st<ihlish"rl thcit? 
A. Correct. 
Q. From your observations and or your 
conversations with Mr. Adler, did you get the 
impression that Mr. Adler could have or would have 
access to Mr. Rothstein? 
:MR. SCAROLA: By that I assume you mean 
unfettered access? 
MR. CRITTON: No,just easy access. 
Unfettered suggests someone can walk in and out 
of the office and you already told me it was a 
compound. Let me reask my question. 
BY MR. CRITTON: 
Q. From what Mr. Adler told you, if you had a 
conversation with Mr. Adler about a particular, 
whether it was an Epstein case or another case, was 
it your understanding that Jvfr. Adler had regular, 
some form of regular communication with 
Mr. Rothstein? 
A. No. 
Q. Okay. Did you understand that ...

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Page 296 
A. J believe so. 
Q. Were you still a State Attorney when 
Mr. Jenne was indicted and then eventually ended up 
in jail? 
A. No. 
Q. Were you in private practice at that 
point? 
A. Con-ect. 
Q. But you lived then in Broward County, so 
you followed the developments ofMr. Jenne's 
downfall in becoming a convicted felon? 
A. I was aware. 
Q. All right. Was Mr. Jenne, would it be a 
correct statement that Mr. Jenne and Mr. Fisten and 
Mr. Roberts were all at the RRA finn when you 
started in April of'09? 
A. I don't believe so. 
Q. Which one was there when you started? 
When I say "there," was already employed by RRA when 
you started? 
A. I am not sure if any of the three were there 
but perhaps all of them were there. 
Q. All you !mow is at some point you came to 
be involved with them as investigators? 
A. Correct. 
Page 297 
Q. All right. With regard to Mr. Jenne, was 
his office on the same floor as yours? 
A. No. 
Q. \1/here, \Vas his office in a.TJ.y \Vay near 
Mr. Rothstein's? 
MR. SCAROLA: What does any way near Mr. 
Rothstein's mean? 
MR. CRITTON: Same floor. 
1HE Wl1NESS: No. 
BY MR. CRITTON: 
Q. Did it appear to you that -- well, let me 
strike that. You said that Mr. Jenne had something 
to do with investigation, correct? 
A. Correct. 
Q. Okay. Did he ever describe for you what 
he did for the firm? 
A. No. 
Q. And I think you said, did you say what his 
title was? 
A. I didn't know his title. I don't know what 
his title is now. 
Q. Did you ever ask IV!r. Jenne why he was 
asking you questions about the Epstein case or 
engaging you in a dialogue regarding the Epstein 
cases? 
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Page 300 
represents multiple Rothstein related investors. He 
indicated in an article that RRA, slash, Rothstein 
had used the Epstein ploy as a showpiece, as a 
showpiece, as bait. That's, and the quote is, 
Epstein ploy, as a showpiece, as bait. That's the 
way he raised all the money. 
He would use cases as bait for luring 
investors into fictional cases. All the cases he 
allegedly structured were fictional. l don't 
believe there was a real one there. 
Okay. lfl asked you to assume that that 
quote is accurate from Mr. Scherer, would it be a 
correct, would it be a correct statement -- well, 
let me strike that. 
Were you aware that Rothstein and other 
individuals were using the Epstein ploy; that is, 
the Epstein cases in order to, as bait in order to 
raise money for, for the firm and Mr. Rothstein? 
MR. SCAROLA: I am going to object to the 
form of the question, but you can certainly 
answer it. 
THE WITNESS: Okay. I am going to answer 
it to the extent that l understand it. No, I 
was not aware that the Epstein cases were being 
used as a showpiece, as bait. But you are also 
Page 301 
asked me to assume that the statement that you 
have injected as Paragraph 20 of the complaint 
is true and it begins with, or ends with I 
don't believe there \Vas a real one i.11 tl-iere, 
talks, speaking as to all the cases. And you 
know and I know that that statement is 
absolutely false in that you know each and 
every one of the claims that have been asserted 
against Mr. Epstein related to his molestation 
of children, they are all true including the 
three that I have against Mr. Epstein. 
So, if you're asking me to assume that 
this is it true, no, l did not know that they 
were being used for anything. 
BY MR. CRITTON: 
Q. Okay. Well, as to whether l\1r. Scherer w...

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Page 304 
A. Weissing. 
Q. Or RRA, Mr. Howell, or Mr. Cassell have 
any interest in those cases? 
A. No. 
Q. At any time -- let me strike that. You 
are aware that Mr. Alfredo Garcia has pied guilty to 
an obstruction of justice charge based on the news? 
A. I don't know Alfredo Garcia at all. 
Q. Sony about that. The head of Alfredo 
Garcia. With regard Mr. Rodriguez, Alfredo 
Rodriguez, are you aware through news reports that 
he pled guilty to obstruction of justice? 
A. Yes. 
Q. At any time have you been given access to 
the pamphlet book and/or any of the yellow pages 
that have been referenced in the criminal 
indictment? 
MR. SCAROLA: I am going to instruct you 
not answer that question on the basis of 
attorney-client and work-product privilege. 
BY MR. CRITTON: 
Q. Has the, have you been, have you had any 
contact with the criminal defense lawyer for 
Mr. Rodriguez? 
MR. SCAROLA: You can answer yes orno. 
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Page 306 
the information that is held by the FB1 which would 
include the pamphlet and the yellow, the pamphlet 
and the yellow pages, true? 
A. I have. Adam Horowitz has, and I may or may 
not have piggybacked his motion. But as sitting here 
right now, I, I don't remember drafting that motion. 
Q. Are you sure he hasn't piggybacked your 
motion? 
A. I'm not sure. If you show me my motion, I can 
tell you whether I drafted it or not. 
Q. Have you --
A. That, that was certainly an idea. 
Q. Have, have you also -- you have also 
served a motion to obtain FBI files that relate to 
Mr. Epstein; is that correct? 
A. Correct. 
Q. Okay. Have you spoken as a result of the 
motion that you filed, has the government, have you 
spoken with the United States Attorney's Office or 
representatives for the FBI with regard to the 
motion which you filed? 
MR. SCAROLA: Ob...

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Page 308 
videotape deposition of Scott Rothstein. The 
time is --
THE WITNESS: Whoa, whoa. 
THE COURT REPORTER: Yes. Bradley 
Edwards. 
THE WITNESS: Please don't lump me in with 
that guy, man. 
MR. SCAROLA: This concludes the 
deposition ofMr. Bradley Edwards. 
THE VIDEOGRAPHER: Oh, I'm sorry. This 
concludes the deposition ofMr. Bradley 
Edwards. The time is 5:07 p.m. 
(A discussion was held off the record.) 
THE COURT REPORTER: Did you want to order 
this? 
MR. CRITTON: Ask me tomorrow. 
MR. SCAROLA: I will take a copy ofit. 
Let's stay on the record. We don't need to be 
on the video record but I want to make the 
statement that we would consider it entirely 
inappropriate for any portion of this 
deposition to be used for any reason whatsoever 
that is not directly connected with the 
prosecution of the pending claim against 
Mr. Edwards or the defense of the 
Page 309 
counterclaims. Thank you. 
MR. CRITTON: Bye. 
MR. SCAROLA: Bye. 
(VVitness excused.) 
(Deposition was concluded.) 
Electronically signed by cynthia hopkins (601-051-976-2934) 
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Page 310 
CERTIFICATE OF OATH 
11--IE ST A TE OF FLORIDA 
COUNTY OF PALM BEACH 
I, the undersigned authority, certify that 
BRADLEY J. EDWARDS, ESQUIRE personally appeared 
before me and was duly sworn on the 23rd day of 
March, 2010. 
Dated this 5th day of April, 2010. 
Cynthia Hopkins, RPR, FPR 
Notary Public - State of Florida 
My Commission Expires: February 25,201 I 
My Commission No.: DD 643788 
CERTIFICATE 
THE STATE ...

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DATE: 
April 5th, 2010 
TO: 
BRADLEY J. EDWARDS, ESQUIRE 
c/o Jack Scarola Esquire 
SEARCY,DE~'J\~Y,SCAROLA, 
BARNHART & SHlPLEY, P.A. 
2139 Palm Beach Lakes Boulevard 
WeSl Palm Beach, Florida 33409 
IN RE: 
Epslein vs. Rothstein 
CASE NO.: 50 2009CA040800XX,'<XMJ3 AG 
Please take notice that on Tuesday, the 23rd of 
March, 2010, you gave your deposition in the 
above-referred matter. At that time, you did not 
waive signature. It is now necessary that you sign 
your deposition. 
As previously agreed to, the transcript will be 
furnished to you through your counsel. Please read 
the following instructions carefully: 
At the end of the transcript you will find an 
errata sheet. 1-'.s you read your deposition, any 
changes or corrections that you wish to make should 
be noted on the errata sheet, citing page and line 
number of said change. DO NOT write on the 
transcript itself. Once you have read the 
transcript and noted any changes, be sure to sign 
and date the errata sheet and return these pages to 
me. 
lfyou do not read and sign the deposition 
within a reasonable time, the originaL which has 
already been forwarded to the ordering attorney, may 
be filed with the Clerk of the Coun. If you wish 
to waive your signature, sign your name in the blank 
at the bottom of this letter and return it to us. 
Very truly yours, 
~~~,LS 
Cynthia Hopkins, RPR., FPR 
I do hereby waive my signature. 
BRADLEY J. EDWARDS, ESQUIRE 
CERTIFICATE 
THE STA TE OF FLORIDA 
rrnTNTY nFPAT MRRAf'.H 
Page 312 
Page 313 
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. 
12 
Dated this __ day of _______ 
~ 
13 
2010, 
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IN THE CIRCUIT COURT OF THE 
FIFTEENTH JUDICIAL CIRCUIT IN 
AND FOR PALM BEACH COUNTY, 
FLORIDA 
GENERAL JURISDICTION DIVISION 
JEFFREY EPSTEIN, 
vs. 
Pl 
' 
t-'-F,... 
~~aln~l~I, 
No. 502009CA040800XXXXMBAG 
SCOTT ROTHSTEIN, individually, 
and BRADLEY J. EDWARDS, 
individually, 
Defendants. 
I 
--------------------
500 East Broward Boulevard, 
Ft. Lauderdale, Florida 
Thursday, June 14, 2012 
0 -lA 
~ m 
-
1°-~, ~ m 
.J. 
":I 
a..ll • 
L 
• ...J 
I 
_t.J•ll. 
D E P O S I T I O N 
Of 
SCOTT ROTHSTEIN 
(Via Video Conference) 
Taken on behalf of the Trustee 
pursuant to a notice of taking deposition 
EXHIBIT 
G 
FRIEDMAN, LOMBARDI & OLSON 
305-371-6677 
5ed93085-0554-447f-bcdd-ca2d8fe941 di 

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APPEARANCES: 
2 
LAW OFFICES OF TONJA HADDAD, P.A. by 
3 
Tonja Haddad, Esq. 
At1omey for the Plaintiff. 
4 
5 
ATTERBURY, GOLDBERGER & WEISS, P.A., by 
Jack Goldberger, Esq. 
6 
Attorney for the Plaintiff. 
7 
SEARCY DENNEY SCAROLA ET AL, by 
8 
Jack Scarola, Esq. 
Attorney for the Defendant, Brad Edwards. 
9 
1 o 
MARC NURJK, P.A., by 
Marc Nurik, Esq. 
11 
Artomey for Scot1 Rothstein. 
(Appearing via Video Conference.) 
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U.S. ATTORNEY'S OFFJCE, by 
Laurence La Vecchio, Esq. 
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Attorney for the Departmen\ of Justice. 
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JNDEX 
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WI1NESS 
DlRECT CROSS REDIRECT RECROSS 
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SCOTT ROTI!STEJN 
(By Ms. Haddad) 
5 
(By Mr. Goldberger) 92 
(By Mr. Scarola) 
]21 
PLAJNTIFFS 
l 
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EXHIBITS 
64 
69 
72 
FOR IDENTIFlCA TION 
Page 
Thereupon: 
SCOTT ROTHSTEIN, 
was called as a witness and, having been duly sworn, 
was examined and testified as follows: 
THE WJTNESS: l do. 
MS. HADDAD: Good morning, Scott. How are 
you? 
THE W]TNESS: Good morning, Tonja. How are 
you? 
MS. HADDAD: Fine, thank you. Jt's nice to 
see you. 
THE WJTNESS: Good to see you, too. 
MR. SCAROLA: Mr. Rothstein,] don't know 
that you and] have met. J'm Jack Scarola, J'm 
representing Brad Edwards and ] know you know Brad 
who's to my immediate left. 
THE WJTNESS: Hey, Brad, how are you? 
Jack, good to see you. 
MR. SCAROLA: Thank you. 
MR. GOLDBERGER: Also present is another 
Jack, Jack Goldberger, and] also represent Jeffrey 
Epstein. To my right is Darryn lndyke --
THE WITNESS: Good morning, Jack. 
MR. GOLDBERGER: How are you today? 
And to my right is Darryn lndyke, who is 
Page 4 
Mr. Epstein's in-house counsel. 
MR. lNDYKE: Good morning. 
THE WJTNESS: Good morning, sir. 
MR. NURJK: Good morning, everyone. 
MR. GOLDBERGER: Hi, Marc, how are you? 
MR. NURJK: Good. You'll be seeing my 
shoulder most of the day. 
MR. GOLDBERGER: Okay. ...

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different form than it ended because it started as 
bridge loans and things of that nature, and then 
morphed into the Ponzi scheme. But you are looking 
back into the 2005 time frame for the very beginning. 
Q. The 2005 time frame, that's when the bridge 
loans started? 
A. I can't be certain exactly what we were 
doing. I need to see all the documents to tell you 
what we were doing at what specific point in time. 
Q. What made you decide to start doing this? 
A. ] started doing it out of greed and the need 
to support the law finn, which was having significant 
financial trouble at the time. 
Q. And in 2005 had you moved over to 401 yet or 
were you still in the building where Colonial Bank 
was? 
A. ] don't remember. 
Q. Do you recall approximately how many 
attorneys you had working for you when it started? 
A. l do not. Between five and ten, Tonja. 
Q. Was it before you started acquiring 
attorneys like you were acquiring cars and watches? 
MR. SCAROLA: Object to the form of the 
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growth started," do you mean both the scheme - do you 
mean the scheme and the firm or either one or both? 
A. Both. 
Q. Do you recall approximately when you took 
the space in the 401 Building? 
A. l do not. 
Q. At the time everything imploded, how many 
partners did you have at the firm, do you recall? 
A. Are you saying partners and shareholders? 
Because remember, we had both, two designations. 
Q. 1 want to start with just attomeys that 
had -- not in your firm name but named as "partner" on 
the cards, for example. 
A. J'd have to see a list of all the employees. 
We had a bunch. 
Q. Do you recall about how many attomeys you 
had working there? 
A. Approximately 70. 
Q. In the year before, do you reca1 l how many 
you had? 
A. 1 do not. 
Q. So how many equity partners did you have or 
shareholders?...

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Q. When you were hiring and bringing in all 
these new attorneys, did everyone come in as a 
partner? 
A. No. 
Q. How did you decide who came in as a partner 
and who came in as an associate? 
A. Depended upon their level of expertise, 
practice, book of business. 1t was a decision Stuart 
and ] made together on a case-by-case basis. 
Q. So you and Stu where the - were in charge 
of hiring? 
A. Stuart and l tried to consult on every 
hiring decision, yes. 
Q. Did you guys also decide salaries? 
A. l generally decided the salary and then Jet 
Stu know what 1 was going to do. And he would say if 
he thought it was okay or if he thought it was too 
much or too little, but l generally had free reign in 
that regard. 
Q. Did someone's book of business directly 
correlate to the salary that you would offer? 
A. That is a very broad question because it 
depends upon what other needs we had for that 
individual. 
Q. What do you mean by "what other needs"? 
Page 10 
Q. Would you need to look at someone's book of 
business if they were coming in just solely to be a 
rainmaker for the finn prior to hiring them? 
A. I discussed it with them. There were not 
many people that ] recall that l actually looked at 
their nwnbers. Once David Boden was working for me I 
had him check people's nwnbers, but I rarely looked. l 
took most people's words for what they were 
generating. 
Q. My recollection is, you were always looking 
to bring in more people, to hire more people, some of 
us were somehow able to resist you while others were 
not. How would you decide who you were looking at to 
bring into your firm? 
A. We were trying to develop, on the legitimate 
side of the law firm, we were trying to develop real 
talent, real practice groups. l mean, Brad is a 
perfect example, great lawyer, got a great reputation. 
~You know, it was our hope that, you know, he was goin~ 
...

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I; 
g 
Q. Okay. When you were looking at peoole t<2 
~ 1 
that time with Fanner and Fistos and Jaffe and 
~ 
bring in to the finn to legitimize, as you said. Your 
,. 
2 
Mr. Edwards. 
firm had a very unique area of practice and had a very 
i 3 
Q. Do you know where Mr. Edwards was working 
unique environment to which to work. _How did you know 
~ 4
5 
when you first learned of him? 
or how did you come to decide what people may or may 
~ 
A. l don't recall whether he was working for 
Tiot fit into that? 
~ 6 
someone or had his own practice, l don't recall. 
A Okay. Hang on one second. 1 think you just 
! 7 
Q. When did you first learn abou1 Brad? 
accidentally misstated my testimonY., 
~ 8 
A 
l don't remember the time frame. 
I was not bringing the peoJ)le in to 
~ 9 
Q. Do you recall when you first met with him 
" 
legitirm.ze the law firm. I was bringing them in to 
~ 10 
regarding a job? 
the legitimate side of the law firm. The bulk of the 
~ 11 
A. No. The easiest way to figure that out is 
law firm, despite the lack of financial success, was a 
~ 12 
to go look at his personnel file, jt will have the 
P. 
large group ofve:r; honest, hard working lawyers 
ij 13 
notes saying when he met with me the first time. 
trying to do their best in difficult economic 
114 
Q. You don't have any recollection of your 
conditions. There were some that were obviously not 
i 15 
first meeting with him? 
legitimate. And the way I decided to bring people in, 
I 16 
A. No. As you know, l was hiring people left 
again, it's really everything I just told you. Are 
I 1 7 
and right and l was also unfortunately very busy doing 
you looking for how 1 brought people into the Ponzi 
i 1 8 
things 1 shouldn't have been doing, so l don't have a 
scheme? 
ff 19 
specific recollection of when I hired him. I barely 
Q. No, right now l'm just asking about the firm 
D 2 0 
have a ...

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unfortunately, you are taking a little tiny spot out 
of a very, very busy time period in my life and in the 
life of the :firm, so 1 can't tell you one way or the 
other. 
Q. 1 know you had a lot going on, J'm just 
trying to see if you remember anything specific about 
this. 
Do you recall what salary you had offered 
Brad to come join the firm? 
A. J do not. You have to just try to 
differentiate that what I knew then is a lot different 
than what I know now so ... 
Q. Meaning? 
A. Obviously meaning that at the point in time 
that I was hiring him or maybe a yeaT after, I would 
be able to tell you what I was paying him, but now 
it's insignificant. l don't remember how much I was 
paying him. 
Q. Did you learn about his book of business or 
know what kind of cases he was bringing in prior to 
-hiring him? 
A. J do know that he - I discussed either with 
Russ, well, ] know with Russ, and perhaps some other 
people, I knew about the Epstein case. 
Q. What did you know about it? 
ii " g 1 
A. Epstein was a billionaire. 
I 2 
Q. Okay. Did you know anything about the 
N 3 
legitimacy or illegitimacy of the claims prior to 
! 4 
knowing he was a billionaire? 
~ 5 
A. I knew what 1 was told. 1 didn't check it 
I 6 
out myself, but 1 trusted the people that told me. 
I 7 
Q. And who to]d you? 
g 8 
A. The only person J remember discussing it 
~ 
F. 
9 
with. as J sit here today, is Russ Adler. But if 
I 10 
Farmer and Jaffe and those guys were ~e at the 
~ 11 
time. 1 likely would have discussed it with them as 
~ 12 
yvell, 
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Q 
S 
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ff 
__, 
. 
o were you aware 01 t 1is case before you 
~ 14 
made an offer to Brad to join the firm? 
!is 
A.~ 
i 16 
Q. You said you didn't -- J don't want to 
11 7 
misquote you. You said you heard about it from other 
~ 18 
people, but you didn't do anything to know that 
I 19 
personally. Was that before you made th...

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IT 
Q. You didn't keep track of it? 
~ 1 
!: 
A. l did not keep track of it. From time to 
8 2 
time Russ and the other guys in the tort group would i 3 
tell me what was going on in certain cases, but until 
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] made a decision to utilize that file for an ille@l 
ff 
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,, 
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purpose related to something illegal that I was doing 
B 6 
along with my co-cons2irators1 1 just assumed my 
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la~ers were going to work the case and eventually it I 8 
';,ould ho12efuJly work out well for the law firm. 
i 9 
Q. At your firm, when e-mails would go out to 
ho 
~ 
attorneys at RRA or all attorneys at RRA, were you 
fi11 
part of that e-mail group? 
h2 
?. 
A. You are talking about all staff? 
~13 
~ 
No, all it says is attorneys at RRA. 
" 
Q. 
!l 14 
ii 
A. It's the e-mail group "attorneys"? 
ti 15 
~ 
Q. Yes. 
H6 
A. Yes, J'm a part of that e-mail group. 
In 
Q. And 1 appreciate that you were very busy and 
b0 
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may not have read all of them, but you did receive 
D9 
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those e-mails when they would go around? 
Ii~, 20 
A. Yes, and l tried my best to read them. 
·21 
Q. Okay. At what point did you decide to use 
122 
~ 
this case to further your Ponzi scheme? 
i23 
A. J don't remember the date, but I can give 
b4 
F. 
you the circumstances, if you'd like. 
bs • 
Page 22 ~ 
.. 
,-.... ~-
Q. Please do. 
1 
A. The Ponzi scheme was running ve!}'. low on 
2 
capital. My co-conspirators and I needed to find a 
I 3 
new feeder fund, new investment sources. We had a 
• 4 
couple of very large, significantly wealthy potential I 
5 
investors out there. I was looking for something that 
6 
would have been very attractive. We had had a lot of 
7 
inquiry during the due diligence period with these 
! 8 
people that were doing due diligence on the putative 11: 
cases t...

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what was going on. And ] may have spoke to him, ] 
know I spoke to Russ, but l may have spoke to him as 
well within a couple of days just prior to this due 
diligence because ] was trying to at least get some 
information in my head that I could use when l was 
creating this story for the investors. 
Q. Scott, what's Q-task? 
A. Q-task is a web based software system that ] 
had invested $7 million in. 
Q. And what was the purpose of this internet 
system? 
A. To be able to communicate in a secure 
~ ,, 
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and with that, with the Q-task and the e-mails, did 
someone assist you with reviewing everything and 
Jetting you know what was going on within the groups? 
MR. SCAROLA: Excuse me, l'rn going to 
object to counsel's testimony. Object to the fonn of 
the question as leading. 
THE WJTNESS: 1 really don't even 
understand the question. 
Can you try to rephrase it for me, Tonja? 
BY MS. HADDAD: 
Q. Of course, 1 would. 
Did you keep abreast of everything that was 
ri 12 
~ 
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fashion ai1d in a unique group fashion about specific 
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going on in every practice group or was someone 
1 4 
files. 
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through Q-task and e-mails, for example, or was 
ij 
15 
Q. So forgive me, we all know l'm not good with 
a 15 
someone giving you information keeping you posted on 
16 
the computer. That was something that would be useful 
116 
what was going on within the practice? 
1 7 
within a law firm, why? 
ff 1 7 
A. Well, as part of the tort group I had a 
18 
A. Because it allowed you to create groups and 
W 18 
pretty good idea of what was going on there all the 
19 
have both general and private chats, organize data in 
! 19 
time just because of the significant amount of 
2 0 
a very unique fashion. That was, at least to our way 
I 2 0 
interaction, both legitimate and otherwise, that l had 
21 
of thinking, would have been very, very he...

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had audio and/or video surveillance? We'll start with 
i) 
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audio. 
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l: 
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A. I don't have a specific recollection of 
I 3 
every place 1 had video and audio, but it was in - l 
~~ 
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had it set up so that in all of the common areas, 
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including our shareholder's lounge, we had -- 1 had 
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audio and video capabilities. 
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Q. When you say "capabilities," does that mean 
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you didn't always turn it on or you just turned it on 
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when you felt like it? 
no 
ii 
A. I turned it on when l felt like it, when 1 
~ 11 
felt like seeing what was going on. l sometimes left 
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t'Je screen up because l had fom computer screens on 
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my desk, 1 sometimes left the screen on with the video § 14 
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of the reception area and some other general areas. 
ll15 
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But unless I wanted to see what was going on or listen h6 
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to what was going on, 1 didn't turn it on. It would 
~ 17 
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have been too distracting. 
;18 
Q. Did the attorneys know that this 
il9 
surveil1ance existed? 
120 
A. You can see it in the -- it wasn't hidden, 
ij 21 
you can see it. There were globes up in the ceiling 
~22 
all over the office. 
123 
Q. Did you have -you said --you didn't 
24 
answer this, you said you didn't recall. Did you have 
25 
Page 30 
= 
any surveillance in the conference rooms? 
1 
A. No. 
2 
Q. Other than the com71on areas you just went 
i! 
3 
" 
i 
over, in the hallways and the reception -- did you 
I 4 
have it in the hallways, is that a common - do you 
~ 5 
deem that a common area? 
I 6 
A. All the hallways pretty much with the 
i 7 
exception of a few blind spots, l can see all the 
I 8 
hallways. 
I 
9 
Q. And this was on all three floors? 
10 
A. Yeah. For some reason l think we might 
11 
have taken some space o...

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A. He had had significant - as you know, he 
I l 
know, having -- there were mixed reasons. For 
also had significant political connections and 
~ 2 
example, I -- are you talking about my Fort Lauderdale 
everyone who is not living under a rock knows l was I 3 
police detail? 
doing everything] could to gamer significant 
~ 
4 
Q. Yes. You had it at the office and at your 
political power. 
l! 
5 
home, correct? 
Q. ] think many people miss your parties. 
g 6 
A. Yeah. There's a myriad of facts that 
But, with respect to Mr. Jenne and his 
@ 7 
motivated me to do that. One was that I really wanted 
TI 
political connections, were you hiring him to utilize 
~ 8 
the security for the office. Two was, 1 was paranoid 
him with respect to any of the police department 
i 9 
and this is in no particular order. Three was the 
investigations? You had stated earlier you had 
~ l O 
Melissa Lewis murder that shook the entire law firm 
dealings with police departments. J don't want --
! 11 
and shook me tenibly. ] didn't want that to ever 
again, J don't want to put words in your mouth. You 
i 12 
have to happen again. And four was, l wanted -- the 
said you had dealings going on with various police 
~ 13 
more iaw enforcement you have around, the 
agencies? 
I 
1 4 
more legitimacy it adds to you and your appearance to 
A. J had - I mean, we had a criminal defense 
t 1 s 
the community. So there were a multitude ofreasons. 
section in the law firm, so we had legitimate dealings I l 6 
l mean, I hired certain law enforcement to 
with law enforcement. But I also had significant 
; 1 7 
work for me that were just friends of mine that 
illegitimate things with law enforcement that had 
I 18 
were -- that needed additional money, so I wanted to 
nothing to do with Ken Jenne. 
§ 19 
make sure that they had money, both guys that did the 
Q. And how about with respect to fo...

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A. l talked to Russ Adler. l may have talke__g 
to some of the other lawyers. l flipped through 
~ertain boxes in the file. 
Q. How did you get the boxes? 
A. I asked someone to bring them to me. 
Q. Do you know where those files were stored? 
A. 1 do not. 
Q. So you flipped -- sorry, please continue. 
Flipped through some files? 
A. ] flipped through some files. l had the 
files in my office. The day that the investor group 
came in, J actually had Ken Jenne and some others 
actuaiiy bring me some more of the boxes actually into 
-my office while the investors were there. l already 
had some of the boxes with me. 
Q. You say "Ken Jenne and others," who were tl1e 
others to whom you are referencing? 
A. l don't specifically recall who carried them 
in. l was very focused on my investors at that time. 
Q. Were any of the lawyers present with you 
when you were meeting with these investors? 
A. During the actual meeting with them, no. l 
recall tllat some of the lawyers may have met some of 
the investors, but I don't recall who. 
Q. Do you recall approximately when that 
Page 38 
happened? 
A. No, it's the same dates that I was giving 
you before. 
Q. Okay. So you had, to further your Ponzi 
scheme, you had to familiarize yourself with this case 
so that you could speak intelligently with the 
investors; is that correct? 
A. Well, sort of because most of what I told 
the investors was all things that I was creating as I 
~ 
Q. A bout this particular case, the Epstein 
case? 
A. Yes, from an investor - you have to 
understand how the inner working of the Ponzi scheme 
were crafted but -
Q. Please tell me then. 
A. I'm telling you -- hang on. From an 
investor's standpoint2 the investor is simpl}'. looking 
for is the case believable. And once they get p~ 
that, is it o...

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R 
to you? 
E 1 
if 
A. Because of who was on it. 
n 2 
p, 
Q. Who was on it? 
f1 
3 
A. l don't recall, but l do recall saying to 
n 4 
r; ., 
the investors -- l recall having a conversation prior 
K 5 
~ 
to the investors coming in with Russ Adler and Russ 
ll 
6 
• 
had told me that Epstein had flown Bill Clinton on his 
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~ 
plane, had flown Prince Andrew on his 12lane.~ 
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" 
,, ,, 
don't remember whether that was on any of the flig!1t 
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manifests or not, but l left that to the investors' 
~10 
• 
imagination as to what they were being told about 
~11 
Mr. Epstein and these other famous people that were 
112 
cavorting with lV'.rr. Epstein and Jet them look at the 
~l..., 
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file. 
9.14 
You have to understand from an investor's 
115 
perspective -- hang on. From an investor's 
!16 
Ii 
Eers2ective the only thing that matters to the 
p7 
gwestor is that it's a real case and that they can 
h0 
verify that real dollars are being :Qaid. The fact 
h9 
that it was a real case was evident, I had a lot of 
20 
boxes with real :rzleadings in it and a lot of other 
21 
information in it. The fact that there was real money 
22 
being :rzaid was a fiction that was created by me and my 
23 
-Zo-conspirators1 eveaone from bankers, to com12uter 
24 
ieople. So the a~tual role of the case, and I want to 
25 
Page 42 
A. I went back to selling the Ponzi deal. 
Q. And did you sell it? 
A. I believe I did. You'd have to look at the 
actual settlement documents to see ifl put one 
together for that, but I'm pretty sure we did. 
Q. Do you recall if the investors asked you for 
any additional information or any additional 
documentation? 
A. I don't recall one way or the other. 
Q. After this initial meeting with the 
investors, did you give any direction regarding this 
particular case? 
A. To whom? 
Q. To any of the attorneys working on the 
Epstei...

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their book of business. This being said,] was 
2 
bringing in )egitimate Ia~ers to fonn legitimate 
3 
..eactice irrouns to practice legitimate law, having 
4 
rothing to do with the Ponzi scheme. 
5 
Q. During the year 2009, were there any, to 
6 
your knowledge, any big settlements of any cases at 
7 
RRA? 
8 
A. To the best ofmy reco1lection, no. We had 
9 
a dismal year. 
10 
Q. The year 2009 was just dismal across the 
11 
board? 
12 
A. Some people did better than others, but yes, 
13 
overall it was for a finn of 70 lawyers, it was 
14 
dismal. 
15 
Q. So there were no big wins coming into the 
16 
finn as far as a financial windfall other than from 
17 
your other businesses? 
18 
A. The only significant capital coming into the 
19 
finn was money my co-conspirators and 1 were stealing. 
20 
Q. Was there any particular practice group that 
21 
you can remember that had a particularly non-dismal 
22 
year in 2009? 
23 
A. Mr. Nurik had a good year. 
24 
Q. Do you recall what the gross revenue was 
25 
from legitimate sources in 2009? 
Page 46 
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121 
p2 
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·25 
Q. For the most part. 
What wasn't fronted by the law firm? 
A. ] recall there being a couple of agreements 
that various tort lawyers had with certain clients 
where they were going to assist in helping to pay the 
costs. All the other costs would have been paid by 
the law firm, both through legitimate and illegitimate 
means. 
Q. So when you say by "illegitimate means," 
where would the illegitimate means money come from? 
A. It came from the Ponzi scheme, and all the 
tentacles of the Ponzi scheme, other illegal activity. 
Q. Such as? 
A. Things 1 was doing with law enforcement, 
things l was doing in politics, things that I was 
doing with organized crime, things ] was doing with 
politicians, judges, othe...

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" 
of 2009 about the Epstein meeting and some additional 
investigation into the Epstein case. 
Does that refresh your investigation as to 
when you met with the investors in the 
Discala/Clockwork Group? 
A. lt does not. The best thing to refresh my 
recollection as to when l met with them would be to 
see the deal documents. 
Q. Okay. l unfortunately don't have those. 
Do you recall if you took Discala and his 
other investors to a football game in 2009? 
A. Sure, l did. 
Q. Okay. Would that be around the time you 
were trying to get them to invest in the case? 
A. lt would have been around the time] was 
trying to get them to invest in general. lt's may 
have been around the time that l was showing them the 
Epstein file. 
Q. Did you show them any files other than the 
Epstein file? 
A. ] may have. l don't have a specific 
recollection one way or the other. 
Q. You testified earlier that you had over a 
dozen boxes brought to your office that were related 
to the Epstein case. 
Page 50 
~ 
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A. I don't recall. 
Q. Did you check? 
A. l don't remember one way or the other. 1t 
was insignificant to me, 
Q. Well, then explain to me. You testified 
earlier that what was important to the investors to 
see is that there was a real case, correct? 
A. Yes. 
Q. What did you look at or show them -- what 
did you look at, first of all, to see if it was, in 
fact, a real case? 
A. l knew it was a real case. 
Q. How did you lrnow? 
A. Because my lawyers told me it was a real 
case. l believed them. 
Q. What lawyers told you that? 
A. l already told you it was a mixture of Russ 
and Jaffe and Fistos and Farmer and Mr. Edwards. 
mean, l knew it was a r...

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i~ 
A. No. 
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case or any communications --
Q. Who is Cara Holmes? 
I 2 
A. 1 may have. 
A. Who is who? 
~ 3 
Q. Do you recall when that --
Q. Cara or Cara, C-a-r-a, Holmes? 
i 4 
A. 1 may have. 
5 
A. To the best of my recollection, she was a 
~ 5 
Q. Do you recall when that may have happened? 
fi 
6 
former FBl agent or maybe JRS agent. ] don't know. I 6 
A. l do not. 
7 
She was a former federal agent. 
~ 7 
Q. Do you recall the first time you looked at 
Q. Did you hire her to work for you? 
~ 8 
the flight manifest to which you referenced earlier? 
8 
9 
10 
A. It was either JRS or FBI. 
i 9 
A. Prior to the investors coming in. ] don't 
Q. Did you hire her to work for you? 
ij 10 
remember the date. 
11 
A. Yes, I hired her at the suggestion ofKen 
i 11 
Q. Did you instruct anybody, to further your 
12 
Jenne. 
;, 12 
Ponzi ~cheme, to investigate or check into anyone 
13 
Q. For what pui µose? 
~ 13 
whose name was listed on the flight manifest? 
• 
14 
A. To work in the group that he was overseeing. 
!l 14 
A. 1 may have, but with this clarification." If 
15 
Q. So what did she do for RRA while she was 
i 15 
l instructed someone to look into something, 1 did it 
1 6 
there? 
~ 16 
without that person knowing that 1 was involved in a 
A. 1 don't remember. 
i 1 7 
Jonzi scheme or that what they were doing was illegal 
17 
18 
Q. Did you ever mention her to your potential 
g 18 
and it was just to get me additional information to 
19 
investors from the Clockwork group? 
S 19 
help with my sale of the fake settlements. 
20 
A. It's a possibility because, as] was 
j 2 0 
Q. So it was to further your-~ 
21 
building the Ponzi scheme, I frequently referred to 
~ 21 
A. So 1 may have asked someone -- l may have 
2 2 
the fact that we had former state and federal law 
D 2
2 
2
3 
asked someone to get me some additional information, 
2 3 
enforcement working for us and on our investigative 
~ 
but as l sit here today, l don...

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Pi 
July 22nd and 23rd there were numerous e-mails sent 
1t 
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ft 
about the meeting. It was almost an all-hands-on-deck 
~ 2 
~ 
type meeting where everybody needed to attend. lt was 
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ti 
labelled the Epstein meeting with an Epstein 
i 
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conference room reserved. 
l 5 
µ 
A. Yes. 
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i! 
Okay. What's your question and I will tell 
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you. 
I 
8 
MR. SCAROLA: First l'rn going to object to 
E 
9 
" 
counsel's testimony, but let's hear the question. 
ho 
ll 
BY MS. HADDAD: 
f 11 
Q. The question is, does that refresh your 
li 12 
~ 
recollection as to whether or not this meeting took 
p 3 
• 
place? 
p4 
A. To the best of my recollection, I actually 
n15 
had introduced some of the investors to some of the 
f16 
people working on the Epstein case, and that is likely 
07 
fil 
the meeting that you are referring to. But for the 
p0 
life ofme, I don't have a specific recollection of 
fl 19 
li 
it. 
po 
Q. But it could be the meeting where you 
introduced the Epstein litigation team to your Ponzi 
g 
P, 21 
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investors? 
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ij 
MR. SCAROLA: Excuse me, I'm going to 
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object to the form of the question. It misstates the 
'25 
Page 58 
prior testimony. It has no predicate. 
1 
BY MS. HADDAD: 
I 2 
Q. That could have been the meeting in which I 
3 
you introduced the Ponzi investors to people working 
4 
on the Epstein case? 
~ 5 
:MR. SCAROLA: Excuse me, counsel. The 
i 6 
!i 
testimony was that there may have been a meeting at 
l 7 
which investors may have been introduced to some 
Ii 8 
~ 
people working on the Epstein file. And your efforts L~ 
continuously to mischaracterize the prior testimony 
are highly improper. I object. 
li Dl 
BY MS. HADDAD: 
b2 
Q. Scott, ~id you or did xou not say that you 
h3 
introduced some of the investors to some o...

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know this is a real case? So J was finally able to 
say this is how you know, here is a case file. 1 may 
have, 1 don't remember specifically one way or the 
other, but l may have utilized actual 2l aintiff names 
from the cases filed, but 1 may have made them UQ. 1 
have no specific recoil ection one way or the other. l 
J:VaS totally geared toward simEIY getting the investor 
mone):'. into the Ponzi schem!t. 
Q. Were you aware that the day after this 
meeting took 2lace on July 24th, 2009i a new federal 
complaint was filed against Epstein with one of the 
same plaintiffs that was already pending in state 
court? 
A. I don't know that l was aware of that or 
not. If they were filing it, someone may have told 
me. ] don't recall one way or the other. 
Q. Did you ask anyone to file it to further 
your Ponzi schemeJ 
A. Noi] don't remember doing the!!.. 
Q. Do you recall any situation where you -
A. You do realize - Tonja, hang on . ...Li.Y.a 
want to make sure this record is clear. Other than 
, Russ Adler, the people that were involved in the 
E2stein case had absolute!:)! nothing to do with the 
Ponzi scheme. 
Page 62 
Q. Directly? 
A. _or indirectly. They had nothing to do with 
it. 
__. Q. Yet ti1ie file was used for you to further 
your Ponzi scheme. l'm not saying that they gave it 
to you to use for the Ponzi scheme; I'm asking, you 
used their case. I'm not - the question is you used 
the case? 
A. ] took advantage of some goodi innocent 
people for my own and my co-conspirator's illegal 
purposes. Mr. Edwards is one of them, and for that ] 
am sorry, Brad. 
Q. Did you ask anyone involved in the Epstein 
case to fiie a federal complaint? 
MR. SCAROLA: Objection, repetitious. 
THE WITNESS: Without seeing a document, 
Tonja, I can't tell you one w...

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from federal court? 
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A. l'm certain] did, Tonja. ] don't have a 
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specific recollection of getting the one pertaining to 
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this. ] don't even know if they sent it to me. ] 
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would imagine they'd send it back to Mr. Edwards. 
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Q. The filing attorney? 
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A. ] suspect, unless the PACER system is 
a 
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registered on my name, then maybe it comes to me, but 
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l am completely guessing. 
address from your firm; is that correct? 
A. Yes. 
Q. And were you filing any cases back in 2009 
in federal court? Do you remember how PACER works? 
MR. SCAROLA: Which question would like 
answered? 
THE Wl1NESS: I don't remember. 
MR. SCAROLA: Objection, compollild. 
BY MS. HADDAD: 
Q. Do you remember how PACER worked when you ! 10 
Q. But based upon the e-mail comnnunications of 
were filing a case, Scott? 
A. l actually never actually did the actual 
electronic filing procedure. J had people that did 
that. 1 knew that we could file electronically. 
Q. Do you know the purpose of your using your 
e-mail address when you were filing electronically in 
federal court? 
A. l guess so you can get a receipt, but I have 
no idea. 
Q. Did you ever receive an e-mail from federal 
court in your e-mail address that showed that a 
document had been filed with the stamps that you see 
on the top of that one? 
MR. SCAROLA: Counsel, are you 
attempting --
111 
July 22nd and the meeting occurring on July 23rd, this 
~ 12 
complaint was filed the day of this meeting; is that 
ij 7 3 
correct? 
i 
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A. Okay. But here is the problem with your 
; 15 
question, 1 don't remember whether or not there 
~ 16 
actually was a meeting. ] said there may have been, 
IT 
~ 1 7 
and 1 don't have an independent recollection of this 
i 18 
being filed. l do not have an independent 
~ 19 
recollection of whether I told someone to file this. 
u 
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And...

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BY MS. HADDAD: 
Q. Or IRS. We'll use the blanket term federal 
agent. ls that a fair assessment? 
A. Yes. 
Q. Thank you. 
Do you recall when you hired her to work for 
you? 
A. J do not. 
Q. Was it in 2009? 
A. J don't have a recollection one way or the 
other. 
Q. Okay. Have you ever seen this e-mail 
before? 
A. J saw it when l was reviewing your exhibits. 
Before that I have no independent recollection of 
having seen it. I'm not copied on it so ... 
Q. Did you ever have any communications with 
Ms. Holmes about people that were close to 
Mr. Epstein? 
A. I do not remember. 
Q. You stated earlier that you knew that 
Mr. Epstein was a wealthy man. ls that a fair 
statement? You q1Hed him "collectible," was that 
because he had money? 
. 
-MR. SCAROLA: He called him a billionaire 
Page 70 
too. 
MS. HADDAD: Billionaire. 
THE WITNESS: I knew he was a billionaire. 
BY MS. HADDAD: 
Q. Do you have any independent recollection in 
the month of July 2009 of this case being intensified 
in any way such as going after those close to 
Mr. Epstein? 
A. I don't remember that one way or the other. 
Q. If you knew that Mr. Epstein was a 
billionaire, do you have any recollection of asking 
someone to investigate those close to Mr. Epstein to 
further your Ponzj scheme? 
A. 1 don't have an independent recollection of 
that one way or the other. 
Q. Do you recall if you ever directed the 
depositions to be taken of the people who were listed 
on the flight manifest that you saw? 
A. I don't recall one way or the other. I may 
have told the investors that I was going to take the 
depositions without ever intending to take them, but 1 
don't recall one way or the other. 
Q. Are you familiar with a gentleman by the 
name of Mr. Rodriguez, Alfredo Rodriguez? 
A. No. 
Page 71 
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A. What does it say? Say it again. 
Q. It says, "The first deposition occurred on 
July 27th," correct? 
A. Yes. 
Q. Some three days after the federal complaint 
was filed, correct, that we referenced earlier? 
A. That's correct. 
Q. And Paragraph 6 clearly delineates that in 
August 2009 a phone call was received by the 
cooperating witness that explained that this 
Mr. Rodriguez had a list of other purported victims or 
contact information for people who Mr. Edwards could 
aiso potentiaJ1y bring iawsuits for - on behalf of; 
is that correct? 
A. ] don't lmow one way or the other. You 
know, Tonja, just so this record is clear, you know, 
as l'm sitting here,] have a vague recollection of 
perhaps Ken Jenne coming, talking to me and telling me 
that someone in my office was going to cooperate with 
someone in this investigation. But for the life of 
me,] can't be certain of that So much time has 
passed, but as l'm reading this, and it could be 
completely umelated to this, ] just want to make sure 
the.ret9rd is _a hundred percent clear, it's possible 
that K~n J ellf)e discussed that with me, but l don't 
Page 74 
know who it was. 
Q. You are testifying that you didn't know it 
had anything to do with the Epstein case, as you sit 
here now, you don't remember? 
A.· ·No, nci, l don't have a specific 
recol:lection, and ] want to just make sure so I answer 
all your questions completely, is that as l'm sitting 
here my recollection was refreshed that] have a vague 
recollection of having a conversation with Ken Jenne 
about the fact that someone in our office was going to 
cooperate as a confidential informant for some law 
enforcement agency, I just can't remember if it was 
the Epstein case or not. 
Q. Do you recall what you said to Mr. Jenne 
about that? 
A. No. ...

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work hours or after work hours? 
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Ponzi scheme investors? 
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3 
A. Both. 
~ 2 
A. Not really. 
~ 
Q. Did you always meet with them in your office 
or did you do it more socially down at Bova or 
elsewhere? 
fi 
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Q. Would it have given more legitimacy to your 
4 
5 
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allegation that it was a good case in which they 
ii 
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should invest? 
6 
A Both. 
~ 6 
A. In the way that] was selling the Ponzi 
7 
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Q. But with this particular case, do you recall 
meeting them at least one time in your office where 
they could look through the files? 
I 7 
settlements, it would have likely been overkill. 
9 
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Q. So did you ever instruct them not to speak 
~ 9 
to the press about the case? 
10 
A. Actually, that group of investors were 
looking at a lot of different cases or at least 
multiple different cases that we were attempting to 
iure them into the Ponzi scheme utilizing, so J met 
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A 
] don't recall that either one way or the 
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other. 
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with them on multiple occasions, both in my office and 
at restaurants. 
Q. Who is Mike Fisten? 
A. Mike Fisten was a law enforcement officer of 
some type that I hired. 
Q. Why did you hire him? 
h2 
ff p3 g: 
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Q. ]fit had gotten out there that the cases 
had not, in fact, settled, as you vvere claiming when 
you were selling the settlement, would that have 
hindered your case, your Ponzi investor's case? 
A Not really because they would have no way of 
knowing if] had created a fake plaintifl's name. ] 
mean, there could have been something in the news 
that -- and] don't know that there was -- there could 
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have been something in the news that says none of this 
il 
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A. He was a Ken Jenne suggestion. 
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Q. And were you hiring him to start up your 
company with Mr. Jenne, as you indicated earlier? 
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settled. And 1 just simply would have created a fake 
~ 
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name with my co-conspirators, created a fake se...

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have? 
!! 1 
A. You said "still require," which would have 
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meant that J testified --
f 3 
Q. Sony. 
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A. -- previously that it was requiring them. 
! 5 
Q. Did you require attorneys at your firm to 
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attend your fundraisers? 
~ 7 
A. J asked them to, 1 urged them to, l tried to 
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cajole them into coming, but it wasn't an absolute 
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requirement. 
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Q. Do you recall between April and July of 2009 I 11 
how many fundraisers you would have had? 
i 12 
A. 1 do not. 
!13 
Q. Did you have fundraisers anywhere besides 
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your home in 2009? 
B 15 
A. 1 probably did, but 1 don't recall without 
~ 16 
seeing the documents. If you have the invitation or ! 1 7 
the e-mails, that would help me. 
h 8 
Q. Did you hold fundraisers at your office in 
; 19 
2009? 
i20 
A. l may have. That wouldn't have been 
ff 21 
unusual, but 1 don't have a specific recollection. 
12 2 
Q. Did you ever meet any of the plaintiffs in 
j 2 3 
the Epstein case? 
D 2 4 
A. ] don't have a specific reco1Jection of 
i 2 5 
Q. When did you hire him? 
A. 2008 or 2009. ] don't have a specific 
recol1ection. 
Q. Jfyou hired lawyers who didn't have a book 
of business, what kind of practice did they do at your 
office? 
A. Jt depended upon the lawyer. 1 would have 
tried to get them to work with other lawyers in an 
area that they either were proficient in or wanted to 
become proficient in. 
Q. Okay. You had a meeting at your office 
during which you were asking about information 
regarding referring attorneys, attorneys who had 
referred business to the firm. Do you know what J'm 
talking about? I believe it was back in December of 
'08 or early 2009. 
A. The way you are characterizing that meeting, 
1 had a lot of meetings like that. 
Q. What was the purpose of those? 
A You are going to have to be more specific 
for me, Tonja. 
Q. Let's start generally then. What was ...

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had to have Curtis Renie or Bill actually come into my 
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office, set up a special icon to allow me to do that. 
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It was a real pain, so it was rare. 
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Q. Who else attended the meetings that you had 
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with the Clockwork group with respect to the investors 
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in the Epstein case? 
, 6 
A. There were multiple meetings with what I'll 
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call the Clockwork investors at various points in 
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time. A variety of people came in and out of the 
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meetings. Some of the meetings occurred down in Bova. po 
Other people came up to the meetings. Some of the 
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meetings involved Michael Szafranski, our fake 
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independent verifier. Some of the meetings may have 
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involved bankers and the like. 1 cannot tell you 
~14 
specifically who was at those meetings. 
!15 
ii 
Q. The specific meetings that we are talking 
;, 16 
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about with - where you left the boxes at your office, 
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do you recall who else was there with you at that 
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meeting? 
pg 
A. 1 only remember there being a handful of 
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people from the investment group and myself. I don't 
~21 
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recall -- and l remember the guys bringing the boxes 
p2 
the down, but they didn't stay for the meeting. There 
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may have been other people there, I don't recall one 
124 
way or the other who it was. 
25 
Page 86 
where we owed 20, $30 million in Ponzi payments out 
and she needed to write a check for even $5,000, she 
probably would have checked with me on that. So 
substantial and whether or not she would have checked 
with me depended upon the circumsta11ce at the time. 
Q. You stated earlier, and l think 1'11 get 
this quote right, that 2009 was a dismal year; is that 
correct? 
A. For the legitimate law firm business, it was 
a dismal year. 
Q. So in the months immediately preceding the 
dissolution ofRRA, July to October of 2009, wh...

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A. Did Wayne Black work for Ron Cacciatore? 
Q. Are you aslcing me --
A. l'm asking anyone in the room who wants to 
talk to me. 
Q. ] love to talk to you, but 1 don't know the 
answer to that question. He might have. Brad might 
be able to tell you. 
MR. EDWARDS: No. 
THE WITNESS: When you said Wayne Black's 
name again and that 1 hired rum to do something, l 
seem to think that he may have been associated in 
some way with Mr. Cacciatore, but J'm not sure one 
way or the other. ] don't remember whether or not 1 
met Mr. Black, it's possible l did, it's also 
possible ] did not. And 1 don't have an independent 
recollection ofretaining him to do anything or 
whether 1 was part and parcel of the decision if we 
did, in fact, retain him, whether l was part and 
parcel of the decision to retain him. 
BY MS. HADDAD: 
~ 4 
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Q. Traveling out of state for depositions for 
~ 21 
the particular cases, did you have to approve that? 
ij22 
A. 1t would depend upon who the lawyers were, 
P, 2 3 
,t 
the significance of the expense. 1t would have been 
~2 4 
case by case. J certainly would not have been 
~ 2 5 
[Short recess taken.] 
FURTHER DJRECT EXAMJNATJON 
BY MR. GOLDBERGER: 
Q. All right. Mr. Rothstein, Jack Goldberger, 
I'm going to ask you some questions now. You 
testified tlrnt you knew Jeffrey Epstein was a 
billionaire. You did testify to that today, correct? 
A. Yes. 
Q. Okay. Tell me how you knew that. How did 
you know that Mr. Epstein was a billionaire? 
A. Russ Adler told me. I looked him up on the 
internet. 
Q. What did you look on the internet about 
Mr. Epstein? 
A. 1 don't recall, but l remember looking up an 
seeing that he was very wealthy, that he was a 
billionaire. 
Q. Okay. So as far as learning that 
Mr. Epstein was a billionaire, you learned via ...

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from speaking to Mr. Adler could bring in a 
significant amount of money to the finn. 
Q. At that time Mr. Adler was one of your 
co-conspirators in the Ponzi scheme; is that correct? 
A. By this time, yes, sir. 
Q. Okay. When did Mr. Adler become a 
co-conspirator in your Ponzi scheme? 
A. ] don't recall the specific date. 
Q. Was it before or after Mr. Adler recommended 
that Brad Edwards be hired at your firm? 
A. Before. 
Q. So before Brad Edwards was hired at RRA, 
Russeii Adler was a co-conspirator of yours in t'ne 
illegal part of the RRA firm; is that correct? 
A. Yes. 
Q. T11en after that time you hired -
Mr. Edwards was hired after Adler was your 
co-conspirator? You are laughing, you are smiling, 
why is that, sir? 
A. Because when you say "RRA" that way, the 
speaker sounds, it sounds like you are roaring. 
Q. Okay. I'll just say Rothstein, how about 
that? You know what l'm talking about ifl just say 
Rothstein. 
A. RRA is fine. 
1 
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Page 
Q. What did Adler tell you about the Epstein 
case that Edwards had at the time you were 
contemplating hiring him to become a member of the 
Rothstein finn? 
A. He told me that it was a huge case involving 
a billionaire pedophile and that it was a winner. 
Q. Did you, when you heard that, did you think 
that that was a case that could become part of your 
Ponzi scheme? 
A. No, l actually thought of it as a way to 
earn legitimate money to help me out of the Ponzi 
scheme. 
Q. So at u½e time you hired Mr. Edwards and you 
were talking to Adler about Edwards, you were trying 
to get out from under the Ponzi scheme? 
A. 1n the bulk of2009 l was praying for some 
sort of legit...

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together possible that l gave Russ the okay to hire 
him before, I just don't have a specific recollection 
one way or the other. 
Q. At some point, I take it, you learned, 
whether you sat in on a meeting when Mr. Edwards was 
hired or whether your co-conspirator hired him, at 
some point you learned that Mr. Edwards, in fact, had 
been hired by the firm; is that correct? 
A. I'm certain that I gave the final okay to 
hire him. 
Q. Okay. When you were giving the final okay 
to hire him, I assume there had to be discussion of 
the money that he was going to be paid, correct? 
A. With somebody, yes. 
Q. Certainly with Mr. Edwards, right? 1 assume 
he wanted to know how much he was getting paid. 
A. Yes, but I don't have a specific 
recollection of whether I discussed that with him or 
whether l authorized Adler or maybe even Rosenfeldt to 
discuss it with him. 1 don't recall. 
Q. Do you have the slightest idea how much 
money Mr. Edwards was paid when he first joined the 
firm, what his salary was? 
A 1 don't have an independent recollection. 
Q. Generally someone like Mr. Edwards at his 
Page 98 
level of accomplishment and his age, you know what the 
general salary would have been at your firm? 
A. It didn't work that way. 
Q. 1 see. Tell me how it worked. 
A. lt's a case-by-case basis. 
Q. Te]] me how it worked. 
A. Case-by-case basis. 
Q. And how did you make that detennination on a 
case-by-case basis? 
A. Actual book of business, potential book of 
business, potentiality for growth, character, what he 
brought to the table, and obviously a function of how 
much money we had available at the time. 
Q. Okay. And you don't have any recollection 
of the machinations that occurred in determining what 
Mr. Edwards salary would be, correct? 
A. 1 do not. 
Q. But certai...

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trying to make money. 
I. 
1 
Q. And these young lawyers, would you consider 
~ 2 
Mr. Edwards to be a young lawyer or a middle-aged 
~ 3 
lawyer? 
i 4 
A. Young lawyer. 
K 5 
~ 
Q. Okay. Was he one of young lawyers that came 
Il 
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to these fundraisers at your home? 
~ 7 
~ 
A. 1 don't recall whether he was there or not. 
f 
8 
ii 
1 recall him being arsome, but I didn't know ifhe 
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f; 
was at all of them. 
ho 
Q. Okay. You do recall him coming to some of 
111 
the fundraisers, though, correct? 
p2 
A. 1 recall him being at my home. it may have 
P3 
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been for firm parties or other parties, it may have 
jl4 
been for fundraisers there. 
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Q. And that was during the time period that the 
~16 
R 
Ponzi scheme was still going on, correct? 
n7 
M 
A. Yes. 
li 18 
§ 
Q. Did Adler ever the tell you about any 
h 9 
discussions he had with Brad Edwards about the illegal 120 
~ 
part of the operations at Rothstein? 
ra 21 
~ 
A. Can you reask the question, please? 
u22 
Q. Sure. Sure. 
H23 
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Did Russell Adler ever tell you -- Russell 
tll; 2 4 
Adler is your co-conspirator, we've established that. 
. 2 5 
Page 102 !i 
Did Russe]) Adler in the furtherance of your 
1 
conspiracy ever tell you he had discussed with Brad 
2 
Edwards about the ilJegal activities at RRA? 
3 
A. No. 
4 
Q. NoW,j'.OU testified when asked about whether 
5 
!he press -- if _l'.OU were involved in asking the press 
~ 6 
G 
to run with the E:gstein stoa, you said something to 
K 7 
the effect, "the wax l was selling the Ponzi scheme it 
"I : 
would be overkilJ." 
I didn't understand your answer like you 
10 
didn't understand some of my questions, so I'd like 
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you to kind ofte]J me what you meant by that. 
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A. ] was selling purportedl:}'. confidential 
I
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settlements. Confiden...

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Q. Okay. And do you remember what Adler told 
you specifically about the Epstein case that helped 
you have a basis of information to sell it to the 
investors? 
A. Other than him telling me that it was a 
billionaire pedophile, other than him telling me about 
the flight manifest,] don't have a specific 
recollection of what else he told me. 
Q. Did you actually look at the flight manifest 
at sometime, Mr. Rothstein? 
A. Yes, sir. 
Q. And what was it about those flight manifests 
that you f eh would heip you pitch i.he Epstein case to 
the investor? 
A. ] don't remember who specifically was on it, 
but] remember it looking juicy. 
Q. You don't know who was on it? 
A. ] don't recall. 
Q. Did you add any names to that manifest at 
any time? 
A. ] had - you mean physically write names on 
there? 
Q. Any way you want to interpret - did you --
not physically write any names on the manifest, but 
did you tell the investors that there were names on 
Page 106 
the manifest that were actually not on the manifest? 
A. 1 told the investors that there were other 
people that appeared on manifests,] don't recall 
whether it was that manifest or other manifests, and I 
got the names of those people from Russ Adler. 
Whether or not they actually appeared on the manifest 
or another manifest, I do not know. 
Q. What names did you get from Russ Adler? 
A. Russ Adler told me tbai Bill Clinton flew on 
Mr. E2stein's Qlane and that Prince Andrew flew on 
Mr. Epstein's plane. 
Q. And is it your testimony today that you 
never looked at the manifest to see whether Bill 
Clinton or Prince Andrew's name were really on the 
man if est that you were going to use to pitch the 
investors? 
A. Jt was my understanding they didn't have all 
the manifests. 
Q. Okay. Did you ever ask for the manif...

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A. ]fyou are including within that me walking 
past Brad in the hall and saying, "Hey, Brad how are 
you? How is the Epstein stuff going?" Then it's very 
likely that l talked to him about it in that manner. 
But l have no specific recollection one way or the 
other as to having any lengthy conversations with 
Mr. Edwards about the case. 
I had a co-conspirator who was deeply 
involved in the Ponzi scheme that l could go to to get 
any information l wanted, Mr. Adler. l didn't need to 
go to Mr. Edwards. 
Q. So if you had a question of your 
co-conspirator, Russell Adler, about the Epstein case, 
you would go ask Adler and would Adler always have the 
answer for you or would he say he would get you the 
answer? 
A. Both. 
Q. When he didn't have the answer, do you know 
who he was getting the answer from? 
MR. SCAROLA: Objection, predicate. 
THE WlTNESS: l don't know who he was 
ii 
A. She may have, I don't recall one way or the 
other. 
i 1 
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J; 
f; 3 
Q. Did you ever ask Ms. Holmes to use any of 
~ 4 
her prior contacts in law enforcement to assist you in 
~ M 5 
the Ponzi scheme to get infonnation :for you? 
I 6 
A. The question is kind of convo 1 uted because 
il 7 
the way you are asking it, it seems like you are 
ff 
8 
intimating that Ms. Holmes knew. l may have asked 
U 9 
Ms. Holmes to get me infonnation that I was going to 
i l O 
utilize with my co-conspirators in the Ponzi scheme, 
l 11 
but Ms. Holmes did not know that there was a Ponzi 
i 12 
scheme going on. 
n 13 
Q. All rigi'it. So you may have asked Ms. Holmes 
I 14 
to try and get some information for you from her 
; 15 
contacts in law enforcement, but it's your testimony, 
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and l don't dispute it, it's your testimony that she 
I 1 7 
knew nothing about the Ponzi scheme, correct? 
R 18 
A....

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A. Clockvvork. 
Q. So we would look at when the Clod,-work group 
was brought into this and the Epstein case was used 
then and then we would look at the payroll records to 
see whether Mr. Edwards got a bonus after the 
Clock-work group was brought into the Ponzi scheme, 
correct? 
A. From a timng perspective, yes. But 
Mr. Edwards had nothing to do with the Ponzi scheme, 
nor was he rewarded even surreptitiously without his 
)rnow]edge for helping me with the Ponzi scheme. lf he 
was rewarded it was because he deserved, I felt he 
deserved a reward, having nothing to do with the Ponzi 
scheme. The bulk of this law firm had nothing to do 
with the Ponzi scheme. 
Q. I think you testified already, though, that 
money was fundable in the firm, right? 1 mean, you 
know, illegal money was used for legitimate purposes, 
correct? 
A. Yes. 
Q. Okay. So, for example, investigations that 
were done with the Epstein case, it's very possible 
that legitimate Ponzi money was used to finance those 
investigations? 
A. I'd be guessing. It's certainly possible 
Page 
because all the money went into a whole series of 
pots, and if you look at, most of the pots were trust 
accounts. Jfyou look back, you look to see what my 
CFO, who was also a co-conspirator was doing, she was 
pulling the money from wherever she needed to to fund 
whatever she needed to fund. 
MR. LA VECCHIO: Off the record a second. 
[Discussion off the record.] 
BY MR. GOLDBERGER: 
Q. Let me circle back to what you needed to 
learn about the Epstein cases to help make your pitch 
to the investors. 
You talked about the manifest already, 
correct, the flight manifest? 
A. Yes. 
Q. Okay. What else did you want to learn about 
the case or what else did you learn about the case so 
that you were conversant when you sp...

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of the underage women had travelled on Mr. Epstein's 
plane_. 
Q. Did you ever meet any of the plaintiffs? 
MR. SCAROLA: That's question that's been 
asked and answered. 
THE WITNESS: l do not have a specific 
recollection of ever meeting them. 
MR. SCAROLA: You are exhausting my 
indulgence. 
MR. GOLDBERGER: Fair enough. 
MR. SCAROLA: You've exhausted my 
indulgence. 
BY Iv:lR. GOLDBERGER: 
Q. Do you know whether any of your 
investigators at the finn had any kind of high tech 
surveillance equipment or, you know, wire tapping 
equipment? 
A. l believe they did. 
Q. Do you know whether this was legal stuff or 
illegal staff? 
A. ] did not know, nor did I care. 
Q. Do you know if any of that stuff was used to 
either wire tap or surveil Mr. Epstein? 
A. ] do not know one way or the other. 
Q. What sort of equipment did you know that 
Page 118 
they had, meaning your investigators? 
A. I had told Mr. Jenne and others involved in 
the investigation arm ofRRA to get whatever equipment 
they thought they needed and to get the best stuff 
that they could get. What they actually did, I can't 
tell you. 
Q. You know as part of the Epstein litigation, 
and I'm talking about now after your using it in the 
Ponzi scheme, do you know whether anyone at your finn 
attempted to depose ex-President Bill Clinton? 
A. I don't recall that, sir. 
Q. Okay. How about Donald Trump, same 
question? 
A. I don't recall that. As a matter of fact, 
we had represented Trump in some things, we had some 
pretty close ties with him, so ] can't imagine that 
they would have done that with my authority. 
Q. Okay. 
A. I don't recall that. 
Q. Do you know whether Adler would have -
would Adler have the authorize to do that without 
getting your permission? 
A. The authority, no. Might he have tried, 
...

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of a single deposition. or the propounding of an;y 
r: 
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discovery in the Epstein cases. Do you have an:y 
~ 2 
reason to doubt the accuracy of that testimonx? 
~ 3 
A. No, sir. 
~ 
4 
Q. ] want you to assume that Brad has or will 
~ 5 
testify that you did not provide any input whatsoever 
:\ 
6 
into the hand]ing of the legitimate Epstein cases. Do 
~ 7 
;rou have any reason whatsoever to doubt the accuracy 
fl 
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of that testimony? 
g 9 
N 
• 
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A. .:,.:.Q..jl!. 
~ 
Q. ] want you to assume that Brad has or will 
H 11 
testify that you never met any of the legitimate 
I 12 
plaintiffs in the Epstein cases. Do you have arzy 
~ 13 
reason to doubt the accuracy of that testimony? 
I 14 
'·; 15 
A. .No, sir. 
~ 
MS. HADDAD: J'm going to object to these 
~ 16 
same questions you keep asking, because Mr. Rothstein i 1 7 
has testified at nauseam that he doesn't recall any 
f 18 
of thEisdand dn~w- yhou ar
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e asdkin?, him to bolster d 
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0
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Mr. 
war s e1t er a rea y given or purporte 
-
testimony when he's testified he doesn't recall it. 
I 21 
BY MR. SCAROLA: 
U 2 2 
Q. ] want you to assume that Brad has or will 
i 2 3 
testify under oath that you never asked him once to 
i 2 4 
report back to you on any factual matters regarding, 
I 2 5 
jllegal activities at the RRA fiun and you concealed 
your knowledge of Brad Edwards' knowledge of that 
~illegal activity. what do you understand the 
consequences of that false testimony to be? 
A. l'II be violating my agreement v,,,ith the 
United States government and] would run the risk of 
dying in prison. 
MR. SCAROLA: Thank you. l don't have any 
further questions. 
THE WlTNESS: Thank you, sir. 
MR. NURJK: Mark, ] don't know what your 
time frame is on your litigation, but the ability to 
receive the transcript, review it and prepare an 
errata sheet within what is normally the time 
allotted un...

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MS. HADDAD: lt's scheduled in a month, 
Mark. 
MR. NURJK: We'll cooperate. 
MR. SCAROLA: Thank you very much. 
[Thereupon, the taking of the deposition was 
concluded at 12:37 p.m.] 
SCOTT ROTHSTEJN 
Sworn to and subscribed 
before me this 
day 
of 
2012. 
Notary Public, State 
ofFlorida at Large. 
Page 126 
1 
CERTlFICATE 
2 
STATEOFFLORIDA 
) 
COUNTY OF MIAMl-DADE 
3 
I, Pearlyck Martin, a Notary Public in and. 
for the State ofFlorida at Large, do hereby certify 
that., pursuant to a Notice of Taking Deposition in 
5 
the above-entitled cause, SCOTT ROTilSTBN was by me 
first duly cautioned and sworn Jo testify the whole 
6 
truth, and upon being carefully examined testified as 
is hereinabove shown, and the testimony of said 
1 
witness was reduced to typewriting under my personal 
supervision and that the said Video Conference 
8 
deposition constitutes a true record of the testimony 
given by the witness. 
I further certify that the said Video 
1 0 
Conference deposition was taken at the time and place 
specified hereinabove and that l am neither of 
11 
counsel nor solicitor to either of the parties in 
said suit nor interested in the event of the cause. 
12 
WITNESS my hand and official seal in the 
13 
City ofMiami, County ofDade, State of Florida, this 
day of June 19, 2012. 
14 
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11 
Pear]yck Martin 
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]] 
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]l 
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FRIEDMAN, LOMBARDI & OLSON 
Suile 924, Biscayne Building 
J 9 Wes1 Flagler Stree1 
Miami, Florida 33130 
Telephone (]05) 371-6677 
June 21, 2012 
IN RE: EPSTEIN VS. EDWARDS 
SCOTT ROTI-ISTEJN Clo MARC N\JRJK 
One Eil51 Br □wilrd Boulevard, Seventh Floor 
Fl. Lauderdale, Florida 3330 I 
Dear SCOTT ROTI-ISTEIN: 
V1/i1h reference lo lhe deposi1ion of 
yourselrlaken on June 14, 2012, in connecli□n wilh 
lhe above-cap1ioned case, pleu.se be advised 1hn1 1he 
lranscrip1 of1he depositio...

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IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT OF FLORIDA 
IN AND FOR PALM BEACH COUNTY 
CIVIL DIVISION 
CASE NO.: 502009CA040800 AG 
JEFFREY EPSTEIN, 
Plain tiff ( s) l 
vs. 
SCOTT ROTHSTEIN, etc., et al., 
Defendant(s). 
__________________ / 
ORDER ON PLJ\JNTIFF'S 
MOTION TO DISMISS COUNTERCLAIM OF DEFENDANT EDWARDS 
THIS CAUSE ca.me before the Court upon the PlaintL.+f's Motion to Dismiss 
the Counterclaim.of the Defendant, BRADLEY J. EDWARDS. The Court heard argument 
of counsel and has reviewed the authorities they have cited, and is otherwise fully advised 
in the prernises. 
First, as to Count I, t..h.e claim for abuse of process, the Court finds that there 
are sufficient allegations in the Complaint to establish an ulterior purpose or motive. 
Furthermore, the allegations are that each and every act in the prosecution of the case in 
chief have been for an ulterior purpose or motive. Such Counterclaims are no longer 
barred in Florida. See e.g., Blue v. Weinstein, 381 So.2d 308 (Fla. 3rd DCA 1980). 
In regard to the malicious prosecution claim, this Court recognizes that, in 
general, a Counterclaim for malicious prosecution cannot arise out of the allegations 
contained in t..h.e Complaint. Therefore, L.7. general, a claim for malicious prosecution 
arising out of dismissed counts of a Complaint is improper as long as t.h.e Complai.7.t is still 
pending. However, the Court finds that the circumstances in the present matter are 
distinguishable from the cases cited by the Plaintiff. In this case, a voluntary dismissal of 
t..h.ose claims was filed by the Plaintiff. Therefore, we are not faced with a situation where 
EXHDBIT 

NOT A CERTIFIED COPY
Epstein v. Rothstein 
CaseNo.502009CA040800XXXXMBAG 
Order 
Page2 
there is non-final order of court because the claims are interrelated to a remainin.g clahn. 
In this case, the Plaintiff voluntarily chose to dismiss those claii--ns. Counsel has provided 
no authority for the proposition that a voluntary dismissal of a claim against a party is not 
a bona fide termination. 
Nevertheless, this Court has serious concerns as to the claimed "damages" 
set forth in the Counterclaim. Therefore, further argument on the damages issues only is 
. scheduled for Wednesday, April 18, 2012 at 8:45 a.m, (UMC), Courtroom 9C, Palm 
Bea.db. County c~ul'!."thou.se, 205 North Dixie Highway, West Palm Beach, Ffodda, 
Counsel shall provide to the Court at that time authority for the damages allowable under 
the claim or malicious prosecution or abuse of process. 
DONE AND ORDERED this-2C/.!aay of M::ill"c'h, 201~st p::ii-rn. Beach, 
Palm. Beach County, Florida. 
Copy furnished: 
DAVIDF. CR W 
CIRCUIT COURT JUDGE 
JACK SCAROLA, ESQUIRE, 2139 Palm Beach Lakes Blvd., West Palm Beach, FL 33409 
JOSEPH L. ACKERMAN, JR., ESQUIRE, 777 S. Flagler Dr., 901 Phillips Point West, West Palm 
Beach, FL 33401 
• 
JACK GOLDBERGER, ESQUIRE, 250AustralianAve. S., Suite 1400, West Palm Beach, FL33401 
MARC NURIK, ESQUIRE, One E. Broward Blvd., Suite 700, Ft. Lauderdale, FL 33301 
GARY M. FA-"RMER, JR., ESQUIRE, 425 N. Andrews Ave., Suite 2, Ft. Lauderdale, FL 33301 
LILLY ANN SANCHEZ, ESQUIRE, 1441 Brickell Ave., 15th Floor, Miami, FL 33131 

NOT A CERTIFIED COPY
IN THE CIRCUIT COURT OF THE 
15TH JUDICIAL CIRCUIT, IN AND 
FOR PALM BEACH COUNTY, FLORIDA 
CASE NO.: 
502009CA040800XXXXMBAG 
JEFFREY EPSTEIN, 
Plaintiff, 
vs. 
SCOTT ROTHSTEIN, individually, 
and BRADLEY J. EDWARDS, 
individually, 
Defendants. 
-------------------I 
VIDEOTAPE DEPOSITION CONT 1 D OF BRADLEY EDWARDS 
VOLUME II OF II 
PAGES 110 -
250 
October 10th, 2013 
10:00 A.M. -
2:30 P.M. 
401 East Las Olas Blvd., Suite 1400 
Fort Lauderdale, FL 
Stenographically Reported By: 
WENDY ROBERTS, RPR 
Notary Public, State of Florida 
Empire Legal Support, Inc. 
Fort Lauderdale Office 6f/J-------.. 
Phone : 
( 9 5 4 ) 2 4 1-1 o 1 o 
EXHIBBT 
I~ 
iG 
'------------------ii 
Electronically signed by Wendy Roberts (201-049-665-8352) 
Electronically signed by Wendy Roberts (201-049-665-8352) 
Electronically signed by Wendy Roberts (201-049-665-8352) 
I 
d2253581-25f4-499f-bc84-db447 41 f4cft 

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Page 111 
APPEARANCES 
ATTORNEY(S) FOR MR. EPSTEIN: 
TONJA HADDAD COLEMAN, ESQUlRE 
Tonja Haddad, PA 
315 SE 7th St Ste 301 
Fort Lauderdale, Florida 333013158 
Phone: 954.467.1223 
Fax: 954.337.3716 
E-Mail: Tonja@tonjahaddad.com 
FRED HADDAD, ESQUJRE 
Fred Haddad PA 
1 Financial Plz Ste 2612 
Fort Lauderdale, Florida 333940061 
Phone: 954.467.6767 
Fax: 954.467.3599 
E-Mail: Haddadfm@aol.com 
JACK GOLDGERGER, ESQUIRE 
Atterbury Goldberger Et Al 
250 S Australian Ave Ste 1400 
West Palm Beach, Florida 334015015 
Phone: 561.659.8300 
Fax: 561.835.8691 
E-Mail: Jgoldberger@agwpa.com 
ATTORNEY FOR BRADLEY EDWARDS: 
WlLLlAM KJNG, ESQUIRE 
Searcy Denney Scarola El Al 
2139 Palm Beach Lakes Blvd 
West Palm Beach, Florida 334096601 
Phone: 561.686.6300 
Fax: 561.684.5816 
E-Mail: Wbk@searcylaw.com 
ALSO PRESENT: JEFF EPSTEIN, PLAINTIFF (telephonically) 
DEBRA FEIN, LAW CLERK 
INDEX 
WITNESS: 
BRADLEY EDWARDS 
Page 112 
Page 
Direct Examination cont'd by MR. HADDAD 
I 14 
EXHIBITS 
PLAINTIFF'S: 
EXHIBITS: 
Description 
Page 
Comp. No. I Response to RP#7 Correspondence between 
BJE and US Government RE Epstein in BJE 
Possession 66 pages 
244 
Comp No. 2 E-mail from Russell Adler to Bradley 
Edwards RE: Oct. 28th depo, sent on 
10/14/09 58 pages 
244 
Electronically signed by Wendy Roberts (201-049-665-8352) 
Electronically signed by Wendy Roberts (201-049-665-8352) 
Electronically signed by Wendy Roberts (201-049-665-8352) 
i 
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Page 113 
( Continued from Volume l dated May 15th, 2013 .) 
Videotape Deposition taken before Wendy Roberts, 
Registered Professional Reporter and Notary Public in 
and for the State of Florida at Large. in the above 
cause. 
THE VlDEOGRAPHER: We are now on the video 
record. Today's date is October 10th, 2013. The 
time is 10:15 A.M. Would counsel please state 
their appearances for the record. 
M...

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Page 115 
between yourself and either, what's his name, Dexter, or 
Miss Villfrans, Villafrana, Villafana, whatever you want 
to call her? 
A That's my understanding. 
Q All right. Well, this all came from your 
files and from your records, correct, e-mails, whatever 
you call those things where you store e-mail servers or 
whatever there? 
A 
You sent a request, l did whatever searches 
that l could to come up with all of the documents 
between us and l turned them over to my attorney who 
turned them over to you. 
Q Ali right. And J don't know if that request 
contained anything regarding any memorandums of 
conversations that you might have had, telephonic 
conversations or in-person conversations. Did any of 
those exist? 
A Not to my recollection. 
Q Okay. So --
A I think that's everything. 
Q That's what I'm asking, everything that there 
is, correct? 
A I believe so. 
Q All right. And this would take -- some of 
it's not numeric -- not numerically -- not --
Page 116 
A Chronological? 
Q Chronological, thanks for the word, 
chronologically presented. But I note the first thing I 
have is to Dexter Lee a..TJd it states somet11ing about 
October 9, 2008, regarding some potential false 
statements the Government made in a sworn declaration 
with the above-captioned case. That was you writing to 
them, correct? 
A What I'm looking at right now appears to be on 
my letterhead from back then, so I would say yes. 
Q All right. And whatever it says, it says --
A That's my signature. 
Q Okay. And that would be the same with all of 
these? Let me -- let me just go through them. Let me 
see which ones I'm going to ask. 
MR. KING: Take your time to look at them --
MR. HADDAD: Yeah. 
MR. KING: -- if you think you need to. 
MR. HADDAD: What do you think, I altered 
them? 
MR...

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Page 119 
Q 
l want the answer from you. 
All right. And then on September 29th, 
2011 -- on September 29th, 2011, there is another letter 
to the United States Attorney, Mr. Ferrer, and it's a 
follow-up on Jeffrey Epstein by the same Mr. Cassell, 
correct? 
A 
That's what it appears to be. 
Q 
All right. There is a carbon copy to Dexter 
Lee and Maria Villafana, correct? 
A 
Okay. 
Q 
Okay doesn't answer. Yes or no? ] need --
A 
That's what it appears to be. 
Q 
Yeah, but -- yeah, 1 know. l am just asking 
you --
A 
I mean, I didn't send the letter. I'm looking 
at the same thing you are looking at. 
Q 
I know. 
A Paul signed it and then he copied Dexter Lee 
and Maria Villafana. 
Q Do you know how you received a copy of this? 
A 
1 don't remember right now. 
Q But it is in your records? 
A 
Yes. 
Q And would you have read it at the time it came 
in? 
Page 120 
MR. HADDAD: Where is that thing of hers? 
MR. GOLDBERGER: Chill. Chill. 
MR. HADDAD: Chill, I always chill. 
Tl-IE \VITI-JESS: \1/hat is your question? 
MR. HADDAD: I don't remember. 
A I think -- 1 think it was whether or not I 
received it at the time that it was sent, and I don't --
I don't know exactly the timing of vkten I received this 
letter. But it would have been close in time to when it 
was sent. I don't know exactly. 
BY MR. HADDAD: 
Q So you could -- you all were working these 
together, correct? 
A Yeah, right. 
Q And whatever is in these documents speaks for 
themselves, correct? 
A Exactly. 
Q Would they have engendered by you any 
follow-up calls to the U.S. Attorney or to anyone in the 
U.S. Attorney's Office? 
A No. 
Q All 1ight. Things such as -- at the same 
time, this -- Rule 26 disclosures, and Jane 1 -- and 
.lane Doe 1 and Jane Doe 2, those are your CRVA {SIC} 
cases, correct? 
Elec...

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Page 123 
1 
saying there. The simple thing -- my simple question is 
-, 
this. Were you in the litigation status that you needed 
L 
3 
to produce this or was this a voluntary production for 
4 
purposes of hoping the Government would respond to you? 
5 
A 
We felt it was necessary. 
6 
Q That's not my question. 
7 
A 
l understand that. 
8 
Q Was this -- okay --
9 
A 
l don't know the answer to your question, 
10 
though. 
11 
Q You are an attorney, you are fairly bright and 
12 
we went through that last time, l don't want to have to 
13 
go through that again, how smart you are. This was --
14 
you're saying here, if you are correct that the civil 
15 
rules apply, that's Dexter Lee, then both sides of the 
16 
case are obligated to make voluntary initial disclosures 
17 
under Rule 26( a). We are writing to make our initial 
18 
disclosures and ask that you promptly do the same, 
19 
correct? 
20 
A 
We felt it was our obligation. 
21 
Q l can read what it says here. 
22 
A Okay. 
23 
Q We are making our initial disclosures and ask 
24 
you to do the same, voluntary initial disclosures, okay? 
25 
A Right. 
Page 124 
1 
Q You felt it was necessary, it wasn't required 
2 
by rule, by anything, it was a voluntary thing you are 
3 
doing, as you are say in your own words, correct? 
4 
A 
Correct. 
5 
Q Did you get a response from the Government? 
6 
A I don't remember. 
7 
Q 
Okay. 
8 
A This is something from March of 2011, I just 
9 
don't remember. 
10 
Q 
You don't remember whether or not the 
11 
Government provided you a list of their discovery, their 
12 
evidence, their witnesses or anything, whatever there is 
13 
in response to Rule 26 that they are required to comply 
14 
with? 
15 
A I can tell you they've provided us very 
16 
little, much less than we wanted. Have they provided us 
17 
nothing? I don't know that that's true. 
18 
Q Well, they provided you a letter saying you 
19 
have no business being in this thing, but besides ...

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Page 127 I 
correspondence between the Federal Government and 
Bradley Edwards' partner, Rothstein, Rothstein and 
Adler, as the way you signed off -- or Bradley 
Edwards -- anything? 
A 
Come on, come on. You're going to have to go 
back in the bag and grab a question that I can actually 
answer. 
Q Look through all of this and tell me if this 
is everything you have, if there is one thing during the 
period of time you were with Rothstein? 
A 
ln this? 
Q ln -- well, that's everything you own, you 
said, regarding the -- that -- that request to produce 
regarding the CRVA, as well as the correspondence. 
A 
All right. Correspondence. 
MR. GOLDBERGER: I think you are one letter 
away. 
MR. HADDAD: Oh, what difference does it make, 
he knew what l was talking about. Crime Rights, 
Victims, Crime Victim Rights, okay. ASPCA, the 
same thing. 
THE REPORTER: Counsel, do you want that on 
the record? 
MR. HADDAD: You can type it, I don't care. 
(Thereupon, a discussion was had off the 
record.) 
A 
I don't see anything. 
BY MR. HADDAD: 
Q i\.H right. Thank you. 
MR. GOLDBERGER: Wait, let--
MR. HADDAD: What? 
Page 128 
MR. GOLDBERGER: I want to make sure the 
question is answered, Fred, before you jump on the 
next one. 
THE WI1NESS: I was going to say --
MR. HADDAD: I don't have a next one to jump 
onto yet. I just dug into a few things here this 
morning when I got up getting my kid ready for 
school. I just dog-eared a few things this morning 
when I woke up, get my kid ready for school. 
A 
You were going to ask me how to do that? Oh. 
BY MR. HADDAD: 
Q I have been doing it for 40-something years. 
I have here, I forget where they came from, a 
whole bunch of e-mails you turned over. 
A 
Okay. 
Q 
Since the last time we met, or since -- yeah, 
since after that depositi...

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Page 131 
MS. COLEMAN: While he is looking at that 
just so the video is clear, the request to produce 
regarding the Government exhibits, I have attached 
as Exhibit l to the deposition that he just went 
over and those will be Exhibit 2. 
MR. HADDAD: Oh, okay. l don't know how to do 
that. 
MR. GOLDBERGER: Yes. Yes, that's what we 
want to do. 
MS. COLEMAN: I'm the token civil lawyer in 
the room. l thought l would just throw that out 
there. 
MR. HADDAD: Token woman in the room too. 
MR. KING: So the Rule 26 disclosures to the 
Government will be Exhibit l; is that right? 
MR. GOLDBERGER: Yes. 
MS. COLEMAN: No, no --
MR. GOLDBERGER: It will be part of it. 
MS. COLEMAN: -- those -- those were 
provided -- those -- the Exhibit 1 is responsive to 
Request No. 7 on the Schedule A, to which 
Mr. Edwards objected prior to the last deposition. 
So they were responsive. 
MR. KING: All l want to know is what is being 
marked as Exhibit 1. 
Page 132 
MS. COLEMAN: It's all -- that's it. 
MR. KING: This document --
MR. GOLDBERGER: Your resp -- Edwards' 
response. 
MR. KING: Got it. 
MS. COLEMAN: This is off the record. 
(Thereupon, a discussion was had off the 
record.) 
A You want me to read through these? 
BY MR. HADDAD: 
Q Just look at them and see -- you know, you 
don't have to read every word of -- word of them, I'm 
not going to -- ifl have one I'm going to ask you 
something about, I will tell you. I am not here to try 
to trick you yet. 
(Thereupon, a discussion was had off the 
record.) 
THE VIDEOGRAPHER: The time is J0:36 A.M. We 
are now coming off the video record. 
(Thereupon, a discussion was had off the 
record.) 
THE VIDEOGRAPHER: The time is J0:40 A.M. We 
are now back on the video record. 
BY MR. HADDAD: 
Q All right. So did you have the ability in the 
Ele...

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Page 135 : 
the attached check from Searcy, they should go into 
trust account, you should keep your own running account 
of checks in and out. 
A 
It is an e-mail from Bill Berger to Pat 
Cai1er, who, by this, I would say the e-mail is at RRA, 
so it is probably his secretary. 
Q 
All right. 
A 
That is what I would assume. 
Q 
Okay. But it's saying it would go to you, 
Brad Edwards is you, this and any other others like it 
should go to Brad Edwards. And then it says Brad. So 
see, it says to Brad Edwards --
A 
Right. 
Q 
-- also. Brad, see attached check from 
Searcy. 
A 
Right. 
Q 
They should go into trust account. 
A 
Right. 
Q 
The trust account that they were going into --
this is dated October 26, 2009. The trust account they 
are going into, I suppose, is RRA's trust account; would 
that be correct? 
A 
I don't know. 
Q 
Well, it's -- they are telling you to put 
stuff into a trust account. The only trust -- did you 
Page 136 
have your own separate Brad Edwards PA trust account? 
A 
No. No. 
Q The only trust account you would have had was 
A 
I didn't have an RRA trust account. 
Q The trust account that was in existence for 
when you were with RRA would have been the RRA trust 
account, right? 
A 
I don't know, I was never --
Q Well--
A 
-- part of any trust account. 
Q Well, if you received a check and it was 
directed that you should put this into a trust account, 
where would you put it? 
A I didn't do any of those things. Here's what 
happened. All of the law firms, it was myself, Bob 
Josefsberg, Jack Scarola, and Sid Garcia, Ted Leopold, 
I'm missing -- Adam Horowitz or Jeff Herman or somebody, 
everybody agreed or forensic accountants. 
Q Okay. 
A 
And sent checks to the finn. 1 never --
Q Toyourfirm? 
A 
-- asked for the firm. To RRA. 
Q Yeah. 
A 
...

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Page 139 
were prosecuting the case against Jeffrey Epstein. 
Q And all of the money was being put into, 
without doubt, RRA? 
A 
l don't know. l don't know ifit was being 
put into RRA or anything. All of the money came in --
Q 
All right. Well, let me put it very simply. 
Let's say that you were working with all these guys, 
Josefsberg and the rest of these guys --
A 
That's true. 
Q -- trying to come up with $5,000 to pay the 
forensic accountant. 
A 
Yeah. 
Q lt came out of your trust account, correct? 
A 
l don't know. 
Q You don't know? Who manned the trust account, 
who did all the -- who took all the monies out of that? 
A 
l don't know. 
Q 
You don't know anything about trust accounts? 
A 
l am assuming now what everybody !mows, 
including yourself, is that Scott Rothstein is the only 
person that ran a trust account. 
Q 
All right. 
MR. HADDAD: l'm so glad you can anticipate 
everything that J'm going to ask in a few minutes. 
Sorry. 
Page 140 
BY MR. HADDAD: 
Q All right. Now, this is on October 26, 2009, 
this is probably the last days yo'.1 had 1;rust accounts, 
so you don't k110\V ,.:vhat -- \vhat 1..vas told to Berger to 
talk about these trust accounts, correct? 
A 
Correct. 
Q You don't know whether or not he was in 
contact with Rothstein and whether Rothstein, who was 
always looking for money was looking for money into the 
trust accounts? 
A I have no idea. 
Q All right. You don't !mow whether or not 
Josefsberg, Scarola or Searcy Denney or any of these 
other lawyers, Herman or any of them had money in the 
Scott Rothstein RRA trust account that was lost? 
A I don't -- I don't know, but in - in -- I do 
believe that they sent the checks. Now, what happened 
with the checks and who accumulated the checks and where 
the checks went to fund the for...

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Page 143 
Q All right. Now, Bradley Edward, from Bradley 
Edwards to Jackie Johnson, October 22nd, 2009, please 
look at the following schedules, see if you can book a 
conference room for many to attend as the following 
group of people for tomorrow, 10 days before, eight 
days -- well, not - eight days before you guys fell 
apart. Please look at the following schedules and see 
if you can book a conference room for as many -- for as 
many as can attend from the following group of people 
for tomorrow: Jenne, Adler, Berger, Stone, Wheeler, 
Holmes, Bruschel { SlC}, Fi -- Fiston and Jaffe. Do you 
know what that's about? Do you know why you were having 
a conference? Obviously, from the names, it had 
something to do with Epstein, l would imagine? 
A Yeah, the subject is Epstein meeting. 
Q Yeah. Do you know? 
A We would-- we would frequently have meetings 
on cases, including this one, to brainstorm about what 
to do with the various issues that were going on in the 
case. 
Q Well, you had no other -- did you have other 
cases while you were at RR.A, besides these? I'm not 
saying that pejoratively, l mean did you have other 
cases? 
A Yeah, of course I did. 
Page 14 4 
Q 
All right. 
A 
1 brought with me many cases. 
Q I didn't-- okay, I didn't !mow that. Nobody 
asked you ru1ythjng about oL½er cases prett'J much~ they 
only asked you about this case. You had other cases you 
were working on? 
A Right. 
Q 
Did you settle any while you were there? 
A 
I don't remember. 
Q 
Okay. 
MR. HADDAD: Yes? 
MR. GOLDBERGER: I just --
BY MR. HADDAD: 
Q 
There was one I wanted to ask you about -- you 
know, there was one 1 really wanted to ask you about 
and, of course, I'm sure I lost it. Okay. Can 1 have 
one second since 1 haven't taken a second? I should 
have had it dog-ear...

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Page 147 
preclude any disclosure of work product infonnation 
that they would have a right to assert. And so 
we're -- in honor of that, of those motions or the 
order, ifit was entered, and I apologize for not 
knowing that, we would -- we would object to any 
questions relating to communications that occurred 
that would fall within a work product doctrine that 
would be owned by those other lawyers. 
MR. HADDAD: I -- I -- I don't think that's 
what I was doing. In fact, I thought I made it 
specifically clear I am not trying to invade any 
privilege. I just asked whether or not there was a 
written -- an agreement among the lawyers, and I 
don't think that would be privileged. Shared 
information among the lawyers would not be -- I 
mean, I'm not going to put you in bad position 
because not -- you're -- you're not the lawyer that 
should -- that, like I said, should have been here, 
but you are not the lawyer that is more familiar 
with this, so I don't want to put -- my usual 
expression would be something else, so I will just 
leave it there and we will take it up with the 
Judge, okay. 
MR. KING: Very good. 
MR. HADDAD: Because I just want to know if 
Page 148 
there's a written -- like -- just like the lawyers 
have a -- a --what do we call that, a joint 
defense agreement. Whether it's a plaintiffs 
agreement .... a sharing --- you can assert .. _ you 
objected, I will leave it at that. I don't want 
to -- as I said, I don't want to cause any --
MR. GOLDBERGER: Just identify the specific 
question you are asking that Mr. King is telling 
his client not to answer. 
MR. HADDAD: Specifically, I already asked 
him, whether or not there was any specific 
agreement among the lawyers to share information 
and share expenses, because we already know they're 
sharin...

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Page 151 
scares me in this case. This is about Edwards, isn't 
it? 
A That's me. 
Q 
There is so much pape -- not Edwards, I -- I'm 
confusing you guys now, Epstein. There is so much paper 
and so many motions and dates and times of everything, 
so important, so many motions, I think we need an 
organized paper file in this case. That's you talking 
about Epstein's case, correct? 
A 
It sounds like it, yes. 
Q 
Okay. And organized paper file would mean 
like a war room, I think, in fact, you have an e-mail 
where you asked for a war room. 
A 
Right in there. 
Q 
Is it in this one? It said war room there? 
Oh, yeah. I just thought I was -- great memory, sorry. 
Okay. 
So on October 19th, Ken Jenne to Epstein. 
Subject: Epstein. To Ken from Bradley J. Edwards. I 
know you are aware of the urgency, and Russell and I 
have discussed the various necessary witnesses in the 
case and the urgent need to speak them. We have a 
discovery deadline coming up and four crucial witnesses 
are in California. And you are talking about Fiston 
going out there. That's in relation to what coming up, 
Page 152 
discovery deadline in the cases that you had before you 
settled them, if you --
A 
lTh, from memory --
Q Yeah, I'm not-
A 
-- the case was a -- the Jane Doe v. Epstein 
case was initially set for trial in November of 2009, so 
I think the discovery deadline was coming up and we had 
some more witnesses to talk to before that. 
Q All right. Who's Pat Diaz? 
A He's an investigator. 
Q 
Okay. Let me -- let me -- yeah, this one, 
probably just because it intrigued me, is from Bill 
Berger to Edwards, Adler, Jaffe, Weissing, Farmer, 
May I 9th, 2000. It was mostly your partners now. You 
are invited to attend our three P.M. conference room, 22 
floor conference room, interview of Amy...

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Page 155 
J assu -- is this one on your Web site or is 
this just here, "Florida Lawyer Ruffles Feathers in High 
Society With His Pesky Subpoenas," did you post that 
one? 
A 
J don't think so. 
Q 
You should, it's a pretty good article for 
you. Okay--
A 
Send it to me again and I will post it. 
Q 
All right. I -- I think -- J don't know ifI 
have any more of these on these e-mails, but -- but at 
some point or another, these all -- were either 
recognized by you, came -- or were produced by you, 
correct? 
A 
They came to me by -- from the trustee, 
sometime --
Q Yeah. 
A 
-- in 2011 and then I forwarded them on to you 
guys. 
Q 
All right. 
Were you deposed at all in any clawbacks or 
anything? 
A 
No. 
Q 
Okay. 
A 
This is my third deposition in this case and 
that's it. 
Page 156 
Q Well, l understand that. l don't understand 
how you get to take more than one deposition because you 
don't in criminal, but we are doing it. Maybe I can -
invite you back again in a fe\.v months. 
A l'm hoping for today to be the last time that 
we are meeting under this circumstance. 
Q I'm enjoying it so much. 
A 
Iknow. 
Q Just so long as you're -- I have never taken a 
deposition this long in a first-degree murder. Of 
course, this is much more serious. 
Let me ask you, this is a document --
MR. HADDAD: Yeah, you got to mark all of 
those, I guess. Do we have copies? 
MR. GOLDBERGER: Do you want to sanitize this 
and make sure it's all good? 
MR. HADDAD: Go ahead, you going to take my 
dog-ears off, l need them -- yeah, whatever. 
MR. GOLDBERGER: That's Exhibit 2. 
MS. COLEMAN: Quarter-miilion-dollar education 
and I am --
MR. HADDAD: Do you want -- did you want a 
copy, Bill, did you a copy right here? 
MS. COLEMAN: No, this is 2 because 1 is 
the --
Electronically signed by ...

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Page 159 
Q 
Okay. 
If -- do you remember approximately when you 
were served with the complaint? 
A 
2009. 
Q I understand that. I see here channel --
channel -- December 7th, rather prophetic, 2009, you 
were with hit with the initial complaint, correct? 
lt -- it say here you -- initial complaint, review and 
research. 
A 
Then that sounds accurate to me. 
Q 
Okay. And did you retain -- did you --you 
didn't know it was coming, obviously? 
A Right. 
Q You were only involved at that time in the 
Jane Doe, let me just call them Jane Doe, whatever you 
want to call them, EW, DW, ET, whatever you call them, 
civil suits and it's GVRA? 
A 
CVRA. 
Q CVRA stuff, correct? 
A As it related to Jeff Epstein. 
Q Right. So that when you -- when got sued, 
this was a blanket new civil litigation that you were 
getting involved in. 
A That's correct. 
Q And that's before the counterclaim and all 
Page 160 
that, this was just a brand my new piece of civil 
litigation --
A Right. 
Q -- where you got sued? Okay, arid the first 
complaint for a number of comps. 
A Right. 
Q 
Correct? 
All right. When was it that you -- what 
approximate date did you hire Mr. Scarola? 
A 
I don't remember. 
Q Approximately. The day you got served? I 
mean, you were already friends with him, I guess. 
A Right. Um, I -- I can say with pretty good 
certainty that it was before the end of that year 2009. 
Q 
Okay. Because I'm -- I am seeing here --
A 
Sometime in the month of December, I think. 
Q All right. Because you got 12/7/2009, initial 
complaint, review and research, 8.1 hours. What did he 
send you, War and Peace? 
A Basica!!y. 
Q Oh, okay. Exhibit 2, seven -- point sev --
what's .7 hours translate to, I don't -- I don't --
A 
42 minutes. 
Q Okay. All right. 12/10, let -- letter 
confirming reg...

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Page 163 
MR. HADDAD: Huh? 
THE Wl1NESS: That would be so much fun. 
(Thereupon, a discussion was had off the 
record.) 
MR. HADDAD: So a couple months a year. 
MR. GOLDBERGER: No. 
BY MR. HADDAD: 
Q Letter from Nurik re depo of Rothstein. What 
would that have to do with this case? Just -- just -- l 
am just trying to figure out why that would have 
something to do with this case. 
A 
What? 
Q 
It says here, you know, 35 minutes, Marc Nurik 
couldn't write a letter that lasted 35 minutes. A 
letter from Nurik re depo of Rothstein. He was in my 
office. He is not able to write that well. 
A 
So--
Q 
Well, how did you -- what does that have to do 
with this case? l mean just -- just looking through --
A 
Out of context, that's a tough question for me 
to answer. But I know that in your recent pleadings, 
you have discussed certain things that Scott Rothstein 
testified to in other cases that included me, and so 1 
would have read those portions of that deposition and 
that's what I am presuming that that is. 
Page 164 
Q 
Whoa, whoa, whoa, whoa. The pleadings that 
they -- you have not -- this is -- this is within a few 
months of the initial complaint and -- and -- and I 
don't \Vant to be real argun1entative \.Vith you, because 
there is no jury here, but it says here, 4/14/2010, 
letter from Nurik, re depo of Rothstein. The depo of 
Rothstein wasn't for another three months. Why would 
you bill Epstein -- what's four-tenths, is what, 
25 minutes? 
MS. COLEMAN: Umm-hmm. 
BY MR. HADDAD: 
Q 25 minutes to read a letter from Nurik. Dear 
Brad, I'm going to be taking the deposition of 
Rothstein, do you have any input, is about the most that 
Nurik could get out of a sentence. 
A I don't -- I don't think that that's what that 
means though. 
Q 
Okay, well what -- you are...

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Page 167 
1 
time? 
2 
A 
Scarola did represent me at the time. 
3 
MR. GOLDBERGER: He did. 
4 
MR. HADDAD: Okay. 
5 
BY MR. HADDAD: 
6 
Q And Scarola attended this deposition? 
7 
A 
lt was never taken, it was canceled. 
8 
Q Okay. Did you meet with Scarola for the 
9 
deposition, no discussions you -- between you and 
10 
Scarola, did you prepare him notes, did you do 
11 
something, send them to him? 
12 
A 
I met with Mike Fiston. 
13 
Q Okay. So you prepared the witness for the 
14 
deposition? 
15 
A 
I talked to the witness about the deposition, 
16 
yes, prepared him for the deposition, yes. 
17 
Q For one point -- for almost two hours? 
18 
A 
No, for 1.1 hour. 
19 
Q l.l and .07? 
20 
A 
But that's a different deposition. 
21 
Q Oh, Fendi, I'm sorry, I can't read. 
22 
Okay. So you prepped two people for 
23 
depositions that day? 
24 
A 
Right. 
25 
Q Okay. To be taken by one of Epstein's 
Page 168 
l 
multiple lawyers and to be attended by your lawyer? 
2 
A Right. 
3 
Q Okay. So you are acting as an adjunct to the 
4 
lav1 firrn but ycu \Von't tell me v1hether you already had a 
5 
cooperation agreement with when they were prepping 
6 
depositions --
7 
MR. HADDAD: Well, change it now. You want to 
8 
do that? 
9 
THE VIDEOGRAPHER: The time is 11 :22 A.M. We 
10 
are now coming off the video record. This is the 
11 
end of Tape No. 1. 
12 
(Thereupon, a discussion was had off the 
13 
record.) 
14 
THE VIDEOGRAPHER: So the time is 11 :23 A.M. 
15 
We now back on the video record. This is the start 
16 
ofTape No. 2. 
17 
BY MR. HADDAD: 
18 
Q Could -- could you explain to me -- and I'm 
19 
sorry, maybe it's your shorthand, 5/5/2010, not 
20 
attending, notice of hearing, motion to enlarge time to 
21 
respond to discovery. Two-tenths is what, 12 minutes? 
22 
A Right. 
23 
Q What does that mean, not attending, notice of 
24 
hearing, you got to read the -- it took 12 minutes to 
25 
read a notice of hearing? 
Electronically signed ...

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Page 171 
Scarola's office, West Palm Beach with Judge Camey, 
6.1 hours. Would that be your atten --
A Probably longer than that, but yes. 
Q 
Okay. That would be your attendance there? 
A Right. 
Q Did you participate in that at all or --
A Yes. 
Q -- did Cam -- did Scarola do it? 
A We all did. 
Q What do you mean, we all did, what did you do 
at that hearing, Scarola let you taik and argue? 
A Yes. 
Q 
Okay. All right. 
A 
And l think everybody had some input as to 
what the process was going to be. lt was a complicated 
process related to e-mails. 
Q 2/17/2011, 4 .1 hours, Edwards hearing on 
Edwards motion to compel Judge Crow, 4.1 hours. 
A It takes three hours just to get back and 
forth, so yes, I mean --
Q Well, I'm just asking what this is. So you 
are charging for your time. Did you testify at it? 
A 1 don't remember. 
Q 
All right. Motion to compel are generally not 
testimony, it's usually a hearing, correct? 
Page 172 
A I don't remember what my role was at that 
particular hearing. 
Q Well, you were co-counsel for all of this 
crap, right? 
A Yeah. Yeah. 
Q For all of this stuff? 
A Yeah. 
Q Okay. And you were billing for all of your 
time as well as the time, whether it was duplicated by 
Mr. Scarola or not, correct? 
A I don't have Mr. Scarola's bills, so I was 
billing for all of my time. 
Q 
Okay. Well, I mean, if Jack called you up and 
said, hey, Brad, what about this or that, it was 
discussing the case, you would bill for it? 
A Right. 
MR. HADDAD: What? Excuse me, yes. 
MR. GOLDBERGER: Is this the good ear? 
MR. HADDAD: Yes. 
(Thereupon, a discussion was had off the 
record.) 
BY MR. HADDAD: 
Q 
Okay. I'm ending with this so we're going 
to -- you know, it's getting close to lunchtime. I 
don't know, ifthere is something more important, l wil...

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Page 175 
would prepare pleadings, send them to Scarola and he 
would sign them? 
A Fair. 
Q Pardon? 
A That's fair. 
Q All right. Now, on l 0/18, after you've 
already filed your -- or prepared your amended 
counterclaim, which took an hour, your motion for 57 0 
105 attorney fees, you should have those rote, don't you 
have those you send out with everything, they are all 
the same? l mean, you just have to hit a button and say 
print, no? 
A ls that how it works in your office? 
Q l don't -- we don't do civil. l only do them 
once -- every once in a great while. The last one l 
had, we just mediated out with Judge Crow. 
Review depositions again, all pleadings, all 
offers and pending motions in preparation for conference 
with counsel regarding strategy for defense and also in 
preparation for prosecution of counterclaim, 11 hours, 
which is a little over a day. 
You've been a -- well, let -- let -- let me 
just ask you. What all offers were you having that you 
had to review, what offers were there? 
A lt would have been all offers that Mr. Epstein 
Page 176 
had ever made to the girls. 
Q 
What did that have to do with your 
counterclaim? 
A 
Okay. 
Q 
Just educate me. 
A 
I'm going to try --
Q 
-- because I have to get this case. 
A 
I'm going to try. 
Q Thanks a lot. 
A 
So Mr. Epstein files a complaint against me 
alleging that I am a fraud and I am part of some RICO 
enterprise, and the basis for his claims were that I 
conducted discovery that could not have possibly been 
relevant to any legitimate claims I was prosecuting, 
such as, 1 took depositions of pilots, I included that 
one of the girls gave him oral sex when it was actually 
different underage girls that gave him oral sex, and so 
forth and so on. 
Q 
Okay. 
A 
So I reviewed those things to mak...

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Page 17 9 
see if there was anything else there. 
BY MR. HADDAD: 
Q This all -- all of this preparation, this 
document, why did you talk for an hour and a half about 
hiring Tonja? Well, you did charge an hour and a half 
for that. 
A 
l probably talked longer than that about that 
fact. 
Q 
Oh, did that upset you? 
A Yeah. 
Q 
Okay. 
A l told her that, she knows it upset me. 
MS. COLEMAN: We worked it out. You had to 
know. 
MR. HADDAD: Huh? 
BY MR. HADDAD: 
Q All right. What did you use to prepare this? 
l mean, do you have just a running computer table? 
A No, l would just write it out --
Q Yeah, I know that. 
A --1 would give it to the secretary, somebody 
would type it in. 
Q What do you, you bill like a lot oflawyers, 
you look at the clock and say, okay? l don't have 
billing sheets, l have never billed a time in my life so 
Page 180 
l don't know how you do it. 
A l grab a piece of paper, I look at the clock 
on the computer, finish doing what I'm doing with it, 
v,11ite revie\V correspondence point \Vhatever that is 
closest to a sixth and pass the piece of paper on. 
Q Let me ask you this. To -- to -- and if you 
delineated what you actually did during this time, l 
suppose it would take as much time to write what you did 
as it is to do what you did. So there must be - do you 
have any kind of like on a computer where you can hit on 
a pro -- do you -- do you have a billing program? They 
do make billing programs where you have certain codes 
where can you hit like No. l, talked to client, No. 4? 
A Wedo. 
Q Make up a couple hours? 
A 
We --we have one. We have a billing program. 
Q All right. And --
A 1 can't say that the attorneys are all that 
familiar with it. But, you know, the entries are done 
by the staff. 
Q You are. 
A I write it on -- l write i...

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Page 183 
l 
other things that you don't have to pay for, they really 
2 
think you are okay? 
3 
A 
1 think so. 
4 
Q 
Okay. Let me ask you, how many cases do you 
" 
carry? 
..) 
6 
A 
1 usually try to stay around the 40-case mark. 
7 
Q 
Okay. And that's 40 intentional --
8 
A 
All litigation. 
9 
Q 
-- 40 tort cases? 
10 
A Right. 
11 
Q 
You don't do anything else, right? 
12 
A 
That's it. 
13 
Q 
1 don't mean that pejoratively, but you are 
14 
tort lawyer. 
15 
A 
Basically. ] mean,] do --
16 
Q 
Okay. 
17 
A 
-- ] do have some commercial cases but they 
18 
usually involve some fom1 of criminal act where l am 
19 
representing somebody that] perceive to be a crime 
20 
victim in the case. 
21 
Q 
Okay. 
22 
MR.HADDAD: Anybody got anything? 
23 
A 
Well, 1 know that you have a pending motion 
24 
about certain objections to work product privilege that 
25 
were stated in the first deposition --
Page 184 
l 
BY MR. HADDAD: 
2 
Q Yeah. 
3 
A 
-- and since, those cases are no longer being 
4 
litigated. .t~Jld to the extent tl1at I have injected 
5 
certain things into this litigation to prove why] did 
6 
certain things during discover, I'll answer whatever 
7 
questions you have in that regard. 
8 
Q ] didn't even look at it. 
9 
MS. COLEMAN: I didn't either. 
10 
A 
I just want to make sure this is the last time 
11 
I'm coming back, so I saw your motion, ]'m here until 
12 
we're not here. 
13 
MS. COLEMAN: Can we go off the record for 
14 
minute? 
15 
MR. HADDAD: No, leave it on the record. ]f 
16 
he is going to withdraw his objection, I am not --
17 
I am not prepared to proceed on that anyhow. 
18 
MS. COLEMAN: Yeall, we don't have it with us. 
19 
MR. HADDAD: ] don't even have -- I don't even 
20 
have the prior deposition. 
21 
MR. GOLDBERGER: Well, let's get on the record 
22 
that he is withdrawing them so that we don't have 
23 
to --
24 
MR. HADDAD: Well, yeall. I mean, if you are 
25 
withdrawing everything, we don't even ha...

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Page 187 
about serial abuse and stuff. Did you -- are you 
familiar with this document? 
A No. 
Q 
And it says here, you are listing all 
attorneys involved in the prosecution of civil claims, 
who would that be, who would the experts be that are 
involved in the civil claims, which attorneys do you 
know that to be? 
A 
Which attorneys were involved in the civil 
claims? 
Q 
Well, your experts --
MR. GOLDBERGER: Ask him what -- what he --
what his lawyer means by that, those words? 
MR. HADDAD: Jack. 
MR. GOLDBERGER: I'm sorry. 
MR. HADDAD: Thanks, I wouldn't figure that 
out on my own. Let me stumble through four or five 
questions. 
BY l'v1R. HADDAD: 
Q Did you understand Goldberger's question? 
A 
Between the two of you, I think there is a 
question in there somewhere. 
Q 
This is going to be :frick and frack trying the 
case in there. 
All right, so you listed -- what it boils down 
Page 188 
to is every frickin' civil lawyer that had a claim, 
you're listing as an expert witness, which would be 
Josefsberg --
A 
Josefsberg. 
Q Horo--
A 
Adam Horowitz. 
Q Horowitz, all of them? 
A Ted Leopold. 
Q Yeah. So you are listing them all as expert 
witnesses, which would waive a.-iy claim of privilege 
right now, if they are going to be witnesses for you, if 
they are going to testify about your claims and about 
everything involved in the claims. So let's go back to 
my other question is, did you have a joint -- joint 
agreement with any of these guys? 
MR. KJNG: Objection to the form. 
MR. HADDAD: Okay. 
MR. KJNG: Also reassert the same objection I 
had before. 
MR. HADDAD: Okay. Form objections don't mean 
much, because you know the question. 
MR. KJNG: It's only the -- only the preface 
to the question. 
MR. HADDAD: Well, l understand that. 
Electronically signed b...

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Page 191 
f 
Q All right. So this is -- these persons, these 
lawyers are going to be testifying to everything they 
did in conjunction with you. My question comes back to 
what we asked before the luncheon break. Did you 
gentlemen have what would be considered in essence a 
joint agreement for purposes of prosecuting claims 
against Edwards? 
MR. KING: The same objection. 
A 
l am Edwards. 
BY MR. HADDAD: 
Q Huh? 
A I am Edwards. 
Q ! mean against Epstein. 
MR. KING: The same objection we had before. 
MR. HADDAD: All right. And are you going to 
instruct him not to answer so I can get it there 
quicker? 
MR. KING: Yes. 
lv1R. HADDAD: All right. That makes it very 
simple. Okay. 
MR. KING: And you under -- you understand 
there --
MR. HADDAD: l understand what --
MR. KING: -- are pending motions or motions 
that were resolved that were filed by those lawyers 
Page 192 
and so, you know, in an abundance of caution we --
MR. HADDAD: Bill, I have no problem, we will 
take care of it, I want to make sure I cover the 
record so that I can get it out at some point in 
time. 
A l just can't waive their privilege, that's it. 
BY MR. HADDAD: 
Q I -- I am not asking for privilege, I'm asking 
you whether you had agreement. There is no privilege to 
an agreement. 
MS. COLEMAN: Once they filed it, they waive. 
MR. KING: No, no, ifthere was a filed 
agreement, I would agree, it-- it would be a 
public record, but most joint agreements --
MS. COLEMAN: What J am saying is, by placing 
them on the record as expert witnesses --
MR. HADDAD: I understand that. 
MR. KING: I understand your position, I 
would--
MR. H..A.DDA.D: They waived it. We understand 
what waiver is. 
MR. KING: They waived it. 
MR. HADDAD: Why am I arguing with you, you 
are on my side? 
MR. KING: That's right. 
E...

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Page 195 
1 
Did Fistein -- Fiston interview an individual 
2 
by the name of Michael Friedman? 
3 
A 
I think so. 
4 
Q And who's Michael Friedman? 
5 
A 
A former housekeeper of Jeffrey Epstein. 
6 
Q All right. Did you obtain a written statement 
7 
from him or written investigative file or anything that 
8 
you are aware of? 
9 
A 
No, I don't think so. 
10 
Q Okay. Who was the first investigator that you 
11 
believe involved -- who cares. 
12 
Who was the first investigator that you 
13 
believe was involved in this, who took this depo? 
14 
MS. COLEMAN: Not me, don't look at me. 
15 
MR GOLDBERGER: Just ask the questions. 
16 
MR. HADDAD: I'm sitting here astounded. 
17 
BY MR. HADDAD: 
18 
Q Who was the first investigator to work on 
19 
these cases? 
20 
A 
That I had anything to do with? 
21 
Q Yeah. Work product, instruct you not to 
22 
answer, okay. Work product. 
23 
Who was it, Fiston? 
24 
A 
Wayne Black. 
25 
Q Okay. Wayne Black, and l saw some stuff. 
Page 196 
1 
That's the same Wayne Black that in the e-mails we 
2 
looked at earlier this morning --
3 
A 
Right .. 
4 
n 
-- \Vas referenced by Ken Jenne and stuff? 
'< 
5 
A That's right. 
6 
Q Okay. You already answered this pretty much. 
7 
MR. GOLDBERGER: You don't need to look to me 
8 
for approval, just ask the questions. 
9 
MR. HADDAD: Well, apparently you are telling 
10 
me I'm asking him wrong when I don't ask right. 
11 
BY MR. HADDAD: 
12 
Q Did -- did you ever direct investigators to go 
13 
through Epstein's trash? 
14 
A No. 
15 
Q Okay. Here, I -- l -- I have to ask it again 
16 
a second time, l guess these guys can't ask a question 
17 
15 different ways. With regard to your investigators, 
18 
you gave direction regarding the Epstein cases during 
19 
the time which you were at RRA, did you ever tell them 
20 
or direct them to go through Mr. Epstein's trash? 
21 
A No. 
22 
Q Did you conduct surveillance of Epstein's 
23 
property? 
24 
A No. 
25 
Q Did you...

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Page 199 
Q Okay. 
MR. GOLDBERGER: You are okay. 
BY MR. HADDAD: 
Q 
All right. Let me ask you this: Did you 
auth -- were any informants, comma, did you authorize 
your investigator to hire informants? 
A l don't even know what that means. 
Q Neither do I, but I am just asking the 
question. 
A Like a mole inside Epstein's house? 
Q l think so. 
A How could 1 possibly mean that? No, I did 
not. Regardless, the answer is no. 
Q I don't know, maybe you went to the Sunrise 
Police Department, it's in the news now, and got one of 
their informants to go out and hire somebody. 
A I didn't have that idea. 
MR. GOLDBERGER: Does he -- does he know if 
they went through the --
MR. HADDAD: Huh? 
MR. GOLDBERGER: Does he -- does he know if 
they went through the --
BY MR. HADDAD: 
Q Does anybody -- did anybody go through the 
trash? 
it. 
Page 200 
A 
The police went through his trash. 
Q 
Well, I know the police did, I read that. 
A 
Right, that's all I -- and that's why I know 
Q 
Okay. Did the police hand you some of the 
stuff they found in his trash? 
A I got it the same way everybody else did, it 
was in the State Attorney's file, FOIA request, 
et cetera, I got the stuff from his trash. 
Q 
A four-year request? 
A 
Freedom oflnformation --
Q 
Oh, FOIA. 
MS. COLEMAN: FOIA, F-0-I-A. 
BY MR. HADDAD: 
Q 
I thought you said four-year request. My bad 
ear. 
A 
But, no. 
Q 
Okay. 
A Nobody that I know went through his trash. 
Q Let me ask, did you authorize any 
investigators to trespass on Epstein's property? 
A 
No. 
Q I guess March 17th must be a big day because 
there is 15 questions regarding March 17th, what was 
that day, besides St. Patrick day? 
Electronically signed by Wendy Roberts (201-049-665-8352) 
Electronically signed by Wendy Roberts (201-049-665-8352) 
Electro...

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Page 203 
about Sheer? 
MS. COLEMAN: Bill Sheer. 
BY MR. HADDAD: 
Q Bill Sheer, did you know he was partners with 
Sheer before he went with Rothstein? 
A I know that now. I did not know that then. 
Q Do you know whether or not Sheer actually used 
Rothstein as an attorney? 
A 
I think I have heard that since, but I didn't 
know that then. 
Q Okay. What is the existence of an entity 
called Blueline Research and Development, do you know 
what that is? 
A 
No. I think that there is a similar title, 
Blueline is a private investigation --
Q Okay. 
A 
-- firm of some sort. 
Q But did you ever use them, because that is 
probably what they are talking about? 
A 
During the time l was at RRA, I am assuming? 
Q Yeah. 
A 
No. 
Q I think all these questions were about when 
you were at RRA. 
A Right, I just -- I just wanted to clarify 
Page 204 
that. 
Q Okay. Now, your -- your assoc -- the next 
subject of the matter is on the motion that -- that 
tumed to }v".if. Edvvards interac -- reported interactions 
with anyone associated with the Epstein case and the 
first question is -- excuse me -- during the time that 
you were with RRA -- excuse me, somebody else's 
handwriting -- and had investigation done on 
Mr. Epstein, was any of your investigation that you 
performed turned over to any person outside ofRRA or 
your clients? 
A No. 
Q You understood that? 
A I think that you were asking, did I do 
investigation, get evidence and then tum it over to 
somebody outside of the firm. 
Q That -- that's what the attempt of that 
question was. The answer is no? 
A 
Right. 
Q 
Okay. k'ld any of the directions that you ever 
gave to the investigators, did you ever put that in the 
form of memo, that is, would you give them written 
directions? 
A 
I would just talk to Mike. 
Q 
The d...

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Page 207 I 
Q 
And of course, Dershovitz, the other one is 
Amber Wexner, David Copperfield, all the rest of them, 
correct? 
A Yes. 
Q Okay. And there is no question about that, 
it's in all the rest of the discovery we got afterwards? 
A 
l was involved in the decision to take 
anyone's deposition that was --
Q 
And -- and l think there is an e-mail that we 
saw yesterday, we better do this to put pressure, an 
e-mail or something, it seems like yesterday, l guess it 
was this morning. 
Okay. Did you have any discussions within 
your firm regarding the taking of the depositions of 
several -- of celebrities or famous people who were 
purportedly on Mr. Epstein's plane, so that they could 
be deposed such that would be an inducement to 
Mr. Epstein to settle his lawsuit? 
A 
Was I involved in a discussion? 
Q Yeah, well, you know, what this question is 
asking, did you guys decide to take some depositions so 
you could induce him to settle the lawsuit, that is, 
almost like pressure. I guess inducement means 
pressure, doesn't it, lure, pressure? 
A 
Do you want the short answer or the long 
Page 208 
answer? 
Q Probably the short answer first. 
MR. KJNG: The right answer. 
A 
The correct ans\ver is this. \\7hat \Ve k.tT}e\,V at 
the time was that --
BY MR. HADDAD: 
Q This is going to be the long answer. 
A 
It is going to be. It is going to be, but to 
be complete, I have no other choice. What we knew at 
the time is that Jeffrey Epstein was molesting children 
literally every day. So we tried to take his deposition 
and he took the fifth. We tried to take his various 
co-conspirators' depositions and they took the fifth. 
We tried to take the next tier of people that we knew 
information about him molesting these children and they 
had lawyers who were paid for by...

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Page 211 
the book was made public? A relevancy objection by 
Mr.King. 
A Did I contact any people? 
Q 
First good objection so far. 
Does Scarola read these things? 
A 
I don't think so. 
Q 
Scarola doesn't read them or-.-.-. 
A 
I don't think so. 
Q 
Scarola doesn't read them? 
A I don't even know what question is on the 
table right now. 
MR. KING: I think you -- you directed that 
last question to me. 
MR. HADDAD: Yeah, I know. 
BY MR. HADDAD: 
Q Did you -- did you have contact with any 
persons who were listed in the book that was eventually 
produced by Mr. Rodriquez after he got arrested and --
A I don't remember. 
Q -- and the book was made public? 
A 
I don't remember. 
Q Were you the Cl that turned over 
Mr. Rodriquez? 
A Yes. 
Q Okay. And that wasn't even here, but thanks. 
Page 212 
Well, along the lines that were taken the last 
time with regard to whatever work product was involved, 
that didn't take Inspector Clouseau to figure that out, 
anyhow. 
A 
I don't think I am telling anybody anything 
they don't already know. 
Q Yeah, I -- I know. I didn't want it to seem 
like I was that smart but-.-.-. 
Well, along the lines that were taken with 
regard to whatever work product was involved in the 
investigation in light of the current state of the case, 
you know, who asked these questions? Even --
A 
ls it a question? 
Q Never mind, I'm am reading Mr. King's 
objection. That's not a question. 
MR. KING: That's right. 
MR. HADDAD: He didn't want to be a Cl. He 
wanted the book. We will get to that later. 
That's a good trial question. 
MR. GOLDBERGER: Oh, I'm sorry. 
MR. HADDAD: That's okay. We don't call them 
Cls, we call them cooperative concerned citizens. 
Right? 
MS. COLEMAN: Or narc. 
MR. HADDAD: No, there's no drugs involved. A 
Electronically sign...

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Page 215 
cases was coming from, the source of the money to pay 
the extensive bills that were being incurred on Epstein 
and other cases? 
A 
The law firm. 
Q 
Okay. And that was based --
MR. HADDAD: Jack, do you want -- do you want 
me to stop and take a break so you can tell me what 
to follow up with? 
MR. GOLDBERGER: No. 
MR. KING: Just so -- just so you know, he did 
answer that at the bottom but --
MR. HADDAD: Yeah. 
MR. KING: -- in the last line. 
MR. HADDAD: l saw it now. He said the law 
firm. 
A 
Good. 
BY MR. HADDAD: 
Q And -- and let me just ask you this. ln 
regards to the law firm at that time, and l know we have 
been through this before, there was no perception of the 
law firm being involved in anything other than legal 
activity? 
A Of course not. And other than being involved 
in legal activity. 
Q Legal activity, yeah, that was representing 
Page 216 
Sheer, had --
A You were talking fast. It's -- I wanted to be 
sure there wasn't an issue. 
Q I k.i~oiv, but I "vVasn't trying to sneak one in. 
l did that with the other thing. But any rate, Sheer, 
representing Sheer, it represented everybody in town, it 
was repres -- it was -- you were -- you were playing 
around with John McCain and all those right-wingers, 
tea-party people and all that other -- not -- not you, 
but you know what l mean, taking care of all of that, 
right? So it gave the appearance of a legitimate law 
firm? 
A Yeah, it was a le -- it was, to everybody 
else, a legitimate Jaw firm. 
Q Except for nobody in town, just you guys at 
and the firm. But anyway --
A You should have shared that with Russ Adler 
before. 
Q I knew that was coming. 
Okay, hourly billing confirmed, :financial 
privacy. Okay. These questions aren't too bad. 
MR. HADDAD: Okay. Thanks, Darren. 
Tiffi WITNESS:...

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Page 219 
senled a big church case with one of those priests with 
the Archdiocese? 
A No. 
Q Okay. So how much were you making? 
MR. KING: The same objection, based on the 
Court's rule. 
MR. HADDAD: Okay. Then -- okay. 
MR. KING: Let me -- let me just -- let me 
just touch base with him on one -- on one issue 
relating to that. 
MR. HADDAD: Yeah. 
MR. KING: Because again, we don't want to 
come back. 
THE VIDEOGRAPHER: The time is I :46 P.M. We 
are now coming off of the video record. This is 
the end of Tape No. 2. 
(Thereupon, a discussion was had off the 
record.) 
MR. KING: Let me just tell you our position 
on --
THE VIDEOGRAPHER: The time is 1 :49 P.M. We 
are now back on the video record. This is the 
start of Tape No. 3. 
MR. KING: Sorry. 
THE VIDEOGRAPHER: No problem. 
Page 220 
MR. KING: Let me tell you what our position 
is. These questions, to the extent I believe all 
of them are directed for him to say -- are asking, 
what did you tell Rothstein about vvhat you were 
making and what did you tell Rothstein about what 
you expected to make, we will let him answer those 
questions. 
MR. HADDAD: Okay. 
MR. KING: I think those are the questions to 
which the objections were made and I don't think it 
goes beyond, and then -- but to the extent that 
there are any questions about how much did you 
make --
MR. GOLDBERGER: Right. 
MR. KING: -- at any time, then it falls 
within the Court's order. So let's --
MR. HADDAD: No. 
MR. KING: -- let's -- if you want to go 
that --
MR. HADDAD: Can you answer his question, 
because I don't want to -- let him answer the 
questions. 
A 
I don't remember what I told him either. What 
I had previously made or what I expected, I don't 
remember that conv -- that part of that conversation 
Electronically signed by Wendy Rober...

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Page 223 
MR. KJNG: Right. 
BY MR. HADDAD: 
Q 
Okay. I am just going to -- how much -- how 
much --
A 
Do you read questions off your hand now? 
Q That's how I do everything. Okay. Did 
anybody else hire Kendall Coffey, that you know of, on 
any cases? It's not you, so it can't be privileged. 
MR. KJNG: Well, because -- because we have 
asserted the privilege, I -- I believe it is --
it's appropriate to inquire about why that 
privilege was asserted. 
MS. COLEMAN: I'm sorry, did you say which 
privilege it was? 
MR. KJNG: The attorney-client privilege. We 
asserted attorney-client privilege to a previous 
question. 
MR. HADDAD: Well, that was about all the 
different lawyers that were involved. 
MR. KJNG: No, no. You had asked him whether 
or not -- one of the questions in here was, did you 
consult with -- with Kendall Coffey about a 
subject. 
MR. HADDAD: Oh, that was about whether he 
consulted Kendall Coffey about the guy that --
Page 224 
Rodriguez. 
MR. I<JNG: Right. 
I\.1R. HADDAD: The boy. 
:r-.1R. KING: .A.id we asserted the privilege --
MR. HADDAD: You asserted the privilege on 
that, but this is just hiring without ever 
consultation. Did any --
BY MR. HADDAD: 
Q Well, let me just ask it and then you can just 
say what you want to. 
Did any of the lawyer -- other lawyers who are 
now listed as your expert witnesses ever hire Kendall 
Coffey, to your knowledge, not consult, what they did 
with him? 
A 
I don't know. 
Q 
You don't know. 
What was your involvement with Conchita 
Sarnoff in the Rodriguez case? 
A 
Nothing. 
Q Okay. Did -- did RRA ever hire Kendall 
Coffey, to your knowledge? 
THE WITNESS: I can answer? 
MR. KING: Urnm-hmrn. 
A 
Yes. 
Electronically signed by Wendy Roberts (201-049-665-8352) 
Electronically signed by Wendy Roberts (201-049-665-...

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Page 227 
A 
I don't know, but it was Jess than $25,000, 
you were right in the last motion, I don't know exactly 
what it was though. 
Q 
Okay. So at least not that they should, you 
went with a big finn and they had the money to 
produce -- the ability to prosecute these cases? 
A 
Any cases, right. 
Q 
Yeah, I mean, I understand, you didn't have 
any other cases -- oh, yeah, you did. 
A 
Right, I did. 
Q 
Okay. Did you share info with Conchita 
Sarnoff? 
A I shared public infonnation with her. 
Q 
Is that that reporter from New York? 
A 
Right. 
Q 
Because they didn't put down who it was and 
I'm asking questions. 
A Right. 
Q 
Okay. 
MR. GOLDBERGER: Well done, way to figure it 
out. 
MR. HADDAD: Huh? 
MR. GOLDBERGER: Way to figure it out. 
MR. HADDAD: I never met somebody named 
Conchita unless she was dancing down in a place in 
Page 228 
Mexico when I was down there drinking. Okay. 
Wasn't that Conchita's Cafe in -- down in West 
Texas, town ofEI Paso? 
MS. COLElVlAN: Yes. 
MR. HADDAD: Marty Robbins -- beautiful --
yes. Okay. 
BY MR. HADDAD: 
Q While you were there with RRA living the high 
life, as it were, did you make political contributions 
at all? 
A No. 
Q Okay. Did they make contributions in your 
name? Did you ever become aware whether or not Scott 
was making contributions in your name, because he made a 
contribution in tons of people's names and covered it 
up? 
A Not that I know of. 
Q Okay. 
A No one's ever told me that to this date. 
Q Because you look like a Republica.T1, I t.houg.ht 
maybe that they would have done that. Did you have 
contact with the U.S. Government in this -- Epstein 
civil cases? 
A 
What? 
MR. HADDAD: I don't understand the question, 
Electronically signed by Wendy Roberts (201-049-665-8352) 
Electronically signed by Wendy ...

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Page 231 
1 
MR. EPSTEIN: Yes. 
2 
MR. GOLDBERGER: Okay. 
3 
BY MR. HADDAD: 
4 
Q 
Okay. So there were no changes to the 
5 
settlement agreements. 
6 
The other thing is, have you had any contact 
7 
with Maria Villafranca -- fianca lately in the last 
8 
year, say? 
9 
A 
Villafana. Yes. 
10 
Q And are you still maintaining contact with her 
11 
regarding the litigation? 
12 
A 
What litigation? 
13 
Q 
Well, the CVRA? 
14 
A 
We have no choice, but we are engaged in 
15 
litigation with the Government and she is one of the 
16 
people that participated. 
17 
Q 
All right. And so you maintain contact with 
18 
her regarding that litigation? 
19 
A Right. 
20 
Q 
All right. Are you meeting with her at ail in 
21 
the possibility of prosecuting or re-prosecution and 
22 
discussing that with her, or just the --
23 
A That has never been discussed. 
24 
Q Okay. Now, lastly --
25 
MR. GOLDBERGER: Go ahead. 
Page 232 
1 
MR.HADDAD: Go ahead. No, tell me. 
2 
( conferring). Oh. 
3 
BY MR. HADDAD: 
4 
n 
Have you discussed \Vith her this case tl-iat· you 
'-< 
5 
are doing right now --
6 
A No. 
7 
Q -- involved in this case? 
8 
A I don't believe so. 
9 
Q Do you lmow if she runs over to the Courthouse 
10 
to look at the docket, what do you call that, PACER? 
11 
That's Federal, whatever you call the docket. 
12 
A I have no idea. 
13 
Q All right. Let's go back to the last thing I 
14 
wanted to do and I had forgotten about it, was damages. • 
15 
What are you -- what are you still claiming for damages, 
16 
other than the lost time, anything else? 
17 
A It hasn't changed since last time. 
18 
Q I don't remember what I asked you, I don't 
19 
remember what you said. 
20 
MR. K_TNG: You got into a very detailed 
21 
reputation. 
22 
MR. HADDAD: Is he still -- he is not claiming 
23 
reputation anymore. 
24 
BY MR. HADDAD: 
25 
Q You have a reputation better than ever. What 
Electronically signed by Wendy Roberts (201-049-665-8352) 
Electronically ...

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Page 235 
\ 
A 
Yes. 
MR HADDAD: Any -- all right. 
MS. COLEMAN: You have any -- can 1 ask the 
question? 
:MR. HADDAD: Yeah. 
:MR. GOLDBERGER: lt will get us out of here 
quicker if you let Tonya. 
MS. COLEMAN: Okay. 
CROSS-EXAMJNA TION 
BY MS. COLEMAN: 
Q 
Do you have any documentation that would 
support the claim of financial loss with respect to any 
injury to your reputation or your emotional distress, 
which you claimed previously? 
A I never made a claim for financial loss in 
this case. And --
Q 
Do you have any --
A 
-- emotional distress is what I testified 
about last time, is that it is a matter of who it is 
that is suing me and the level of stress and anxiety 
that has gone along with that is certainly extreme. And 
I have been and remain to be in fear for my safety 
because of him. So will that -- is that still the same? 
Yes, it's the same now, was then, you know. 
Q 
How do you plan to quantify that? 
Page 236 
THE WITNESS: Should I answer this, I mean --
:MR. KING: Hold on, hold on a second. 
THE WITNESS: I can answer it with a question, 
maybe. 
:MR. KING: No, no. 
THE WITI'JESS: Okay. 
:MR. KING: Ultimately, the quantification is 
up to a jury. But it's fair -- it would be fair to 
inquire. He can't put a number on it and it's 
unfair to ask witnesses to put a number on a matter 
that a jury is going to respond to and I would 
object if that's the intent of your question. 
MS. COLEMAN: It is not. 
:MR. KING: If -- if there is a proper more 
precise question, 1 will let him answer. But that 
question calls for -- that's an inappropriate 
question, in that it call -- it asks for what he 
thinks the number might be or what a jury might 
evaluate it to be. At least, arguably, it could be 
construed that way. 
MS. COLEMAN: I mean --
:MR. KING: If you...

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Page 239 
read. So therefore, l have not had a phone call where 
somebody has said, hey, Brad, l was going to hire you 
but l read this and, so, therefore, l'm not, and l am 
hiring some other person, which is the only context in 
which that could ever arrive. 
Q 
But have you always advertised Jeffrey Epstein 
on your firm Web site since you guys founded Farmer 
Jaffe? 
MR. KING: All right. Look, l'm going to 
object. This is repetitious and now we are 
getting -- we are getting to other lawyers asking 
questions well beyond. 
MR. HADDAD: All right, fine. 
BY MR. HADDAD: 
Q 
When was the last time you talked to Marie, by 
the way, Villafrankie {SIC}? 
A 
I don't -- I don't remember. 
Q 
Within the last month? 
A 
No. 
Q 
Okay. And 1 had one good question and it 
escapes me. 
A 
It's on your hand. 
Q 
No, that wasn't the one that was on my hand. 
Uh, It was on damages, I will worry about it later. One 
second. 
Page 240 
MR. HADDAD: Huh? 
MR. GOLDBERGER: The safety stuff, he says he 
got some--
I\.1R. Pi.ADDAD: Oh, yeai½, yea.½) yeah. 
BY MR. HADDAD: 
Q 
How many bodyguards have you hired for your 
safety? 
A 
I haven't hired bodyguards. 
Q Have you changed -- have you changed your 
place ofliving, hiding in an apartment, in a 
safe-house, witness protection? 
A 
Not in witness protection. 
Q Has anybody made any threats to you, 
surveilled you, followed you? 
A 
Yes. 
Q Now, recently? 
A 
Well, I don't know about recently whether they 
have or have not. 1 know that in the past, people did. 
Q For purposes of -- you don't know what 
purposes for -- for preparing for litigation, like 
people do, you know, with those videotapes like the guys 
who said they got bad legs and they play golf when no 
one is looking? 
A 
Right. There is a purpose behind that 
surveillance. ...

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Page 243 
MR. KJNG: Can we detennine that this -- this 
deposition is concluded? 
MR. HADDAD: Yes. 
MR. KJNG: All right. Thank you, sir. 
THE VJDEOGRAPHER: The time is 12:00 P.M. We 
are now coming off the video record. This is the 
end of Tape No. 3. 
(Thereupon, a discussion was had off the 
record.) 
THE REPORTER: Do you want to read this? 
THE WlTNESS: Oh, l can't wait. 
MR. KJNG: Yeah, he will read. Do you want to 
go back on the deposition. He will read. 
THE REPORTER: And do you want one if this 
ordered? 
MR. HADDAD: l can't afford it. 
MS. COLEMAN: l will take it. 
18 
THE REPORTER: Do you want a copy of the 
19 
transcript? 
20 
MR. KJNG: Yeah. 
21 
(Thereupon, a discussion was had off the 
2 2 
record.) 
2 3 
(Witness excused.) 
2 4 
(Thereupon, Plaintiffs Exhibit Nos. l and 2 
2 5 
were marked for identification.) 
Page 244 
(Deposition was adjourned at 2:30 P.M.) 
AND FURTHER DEPONENT SAlTH NOT 
SIGNATURE OF WITNESS 
STATE OF FLORIDA 
BROW ARD COUNTY 
SUBSCRIBED AND SWORN to before me this 
day of 
, 2013 at Broward County, 
Florida. 
Notary Public, State of Florida at Large 
Commission No: 
My Commission Expires: 
Electronically signed by Wendy Roberts (201-049-665-8352) 
Electronically signed by Wendy Roberts (201-049-665-8352) 
Electronically signed by Wendy Roberts (201-049-665-8352) 
CERT!FlCATE OF OATH 
ST A TE OF FLORJDA 
COUNTY OF BROWARD 
l, the undersigned authority, certify that BRADLEY 
EDWARDS personally appeared before me and was duly sworn 
on the 10th day of October, 2013. 
Witness my hand and official seal this 24th day of 
October, 2013. 
Wendy Roberts 
Registered Professional Reporter 
Notary Public, State ofFlorida at Large 
Commission No.: EEl 78268 
My commission expires: March 29, 2016 
CERTIFICATE 
STATEOFFLORIDA,) 
COUNTY OF BROWARD. ) 
l, WENDY ROBER TS, Registered Professional 
Reporter and Notary Public in and for the State of 
Florida at Large, d...

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EMPIRE LEGAL SUPPORT, INC. 
401 EAST LAS OLAS BOULEY ARD, STE 1400 
FORT LAUDERDALE, FL 3330 I 
To: BRADLEY EDWARDS, ESQUIRE 
Fanner Jaffe Weissing Edwards Fistos Lehnnan 
425 North Andrews Avenue, Suite 2 
Fort Lauderdale, Florida 33301 
Re: CASE NO.: 502009CA040800XXXXMBAG 
I 
Dear BRADLEY EDWARDS, 
Your deposition taken in the above 
entitled cause is now ready for signature. 
Please come to this office and sign same; or 
if you "~sh to waive the signing of the 
deposition, please so advise. 
If this deposition has not been signed 
within 30 days of today's date, October 24th, 
2013, we shall consider your signature waived. 
Your prompt attention in this matter is 
appreciated. 
Sincerely, 
-
.• 
Wendy Roberts; RPR 
DEPOSITION ERRATA SHEET 
Our Assignment No. 12217 
Case Caption: JEFFP~Y EPSTEfr~ 
vs. SCOTT RO1HSTEIN 
DECLARATION UNDER PENALTY OF PERJURY 
I declare under penalty of perjury 
that I have read the entire transcript of 
my Deposition taken in the captioned matter 
or the same has been read to me, and 
the same is true and accurate, save and 
except for changes and/or corrections, if 
any, as indicated by me on the DEPOSITTON 
ERRATA SHEET hereof, with the understanding 
that I offer these changes as if still under 
oath. 
Signed on the ___ day of 
, 2013. 
BRADLEY EDWARDS 
Electronically signed by Wendy Roberts (201-049-665-8352) 
Electronically signed by Wendy Roberts (201-049-665-8352) 
Electronically signed by Wendy Roberts (201-049-665-8352) 
DEPOSITION ERRATA SHEET 
Page No. __ Line No. __ Change to: 
Reason for change: 
Page No. __ Line No. __ Change to: 
Reason for change: 
Page No. __ Line No. __ Change to: 
Reason for change: 
Page No. __ Line No. __ Change to: 
Reason for change: 
Page No. __ 
Line No. __ 
Change to: 
Reason for change: 
Page No. __ Line No. __Change to: 
Reason for change: 
Page No. __ Line No. __ 
Change to: 
Reason for change: 
SIGNATURE: 
DATE: 
BRADLEY EDWARDS 
DEPOSITION ERRATA SHEET 
Page No. __ ...

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✓ 
IN THE CIRCUJT COURT OF DIE 
15TH JUDICIAL CIRCUJT, IN AND 
FOR PALM BEACH COUNTY, FLORIDA 
CASE NO.: 502009CA040800XXXXMBAG 
JEFFREY EPSTEIN, 
Plaintiff, 
vs. 
SCOTT ROTHSTEIN, individually, 
and BRADLEY J. EDWARDS, 
individually, 
. Defendants. 
____________ _;/ 
VIDEOTAPE DEPOSITION OF BRADLEY EDWARDS 
May 15th, 2013 
10:00 A.M. - 12:20 P.M. 
40 I East Las Olas Blvd., Suite 1400 
Fort Lauderdale, FL 
Stenographic ally Reported By: 
WENDY ROBER TS, RPR 
Notary Public, State of Florida 
Empire Legal Support, Inc. 
Fort Lauderdale Office 
Phone:(954)241-l0I0 
APPEARANCES: 
ATTORNEY(S) FOR MR. EPSTEIN: 
TONJA HADDAD COLEMAN, ESQUIRE 
Tonja Haddad, PA 
315 SE 7th St Ste30I 
Fort Lauderdale, Florida 333013158 
Phone: 954.467 .1223 
Fax: 954.337.3716 
E-Mail: Tonja@tonjahnddad.com 
FRED HADDAD, ESQUIRE 
Fred Haddad PA 
J Financial Plz Ste 2612 
Fort Lauderdale, Florido 33394006I 
Phone: 954.467.6767 
Fa.x: 954.467.3599 
E-Mail: Haddadfin@aoJ.com 
JACK GOLDGERGER., ESQUIRE 
Anerbury Goldberger Et Al 
250 S Australian Ave Ste 1400 
West Palm Beach, Florida 334015015 
Phone: 561.659.8300 
Fax: 561.835.8691 
E-Mail: Jgoldberger@agwpa.com 
ATTORNEY FOR BRADLEY EDWARDS: 
WJLLIAM KJNG, ESQUIRE 
Searcy Denney Scarola Et Al 
2139 Palin Bench Lakes Blvd 
West Palm Bench, Florida 334096601 
Phone: 56Ui86~6300 • 
Fa.,: 561.684.5816 
E-Mail: \li'bk@searcylaw.com 
ALSO PRESENT: JEFF EPSTEIN, PLAINTIFF 
DEBRA FEIN, LAW CLERK 
EMPIRE 
Electronically signed by Wendy Roberts (201-049-665-8352) 
Electronically signed by Wendy Roberts (201-049-665-8352) 
Electronically signed by Wendy Roberts (201-049-665-8352) 
Page 2 
( 
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Page 3 
INDEX 
WlTNESS: 
Page 
BRADLEY EDWARDS 
Direct Examination by MR. HADDAD 
4 
EXHIBITS 
PLAlNTIFPS: 
EXHIBITS: 
Description 
Page 
No. l part of Farmer, Jaffe, Weissing Web site 93 
No. 2 from the Web site 
93 
No. 3 from the Web site 
93 
No. 4 from the ...

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Page 5 
l 
THE COURT REPORTER: Would you raise your hand 
1 
2 
to be sworn in, please. Do you solemnly swear the 
2 
3 
testimony you are about to give in this case will 
3 
4 
be the truth, the whole truth and nothing but the 
4 
5 
truth, so help you God? 
5 
6 
THE WITNESS: Yes. 
6 
7 
Thereupon: 
7 
8 
BRADLEY EDWARDS 
8 
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having been first duly sworn or affirmed, was 
9 
10 
examined and testified as follows: 
1 O 
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DIRECT EXAMINATION 
11 
12 
BY MR. HADDAD: 
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13 
Q State your name, please. 
13 
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A Brad Edwards. 
14 
15 
Q All right. And is that your practicing name 
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or your legal name? 
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A My practicing name. 
1 7 
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Q All right. You're Bradley Edward, what's your 
18 
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middle name? 
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A Bradley James Edwards. 
2 O 
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Q Okay. You're how old? 
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A 
■· 
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23 
Q Okay. You were admitted to practice when? 
2 3 
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A 2002. 
2 4 
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Q All right. So that's 13 years you have been 
2 5 
Page 6 
1 
practicing -- no, 11 years? 
1 
; 
... 2 
A Y~. 
2 
3 
Q Ail right. And my recollection is you gave a 
3 
4 
deposition in 2010, correct? 
4 
5 
A 
C01Tect. 
5 
6 
Q A couple hundred pages of depositions? 
6 
7 
A 
Correct. 
7 
8 
Q All right. And I am not here to reinvent the 
8 
9 
wheel or reinvent the deposition. I ]mow what you said 
9 
10 
then. We've had three years elapse since that time so I 
10 
11 
just want to catch up a little bit to start with. You 
11 
12 
spent some time in the State Attorney's Office, correct? 
12 
13 
A 
Correct. 
13 
14 
Q How many years? 
14 
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A Roughly three. 
15 
16 
Q All right. And when you left the State 
16 
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Attorney's Office, were you a division prosecutor, 
1 7 
18 
special units prosecutor? 
18 
19 
A Division prosecutor. 
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Q Which division were you in when you left, if 
2 0 
21 
you recall? 
21 
22 
A JudgeGates. 
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23 
Q 
Okay. And were you the lead? 
2 3 
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A Yes. 
24 
25 
Q And how long had you had the lead in that 
2 5 
Page 7 
division? 
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Page 9 
1 
personal injury tort lawyer. He did mainly qui tam and 
2 
class action, which was a separate division ofRRA. 
3 
Q All right. Now, you left that firm obviously 
4 
for the obvious reason, there was no firm, and you guys 
5 
started your own firm; would that be fair? 
6 
A I started my own firm with some of the other 
7 
people that were previously at RRA, correct. 
8 
Q 
All right. And my recollection is you are an 
9 
association ofP.A.s, correct? 
10 
A Yes. 
11 
Q P.A., that's another association of P.A., am I 
12 
correct? 
13 
A The cmTent firm that I'm at? 
14 
Q Yeah, yeah. 
15 
A Yeah. 
16 
Q You are Bradley Edwards, P.A., as part of the 
17 
rest of the firm P.A., correct? 
18 
A 
You have the right idea. 
19 
Q Huh? 
20 
A You have the right idea. 
21 
Q Thank you. 
22 
MR. GOLDBERGER: He's an LLC. 
23 
MR. HADDAD: Huh? 
24 
MR. GOLDBERGER: He's an LLC, that's what he's 
25 
trying to tell you. 
Page 10 
-
1 
A 
Yeah, but you are on the right track, I got 
2 
you, we understand each other. 
/ 
3 
MR HADDAD: We are the same, Jack. You know, 
4 
us poor sole practitioners don't get along with 
5 
that sort of thing, you know. We are from the old 
6 
school, we don't need to keep books. 
7 
BY MR. HADDAD: 
8 
Q So at any rate, you became with that film, 
9 
correct? 
10 
A 
Yes. 
11 
Q All right. Now, you brought with you, and I'm 
12 
not going through all of this other stuff, the Epstein 
13 
cases, correct? When you went to RRA, that was part of 
14 
the reason Russell was asking you to come in? 
15 
MR. KING: I'm going to object because this is 
16 
repetitious. 
17 
MR. HADDAD: I understand that. 
18 
MR KING: It was all done in his first depo. 
19 
I'm giving you a little lee'wafhere so_: 
20 
MR. HADDAD: Yeah, I understand. I'm just 
21 
trying to lead into this. I am not trying to go 
22 
into that all over again. 
23 
BY MR. HADDAD: 
24 
Q It's just from more of a pointing chip for the 
25 
deposition, correct? 
1 
2 ...

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·, 
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summer of 2008. I don't know the exact month. 
1 
Q 
All right. And is it near resolution? 
2 
A 
I don't know. 
3 
Q 
Is -- can you tell me the style of the case? 
4 
A 
Yes, it's Jane Doe I and Jane Doe II versus 
5 
United States of America 
6 
Q 
All right. And the purpose of that lawsuit is 
7 
to do what? 
8 
A 
Hold the United States Attorney's Office and 
9 
Government responsible for violating the rights of the 
10 
victims in that particular case. 
11 
Q 
By entering into a settlement agreement with 
12 
tv'.lr. Epstein? 
13 
A 
It has nothing to do with Mr. Epstein. He 
14 
voluntarily intervened into the case; had something to 
15 
do with discovery that we were trying to get. 
16 
Q 
All right. 
1 7 
A 
I think Roy Black represents him in that. 
18 
Q 
Okay. And that's for the -- okay, I will let 
19 
it go at that for just a minute. 
2 0 
The ultimate result of what you are seeking in 
21 
it that suit is what? 
2 2 
A 
Something that compensates the victims. 
2 3 
Q 
Financially or otherwise? 
2 4 
A 
I don't believe the Crime Victims' Rights Act 
2 5 
Page 14 
allows for financial recovery. 
1 
Q What -- what recovery does it allow? 
2 
A 
Well, that's part of -- that is what that 
3 
lawsuit is about, I mean, I think that we have proven 
4 
that there was a violation, now we're at a stage where 
5 
there is an attempt to uncover what Judge Marra believes 
6 
is the appropriate remedy for the violation. 
7 
Q 
All right. 
8 
A 
And I don't know what his result is going to 
9 
be. 
10 
Q All right. 
11 
A 
It's going to be a judge-made decision. 
12 
Q I'm sorry. That lawsuit has been pending 
13 
since 2008, you said, correct? 
14 
A 
That was the first of all of the lawsuits that 
15 
was filed. 
16 
Q All right. 
1 7 
A 
Yes. 
18 
Q And...

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of this lawsuit and because of the suit that WcJ.S 
1 
filed, I think it's totally relevant. 
2 
MR. KING: Well, I -- I --
3 
MR. HADDAD: If you wantto instruct him not 
4 
to answer, we can take it up before a judge. 
5 
MR. KING: Right. I disagree. 
6 
MR. HADDAD: It's up to you, Mr. King. 
7 
MR. KING: I disagree. 
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MR. HADDAD: That's why we have judges. 
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MR. KING: I will allow you some -- some 
10 
leeway there, but then I'll evaluate it as you go 
11 
along. 
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MR. HADDAD: Can you give me his answers 
13 
per diem? 
14 
BY MR. HADDAD: 
15 
Q 
So I will ask the question again, how much 
1 6 
time -- and see what the leeway is -- how much time 
1 7 
would you say roughly you devoted -- let's -- okay, 
1 8 
let's call it since to 2010, since your last deposition 
1 9 
'til today, approximately? 
2 0 
A I don't !mow. If you showed me the docket on 
21 
that case or something that would help me, then I could 
2 2 
approximate a little better, but I really don't know. 
2 3 
Q 
All right. Just for -- in your answers to 
2 4 
interrogatories, you have been obligated to divert --
2 5 
Page 18 
your response was: "To divert time, effort and attention 
from the productive practice of his profession to defend 
tortious misconduct of Epstein. Every minute the 
verdict -- verdict from his professional pursuits 
impeded his ability to advance the claims and interest 
of existing clients and precluded him from taking other 
and additional responsibilities. Time records made 
available in response to Epstein's response, request to 
produce detail, at a minimum, the extent of the 
diversion he is suffering." 
So you obviously must have been aware of these 
when you produced these and filed these responses to 
interrogatories. I'm just asking for an approximat...

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1 
Q 
Was that the Government who filed it or was it 
1 
2 
someone intervening who filed it? 
2 
3 
A 
It wasn't someone intervening. It was either 
3 
4 
the Government filing a motion or the Court sua sponte 
4 
5 
issuing -- I don't remember it being an order, but I 
5 
6 
remember seeing some notification that it was going to 
6 
7 
be dismissed or something along those lines. 
7 
8 
Q 
All right. I think since I started with this, 
8 
9 
with the diversion of time, effort, when you started the 
9 
10 
law firm in 2000 -- well, 2009 you started the law firm, 
10 
11 
correct, October of 2009, your deposition was in 
11 
12 
Febmary of2010; as I recall, correct? 
12 
13 
A 
Okay. I'm taking your word for it. 
13 
14 
Q 
Well, do you think I would bull -- I would 
14 
15 
make a misrepresentation to you? 
15 
16 
A 
Not intentionally. 
1 6 
17 
Q 
Well, I just did because it was March 23rd. 
1 7 
18 
A There we go. 
1 8 
19 
Q 
I apologize so~.~.~. I forgot we have a video 
19 
20 
recording. I almost slipped and thought I was in 
2 0 
21 
trial -- in crirni nal court. 
2 1 
22 
At any rate, March 23rd, so that would have 
2 2 
23 
been five months after you went into practice, cmTect? 
2 3 
24 
A 
Five months after we started --
2 4 
25 
Q 
You started the firm? 
2 5 
Page 22 
-
1 
A -- our current law firm. 
1 
2 
Q All right. Now, when RRA imploded, you 
2 
3 
started the current finn, were all the named partners in 
3 
4 
that firm members ofRRA? 
4 
5 
A Yes. 
5 
6 
Q Farmer, Jack. Matt Weissing had been over 
6 
7 
th~? 
7 
8 
A Yes. 
8 
9 
Q All right. And you all regrouped. Where are 
9 
10 
your offices located now? 
1 0 
11 
A Andrews A venue. 
11 
12 
Q Where? 
12 
13 
A 425. 
13 
14 
Q Andrews A venue, north or south? 
1 4 
15 
A Just south of Maguire's, north of Broward. 
15 
16 
Trying to give you landmarks you may know. 
1 6 
17 
Q No, nothing is better for you guys than that 
1 7 
18 
law firm, that -- I tell you, I u...

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Page 25 
produced this time record. With respect to reputation, 
I believe that over the course of the last three years I 
have done a pretty dam good job resurrecting any damage 
that was done to my reputation in this community. 
Q 
Well, let's -- let's start with that. You 
don't -- you never had a reputation damage, did you? 
MR. KING: Objection, form. 
BY MR. HADDAD: 
Q 
Okay. What damage, if any, did you initially 
have done to your reputation by the filing of a lawsuit 
against you that suggested that you were so aggressive 
as a lawyer someone was going to sue you? 
A No, the iawsuit that was fiied against me --
MR. KING: Object to form, argumentative. 
A The lawsuit that was filed --
MR HADDAD: I was paying a compliment. 
MR. KING: Yes. 
Go ahead. 
A The lawsuit that was filed against me said 
that I was part of some racketeering scheme, said that I 
was involved in a Ponzi scheme, that I was 
co-conspirator of Scott Rothstein's and that I was 
committing fraud and conspiracy to commit fraud. A 
bunch of criminal actions were alleged against me. In 
fact, I thinlc the complaint was entirely crimes that I 
Page 26 
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had committed as a lawyer, which is the exact opposite 
1 
ofthe type of reputation that you want as a lawyer. 
2 
With that being said, that complaint, the 
3 
various motions maki!1g those allegations about me being 
4 
some form ofco.:conspirator in a Ponzi scheme was 
5 
repeatedly filed and stated on the record and in 
6 
hallways over at the bankruptcy court, because every 
7 
lawyer who was imybody in South Florida had something to 
8 
do with the bankruptcy proceedings over at the 
9 
bankruptcy court. So I had to go over there 
1 0 
continuously and...

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Page 29 
his lawyers. 
1 
Q 
Let me ask you this as a lawyer. Let me ask 
2 
you this as a I awyer. You are a prosecutor, correct? 
3 
A 
Yes. 
4 
Q 
And I read in your deposition you didn't do 
5 
RJCO cases and you didn't really do economic crimes, 
6 
correct? 
7 
A 
Right. 
8 
Q 
All right. Did you investigate cases? 
9 
A 
Yes. 
10 
Q 
Okay. And you're aware that in the instance 
11 
of this case that Mr. Rothstein used, and I mean it's 
12 
hundreds of pages to your depo that I'm not going to 
13 
reinvent the wheel on or !O's of20 pages that 
14 
Mr. Rothstein had your boxes and your cases included in 
15 
a room right upstairs here wher_e he brought in 
1 6 
investors, correct? 
1 7 
A 
I am aware of that. 
18 
Q And he used your cases, Bradley Edwards' cases 
1 9 
to lure investors into his fraudulent schemes, you've 
2 0 
testified to that in bankruptcy court and other courts, 
21 
haven't you? 
2 2 
MR. KING: Objection, form. 
2 3 
MR. HADDAD: Oh, excuse me, you are right 
2 4 
counsel, I'll try. 
2 5 
Page 31 
obviously, that Scott preyed upon you, as it were. You 
were one of Scott's victims. No -- no -- incredibly --
not -- not incredibly because Scott would do that to 
anybody, you were one of Scott's victims. He didn't 
care two cents about using you; would you agree? 
A 
Clearly. 
Q 
Obviously, he put you in that position, 
correct? 
A 
Clearly. 
Q 
He brought you in and every single investor, 
whether they were criminal investors or not criminal 
investors, were led to believe that Bradley Edwards was 
assisting him and using his cases to promulgate these 
settlements, correct? 
A 
I don't !mow that at all --
Q 
All right. Well, you've heard that from 
Sheer--
A 
-- to be true. 
Q -- when he won his verdicts and his lawsuits, 
didn't you? I am just asking --
A 
No. 
Q 
-- if you familiarized yourself with --
A 
No. 
Q 
-- that tome that...

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Page 33 
1 
A 
A complaint that was --
1 
2 
Q Umm-hmm. 
2 
3 
A -- filed but never served --
3 
4 
Q Yeah. 
4 
5 
A -- against Epstein? 
5 
6 
Q Yeah, a complaint that was --
6 
7 
A 
By Scott Rothstein? 
7 
8 
Q No, by you? You signed it --
8 
9 
A 
Oh, did 1? 
9 
10 
Q Yeah. And it was a misspelling of some type. 
10 
11 
A Fred, just ask me a question, 1 will answer 
11 
12 
it. You are asking so many different things. 1 don't 
12 
13 
know what you are talking about. 
13 
14 
Q Do you remember filing another lawsuit at the 
1 4 
• 15 
time Rothstein's Ponzi scheme was falling apart? 
15 
16 
A Did I file a lawsuit--
16 
17 
Q Yes --
l 7 
18 
A -- when Scott Rothstein's --
1 8 
19 
Q -- that was never served? 
1 9 
20 
A -- Ponzi scheme was falling apart? 
2 0 
21 
MR. HADDAD: Let me just see, Jack Do you 
21 
22 
want to take over? 
2 2 
23 
BY MR. HADDAD: 
2 3 
24 
Q Okay. You don't remember a Federal court 
2 4 
25 
case? 
2 5 
Page 34 
--
1 
A About Jeffrey Epstein. 
1 
2 
Q Umm-hrnm. 
2 
3 
A 
Or about -- it had nothing to do with 
3 
4 
Rothstein? 
4 
5 
Q No, Jeffrey Epstein. 
5 
6 
A Okay. 
6 
7 
Q A lengthy Federal case against Mr. Epstein? 
7 
8 
A I filed Federal complaints against Jeffrey 
B 
9 
Epstein before. 
9 
10 
Q Okay. Do you recall one that was filed that 
1 O 
11 
was never served that contained a misspelling of 
11 
12 
someone's name? l'mjust asking if you recall. If you 
12 
13 
don't recall it, you can tell me. 
13 
14 
A 1 recall filing a complaint against hirn that 
14 
15 
was never served. 1 don't know about a misspelling or 
15 
16 
what we are talking about. 
1 6 
17 
Q Do you recall filing one against him that was 
1 7 
18 
never served, correct? 
1 B 
19 
A·. • I do recall filing a complaint against hirri. • 
19 
20 
It was never served. 
2 0 
21 
Q How long was that complaint? 
21 
22 
A I don't know. lfyou have it, 1 will look at 
22 
23 
it. It will definitely help to refresh my recollection. 
2 3 
24 
It...

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Page 37 
trying to be difficult but I'm just going off what you 
1 
said. 
2 
Q Be difficult, it's fine with me. 
3 
A 
I don't want to be. I want it to be over with 
4 
so go ahead. 
5 
Q It will be over with tomorrow. 
6 
A 
At this rate, for sure. 
7 
Q 
So at any rate, Rothstein had said what he 
8 
said in the deposition, the deposition speaks for itself 
9 
but --
1 O 
A 
Right. 
11 
Q -- do you recall --
1 2 
A 
I was there. 
13 
Q -- when was that deposition? 
14 
A 
I don't remember. 
15 
Q Do you recall the year? 
1 6 
A 
Can you show me the deposition? It was either 
1 7 
2011 or 2012. 
18 
Q 
Okay. When he was deposed for those days that 
19 
Judge Bray -- Judge Cohn allowed? 
2 0 
A 
Deposed in this case I think --
2 1 
Q Yes. 
22 
A 
-- that your daughter took the deposition. 
2 3 
Q Do we -- she's old, can you refer to her as 
2 4 
co-counsel? All right. She took the deposition. All 
2 5 
Page 38 
right. And that was -- that was the video deposition as 
1 
opposed to Scott being in person when he was over the 
2 
grand jury room, correct? 
3 
A 
I didn't even know that happened, so, yes, 
4 
that's when it was. 
5 
Q Ail right. Now, that would have been within a 
6 
year, year and a halflater ago, correct, something like 
7 
that; would that be accurate? 
8 
A 
I'm not going to quarrel it, if you are 
9 
telling me --
10 
Q Yeah. 
11 
A 
-- that's what it was, that's it. 
1 2 
Q All right. And at that point in time, any 
13 
person who ]mew anything at all or was following the 
14 
case would have learned that Scott Rothstein 
15 
affirmatively stated you had no involvement? 
1 6 
A 
I agree with that. 
1 7 
Q 
Okay. Do you know whether or not he had made 
18 
that representatioii'toothers prior to that in other 
19 
depositions or in debri...

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Page 41 
BY MR. HADDAD: 
1 
Q 
Well, let me ask you this: In --
2 
A 
Do I believe that right now my reputation is 
3 
better than it has been at any time in the past, yes. 
4 
Q 
All right. And as a matter of fact, since the 
5 
Rothstein case, you're now included, probably one of the 
6 
youngest guys there is, in Best Lawyers in America, 
7 
correct? 
8 
A 
Probably. 
9 
Q 
All right. There are not many guys that have 
10 
been practicing ] I years to be included in that. 
11 
A 
I agree. 
12 
Q 
And that is 100 percent for old people like 
13 
Goldberger, for the most part. You are included in that 
14 
based upon peer review and nothing else? 
15 
A 
That's true. 
1 6 
Q 
You--
17 
A 
I mean, I don't ac -- actually don't imow the 
18 
answer to that. I -- if you are saying that's what it 
19 
is, it might be. 
2 0 
Q 
Did you solicit anybody to become in that? 
2 1 
A 
No. 
22 
Q 
Did you receive a letter saying you have been 
2 3 
nominated for Best Lawyers in America? 
2 4 
A 
I don't think so. 
2 5 
Page 42 
Q No, you just got a notice one day that you --
1 
A 
Right. 
2 
Q -- are included, correct? 
3 
A 
Right, that's true. 
4 
Q 
Out of the whole world, out of thousands of 
5 
lawyers practicing law 10 years, you are notified, hey, 
6 
you are one of the best lawyers in America for what you 
7 
do? 
8 
A 
Right. 
9 
Q 
Okay. Now, you also are one of the top 40 
10 
lawyers under 40, correct? 
11 
A 
Right. 
12 
Q 
You are 37 years old? 
13 
A 
Correct. 
1 4 
Q And you are considered one of the top trial 
15 
lawyers in Florida? 
16 
A 
Right. 
17 
Q There is a group called the Top 100 T1ial 
18 
Lawyers in America, correct? 
19 
A 
I think so. 
2 0 
Q That's part of what you are in? 
21 
A Okay. 
22 
Q 
Yeah, they have the top 100 trial lawyers for 
2 3 
o...

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____ _.,. 
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Page 45 
Q 
Okay. 
1 
A 
1 answered one question one time. 
2 
Q 
Yeah, about herpes or something? 
3 
A 
1 participate a lot less than everybody else 
4 
in my law firm, yes. 
5 
Q 
Okay. But 1 am just saying, you got -- they 
6 
rated you without your request, correct? 
7 
A That's true. 
8 
Q 
And they rated you as a superb lawyer? 
9 
A 
Okay. 
10 
Q 
Yes orno? 
11 
A 1 don't know. 
12 
Q 
Let me--weii-
13 
A 
You keep up with this more than 1 do. l'm 
14 
telling you, I don't -- I don't --
15 
Q 
1 didn't keep up with this at all. 
16 
A 
1 don't know these things. 
1 7 
Q 
I don't know how to use computers. Somebody 
18 
did this for me. 
19 
A 
Show me what it is and I'll --
2 O 
Q Yeah. Do you think I care about looking up 
21 
Brad Edwards? 
2 2 
A 
Apparently. 
2 3 
Q 
I don't even look up myself 
2 4 
A 
Exactly, that's my point. 
2 5 
Page 46 
MR. GOLDBERGER: Someone did it for me. 
1 
MR. HADDAD: Oh, someone did it for you? 
2 
MR. GOLDBERGER: Look at the number. 
3 
MR. HADDAD: What? 
4 
MR. GOLDBERGER: 10.0.B. 
5 
MR. HADDAD: 10.0? 
6 
A 
Yep. I don't know -
7 
BY MR. HADDAD: 
8 
Q 
Okay. You're rated as a superb lawyer, 
9 
correct? 
1 0 
A 
Okay. Yes. 
11 
Q 
Okay. Now, that's not a bad reputation to 
12 
have at 11 years out, correct? 
13 
A 
No, I -- I agree, 1 said that from the 
14 
beginning. 
15 
Q All right. And 2009, 2010, you didn't have 
16 
any of these accolades? 
1 7 
A 
I -- I agree with that. 1 think that's right. 
18 
Q 
Okay. So that's evolved iri the last two 
19 
years, okay; would you agree with that? 
2 0 
A 
Yes. 
21 
Q 
Ali right. And then -
2 2 
A 
I think it has a lot to do with jury verdicts 
2 3 
that I have received that have nothing to do with 
2 4 
Epstein but iust to the extent that you are implying it 
2...

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Page 49 
A 
I don't lrnow that. 
1 
Q 
Okay. How about Skip Campbell, you are 
2 
buddies with him? 
3 
A I never talked to him in my life. 
4 
Q Oh, you didn't, I thought you lrnew him. 
5 
A No, l don't lrnow him. 
6 
Q So you made 20 million in verdicts in the last 
7 
two, three years? 
8 
A llighl. 
9 
Q Okay. And how many-- how much money has your 
10 
firm had in gross verdicts in the last couple of years, 
11 
let's say the last since 2009, when you all split 
12 
with -- well, you didn't split with Rothstein when you 
13 
were, I want to say disemboweled, but, I guess, 
14 
disengaged with that law firm, how much money has --
15 
what's the name, Farmer, Jaffe, let me just use short 
1 6 
for that? 
1 7 
A I tried the vast majority of our cases at that 
1 8 
firm. 
19 
Q Okay. How much -- well, did Gary Farmer win a 
2 0 
big verdict recently or a settlement? 
21 
A Maybe that, but --
2 2 
Q Settlement was how much? 
23 
A -- you lrnow the difference. 
2 4 
Q Yeah. Do I lrnow the difference? A little 
2 5 
Page 50 
bit, not much. 
1 
A 
Yeah. Exactly. 
2 
Q 
How much did Farmer settle for? 
3 
A 
He has had a bunch of them. 
4 
Q 
How much would you say he's settled for, he 
5 
has had some -- didn't he have a big qui tam suit, or 
6 
whatever you call them? 
7 
A 
He has had several of them, yes. 
8 
Q 
How much did he settle for? 
9 
A 
Hundreds of millions of dollars. 
10 
Q 
More than that, no, didn't he settle one for a 
11 
billion? 
12 
A 
I think that predated our current firm though. 
13 
Q 
Oh, okay. So hundreds of millions of dollars 
14 
coming into your finn from him in settlements? 
15 
A 
I mean, that's a different question that I'm 
1 6 
not willing to answer but~.~.~. 
1 7 
Q 
Okay. 
18 
• • A • • Ahd it has nothing to do with me, I mean, ...

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1 
me let you finish your question. 
2 
A Donald Baker, is that the --
3 
MS. HADDAD COLEMAN: No, it's different. 
4 
THE W1TNESS: Oh, different. 
5 
BY MR. HADDAD: 
6 
Q Oh, you got sued twice? 
7 
A Apparently. 
8 
Q All right. And then did -- let me ask you 
9 
about the -- I had it right here. 
10 
A I convicted some guy, he went to prison and 
11 
then sued the judge and every -- all the police and 
12 
everything else. 
13 
MR. GOLDBERGER: Here you go. 
14 
MS. HADDAD COLEMAN: This guy's name is 
15 
different. 
16 
MR. HADDAD: Yeah, Shaarbay, Sharbasom. I 
17 
guess that must be --
18 
MR. GOLDBERGER: Spell it. 
19 
MR. HADDAD: -- the Arab guy. S-H-A-A-R-B-A-Y 
20 
versus --
21 
A News tome. 
22 
BY MR. HADDAD: 
23 
Q - various persons. Were you ever served with 
24 
a lawsuit? Among the persons sued was --
25 
A No. 
Page 54 
. 1 
Q - Pete Weinstein, Michael Gates, Finkelstein, 
2 
Satz, Dan Callahan, Brad Edwards. 
·--.. ,./ 3 
A No. I don't recognize that person's name. I 
4 
have never been served with that lawsuit, to my 
5 
recollection. 
6 
Q To your recollection, okay. 
7 
A No. 
8 
Q All right. Bu1 you said there was another 
9 
one, who else sued you? 
10 
A Donald Baker sued me and Mike Satz and Michael 
11 
Gates and all of the Hollywood Police Department. 
12 
Q And what happened with that case? 
13 
A 
It was dismissed. 
14 
Q All right. Would those predate the time that 
15 
you were sued by Mr. Epstein? 
16 
A Yes. 
17 
Q Okay. Now, tell me how --
18 
A Well, I don't know about this new one that you 
19 
just told me abcii.Jt it, it may have been yesterday for 
20 
all I know. 
21 
Q All right. 
,.,,., 
A 
I am unaware of it. 
<.<. 
23 
Q Emotional distress, embarrassment, mental 
24 
anguish, humiliation, 1 will start with those, because 
25 
we know loss of reputation and standing in the community 
1 
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1 
unscathed and nobody thought that 60 lawyers were 
. · .. 
2 
involved in a Ponzi scheme. I -- me and your client, 
3 
Russ Adler, are two of the only that have been pinned as 
4 
co-conspirators of Scott Rothstein's. 
5 
Q No, I would say there have been others. 
6 
A 
Well, you would lmow better than I. 
7 
Q Of course. 
8 
A 
But publicly -- well, that was my perception. 
9 
Q And I noticed Adler is still out there trying 
10 
cases, he just won three million bucks down in Miami 
11 
with some lawyer. 
12 
A 
He is a good lawyer. 
13 
Q 
Okay. And you are a good lawyer. 
14 
A Right. 
15 
Q 
All right. And I want to lmow exactly where 
16 
you were humil -- all right, I understand no one likes 
17 
getting sued and no one likes being accused of anything, 
18 
how did it impact you, this emotional distress, 
19 
embarrassment and mental anguish, how did it manifest 
20 
itself that we can put a -- a -- anything on it. Did 
21 
you ever not go to court? 
22 
A 
No, I -- I always fulfilled my obligations. 
23 
Q 
Did you seek -- did you seek mental -- uh, 
24 
what do they call those people, mental health helpers --
25 
A 
No. 
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Page 59 
about and who he doesn't care about and I know the kinds 
of things that he has done in the past, how he lives his 
life and what he is capable of doing to n,e and what I 
believedthathewouldtodome. Soyeah, it's all 
about him. 
Q All right. And let's go there. So everything 
is about J effiey Epstein because he sued you, as opposed 
to anyone else in the world? 
A Yeah. 
MR. KING: You know, I'm going to -- let me --
let me interject here. I was at a prior deposition 
where Mr. Epstein was here and it's the same facial 
expressions, the same unprofessional attitude that 
he is displaying here that he displayed then. So 
I'm just going to ask you to instruct him to 
maintain a poker face, to the extent h...

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Page 63 
1 
A 
Right. 
1 
A I -- I know. You also told everybody in the 
2 
Q 
Did you get threatened by people when you were 
2 
courtroom that on that day, very, very lffudly. I 
3 
putting them in prison? 
3 
remember. 
4 
A 
To some extent. 
4 
Q That's right, Marty Vanskyhawk. 
5 
Q 
Yeah, you were a prosecutor, you --
5 
A That was it. 
6 
A 
Yeah. 
6 
MS. HADDAD COLEMAN: He needs to stop paying 
7 
Q 
-- were threatened by criminals, correct? 
7 
my exterminator apparently. 
8 
A 
Right. 
8 
Tv!R.. HADDAD: He stuck dead fish down the eaves 
9 
Q 
People that were going to prison? 
9 
of the house when they went to throw him out? 
10 
A 
Yeah. 
10 
A Correct. 
11 
Q 
They threatened to kill you, they threatened 
11 
Q Barracudas and Wahoo? 
12 
to get even with you, all kind of stuff, correct? 
12 
A Exactly. 
13 
A 
Right. 
13 
Q Yes. And If you were Norwegia...7, you would 
14 
Q And you were a -- I was going to slip again --
14 
have called it lutefisk and ate it. 
15 
you were a hard-nosed prosecutor? 
15 
A And you actually had it with Jody, but she 
16 
A 
That's true. 
16 
wasn't there that day, so I had to deal with you and him 
17 
Q 
All right. And you had the biggest -- I can't 
17 
and the whole mess. 
18 
think of him without saying anything, the hardest 
18 
Q Well. 
19 
unyielding judge there was in Michael Gates, correct? 
19 
A So yes. 
20 
A 
Great judge. 
20 
Q Okay. So, let's face it, you --you --
21 
Q 
There was no amount of prison time that was 
21 
A And he went to prison for fish. 
22 
not enough for him, great judge as you said, correct? 
22 
Q He went to prison for fish. 
23 
A 
I don't know if that's correct, I don't agree 
23 
A Right. 
24 
with that. 
24 
Q So did Jerry Chilli when I represented him. 
25 
Q 
Well, he was worse than -- well, you don't 
25 
Of course, he was a Mob kingpin. Excuse me. 
Page 62 
Page 64 
1 
remember Futch, you weren't born yet. He was the 
1 
(Thereupon, a discussion was ...

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Page 65 
1 
talked about your finn has a PR department, correct? 
2 
A 
That's correct. 
3 
Q 
Which is not unusual, I guess, for personal 
4 
injury lawyers, correct? 
5 
A 
That's correct. 
6 
Q 
All right. I don't know if it's -- how often 
7 
does -- and the only reason I'm asking is I went through 
8 
this stuff and I'm seeing this, what they call a PR log. 
9 
A 
Okay. 
10 
Q 
Whatever it is, okay. And do you have -- I 
11 
guess you just what, hire somebody to do your PR? 
12 
A 
That's correct. 
13 
Q 
And does -- do you have a point person who 
14 
does it, like one of your lawyers? 
15 
A 
Yes. 
16 
Q 
And who would that be? 
17 
A 
Seth Lehrman. 
18 
Q 
Okay. And do you also use Facebook to promote 
19 
the law firm? 
20 
A 
I believe the law furn has a Facebook page, 
21 
but I can't say for certain. 
22 
Q 
All right. Do you actually do any of the 
23 
input yourself? 
24 
A 
Zero. I never have. 
25 
Q 
Do you have the approval yourself of what's 
Page 66 
1 
put in there, do you have to approve what's put in there 
2 
or it's --
.-
.. 
3 
A No. 
4 
Q 
Okay. All of the advertising that is done 
5 
about Bradley Edwards then, such as --1 mean, I'm sure 
6 
you have seen them sh owing your face on channel -- I am 
7 
talking about the Huizenga thing now where, what's her 
8 
name, Buntrock? 
9 
A 
I have never seen it. 
10 
Q Okay. All of that's done by someone else? 
11 
A Yes. 
12 
Q You are -- you are presently involved in 
13 
the -- are -- have you filed suit in that case yet? 
14 
MR. GOLDBERGER: Identify the case for him. 
15 
MR. HADDAD: Pardon? 
16 
IV1R. GOLDBERGER: Just so we have a record. 
17 
MR. HADDAD: I will get to it in a second. If 
18 
he says he filed suit, I'll do it. 
... ·19 
A • You -- you're talking about --
20 
BY MR. HADDAD: 
21 
Q 
I'm talking about the pastor --
22 
A I know what you're --
23 
Q --you know exactly what I'm talking -- first 
24 
time I saw --
25 
A Talking about Jeffrey London? 
1 
2 
3 
4...

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Page 69 
A I hesitated because you asked how many 
1 
plaintiffs there are. And for you to be a plaintiff, 
2 
there has to be a lawsuit. 
3 
Q How many potential plaintiffs are you 
4 
representing? 
5 
A Let me describe what I do in that case and 
6 
then you can take it from there. There are, I believe, 
7 
seven or eight victims that we have signed on to 
8 
represent them through the criminal process as crime 
9 
victims' rights attorneys. Some -- some may have civil 
1 0 
claims that still are viable and some may not. Right 
11 
now we have filed one. In the future, we may decide to 
12 
file others. That's the best I can do. 
1 3 
I mean, there -- obviously, we are dealing 
14 
with a lot of issues that relate to abuse that happened 
15 
many, many years ago, which raises other issues that 
16 
everybody is probably familiar with so-.-.-. 
1 7 
Q 
A!! right. Now, in that case, of course, 
1 8 
there is, I suppose, some issue of whether or not --
19 
well, obviously Mr. London would be what the -- they 
2 0 
used to say is an impossibility, judgment-proof, 
21 
correct? He has got no --
2 2 
A I would hope that the guy goes to prison for 
2 3 
the rest of his 1 ife so --
2 4 
Q 
Well,Iunderstandthat. 
25 
Page 70 
A -- that would probabiy make him 
l 
judgment-proof. 
2 
Q 
Well, I understand that, but the benefactor of 
3 
that place where he was is far from judgment-proof, 
4 
correct? 
5 
A Benefactor of what place? 
6 
Q Of the -- of the place where he had these 
7 
kids, would be farfromjudgrnent-proof, correct? 
8 
A 
The owner of the.house I believe is Elizabeth 
9 
Buntrock. 
10 
Q All right. And Miss Buntrock is Huizenga's 
11 
sister or cousin? 
12 
A 
Some relative. 
13 
Q All right. And she was married l:).Ild had one of 
14 
the huge...

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Page 73 
Q Now I got to work. 
1 
A Sorry. 
2 
Q That's okay. 
3 
(Thereupon, a discussion was had off the 
4 
~~J 
5 
I'm trying to truncate this because I know 
6 
most plaintiffs lawyers and civil lawyers would keep 
7 
you here for six hours and probably--
8 
A 
I feel like we're headed down that road. 
9 
Q You're not going to be headed down that road 
10 
with me. I am not staying that long. I'm just trying 
11 
to find it. See ifl was a civil lawyer, I would have 
12 
ali of this stuff nice and neat. W-here is this stuff? 
13 
There it is. 
14 
There is -- and this is why I am doing this --
15 
is, Dear Miss Coleman, the accompanied -- this is 
16 
May 8th, 2012, are -- in producing response to 
1 7 
plaintiff's discovery request, subject to our agreement 
18 
that this production does not constitute or support a 
1 9 
waiver of privilege asse1ted as to any other documents. 
2 0 
A 
Okay. 
21 
Q And there are hundreds of e-mails that 
2 2 
Mr. Scarola produced to Miss Coleman. 
2 3 
(Thereupon, a discussion was had off the 
2 4 
record.) 
2 5 
Page 74 
BY MR. HADDAD: 
1 
Q 
Okay. 
2 
A 
l have seen those. 
3 
Q 
Oh, can I see them, because I want to go 
4 
through every one of them? 
5 
A 
I can't wait. 
6 
Q 
Well, you're -- if Scarola was here I would do 
7 
it just for the hell of it. 
8 
A 
I bet you would. 
9 
Q I would. 
10 
MR. KING: Thank you. 
11 
MR. HADDAD: You're welcome. 
12 
BY MR. HADDAD: 
13 
Q 
All right. In looking through these, these 
14 
are all e-mails that you sent, correct? 
15 
A 
I think either I sent or received or was 
16 
copied on. I mean, I think that there are some --
1 7 
Q 
All right. And there is no questions you had 
18 
ariy relationships with the press tlrroughout this entire 
19 
proceeding? 
2 0 
A 
I agree. 
21 ...

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1 
put out? 
1 
in London papers regarding Jeffrey Epstein? 
2 
A 
I don't know, I haven't seen that. You are 
2 
A 
Right now, as I sit here right now, no, I 
3 
pulling it from our firm Web site. I told you I haven't 
3 
don't remember ever seeing this or ]mowing this. 
4 
input anything, so the fact that it's here, it seems 
4 
Q 
Okay. And did you ever express to your law 
5 
like it's here. 
5 
firm that you are so afraid of Jeffrey Epstein not to go 
6 
Q 
Well, I --
6 
do things like this because you might get him mad? 
7 
A 
You are reading it, right? 
7 
A 
No, the opposite. I mean, I think that being 
B 
Q 
I want to ask you questions. I am reading it 
8 
public is what saves me so-.-.-. 
9 
right? 
9 
Q 
Okay. 
10 
A 
It seems that way. 
10 
A 
I don't-
11 
Q 
Okay. You have never seen that? 
11 
Q 
So the more public you are, such as -- well, 
12 
A 
No. 
12 
let me ask you this. 
13 
Q 
So your finn is putting these things out and 
13 
A 
If something happened to me right now, I think 
14 
they do it without your knowledge or with your 
14 
that everybody will know he did it, so I think that 
15 
knowledge? 
15 
helps. 
16 
A They know about my cases so-.-.-. 
16 
Q 
Have you ever been married? 
17 
Q 
I understand that. I'm just asking you if you 
17 
A 
Yeah. 
18 
are consulted about the content of what your finn IT guy 
18 
Q If something happened to --
19 
m whoever it is puts out, that's all I'm asking, not a 
19 
A 
Not as many times as you. 
20 
hard question. 
20 
Q 
And -- I'm just looking at this. How did you 
21 
A 
I was not consulted. Here's the thing, has 
21 
get $735,000 for three toes? 
22 
there ever been a conversation where the PR person has 
22 
A Three toes were chopped off and there was a 
23 
asked me the truthfulness of this information and me say 
23 
little more to it but-.-.-. 
24 
yes, that possibly happened. Have I known that this was 
24 
Q 
Oh, I guess so, that's a lot of money. 
25 ...

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Page Bl 
1 
Q I don't know, I'm just asking you. It's a 
1 
2 
1ady that you guys were talking about when they picked 
2 
3 
up, what's his name, Polanski, you guys thought about 
3 
4 
maybe using the Polanski case to help rake -- gear up 
4 
5 
some things, you had a series of e-mails. Do you recall 
5 
6 
ili~ 
6 
7 
A I don't remember that either. 
7 
8 
Q You don't, okay. You don't remember anything 
8 
9 
about anything about -- any com -- communications, 
9 
10 
Polanski got arrested, what, two years ago? They --
1 0 
11 
A I don't remember either. 
11 
12 
Q -- picked him up in Switzerland and then they 
12 
13 
had to let him go? 
13 
14 
A I don't remember any correspondence about --
1 4 
15 
Q Conchita? 
15 
16 
A Conchita, yeah, I know -
1 6 
17 
Q Who is she? 
1 7 
18 
A A reporter somewhere up north. 
1 8 
19 
Q Okay. And do you know how many e-mails you 
1 9 
20 
may have exchanged with her? 
2 0 
21 
A Nn 
21 
22 
Q Do you know how many telephones calls you had 
2 2 
23 
with her? 
23 
24 
A No. I have had telephone calls. I have had 
2 4 
25 
e-mails. 
2 5 
Page 82 
1 
Q All right. Did you ever give Michele the 
1 
.. j 2 
phone number for Epstein's probation officer down in 
2 
3 
Virgin Islands or anything? 
3 
4 
A I don't remember doing that, but I might have. 
4 
5 
Q All right. And do you recall giving them 
5 
6 
infonnation about where to find Mr. Epstein at various 
6 
7 
times to different reporters and what you were able to 
7 
8 
find out about him? 
8 
9 
A 
Specifically, what? There is certain 
9 
10 
information I may have given. I -- I was - I use my 
1 0 
11 
discretion I think pretty responsibly to get the 
11 
12 
information that I needed while also disseminating only 
12 
13 
the information that I thought would ultimately be 
13 
14 
helpful. 
14 
15 
Q To whom? 
15 
16 
A 
To whatever reporters that we're talking 
1 6 
17 
about. 
1 7 
18 
Q 
Oh, and--
18 
•• 19 
A If we are talking about Michele Dargan, t...

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Page 85 
Q 
I am too professional for that. 
1 
A 
That is a shot at yourself. 
2 
Q That's something no one would ever say about 
3 
me, so I figured I would do it. 
4 
A 
Uh, I don't remember that e-mail, but I, like 
5 
you, find it somewhat amusing. I mean, you see me 
6 
saying I -- the cases seem so different, not factually 
7 
but procedurally, or I'm unsure as to how we can use one 
8 
to help in the other, so I mean, that's my answer --
9 
Q But--butl--
10 
A 
-- I agree with today. 
11 
Q 
I understand that's your answer, but what we 
12 
are talking about is there is a -- a -- it ls a --
13 
almost a circle of people involved in this case 
14 
involving you, the press and others. I mean, there is 
15 
hundreds of e-mails there. 
16 
A 
More people in this case --
1 7 
MR. KING: Objection, fonn. 
18 
A 
-- than any other case I have ever had. 
19 
MR. KING: Objection to form. 
2 0 
BY MR. HADDAD: 
21 
Q All right. And that's involved with members 
2 2 
ofthepublicalso? 
23 
A 
I think that you could say that no matter what 
2 4 
category we are talking about, just a lot of people. 
2 5 
Page 86 
Q 
Did you ever meet Conchita face-to-face? 
1 
A Iili~ 
2 
Q Where? 
3 
A 
In the Palm Beach Courthouse. 
4 
Q 
Okay. State Courthouse? 
5 
A 
Yeah. 
6 
Q 
Okay. On one of the Epstein cases? 
7 
A 
She approached me telling me that she had 
8 
known him for 20 years, coming -- I was coming out of 
9 
the courtroom. And I think that I was at a hearing on 
10 
an Ep -- on a case against Jeffrey Epstein. 
11 
Q All right. And -- okay, can I see that back 
12 
for a second? There was something else I wanted to see 
13 
and let me just give -- if you don't mind giving me one 
14 
second. 
15 
Are you familiar with a 2010 case. Your 
16 
deposition was in March of...

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Page 89 
l 
MR.KING: Was the book published by somebody 
2 
else? 
3 
MR. HADDAD: No, he-- I am asking the 
4 
questions, I don't know. I didn't hear what you 
5 
said, I'm sorry, Jack, what was that? 
6 
MR. KING: That's all right. I said as to a 
7 
book published by somebody else. 
8 
MR. HADDAD: No, no, no, no. What happened in 
9 
this, I am sure you are not familiar, is Alfredo 
10 
Rodriguez was his -- was his house manager. 
11 
MR. KING: Right. 
12 
MR. HADDAD: He gave a deposition in the case. 
13 
Brad was there, l beiieve, and a bunch of other 
14 
lawyers that were suing Mr. Epstein. 
15 
MR. KING: Right. 
16 
MR. HADDAD: After that deposition, 
17 
Mr. Rodriquez approached an individual and said, I 
18 
have a book that contains a lot more than what I 
19 
said at my deposition. In essence, I withheld tons 
20 
of stuff at my deposition, I want 50 G's. The 
21 
person he approached, I assume, is Mr. Edwards. 
22 
Mr. Edwards, being the lawyer that he is didn't get 
23 
the book, he approached the police and said someone 
24 
is trying to commit a crime, and the book -- the 
25 
gentleman was arrested through a roundabout 
Page 90 
-
l 
different sort of thing. And then I assume the 
2 
book was made public and the names were produced 
3 
and I wanted to know whether or not Mr. --
4 
MR. KING: That book? 
5 
MR. HADDAD: That book. Whether or not 
6 
Ivlr. Edwards had contact with any persons that were 
7 
listed in that book. 
8 
MR. KING: Well, along the lines that were 
9 
taken last time with regard to whatever work he 
10 
undertook, whatever work product was involved in 
11 
the investigation of his cases, in light of the 
12 
current status of the case, in which the -- you 
13 
know, pending claim is what it is --
14 
MR. HADDAD: Umm-hmm. 
15 
MR. KING: -- I think it's -- it's even more 
16 
reinforced those objections are and will be raised. 
17 
MR. HADDAD: All right. That's fine, I 
18 
just -- to let you object. 
19 
BY...

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(Whereupon, a break was taken.) 
(Thereupon, Defendant's Exhibit Nos. l - l l 
and 13 & 14 were marked for identification.) 
Page 93 
THE VIDEOGRAPHER: The time is 12:08 p.m. We 
are now back on the video record. 
MR. KING: Andjust--just before -- before 
we go on, I understand that you all have marked 
various exhibits that were referenced during the 
course of the testimony which hadn't been marked 
earlier which you now marked 1 through what? 
MS. HADDAD COLEMAN: 1 through l l, and they 
were shown to coun - to Mr. Edwards during the 
course of this deposition. 
MR. KING: Very good. 
1 
2 
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13 
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MS. HADDAD COLEMAN: And not contemporaneously 
15 
re-referenced. 
MR. KING: Very good. 
THE WITNESS: It's -- it's a little bit more 
than that, I through 11 and then 13 and 14. 12 was 
taken out of there so-.-.-. 
MS. HADDAD COLEMAN: Okay. 
MR. KING: So just let's put on the record 
what we have then so the record is clear. 
THE WITNESS: Okay. Exhibit 1 was part of 
Farmer, Jaffe, Weissing Web site. Exhibit 2 is 
Page 94 
16 
17 
18 
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from the Web site. Exhibit 3 from the Web site, 
1 
Exhibit 4 from the Web site. Exhibit 5 from 
2 
National Trial Lawyers Web site. Exhibit 6 from 
3 
AVVO,A-V-V-O. Exhibit7fromtheFarmer,Jaffe, 
4 
Weissing Web site. Exhibit 8 from lawyers.corn. 
5 
Exhibit 9 from for 40 under 40. Exhibits 10 and 11 
6 
are interrogatories directed to me and responses. 
7 
Exhibit 13 is the transcript of the sentencing 
8 
proceedings for Alfredo Rodriguez. Exhibit 14 is a 
9 
plea agreement between th~ United States and 
10 
Alfredo Rodriguez. 
11 
BY:MR. HADDAD: 
12 
Q 
Let me go back, ifl may, just for a minute to 
13 
the plea agreement so your counsel can object. Did 
14 
you -- d...

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Page 97 
A 
Attorney-client privilege. 
1 
BY MR. HADDAD: 
2 
Q 
Okay. I just - I just ask the questions, 
3 
that's all. You can always say no. 
4 
A 
I've just never heard of an attorney 
5 
actual! y --
6 
Q 
You -- you -- well, I --
7 
A 
-- ask it that way. 
B 
Q 
-- well, let me put it this -- you were aware 
9 
that Mr. Scarola's law firm represented other purported 
1 D 
victims of lVrr. Epstein, correct? 
11 
A 
I was aware that his law firm represented 
12 
victims of Mr. Epstein, yes. 
13 
Q 
And how many? 
14 
A 
How many victims? 
15 
Q 
Yeah. 
16 
A 
I'm not sure. 
1 7 
Q 
All right. And do you !mow which lawyers? 
1 B 
A 
I believe that Jack was one of them. I ]mow 
19 
Jack was one of then. He was the main lawyer that 
2 D 
handled the cases over there. 
21 
Q 
Oka~ 
22 
A 
In fact, 1 don't remember the nai71e of any of 
23 
the other lawyers from the firm that handled the cases. 
2 4 
Q 
All right. 
2 s 
Page 98 
MR. HADDAD: I don't think I have any other 
1 
questions. Does anybody have anything they want 
2 
to -- Debbie? 
3 
MR. KING: As I lll1derstand it, what -- well, 
4 
go ahead, I didn't mean to cut you off. 
5 
MR.. HADDAD: That's okay. 
6 
BY MR. HADDAD: 
7 
Q 
As you know, we still have -- as you said you 
8 
would not answer any of the questions that were 
9 
propounded to you before and objected to. 
1 O 
A 
My objection to those previous questions would 
11 
be my objection today. 
12 
MR. HADDAD: All right. It was set for a 
13 
hearing April 12th of 2011 and then again reset for 
14 
another time and no one ever went -- the hearing 
15 
never went forward, so those questions are still 
16 
objected to, unresolved. So we'll stop. We will 
1 7 
go from there, see whatever happens. 
18 
THE WITNESS: • Okay. 
19 
MR. GO...

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Page 101 
in having to reestablish that you were objecting 
and, you know --
JvlR. GOLDBERGER: Obviously, if those records 
had been produced, we would have had a ton of 
questions about that but-.-.-. 
JvlR. KING: I understand, but my only concern 
was I didn't know, because I was not there at the 
hearing, I didn't participate in any way with 
respect to that, so I don't know what the Court's 
expectations were as to whether or not the Court 
wanted you to ask any questions. If you don't 
proceed, that's the case. 
JvlR. HADDAD: No, I don't think it was 
necessary --
MS. HADDAD COLEMAN: In his order, the Court 
permitted the deposition to go forward. I said at 
the hearing we wouldn't get into any questions that 
were directly related to those documents, with the 
express understanding once the Court rules we may 
ask whatever the Court permits us to ask. 
JvlR. KJNG: That's what I needed to !mow. 
Thank you. All right. 
JvlR. HADDAD: All right. We're -- do you 
want -- do you want to read or waive this part of 
it? 
Page 102 
THE WI1NESS: I will read it. 
MR. GOLDBERGER: Okay. 
THE VIDEOGRAPHER: The time is 12: 16 p.m. We 
are now coming off the video record. This is the 
end of Tape No. 2. 
THE COURT REPORTER: Do you want this typed 
up? 
MR. HADDAD: Do I want ii typed up? I'd 
like - you got to make money. I represent the 
richest guy in America. 
THE VIDEOGRAPHER: Counsel; copy of the video? 
MR. HADDAD: Huh? 
THE VIDEOGRAPHER: Do you want a copy of the 
video, sir? 
MR. HADDAD: Sir? No. I don't know. Do we 
want a copy of the video? 
THE COURT REPORTER: Do you want a copy of 
this? 
MR: KING: Yes, please. _ 
(Witness excused.) 
(Deposition was adjourned at 12:16 p.m.) 
AND FURTHER DEPONENT SAITH NOT 
SIGNATURE OF WITNESS 
1 
2 
3 
4 
5 
6 
7 
8 
9...

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CERTIFICATE 
ST ATE OF FLORJDA, ) 
COUNTY OF BROWARD.) 
I, WENDY ROBERTS, Registered Professional 
Reporter and Notary Public in and for the State of 
Florida at Large, do hereby certify that the 
foregoing testimony was taken before me; that the 
witness was duly sworn by me; and that the foregoing 
pages constitute a true record of the testimony 
given by said witness. 
I further certify that I am not a relative or 
employee or attorney or counsel of any of the 
parties, or a relative or employee of such attorney 
or counsel, nor financially interested in the 
action. 
Under penalties of perjury, I declare that I 
have read the foregoing certificate and that the 
facts stated herein are true. 
Signed this 24th day ofMay, 2013. 
'."~\ 
-~~~5~~S, Registered Professional Reporter 
EMPIRE LEGAL SUPPORT, INC. 
401 EAST LAS OLAS BOULEVARD, STE 1400 
FORT LAUDERDALE, FL 33301 
To: BRADLEY EDWARDS, ESQUIRE 
Fallller Jaffe Weissing Edwards Fistos Lehrman 
425 North Andrews Avenue, Suite 2 
Fort Lauderdale, Florida 33301 
Re: CASE NO.: 502009CA040800XXXXMBAG 
--------------~/ 
Dear BRADLEY EDWARDS, 
Your deposition taken in the above 
entitled cause is now ready for signature. 
Please come to this office and sign same; or 
if you wish to waive the signing of the 
deposition, please so advise. 
If this deposition has not been signed 
within 30 days of today's date, May 24th, 2013, 
we shall consider your signature waived. 
Your prompt attention in this matter is 
appreciated. 
Si11cerely=---
1{~,(~~>f .· 
DEPOSITION ERRATA SHEET 
Our Assignment No. 10402 
Case Caption: JEFFREY EPSTEIN 
vs. SCOTT ROTHSTEIN 
DECLARATION UNDER PENALTY OF PERJURY 
I declare under penalty of perjury 
that I have read the entire transcript of 
my Deposition taken in the captioned matter 
or the same has been read to me, and 
the same is true and accurate, save and 
except for changes and/or corrections, if 
any, as indicated by me on the DEPOSITION 
ERRATA SHEET hereof, with t...

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DEPOSJT!ONERRATA SHEET 
Page No. __ Line No. __ Change to: _____ _ 
Reason for change: ____________ _ 
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Reason for change: ____________ _ 
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Reason for change: ____________ _ 
Page No. 
Line No. __ Change to: _____ _ 
Reason for change: ____________ _ 
SIGNATURE: _________ DATE .. • ____ _ 
BRADLEY EDWARDS 
EMPIRE LEGAL SUPPORT, INC. 
( 954) 241-1010 
28 (Page 109) 
Electronically signed by Wendy Roberts (201-049-665-8352) 
Electronically signed by Wendy Roberts (201-049-665-8352) 
Electronically signed by Wendy Roberts (201-049-665-8352) 
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Surrounding text: Street, Hallandale Beach Q. Date of birth, ple A. Q. Mr. Edwards, ha deposition taken before'