IN THE CIRCUIT COURT OF THE

IN THE CIRCUIT COURT OF THE 1 I 3 INDEX FIFTEENTH JUDICIAL CIRCUIT, IN 2 AND FOR PALM BEACH COUNTY, FLORIDA 2 Videotaped Depoeitien ofWILLIAMBERGER Page lb. Case No. 502009CA040800XXXXMB 4 JEFFREY EPSTEIN, 5 Direct Examination by Hr. Scarola 5 Plaintiff/Counter-Defendant, 4 Cross-Lamination by Mr. Lick SS Vs. 7 Redirect Examination by Mr. Scarola 131 SCOTT 0.0TNSTBIN, individually; 0 Rocones-Exaninatien by Mr. Lick 138 BRADLEY EDWARDS, Individually, 9 Further Redirect Examination by Mr. Scarola 160 Defendants/Counter-Plaintiff. 10 Certificate of Oath 170 / 11 Certificate of Reporter 171 12 13 PLAINTIFF'S EXHIBIT INDEX VIDEOTAPED DEPOSITION le OF WILLIAM BERGEA 15 No. Descriptich Page No 16 1 Razosbadt Cctplaint OS 17 2 (Premarked but not mentioned during deposition.) Taken on Behalf of Defendant/Counter-Plaintiff IS 3 Cceplaint in current case 118 19 Friday, February 23rd, 2028 20 9:27 . - 1:32 . 21 DEFENDANTS/COUSTER-PLAINTIFFS' EXHIBIT IM3EX 2255 Glades Road, Suite 218-A 22 (No exhibits were tacked.) Boca Raton, Florida 33431 13 24 25 2 4 1 Examination of the witness taken before 1 THE VIDEOGRAPHER: This is the 23rd day 2 Sonja D. Hall 2 of February 2028. The time is approximately Palm Beach Reporting Service, Inc. 9 1665 Palm Beach Lakes Boulevard, Suite 1001 $ 9:27 West Palm Beach, FL 33401 4 This is the videotaped deposition of 4 1561) 471-2995 5 Berger in the matter of Jeffrey 5 APPEARANCES: 6 For Plaintiff: 4 Epstein versus Scott Rothstein and Bradley 7 LINK 4 ROCKENBACH, . Edwards. 1555 Palm Beach Lakes Boulevard, Suite 301 0 9 West Palm Beach, FL 33401 By SCOTT J. LINK, ESQUIRE , This deposition is being hold 2255 Glades Road, Suite 218-A, Boca Piton, :0 Florida 23431. 10 For Plaintiff: 11 DARREN K. INDYKE, PLLC Ii My name is Manuel Santiago. I am the 575 Lexington Avenue 12 VICIOD9taptier representing Above a Beyond 12 New York, NY 10022 By DARREM K. INDERE, ESQUIRE 29 Reprographics. IS 24 Will the attorneys please announce 14 For Defendant/Counter-Plaintiff: 15 their appearances for the record? 15 SEARCY, DENNEY, SCAROLA, BARNHART 4 SHIPLEY, . 16 MR. LINK: Sure. Scott Link on behalf 26 2139 Palm Beach Lakes Boulevard 17 of plaintiff, Jeffrey Epstein. West Palm Beach, FL 33409 27 By JACK SCAROLA, ESQUIRE 19 MR. INDYKE: Darren Indyke on behalf of la 19 plaintiff, Jeffrey Epstein. 19 ALSO PRESENT 20 MR. SCAROLA: My name is Jack Scarola. 20 Above 4. Beyond Reprographics 2161 Palm Beach Lakes Boulevard 21 I am counsel on behalf of Brad Edwards. II West Palm Beach, Florida 33401 22 Brad Edwards is plaintiff in the By Manuel Santiago, videographer 22 23 counterclaim in which this case -- excuse me 23 24 -- in which this deposition is being taken. 24 25 25 Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798337 5 7 2 4 THEREUPON, WILLIAM BEAZER, being a witness in the notice heretofore and being first duly sworn in the above cause, S testified on hla oath as follows: THE WITNESS: I do. DIRECT EXAMINATION 4 BY HR. SCAROLA: • Q Could you please introduce yourself to the 10 ladles and gentlemen of the jury, before whom this II deposition is likely to be shown? 12 A My name is William Joseph Berger. 13 Q And where la the deposition being taken 14 today, Mr. Berger? II A It's being taken in the Law Office of Weirs, IS Handler 4 Cornwell, the firm that 1 work for. I7 IS If 20 2l 22 2) 24 25 O What is your capacity with the firm? A I an an attorney with the firm. Q How tong have you been employed by Kelm, Handler Cornwell. A Since approximately December of 2009. Q You understand that this deposition is being taken in a case in which Bradley Edward➢ has brought suit again➢t Jeffrey Epstein for malicious prosecution, correct? Of Florida graduate school and got a master's degree in 2 philosophy. I then applied to trio university of Miami ) law school. And I went to law school iron 1972 to 4 1975, when I graduated the University of Miami law 5 school. 4 Q Tell us how you came t0 select philosophy ▪ an a major? • A How such flaw do you have? • Q Well, I have a lot of tine, but I expect 10 that the jury would like you to be relatively brief. 11 A I have also had a very longstanding interest 12 in the ideas, concepts, fundamental principles, and I 13 was attracted to philosophy. II CI All right, sir. Were your plans when you 17 chose that major to eventually go to law school? IS 17 IS A No. 0 what were your plans? A I was going to open up a philosophy shop and Is tell people if Choy existed or not. 20 Q sounds like an endeavor that was not likely 21 to enable you to support a family? 22 A Actually, It was teaching. I was going to go 2) into teaching, and then I decided to go into law 24 school. 25 Actually, law seamed to me to be -- I have 2 A Yes. O And can you tell us, understanding 3 that the case is set to be tried the second two weeks • in arch, whore you are going CO be the second two • weeks Of Mirth? 4 6 A I will have surgery out of town March 5, and / I will bo rehabilitating or recovering probably for the • resit of the month. 9 0 All right, sir, thank you. We wish you 10 beat of luck with your surgery. Sorry that you are II not going t0 be with us at trial in person. But 12 that's the reason why wo are taking this videotaped 1) deposition today. 14 A Thank you. 15 Q I want, before we begin dealing with the If issues involved in this case, co talk to you a little 17 bit about your professional history. So let'➢ start In with higher education. 19 Where did you go to school and what did 20 you study? 31 A I went to college for a year at Syracuse, 22 then I transferred to the University of Florida. I 23 graduated from the University of Florida with a 24 bachelor's degree. I had a degree in philosophy, and 25 that was to 1971. And then I stayed at the University I always thought of law a➢ the combination of 2 philosophy in action. That's what, to ma, law is, 3 the application of principles to real life 4 situations. 0 Where were you born and raised? 4 A I wan born in Philadelphia, Pennsylvania. 7 And at the age of ono year, my family moved to Miami • Beach, and I grew up on Miami. Hooch. 9 Q Do you have a family of your own now? 10 A Yea. Linda and I have been married for 47 IL years and we have three daughters. 12 Q Let's pick up with your graduation from law 1) 14 15 If 17 IS 19 30 8 school in 1975, and tell ua what you did after graduating. A From 1975 to 1997 I was an attorney in Miami, and I wan with several law firm during those 22 years. I was with the Greenberg Traurig law fire; the Fine Jacobson law firms a firm called Hughes Hubbard t Read, which is a New York firm that had a *Maul office. And I had my own practice in between. So that takes me to 21 1997. 22 Then in 1997 Linda and I decided that we 33 Were going to ROVO to Boca Raton, and we did. I 21 joined this fire in 1997, the Rehm Handler firm. 25 was here for a year, and then I started ny own Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798338 9 11 practice, just a solo practice until 2002. 2 And in 2002, I ran for circuit court Judge 2 hero in Palm Beach County and I was elected. I 4 served a➢ a circuit judge in Palm Beach County from • January of 2003 until Juno of 2008. Q Lot's talk a little bit about the nature of 7 your practice before you were honored with a position s on the bench. Toll us, if you would, please, about * what kind of legal work you did in those decades It before you became a circuit court judge? 11 12 13 state and federal. In the 190. I started to focus on 13 employment discrimination law whore I represented 14 the employe*a who had been fired or disciplined. I7 Those were cases against their employers. And so if Is I had any kind of concentration, it was in that IS area. Probably a third of my practice was in that 20 area until I was elected to the bench. 21 Q During that period of tine before taking 22 the bench, did you focus your practice exclusively on 22 representing either plaintiff➢ or defendants? 24 You told us that your employment law 25 practice was focused on representing plaintiffs. A I handled lawsuits of people suing other ',maple, companion suing companion. General-type work, Q Tell us atittle about them, if you would, 2 please. A My daughter Marla is 43 today. It'➢ her 4 birthday. she's a mental health counselor. S Unfortunately, her -- in the sense that she specializes 4 in grieving, she administers mental health counseling 1 to -- particularly to children -- she works for a a charity called Tomorrow'➢ Rainbow in Broward County. / she has her hands full right now with the shooting. 10 My daughter Lauren is 41, and oho'➢ a II social director -- rather, an activitie➢ director 12 for a large temple here in Boca Raton. 13 My youngest daughter is Brooke, who is 29 14 years old. Brooke is looking co find herself, so she's back at hone now, and wo are going to nee where She goes next. Q I have a few of those myself. IC Tell us, if you would, please, how you 13 14 If went about addressing the financial issues that 20 arose in '07 and '08 that compelled you to leave the 2L bench? 22 A I decided I needed to go back to private 23 practice. I took a substantial cut in pay to become a 24 Judge, and we realized that going into it. But it was 25 just something that needed to be addressed as a result 10 I What about prior to that? 2 A well, I did -- I did -- oven during that 3 time, I did represent Gone employers, so I did 4 represent both aides. In other types of canon, there wan no 4 exclusive representation of plaintiffs or defendants 7 in what we would call civil matters, comeorcial t disputes and those types of things. 9 Q What motivated you to nook a position on 10 Il 12 13 14 15 14 11 the bunch? A Maybe the same thing that motivated no to go into philosophy. It was something whore I could actually apply principles, legal principles to real -life situations and deal with people's Isamu➢ and really do something for society. And it was something that was vary rewarding when I was on the bench. O What were the circumstances under which you IS left? IS A well, unfortunately in 2007/2008, wo wore 24 hit -- my family wan hit with the recession, no w0 21 had -- it was a serious financial ➢ltuation for us, so 22 I decided I needed to go back into private practice. 23 Q You told ua about your 47-year marriage. 24 Do you have Children? 33 A Yea, three daughters. 12 of the recension, so I decided to look to go back into 2 practice. And I was -- I interviewed with a couple of 3 largo firms. 4 Q roll us, before wo leave focus on your 3 Judicial career, what you did during those five to 4 nix yearn? 7 A well, in Palm Beach County, the circuit • court, which is the higher-level trial court, La • divided into five divisions: civil, criminal, family, 10 probate and Juvenile. In the five to six years that I IL was a Judge, I served in the civil division for ono 12 year, then I nerved to the family division involving 13 divorcoa, custody fights for two and a half years. And 14 that was in the branch court in Delray Beach. And I 15 was the administrative judge for the Delray Beach 14 Courthouse. 11 And then the last approximately two year➢ IS that I was on the bench, I Served in the criminal 19 division, so I presided over Colonial/capital case➢ 24 for two years. 21 Q I know from the review of your professional 22 sestina that you currently, in addition to doing trial 23 work, also do soma appellate work; is that correct? 24 A Yea. 33 O Did you have any app responsibilities Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798339 13 15 l while you were a judge? 1 A Yes. Judges that are circuit court judges 3 have appellate responsibility for cases from the county 4 court being appealed to the circuit court, and I worked S on those. And then I was also invited by the Fourth f District Court of Appeal, which is our appellate court / for Palm Beach County, Broward County and the Treasure • Coast. I was invited ono simmer to sit on -- to 10 sit on that court in place of a judge who was on 11 vacation, Judge Barry Stone. So I served on the 12 Fourth District and served with a panel of judges 13 and heard quite a number of cafes and wrote several 14 decisions for the Fourth District. Q The jury may not be familiar with the 14 procedure, but when the appellate court reviews 17 decision➢ that are rendered and jury trial re➢ult➢ at 18 the trial court level, how many judges aro involved It in that review process? 13 20 A Three. 21 Q And you then wore one of three panel 21 members in the review of multiple cases that were 23 heard before the Fourth District Court of Appeal? 24 A Yea. 2S Q Did you ever have the responsibility of 1 1 3 4 S a circuit court judge➢. Q In going through your career, we had reached the point where in 2008 you faced the economic reality of having to leave the bench. where did you than go? A I was hired by the Rothstein, Rosonfoldt a Adler firm. O How did that cone about? A As I said, I was interviewing with two firms. 10 There wore two largo firma that had offices in Palm Beach County -- largo offices In Palm Beach County. 12 Neon wo moved up hove in 199?, my daughter 13 Brooke got to know Stuart Rosonfoldt,a daughter, and 14 we became socially acquainted with Stuart Rosenfeldt 13 and his wife. So I know him from 2997 until - wo - 14 aro at 2008. I knew him that entire time. In fact, when I went on the bench in 2003, 18 I referred to Stuart my employment case➢ that I had. It I had a great deal of respect for Stuart. 20 Stuart was a very prominent attorney in 21 the employment law area. No wrote for the Florida 21 Bar the teat that lawyers take to become board 23 certified in labor law. lie had an excellent 24 reputation in that area. 2S And Stuart, I would see ha every once in 11 14 1 writing opinions on behalf of the court, oven though 2 you were an a➢sociate judge and not a regular member 3 of the Court? 4 A Yea, I wrote several divisions that were 3 published and -- for the courts -- for the court of 4 appeal. 7 Q Did you also, during the course of those ▪ years, when you were serving as a circuit court judge, 9 receive the honor of having been selected by the 10 chief justice of the Florida Supremo Court to fulfill II 12 13 14 any responsibilities on behalf of the Supremo Court of Florida? A Yes. The position of chief justice rotates among the justices in the court. And at the time the IS chief justice of the Florida Supreme Court was Fred If Lowia. And Justice Lewis appointed me to a ➢tatewide 17 panel conflating of laypersons, judges at the trial 18 level, and appellate judges and retired Supreme Court 19 justices on a cormittoo to study how the public Could 20 130 batter informed in voting for trial judges. 21 In Florida, county and circuit court aro 22 elected. Appellate judges are appointed by the 33 governor. And the purpose of the panel was to deal 24 with how the public could bo bettor informed in 33 decisions of -- towards voting for county and 16 a while, and ho would toll mo about this firm that 2 ha was now with, Rothstein, Rosenfeldt 4 Adler, and 3 it was upbeat. Be portrayed it as a vary dynamic 4 firm. So during CM time I was looking to go 4 back into private practice talking to other firms, I 7 road In the paper that Rothstein, Roacmfoldt 4 Adler • had just hired the former mayor of Boca Raton Stove 9 Abraea to open up a Boca Raton office. 10 I 12 13 14 IS If 17 Now, I knew Stove Abrams. Ho was my mayor. NO was our mayor here In Boca Baton during 9/11, and I had a groat deal of respect for hie. Ne had an anthrax attack here in Boca at the National Enquirer building. And Mayor Abrams was like Mayor Giuliani for Boca Baton. He was vary -- showed great leadership skills. So when I saw and then ho was not the IS mayor anymore, of course, in 2009. But when I saw 19 that the firm was hiring -- had hired Steve Abrams 20 to open up an office here, which would be a 21 brand-new office, not a branch office of a big firm 22 that had -- that already had a largo number of 23 people in a branch office, it just seemed like an 24 opportunity I needed to explore. 23 So I called Stuart. And I said, Stuart, I Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798340 17 19 would like to talk to your fire about -- I told him 2 I was thinking of leaving the bench. And I asked if 3 I could be interviewed by the firm to work with 4 Stove Abrams in opening up the office here. 5 Q Did you then interview with the firm of 4 Rothstein, Rosenfoldt a Adler? 7 A Yea. Stuart and I talked, and then ho 4 introduced ma to Scott Rothstein, and that was the • interview I had. 10 Rothstein and I talked for about a half II hour in his office, and he made me an offer and I 12 accepted it. 13 Q Which office wad it at which you were 14 interviewed by Mr. Rothstein? A The firm didn't have a Boca location. It had 14 a Fort Lauderdale location on East Las Olaa Boulevard, 12 ➢o it was in that suit of offices there, in hi➢ office. Q roll ua about that suit of offices. A Noll, at the tine the -- I call it RRA for 20 Rothstein, Rosonfoldt a Adler -- MA had -- if not 21 mistaken, it had one and a half floors of that 22 high-rise office building on East Las Olam. And 23 Rothstein's office was on the floor -- the main floor 24 whore they had the entire floor. 25 Q Describe the offices. A Probably maybe double the total, if you 2 counted the lawyers. So it probably had 120 to 140 S 4 omployoos. Q What happened to the aim of the firm during the period of tiro that you were associated with the firm? A Tho firm did grow. It also -- I moan, it a grow in Fort Lauderdale. We also hired wo * eventually did open up a Boca Raton office where Nayor ic Abram and I practiced. He had one attorney along with 11 us that was full -Cleo there and another attorney that 12 was part-time. If And then the firm al➢o acquired an office 14 in Venezuela and maybe in Tallaha➢lee. not sure 13 about that. No also had an office In Washington, it III. that wasn't staffed -- fully ➢taffed. There 12 might have boon one other office possibly in Now IS York. I don't recall. is Q You told us about knowing Mr. Rosonfoldt 20 and knowing Mayor Abrams. Wore there any other 2L lawyers working in that office who you either know or 22 know of? 23 A Yea. And that'➢ one of the reasons that 24 chose that firm. Thera were several people. I learned 25 that -- I think front al discus➢ion with Scott Rothstein 18 A Noll, the offices wore a number -- you had a 2 waiting room, you had a number of attorneys' office➢, 3 and sort of common . Sono of the offices were 4 bigger, some wore corner offices, depending on the 3 attorney's position with the firm, and Rothstein had 4 his own office, which, of course, was larger than 7 others. • Q Descrlbo Kr. Rothsteln's office for the 9 10 II 12 13 14 15 If 11 IS 19 30 31 benefit of the jury, if you would please. A Noll, it was a big office. It got bigger later. It was renovated in 2009 after I was hired. At the time, it wa➢ -- iC wa➢ not an overly large office, but it wa➢ clearly the office of the attorney that wan the named partner in the firm -- the first named partner in the firm. Q How about once the office got renovated? Did you have occasion to over be in Mr. Rothstein's office after the renovations? A Yeah. It wan either maybe triple the size than it had been before, lavishly decorated. Q How largo wan the firm at the time you 22 joined it? Now many lawyers, approximately? 33 34 A It had about 60 or 70 lawyers at the time. • And total number of omployooa, could you 25 estimate that for ua? 20 when he interviewed no -- Judge Barry Stone, the sane 2 appellate judge that I had taken his place when I sat 3 on the Fourth District -- that ha had been hired by the 4 firm, and he had either already started or he was going 3 to start. 6 Judge Stone baa a tremendous reputation. • I think he was Cho longest sitting judge on the S Fourth District. In cases whore I wa➢ -- as a circuit court 10 judge whore I was reversed by the Fourth District IL Court of Appeal ho dissented from those nave aaaaa 12 several times. 13 15 If 17 IS Q So ho had a special place in your heart? A Right. Right. So I had a groat deal of respect for Judge Stone. Another attorney, who is Gary Farmer Jr., Gary Farmer Jr. is the ➢on of Gary Farmer Sr. And Cary Farmer Sr. wan also a judge on the Fourth 19 District Court of Appeal. And I knew his son was an 30 active, prominent personal injury attorney and class 21 action attorney, consumer attorney. Ho had just 22 settled a gigantic, hundreds-of-millions-of-dollars 23 whistletdower case against the pharmaceutical 24 industry. Noll, that was very impressive. So Gary 25 either had joined the firm or was going to join the Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798341 21 23 firm. I knew that. 2 In addition to Mayor Abrans and -- there 3 was also an attorney named Steve Lippman, who I did 4 not know. But I got to know him. I heard of him. • He had quite a number of financial institutions a➢ clients. So when I joined the firm, the firm was 7 representing Citicorp, Walla Fargo, JCPenney, Ed 4 Morse Automotive dealer➢hip.. It was a crui➢e * line -- I forget the name of it, but we represented 10 a cruise line. II Robert &ache], who was an attorney who 12 was at that fire. Roach.' represented police 13 unions. So we had as clients the union➢ that 14 represented police officers. And I think those are Is the attorneys that I knew going into the firm. Q Do you remember the approximate month that I/ you actually joined RRA? 14 IS It A Julie of 2009. sorry. June of 2000. Q You remained with the fire, then, [or haw 20 long? 2L A Until probably around November 8th to 10th, 22 something like that, 2009. So June 2008 to November of 23 2009. 24 Q Approximately 18 months -- about year and a 25 half? represented another law firm in a breakup of firma 2 And the Scherer firm waa owed over a million 4 5 4 7 • In Coos. And the client, the other law firm, was reneging on paying that. And Scherer won at the trial level, and then Judge Stone and I defended that judgment and protected that judgment on appeal, and we were ultimately successful. So you had a very prominent attorney, who, * ironically later, became an attorney for clients 10 suing the firm after the firm'! demise. But at the II time, Bill Scherer -- I was very impressed with the 12 fact that Bill Scherer was a client of the firm. 13 And he spoke publicly in -- I remember a newspaper 14 article on the Internet that Michael Mayo, I 15 believe, with the Sun Sentinel, interviewed Bill 14 Scherer about Rothstein. And I remember Scherer 17 saying that -- he ➢aid, I don't know what Scott 10 Rothstein la doing, but whatever in it I like it. II He said, I like it so much that my firm has given 20 him hla major case. So that was -- I thought that 21 was a testament to the firm's reputation. 22 Q When you joined RRA, how was your position 23 with the firm, your relationship with the firm 24 publicly described? what position did you have? 25 A Noll, I had -- I was called a shareholder. 2 3 a 4 9 10 II 12 13 14 15 IS Il IS It 22 A Yeah. O All right. At that time you joined the fire and through the end of October of 2009, how would you describe the perception of the firm, the firm's reputation in the South Florida legal community? A I think it was in very high regard by the legal community. When I joined the firm, I looked up ea the Internet, articles about RRA. And it was a firm that had -- that was very much involved in civic and charitable work, giving, that sort of thing. Rothstein was awarded many honors by charities for his work, charitable work. The attorneys that I associated with at the firm I thought were very, very high-caliber -- extremely high-caliber. I got to know more people there, of course. One of the clients of the firm was the Conrad Scherer firm. The Conrad Scherer firm was 20 ran by Bill Scherer. Bill Scherer la one of most 21 prominent lawyers in South Florida, certainly in 32 Seaward County. And he was a client of the firm. 33 In [act, Judge Stone and I worked on a 24 case that he had with u➢. It was a major cane for 25 that law firm. It was -- that law firm had 24 The firm had associates, partners and shareholders. I 2 wasn't really an equity owner in the firm. It was -- 3 When I was with the Pine Jacobson firm I 4 was designated as a partner. I wasn't really an 5 equity owner in that. So I had the -- that was sort 4 of -- there were probably 10 people that were 7 designated as shareholders. Then under that -- ➢o we had sort of a • mere senior role with the firm. 10 Q Was it unusual, based upon the experience that you have described, for law firma to de➢ignate 12 employeen of the fire a➢ being shareholders or 13 partners without those individual! having an equity 14 interest in the firm and ownership interest? A No. I had seen that before. As I ➢aid, the 19 Fine Jacobson firm was a ?0-attorney fire in Miami that was a vary, very prominent fire In the 1980s. And I was a partner with that firm, but I did not have an equity interest in it. 20 Now, afterward➢ when RR. collapsed, 21 obviously among all of the things that all of ua at 32 the firm went through in terms of being interviewed 33 by law enforcement and that sort of thing, I was 34 also interviewed by the Florida Bar. And one of the 25 points they raised was the fact that I was being II 15 17 IS 19 Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798342 25 27 1 called a shareholder and yet didn't have an equity 2 Interact In the firm. 3 I learned from the Bar, really, that that O was not -- not that It was widely -- a widely used 5 practice, but it was ono that the Bar was well aware i of and did not discipline the attorneys, to my 7 knowledge, certainly not In my case, for having been • called a shareholder and not having equity. But I learner!d from that inquiry that this 10 is a practice that seemed to be common, ao to speak, II throughout the 12 0 You have told us that your relationship 13 with Rita ended in early November of 2009. Tell ua 14 about the circumstances under which that occurre➢. II A well, the exact circumstances are that the 14 firm had already collapsed. November 1 was a Sunday. 17 And that's when I learned that there were problems, and le that Rothstein had left the country. November 2 was a Monday. And the attorney 20 that the firm hired co represent it in this 21 Rothstein problem and who had filed a lawsuit for 22 the firm against Rothstein immediately -- Kendall 23 Coffey was the attorney -- I stayed on for a couple 24 more day➢, probably a week, 10 days, something like 2S that, and then I left. i effect. He stepped into the ➢hoes of the law firm, and 2 he was now responsible for -- the firm had clients. No was responsible for collecting whatever foes could be O collected for paying aqsloyees, for seeing that there 5 was a transition from the firm to other attorneys 4 outside the fire to take over those matters, and also 1 to collect, against whoever was responsible, money to • re -- in effect to reimburse the firm for money that * was stolen from the firm. So Herb Stettin had that IC role. 11 Q So tell us, if you would -- you have 12 described the fact that the firm collapsed. How did 13 your knowledge of the circumstances surrounding that Is collapse evolve? II A Well, it evolved very quickly. On Saturday 14 October 31st, I was copied on an email that said -- 17 that was -- that didn't have broad circulation within I➢ the firm that said something about, Where's Scott? Is Something like that. 20 Q Scott meaning Scott Rothstein? 21 A Yeah. Two or three days before that, maybe 22 Wednesday of that prior week, at the and of October, 2) there was a charitable event at his home and he didn't 2• attend. He wasn't there. Nis wife was there and 25 dozens and dozens, if not over 200 people were there. 26 1 The firm had basically collapsed. We 2 weren't getting a paycheck. I felt I owed it co the 3 people in the firm -- we atilt had employees that 4 weren't getting paid but atilt had some benefits -- 5 maybe they were getting paid somewhat. The • attorney➢ weren't getting paid. I felt I needed to 7 stay there for scam period. And Herb Stettin had been appointed by t Judge Streitfeld a➢ a receiver for the firm. I knew 10 Herb Stettin for years and I felt some loyalty to him to stay for a while, at leant. But then it got 12 to the point where I had to leave. I had to get a 13 paycheck, so I left probably around November 7th or 14 10th, something like that. • Explain to the jury, if you would, please, li what a receiver la. What was the responsibility that Mr. Stettin was appointed to fulfill by circuit court Judge -- A Streltfeld. O Streitfeld. 11 IS 17 Ii It 30 21 A A receiver la somebody who is appointed by 22 the court -- and It's typically an attorney -- to take 23 charge and to basically run whatever the company is or 24 the business that is now in receivership. And that was 25 the law firm. So he was -- he became the law firm, in 28 It was a big event, but he wa➢n't there. It raised 2 questions. Where was he? 3 So on Saturday I saw an email that ➢aid he 4 has left the country. Something like that. And 5 then Sunday morning or Sunday afternoon, I got an • email that -- I forget who sent it -- but said to 7 re, Ma are going to have a meeting among -- I think S the people -- the shareholders at the fire that 9 afternoon or evening, and I went to that. 10 So there were probably about seven or IL eight or nine of u➢ there. Somebody -- maybe Stuart 12 13 IS Rosenfeldt -- had already hired Kendall Coffey, who was -- Kendall la a Miami attorney. Kendall and I practiced together at Greenberg Traurig in the '70a. Kendall became the united States attorney for the If District of Florida. I/ A presidential appointment? A Pre➢ident Clinton hired him. And then Kendall, at sans point, left that 30 position and he we­ out in private practice. 21 So Kendall we­ there at this meeting, 22 along with seven or eight of the other attorneys in 23 the firm, and that'➢ when I learned that Scott 24 Rothstein was in Morocco. And I was shocked. And 25 also -- because we were there for a couple hours, I IS It Southern 0 Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798343 29 31 al➢o learned that our tru➢t account➢ -- and those 1 are bank accounts that contain client money on deal➢ 3 that are pending, deal➢ that are settled, but the 4 money he➢n't been di➢tributed -- million➢ of 5 -- that those account➢ had been looted, they 4 were empty. I learned that that night. So those 7 were the circumstances where I learned that the firm 4 had basically imploded. Q Did there coma a point in time when you 10 became aware that Scott Roth➢tein was operating a 11 Renzi scheme out or the law firm? 12 A I learned that maybe a day or two after 13 November 1st, and I think I read it in the paper. 14 4) Before the disclosures that you have Is described to us, the raiding of the trust account and 14 the operation of the Moral ➢chme, having been at 15 that the firm for approximately a year and a half, II did you over have oven the slightest suspicion that It Scott Rothstein or anyone also associated with 20 Roth➢tein, Rosenfeldt t Adler wore engaged in any 2L kind of improper activity? 21 A No. 23 Q Evan in retrospect, as you sit here today, 24 can you look back on that time period and say, You 25 know, I should have realized there was something that were being prosecuted on behalf of throe young 1 woman: M., B.N. and Jane Doe. And w➢ will refer to them when I talk to you about them in that ➢ame way, 4 referring to sham by those initial➢ and that 5 pseudonym. 4 Describe how it i➢ you cam, to ➢hare ro➢ponsibility for those ca➢es with Brad. A I don't remember the first -- my first s introduction to the ca➢e➢. 0bviou➢ly, there wan a 10 meeting. Obviously, I met Brad for maybe the first 11 time, and I was -- I wa➢ asked -- I don't remember by 12 whom -- to work with Brad on these case➢ I think 13 principally becau➢e they were ➢ignificant ca➢e➢. 14 I had been practicing for quite a while. 15 I had been a Judg➢ in Palm Beach County and had 14 practiced in Palm Beach County. The fife was In 15 Fort Lauderdal➢. Brad wa➢ a Broward County lawy➢r, la I think, primarily. And I had thi➢ connection with is Palm Beach County. 20 Q Where were the case➢ pending? 21 A The canes were pending in Palm Beach County. 22 So there was a natural Lit for me to work on the➢e 23 cases, and I think that'➢ why I was brought in to work 24 with him. 25 Q You described these as significant cases. 30 1 wrong that wa➢ going on here? 2 A No. 3 0 Did all of thi➢ new➢ coma as a complete and 4 total shock to you? 5 A Absolutely. 0 Do you know Brad Edwards? A Yes. 5 Q When and how did you first moot Brad? 9 A I met him at the firm sometime in the first 10 three months, something like that, of 2009, after I had 11 been with the firm [or about almost a year. I met him 12 there. 13 Q Well, the jury will have been told, by the 14 time that your to➢timony is played to then, that Brad 15 joined the firm con➢iderably after you joined and wan 14 there for a period of about five months. So you were 17 there for almo➢t a year before Brad joined the firm, correct? 19 A Right. 20 0 Did you ever have occasion to ➢hare any 21 ro➢ponsibilities with Brad Edwards. 22 A Ye➢. I believe the only matter Brad and I 23 worked on together, if not mistaken, was the -- or 24 were the three lawsuits against Nr. Epstein. 25 Q We have identified those case➢ as case➢ IS 32 I What doe➢ that mean? 2 A Well, they involve terrible thing➢ that I happened co these three young women when they were 4 minors, ➢o they were significant in the ➢ense that the 5 personal injury to them wan enormou➢. They were al➢o 4 significant ca➢es in terms of what their potential damages were in terms of dollars. 0 Why? 9 A Because jurie➢ are asked to use their common 10 sense and their reasoning to come up with a dollar Il amount to compensate victims of wrongdoing by others. 12 Q We have identified the defendant in these 13 case➢ as Jeffrey Epstein. Was there anything about 14 the circumstances, nature or character of the IS defendant that had any influence on your describing 14 these a➢ ➢ignificant case➢? I/ A Yes. If you are going to be representing In somebody who has suffered, what I would call -- 19 although it wa➢n't exactly physical, it wan mental -- 20 catastrophic damage➢, catastrophic trauma, which I 21 believe these young women experienced when they more 22 minors and wa➢ ➢till affected by, if you're going to 23 represent them in that type of ca➢e, the case la more 24 significant IC the person that you aro suing has a➢sets 25 that you can go after ➢o that you -- so that your Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798344 2 3 5 7 s 20 II 12 13 le Is 14 11 Is Is 20 21 22 23 24 25 33 client can be compensated. And Jeffrey Epstein was a billionaire. And ao in terms of compensating, making g➢od to these young women, which would be called compensatory damage➢, this was a very significant case. You had terrible injuries, mental injuries. You had a defendant who, to me, was clearly libel, and so there would a very, very significant award of compormatory damage➢. In addition, if you were able to prove a certain degree of willfulne➢➢, that the➢e act➢ -- that he did thesethings intentionally, or he did them with a certain mindset, you could recover, what's callsd under the law, punitive dmage➢. Punitive damages are based on how wealthy the defendant is, ➢o that the defendant could be punished. And lf a person is extremely wealthy, then an award of punitive damages that'➢ $100,000, which would seem like a largo award if it wa➢ awarded against mo, would be an insignificant award of punitive damage➢ against somebody who is billionaire. So to -- so the firm wan In a position in representing 'these young women to go to a jury and ask for very, very high number of -- in dollars 1 4 5 4 s * Is II 12 13 IS Is 14 17 Is Is 20 21 22 23 24 25 35 But you do recall Paul Cassell 's involvement. What about other local lawyers? Wore there other local lawyers who were participants in the prosecution of she cases against Jeffrey Epstein? A Yeah. Not representing our three clients, but there were other firms that were representing other young woman that had been abused by him. Ye➢, I did know of those firms. There vas the Podhurst firm in Miami, a very prominent firms Bob Josofsborg, who I have known for years. Bob is one of the moat prominent attorneys also in South Florida. He had a case -- ho had cases against Mr. Epstein. Or he had clients -- I don't know if he actually filed cases, but he had clients that were victims of MX. Epstein. Sid Garcia is a very prominent attorney in Palm Beach County, who was also representing victim. Spencer Nuieln was another lawyer. Ted Leopold, another prominent attorney, ho also had clients. The Searcy Denney, who is a prominent firm, had clients as well against Kr. Epstein. And I believe an attorney named Adam Horowitz also. Those are attorneys that I recall had similar cases I 2 3 4 I 7 10 II 12 13 14 IS It 11 IS 34 compensatory damages, as well as an extremely high norther in punitive damages, because it would take a very large amount of punitive damages to punish somebody who is a billionaire. Q Dld the prosecution of the three lawsuits for which you and Brad Edwards were responsible involvo efforts of any lawyers outside of RRA? A There was a Paul Cassell who wan co-counsel with Brad. I never met him. I have spoken so him. And he had been working with Brad -- Brad brought these cases to the firm. No didn't -- he didn't get hired on these cases after he joined ARA. Be had already filed these cases, I believe. I know ho had shoe -- the ladies as clients before he joined the firm. And Cassell was co-counsel with him on those. So in terns of attorneys that were co-counsel wish ua, he was a co-counsel representing the three young woman that we represented. I 2 3 I S t 10 11 12 13 le 15 If 17 le 36 to ours. Q Tell ua about shit extent to which you wore working together in coordinating efforts with those other lawyers. A Well, wo had -- we were conmenlcating, we wore comparing notes, we were strategiming with then. 0 What is a joint prosecution agreement? A A joint prosecution agreement la an agreement typically in writing -- although it doesn't have to be between the attorneys for different clients to pool their efforts and to keep confidential their confidential communications and to jointly assist each other because their clients have a common goal and aro typically litigating against the sane person or company. It's an agreement to share information. Q Did such an agreement exist to which you and you Brad, as lawyers with RNA, were cooperating in a joint prosecution effort with Bob Joaaf➢berg, It 0 Toll ua about Paul Caaaell. IS Spencer kuvin, Sid Garcia, Tod Leopold, Adam Horowitz 20 A Well, I don't know a whole lot about him, 30 and the Searcy Denney law firm? 21 other than he lives out of atato. And I think he's 21 A Yea. 22 connected with a university. I may be mistaken. 22 0 To what extent did Brad Edwards as➢um a 23 0 No, I think that you aro recalling 23 leadership role in that prosecution effort? 24 correctly, but we will get those detail➢ from other 24 A With our firm, with RNA, I was -- I took a 31 wan aaaaa 23 secondary role to Brad. Brad was the load attorney. Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798345 37 39 These were his clients, and I had -- I had specific 1 roles, really. I wasn't handling the same breadth of 3 issues that Brad was. I wan handling certain specific 4 aspects to the case, and also strateglzing with Brad. S But he had the lion's share of the representation. 4 Q And were there also joint prosecution 7 conferences regarding how discovery was conducted, 8 who wan to lead the discovery efforts, what discovery * was to to taken among this group of lawyers who wore 10 all prosecuting claims on behalf of child victims 11 against Jeffrey Epstein? 12 A Yes. We had verbal. I think I attended one 13 in peIlon. O Did those neetinga go on throughout your 19 involvement in the prosecution of those claims? I, A Yea. Q Describe the nature and extent of the 14 investigation into Jeffrey Ep➢tein's activities that It was undertaken in connection with thin group effort 20 to hold Mr. Epstein responsible for the victimization 21 of children. 21 MR. LINK: Object to the form. 23 BY MR. SCAROLA: 24 Q Let me restate the question. 2S Describe, if you would, please, the nature I BY I . SCAROLA: 1 4 S Q When you refer to young women being on the planes, did you ever make a determination as to whether there were, In fact, children balm; transported on those planes by Mr. Epstein? 4 A I have to correct myself. When I talk about ▪ young unman, they were young women when we wore ▪ representing them and at the tine that I was involved. * But at the time these things happened, they wore IC minors. 11 • You were involved in the representation of 12 three specific individuals. Of what significance was 13 it in your representation of those three individuals to be investigating and cooperating in the 19 investigation of offenses alleged to have 14 conflicted -- to have been comnatted by Jeffrey 17 Epstein against other children? to A Well, although we just represented three 11 minors, or three young women at the time, the rules of 20 evidence at a trial do allow an attorney for -- would 21 have allowed us, as attorneys for these waxen, to put 21 on evidence of other victims and other bad acts by 23 Mr. Epstein. 24 There's a Florida statute, 90.404, that 2S allows other acts, even though they weren't II 1 2 3 4 8 9 30 32 32 39 34 24 16 17 18 19 20 21 22 23 24 25 38 and extent of the investigation that was undertaken into Jeffrey Epstein's wrongdoing. MR. LINK: Object to the form. THE WITNESS: Well, it was pretty extensive. There were a number of people interviewed and you had a network of -- you had people that were -- that surrounded Epstein In terns of members of his entourage or his organization or -- that worked for him, and there was a major effort to locate these individuals that may be potential witnesses. There were third parties that -- such as pilots that wore -- we were trying to track down or communicate with, because there had been statements made about how sane of these victims wore on planes that wore chartered or owned by Mr. Epstein, so there were efforts to get the flight logs, and to depose people who -- many of whom turned out to be very prominent, nationally, individuals that were on planes that we believed contained -- at the same time there were young women on the planes -- to track down those witnesses. 40 committed against your particular client, to be 2 introduced to show a pattern, a practice, a modus 3 operandi, motives, and so it was important for ue to 4 investigate any wrongdoing by Hr. Epstein against 5 any young woman that was similarly situated and 4 groomed and recruited, like ours were, when they 7 were teenagers. That would all possibly have been • evidence that could be presented to a jury in a 9 trial, even though our clients weren't directly 10 involved in those instances. • In light of the rules of evidence and the 11 Florida statute that you have referenced, did you 13 perceive that any obligation existed to investigate 14 alleged crimes committed against other children by IS Jeffrey Epstein under the same circumatances as your 14 own clients had been victimized? A I think it would have been professional IS malpractice not to have investigated other instances, because they were all potentially relevant and it was 20 powerful evidence that if he did it to other women, he 21 did it to us. If the techniques wore the same and the 22 same pattern of activity existed -- so I think we were 23 bound as attorneys to conduct these other 24 investigations. 21 Q Were any of your three clients molested by 11 17 19 Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798346 41 43 Jeffrey Epstein onboard any of Jeffrey Epstein's 2 pats? 3 A I don't recall that, no. 4 Q In spite of the fact that there wore no • specific allegations that any of your clients were 4 abused onboard Jeffrey Epstein's jets, why did you 7 pur➢ue an investigation as to what went on onboard • the jots? • A Nell, if -- IC minors wore molested on those IC jets, even though they weren't our clients, it would II fit the pattern of what Mr. Epstein had done to our Id clients, and could have been evidence that the judge 13 would have allowed the Jury in that case to hoar. II 0 You mentioned that names of high -profile 14 individuals and celebrities came up during the course 14 of the investigation. were investigative loads 17 pur➢ued with regard to those individuals? II A I didn't have any direct involvement of that. It I just know that wo talked about specific Individuals, 20 that they were on the planes or they were at 21 Mr. Epstein'! house. 21 Whether -- when I was working on the 23 ease -- the cases before the firm collapsed -- 24 whether we issued ➢ubpoenas or tried to issue 2S subpoena➢ to those persons, I don't recall that. 1 4 S • Why would Jeffrey Epstein be flying on a plane with a minor child who is not his child? And what connection did that child have to him? why would she be on the plane. That would tend to prove that he had evil motives and it had fit the pattern of molestation of our clients. So the slightest -- any proof that he was in the presence of minor children that weren't his * children that he had no connection with was valuable IC evidence because it fit the pattern. II 12 iI Q What was the geographic scope of the Investigation that was undertaken with regard to Jeffrey Epstein? A Nell, it was almost global, really, because II of the range of his movements. It was certainly 14 national. I know he had also prope 17 property in the Bahamas -- the Caribbean, so chore were I• tie➢ throughout the western hemisphere. Q As an active participant responsible for 20 sharing the task of representing these throe clients' 21 in claim* against Jeffrey Epstein involving pattern➢ 21 of the molestation of children, was there ever 2) anything illegal, unethical or even unreasonable 24 about the things that wore investigated in the 2S Epstein cases? II 0 If, in fact, there was evidence that 2 high-profile individuals and celebrities were in a 3 position to have observed Jeffrey Epateirrs conduct 4 in the presence of minors who turned out to be I victims of sexual molestation, would there to any 4 reason to refrain from pursuing investigative lead➢ 7 with regard to those individuals? MR. LINZ: Object to the form. 10 11 12 1) 14 IS 14 17 IS IS 30 31 32 33 34 33 42 THE WITNESS: No. BY MR. SCAROLA: You spoke about an obligation to pursue investigative loads. Now would that obligation pertain, if at all, to investigative leads that lead to high -profile and celebrity individuals? A You know, the Bar has in writing that an attorney is supposed to zealously represent a client. To ma we were duty-bound to pursue these lead➢. And I think that we were obligated to do it. If Mr. Epstein was on an airplane, either his plane or a plane he chartered, and he was with another person, whether that person was a high-profile person or somebody else, and there was a minor, a young minor -- female minor on that plane -- whether molestation occurred on that plane or not, to me that'➢ powerful evidence. 44 A No. 2 Q Was there ever anything illegal, unethical 3 or even unreasonable about the people included in the 4 scope of that investigation? A No. 4 Q was there ever anything illegal, unethical 7 or even unrea➢onable about the way in which the S Investigation was conducted? 1 A No. 10 Q Did you over have any reason to question II the legitimacy of any of the claims that were being 12 prosecuted against Jeffrey Epstein by your law firm 13 and by you? 14 A No. IS Q Did you ever have any reason to question If the legitimacy of any of the claims that were 17 prosecuted against Jeffrey Epstein by those with whom IS you were participating in a joint prosecution agreement? A No. Q You have told us that, from your perception, based upon your experience and training, 23 these were significant cases. Did you ever Corm an 24 opinion regarding the potential value or the claims from a compensatory damage standpoint? If 30 31 32 33 Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798347 45 47 I A They were in the multi-millions of dollars 1 So there was then discovery directed to 2 from a compensatory standpoint. 2 VS to her to discuss her life as a ) 0 And did you form an opinion regarding the 3 prostitute. Nell, as a prostitute, a 4 potential punitive damage value of the cases? 4 prostitute would have a pimp, a guy that 5 A Again, multi-millions of dollars. S would control her, that would be her boss, 4 0 Who controls the decision as to whether to 4 and who would have her under his thumb, and f settle a civil lawsuit? 7 who could threaten her and physically harm 0 A Well, as in any case, the client calls the 8 her if she didn't do what he wanted. I shots and makes the decision to settle. q Nell, Epstein's attorneys wanted us to le 0 What was your perception of the 10 disclose -- wanted our client to disclose 11 difficulties, If any, faced by the child victims who II those relationships, who was her pimp, 12 were prosecuting claims against Jeffrey Epstein? 12 things like that. Her life was now 13 A In toms of bringing choir claims? 13 completely in danger, so we had to deal with 14 0 Yes, sir. In corms of pursuing these 14 those issues. Is claims. Did they face any difficulties, or did they 15 So every person who brings a lawsuit II jest turn this matter over to choir lawyers and they 10 whore their main damage is what's been done 19 didn't need to be concerned about it from that point? 17 to their mind, not so much what's been done 10 MR. LIWR: Object to the form. 16 to their body -- those young women weren't II THE WITNESS: Well, yeah, Choy nada 19 physically disabled. They were mentally 20 themselves targets of personal criticism by 20 disabled and their lives had been destroyed. 21 Mr. Epstein's attorneys. And similarly to 21 Any person that brings that type of a 22 how, I think, the plea deal cane down, sane 22 lawsuit, everything about them IS open to 2) reasons. 23 investigation. That's part of bringing a 24 But the process that we are involved in 24 lawsuit. That was particularly difficult in 25 right now is discovery. So the discovery 25 those circumstances. So those young women 46 48 I process with regard to bringing these claims I wont through a lot during the time that I 2 by these young women involved opening up 2 was representing then in that regard. It 3 their lives to Mr. Epstein and his 3 was very, very difficult for them to go 4 investigators and to the public. 4 through this lawsuit process. These were young women who were groomed by him. They wore identified by him and his 0 4 It wasn't just, here is my case, Attorney. You represent no. They wore now 7 associates as candidates for his 1 part of it and they wore paying the price. 6 molestation. They were from broken homes, $ BY KR. SCAROIA: 9 broken families. Their mothers night have 9 Q Did you over observe anything during CIO 10 boon prostitutes themselves. And those 10 course of the prosecution of those claims chat was. 11 young woman's lives were destroyed by tan. 11 intended co inproporly or falsely exaggerate the 12 And consequently, after he was finished 12 seriousness of the impact that these molestation had 13 with them, they had to then live their I) had on your clients? 14 lives, and many of them had problems, and 14 A I wouldn't go so far as to say that is was an 15 they faced hardships as a result of what he 15 attempt to exaggerate it. I think that the attorneys 14 did to them. And all of those things would 14 chat wo wore facing wore trying co diminish the effect 17 be made public and would be investigated. 17 of what Epstein did co our clients by saying that 18 And you also had a situation -- it was IS they somehow -- that our clients sonehow would have 19 a very difficult situation -- I was directly 19 done these things anyway. 20 involved with it -- in terms of courtroom 20 But I can't really -- it was very 21 appearance where, if not mistaken, one 21 difficult. It took a lot of courage -- a lot of 22 or two -- maybe ono of our clients was 22 courage for those young women co pursue those cases. 23 accused of being a prostitute herself as she 23 But I couldn't say that -- really that it was 24 grew up and after Epstein was finished with 24 anything unethical that the opposing attorneys were 25 her. 25 doing. They wore representing him zealously, too. Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798348 2 3 4 7 4 * IC II 12 13 IS II It I? IS IS 20 21 22 23 24 25 49 Q So let's focus on what you and Brad Edwards were doing. Waa there anything ever improper that was undertaken to try to exaggerate the value of these claim's or the impact that Jeffrey Epatein's molestation had had on these young children? A No. Q Did you ever see anything that was done in prosecuting the Epstein cases that was illegal, unethical or unreasonable in any way? A No. Q Was anything done that was not part of a completely proper effort to protect the legal rights of your three child victims? A No. Q Dld there coma a tine when you learned that Rothstein had used the cases that we have been referring to to attract Ponsi schema investor➢? A I learned that sometime in the beginning of November of 2009 by -- , by reading it in the paper. Q prior to that tine, was there any reason whatsoever for you to have even suspected that any of [base claims being legitimately prosecuted by you and Brad Edwards were being used for any improper purpose? 2 ) 4 5 4 7 s * IC II 12 13 14 13 14 I7 14 I* 20 21 22 23 24 25 51 Jeffrey Epstein wa➢ attempting to defend himself over the course of the month➢ that you were involved in these claims? A Nell, he took the Fifth amendment and then he went after the clients -- or his attorney did very aggressively. Q In light of hi➢ aggressive attack➢ on the victim, did it coma as a surprise to you that Jaffrey Epstein had attempted to attack Brad Edward➢? A Well, it was -- again, I was ➢till ➢tuned that he did. 0 In addition to prosecution of these three civil lawsuit➢ against Jeffrey Epstein, did you become aware of the fact that Brad WAS volunteering his services to challenge the validity of Jeffrey Epstein'➢ criminal plea deal? A I didn't know what Brad'➢ financial arrangement wa➢ at all. I did know that he wa➢ representing, I think, the throe same clients in a federal lawsuit challenging the plea agreement. Q Dld you become aware of the terms of that plea agreement? A Yes. Q And what was your reaction when you learned that Jeffrey Epstein had been granted federal 50 A No. 52 immunity -- not only for himself, but from -- for all 2 Q Evan as you sit here today, looking back in 2 of his co-conspirators -- against any federal 3 retrospect, la there anything that you can point to prosecution in exchange for an 1S-month state )all 4 and say, you know, I didn't reopens* it at the time, but maybe that should have raised ➢ome suspicion? 4 sentence? A It gas an outrageou➢ly wrong plea agreement. 4 A No. Tho idea that he wan conducting a Ronal 4 I was embarra➢sed for the -- that the V.S. Attorney's scheme had never -- I never had the slightest inkling / office and the state attorney in Palm Beach County that that was occurring. S would agree to such a deal. 9 0 No are bore taking your deposition today 9 Q What was the ➢ignificance of Brad'➢ 10 because, as you know, Jeffrey Epstein filed a lawsuit 10 involvement in attempting to undo that transaction on II against Brad Edward➢ accusing him of having been a II behalf of Jeffrey Epstein•a victims? 12 knowing participant in Scott Rothstein'➢ Rani 12 MR. LINK: Object to the form. 13 scheme -- 13 NITHESS: Nell, it was the right 14 MR. LINK: Object to the form. 14 thing to do. They were -- I didn't have any IS BY I . SCAROLA: IS direct involvement in that proceeding. As I If 0 -- of having been involved in the If understood it, as in Florida -- Florida has 17 commission of a variety of serious crimes. 17 a law -- as a criminal judge, I try to IS What was your reaction when Epstein sued IS uphold that and I ➢aw it unfold in front of la Brad alleging that he had participated in 19 me, because people who are victim have a 20 fabricating or exaggerating claims against Jeffrey 20 right to notice and to participate and to bo 21 Epstein? 31 present during key facets of the prosecution 22 A I read that in the paper and I was ➢tunned. 22 of the parson who is the wrongdoer, the 33 0 Why? 33 person who is Charged With a crime, 24 A It was outrageous. 34 particularly when it came to a sentencing 23 Q Had you come to know the manner in which 31 hearing. And the right of a victim to Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798349 53 55 1 attend the sentencing hearing and to bo I the court reporter would like to do. 2 apprized that it's coming and to have the 2 THE VIDEOGRAPHER: Going off the record 3 right to give input to the prosecutor is a ) at 10:45 4 right that I try to enforce, and I saw It 4 4A recess was had.) 5 unfold. And the state attorney's office S THE VIDEOGRAPHER: Going back on the 6 complied with that when I was on the bench, 4 video record. The time is 10:55 . 7 so I was somewhat familiar with that 1 CROSS-EXAMINATION 8 concept. We are dealing here with the 4 BY KR. LINK: 9 federal prosecution. I came to learn that 4 0 Good morning. 10 under federal law, there's a similar law to is A Good morning. 11 the one that we have under the state system. II 0 As you know, Scott Link, and 12 And so I thought it was very 12 representing the plaintiff, Jeffrey Epstein, in this 13 significant. It was unique for an attorney 13 matter. 14 to bo representing victims who had -- where is We, too, hope that your surgery is IS the perpetrator was prosecuted in a federal II successful and that you recover fully. If casco, and the attorney was trying to uphold is A Thank you very much. 17 the right of these victims to have 17 Q And we appreciate you being hero today. le participated in and boon consulted and given is During your direct examination, ono of the 19 notice for an opportunity to bo heard with Is things that you were talking about was the Pons" 20 regard to the sentencing of the parson who 20 scheme that Mr. Rothstein ran as part of the -- you II did those crimes to them. I thought Brad 21 called it RIM -- that's the law firm -- the 22 was doing something that I had never hoard 21 Rothstein firm, right? 22 an attorney do. It was a very courageous 2) A Noll, you said right. It wasn't part of the 24 act and ho should be commended for it. 24 RRA firm. IS 2S Q It wasn't? 54 56 I BY I . SCAROLA: I A No. 2 Q During the course of your decades of 2 Q So there wasn't any part of the cases or 3 practice, including the time you spent as a circuit 3 the omployeea or anybody at the Rothstein law firm 4 court judge, had you over oven hoard of a plea deal 4 that were participants in the Rothstein Ponsi schema. 3 where not only was the defendant himself 'amazed, 2 Is that your testimony? 4 but all of his unnamed co-conspirators were given 6 MR. SCAROLA: Objection, compound. 7 Imaunity for all of Choir unnamed crises? 7 THE WITNESS: I mean, there wore S MR. LINK: Object to the form. I employees that wore -- I don't consider it 9 THE WITNESS: No. 9 part of the BRA firm. It was a rogue IC By I . SCAROLA: 10 criminal activity that was outside the 11 0 Except as an effort to try to intimidate II purpose of the firm and -- I moan, I admit 12 and bully Brad Edward,' into backing off what Brad was 12 it was done by Rothstein. And certainly 11 doing both in attempting to hold Jeffrey Epstein 1) several of the attorneys were prosecuted. 14 civilly responsible for his wrongs and to challenge 14 Sena of sham, of course, were prosecuted, IS the plea that he had been permitted to enter, are you IS but having nothing to do with the Ponsi 14 aware of any reason whatsoever that would justify 14 scheme, such as Steve Lippman and Stuart 17 Jeffrey Epstein In suing Brad Edwards? 17 Rosenfeldt, as far as I know. And there II MR. LINK: Object to the form. II wore a couple of employees that were 19 THE WITNESS: No. 19 irplicated in connection with the Ponsi 35 MR. SCAROLA: Thank you. I don't have 25 scheme. And there wan even one or two 31 any further questions. 21 clients that More part of the Ponsi scheme. 32 MR. LINK: Mr. Borger, before we start 22 But maybe. being -- playing on 33 [roes-examination, do you want to take a 23 nocantics. I just don't consider it to be 24 break or aro you okay? 24 part of the firm. But I have acknowledge 33 THE WITNESS: I would go with whatever 21 those connections that you are pointing out. Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798350 57 59 BY RR. LINK: 2 Q Do no a favor. Toll the jury what a Banal 3 scheme is. A A Ronal schema la -- is -- not that I know -- I have learned much more as to what it is by reading 4 about the Rothstein scam. A Ronal scheme is where you ? solicit investors and you have something that you're ­ promoting with their money. You're soliciting their * money and you are paying them a return on their money, 14 not from profits of whatever enterprise it, but you are 11 paying them from money that you are getting from 12 lnve➢tors after them. 13 so the business enterprise that you're 14 promoting, that you're soliciting the money for 12 13 not really a legitimate business enterprise with a 14 purpose of being self-➢ufficient. It'➢ one that'➢ 12 funded by the continual investments or investments 14 by investors and investors after them, and so it ha➢ 1* no substance. So at some point it's got to fall 20 apart because you can't keep bringing in now IL investors and milking new Investors to keep 22 everything afloat and payoff the return to the other 23 investors. 24 0 so would you agree with me Mr. Rothstein 25 wa➢ fabricating settlements and using those 1 2 4 4 7 IC II 12 13 II If 14 17 is It 20 2L 22 23 24 25 particular who eventually wrote a book -- Sako -- something like that. No said that the reason -- ono of the reasons ho backed out of investing money is because he wasn't allowed to see the file. So I don't know if Rothstein actually physically showed these three files to victims of his scam. But he certainly had physical possession of them and used then in soma way. BY NR. LINK: O so you don't know the details, but you aro aware that Rothstein used the three pending cases against Epstein and fabricated settle ants and information in order to try to keep his Ponsi scheme alive? MR. SCAROLA: objection. Secondhand knowledge and compound. THE WITNESS: Again, when you say, I know, I heard that. I don't know if it was all three. And I don't know exactly how he used then In terms of -- since we didn't have -- you know, the cases wore going by initials -- and I just don't know what use he put then to. 58 I fabricated settlements to try to entice folks to give 2 him money? 3 A Yea. 4 Q Investors to give hie money? A Yes. 4 Q And he would use actual, sometime➢, cases 7 that were pending at the law firm? A Apparently that is what he did. I learned 9 that after the fact. 10 Q Can you tell the jury what Mr. Rothstein II did with the three cases that were pending against 12 13 15 13 IS 19 30 31 32 33 34 35 Mr. Epstein? Now did Rothstein use them? MR. SCAROLA: objection. Predicate. THE WITNESS: I don't know exactly. I have read -- I have only read that he physically had the flies of those cases, the case file➢, and I think had -- at ➢one point had brought then into his office after hours. I don't know what he did with them. I don't know if he showed thew to investors or he was just familiarizing himself with the details, because in reading sone other statements by people who were scanned, ono of the things that -- well, one person in 60 BY NR. LINK: 2 Q Can you tell me the first time you spoke to 3 Mr. Rothstein about ono or all of the three pending I 5 S 10 cases against Hr. Epstein? A You know, not even sure I talked to Scott about the case➢. Q You don't have a memory, as you sit here today, of participating in group conversations with the lawyers involved in the Epstein cases meting with Mr. Rothstein? IL A No. 12 Q How often would you neat with 13 Mr. Rothstein? 14 A You know, I would see him in the hall. I 15 would go co his office If I had a question. How often? 14 Sometimes I saw him ovary day. When you say moot with him, wo didn't IS have -- I moan, we did have -- we did have -- It don't know if they were regular or periodic, but we 24 did have meetings of shareholders in the firm. Not 21 to discuss specific cases, really, but just to -- 22 just firm business. So I saw him probably everyday. 33 Q so mentioned the fire's shareholders. That 31 was the small elite group of the senior lawyers of 25 the firm, right? Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798351 61 1 A Well, it was the small group of the senior 2 attorneys. I don't know that I would call It elite. 0 And you were ono of them? 4 A Yoa. 5 0 And you held yourself out to the public as 6 a shareholder? 7 A Yoa. 0 What does it moan to bo a shareholder? 9 A It could mean -- I guess the common 10 knowledge -- or the common connotation would be 11 somebody that owns a piece of the conpany. 12 0 Sure. If you own shares In the company, 13 right? 14 A Right. 25 0 Did you, in fact, own shares company? 26 A No. 22 0 Yet you did hold yourself out as a 28 shareholder? 29 A Yes. 20 0 I fact, I've road newspaper articles that 21 talk about you as a shareholder. Do you romanber 22 A 22 MR. SCAROLA, Excuse me. 24 Object to the form of the question. IS 63 I meetings to discuss the business of the firm, did you 2 talk about the financial aide of the business? 3 4 S 4 s 10 11 12 13 11 15 14 17 IS It 20 21 22 23 24 25 A we talked about finances just in general, not really -- not numbers in terms of, for example, the firm had revenue of k dollars this month. No, we didn't have that type of discussion. Q Mere you aware of revenue that the lawyers in the firm were generating? A No. Q You aro not aware that in 2008 the total revenue was about 58 million? A No. Q How such revenue a year did you generate, air? A I don't remember. Q Now such were you paid when you first started? A Three hundred thousand a year. Q Dld your salary go up when you were there? A No. Q Did you have any clients when you started at the firm? A Well, I had just loft the bench, so I didn't have clients, no. Q How such was your salary when you were on 2 3 4 5 t 7 10 II 12 13 14 IS If 11 62 BY MR. LINK: Q Do you remember seeing newspaper articles holding you out as a shareholder? MR. SCAROLA: Objection. Secondhand knowledge, hearsay. IRE WITNESS: I don't remember seeing -- I can't recall an article whore I was totaled as a shareholder. I wouldn't doubt it, though, because that's what I was called. BY MR. LINK: Q That's what you were called and that's what you hold yourself out aa, right? MR. SCAROLA: Sara objection. TIC WITNESS: Right. BY MR. LINK: O How many shareholders wore there In this IS roughly 70-lawyer firm? 19 30 31 A I think there were about 10. Q And who were the other shareholders? A Stuart Rosenfeldt, Russell Adler, Lea 22 Streltfeld, Steve Lippman. There were others -- Mare 23 think might have been -- - pretty sure Hunk was a 24 shareholder. I just don't camber other names. 35 Q And when you would have these shareholder 64 the bench? 2 A About 150,000. 3 Q So you doubled your salary by going with 4 the Roth➢tein fir? 5 A Correct. Q Did you have any offers from law fires 5 Other than the Rothstein firm? A No. Not offer➢. 9 0 During the tine that you were with the 10 Rothstein firm, you said chinos changed, the way -- Il the office size and things, of that nature, right? 12 A Right. 13 0 Mr. Scarola asked you about whether Chore 14 was anything you saw that was a bit of a red flag at IS the time or when you look back. I want to talk to If you about the changes that you saw, okay? 17 Can you describe for the jury how you IS would gat to Kr. Rothstein , . office in October 2009? 19 What process did you have to go through? 30 A You had to speak to -- Ms. Feiss, I believe, 21 was hla aaaaaaa nt -- or scootody else to soo if Scott's 22 in, could you talk to him. 23 Q Was his office just sitting out there on 21 the main floor like your office la here at this law 25 fi rm? Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798352 65 67 1 A Well, it was on the nain floor. It was -- 2 there wa➢ a corridor, and his office wa➢ behind the 3 door at the end of the corridor. 4 Q Was there ➢ecurity guards? In order to get 5 to his office you had to go passed security guards? A There w➢ security at tines in the firm. I 7 wouldn't -- keeping in mind I was in Boca most of the s time around that time, ➢o I couldn't say whether there * was security in the Fort Lauderdale office 24/7. But 10 there wore a couple of ➢ecurity guards that -- they 11 didn't wear uniforms, but they were bodyguard➢. That's 12 how I phrase theft. 13 Q Rothstein had bodyguards? 14 A Yeah. 15 O Nave you ever had a bodyguard as a lawyer? 14 A No. 17 Q Dld you think it at all strange that 14 Mr. Rothstein had a couple of bodyguards protecting Is him? 20 A I thought it was strange, yeah. 21 Q I have heard that to get to his office that 22 you had to actually pass dawn this corridor and that 23 there were sort of obstacles and hurdle➢ in ardor to 24 get in there. It wasn't as though you could walk IS down the main hallway, open his door and walk in. 1 Q lust in the cannon areas you thought? 2 A I didn't know that there were speakers or 3 wiretaps or surveillance In people's offices. 4 0 Were you aware that he had a private S elevator in his office? MR. SCAROLA: Could we identify when 7 this. awareness arose? MR. LINK: Mr. scarola, we already • talked about it being October 2009. THE NITNESS: sorry, you talked 11 about -- you asked no how did you get in the 12 office in October of 2009. 13 BY MR. LINK: • That's what talking about. 15 A I wasn't aware of electronic surveillance in 14 October of 2009. I learned that afterwards. 17 0 You were not -- IS A No. It Q so while you were at the fi rm you were 20 unaware that there was electronic surveillance at the 21 firm? 22 A Yes. 23 Q Were you aware that his office had a 24 private elevator? 2S MR. SCAROLA: When? 2 3 4 9 10 II 12 13 14 IS If I IS 19 30 31 32 33 34 25 66 MR. SCAROLA: Object to the fore of the question. THE WITNESS: If you're talking about something like a mall would have an obstacle➢ for somebody -- they couldn't drive a car through a door at NaCy'S or smoothing like that -- I don't remember any obstacle➢. BY MR. LINK: • You don't remember there being an off -duty sheriff in the building providing ➢ecurity? A Not really, no. O Do you remoter the electronic surveillance equipment that Mr. Rothstein had at the firm? A Yes. O Describe it for us, A Re had -- there was a loudspeaker, and I learned that it wa➢ a two-way one where he could listen to what you were saying. O In your office? A No. That I didn't know. Q NOW about in the conference room? A I didn't knew specifically whore. Q Whore would he be listening to people at? A The common areas. 2 4 4 8 9 10 IL 12 13 14 IS If IS 68 BY MR. LINK: Q sir, all of them questions are October 2009, okay? A When you say a private elevator -- when I joined the fire in June of 2008, there was an elevator that Stuart Rosenfeldt and Scott Rothstein used that was in the building. It's not like in October of 2009 they had an elevator constructed. There was an elevator that would -- it wasn't in the public corridor where the other elevators were. Now, whether this elevator serviced other people in the building or not, I have no idea. I never was on it. Q You were never invited to ride on Mr. Rothstein's elevator? A Well, you call it Mr. Rothstein's elevator. It was in a location that accessible by Stuart and 19 Scott. Whether it could have been acce➢sible by 30 somebody else, I don't recall. I might have ridden OA 21 the elevator, but I don't know that it was one that was 22 specifically for then as opposed to any other tenants 33 in the building. 34 It wasn't One that was publicly used. 25 will agree to that. Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798353 1 3 4 S s Is II 12 13 12 14 17 'a Is 20 2l 22 23 24 25 69 Q You mentioned Hr. Kendall Coffey. Old you read hi➢ report on the layers of secrecy that he described as he wa➢ trying to ➢ay that what Rothstein was doing was unknown because of the secret world that Mr. Rothstein created at the firm. Did you road that report, ➢ir? A No, I didn't road the report. Are you familiar with what El talking about? A No, I didn't know there was a written report. I did see Kendall Coffey on TV. No invited newspaper reporters -- he Malted reporters and a cameranan to walk through the office. That I did see. 4) Okay, tell ue -- tell the jury what it is that you saw. What was Hr. Kendall Coffey pointing out sheet the layer of Hr. Rothstein? MR. SCAROLA: Excuse ne. Could we set a tine frame, please? BY I . LINK: Q Has there more than one tine you saw Mr. Coffey on TV? A No, this was probably in November of 2009. Q Can you ➢hare with the jury what Mr. Coffey was showing the world about Rothateln'a inner sanctum. 2 4 5 4 7 II 12 13 14 13 14 I7 14 is 20 2L 21 23 24 25 71 But before that, Scott's office, basically, you could just walk in on his office. I once walked into Scott Rothstein'➢ office -- again, before the renodallm -- and -- within the Jewish religion, people, if they are devout believers, would do something called davening, and that's praying. My father did that every morning. And that would mean you had the Bible, the Torah, and you prayed and you chanted and you talked in Hebrew. I walked in and Scott was davening. It was ao -- excuse no. So it was almost an open door policy for most of the tine that I was there until this remodeling occurred. BY I . LINK: Q Right. And that's what focused on, which la how things changed during the tine that you were at the fins. A Right. Q so he had an open door policy, than Chore's a renodallng and his open door policy vanished, correct? A To moat extent, yea. Q Could you just walk up and go into hla 2 70 MR. SCAROLA: Object to the form of the question. 2 72 office without being cleared first? A Sonatinas, yea. 3 THE WITNESS: He showed them that to 0 Into the remodeled space? 4 get to the office, you had to walk through a 4 A Yeah. It's happened. 5 corridor. TILL➢ is just what I can visually Q So you had that level of relationship with 4 Mr. Rothstein that you could go to the Fort Again, I do not recall obstacles, as 7 Lauderdale office, once it wan remodeled, and simply 8 you put it. walk ln, open his door and go see him without having Certainly, there weren't any security 9 to clear any ➢taff person or ➢ecurity to do that; is 10 guards Standing there when Coffey was 10 that right? 31 showing the newspaper reporters things. II A sonatinas that happened once or twice, and it 32 Then there was a door. The door -- you 12 happened with other people, too. It's just that 19 would open the door and there was the 13 somebody wasn't there. 34 office. What he was actually showing to a 14 You would walk dawn the corridor. And if Is TV audience in the way of security, you 15 somebody didn't say Scott's busy or acmothing like 16 really couldn't toll because there was If that, you just knock on the door and ho would say, 17 nobody there and he wasn't -- he couldn't 17 Come in, something like that. That may have 18 point to anything electronic. He was just IS happened a couple of [Irma. It wasn't because of m➢ 19 showing where the corridor was and wham the 19 or who I was. It was ju➢t the timing of M. It 20 doors were and there wa➢ a door. It could 20 wasn't like it was 24/? all the tine. 21 have boon a double door or not. And that 21 SO I will agree it was different at the 22 Was -- again, that was -- as I said, the 22 tine period you are talking about than before in 23 office had been remodeled. 33 terms of access. 24 How soon before that -- I don't 24 In your 40 years of being a lawyer, have 25 remember when that remodeling had occurred. 23 you ever seen a law office like Mr. Rothstein's once Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798354 73 75 I he romodolod it? 2 A You moan the physical layout. Q Yes, air. A To ➢one extent. Are you talking about the decor in the f office itself? 7 Q Let's talk about the whole thing, the 4 process to gat to that office, where he wont from * being doors open to a secluded office. le A Wall, I mean, look, I worked for Mel 11 Greenberg who founded Greenberg Traurig, which is now 12 the largest firm in the world. I couldn't just knock 13 on Nal Greenberg's. door and walk in. I had to go 14 through -- I had to go through -- not security, a➢ you II would call it, but I had to go through hla secretary or 14 I had to make an appointment. He didn't have an open la door policy. Q Did Hr. Greenberg have bodyguards? A No. 20 Q How big was his office? 21 A He had a big office. 22 0 How big, roughly? 23 A I can't -- the conference room was bigger 24 than this conference room. 25 Q And how about Kr. Rothateln's office I him need two bodyguards to protect him? Who was 2 after him? A I don't know. 4 MR. SCAROLA: Objection, compound. S THE WITNESS: I don't know. I don't know. BY KR. LINK: Q Did you ever go to his house? A Yes. so Q What was hla house like? II A It was a lavish home. It wasn't the biggest 12 home in the community. He lived in a very high-end 13 cowounity on the water off of Las Olas Boulevard. It's 14 kind of a zero-lot-line community. There's not a lot Is of land outside the homes. So it was a very lavish 14 17 Q Hawaii:Iabout 66 million for it? la It 20 21 22 24 25 A I don't know what he paid. Q Do you know what kind of cars he had? A Well, I know he had a Rolls-Royce and he had a Bugatti. Q What's a Bugatti? loll the jury what a Bugatti is. A It's a very expansive sports car. Q Approximately how much to a buy a Bugatti? 74 1 compared to this conference room? 2 A It was a little bit bigger. Obviously it was 3 configured differently. Thin isn't a rectangular 4 office. I worked for Marty Fine and Bernie 4 Jacobson in Miami. They didn't have an open door / policy. • So their office was set up in the ➢ane way 9 as Rothstein? 10 Il 12 13 la 15 If 17 IS 11 A You are talking about an open door, okay. Open door can be different things. You still had to make -- you ➢till had to speak to their secretary to got in. You didn't have -- no, there weren't bodyguards. Not that there were bodyguard➢ everywhere and all the tine. There were people -- security people in the Roth➢tein firm. I didn't see that in other firma, no. Q Are you aware that Nr. Rothstein traveled 20 with bodyguards when he would go to meetings? 21 A Not specifically, no. I wouldn't be 32 surprised, but I didn't know that. 23 Q It wouldn't surprise you if he did? 24 A No. 2s Q What was is about Mr. Rothstein that made 2 3 76 A Half a million. Q What other kind of care did he have? A I don't know what other care he had. I moan 4 I know he had other cars. I don't know -- 9 10 11 12 13 la 15 If 17 IS 19 Q Did you ever ➢ee his Ferraris? A No. O His Lamborghinis? A No. O Did he have a boat? A Yea. Q What kind of boat did he have? A Ho had a -- I don't know Cho make of it. It was about 9O-foot -- I guess call it a -- not aura if you would call It a yacht. But it was a 90-foot boat. Q I would call 90-foot a yacht. A I wean it didn't have a sail -- it didn't have a west. So you could call it a yacht. A motor yacht I would call it. 20 0 So it was 90 feet long? 21 A Right. 22 4) Did he have a crow or did he drive that 33 boat himself? 24 A No, he didn't drive it himself. There wan a 2s captain. not ➢ure if there was a mato or anybody Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798355 2 3 4 5 4 7 10 11 12 13 4 13 14 Is 20 21 22 23 24 25 77 else that was associated with the boat. I think there Q Any other lawyers in Fort Lauderdale that you knot. have the 56 million home and the 90-foot boat behind it? MR. SCARALA: Excuse me. IM going to object. No proper predicate to the question. Assumes facts not In evidence. THE WITNESS: I don't know. BY MR. LINK: 0 Can you tell no ono other lawyer in Fort Lauderdale that has the Bugatti, Ferraris, Rolla-Royce, Lantorghlal, two bodyguards, a very large house on the , and a 90-foot boat? MR. SCAROLA: Objection. Improper predicate. kaaLlilaa facts not in evidence. THE WITNESS: I don't know. By KR. LINK: 0 Do you know of anyone? A No. Q Whore did the noway coma from for Mr. Rothstein to buy all of those things? A I don't know. Q Did you ever ask him any questions about where all this stuff cane from? 2 4 S 4 e I 10 11 12 11 14 II 14 17 is If 20 tl 22 23 24 25 79 that will give plaintiffs money for an a➢➢ignment of the potential recovery, right? A Right. Q Were you aware that Hr. Rothstein was doing something like that? A I had no idea. Q Did Hr. Rothstein over talk to you about the cases you were working on and what type of counts -- legal counts you had include! in your complaint. A No. You aro talking -- no, ho didn't. Q Would there to a difference in -- from ➢ort of this factoring standpoint -- the Pons,. scheme standpoint between a tort count and a non-tort count from a settlement ➢tandpoint? A Nell, I. not sure I ROCS Whit you're talking about. I don't know what you mean by the difference. I know what a tort claim is. A tort claim is ono where ➢omebody is personally injured, and a non-tort clam would be not involving a personal injury. Q Is there any difference in the law and the regulations on structured settlements between tort claims and non-tort claims? A No. That, I don't know. 78 A No. 80 Q Mr. Rothstein, during the tine that you 2 Q While you were working at the Rothstein 2 were employed there, I understand, bought a 2 firm, how many multi-million-dollar employment camas a restaurant called Bova. Are you familiar with that 4 did y 4 restaurant? 4 A I don't know of any. Q In the practice group that you Were in -- A Yes. It was downstairs in the building. 0 Did you ever eat there with Mr. Rothstein? 7 you were in tort practice group? 7 A Yes. S A No. No, I wasn't in the tort practice group. Q Can you tell no any other restaurants 9 0 Okay. 9 Mr. Rothstein owned other than Bova? 10 So in the tort practice group, though -- 10 A Nell, Bova had -- I believe Scott had an II you are familiar with, right -- how many 11 ownership interest with Tony BOVa in the Bova that 12 multi -million -dollar employment cases dad they 12 you're talking about, which was in the lobby of the 13 wattle during the time that you were employed at 13 office building. Tony Bova also had a restaurant here 14 RRA? 14 in Boca called Bova. And I don't know if Scott had an 15 A I don't know. 15 interest in that. If 0 Any? If 0 Did the firm have boxes at sporting events? I/ A I don't know. I didn't hoar of any. 17 A That, I don't know. No had -- I mean, I have II Q More you aware that Mr. Rothstein was -- IS used tickets, but not in a box. 19 let's not call it a Reail scheme -- but that he was 19 0 Not in a box? 30 using canes and was looking to generate moray to pay 30 A No. 31 off the plaintiffs ahead of time? 21 4) Have you heard that Hr. Rothstein had very 32 A After the fact. No. 32 expensive boxes at sporting events? 33 Q But not while it was happening? 33 MR. SCAROIA: Objection. Hearsay, 24 A No. 24 secondhand knowledge. 21 Q You know there aro twain aaaaa out there 31 THE WITNESS: not sure. I don't Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798356 I remember that. 81 I 83 overwhelming evidence. It doe➢n't even mean that you 2 BY NR. LINK: 2 have -- that it's more likely than not that your cane 3 Q You talked earlier about Bill Scharer. ) la a winner. It means that you have something. It 4 Re'➢ a friend of yours? 4 mean➢ that you have acme evidence. 5 A No, he's not a friend of nine. 5 Q In your plaintiffs practice, you have f 0 As a lawyer did you have respect for him? 4 brought -- filed complaints against different 3 A Yeah. I heard of Bill Scharer. Bill Scherer 1 defendants? 4 is a prominent Fort Lauderdale attorney who wa➢ a 0 A Sure. 3 client. His firm Conrad Scherer -- yeah, I've 1 Q And before you would file that complaint, 10 practiced here since 1975. And I had a number of cases 10 you would make sure that you had some information II in Port Laude , even though the offices I worked II before you would file it, right? 12 out of wore in Miami. And I have heard of the Conrad 12 A Right. 13 Scherer firm throughout my practice. II Q Would you note every single fact that 14 4) You said one of the things in your direct 14 existed at the time you filed it? Is examination that made you feel comfortable about is A No. It joining the Rothstein fire was that Bill Soberer was 14 Q Would you know maybe even half of all the 13 a client. 17 information you might learn through the course of the 14 A Right. Is case? It Q Because of his stellar reputation. It A No. 20 A Right. 20 So have is -- 0 what you really would noel to 21 Q Does he continue to have a stellar 21 like on a scale of ono to ton, what level of 22 reputation? 22 information would you need to have? 23 A Nell, he's -- there's some bad press about 23 A Ono. 24 him now -- occurring now. This year. 24 0 For probable cause? Ono? 25 Q How about in 2009? what wan hla reputation 25 A Yeah, you need to have sone sense that the 82 84 1 like? I client -- what the client is telling you is provable. 2 A In 2009? 3 0 oh-huh? 3 MR. SCAROLA: Co ahead. I didn't mean 4 A I don't know what his reputation was like in 4 to interrupt. 3 2009, specifically. 3 THE WITNESS: Some degree of proof. 4 Q 2009 is when Kr. Scherer filed a lawsuit 6 MR. SCAROLA: . going to voice an 7 against Scott Rothstein and others related to the 7 objection to the line of questioning to the S Foss,. scheme he wa➢ running. S extent that it call➢ for legal conclusion➢ 9 A Exactly. Scherer became probably the moat 9 that invade the province of the court. 10 noted attorney to sue the Rothstein firm. 10 MR. LINK: Okay, this is a discovery 11 0 on your knowledge of Mr. Scherer, do 11 deposition. I only objected to the form for 12 you believe he would have filed that lawsuit without 12 you, because we will be doing the objections 13 having probable cause to do so? 13 for trial, and I would ask that you do the 14 15 MR. SCAROLA: Objection. Hearsay, secondhand knowledge, predicate. 14 15 same thing. You don't need to make your trial objection➢ now. You know they're 14 THE WITNESS: I don't think that Bill If preserved. I? Scherer Mod that lawsuit without probable 11 MR. SCAROLA: Thank you. Ii cause. I think ho had probable cause. IS By I . LINK: 19 BY NR. LINK: 19 0 So, Hr. Berger, I may have steppe! on you 24 Q Can you tell the jury what the term 20 when you were speaking. But I think you said on a 21 probable cause means, please? 31 scale of one to ten it takes a ono; is that right? 22 A It means -- the probable cause means that 22 A Yes. 23 there's a -- there's -- this is not going to be very 23 Q When you were evaluating probable cause as 34 informative -- but a colorable claim. You have 24 a lawyer, were there Cases that you thought were 35 something there. Doesn't mean that you have 25 going to turn out better than they, in fact, did? Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798357 85 87 A Yes. 1 Q And probably ➢one casea turned out better 3 than you thought they might otherwise, right? 4 A If I was fortunate, yeah. 5 0 Somatimea. not aura I have ever had any of those. Not often, right? Usually ca➢es get 7 worse as they go along? 4 A Or at least no better than you thought they I. Were. 10 Q I got it. Did you look at the complaint, II that you have as Exhibit 1 In front of you that 12 Mr. Scherer filed In November 2009? It's called the 13 Razorback Complaint? II A 13 4Plaintiff'a Exhibit Norther 1 was marked 14 for identification.' 17 0 You have never seen that before? II A No. It 0 Would you do ma a favor and turn to page 12 20 of 147? 21 A Okay. 21 0 Why don't you just read paragraph 40 for a 23 minute, and I an going to ask you a fat questions. 24 A Okay. 25 Q If you look -- you know that this is the 1 4 S defendant's side, right? A Right. Q when you were a plaintiffs lawyer [or a client, were you aggressive and zealous for than? A Yea. Q when you represented a defendant, were you aggressive and zealous for then? A Yes. 1 0 Would it be your expectation that Is Mr. Epatein'a lawyers, on his behalf, would have been II 2.0.110.32 and aggressive in defending him? 12 MR. SCAROLA: Objection. Calls for 13 speculation. 14 THE WITNESS: Y02. Is BY KR. LINK: 14 Q You don't find anything inappropriate, 17 illegal about Hr. Epateln *2 lawyer being zealous and a aggressive, do you? it A No. 20 Q In fact, we've heard that your law firm -- 21 Mr. Edwards was aggressive and zealous, right? 21 A Yea. 23 0 And that's what you would expect him to do, 24 right? 25 A Right. lawsuit that Kr. Scherer filed, right, on behalf of 2 Razorback? 3 A Right. 4 Q And you ➢ee what Mr. Scherer alleges here 3 is D3, a potential investor, was shown 13 Bankers 4 Boxes of actual case files in Jana Doe. Do you see 7 that? A That's what it says. 0 Do you have any reason to suspect that 10 86 Mr. Scherer didn't write that down properly? A I don't know what Mr. Scherer investigated or 11 what the basis for him making this allegation is. 13 Q What I would like to know is, was there 14 ever a tine that Mr. Rothstein offered 5200 million dollars to settle the three cases being prosecuted by the law firm you gore a shareholder in? I/ A Not to my knowledge. IS Q Did Hr. Epstein, during the tine you were a 1/ shareholder at the Rothstein firm, ever offer 20 530 million for a pre-suit settlement? 31 A Not to my knowledge. 32 Q You mentioned earlier m direct that a 33 lawyer is duty-bound to be zealous, right? IS If 24 A Right. 23 Q That's on both on plaintiff's side and the 0 Just like you would expect if you were 2 defending Mr. Epstein. Would you have boon zealous 3 and aggressive in his defense? 4 A Yea. 10 88 Q Would you have -- strike that. I will coma back to it. What you observed during the tine that you were at Kr. Rothatein's firm, can you point to Oft0 thing that Mr. Epstein's lawyers did that you thought vas unethical? A No. 11 Q Can you point to one thing Hr. Epatein'a 13 14 15 If la lawyers did that you thought was illegal? A You aro talking about LA defending against -- O Yea. A -- the throe cases? O Yes, air. IS A No. 19 42 and are you familiar with the law firm that 20 was representing Mr. Epstein while you were involved? 21 A well, lack Goldberger and the Luttier firm, I 22 believe. 33 0 Bob Critton. 24 A Critton. 23 0 Dld you know Bob Critton? Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798358 89 91 A Causally. 2 0 What was Kr. Crltton's reputation in -- 3 A It's a good firm. I know the firm. 4 0 It'➢ an excellent law firm, correct? 5 A Yes. 6 0 Ara you aware of Mr. Critton's skills as a 7 lawyer that you -- from when you were either on the bench or Ln the practice of law? 9 A No, not really. I think I nay have -- I 10 think I mot him during the Ep➢tein deposition. But II that might have bean the first time I mot him. 11 0 Now about Kr. Goldberger, Jack Goldberger? 13 A Probably the first time I mat him, too. 14 0 Did you do any research on Mr. Crltton or 39 Mr. Goldberger? 26 A No. I didn't do research. 27 0 Was there anything Kr. Critton did during 30 his representation of Mr. Epstein that you thought 19 was illegal? 20 A No. 21 0 Unethical? 22 A No. 22 0 Improper? 14 A No. Si 0 Now about Kr. Goldberger? A I don't know. 2 Q How old was Jane Doe? A I don't know. 4 Q When did you first moot..? S A I don't know -- I don't know which ones I 4 mot. I can't recall. I would have known at the time. • And I don't know how many, either. I know there'➢ only 4 three. But I can't really recall if I met ono, two or s three. le Q So you didn't moot all of them? II A I may have. I may have. I just don't 12 recall. 13 Q Let's talk about III. for a minute. What 14 do you remember about her? 13 A Again, I don't know which ono was III. which 14 one was .314 laic'. 17 Q You were ■.'➢ lawyer, weren't you? 1➢ A Yes. It Q And you told u➢ that you evaluated the 20 financial, right, Narita of her case' what that case 2L was worth in compen➢atory damages. Isn't that what 22 you told the jury? 23 A Yea. 24 Q So I want to know what was it about III.'a 25 case -- I want to go through what the pros and the 2 3 4 4 10 Il 11 II 14 15 16 90 A No. O Do you know Mike Borman? A I've heard of him. O What have you heard of Mike Borman? A He has got a good reputation. O Mr. Berson was ono of Mr. Epstein'➢ lawyers at the time, right? A I don't know what his personal involvement was. His firm certainly represented Epstein. Q Can you tall ma of anything that Mr. Berman did that you aro aware of in representing Mr. Epstein that wan unethical? A No. O Illegal? A No. O Inappropriate? I/ A No. IS la 30 Q Do you know Joe Ackerman? No's at the Fowler White Elm. A No. 21 Q During the time that you were at the 22 Rothstein firm and representing E.M. and Sane 23 Doe, tell me how old was M.? 24 A I don't know. 25 Q How old was L.M.? 92 I con➢ were that caused you to be able to render your 2 opinion to this jury about the financial value of 3 that case. And the only way I know to that is to 4 talk about III. So let's talk generally, okay? Rave you 4 handled alleged sexual abuse cases? 7 MR. SCAROLA: I am going to object to • the predicate as, argunentive. Move that It 9 be stricken. 10 I have no objection to have you handled IL sexual abuse cases. 11 THE WITNESS: Could you -- 13 BY MR. LINK: 14 Q other than the throe cases that you were 15 involved with at the Rothstein firm, have you 14 represented clients, either plaintiffs or defendants, I7 involved in alleged sexual abuse? IS A Never a minor. And not the degree that was I9 involved hero. I represented several wem➢n -- adult 20 women LA an employment context who were touched, 21 seduced, not -- not in the sense of violently raped, 22 but talked into having sox with the boas. But -- so 23 that's -- verbally abused. But again, not minor -- 34 Q Was that before you started at the 25 Rothstein firm or aft➢r? Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798359 93 95 1 A Yes, before. 1 0 And what happens -- and things that they do 2 Q So before you took on the representation of 2 afterwards -- that they are touched -- is information 3 ., E.N. and Jane Dee, your only experience with ) you would evaluate in evaluating their case, wouldn't 4 alleged sexual abuse were three -- 4 you? 5 A No, not three. It might have been alx to 12 5 A Yes. 4 woman la that circumstance. 4 Q So their history before the event and after 7 0 Slx to 12 women in that circumstance. 7 the event la relevant to an evaluation of their a A Under an employment setting. a emotional damage. Would you agree with that? * Q And you represented the wcmen in that s A Yes. IC setting? Is Q And lf you were defending that cospany II A Right. II instead of the 6 to 12 women, would you have done all 12 Q And sued whoever the boss was, right? 12 you could to discovery what emotional stress they had 13 A The company. 13 been through before the incident? II 0 The corpany. II A Yea. is By the way, did you explain to those women 12 0 And would you have done all you could to 14 before you undertook their representation that their 14 discover what emotional di➢tre➢➢ they had been 17 life would be examined under a microscope? 17 through after the accident? IS A Yes. IS A Yea. IS 20 Q You know that before the case is filed, right, that that's going to happen? IS 20 Q How would that lapact the evaluation of the case? Tell the Jury how that information impacts al 22 A Right. Q }barn nothing surprising to you as a 21 22 when you're evaluating the financial worth of a case, please? 23 lawyer about that, is it? 23 A Nell, it has some significance. You try to 24 A No. 24 analogize it to a person that has a pre-existing 25 Q If you were defending whoever that company 2S physical injury. And the question la whether this 94 96 I was, would you have put the 6 to 12 wcman'a live! 1 particular incident perpetrated by this particular 2 under a microscope? 2 parson aggravated a pre-existing condition or didn't. 3 A Yea. 3 On the other hand, you take your victim as 4 0 That's your Job, right? 4 you find her. And if somebody has a pre-existing a A Right. 5 back condition and you drive your car into their car 4 7 Q To learn everything you can about their sexual history? 4 7 and you aggravate thole pre-existing back condition, you are still responsible for having done that. S A I don't know about that. Depends on the S So there is some relevance. It's a t case, what relevance it has. t question as to how much relevance it has for or 10 0 But it might have relevance, right? le against the person bringing the case. Sometimes 11 A Theoretically it might. ll if a -- well, it could have a positive effect, it 12 0 What if the only claim that was Deming -- 12 could have a negative effect, it could have no 13 was the claim you were making mental anguish or some 13 effect. 14 type of physical injury? 14 Same with the person's post-event IS A Mental anguish. It wasn't physical injury. IS experience: could have a positive effect, could have 14 Q In evaluating those cases, things that 14 a negative effect. It's a complicated ease-by-ease 11 happened before the unwanted touching by whoever I7 analy➢i!, and it's ➢orething that you would look le their boss vas, something you would look at in le into. 1* evaluating the lamaet of that event on their mental IS Q It absolutely is case-by-case, isn't it? 24 health? 20 A Yes. 21 A Yes. 21 Q Two people going through the exact sale 22 4) So what happened to them before the 22 unwanted sexual abuse could have a totally different 23 accident la relevant to determining what emotional 23 emotional reaction to it, right? 24 damages they nay have suffered. You agree with that? 24 A Right. 23 A Right. 23 Q If you lined up 10 manor, who -- or 12, like Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798360 97 99 1 you nay have represented, who had an unwanted sexual 1 experience, they may all have had different emotional 3 reaction➢ to it, correct? 4 A Correct. 5 Q And one of the things you try to evaluate on both the plaintiff's ➢ide and defense's side is / what impact that particular event had on that per➢on • front an emotional damage standpoint. Do you agree • with that? IC II A Right. Q And I know you don't remember whether you 12 met all three of the Epstein-related clients in 13 parson, but did you remember talking to them on the I4 phone? A I don't remember that, no. Q Tell Oa what you knew about the background 17 of before she mot Mr. Epstein? A I don't remember. I don't remember anything It specific about our particular clients in tome of their 20 backgrounds. 21 0 so when you wore at the Rothstein firm in 21 2009 and you wore working on these three camas, did 23 you sit down and do a list of the strengths and 24 weaknesses of each of these individual cases? 25 A No, I didn't do that. 1 4 S 7 agreement unsealed. That's something I spent a lot of time on. I attended, I believe, at leant two hearings In front of Judge Colbath -- • To get that unsealed? A -- to get that unsealed. • What wan the purpose in getting that • unsealed? • A So that it could be used as evidence because IC It was sealed. I believe we already had a copy of it, 11 but it wasn't something that we could disclose because 12 it had boon sealed. 13 Q Disclosed to whom? Who did you want to 14 disclose it to? 15 A To a jury or to third parties for use In 14 investigation. I, Q What was it about the non-prosecution 14 agreement that a third party would need to do an 1* Investigation related to these three folks? 20 A I don't know the specific point. I know that 21 we wanted to get the document unsealed. It had 22 Information in it that was important to us. 23 Q Did you want it for press purposes? 24 A No, not for press purposes. 25 Q Aro you aware that Mr. Edwards communicated 98 Did you do an evaluation of each of the 2 throe canon at that time of what you thought the 3 settlement value was? • A No. s Q Did you do an evaluation for each of the • throe individual canon to determine from a jury 7 standpoint how much each of them individually might • be awarded? 9 A No. 10 Q And when you wore doing -- it sound➢ like 11 your role in those cases may have been limited. Was 12 it? 13 A Yes. 14 Q How much time during 2009 while those three 15 folks were clients of the Rothstein firm did you II spend on M.'s case? 17 A I can't quantify by the number of hours that IS I spent on the cases. I didn't work on them Cull-time 19 and I didn't work on them every day. There were 20 certain specific things that I did. Q You attended a couple of hearings? 32 A Yeah, I attended a couple of discovery 31 23 hearings, and I also -- I was also involved -- and it 24 was my relpon➢ibility to appear in front of the 25 criminal court to try to get the non-prosecution 100 with the press while ho wan at the Rothstein firm 2 about the Epstein cases? 3 MR. SCAROLA: Objection. Assuan facts • not in evidence. s THE WITNESS: Yes, I believe so. • BY I . LINK: 7 0 Were you aware that one of those clients of • the Rothstein firm actually did a TY interview? A I don't recall that. 10 0 An you sit hero, you don't remember 11 12 13 14 15 14 IS 11 Mr. Edwards having ono of his clients on an NBC interview? A No, I don't remember that. Q Dld he consult -- did Mr. Edwards consult with you before he would talk to the press about the Epstein cases. A No. Q Dld you over talk to the press about the Epstein cases? 30 A Well, yes, when I -- I think two of the 21 hearing➢ that I attended, when I loft the courtroom the 22 pre➢➢ was there out in the corridor, so reporters asked 33 to questions on Camera. 24 Q You are not required to answer them, aro 35 you? Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798361 101 103 A No. 2 Q So what made you decide that you wanted to 3 answer the reporters' questions akout the Epstein 4 cases? 5 A I was an➢wering que➢tion➢. 4 Q Knowing that it was going to be in the 7 press? 4 A Yes. • Can you toll ma, how old was III. when she la met Mr. Epstein? 11 A I don't recall what her ago was, other than 12 she was a minor. 13 0 Were you aware of mother Doing a 14 prostitute and III. working with her before ➢he met 13 Mr. Epstein? 14 A I seen to recall that ono of the young woman 17 we represented, her mother was a prostitute. I don't Is know which one it was. And I had never heard before I* you mentioned it just now that there was a statement 20 that she worked with her mother as a prostitute, no. 2l Q Were you aware that all three of the 22 Rothstein clients were paid for every tine they 23 provided Mr. Epstein with a massage? 24 A Not as specific as you say it. I knew 25 generally that was part of the allegations that they A No, no. They had already been brought into 2 the case -- into the firm. I was not doing intake. Wo already had the ca➢es. 4 Q So whether the➢e cases financially were weak or ➢trong, you didn't do any work to reach an 4 opinion; is that true? 7 A When you aay I didn't do any work, I did O reach an opinion. If you were a young -- if I • represented an underage young girl who was trolled by a 10 billionaire's assistant and selected because she didn't 11 have any tattoos and she was white and she was young 12 and attractive and ➢he was lured by money to go to the 13 guy's house and help him masturbate, I don't need to 14 know a whole lot more to tell me that that's a 13 significant case. 14 Q So were you aware that III. actually 17 brought E.N. to Mr. Epsteln's house to be paid fast la money to give him a manage? A Well -- 20 0 Did you know that, air? 21 A I don't know whether what you said is true, 22 and I hadn't hoard it before or that I can recall. 23 Q Dld you know that ■. brought Jane Dos to 24 Mr. Epstein's house and that III. was paid for doing 25 that? 102 I were paid money, or given money by either -- personally 2 by Epstein or by one of hla aaaaa tans. I couldn't say 3 that I heard that it we­ every time, but that it was 4 all three. • Q Doe➢ it surprise you that all three of have • testified that every single tine they wont to see 7 Mr. Epstein to give him a massage they were paid? S A Would it surpriae me? I have no opinion t about that when it -- If it would surprise ma. 10 Q Were aware in 2009 that all throe of the Il Rothstein clients solicited other people co cone 12 provide massages to Mr. Epstein and were paid a 13 solicitation fee? 14 A So these minor girls that you are saying 15 solicited other minor girls? Q Yea, and brought then to Mr. Ecutein'a house, told then what they were going to do, and were paid for bringing them? Did you know that? 14 IS 19 A No, I never heard of that. 20 Q Never heard of that, okay. 31 Did you read statement to the FBI 22 as part of your evaluation -- let no go back for a 23 second. 34 Did you evaluate these cases from a 23 financial standpoint at all? 104 A I don't know that that happened. I nay have 2 heard that as part of the case. I don't recall that 3 • 4) Are those all facts that you would take 5 Into consideration in evaluation of the strengths and • weaknesses of the cases from a financial standpoint? A If I was working the case -- S 0 Yea. A -- and I -- I would want to know If that 10 haft:ono!. Q Right. 12 A What significance it would have, not 13 sure. 14 0 But you would take it Into consideration, 15 wouldn't you? 14 A I would take it into consideration. To no If IS IS 30 31 what it does is It enhances the reprehensible nature of what Epstein did, that he would have young woman do this typo of thing, because legally they couldn't be consenting to what they were doing. 23 A So it doesn't -- to me it does not negatively 23 affect the economic value of the case or lessen the 24 damage to the young women if they did what you say. 35 Q So if they had already been involved in Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798362 i 105 prostitution, would that impact your view of this I 107 not sitting here a➢ a judge, are you? 2 reprehensible conduct of masturbating in front of 2 MR. SCAROLA: Objection, argumentative. 3 them? 3 THE WITNESS: Of course, no. 4 A You are talking about children, so no. 4 BY I . LINK: 5 In fact, it'➢ Worse. You're dealing with 5 Q You haven't been a judg➢ for over 10 year➢, 4 troubled, damaged, young -- if what you aay i➢ 4 right? / true and the girl -- let'➢ assume that the girl was 7 A Of course. That'➢ correct. You are asking • a paid prostitute a➢ a minor and Epstein Caro➢ along a my opinion. • and he does what he doe➢ to than, it's even worse. , Q And asking about while you Were 10 Q Masturbating In front of them? la amployof at the Rothstein firm. ?hat'➢ what 11 A It'➢ oven Worse, because he'➢ taking a II interested in. interested in these three folk➢. 12 damaged child and Making her even more damaged. 12 And so is it your opinion that if you are a 13 Q You didn't meet with any of these three to 13 17-year-old girl involved in prostitution that you 14 evaluate whether they wore more damaged, did you? I4 cannot to hold accountable for the deci➢ions you II A Are you asking ne hypothetically whether la make? I➢ that your to➢timony? 14 these things would be thing➢ that you would take into 14 MR. SCAROLA: objection, argumentative. I/ consideration? 17 THE WITNESS: Kell, you can, but not in IS 0 Yea. la this context. These young woman wore 19 A And ■ pointing out, yeah, they would be, Is manipulated by this guy and he trot 20 and they could ➢Mane the case a➢ opposed to detract 20 advantage of th➢n, and they can't be hold 21 from it. 21 responsible for that. 22 0 Could b➢ a &optima, could b➢ a positive. 22 And the fact that they have a past, as 23 A Could b➢ a negativ➢, could b➢ a positive. 2) you described it, nay -- nay make what he 24 Q D➢pends on what spin you put on it. 24 did even ➢ore reprehensible. 25 MR. SCAROLA: Object to the form of the 25 106 108 1 qu➢ltlon. I BY I . LINK: 2 THE WITNESS: I don't 14110W about a 2 Q Or make it 3 spin. R➢ality doesn't have a ➢pin. 3 A May make it less. 4 BY NR. LINK: 4 Q But it's a subjective evaluation, isn't it? a 0 I agree with that. So ■ asking you -- s A By a lawyer, or course. It's subjective and 4 it's your testimony -- 4 you try to build objectiv➢ facts. You hire expert➢, 1 A And the truth doesn't have a spin. / you hire a psychologist to review the people and you 5 0 IMI a➢king if it's your opinion that if you S build this a➢ a factual case. 9 are sexually active, a prostitute, your mother i➢ a • 0 And you are exactly right. And the reason 10 prostitute, you have boon homeless, your parents are 10 I ➢aid subjective i➢ because you could take 10 really Ii drug addicts, that the trawna of watching an older II competent lawyers t0 evaluate each of these throe 12 man masturbate in front of you when you are getting 12 case➢ and all 10 may coma up with a different opinion 13 paid and voluntarily come back dozens or time➢ is 13 of whether the ca➢e➢ are strong, median of weak. Can Id more aggravating than all of the pr➢condition➢? 14 you agree with that? 15 MR. SCAROLA: Object to the form of the 15 MR. SCAROLA: Objection to form. 14 qua:Miro. 14 THE WITNESS: No, I don't agree with 11 THE WITNESS: Fir➢t of all they 17 it, becau➢e if you have a case where a young IS can't -- under the law they are not IS woman, regardle➢s Of the Circumstances, is 19 voluntarily doing anything. The law doesn't 19 brought into a billionaire's hone by 20 recognize that. 20 herself, by herself, not with her parent➢' 21 You know, I sat as a judge on capital 21 knowledge, but by herself, one-on-one, 22 rape case➢ where people tried to defend and 22 there's nothing about her pa➢t that would 23 said consent. There is no con➢➢nt. 23 make that a bad case. 24 BY LINK: 24 BY KR. LINK: 25 0 Thi➢ isn't a capital rape case and you are 25 0 I didn't ➢ay it was a bad case. I said in Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798363 109 111 evaluating the economic damages, would 10 lawyer➢ in 2 evaluating the fact➢, could they reach reasonably 3 different opinion about the dollar value of the 4 ca➢e? A It would just be how many more zero➢ you 4 would add to the case -- to the value of case. That's 7 all. Q That'➢ your opinion of it, right? A That'➢ my opinion, exactly. 10 Q By the way, are you always right In your II opinion? MR. SCAAOLA: Objection, argmmentive. II THE WITNESS: No, not always right in my opinion. Is BY MR. LINK: 14 Q You mentioned when you Nero a trial court 17 judge you were rever➢ed a few time➢. II A More than a few times. IS Q How many tire➢ wore you reversed? 20 A I don't know. I made a lot of deci➢ion➢ and 21 22 a lot of then were affirmed and a lot of them wore appealed. I wa➢ reversed a number of times. 23 0 Rough gue➢➢? 24 A I Couldn't tell you. I couldn't tell you how 2S many [limos. Nurik or Rothstein -- did they feel bullied or 2 threatened by Epstein lawyer➢? MR. SCAAOLA: Objection, predicate. 4 THE WITNESS: You are assuming that Nurik and Rothstein worked a➢ attorney➢ on 4 these cases. I don't know that they did. Adler was tangentially involved. I ▪ don't think that anybody was bullied by • Epstein. 14 BY MR. LINK: 11 Q And do you think any quality of the 12 representation of the three clients while at 13 Roth➢tein wa➢ impacted by the aggre➢sive, zealous 14 behavior of Mr. Epstein'➢ lawyers? 15 A No. 14 Q Is Ws. Edward➢ a tough, hard-nosed 17 lawyer? A Yeah. If 0 Tried criminal c aaaa ? 20 A Noll, I a➢➢me so. You know, I -- until -- 21 until you mentioned it, I forgot that Brad had been a 22 prosecutor. I didn't really remember that until you 23 mentioned it. 24 Q Ho wa➢ a prosecutor in the Broward State 2S Attorney'➢ Office and told us ho prosecuted murderers 110 O Ton? 2 A More than 10. 3 O One hundred? 4 A No, not 100. Q S0013Where between 10 and 100 tine➢? 4 A I would aay between -- maybe 10 and 20, 30 7 tides. ➢seething like that. Twenty, 30. Something • like that. 9 10 11 12 Q Somewhere in that range. Okay. Where three people that evaluated your deci➢ion decided that -- for whatever reason to reverse your deci➢ion, right? 13 A Yeah. 14 IS 14 17 IS Q Old you over feel threatened and bullied by Mr. Boatman's lawyer➢? A No. O Old 14r. Edwards come to you and aay I feel threatened and bullied by Mr. Epateln's lawyer➢? 19 A No. 20 Q Do you think Mr. Edwards, who had been a 21 former criminal prosecutor, wa➢ bullied and 22 threatened by Hr. Ep➢tein'a lawyers? 23 A No. 24 0 Were any of the lawyers at the Roth➢tein 25 flea that were working on thi➢ ca➢e -- Mr. Adler or 112 and hard criminal➢? 2 A Okay. 3 Q That's not a job for the weak of heart, is 4 it? A No. 4 Q Was there any part of your evaluation of 7 Mr. Edwards that made you think that he was afraid of S Mr. Epstein and hi➢ lawyer➢? 9 A No. 10 MR. SCAAOLA: Objection, compound. IL BY MR. LINK: 12 0 When you were working on the throe Epstein 13 cases while you were at the Rothstein firm, wore you 14 aware that III. gave a ➢worn ➢tatement with immunity IS to the FBI? 14 A No. Il IS 0 What'➢ the reason for the FBI to give iMMUnity when they take a ➢worn statement from It somebody? 30 MR. SCAAOLA: Objection. No predicate. 31 THE WITNESS: I could only talk in 22 general a➢ to -- 23 BY MR. LINK: 24 0 Toll the jury in general, 33 A I would a➢➢we that a police agency or a Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798364 113 115 prosecutor would give ismiunity. Immunity means 1 basically a promise not to prosecute the person in 3 exchange for information. 4 0 In telling the truth? A In telling the truth. 4 Q so there's a premium on telling the truth / to keep your innualty. You agree with that? • A Noll, a condition for the isownity to stick, • I would anima, would be that you've told the truth. 10 Q Which would mean that if you were providing 11 a sworn ➢tatemnt to the FBI to gat isownity you 12 should tell the truth? 13 A Yeah. II Q Did you ever review the transcript of II taped ➢tatemnt that wan given to the FBI in 14 April of 2001? If A No. I don't believe I ever read it. is Q Did you ever -- did anybody ever tell you la that there wore significant differences between the 20 statement given by before she was repre➢ented by the Rothstein firm and what her testimony was after 22 being represented by the Roth➢tein firm? 23 MR. SCATtOLA: objection. Calla for 24 hearsay, secondhand knowledge, argumentive. 25 THE WITNESS: I think I heard that. the clients you wore representing gave FBI sworn 1 testimony and then changed her story at her deposition, did you go nay, Let me look and ➢ee 4 what's going on, let ma compare then? S A I think that it was presented in writing, so 4 when you say did I go and compare it, I think that, not only was It stated to the judge, but beforehand in soma a written paper, Hr. battier or Mr. Goldberger had out * the two ➢tatemnts ➢ide by side, so I compared it in la that sense. ll I don't have a particular recollection of 12 doing it. I generally remember that there was 13 statement by counsel that one of the clients had 14 15 14 I, a I, 20 21 21 23 24 25 said something to the FBI that was different than what she said at the time. O I understand. A So generally what you are saying El familiar with. Q And I understand that there's sane snippets of it in the papers they filed. What asking is different. Did you, once you had that information, go back, pull the two transcripts and look at them personally to evaluate the Inconsistencies in her under -oath te➢timony. A No, I didn't pull the Whet* -- no, I didn't 114 BY NB. LINK: 2 0 Who told you that? 3 A I think I hoard it, at least, by either 4 Mr. Critton or Hr. Goldberger at one of the discovery • hearings. 4 S 10 II 12 13 14 IS If 11 O And they were informing the court? A Yes. Q And you were there as a participant for ono of the Rothstein clients, and they were describing that gave a sworn statement with Immunity and now at the Rothstein firm her testimony has changed. Did you take that information, go back and compare them to see if what they said is accurate? MR. SCAROI.A: Objection. Calla for hearsay, secondhand knowledge, improper predicate. THE WITNESS: They didn't couch it in IS terms of now that ➢he's with the Rothstein 19 firm, okay. I think it was couched in terms 20 of she said one thing one time and now ➢he's 21 saying something else. 22 And now you're asking ma if I actually 23 went and compared it side by side. 24 BY HR. LINK: 25 Q Once you heard to open court that ono of pull the whole transcripts to do that, no. 2 0 You mentioned Ns. tutelar, Mark tattler. 3 Ha was one of the lawyers at Ns. Crleton's firm? 4 A Yes. 5 Q You aro familiar with Mark 'Antler? 4 A Yes, I know Nark LUttier. 7 Q What kind of reputation does he have? S A He'➢ a very good attorney. 9 Q Was there anything that Hr. battier did 10 IL 11 13 14 IS 116 during his representation of Epstein that you thought was unethical? A No. O Illegal? A No. O Inappropriate in any way? If A No. If Q Are you aware of their firm, the Berman, IS Critton 4 tattler law firm were the lawyers that were 19 representing Ns. Epstein at the time that the lawsuit 20 against Hr. Rothstein, III. and Hr. Edwards wan 21 filed? 22 A No. I didn't know who wan representing 23 Mr. Epstein at that time. 24 Q Mr. Berger, wore you involved In the motion 25 to set a bond for $15 million based on the illegal Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798365 2 3 4 f 7 4 a 10 11 12 13 13 17 IS 20 21 22 23 24 25 117 transfer of a➢aota by Mr. Epstein that waa filed with Judge Marra? A No. I never hoard of that. Q Did you review the order entered by Judge Marra where he found that there wa➢ no evidence to support the filing of that motion by Mr. Edwards? A No. MR. SCAAOLA: I am going to object to the form of the question. It assumes facts not in evidence. BY I . LINK: Are you familiar with Judge Marra? A Oh, I know Judge Marra. What is his reputation? A Very good judge. Excellent juri➢, right? A Yeah. Q Would it surprise you that Mr. Edwards and the Rothstein firm would file such a motion that Judge Marra would find had no merit? A I don't even know the context. I don't know anything about what you're talking about. I didn't know that such a motion was filed. I will show that to you in a minute. Take a look at that. But you weren't involved in drafting 2 4 4 IC II ix 13 14 13 14 17 Is Is 20 21 22 23 24 25 119 about earlier at the Critton the Borman, Critton Luttler firm, right? A Correct, and Michael Pike. 0 Do you know Michael Pike? A Yeah. Q What is Michael Pike's reputation in the community? A No is a good attorney. Q Did Michael Pike do anything in his representation of Kr. Epstein you thought was illegal? A No. Q Unethical? A No. 0 Inappropriate? A No. Nave you ever seen anything in looking back at the representation of Mr. Epstein by Berman, Critton a tutelar and their lawyers that causes you to think that something they did in that representation was illegal? A No. Q Unethical? A No. Q You mentioned during your direct I 118 that motion or arguing it in any way? A No. 2 120 examination that you thought it would to malpractice not to investigate every other instance of alleged 3 MR. LINK: Can we mark that as number 3 wrongful conduct by Mr. Epstein. Do you remember three, please? 4 saying that? (Plaintiff's Exhibit Number 3 was marked a A Yea. 4 for identification.' Q Is it your testimony that while you wore 7 BY MR. LINK: 1 representing the three plaintiffs and Rothstein that S 0 Wo are looking at Plaintiff's Exhibit S every single incident of potential wrongful conduct Member 3, the original complaint filed by Mr. Epstein / by Kr. Epstein wan investigated by your firm? 10 against Scott Roth➢tein, Bradley Edwards and ■. 10 A I don't know that. 11 Nave you ever seen this complaint? IL Q so if they didn't do that, would you agree 12 A Yes, I saw it. 12 that that was committing malpractice? 13 0 When did you see it? 13 A I think that'➢ too speculative a question to 14 A I saw it the other day. Mr. Scarola sent mo 14 ask. 15 a copy of it. 15 0 You remember testifying that it was If Q Had you seen it before the other day? If Malpractice not to investigate every other instance 17 A No. I? Of wrongful activity by Kr. Epstein? IS Q Did Mr. Edward➢ ever call you to talk to IS MR. SCAAOLA: Excuse me. MI going to 19 you about this complaint? IS object. No proper predicate. Misstate➢ 20 A No. 30 prior testimony. 21 Q rake a look -- I asked you if you know who 21 BY NR. LINK: 22 filed it. Will you just take a look and sea the 22 Q Do you remomber that testimony, air? 23 lawyer that signed this complaint when it was filed? 23 A Con aaaaa y, yeah. I said -- yeah. 24 A Robert Critton. 24 0 You said that, right? 23 Q And that'➢ NC. Critton We were talking 23 A Yes. Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798366 121 123 I Q And ao that would moan -- for example, 1 when you aay -- it wasn't during the time of the 2 Mr. Scarola's firm represented a client against 2 Rothstein -- Brad Edward➢ wasn't working for the ) Mr. Epstein, right? ) Rothstein firm, I don't believe, when this happened. 4 A Correct. 4 Q When he settled? 5 Q So if Mr. Scarola's firm, before settling 5 A When he settled. S that ease, did not investigate every other incident 4 Q Correct, he was not. 1 of alleged wrongdoing by Hr. Epstein, you would deem 7 And you didn't get any part of the • that as malpractice, wouldn't you? • financial arrangement, did you, sir? s A Not if enough money wan put on the table, s A No. IC they wouldn't need to do it. Ici Q We were talking about this duty to II Q Oh. Whoa, whoa, whoa. So I can avoid II investigate. And ono of the things that you said 12 malpractice and the fulfillment of my ethical 12 that caught my attention was that I don't have to 13 obligations by getting enough money for the client? 13 fulfill thin duty to investigate and it wouldn't be 14 A If the client -- once they accept the 14 malpractice if I settled for an amount that the 15 settlement, then there'➢ -- the case is over. 15 client approved. Is that your sworn testimony? 14 0 I got lt. But during that window between 14 A Yeah. 17 when the case is filed and when it's nettled is when I7 Q So, you made the statement that your law Is you aro supposed to be doing thin investigation, Is firm had a joint prosecution agreement with other law Is right? It firms. Old you ever see that agreement? 20 A Correct. 20 A I don't recall -- I can't recall seeing it. 21 0 You are not telling this jury that I can 21 I recall hearing of it. 22 discharge my ethical obligations by simply getting 22 Q Was there a written joint representation 2) money for a client, are you? 2) agreement? 24 A Well, not sure I know what you mean. I 24 A I don't know if it was written. 25 moan, if a client is suing, if a client has a 25 0 Did you ask to sea it? 122 124 1 particular dollar amount that she thinks will make her i A No. 2 whole for what he has done to her, and Kr. Epstein 2 0 You said you attended a meeting, right, of 3 offered that amount, then the client has achieved their 3 tamers from other ['arm? 4 purpose. 4 A I remoter -- and it's very vague. I a 0 Let me a➢k you this. Since you -- 5 remember -- I think it was the first time I met Adam 4 MR. SCAROLA: . sorry. I don't 4 Horowitz. And I think I met Spencer Kuvin. I just 7 believe the witness has finished his 7 can't place exactly where it wan. It wasn't at the 8 response. S Rothstein office. And I just don't -- it was somewhere 1 THE WITNESS: And wo keep talking about t in Went Palm Beach -- at a law firm in West Palm. 10 money. But a➢ attorneys always tell jurors, 10 Q So the joint prosecution agreement concept II this is the only way the system can IL la that you can share information with each other and 12 compensate or make somebody whole. It's 12 not waive your attorney-client or work product I) financial. So It does toll down to that. 1) privilege, right? 14 BY KR. LINK: 14 A That's one of them -- ono of the features of 15 0 I got it. 15 it, yeah. The other would to that you are going to If So what you said is if the three If cooperate. 1/ plaintiffs represented by the Rothstein firm made a 17 0 sure. You are going to share information. IS decision that the money they were offered would IS A Right. It compensate them fairly, then they have the right to 19 Q plaintiffs lawyers do that all the time in 24 take it and to done, right? 24 multiple cases, don't they? 21 A Correct. 21 A Yea. 22 Q And that'➢ what happened here, correct? 22 0 That's not uncommon? 23 A I have heard that there wan a settlement. I 23 A No. 24 wasn't involved personally, so I don't have personal 24 Q And defense lawyers do that, right? 25 knowledge of it. I heard that's what happened. And 21 A Correct. Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798367 125 127 1 3 4 5 4 14 II 12 12 II is 14 I, IS It 20 21 21 23 24 25 Q So I heard you say on direct examination that Brad Edwards wa➢ the lead lawyer for thin group of distinguish lawyers that had cases against Mr. Epstein. Ia that true? MR. SCAROLA: objection. No proper predicate. THE WITNESS: not sure I said that. If I did I made a mistake. Brad -- you are dealing with none very heavy-weight people. Brad wan an excellent lawyer, but ho didn't have the reputation of Bob iceoCaberg. I didn't -- BY NR. LINK: O I didn't moan to interrupt you. A I didn't mean to nay that Brad lad the collective group of attorney➢. within our firm he wan the lead attorney. Q He wan a lead lawyer at the Rothstein firm, right? A Correct. Q He wan not the lead lawyer for Bob Josefaborg, wa➢ he? A No, he wasn't. When you nay lead, he didn't have a leadership role. First of all, I didn't attend -- I can only recall -- and that's only vague -- 1 developing their case? Do you believe that, sir? 1 MR. SCAROLA: objection. Compound, speculative and argunentivo. 4 THE WITNESS: You aro proposing an extreme example. I could see how an 4 attorney -- Bob Sonefaborg, Ted Leopold, Sid 7 Garcia, Adam Horowitz, Spencer Kuvin, any of ▪ them could nay, You know, Brad, you go ahead 1 and pursue this particular line of Inquiry. 10 We will rely on you to do that. That's not II out of the question. 12 BY RR. LINK: 13 Q It happens all the time. II A If you are saying that they turned everything 15 over to Brad, ■ not saying that that happened, but I 14 could see the particular lino of investigation could 17 have boon delegated co Brad. is 0 Was it? is A I don't know. I don't know it it wan. I 20 know that there van coononleatlen among Brad and these 21 other lawyers, because I heard of it secondhand. I 21 didn't directly participate in much of it. I have 23 very, very vague recollections. 24 I know -- I think I talked to Josernberg 25 once or twice, and the nano would be with regard to 126 I one 'meting with other counsel. Bob Sonefaberg wan not 2 at that meeting. 3 0 So you've known Bob Josefaborg for a long 4 time, right? 5 A Yeah. 4 Q He's ono of the top trial lawyers in our 7 state, isn't he? S A Yes. Q Ho'n a dean of the trial bar, right? 10 A Yes. Il 0 You agree with that? 11 A Yeah. 13 0 And at the time, Mr. Edwards wan about a 14 six-year lawyer, right? 15 A I don't know. I don't know when Brad started 14 practicing. He wasn't as senior as Bob Josefsborg. 17 O Probably none of us are. IS A Not ne. It Q Right. Re either. I think not even 20 probably Hr. Scarola. 21 So do you really think Bob Sosefsberg in 22 his head in representing his clients said, I an 22 going to let Hr. Edwards, thin young lawyer, handle 24 the representation of my clients and gather 23 information for them and be respm➢ible for 128 Kuvin, Leopold, Garcia, Horowitz, and I do remomber 2 this meeting. 4 O To share information? A To share information and to strateglze, sure. Did any or these lawyer➢ ask you, 4 Mr. Berger, to do anything on their behalf? 5 Mr. 30203[2130r07 Sid Garcia? S A No, I don't member that. I know that we 10 IL 11 13 14 15 14 17 IS IS 30 31 32 took the lead, meaning Brad and I, and ma, apoclflcally, In trying to got the non-prosecution agreement unsealed. Whether or not that wan ➢omething that was asked of ua collectively by the group or we just went ahead and did it, I don't remember that. I don't remember anybody also making that effort but myself. Actually, I wan Cho ono that filed the papers and argued it. Q And you don't remember Bob Sosefaberg calling you and asking you to do that? A No. • You don't [member Adam Horowitz calling you and asking you to do that? 23 A No. 24 0 Or Mr. Scarola? 25 A No. I don't remember that. Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798368 129 131 0 2 case? Did you over talk to Mr. Scarola about his 3 A No. 4 0 Obviously Kr. Scarola didn't ask you to do • anything to help hla client. 6 A I don't remember that. Did you swat any of the other lawyers who • had pending cases with clients in order to evaluate 9 their situation? 10 A The clients, no. 11 12 13 O Did you review any of the discovery that was being filed by the other law firms? A You mean the discovery requests? 14 Q Discovery requests and information coming 35 ln. 36 A I don't natant:or that. 1? 0 Did you participate in negotiating 28 Mr. Scarola'a settlement for his client? 19 A No. 20 0 Did you participate in negotiating any of II the non-Rothstein clients' settlement discussions? 22 A No. 22 0 Are you aware of the cases that wore 24 settled that were unrelated to the Rothstein three 26 clients? 1 notes and son if wo can wrap up. 2 THE VIDEOGRARMER: Going off the record at 12:18 III. 4 4A recess was had.) S THE VIDEOGRAPHER: Going back on the 4 record. The tine is 12:21 III. REDIRECT EXAMINATION O BY KR. SCAROLO: 1 Q Hr. Berger, I want to start where opposing 50 counsel left off talking about the scope of the 11 investigation necessary with regard to other 12 circumstances where Jeffrey Epstein was involved in 13 the sexual abuse of children. 4 When you spoke about the need to 13 investigate other Epstein -- other incidents of 14 Epetein'➢ abuse of children, is it necessary to 17 evaluate how much damage was done to child victims 14 who wore not your clients? Is A No. Not -- certainly not In the sane detail. 20 Q What la it that you aro focusing on when 21 you aro investigating other incidents of the sexual 22 abuse of children by Jeffrey Epstein? 23 A Well, you are not specifically looking to how 24 damaged that other victim was. what you aro looking at 25 are the circumstances -- Cho objective circumstances of 130 A Well, I wan -- just in general. I think 2 dosefaberg settled a number of thank. There wore a 3 number that wore settled, but I only -- ■ not really 4 aura how I learned of this information. I didn't 3 participate in them. 4 Q Was the Rothstein firm asked to participate 7 in negotiating settlements for clients they didn't • represent? 9 A No. 10 IL 12 13 14 IS If O Were you aware that Mr. Joaefsberg settled multiple cases without filing them? A I heard that ho did, yea. Q Did he consult with you and 14r. Edwards about whether he should settle the case or file suit? A No, he didn't consult with us about that, no. O Did he consult with you about whether the 17 money being offered by 14r. Edwards to his client was 18 a fair nuaber? 19 A No. 30 Q Did you discuss with Mr. Josefsberg or any 21 other lawyers the differences in each of the clients' 22 mental statamanta at the time of the alleged abuse? 33 A No. 24 MR. LINK: Why don't we take a couple 21 minute -- quick break, let ma go through my 132 the abuse. So was it -- how was it done? What was the 2 method? Did it even occur? 3 Even if it wasn't a similar setting or a 4 similar technique, if it happened it's relevant to 5 proving that it had happened to your client. 4 The whole point is to prove that it / happened to your client, Donau.* it happened to • other people. And the circumstances, if they can be • similar, that helps as wall. 10 II • You spoke about modus operandi. What does that Latin phrase mean? 12 A That means how did the parson do it. What 13 was the method of operation. 14 And in particular hare, you aro dealing, IS in soma respect, with a one-on-one situation. It'➢ 14 conceivable that Epstein could say that although he Il was present -- In the presence of a young woman, our IS clients, nothing bad over happened, and it would be 19 a he-said-oho-said. So it would to important to 20 have evidence of other abuse to discredit that 21 nothing happened. 22 So modus operandi would be how was it 33 24 31 done; what was the method of operation that the person used. Q Of what significance, if any, would it be Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798369 133 135 if it were determined that Epstola's method of abuse 2 was to intentionally target disadvantaged children as 3 young as 12 and 13 years of age to entice them with 4 substantial sums of money, not only to engage in • sexual conduct with Jeffrey Epstein and to submit to mo aaaaa tiona by Jeffrey Epstein, but also to go out 7 and bring other similarly situated, similar ▪ circumstanced individuals to Epstein who would be * willing to endure the sane abuse at the same age? 14 Would that have any significance? II MR. LINK: Form, compound, speculative, 12 no facts in evidence. Maybe the NhOla 13 evidence code. 1 THE NIT HESS: Nell, lb would 111303/ a 13 pattern that that's what he did. 14 If it can be proven that he did it to 17 other children and your client is testifying that he did the sane thing to her, it Is corroborates your client's testimony. 20 By NB. SCAROU: 21 Q Are you familiar with the concept of an 22 advice of counsel defense? 23 A Yea. 24 Q Describe, for the benefit of the jury, if 25 you would, please, what an advise of counsel defense 1 MR. LINK: Joseph Ackerman? Joe 2 Ackerman? MR. SCAROLA: Yes. 4 THE WITNESS: Yes. S BY NE. SCARCNA: 4 Q And you acknowledged that as far as you ▪ were concerned, those were lawyers who had good ▪ reputations and they didn't do anything unethical, * improper or unreasonable in their representation of 14 Jeffrey Epstein, correct? 11 THE WITNESS: Correct. 12 BY NR. LINK: 13 Q It was then pointed out that one or sore of 14 those lawyers was involved in bringing the suit la against Bradley Edwards, correct? 16 A Correct. 17 Q In order for Jeffrey Epstein to even 14 suggest that he has the protection of having been 11 represented by good, ethical lawyers in filing that 20 lawsuit, Jeffrey Epstein would need to waive al attorney-client privilege so that we could take the 22 depositions of those lawyers and find out what it was 23 that Jeffrey Epstein told them that convinced them it 24 was proper to sue Brad Edwards, right? 25 MR. LINK: Ctject to the form. I is. 2 134 A It mane that you can't hold no liable for 3 what I did because I was acting on the advice of my 4 attorney. s Q In order to raise an advice of counsel 4 defense, is it necessary for the individual who is 7 seeking the protection of advice of counsel to waive • the attorney-client privilege so that the jury la • able to evaluate whether the counsel was giving 10 advice on the basis of truthful information or on the II peals of lies? 12 13 14 15 If 11 A I believe that the Florida Evidence Code says that if you -- that you can't assert the attorney-client privilege when -- to prove your position -- it's relevant as to what was stated between you and your attorney. • So you were asked queationa about the IS reputation and your observations of the conduct of 15 Mr. Critton, Ns. Goldberger, Mr. battier, Mr. Berman 20 and Mr. Pike, all of when were involved at some point 21 In time in the representation of Jeffrey Epstein, 32 Correct? 33 A Yea. 24 Q I think I missed Mr. Ackerman on that list. 23 Mr. Ackerman as well. 136 I BY NE. SCAROLA: 2 Q Lot me restate the question. 3 what extent, if any, would it be necessary 4 for ua to find out what those lawyers were told in 3 order to rake a judgment about whether they acted 4 properly or improperly in filing the suit against 7 Bradley Edwards? S A I think you have to know -- you have to know .3 that. 10 Q Is a lawyer entitled, unless he knows II otherwise, to assume that his client la being 12 truthful with him? 13 A Yea. 14 Q So, for example, if Jeffrey Epstein wore to IS have lied to his ethical lawyers, and his ethical 14 lawyers antlered he was telling the truth, would his 17 ethical lawyers be permitted to rely upon the assumed IS truthfulness of Jeffrey Epstein if they didn't know IS better? 20 A Yes. 31 Q You were shown Plaintiff's Exhibit Number 32 1, referred to as the Razorback complaint. 33 A Right. 0 And when that complaint was handed to you, 23 It was stated by opposing counsel that Bill Scherer, Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798370 137 139 a respected lawyer, sued the Rothstein firm. Do you 2 remember that being said? 3 A Yea. 4 Q Take a look at the complaint, if you would. S That complaint identifies all of those people who were defendants who were sued by Bill Scherer, 7 doesn't it? O A Correct. MR. LINK: Object to the form. 10 BY RR. SCAROLA: 11 Q All of those defendants who presumably Bill 12 Scherer had probable cause to sue when the complaint 13 was filed, correct? 14 A Correct. II Q And among all of the defendants that Bill 14 Scherer had probable cause to sue, la the Rothstein, 17 Roaenfeldt a Adler included? Is A No. Is Q Are you among the lawyers who were ➢ued by 20 Bill Scherer as having been actively involved in this 21 Penn achame? 22 A No. 23 Q Is Bradley Edwards identified as someone 24 that Bill Scherer had some basis to believe had been 2S involved In the Rothstein Pont scheme? 0 Are you aware that the V.S. Attorney's 2 Office announced that there were a number of unnamed co-conspirators that they wore still evaluating in 4 November and December of 2009? A No, I don't remember that. 4 Q so you gave the opinion that you didn't • think there was probable cause to ➢ue Mr. Edwards. a But have you reviewed any of the evidence that * Mr. Epstein monod on in bringing the suit? 10 MR. SCAROLA: I don't think you meant 11 to ➢ay that. 12 Which suit? 23 MR. LINK: Thin suit. 14 MR. SCAROLA: sorry. I thought you Ii wore talking about Razorback. It By RR. LINK: 27 Q Let me ask it again. Mr. Scarola asked you la if, in your opinion, a reasonably prudent person It would have probable cause to have made the allegation 20 that Bradley Edwards could have been connected to the 21 Rothstein POnil scheme. Do you remember that 22 question? 23 A I was thinking of your other question. Not 24 exactly, but -- 2S 138 A No. 2 Q Was there own the ➢lightest ➢uspicion that 3 would have justified any reasonably cautious person 4 in ➢uing Bradley Edwards and alleging that he was a 5 participant in the Rothstein Pons' ethane? 4 A No. 7 MR. SCAROLA: Thank you. I don't have • any further questions. 9 RECROSS-EXAMMATION 10 By NB. LINK: 11 Q Mr. Berger, the Exhibit 1 by Mr. Scherer, 12 who does it sue -- who does he sue? 13 A Scott Rothstein, David Roden, Debra 'Allegan, 14 Andrew Barnett, TO Bank, Frank Spinoaa, Jennifer IS Kerstetter, Rosanne Caretsky and Frank Prove. 14 Q And Mr. Rothstein was the chairman of the 17 Rothstein firm? IS A On November 20, 2009, I don't believe he was, 19 but he had been. 20 Q And at all times during the operation of 21 the Ponsi scheme? 22 A Yes. 23 Q And are you aware that Mr. Scherer anended 24 that complaint to add additional defendants? 25 A No. 140 Q Okay, so let me ask you this. What 2 information have you evaluated as a lawyer to 3 determine whether you would have found probable cause 4 in Deceaber of 2009 to allege that Hr. Edwards may 5 have been connected co the Rothstein Maui school.? 4 A There is no way in the world that Jeffrey 7 Epstein had probable cause to sue Brad Edwards. 0 My question -- 9 MR. SCARCER: Pardon me. The witness 10 had not finished his response. II MR. LINK: He's not answering it. 12 MR. SCARCER: The witness had not 13 finished hla response. 14 Go ahead, Hr. Berger. IS THE WITNESS: Jeffrey Epstein knew what If he did, and he knew that what Brad was ➢uing 17 him for was true. IS By RR. LINK: 19 not asking you that. Masking you 20 what evidence did you look at -- I am not asking you 21 about Mr. Epateln'n sexual contact with anybody. 22 asking you what evidence did you look at to ➢ee 23 whether there was a rea➢onable basis to allege -- in 24 thin one-out-of-ten standard that you articulated -- 25 to allege that Hr. Edwards may have been connected to Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798371 2 3 4 5 7 4 10 II II 13 24 is 14 27 Is It 20 21 22 23 24 25 141 the Rothstein Ponsi scheme. what evidence did you review? A I know ho wasn't. 0 IM not asking you what you know, air. IN asking you what evidence did you review. A well, hold on a second. You're saying -- I moan, when would I have reviewed it? I mean, Mr. Stomata asked ne the question -- Q Before you gave your opinion. A So you mean what did I review during this deposition when Mr. Scarola asked no the question? Q No. I an asking you did you review the evidence that existed in December 2009. A Let ne just atop you. Did I review in December of 2009? 0 No, no, before giving your opinion to Mr. Stomata and this jury that no reasonable person could have brought a claim against Brad Edwards. asking you before you gave that atatorant to this jury, what of the physical evidence that Hr. Epstein relied on did you review? A I just know what happened. There's no -- when you may did I review, you moan did I review during the course of this deposition? 0 No, air, before giving your opinion. 2 3 4 5 4 s s IC II 12 13 15 17 a It 20 2L 22 23 24 25 143 A The fact of the matter is, it's Epstein that filed it, and I know that it was false, ao -- 0 Co ahead. A -- I don't know how to answer your question. Q Because you know that you don't judge whether somebody had probable cause based on whether it turns out to be true or false, correct? Is that the standard you're hold to a➢ a lawyer, Hr. Berger? A I think I understand your question. I would answer yea to your question. Q so it's not whether you aro right or wrong that you allege at end of the day that determines whether you had probable cause, la it, air? A You are talking abaft the attorney or are you talking about the party that the attorney represents? 0 Ono in the sane. MR. SCAROLA: Objection. TIM WITNESS: It's not ono in the nano. It's not ono in the same. If I murdered you and your spouse sues mo [or wrong -- BY MR. LINK: Q You don't want to murder no, do you? A -- sues ne for wrongful death -- coming up with a bad example. I apologize. 2 142 Did you just toll this jury that, in your opinion, no reasonable lawyer In the world could 2 144 But there's no way in the world that Jeffrey Epstein had probable cause to sue Brad 2 have filed the lawsuit against Mr. Edwards? 3 Edwards. 4 MR. SCAROLA: Pardon me. That's 4 Q And what Masking -- I appreciate that. not what -- that'➢ not what the testimony 5 You consider Brad Edwards a friend, don't you? 6 was. That's a complete mischaractorization. 4 A Yeah. 7 That question had nothing to do with 7 0 You like Brad Edwards? lawyers. It had to do with Jeffrey Epstein. S A I da. 9 BY HR. LINK: What's his reputation In the legal 20 Q sir, is it your opinion -- you know 10 community? 31 Mr. Epstein didn't file the case, right? No's not a IL MR. SCAROLA: Objection. Beyond the 32 lawyer. 12 scope of redirect. 22 A I know. 13 THE WITNESS: I think be has a good 24 0 So my question is really simple. Is it 14 reputation. 36 your opinion that no reasonable person could have 15 BY MR. LINK: 16 filed a complaint in December of 2009 making an If Q And has he always had a good reputation? )7 allegation that Mr. Edwards may have boon connected 17 A I baileys, ao. 10 somehow to the Rothstein Ponsi scheme? IS Q SO, What really trying to understand 19 MR. SCAROLA: Objection. 19 from you la will you agree with me that you evaluate 20 Mischaracterimation of the allegations Ln 30 probable cause at the time that the lawsuit is filed? 21 the complaint. 21 A Yes. 22 THE WITNESS: when you say no person, 22 Q And sometimes the allegation,. prove to be 23 do you mean no lawyer or no party? 23 true, right? 24 BY KR. LINK: 24 A Right. 25 Either one. 25 0 And sometimes the allegation you make prove Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798372 2 4 5 145 to be untrue, right? A Correct. Q Have you over pied any allegations, Mr. Berger, that turned out to be untrue. down the lino? 1 4 S 147 Epstein? A It's patently [also that Jeffrey Epstein wan not Intel injured by anything that Brad Edwards did or if -- I don't deny that there wan a 0042l scheme that used the three cases we had as bait. 4 MR. SCAROLA: Objection, argumontivo, 4 Q Thoy did, right? 7 repetitious. THE WITNESS: I have never plod allegations that I knew were false. MR. SCAROLA: Excuso me. Please lot the witness finish his response. THE WITNESS: I wasn't there. I don't 10 BY I . SCAROLA: 10 have personal knowledge. I am telling you 11 Q so it's your view that the allegations In 11 my conclusion based on what I have road In 12 the complaint were known to be false? 12 the papers and all that -- so -- the 13 A To Jeffrey Epstein. 13 Pont! -- Rothstein did use the Penal scheme. SO which allegations - - II Brad Edwards had no involvement in it. IS A Are we talking about the Scharer lawsuit -- 13 Jeffrey Epstein was not damaged in any 14 14 way, shape or Corm by the Pont! scheme. A -- or aro we talking about Epstein's I, It's impossible. 14 allegations? 10 Jeffrey Epstein sexually abused dozens, It Q Epstein. I, if not hundreds, of children. The. fact that 20 Show me which allegations in there 20 that -- that those [acts were used by a 21 Mr. Epstein knew wore filse at the CUM he made it. 2L crook to promote a Son21 schwas didn't hurt 22 That's what you just said, so show me. Please point 22 Jeffrey Epstein ono bit. 23 out the allegations in that complaint, air, that 23 BY NB. LINK: 24 Mr. Epstein knew wore false when ho made them. 24 Q so can you separate in your mind for your 25 You can underline with my pen. 25 testLmony today what Mr. Epstein did and suits 146 148 1 A If he's alleging that he didn't do what he against him by plaintiffs that allege wrongful sexual 2 did -- 2 Conduct and his lawsuit against Rothstein, M. and Q You just testified that Mr. Epstein made 3 Edwards related to the Pone' scheme? Can you draw 4 allegations ho know wore . This is the complaint. I would like you to highlight them for 4 separation, Mr. Berger? A I think so. A okay. Take a break. 7 Q Because you hoop telling me about the sexual conduct that Mr. Epstein -- 8 Q Sure. S A My point is, he was not -- he wan not 9 THE VIDEOGRAPHER: Going off the record 9 Injured -- no reasonable person could think that 30 at 12:40 III. 10 Jeffrey Epstein who abused dozens of children and wan 31 IA recess was taken. IL sued for it could be injured mentally. Noire talking 12 THE VIDEOCRAPHER: Going back on the 12 about mental injury hero mentally Injured by Scott 13 record. The tine is 1:14 III. 13 Rothstein using those legitimate cases to defraud 14 BY HR. LINK: 14 investors. 15 Q Hr. Berger, before we took our break, I 15 Jeffrey Epstein'a reputation was not 36 asked you to underline every allegation In that 14 damaged at all. Ho had no reputation. Ho wasn't 37 complaint that you know that, at the time it was 1/ mentally -- no one can convince ma he was 30 written, that Mr. Epstein know the statement was 18 emotionally disturbed by the [act that he learned 19 false, right? 19 that his sexual predatory tactics wore used in a 20 A Right. 24 Manzi scheme. It's inconceivable. And that's 21 Q So may I moo what you have underlined that 21 basically the -- by the way, I didn't road the parts 22 you know that Mr. Epstein know it was false? 22 that deal with the legal counts. I read the factual 23 Okay, so on the first page you underlined 23 parts. 24 that -- what happened at the Rothstein flat that 24 Q so, can I just see the rose of it for a 25 resulted in profoundly serious injury to Jeffrey 33 minute that you marked? Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798373 3 4 5 4 10 11 12 13 14 15 14 15 14 Is 149 A I didn't go through them -- Q I understand. A when I got to count ono, I stopped. That was legal discussion. I Just looked at the factual allegations. Q So, can you point out to no here where Mr. Epstein talks about the damage to his reputation? A It's damages. Tho first lino you read said profoundly damaged, swathing like that. Q well, profoundly damaged, you could have monetary damages, right? Is there a distinction in monetary damages and emotional damage➢? A Theoretically there are. Q Show me where Mr. Epstein asked for his damage to reputation. That'➢ what you just said, hi➢ reputation couldn't have boon thinned. Mere does he ➢oak damage➢ for his reputation? 2 ) 4 f * IC m 12 13 14 15 14 17 10 II 151 A -- between what she said to her depo➢ition. But she was not a part of any schwa. Epstein knew that. 0 So Epstein knew the reason why she changed her sworn testimony to the FBI and then when she got to the Rothstein firm was -- how did ho know why she did that? How would ho know? A Sir, Epstein knew that her second testimony whore she accu➢ed his of those was true. So she didn't change it because of a Ponsi scheme. she's changed it because ➢he told the truth. So she lied to the FBI? A Right. 0 So she's an admitted liar to the federal government. Is there a consequence for lying CO the federal goverment? MR. SCAROLA: Objection, argumantive. THE WITNESS: I don't know. 20 MR. SCAROLA: Excuse me, Counsel. What 20 was she prosecuted? 2l was read was, •resulted In profoundly 21 BY Ma. LINK: 22 serious injury to Jeffrey Epstein.• That's 21 0 . just asking lf there's usually a 23 what was just discussed. 23 consequence. 24 THE WITNESS: Brad Edwards did not have 24 A I don't know. 25 anything to do with the Ronal schwa. 25 0 You don't know? 150 152 I BY M. SCAROLA: A No. 2 Q I know you believe that, sir. I believe in 2 I don't think that ➢he wa➢ prosecuted. 3 my heart that you believe that, okay? 3 Q So you underlined that Rothstein and his 4 A I believe Jeffrey Epstein knew that. 4 co-conspirators unlawfully obtained approximately But what I asked you to do is to point out 5 1.2 billion. Mat is untrue about that? 4 in here the allegations that you S0110M1041 know that, 4 A well, if it's reflected on Brad, he wasn't a / when they were nado, that Mr. Epstein in his mind know they were false. 7 co-conspirator. Q It doesn't my Brad's nano, doe➢ it? 9 MR. SCAROLA: And that's exactly what 9 A Just ono second. I assume that it's part of 10 the witness la doing. would you please let 10 a complaint against Brad, so if it didn't mean to 11 him finish his response? II include Brad, then I shouldn't have underlined it. 12 THE WITNESS: So the first one was 11 Q So do you want to squiggle through that I) that -- Epstein saying he was profoundly 13 ono? rite it out? 14 damaged. There's no way in the world that 14 A Do you want to put in hare that it's not 15 that's true. 15 Brad? I will do that if you write, •except Edwards.• If BY M. LINK: If Co ahead. I/ 0 So he was not profoundly damaged, okay. 17 Q I. not going to change it, if that's Whit IS The next thing underlined was that the allegation IS you want to put in there. 19 about III. being a participant in the schema by, 19 Okay, let's see what else. Is it a true 24 among other things, changing her prior sworn 24 statement that Rothstoin and his co-conspirators 31 testimony. 21 stole over a billion dollars from unexpected 33 A she was not a participant in a schema. She 32 victims? 23 may have changed her prior testimony. You pointed out 33 A Yes. 24 an inconsistency -- 34 Q So you underlined in paragraph 18 the XS 0 Right? 25 Matament, •What la clear is that a fraudulent and Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798374 153 155 3 4 Improper investment or Poral scheme was In fact conducted and operated by RRA and certain of the named defendants.' One of the named defendants is S Mr. Rothstein, right? A Yea. Q And did Kr. Rothstein, in fact, participate 4 in the Moral scheme? 10 A Yea. Q So what la it about that allegation that II wan untrue when it was written? 12 13 II A If it meant to include Brad and III. -- O Does IX say Brad and III. in there? A No. But it could be road to mean that. So 13 saying it would false lf it was meant to include 14 them. I7 IS Id 20 21 22 23 24 25 O But it doesn't nay Brad and ■.? MR. SCAROLA: No, but it does say defendants, plural. Please stop arguing. Ask gentians, let the witness answer them, but p don't argue. TEE WITNESS: If it said Rothstein, It would bo true. 1 Q A203 you aware of meetings that Hr. Edwards, 2 had with Hr. Rothstein? A not aware of any meetings he had. 4 Q Mere you aware of the walla between 5 Mr. Rothstein and Kr. Edwards about these lawsuits? 4 A No. 7 Q Mere you aware of the amain between Marc s Nurik and Mr. Rothstein about these lawsuits? A No. 10 Q Were you aware of any structuring of these II lawsuits with Hr. Edwards and Hr. Rothstein related le to what would be pled? 13 A Am I aware -- II 0 Are you aware of that? 13 A If it happened? 14 0 Yeah. 17 A No. IS Q So an you sit 11024 today, isn't it true Is that you really, as I understand it, have no personal 20 knowledge of the way the scheme was, in fact, 21 conducted or who waa involved; isn't that true? 22 A I don't have any eyewitness knowledge. 23 Q Personal knowledge, do you, air? 24 A Personal knowledge la the lawyers term for 25 eyewitne➢s knowledge, and I don't have any eyewitness 1 BY KR. LINK: 154 2 0 So in your world it's partially true 3 because It included Kr. Rothstein? Yes? 4 A No, it's not in my world. It's reality. 5 0 So I thought you told us that you had no 6 idea what was going on at the firm at the time, 7 right? S In 2000 and '09, you had no idea about the 9 Portal scheme or what Mr. Rothstein was doing, is 20 that right? II A Right. 12 0 Do you know every action that Mr. Edwards 19 14 1S I6 17 10 19 20 21 took in dealing with Mr. Rothstein? MR. SCAROLA: Excuse me. Could we ask one question at a time? And the cm, that la pending is to identify those portions of the complaint which this witness can identify as knowingly false statements by Epstein. Can we lot him finish that question? BY RR. LINK: 22 0 You can answer my question. 23 Are you aware of all of Mr. Edwards' 24 interactions with Mr. Rothstein? 25 A No. 2 4 S 10 II 12 13 14 15 If 17 IS 19 20 21 22 23 24 23 156 knowledge. Q You don't have any, do you? So what you're telling this jury is you happen to like Brad Edwards, and you don't want to even conceive for one second that he may have had some connection with Mr. Rothstein in the way these three cases wore used' is that true? MR. SCAROLA: Objection, argumentive. THE WITNESS: There aro ➢tatements in here that are categorically false because Jeffrey Epstein knew what he did. I do like Brad Edwards, and I don't believe that he participated in the scheme with Rothstein. BY KR. LINK: • I got it. But you aro not aware of any of the evidence connecting Kr. Edwards and Hr. Rothstein that relate to the three cases that were pending at the Rothstein firm, are you? MR. SCAROLA: Excuse me. IM going to object. That question assumes that any such evidence exists, when Mr. Epstein had every opportunity to present that evidence to the court and has never present/pi any, because it doesn't exist. Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798375 157 MR. LINK: pretty sure that lawsuit 159 sentence had nothing to do with the Ponzi 2 has gone, Mr. scarola. Please, save the 2 schema. 3 commontary. I appreciate it. It's groat ) BY HR. LINK: 4 advice, and I will continuo to try to learn 4 Q Did Hr. Adler go to jail? 5 from you. 5 A Mr. Adler did go to jail. 6 MR. SCAROLA: Thank you. How about you let the witness finish the answer to your question before you got involved -- 4 Q Nora you surprised that Mr. Adler would end up going to jail for election Improprieties? A Yee. 9 MR. LINK: I change the question as I 1 Q How about your really good friend 10 go. I can do that. 10 Mr. Rosenfeld? 11 BY HR. LINK: II A Sams thing. 12 0 So, Mr. Borger -- 12 0 Same thing. 13 MR. SCAROLA: So as long as the record 13 So these are people that you know really 14 is clear that you have declined to allow him 14 well, right? 25 to continue to answer the question, that's Is A Right. 36 fine. 14 Q Worked wish then, trusted them, and they 21 BY HR. LINK: 13 did things that you couldn't imagine, isn't that 36 0 Is there something more you wanted to say is true? 29 about my pending question? It A That's true. 10 MR. SCAROLA: The pending question was 20 Q So the fact that you can't imagine Brad 21 to identify ovary portion of this 21 doing it doesn't moan that Brad wasn't somehow 22 complaint -- 22 connected, does it? 29 MR. LINK: Not -- 23 A Maybe to you it doesn't. 14 MR. SCAROLA: -- that Mr. Barger knows 24 Q You thought that way about Mr. Rothstein, 25 to be false. 25 didn't you? 158 160 I 2 BY HR. LINK: Q I will give you a vary simple question. 2 MR. SCAROLA: Objection. Argumentiva, repetitious. 3 Rave you reviewed any of the ommunlcations BY MR. LINK: 4 involving Rothstein and the three plaintiff cases 0 Yos, sir? that were being handled at the tins you were at the 5 A Yos. 4 Rothstein firm? 0 And Mr. Adler? 7 A I don't know of any and I haven't reviewed any. 0 MR. SCAROLA: Objection. Argumentiva, repetitious. 9 0 So isn't it true that your opinion about 9 BY MR. LINK: 10 Brad Edwards is based on your personal view of him? 20 0 And Mr. Rosonfoldt? II 12 A And my Interaction with him. Q And I suspect you wouldn't have joined the 33 MR. SCAROLA: Objection. Argumentiva, repetitious. 13 Rothstein firm if you didn't think ho was a good guy, 23 THE WITNESS: Correct. 14 would you? 24 MR. LINK: I don't have any further 15 A Yes. 25 questions. 16 Q Right. And I bet it was a shock to you 16 REDIRECT EXAMINATION 13 that ho was running a Ponzl scram, because nowhere 17 BY KR. SCAROLA: IS in your mind would you have thought that was 10 0 Ara there any other sections of this 19 possible, true? 19 complaint that you know Mr. Epstein could not have 30 A True. 20 allagod in good faith? 31 Q And probably the same thing with your 21 MR. LINK: That was not my question if 22 friend Mr. Adler. Didn't Mr. Adler have to go to 22 you want to -- 23 jail? 23 MR. SCAROLA: It's my question. ICs 34 MR. SCAROLA: Excusable. • going to 24 my question. 33 object. Compound. And Adler's jail 25 MR. LINK: okay. So you aro changing Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798376 161 163 1 the standard. That's fine. 2 Do you want the rest of it back, 3 Mr. Berger? THE WITNESS: It's along the ➢ame 5 lines -- all of these aro basically along 6 the sane lines in terms of lumping • Mr. Edwards together with -- I should say o Mr. Edwards and III. together with 9 Rothstein. So that's basically the -- my 10 criticism of this, as well as -- as well as 11 any suggestion that he could have been 12 damaged. 12 And if he was damaged financially, it 14 IS le 1> was -- he wasn't damaged -- he wa➢ out-of-pocket financially, but it's by his own doing, so I wouldn't consider that to be legal damages. le BY MR. SCAROLA: 29 C. It was suggested that Hr. Epstein, in 10 filing this complaint, may have somehow relied upon 21 internal email communIcationa within Rothstein, 22 R aaaaaaa dt a Adler. This complaint that we are 22 looking at -- 24 MR. LINK: I am going to object. That IS is not that I said. correct? 2 A Correct. Q And were also aware at the tine that the 4 use of initials and pseudonyms were re:patrol to S protect the identity of individuals who were 4 juveniles at the tine these offenses were committed ▪ against them? ▪ A Yes. Q Was there ever any effort to use initials 10 or pseudonyms as an element in a fraudulent ➢chins as 12 opposed to simply following the law to protect the 12 identity of juveniles? 13 MR. LINK: going to object the 1 fora. going CO nova CO strike. It'➢ beyond the scope. He did not underline any 14 Of the phrases that you are referring to. If THE WITNESS: No. le By MR. SCAROLA: If Q Dld Jeffrey Epstein know that the victim 20 he was abusing were juveniles at the tires he abused 21 them? 22 A Yea. 23 Q In paragraph 31, the allegation is made 24 that the litigation team -- of which you were 25 identified as a member -- the litigation team reached 162 I BY RR. SCAROLA: 2 0 This complaint that we aro looking at -- 3 MR. LINK: Mr. Scarola, you aro 4 misstating what I ➢aid. 2 BY HR. SCAROLA: 4 Q shows a filing date of December 7, 2009. 7 Do you know of any way whatsoever that Mr. Epstein S could have had access to internal aaaaaa of t Rothstein, Rosonfoldt s Adler in December of 2009? 10 A No. IL MR. LINK: Move to ➢trike. 12 MR. SCAROLA: Paragraph 23 of -- 13 THE WITNESS: Excuse me. Excuse Ifia. I 14 at going CO frOVO strike. It'➢ a IS misstatement of what I said. If BY HR. SCAROLA: O Q Paragraph 230C this complaint says that IS Edwards claiming the need for anonymity with regard 19 to existing or fabricated clients, they were able to 20 effectively u➢e initials, Jane Doe or other anonymous 21 designations, which was a key element in the 22 fraudulent SChOISO. 23 Let me a➢k you, first of all, about your 24 own conduct. You were aware that these cases were 25 being prosecuted using initials and pseudonyms, 164 agreements to share attorney'➢ foes with non-lawyers. 2 Dld you ever roach an agreement to ➢hare 3 attorney's fees with non-lawyers? 4 A No. • Q Could there have possibly been any basis 6 for Jeffrey Epstein to have alleged that there wa➢ an 7 agreement reached by you or Brad Edwards to ➢hare S attorney's fees with non-lawyers? 9 A No. 10 II 12 13 14 Q Subparagraph C says the litigation team used investor money to pay plaintiffs -- that is, III., E.N. and Jane Doo -- upfront noney such that plaintiffs would refuse to settle the civil actions. Did that over happen? IS A No. If 11 IS 19 30 21 22 23 24 3, Q Could there ever have possibly been any rea➢onable basis for Jeffrey Epstein in December of 2009 to have alleged that it happened? MR. LINK: Object to the form. Hove to strike. How he known what's in Jeffrey's mind, I don't know. And the words say may have. It doesn't say it was done. You can answer. THE WITNESS: No. Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798377 165 167 1 BY MR. SCAROLA: 2 Q Were any searches, wiretaps or intercepted 3 conversations use! in violation of state or federal 4 lawn and Bar rules in connection with those -- the S prosecution of the claims against Epstein? A No. Q Y➢u have already told u➢ that there was no 4 unreasonable or unnec➢➢➢ary discovery that was * engaged in for the sole purpose of furthering the 10 panel scheme, correct? 11 12 A Correct. O Did Jeffrey Epstein know what Jeffrey 13 Epstein did and, therefore, recognized the fact that 14 when other victim' cases were being investigated, 15 activities on the airplane were being investigated, 14 what Jeffrey Epstein was doing on his private Inland 1/ was being investigated, what Jeffrey Epstein was le doing in hla 102 of millions of dollars Now York is penthouse was doing, did he know what he himself did? 20 A Of course. 21 Q So whom Jeffrey Epstein alleges in 22 paragraph 33 that the litigation team know that 23 issues were balm; pursued and evidence was being 24 pursued unrelated to and unnecessary to the claim 2S plod in the cases on behalf of III., E.M. and Jana 2 4 S dozen of children over an extended period of time, could Jeffrey Epstein have possibly made that allegation in good faith? MR. LINK: Object to the form. Move to strike. THE WITNESS: No. * BY MR. SCAROLA: a Q When it is alleged in subparagraph E, on s that same page, that you and Brad Edwards together 14 add aaaaa d the court on variou➢ motions using 11 ridiculous, inflammatory and sound-bite-rich 12 Matments for purposes of pumping a Penal scheme, 13 could Jeffrey Epstein possibly have believed that to 14 DO true when Jeffrey Epstein knew that ho had, in 15 fact, engaged in dozens and dozens and dozens of 14 sexual molestation crimes? I? MR. LINK: Object to the form and move is to strike. Ia THE WITNESS: Ho. 20 BY MR. SCAROLA: 21 Q When Jeffrey Epstein alleges in 22 subparagraph N that the litigation team, defined as 2) including you, know or should have known that their 24 filed cases were weak and had minimal value, could 2S Jeffrey Epstein, knowing what he did to those three 166 Doe, did Jeffrey Epstein know about those things that 2 Jaffrey Epstein himself had done? 3 A Of course. 4 Q And if Jeffrey Epstein alleges there wore 5 no juveniles, no children being transported on his 4 plane when the flight logs reflect that there were • children transported on Jeffrey Epstein•s plane when • Jeffrey Epstein himself was on the plane, is there 9 any reasonable basis for Jeffrey Epstein to have 10 alleged otherwise? 11 A No. 12 Q Paragraph 42C on page 16 alleges that 13 Bradley Edwards, you and Russell Adler participated 14 in a deposition whore outrageous questions were asked IS of Epstein which had no bearing on the case, but so If that the video and questions could be shown to I/ inve➢tort. IS IS so Could Jeffrey Epstein possibly have had any good faith basis for making that allegation? A No. 21 Q When Jeffrey Epstein alleges that discovery 22 was conducted and attempted, that was completely 23 irrelevant discovery, unrelated to the claims, when 24 Jeffrey Epstein knows that he had been engaging in 25 the sexual abuse of dozens and dozens and dozens and 168 children, have possibly mud➢ that allegation in good 2 faith? 3 MR. LINK: Object to the form and move 4 to strike. THE MITNESS: No. 4 BY RR. SCAROLA: 7 0 When it is alleged In subparagraph K that • the litigation team sought pilot and plane loge to 9 prime the investment pump with new money without any 10 relevance to the existing claims made by the MA II clients, could Jeffrey Epstein, knowing about what 12 went on on those airplanes, have made that allegation 13 in good faith? 14 MR. LINK: Object to the form and move IS to strike. 14 THE MITNESS: Ho. Is BY MR. SCAROLA: IS Q If Jeffrey Epstein alleges in this 19 complaint against Bradley Edwards that III., E.W. or 24 Jane Doe voluntarily consented to their sexual 21 molestation, could Jeffrey Epstein have possibly made 22 that claim on the basis of any probable cause 23 whatsoever? MR. LINK: Object to the form. 35 THE WITNESS: No. Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798378 169 171 1 MR. SCAROLA: I have no further 1 REPORTER'S DEPOSITION CERTIFICATE 2 questions. 2 3 MR. LINK: I think we aro done. 3 STATE OF FLORIDA 2 4 MR. SCAROLA: Good. Thank you. : SS S THE VIDEOGRAPRER: Going off the 4 COUNTY OF PALM BEACH 2 5 record. Tho tiro is 1:32 2 I, SONJA D. MALL, certify that I was MR. SCAROLA: Before we go off the 4 authorised to and did stenographically report the 8 record, would you like to road the 7 deposition of WILLIAM BERGER; that a review of the deposition transcript? 4 transcript was not requested, and that the transcript t is a true and complete record of my stenographic 10 THE WITNESS: No. 10 notes. 11 MR. SCAROLA: Witness waives. 11 I further certify that I an not a relative, 12 - - - 12 employee, attorney, or counsel of any of the parties, 13 4Tho deposition concluded at 1:32 13 nor an I a relative or employee of any of the parties' 14 14 attorney or counsel connected with the acticm, nor am Is 15 I financially in aaaaaaa d in the action. :o If 37 17 Dated this 27th day of February 2028. 30 14 9 IS 20 20 21 21 SONJA D. MAIL 22 22 22 23 14 24 26 25 170 1 STIPULATION 2 It is hereby stipulated by and between counsel for the respective parties and the witness 3 that the reading and signing of the foregoing deposition, and notice of filing be, and the soma aro 4 hereby waived. 5 A182 FURTHER DEPONENT SAITH NAUGHT f 7 CERTIFICATE OF OATH 4 STATE OF FLORIDA 2 a COUNTY OF PALM BEACH 2 10 11 I, the undersigned authority, certify that 12 WILLIAM BERGER personally appeared before ma and was 13 duly sworn. 14 WITNESS my hand and official seal this 27th 15 day of February 2028. 14 11 II It Sonja D. Hall 20 Commission No.: GC 268652 21 Notary Public - State of Florida 22 My Commission Expires: 02-01-2022 23 24 25 Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798379 172 A 1:214:3 55:3,6 able 33:10 92:1 134:9 162:19 Abrams 16:9,10,14 16:19 17:4 19:10 19:20 21:2 absolutely 30:5 96:19 abuse 92:6,11,17 93:4 96:22 130:22 131.13,16,22 132:1,20133:1,9 166:25 abused 35:8 41.6 92:23 147:18 148:10 163:20 abusing 163:20 accept 121:14 accepted 17:12 access 72:23 162:8 accessible 68:18,19 accident 94:23 95:17 account 29:15 accountable 107:14 accounts 29:1,2,5 accurate 114:13 accused 46:23 151:9 accusing 50:11 achieved 122:3 Ackerman 90:18 134:24.25 135:1.2 acknowledge 56:24 acknowledged 135:6 acquainted 15:14 acquired 19:13 act 53:24 acted 136:5 acting 134:3 action 8:2 20:21 154:12 171:14,15 actions 164:13 active 20:20 43:19 106:9 actively 137:20 activities 1 I:11 37:18 165:15 activity 29:21 40:22 56:10 120:17 acts 33:11 39:22,25 actual 58:6 86:6 Adam 35:24 36:19 124:5 127:7 128:21 add 109:6 138:24 addicts 106:11 addition 12:22 21:2 33:10 51:12 additional 138:24 addressed 11:25 167:10 addressing 11:19 Adler 15:7 16:2,7 17:6,20 29:20 62:21 110:25 111:7 137:17 158:22,22 159:4,5 159:6 160:6 161:22 162:9 166:13 Adler's 158:25 administers 11:6 administrative 12:15 admit 56:11 admitted 151:14 adult 92:19 advantage 107:20 advice 133:22 134:3 134:5,7,10 157:4 advise 133:25 affect 104:23 affirmed 109:21 afloat 57:22 afraid 112:7 afternoon 28:5,9 age 8:7 101:11 133:3,9 agency 112:25 aggravate 96:6 aggravated 96:2 aggravating 106:14 aggressive 51:7 87:4,7,11,18,21 88:3 111:13 aggressively 51:6 agree 52:8 57:24 68:25 72:21 94:24 95:8 97:8 106:5 108:14,16 113:7 120:11 126:11 144:19 agreement 36:7,8.8 36:15,16 44:19 51:20,22 52:5 99:1,18 123:18,19 123:23 124:10 128:11 164:2,7 agreements 164:1 ahead 78:21 84:3 127:8 128:14 140:14 143:3 152:16 airplane 42:19 165:15 airplanes 168:12 alive 59:16 allegation 86:12 139:19 142:17 144:25 146:16 150:18 153:10 163:23 166:19 167:3 168:1,12 allegations 41:5 101:25 142:20 144:22 145:3,9,11 145:14,18,20,23 146:4 149:5 150:6 allege 140:4,23,25 143:12 148:1 alleged 39:15 40:14 92:6,17 93:4 120:2 121:7 130:22 160:20 164:6,18 166:10 167:8 168:7 alleges 86:4 165:21 166:4,12,21 167:21 168:18 alleging 50:19 138:4 146:1 allow 39:20 157:14 allowed 39:21 41.13 59:5 allows 39:25 amended 138:23 amendment 51:4 amount 32:11 34:3 122:1.3 123:14 analogize 95:24 analysis 96:17 Andrew 138:14 anguish 94:13,15 announce 4:14 announced 139:2 anonymity 162:18 anonymous 162:20 answer 100:24 101.3 143:4,10 153:21 154:22 157:7.15 164:24 answering 101:5 140:11 anthrax 16:13 anybody 56:3 76:25 111.8 113:18 128:15 140:21 anymore 16:18 anyway 48:19 apart 57:20 apologize 143:25 Apparently 58:8 appeal 13:6,23 14:6 20:11.19 23:6 appealed 13:4 109:22 appear 98:24 appearance 46:21 appearances 2:5 4:15 appeared 170:12 appellate 12:23,25 13:3,6,16 14:18 14:22 20:2 application 8:3 applied 7:2 apply 10:13 appointed 14:16,22 26:8.17,21 appointment 28:17 73:16 appreciate 55:17 144:4 157:3 apprized 53:2 approved 123:15 approximate 21:16 approximately 4:2 5:21 12:17 18:22 21:24 29:17 75:25 152:4 April 113:16 area 9:19,20 15:21 15:24 areas 18:3 66:25 67:1 argue 153:22 argued 128:17 arguing 118:1 153:20 argumentative 107:2,16 argumentive 92:8 109:12 113:24 127:3 145:6 151:18 156:8 160:1,7,11 arose 11:2067:7 arrangement 51:18 123:8 article 23:14 62:7 articles 22:9 61:20 62:2 articulated 140:24 asked 17:2 31:11 32:9 64:13 67:11 100:22 118:21 128:13 130:6 134:17 139:17 141:8,11 146:16 149:15 150:5 166:14 asking 105:15 106:5 106:8 107:7,9 114:22 115:20 128:19,22 140:19 140:19,20,22 141:4,5,12,19 144:4 151:22 aspects 37:4 assert 134:13 assets 32:24 117:1 assignment 79:1 assist 36:12 assistant 64:21 103:10 assistants 102:2 associate 14:2 associated 19:5 22:14 29:19 77:1 associates 24:1 46:7 assume 36:22 105:7 111:20 112:25 113:9 136:11 152:9 assumed 136:16,17 assumes 77:8,16 100:3 117:9 156:21 assuming 111:4 attack 16:13 51:9 attacks 51:7 attempt 48:15 attempted 51:9 166:22 attempting 51:1 52:10 54:13 attend 27:24 53:1 125:25 attended 37:12 98:21,22 99:3 100:21 124:2 attention 123:12 attorney 5:18 8:15 15:20 18:13 19:10 19:11 20:16,20,21 20:21 21:3,11 23:8,9 25:19,23 26:22 28:13,15 35:17,21,24 36:25 39:20 42:16 48:6 51:5 52:7 53:13 53:16,23 81:8 82:10 116:8 119:8 125:17 127:6 134:4,16 143:14 143:15 171:12,14 attorney's 18:5 52:6 53:5 111:25 139:1 164:1,3,8 attorney-client 124:12 134:8,14 135:21 Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798380 173 attorneys 4:14 21:15 22:14 25:6 26:6 27:5 28:22 34:16 35:13,25 36:10 39:2 I 40:23 45:21 47:948:15 48:24 56:13 61:2 111:5 122:10 125:16 attorneys' 18:2 attract 49:17 attracted 7:13 attractive 103:12 audience 70:15 authority 170:11 authorized 171:6 Automotive 21:8 Avenue 2:11 avoid 121:11 award 33:8,18,19 33:20 awarded 22:12 33:20 98:8 aware 25:5 29:10 51:14,21 54:16 59:13 63:7,10 67:4,15,23 74:19 78:18 79:4 89:6 90:11 99:25 100:7 101:13,21 102:10 103:16 112:14 116:17 129:23 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16:14 17:22 66:1 1 68:7 68:13,23 80:5,13 bullied 110:14,18 110:21 111:1,8 bully 54:12 Busche121:11,12 business 26:24 57:13,15 60:22 63:1,2 businesses 78:25 busy 72:15 buy 75:25 77:22 C C 164:10 call 10:7 17:19 32:18 61:2 68:17 73:15 76:13,14,16 76:18,19 78:19 118:18 called 8:18 I 1:8 16:25 23:25 25:1 25:8 33:4,14 55:21 62:10,12 71:7 80:3,14 85:12 calling 128:19,21 calls 45:8 84:8 87:12 113:23 114:14 camera 100:23 cameraman 69:12 candidates 46:7 capacity 5:17 capital 106:21,25 captain 76:25 car 66:6 75:24 96:5 96:5 career 12:5 15:2 Caretsky 138:15 Caribbean 43:17 cars 75:19 76:2,3,4 case 1:3 3:18 4:23 5:23 6:3,16 20:23 22:24,24 23:20 25:7 32:23,23 33:6 35:13 37:4 41:13,23 45:8 48:5 53:16 58:17 83:2,18 86:6 91:20,20,25 92:3 93:19 94:9 95:3 Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798381 174 95:20,21 96:10 98:16 103:2,15 104:2,7,23 105:20 106:25 108:8,17 108:23,25 109:4,6 109:6 110:25 121.6,15,17 127:1 129:2 130:14 142:11 166:15 case-by-case 96:16 96:19 cases 9:17 10:5 12:19 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121:2,13,14 121:23,25,25 122:3 123:15 129:5,18 130:17 132:5,7 133:17 136:11 client's 133:19 clients 21.6,13 22:18 23:9 27:2 34:14 35:6,14,16 35:22,23 36:10,13 37:1 40:9,16,25 41:5,10,1243:6 43:20 46:22 48:13 48:17,18 51:5,19 56:21 63:21,24 92:16 97:12,19 98:15 100:7,11 101:22 102:11 111:12 114:9 115:1,13 126:22 126:24 129:8,10 129:25 130:7 131:18 132:18 162:19 168:11 clients' 129:21 130:21 Clinton 28:18 co-conspirator 152:7 co-conspirators 52:2 54:6 139:3 152:4,20 co-counsel 34:8,15 34:17,17 Coast 13:8 code 133:13 134:12 Coffey 25:23 28:12 69:1,11,15,21,23 70:10 Colbath 99:4 collapse 27:14 collapsed 24:20 25:16 26:1 27:12 41:23 collect 27:7 collected 27:4 collecting 27:3 collective 125:16 collectively 128:13 college 6:21 colorable 82:24 combination 8:1 come 15:8 29:9 30:3 32:10 49:15 50:25 51:8 72:17 77:21 88:6 102:11 106:13 108:12 110:17 comes 105:8 comfortable 81:15 coming 53:2 129:14 143:24 commended 53:24 commentary 157:3 commercial 10:7 commission 50:17 170:20,22 committed 39:16,16 40:1,14 163:6 committee 14:19 committing 120:12 common 18:3 25:10 32:9 36:13 61:9 61:10 66:25 67:1 communicate 38:15 communicated 99:25 communicating 36:5 communication 127:20 communications 36:12 158:3 161:21 community 22:6,8 75:12,13,14 119:7 144:10 companies 9:12,12 company 26:23 36:15 61.11,12,15 93:13.14,25 95:10 compare 114:12 115:4.6 compared 74:1 114:23 115:9 comparing 36:6 compelled 11:20 compensate 32:11 122:12.19 compensated 33:1 compensating 33:3 compensatory 33:5 33:9 34:1 44:25 45:2 91:21 competent 108:11 complaint 3:16,18 79:10 83:9 85:10 85:13 118:9,11,19 118:23 136:22,24 137:4,5,12 138:24 142:16,21 145:12 145:23 146:5,17 152:10 154:17 157:22 160:19 161:20,22 162:2 162:17 168:19 complaints 83:6 complete 30:3 142:6 171:9 completely 47:13 49:12 166:22 complicated 96:16 complied 53:6 compound 56:6 59:18 75:4 112:10 127:2 133:11 158:25 conceivable 132:16 conceive 156:5 concentration 9:18 concept 53:8 124:10 133:21 concepts 7:12 concerned 45:17 135:7 concluded 169:13 conclusion 147:11 conclusions 84:8 condition 96:2,5,6 113:8 conduct 40:23 42:3 105:2 120:3,8 133:5 134:18 148:2,7 162:24 conducted 37:7 44:8 153:2 155:21 166:22 conducting 50:6 Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798382 175 conference 66:22 73:23.24 74:1 conferences 37:7 confidential 36:1 I 36:12 configured 74:3 connected 34:22 139:20 140:5,25 142:17 159:22 171.14 connecting 156:17 connection 31:18 37:19 43:3,9 56:19 156:6 165:4 connections 56:25 connotation 61:10 Conrad 22:19,19 81:9,12 cons 92:1 consent 106:23,23 consented 168:20 consenting 104:20 consequence 151:16 151:23 consequently 46:12 consider 56:8,23 144:5 161:16 considerably 30:15 consideration 104:5 104:14.16 105:17 consisting 14:17 constructed 68:8 consult 100:14,14 130:13.15,16 consulted 53:18 consumer 20:21 contact 140:21 contain 29:2 contained 38:23 context 92:20 107:18 117:21 continual 57:17 continue 81:21 157:4.15 control 47:5 controls 45:6 conversations 60:8 165:3 convince 148:17 convinced 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171:17 days 25:24,24 27:21 deal 10:14 14:23 15:19 16:12 20:14 45:22 47:13 51:16 52:8 54:4 148:22 dealerships 21:8 dealing 6:15 53:8 105:5 125:9 132:14 154:13 deals 29:2,3 dean 126:9 death 143:24 Debra 138:13 decades 9:9 54:2 December 5:21 139:4 140:4 141:13,15 142:16 162:6,9 164:17 decide 101:2 decided 7:23 8:22 10:22 11:22 12:1 110:11 decision 45:6,9 110:11,12 122:18 decisions 13:14,17 14:25 107:14 109:20 declined 157:14 decor 73:5 decorated 18:20 deem 121:7 defend 51:1 106:22 defendant 32:12,15 33:7.16,16 54:5 87:6 defendant's 87:1 Defendant/Count... 1:18 2:14 defendants 9:23 10:6 83:7 92:16 137:6,11,15 138:24 153:3,4.19 Defendants/Coun... 1:9 DEFENDANTS/... 3:21 defended 23:5 defending 87:11 88:2,14 93:25 95:10 defense 88:3 124:24 133:22,25 134:6 defense's 97:6 defined 167:22 defraud 148:13 degree 6:24,24 7:1 33:11 84:5 92:18 delegated 127:17 Delray 12:14,15 demise 23:10 Denney 2:15 35:22 36:20 deny 147:4 depending 18:4 Depends 94:8 105:24 DEPONENT 170:5 depose 38:20 deposition 1:13 3:3 3:17 4:4,8,24 5:11 5:13,22 6:13 50:9 84:11 89:10 115:3 141:11,24 151.1 166:14 169:9,13 170:3 171:1,7 depositions 135:22 describe 17:25 18:8 22:5 31:6 37:17 37:25 64:17 66:16 133:24 described 23:24 24:11 27:12 29:15 31:25 69:3 107:23 describing 32:15 114:9 Description 3:15 designate 24:11 designated 24:4,7 designations 162:21 destroyed 46:11 47:20 detail 131:19 details 34:24 58:23 59:12 determination 39:3 determine 98:6 140:3 determined 133:1 determines 143:12 determining 94:23 detract 105:20 developing 127:1 devout 71:6 difference 79:12,17 79:22 differences 113:19 Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798383 176 130:21 different 36:10 72:21 74:11 83:6 96:22 97:2 108:12 109:3 115:14,21 differently 74:3 difficult 46:1947:24 48:3.21 difficulties 45:11,15 diminish 48:16 direct 3:5 5:7 41:18 52:15 55:18 81:14 86:22 119:25 125:1 directed 47:1 directly 40:9 46:19 127:22 director 11:11,11 disabled 47:19,20 disadvantaged 133:2 discharge 121:22 discipline 25:6 disciplined 9:16 disclose 47:10,10 99:11.14 Disclosed 99:13 disclosures 29:14 discover 95:16 discovery 37:7,8,8 45:25,25 47:1 84:10 95:12 98:22 114:4 129:11,13 129:14 165:8 166:21.23 discredit 132:20 discrimination 9:15 discuss 47:2 60:21 63:1 130:20 discussed 149:23 discussion 19:25 63:6 149:4 discussions 129:21 disputes 10:8 dissented 20:11 distinction 149:12 distinguish 125:3 distress 95:16 distributed 29:4 District 13:6,12,14 13:23 20:3,8,10 20:19 28:16 disturbed 148:18 divided 12:9 division 12:11,12,19 divisions 12:9 14:4 divorces 12:13 document 99:21 Doe 31:2 86:6 90:23 91:2 93:3 103:23 162:20 164:12 166:1 168:20 doing 12:22 23:18 48:25 49:2 53:22 54:13 69:4 79:4 84:12 98:10 103:2 103:24 104:20 106:19 115:12 121:18 150:10 154:9 159:21 161:16 165:16,18 165:19 dollar 32:10 109:3 122:1 dollars 23:2 29:5 32:7 33:25 45:1,5 63:5 86:15 152:21 165:18 door 65:3,25 66:6 70:12,12,13,20,21 71:14,21,22 72:8 72:16 73:13,17 74:6,10,11 doors 70:2073:9 double 19:1 70:21 doubled 64:3 doubt 62:9 downstairs 80:5 dozens 27:25,25 106:13 147:18 148:10 166:25,25 166:25 167:1,15 167:15,15 drafting 117:25 draw 148:3 drive 66:6 76:22,24 96:5 drug 106:11 duly 5:4 170:13 duty 123:10,13 duty-bound 42:17 86:23 dynamic 16:3 E E 3:1 167:8 E.W 31:2 90:22,25 93:3 103:17 164:12 165:25 168:19 earlier 81:3 86:22 119:1 early 25:13 East 17:16,22 eat 80:6 economic 15:4 104:23 109:1 Ed 21:7 education 6:18 Edwards 1:8 4:7,21 4:22 5:23 30:6,21 34:6 36:22 49:1 49:24 50:1 I 51:9 54:12,17 87:21 99:25 100:11,14 110:17,20 111:16 112:7 116:20 117:6,18 118:10 118:18 123:2 125:2 126:13,23 130:13,17 135:15 135:24 136:7 137:23 138:4 139:7,20 140:4,7 140:25 141:18 142:3,17 144:3,5 144:7 147:3,14 148:3 149:24 152:15 154:12 155:1,5,11 156:4 156:12,17 158:10 161:7,8 162:18 164:7 166:13 167:9 168:19 Edwards' 154:23 effect 27:1,8 48:16 96:11,12,13,15,16 effectively 162:20 effort 36:18,23 37:19 38:1049:12 54:11 128:15 163:9 efforts 34:7 36:3,11 37:8 38:19 eight 28:11,22 either 9:23 18:19 19:21 20:4,25 42:19 89:7 91:7 92:16 102:1 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mean 19:7 32:1 56:7,11 60:18 61:8,9 71:9 73:2 73:10 76:3,17 79:17 80:17 82:25 83:1 84:3 113:10 121:1,24,25 125:14,15 129:13 132:11 141:7,7,10 141:23 142:23 152:10 153:14 159:21 meaning 27:20 128:9 means 82:21,22,22 83:3,4 113:1 132:12 134:2 meant 139:10 153:12,15 medium 108:13 meet 30:8 60:12,17 91:4,10 105:13 129:7 meeting 28:7,21 31:10 60:9 124:2 126:1,2 128:2 meetings 37:14 60:20 63:1 74:20 155:1,3 Mel 73:10,13 member 14:2 163:25 members 13:22 38:8 memory 60:7 mental 11:4,6 32:19 33:6 94:13,15,19 130:22 148:12 mentally 47:19 148:11,12,17 mentioned 3:17 41:14 60:23 69:1 86:22 101:19 109:16 111:21,23 116:2 119:25 merit 117:20 merits 91.20 met 30:9,11 31:10 34:9 89:10,11,13 91:6,8 97:12,17 101.10,14 124:5,6 method 132:2,13,23 133:1 Miami 7:2,4 8:7,8 8:15,19 24:16 28:13 35:1074:6 81:12 Michael 23:14 119:3,4,6,9 microscope 93:17 94:2 Mike 90:2,4 milking 57:21 million 23:2 63:11 75:17 76:1 77:4 86:14,20 116:25 millions 29:4 165:18 mind 47:17 65:7 147:24 150:7 158:18 164:21 mindset 33:13 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130:11 murder 143:23 murdered 143:20 murderers 111:25 N N3:1 name 4:11,20 5:12 21:9 152:8 named 18:14,14 21:3 35:24 153:3 153:4 names 41:14 62:24 national 16:14 43:16 nationally 38:21 natural 31:22 nature 9:6 32:14 37:17,25 64:11 104:17 NAUGHT 170:5 NBC 100:11 necessary 131:11,16 134:6 136:3 need 45:17 75:1 83:20,22,25 84:14 99:18 103:13 121:10 131:14 135:20 162:18 needed 10:22 11:22 11:25 16:24 26:6 negative 96:12,16 105:22,23 negatively 104:22 negotiating 129:17 129:20 130:7 network 38:6 never 34:9 50:7,7 53:22 68:14,15 85:17 92:18 101:18 102:19,20 117:3 145:8 156:24 new 2:12 8:19 19:17 57:20,21 165:18 168:9 news 30:3 newspaper 23:13 61:20 62:2 69:11 70:11 night 29:6 nine 28:11 non-lawyers 164:1 164:3.8 Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798389 182 non-prosecution 98:25 99:17 128:10 non-Rothstein 129:21 non-tort 79:14,20 79:24 Notary 170:21 note 83:13 noted 82:10 notes 36:6 131:1 171:10 notice 5:3 52:20 53:19 170:3 November 21:21,22 25:13,16,19 26:13 29:13 49:19 69:22 85:12 138:18 139:4 number 13:13 16:22 18:1,2,24 21:5 33:25 34:2 38:5 81:10 85:15 98:17 109:22 118:3,5,9 130:2,3 130:18 136:21 139:2 numbers 63:4 Nurik 62:23,23 111.1,5 155:8 NY 2:12 0 oath 3:10 5:5 170:7 object 37:22 38:3 42:8 45:18 50:14 52:12 54:8,18 61:24 66:1 70:1 77:7 92:7 105:25 106:15 117:8 120:19 135:25 137:9 156:21 158:25 161:24 163:13 164:19 167:4,17 168:3,14 168:24 objected 84:11 objection 56:6 58:13 59:17 62:4 62:14 75:4 77:15 80:23 82:14 84:7 87:12 92:10 100:3 107:2,16 108:15 109:12 111:3 112:10,20113:23 114:14 125:5 127:2 142:19 143:17 144:11 145:6 151:18 156:8 160:1,7,11 objections 84:12,15 objective 108:6 131:25 obligated 42:18 obligation 40:13 42:11.12 obligations 121:13 1, 1:” observations 134:18 observe 48:9 observed 42:3 88:7 obstacles 65:23 66:5 66:8 70:7 obtained 152:4 obviously 24:21 31:9,10 74:2 129:4 occasion 18:17 30:20 occur 132:2 occurred 25:14 42:24 70:25 71:15 occurring 50:8 81:24 October 22:4 27:16 27:22 64:18 67:9 67:12,16 68:3,7 off-duty 66:10 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104:2 112:6 123:7 151:2 152:9 part-time 19:12 partially 154:2 participant 43:19 50:12 114:8 138:5 150:19,22 participants 35:3 56:4 participate 52:20 127:22 129:17,20 130:5,6 153:7 participated 50:19 53:18 156:13 166:13 participating 44:18 60:8 particular 40:1 59:1 96:1,1 97:7,19 115:11 122:1 127:9,16 132:14 particularly 11:7 47:24 52:24 parties 38:13 99:15 170:2 171:12 parties' 171:13 partner 18:14,15 24:4,18 partners 24:1,13 parts 148:21,23 party 99:18 142:23 143:15 pass 65:22 passed 65:5 patently 147:2 pattern 40:2,22 41:11 43:5,10 133:15 patterns 43:21 Paul 34:8,19 35:1 pay 11:23 78:20 164:11 paycheck 26:2,13 paying 23:4 27:4 48:7 57:9,11 payoff 57:22 pen 145:25 pending 29:3 31:20 31:21 58:7,11 59:13 60:3 129:8 154:16 156:18 157:19,20 Pennsylvania 8:6 penthouse 165:19 people 7:19 9:11,12 16:23 19:24 22:16 24:6 26:3 27:25 28:8 38:5,7,20 44:3 52:19 58:24 66:24 68:13 71:5 72:12 74:16,16 96:21 102:11 106:22 108:7 110:10 125:10 132:8 137:5 159:13 people's 10:14 67:3 perceive 40:13 perception 22:5 44:22 45:10 period 9:21 19:5 26:7 29:24 30:16 Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798390 183 72:22 167:1 periodic 60:19 permitted 54:15 136:17 perpetrated 96:1 perpetrator 53:15 person 6:11 32:24 33:17 36:14 37:13 42:21,21,22 47:15 47:21 52:22,23 53:20 58:25 72:9 95:24 96:2,10 97:7,13 113:2 132:12,24 138:3 139:18 141:17 142:15,22 148:9 person's 96:14 personal 20:20 32:5 45:20 79:20 90:8 122:24 147:10 155:19,23,24 158:10 personally 79:19 102:1 115:23 122:24 170:12 persons 41:25 pertain 42:13 pharmaceutical 20:23 Philadelphia 8:6 philosophy 6:24 7:2 7:6,13,18 8:2 10:12 phone 97:14 phrase 65:12 132:11 phrases 163:16 physical 32:19 59:9 73:2 94:14,15 95:25 141:20 physically 47:7,19 58:16 59:7 pick 8:12 piece 61:11 Pike 119:3.4.9 134:20 Pike's 119:6 pilot 168:8 pilots 38:14 pimp 47:4,11 place 13:10 20:2,13 124:7 plaintiff 2:6,10 4:17 4:19,22 55:12 158:4 plaintiffs 3:13 85:15 86:25 97:6 118:5,8 136:21 Plaintiff/Counter-... I:6 plaintiffs 9:23,25 10:6 78:21 79:1 83:5 87:3 92:16 120:7 122:17 124:19 148:1 164:11,13 plane 42:20,20,24 42:24 43:2,4 166:6,7,8 168:8 planes 38:17,22,24 39:3,5 41:20 plans 7:14,17 played 30:14 playing 56:22 plea 45:22 51:16,20 51:22 52:5 54:4 54:15 please 4:14 5:9 6:2 9:8 11:2,18 18:9 26:15 37:25 66:16 69:18 82:21 95:22 112:24 118:4 133:25 145:22 147:7 150:10 153:20,21 157:2 pled 145:3,8 155:12 165:25 PLLC 2:11 plural 153:19 Podhurst 35:10 point 15:3 26:12 28:19 29:9 45:17 50:3 57:19 58:17 70:18 88:8,12 99:20 132:6 134:20 145:22 148:8 149:6 150:5 pointed 135:13 150:23 pointing 56:25 69:15 105:19 points 24:25 police 21:12,14 112:25 policy 71:14,21,22 73:17 74:7 Pond 29:11,16 49:17 50:6,12 55:19 56:4,15,19 56:21 57:2,4,6 59:15 78:19 79:13 82:8 137:21,25 138:5,21 139:21 140:5 141:1 142:18 147:4,13 147:13,16,21 148:3,20 149:25 151:10 153:1,8 154:9 158:17 159:1 165:10 167:12 pool 36:11 portion 157:21 portions 154:17 portrayed 16:3 position 9:7 10:9 14:13 18:5 23:22 23:24 28:20 33:23 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prostitute 46:23 47:3,3,4 101:14 101:17,20 105:8 106:9,10 prostitutes 46:10 prostitution 105:1 107:13 protect 49:12 75:1 163:5.11 protected 23:6 protecting 65:18 protection 134:7 135:18 prove 33:10 43:4 132:6 134:14 144:22,25 proveable 84:1 proven 133:16 provide 102:12 provided 101:23 providing 66:11 113:10 province 84:9 proving 132:5 prudent 139:18 pseudonym 31:5 pseudonyms 162:25 163:4.10 psychologist 108:7 public 14:19,24 Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798391 184 46:4,17 61:5 68:10 170:21 publicly 23:13,24 68:24 published 14:5 pull 115:22,25 116:1 pump 168:9 pumping 167:12 punish 34:3 punished 33:17 punitive 33:14,15 33:18,21 34:2,3 45:4 purpose 14:23 49:25 56:11 57:16 99:7 122:4 165:9 purposes 99:23,24 167:12 pursue 41:7 42:11 42:17 48:22 127:9 pursued 41:17 165:23.24 pursuing 42:645:14 put 39:21 59:25 70:8 94:1 105:24 121:9 152:14,18 0 quality 111.11 quantify 98:17 question 37:24 44:10,15 60:15 61:24 66:2 70:2 77:8 95:25 96:9 106:1,16 117:9 120:13 127:11 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21:9,12,1423:1 34:18 39:18 87:6 90:9 92:16,19 93:9 97:1 101:17 103:9 113:20,22 121:2 122:17 135:19 representing 4:12 9:23,25 21:7 32:17 33:24 34:17 35:6,7,18 39:8 43:20 48:2,25 51:19 53:14 55:12 88:20 90:11,22 115:1 116:19,22 120:7 126:22 represents 143:15 Reprographics 2:20 4:13 reputation 15:24 20:6 22:6 23:21 81:19,22,25 82:4 89:2 90:5 116:7 117:14 119:6 125:11 134:18 144:9,14,16 148:15,16 149:7 149:16.17,19 reputations 135:8 requested 171:8 requests 129:13,14 required 100:24 163:4 research 89:14,16 respect 15:19 16:12 20:15 81.6 132:15 respected 137:1 respective 170:2 response 122:8 140:10.13 147:8 150:11 responsibilities 12:25 14:11 30:21 responsibility 13:3 13:25 26:16 31:7 98:24 responsible 27:2,3,7 34:6 37:20 43:19 54:14 96:7 107:21 126:25 rest 6:8 148:24 161:2 restate 37:24 136:2 Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798392 185 restaurant 80:3,4 80:13 restaurants 80:8 result 11:25 46:15 resulted 146:25 149:21 results 13:17 résumé 12:22 retired 14:18 retrospect 29:23 50:3 return 57:9,22 revenue 63:5,7,11 63:13 reversals 20:11 reverse 110:12 reversed 20:10 109:17,19,22 review 12:21 13:19 13:22 108:7 113:14 117:4 129:11 141:2,5,10 141.12,14,21,23 141.23 171:7 reviewed 139:8 141:7 158:3,7 reviews 13:16 rewarding 10:16 ridden 68:20 ride 68:15 ridiculous 167:11 right 6:9 7:14 11:9 20:14,1422:2 30:19 45:25 52:13 52:20,25 53:3,4 53:17 55:22,23 60:25 61:13,14 62:13,15 64:11,12 71:17,2072:10 76:21 78:11 79:2 79:3 81:18,20 83:11,12 84:21 85:3,6 86:1,3,23 86:24 87:1,2,21 87:24,25 90:7 91:20 93:11,12,20 93:21 94:4,5,10 94:25 96:23,24 97:10 104:11 107:6 108:9 109:8 109:10,13 110:12 117:16 119:2 120:24 121:3,19 122:19,20124:2 124:13,18,24 125:19 126:4,9,14 126:19 135:24 136:23 142:11 143:11 144:23,24 145:1 146:19,20 147:6 149:11 150:25 151:13 153:5 154:7,10,11 158:16 159:14,15 129:24 130:6 137:1,16,25 138:5 138:13,16,17 139:21 140:5 141.1 142:18 says 86:8 134:12 162:17 164:10 scale 83:21 84:21 scam 57:6 59:8 scammed 58:24 154:9 155:20 156:13 158:17 159:2 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RRA 17:19,20 114:14 117:8 27:18,20,20 28:23 Rosenfeldt 15:6,14 21:17 22:9 23:22 118:14 120:18 29:10,19 50:12 16:2,7 17:6,20 24:20 25:13 34:7 122:6 125:5 55:11 60:5 68:6 19:19 28:12 29:20 34:12 36:17,24 126:20 127:2 68:19 71.3,12 56:17 62:21 68:6 55:21,24 56:9 128:24 129:1,4 80:10,14 82:7 137:17 160:10 78:14 153:2 131:8 133:20 118:10 138:13 161:22 162:9 168:10 135:3,5 136:1 148:12 Rosenfeldt's 15:13 rules 39:19 40:11 137:10 138:7 Scott's 64:21 71:1 rotates 14:13 165:4 139:10,14,17 72:15 Rothstein 1:8 4:6 run 26:23 140:9,12 141:8,11 seal 170:14 15:6 16:2,7 17:6,8 running 82:8 141:17 142:4,19 sealed 99:10,12 17:10,14,20 18:5 158:17 143:17 144:11 searches 165:2 19:25 22:12 23:16 Russell 62:21 145:6,10 147:7 Searcy 2:15 35:22 23:18 25:18,21,22 166:13 149:20 150:1,9 36:20 27:20 28:24 29:10 151:18 153:18 secluded 73:9 29:19,20 49:16 S 154:14 156:8,20 second 6:3,4 102:23 55:20,22 56:3,4 sail 76:17 157:2,6,13,20,24 141:6 151:8 152:9 56:12 57:6,24 SAITH 170:5 158:24 160:1,7,11 156:5 58:10,12 59:6,13 Sako 59:2 160:17,23 161:18 secondary 36:25 60:3,10,13 64:4,7 salary 63:19,25 162:1,3,5,12,16 secondhand 59:17 64:1065:13,18 64:3 163:18 165:1 62:4 80:24 82:15 66:14 68:6 69:3,5 sanctum 69:25 167:7,20 168:6,17 113:24 114:15 69:16 72:6 74:9 Santiago 2:21 4:11 169:1,4,7,11 127:21 74:17,19,25 77:22 sat 20:2 106:21 Scarola's 121:2,5 secrecy 69:2 78:2,18 79:4,7 Saturday 27:15 129:18 secret 69:4 80:1,6,9,21 81:16 28:3 scheme 29:11,16 secretary 73:15 82:7,10 86:14,19 save 157:2 49:17 50:7,13 74:13 90:22 92:15,25 saw 16:17,18 28:3 55:20 56:4,16,20 sections 160:18 97:21 98:15 100:1 52:18 53:4 60:16 56:21 57:3,4,6 security 65:4,5,6,9 100:8 101:22 60:22 64:14,16 59:15 78:19 79:13 65:10 66:11 70:9 102:11 107:10 69:15,20 118:12 82:8 137:21,25 70:15 72:9 73:14 110:24 111:1,5,13 118:14 138:5,21 139:21 74:16 112:13 113:21,22 saying 23:17 48:17 140:5 141:1 seduced 92:21 114:9,11,18 66:19 102:14 142:18 147:4,13 see 11:15 15:25 49:7 116:20 117:19 114:21 115:17 147:16,21 148:3 59:5 60:14 64:21 118:10 120:7 120:4 127:14,15 148:20 149:25 69:11,13 70:6 122:17 123:2,3 141.6 150:13 150:19,22 151:2 72:8 74:17 76:5 124:8 125:18 153:15 151:10 153:1,8 86:4,6 102:6 Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798393 186 114:13 115:3 118:13,22 123:19 123:25 127:5,16 131:1 140:22 146:21 148:24 152:19 seeing 27:4 62:2,7 123:20 seek 10:9 149:18 seeking 134:7 seen 24:15 72:25 85:17 118:11,16 119:17 select 7:6 selected 14:9 103:10 self-sufficient 57:16 semantics 56:23 senior 24:9 60:24 61:1 126:16 sense 11:5 32:4,10 83:25 92:21 115:10 sent 28:6 118:14 sentence 52:4 159:1 sentencing 52:24 53:1,20 Sentinel 23:15 separate 147:24 separation 148:4 serious 10:21 50:17 146:25 149:22 seriousness 48:12 served 9:4 12:11,12 12:18 13:11,12 Service 2:2 serviced 68:12 services 51:15 serving 14:8 set 6:3 69:17 74:8 116:25 setting 93:8,10 132:3 settle 45:7,9 78:4,13 86:15 130:14 164:13 settled 20:22 29:3 121:17 123:4,5,14 129:24 130:2,3,10 settlement 79:15 86:20 98:3 121:15 122:23 129:18,21 settlements 57:25 58:1 59:14 79:23 130:7 settling 121:5 seven 28:10,22 sex 92:22 sexual 42:5 92:6,11 92:17 93:4 94:7 96:2297:1 131:13 131:21 133:5 140:21 148:1,7,19 166:25 167:16 168:20 sexually 106:9 147:18 shape 147:16 share 30:20 31:6 36:15 37:5 69:23 124:11,17 128:3,4 164:1,2,7 shareholder 23:25 25:1,8 61:6,8,18 61:21 62:3,8,24 62:25 86:16,19 shareholders 24:1,7 24:12 28:8 60:20 60:23 62:17,20 shares 61:12,15 sharing 43:20 sheriff 66:11 SHIPLEY 2:15 shock 30:4 158:16 shocked 28:24 shoes 27:1 shooting 11:9 shop 7:18 shots 45:9 show40:2 117:24 133:14 145:20,22 149:15 showed 16:16 58:21 59:7 70:3 showing 69:24 70:11,14,19 shown 5:11 86:5 136:21 166:16 shows 162:6 sic 91:16 147:3 Sid 35:17 36:19 127:6 128:7 side 63:2 86:25 87:1 97:6,6 114:23,23 115:9,9 sides 10:4 signed 118:23 significance 39:12 52:9 95:23 104:12 132:25 133:10 significant 31:13,25 32:4,6,16,24 33:5 33:8 44:23 53:13 103:15 113:19 signing 170:3 similar 35:25 53:10 132:3,4,9 133:7 similarly 40:5 45:21 133:7 simple 142:14 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stellar 81:19,21 stenographic 171:9 stenographically 171:6 stepped 27:1 84:19 Stettin 26:8,10,17 27:9 Steve 16:8,10,19 17:4 21:3 56:16 62:22 stick 113:8 stipulated 170:2 STIPULATION 170:1 stole 152:21 stolen 27:9 Stone 13:11 20:1,6 20:15 22:23 23:5 stop 141:14 153:20 stopped 149:3 story 115:2 strange 65:17,20 strategize 128:4 strategizing 36:6 37:4 Streitfeld 26:9,19 26:20 62:22 strengths 97:23 104:5 stress 95:12 stricken 92:9 strike 88:5 162:11 162:14 163:14 164:20 167:5,18 168:4,15 strong 103:5 108:13 structured 79:23 structuring 155:10 Stuart 15:13,14,18 Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798394 187 15:19,20,25 16:25 16:25 17:7 28:11 56:16 62:21 68:6 68:18 study 6:20 14:19 stuff 77:25 stunned 50:22 51:10 subjective 108:4,5 108:10 submit 133:5 subparagraph 164:10 167:8,22 168:7 subpoenas 41:24,25 substance 57:19 substantial 11:23 133:4 successful 23:7 55:15 sue 82:10 135:24 137:12,16 138:12 138:12 139:7 140:7 144:2 sued 50:18 93:12 137:1,6,19 148:11 sues 143:20,24 suffered 32:18 94:24 suggest 135:18 suggested 161:19 suggestion 161:11 suing 9:11,12 23:10 32:24 54:17 121:25 138:4 140:16 suit 5:24 17:17,18 130:14 135:14 136:6 139:9,12,13 Suite 1:21 2:3,74:9 suits 147:25 summer 13:9 sums 133:4 Sun 23:15 Sunday 25:16 28:5 28:5 support 7:21 117:6 supposed 42:16 121:18 Supreme 14:10,11 14:15,18 sure 4:16 19:14 60:5 61:12 62:23 76:14,25 79:16 80:25 83:8,10 85:5 104:13 121:24 124:17 125:7 128:4 130:4 146:8 157:1 surgery 6:6,10 55:14 surprise 51:8 74:23 102:5.8,9 117:18 surprised 74:22 159:6 surprising 93:22 surrounded 38:7 surrounding 27:13 surveillance 66:13 67:3,15,20 suspect 86:9 158:12 suspected 49:22 suspicion 29:18 50:5 138:2 sworn 5:4 112:14,18 113:11 114:10 115:1 123:15 150:20 151:5 170:13 Syracuse 6:21 system 53:11 122:11 T table 121:9 tactics 148:19 take 15:22 26:22 27:6 34:2 54:23 96:3 104:4,14,16 105:16 108:10 112:18 114:12 117:24 118:21,22 122:20 130:24 135:21 137:4 146:7 152:13 taken 1:18 2:14:24 5:13,15,23 20:2 37:9 146:11 takes 8:20 84:21 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114:18,19 161:6 terrible 32:2 33:6 test 15:22 testament 23:21 testified 5:5 102:6 146:3 testifying 120:15 133:17 testimony 30:14 56:5 106:6 107:15 113:21 114:11 115:2,24 120:6,20 120:22 123:15 133:19 142:5 147:25 150:21,23 151:5,8 thank 6:9,14 54:20 55:16 84:17 138:7 157:6 169:4 Theoretically 94:11 149:14 thing 10:11 22:11 24:23 52:14 73:7 84:14 88:9,12 104:19 114:20 133:18 150:18 158:21 159:11,12 things 10:8 24:21 32:2 33:12 39:9 43:24 46:16 47:12 48:19 55:19 58:25 64:10,11 70:11 71:18 74:11 77:22 81:14 94:16 95:1 97:5 98:20 105:16 105:16 123:11 150:20 159:17 1661 think 19:25 20:7 21:14 22:7 28:7 29:13 31:12,18,23 34:21,23 37:12 40:17,22 42:18 45:22 48:15 51:19 58:17 62:19 65:17 77:1 82:16,18 84:20 89:9,10 100:20 110:20 111:8,11 112:7 113:25 114:3,19 115:5,6 119:20 120:13 124:5,6 126:19,21 127:24 130:1 134:24 136:8 139:7,10 143:9 144:13 148:5,9 152:2 158:13 169:3 thinking 17:2 139:23 thinks 122:1 third 9:19 38:13 99:15,18 thought 8:1 22:15 23:20 53:12,21 65:20 67:1 84:24 85:3,8 88:10,13 89:18 98:2 116:10 119:10 120:1 139:14 154:5 158:18 159:24 thousand 63:18 threaten 47:7 threatened 110:14 110:18.22 111:2 three 8:11 10:25 13:20,21 27:21 30:10,24 31:1 32:3 34:5,18 35:6 39:12,13,18,19 40:25 43:20 49:13 51:12,19 58:11 59:7,13,21 60:3 63:18 86:15 88:16 91:8,9 92:14 93:4 93:5 97:12,22 98:2,6,14 99:19 101:21 102:4,5,10 105:13 107:11 108:11 110:10 111:12 112:12 118:4 120:7 122:16 129:24 147:5 156:7,18 158:4 167:25 thumb 47:6 tickets 80:18 ties 43:18 time 4:2 7:8,9 9:21 10:3 14:14 15:16 16:5 17:19 18:12 18:21,23 19:5 22:3 23:11 29:9 29:24 30:14 31:11 38:23 39:8,9,19 48:1 49:15,21 50:4 54:3 55:6 60:2 64:9,15 65:8 65:8 69:18,20 71:14,18 72:20,22 74:15 78:13,21 80:1 83:14 86:14 86:18 88:7 89:11 89:13 90:7,21 91:6 98:2,14 99:2 101:22 102:3,6 114:20 115:15 116:19,23 123:1 124:5,19 126:4,13 127:13 130:22 131:6 134:21 144:20 145:21 146:13,17 154:6 154:15 158:5 163:3,6,20 167:1 169:6 times 20:12 65:6 72:18 106:13 109:17,18,19,22 109:25 110:5,7 Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798395 188 138:20 timing 72:19 today 5:14 6:13 11:3 29:23 50:2,9 55:17 60:8 147:25 155:18 told 9:24 10:23 17:1 19:19 25:12 30:13 44:21 91.19,22 102:17 111:25 113:9 114:2 135:23 136:4 151.11 154:5 165:7 Tomorrow's 11:8 Tony 80:11,13 top 126:6 Torah 71:10 tort 78:7,8,10 79:14 79:18,18,23 total 18:24 19:1 30:4 63:10 totally 96:22 touched 92:20 95:2 touching 94:17 tough 111:16 town 6:6 track 38:15,24 training 44:22 transaction 52:10 transcript 113:14 169:9 171:8,8 transcripts 115:22 116:1 transfer 117:1 transferred 6:22 transition 27:5 transported 39:5 166:53 trauma 32:20 106:11 Traurig 8:17 28:14 73:11 traveled 74:19 Treasure 13:7 tremendous 20:6 trial 6:11 12:8,22 13:17,18 14:17,20 23:5 39:2040:9 84:13,15 109:16 111.16 126:6,9 tried 6:3 41:24 106:22 111:19 triple 18:19 trolled 103:9 troubled 105:6 true 103:6,21 105:7 125:4 140:17 143:7 144:23 150:15 151:9 152:19 153:24 154:2 155:18,21 156:7 158:9,19,20 159:18,19 167:14 171:9 trust 29:1,15 trusted 159:16 truth 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158:10 Villegas 138:13 violation 165:3 violently 92:21 visually 70:5 voice 84:6 voluntarily 106:13 106:19 168:20 volunteering 51:14 voting 14:20,25 vs 1:7 waiting 18:2 waive 124:12 134:7 135:20 waived 170:4 waives 169:11 walk 65:24,25 69:13 70:4 71:2,25 72:8 72:14 73:13 walked 71:3,12 want 6:15 54:23 64:15 91:24,25 99:13,23 104:9 131:9 143:23 152:12,14,18 156:4 160:22 161:2 wanted 47:8,9,10 99:21 101:2 157:18 Washington 19:15 wasn't 19:16 24:2,4 27:24 28:1 32:19 37:2 48:5 55:23 55:25 56:2 59:4 65:24 67:15 68:10 68:24 70:17 72:13 72:18,20 75:11 78:8 94:15 99:11 122:24 123:1,2 124:7 125:23 126:16 132:3 141:3 147:9 148:16 152:6 159:21 161:14 watching 106:11 water 75:13 77:14 way 31:3 44:7 49:9 59:10 64:10 70:15 74:8 92:3 93:15 109:10 116:15 118:1 122:11 140:6 144:1 147:16 148:21 150:14 155:20 156:6 159:24 162:7 We're 148:11 we've 87:20 weak 103:5 108:13 112:3 167:24 weaknesses 97:24 104:6 wealthy 33:15,17 wear 65:11 Wednesday 27:22 week 25:24 27:22 weeks 6:3,5 Weiss 5:15,19 8:24 Wells 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32:3,21 33:4,24 34:18 35:8 38:24 39:2,7 39:7,19,2 I 40:20 46:2,5 47:18,25 48:22 92:19,20 93:6,7,9,15 95:11 96:25 101:16 104:18,24 107:18 women's 46:11 94:1 won 23:4 words 164:22 work 5:16 9:9,12 12:23,23 17:3 22:11,13,13 31:12 31:22,23 98:18,19 103:5,7 124:12 worked 13:4 22:23 30:23 38:9 73:10 74:5 81:11 101:20 111:5 159:16 working 19:21 34:10 36:3 41:22 78:2 79:8 97:22 101:14 104:7 110:25 112:12 123:2 works 11:7 world 69:4,24 73:12 140:6 142:2 144:1 150:14 154:2,4 worse 85:7 105:5,9 105:11 worth 91:21 95:21 wouldn't 48:14 62:8 65:7 74:21,23 95:3 104:15 121:8 121:10 123:13 158:12 161:16 wrap 131:1 write 86:10 152:15 writing 14:1 36:9 42:15 115:5 written 69:10 115:8 123:22,24 146:18 153:11 wrong 30:1 52:5 143:11,21 wrongdoer 52:22 wrongdoing 32:11 38:2 40:4 121:7 wrongful 120:3,8,17 143:24 148:1 wrongs 54:14 wrote 13:13 14:4 15:21 59:1 X X 3:1 63:5 Y yacht 76:14,16,18 76:19 yeah 18:19 22:1 27:21 35:6 45:19 65:14,20 72:4 81:7,9 83:25 85:4 98:22 105:19 110:13 111:18 113:13 117:17 119:5 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63:11 85 3:16 8th 21:21 9 9/11 16:12 Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798397 19C 9:27 1:21 4:3 90 76:20 90-foot 76:B.15.16 77:4,14 90.404 39:24 90s 9:14 Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798398