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Page 1 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE No. 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff, - vs - SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and ., individually, Defendants. VIDEOTAPED DEPOSITION OF JEFFREY EPSTEIN Wednesday, March 17, 2010 10:17 a.m.- 1:27 p.m. 303 Banyan Boulevard Suite 400 West Palm Beach, Florida 33401 Reported By: Sandra W. Townsend, FPR Notary Public, State of Florida West Palm Beach Office Job 41358 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 iddcfb&Cb324-4437-a670-765e29067145 EFTA01076611 ) EFTA01076612 aye APPEARANCES: 2 On behalf of the Plaintiff 3 MICHAEL PIKE, ESQUIRE BURMAN CFUTTON LUEIER & COLEMAN, 11? 1 303 Banyan Boulevard, Suite 400 West Pailikirda 33401 Phone: 0 On behalf of the Defendant Bradley Edwards: JACK SCAROLA, ESQUIRE SEARCY, DENNEY, SCAROLA, BARNFIART & SHIPLEY 2139 Palm Beach Lakes Boulevard West ' 33409 10 Photo: 11. Oat:chaff° the 12 BRADLEY EDWARDS,I II‘IRE FARMER, JAFFE, WESSINO, EDWARDS, HMS, 13 & LEEMAN, Pl. 425 North Andrews Avenue 14 Suite 2 Fon Lt. 33301 15 Phone: 16 Also Present 11 STEVEN JAFFE, ESQUIRE FARMER, JAFFE, WEISER:I, EDWARDS, Ftb ILb 78 & LEHRMAN, P.L. 425 North Andrews Avenue 19 Suite 2 20 Fon Lit da 33301 Phcoe: 21 22 23 24 25 Page 4 PROCEEDINGS 2 3 Deposition taken before Sandra W. Townsend, Court 4 Reporter and Notary Public in and for the State of 5 Florida at Large, in the above cause. 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 VIDDOGRAPHER: We are now on video record. This is media number one in the videotaped deposition of Jeffrey Epstein in the matter of Jeffrey Epstein versus Scott Rothstein, Bradley Edwards and M. Today is Wednesday, March 17,2010 at 10:17 am. We are at the law offices of Burman, Critton — Banyan — of Burman, Critton on Banyan Boulevard, Suite 400, West Palm Beach, Florida. My name is Joe Kozak. I'm the videographcr. The court reporter is Sandra Townsend from Prose Court Reporting Agency. Would Counsel please introduce yourselves and then the court reporter will swear in the witness. MR. SCAROLA: My name is Jack Scarola. I am Counsel on behalf of Brad Edwards in his capacity, both as Defendant and Counter-Plaintiff in this action. Mr. Edwards is present with me. I 2 3 Page 3 - - - EXHIBITS NUMBER DESCRIPTION PAGE Exhibit number 1 Eyeglasses 133 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 5 1 MR. PIKE: Michael Pike, on behalf of the 2 Plaintiff, Jeffrey Epstein. 3 MR. EDWARDS: Brad Edwards, on behalf of the 4 Defendant, M . 5 Also present Steve Jaffe, on behalf of the 6 Defendant, M., as well. 7 THEREUPON, 8 JEFFREY EPSTEIN, 9 having been first duly sworn or affirmed, was examined 10 and testified as follows: 11 THE WITNESS: Yes, I do. Thank you. 12 MR. PIKE: Before we get started, Jack, I just 13 wanted to get on the record, I just want to make 14 sure that you received this letter that I sent to 15 your office yesterday of March 16, 2010. 16 MR. SCAROLA: !did receive the letter. 17 MR. PIKE: Okay. And we're still on for 18 Mr. Edwards' deposition, as we sit here today? 19 MR. SCAROLA: That's correct. 20 MR. PIKE: Okay. Thank you. 21 DIRECT EXAMINATION 22 BY MR. SCAROLA: 23 Q. Please state your full name and your current 24 residence address. 25 A. My name is Jeffrey Epstein. Pm currently PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 2 (Pages 2 to 5) 1 ddefb84-b324-4437.4t670.766e29067146 EFTA01076613 Page 6 Page 8 i residing at 358 El BriIto in Palm Beach. 2 Q. How long have you resided at that location, 3 Mr. Epstein? 4 A. I'm sorry. On advice of Counsel today, I'm 5 going to take the Fifth, Sixth and 14th Amendment with 6 respect to that question, Mr. Scarola. 7 Q. Have you maintained any other residences over 8 the course of the last five years? 9 A. Though I'd I lice to answer each and every one 10 of your questions here today, with respect to that 11 question 15n going to have to assert my Constitutional 12 Rights as provided by the Sixth, 14th and Sixth -- 13 Fifth — sorry — Fifth, Sixth and 14th Amendment. 14 Q. Does anyone reside with you at the El Milo 15 address? 16 A. Again, Mr. Scarola, though Pd like to answer 17 each and every one of your questions here today, at 18 least with respect to that question, I'm going to have 19 to assert my rights as under the Sixth, Fifth and 14th 20 Amendment. 21 And I've been advised by Counsel, though I'd 22 lute to answer these questions, if I do so, I risk 23 losing their representation. 24 Q. What did your lawyer tell you in that regard? 25 MR. PIKE: I'm going to instruct you not to 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 your questions here today. However, on advice of Counsel, I'm going to have to assert my Fifth. Sixth and 14th Amendment Right. Q. Are you a Plaintiff in a lawsuit against Scott Rothstein, Bradley J. Edwards and an individual identified by the initials In, A. Yes, sir, l am. Q. Who is the individual identified ass? A. I believe from depositions that I've read her full name is M. Q. When and under what circumstances did you first meet the individual referenced by the initials A. Mr. Scarola, I think you arc awarc these questions are simply designed to have me invoke my Fifth Amendment, Sixth Amendment and 14th Amendment Right in relation to other questions and other cases But in response to your question, I'm going to have to invoke my right not to testify. Q. Do you know the individual named ■ identified by the initials Ini? A. Mr. Scarola, at least today -- I would like to answer that question; however, today, on advice of Counsel, I'm going to have to refuse to answer that question. Page 7 1 answer that question. Attomey/client. 2 BY MR. SCAROLA: 3 Q. Well, didn't you just tell me that your lawyer 4 advised you that if you answered questions he wouldn't 5 represent you anymore? 6 MR. PIKE: Mat's exactly what he said, 7 Mr. Scarola, and Pm instructing him not to answer 8 the question. 9 BY MR. SCAROLA: 10 Q. Okay. So I want to know then — I want to 11 know what your lawyer told you about that. 12 MR. PIKE: I'm going to instruct you not to 13 answer that question. Attorney/client. 14 MR. SCAROLA: And it is our contention, 15 obviously, that by making the statement that he has 16 made, Mr. Epstein has waived any attorney/client 17 privilege with regard to that matter. 18 MR. PIKE: Your contention, definitely not 19 mine. 20 BY MR. SCAROLA: 21 Q. Mr. Epstein, who else has shared that 22 residence with you at any time over the course of the 23 last five years? 24 A. Again, Mr. Scarola, I'd like to answer that 25 question, as Pd like to answer each and every one of Page 9 1 Q. Have you ever acknowledged in the presence of 2 any other person knowing the individual identified by 3 the Initials M.? 4 MR. PIKE: Form. 5 THE WITNESS: Again? Sony. Can you repeat 6 the question, sir? 7 BY MR. SCAROLA: 8 Q. Yes, sir. Have you ever acknowledged in the 9 presence of any other person knowing the individual 10 identified by the initials M.? 11 MR. PIKE: Perm. Also could invade 12 attomey/client. 13 11-16 WITNESS: Again, I would like to answer 14 that question, but today I'm going to have to 15 Invoke my Fifth Amendment, Sixth Amendment and l,ttn 16 Amendment Right. 17 BY MR. SCAROLA: 18 Q. Have you ever acknowledged in the presence of 19 any person, other than your ownlw,=, having known the 20 individual identified by the initials M.? 21 MR. PIKE: Form. 22 THE WITNESS: Again, I'd late to answer each 23 and every one of your questions here today, 24 Mr. Scarola; however, on advice of Counsel, at 25 least today, fm going to have to reflate to answer PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3 (Pages 6 to 9) lcIdcf b84 .12 24 al 4 37-a6 70-76 Se 29067145 EFTA01076614 Page lU 1 that question. 2 BY MR. SCAROLA: 3 Q. Have you ever acknowledged to -- 4 A. Excuse me. 5 Q. --Bradley- 6 A. Sir, may I suggest that if I say I refuse to 7 answer, that it means the Fifth, Sixth and 14th or would 8 you prefer that I recite it each time? 9 Q. I would prefer that you answer the questions, 10 that's my preference. But if you're going to assert a 11 privilege, I will assume that if you simply say that you 12 are refusing to answer, your refusal to answer will be 13 on the basis of various Constitutional privileges 14 against self-incrimination without the necessity of 15 specifying, 16 If your refusal to answer is on the basis of 17 any other privilege, it will be necessary for you to 18 identify that privilege. 19 A. ThanIcyou. 20 MR. PIKE: And Pm going to instruct you, too, 21 when you do invoke, invoke the Fifth, Sixth and the 22 14th. 23 THE WITNESS: Yes. 24 BY MR. SCAROLA: 25 Q. Have you ever acknowledged in the presence of Page 12 1 invoke my Fifth, Sixth and 14th Amendment Right. 2 Q. Have you ever acknowledged in the presence of 3 Terri Becker, a court reporter present at a deposition 4 taken by Brad Edwards in a — in a case in which the S individual identified by the initials' was a 6 Plaintiff that you knew and/or liked — 7 MR. PiKE: Form. 8 THE WITNESS: Again, -- 9 BY MR. SCAROLA: 10 Q. 11 MR. Same objection. 12 THE WITNESS: Again, I'm going to have to 13 assert my Fifth, Sixth and 14th Amendment Right. 14 BY MR. SCAROLA: 15 Q. Have you ever acknowledged in the presence of 16 Steve Jaffe that you knew and/or liked a ? 17 A. Again, Mr. Scarola, though I'd I c to answer 18 each and every one of your questions today, Pm going to 19 have to, at the advice of Counsel, invoke my Fifth, 20 Sixth and 14th Amendment Right. 21' Q. Why are you suing.? 22 MR. PIKE: Form. 23 MR. SCAROLA: Let me state for the record that 24 I don't consider a form objection to be a proper 25 objection, unless you specify the defect in the 1 2 3 4 5 6 7 9 10 11 12 13 14 15 16 17. 18 19 20. 21 22 23 24 25 Page 11 Bradley J. Edwards that you knew the individual identified by the initials.? A. Pm going to have to refuse to answer that question. Q. Have you ever acknowledged in the presence of Bradley J. Edwards that you knew.? MR. PIKE: Again, for purposes of the record, I'm instructing you to invoke the Fifth, Sixth and 14th, rather than just simply say -- THE WITNESS: Okay. MR. PIKE: —I refuse to answer. I want it to be clear for the Court that you have invoked your Fifth, Sixth and 14th. THE WITNESS: Fine. Then on advice of Counsel, I'm going to have to invoice my Fifth, Sixth and 14th Amendment Right. BY MR. SCAROLA: Q. Have you ever acknowledged in Brad Edwards' presence that you liked the individual identified by the initials.? A. Again, Pm going to have to invoke my Fifth, Sixth and 14th Amendment Right, Mr. Scarola. Q. Have you ever acknowledged in Bradley Edwards' presence that you liked A. Again, Mr. Scarola, fm going to have to 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 13 form and provide me with an opportunity to correct the defect. MR. PIKE: That's fine. I believe the rules provide otherwise. But, nonetheless, i stand on my objection to form. THE WITNESS: Pm sorry. You have to repeat the question. BY MR. SCAROLA: Q. Why are you suing M? MR. PIKE: Fonn. 11W WITNESS: is part of a conspiracy with Scott Rothstein, ley Edwards, creating -- excuse me — creating fraudulent cases of a sexually charged nature in which the U.S. Attorney has already charged the firm of Rothstein, a firm of which Bradley Edwards is a partner, was a partner, with creating, fabricating malicious cases of a sexual nature, including cases with respect to me, specifically, in order to fleece unsuspecting investors in South Florida out of millions of dollars. BY MR. SCAROLA: Q. What role do you contend =. played in that conspiracy to create fraudulent cases A. testimony before she met Mr. Edwards (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 ••• 4 (Pages 10 to 13 MIIIIIIIMIOMI 1ddc1b84-b324-4437-a670-765029067145 EFTA01076615 2 3 4 5 6 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 14 was dramatically -- sworn testimony to the FBI was dramatically different after she came in contact with Mr. Bradley Edwards, where her testimony then changed to sort of a hostile and had claims of -- claims never made before, never made to anyone before, and allegations that i've read in her Complaint that that had been dramatically different from the ones she had spoken to the FBI about, sir. Q Is it your contention that as statement to the FBI was true? MR. PIKE: Form. THE WITNESS: Mr. Scarola, unfortunately, today with respect to that question, iin going to have to assert my Fifth, Sixth and 14th Amendment Right. Though I know — I believe you know the answer to that question, I can't answer the question under advice of Counsel. And hes told me if i chose to do so, I risk losing his representation. BY MR. SCAROLA: Q. What is the basis of your belief that i know the answer to the question? MR. PIKE: Form. THE WITNESS: You — I believe you have seen this, because you're supposed to be a decent 1 2 3 4 5 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 16 according to you, she met Mr. Edwards and changed her testimony, true? A. Did she change her testimony? Is that — yes, her testimony was changed. Q. My question to you is: Was her testimony which you contend was changed true testimony? A. Your question is not a good question. Is it her testimony before or after? Q. Was the subsequent testimony given by after she met Mr. Edwards which you contend was different from her testimony before the FBI, was the subsequent testimony true or false? MR. PIKE Form. THE WITNESS: Sr, I'm going, at least today, Pm going to have to assert my Fifth, Sixth and 14th Amendment Right BY MR. SCAROLA: Q. Did you ever engage in any sexual conduct with . I would like to answer that question, but — Q. You don't need to tell me what you'd like to do, Mr. Epstein. You just need to do it, please. THE WITNESS: Please — MR. PIKE Mr. Smola, please let the witness finish his response. Page 15 1 lawyer, youfve read the testimony. I would guess 2 you've read the difference in her testimony to the 3 FBI versus her testimony after she's met your 4 client and his partners, who are currently in jail. 5 BY tvfit. SCAROLA: 6 Q. How does that respond to my question as to 7 whether you contend that her testimony to the FBI was 8 true or false? 9 MR. PIKE: Form. 10 THE WITNESS: I don't believe that was your 11 question. Will you repeat? 12 BY MR. SCAROLA: 13 Q. Okay. Well, let's let me rephrase the 14 question then. 15 Is it your contention that M.'s statement to 16 the FBI was true? 17 A. Sr, on advice of Counsel, at least today, Pm 18 going to have to assert my Fifth, Sixth and 14th 19 Amendment ejR tt. 20 Q. Was M.'s statement to the FBI false in any 21 respect? 22 A. Sir, at least, again, today, on advice of 23 Counsel, Pm going to have to assert my Fifth, Sixth and 24 14th Amendment Right. 25 Q. Was .'s subsequent testimony after, 1 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 17 MR. SCAROLA: That's not a response to my question. MR. PIKE: In your mind it may not be a response. In a Judge's mind, it may be. We may have to certify it to the Court. If such a procedure even exists, we can take it up with the Court. But please let the witness finish his response. THE WITNESS: Again, please? BY MR. SCAROLA: Q. Did you engage — ever engage in any sexual conduct with M7 A. I would u e to answer that question; however, today Pm going to have to assert my rights as provided by the Fifth, Sixth and 14th Amendment to that question, sir. Q. Have you ever exchanged anything of value with MR. PiKE: Form. THE WITNESS: At least today, I'm going to have to assert my Fifth, Sixth and 14th Amendment Right, sir. BY MR. SCAROLA: Q. Did you ever direct anyone to deliver anything of value to .7 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 5 (Pages 14 to 17) ickklb844424443741170466•29067145 EFTA01076616 Page 18 Page MIL PIKE: Form. THE WITNESS: At least today, I'm going to 3 have to refuse to answer that question based on the 4 Fifth, Sixth and 14th Amendment 5 BY MR. SCAROLA: 6 Q. Do you Imow A. At least today, sir, 1'm going to have to 3 refuse to testify about that question. Based on advice 9 of Counsel, I'm going to have to assert my Fifth, Sixth 10 and 14th Amendment Ri t. 11 Q. Di introduce you to M.? 12 A. Sir, nape...tfully, I'd like to answer that 13 question today. As I said, I'd like to answer each and 14 every one of your questions. However, on advice of my 15 Counsel today, inn going to have to assert my Fifth, 16 Sixth and 14th Amendment Right. 17 Q. Did M. suffer any dama ts a consequence of 18 any interaction between you and M.? 19 MR. PIKE: Form. 20 THE WITNESS: Could you repeat the question, 21 please? 22 BY MR. SCAROLA: 23 Q. Did IN. suffer any damage as a consequence of 24 any interaction between you and M.? 25 MR. PIKE: Form. 1 which is outrageous. 2 BY MR. SCAROLA: 3 Q. How much have you settled claims for? 4 MR. PIKE: ism going to instruct you not to 5 answer that question. 6 MR. SCAROLA: And the basis of that 7 instruction is? 8 MR. PIKE: Confidential settlement agreements. 9 to the extent that they exist. And the terms would 10 be confidential. 11 BY MR. SCAROLA: 12 Q. Have you settled claims? 13 A. Yes, l have. 14 Q. What is the nature of the claims you settled? 15 MR. PIKE: Pm going to instruct you not to 16 answer that question. 17 BY MR. SCAROLA: 18 Q. How many claims have you settled? 19 MR. PIKE: IN going to instruct you not to 20 answer that question as well. 21 MR. SCAROLA: What is the basis for those 22 instructions? 23 MR. PIKE: Confidential, as well as there is a 24 VICTIM'S Right Statute that may — you may be 25 tiptoeing into the identity of - Page 19 1 THE WITNESS: I'd hie to answer each and 2 every one of your questions here today, 3 Mr. Scarola; however, on advice of Counsel, today, 4 Pm going to have to assert my Fifth, Sixth and 5 14th Amendment Right. 6 BY MR. SCAROLA: Your Complaint in this action alleges that 8 . made claims for damages out of proportion to her 9 alleged damages. What does that mean? 10 A. It means what it says. 11 Q. I don't understand it. Explain it to me. 12 MR. PiKE: To the extent you can answer that 13 question without disclosing my conversations with 14 you or Mr. Critton's conversations with you, as 15 well as my work product, you can answer the 16 question. 17 THE WITNESS: I believe that as part of the 18 scheme to defraud investors in South Florida out of 19 millions of dollars, claims of outrageous sums of 20 money were made on behalf of alleged victims across 21 the board. And the only way — in fact, Scott 22 Rothstein sits in jail. And what I've read in the 23 paper, claims that I've settled cases for 24 S200-million, which is totally not true. 25 She has made claims of serious sum of money, Page 21 1 MR. SCAROLA: Pm not tiptoeing anywhere. 2 MR. PIKE: Let me finish my objection, 3 Mr. Scarola. 4 You may be tiptoeing into the identity of 5 various alleged victims underneath the Victims 6 Right Statute, as well as ongoing investigations or 7 past investigations that have remained open with the State, as well as the Federal Government. 9 So in that regard, we would have to put the 10 State Attorney, as well as the Federal Government 11 on notice that you were seeking to potentially back 12 door certain identities at this deposition. 13 BY MR. SCAROLA: 14 Q. Other than having allegedly given different 15 testimony before she met Mr. Edwards then given after 16 she met Mr. Edwards, did S do anything else that 17 forms the basis for your claim against her? 18 MR. PUCE: Form. Asked and answered. 19 THE WITNESS: I'd like to answer that 20 question, as well as every one of your questions 21 with respect to M. here today; however, on advice 22 of Counsel, at least today, Mr. Scarola, Pm going 23 to have to assert my Sixth Amendment, Fifth 24 A•essIntent and 14th Amendment Right. 25 BY MR. SCAROLA: PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401M Electronically signed by Sandra Townsend (401 6 (Pages 18 to 21) tddctb84•b324-4437-a670.765o29067145 EFTA01076617 Page 22 1 Q. Did fail to do anything that she had an 2 obligation, duty or responsibility to do 3 MR. PIKE: Form. 4 BY MR. SCAROLA: 5 Q. — that forms the basis for your claim against her? 7 MR. PIKE: I apologize. Form. 8 THE WITNESS: Again? I'm sorry. Has she 9 failed to do? Can you repeat? 10 BY MR. SCAROLA: 11 Q. Yes, sir. Lawsuits are generally based, civil 12 lawsuits are generally based on a claim that someone has 13 done something that they shouldn't have done or failed 14 to do something that they should have done. 15 I asked you whether did anything that she 16 shouldn't have done and you asserted a Fifth Amendment 17 privilege in refusing to answer that question. 18 I'm now attempting to find out whether ■. 19 failed to do something that she should have done that 20 forms the basis of your claims against her. 21 Did M. do anything that she should have done 22 that forms the basis of your claims against her? 23 MR. PIKE: Form. 24 THE WITNESS: On advice of Counsel, at least 25 today, Mr. Scarola, Pm going to have to refuse to Page 24 1 MR. PIKE: Mr. Scarola, that's the second time 2 that I'm going to ask you not to interrupt the 3 witness when he's giving a response. He is giving 4 a response. When he finishes his response, you can 5 go on with your next question or you can — you can 6 elicit any sort of information you intend to elicit 7 from the witness. 8 MR. SCAROLA: He's being unresponsive. 9 MR. PIKE: No, that's your contention. 10 MR. SCAROLA: No, that's a fact. 11 MR. PIKE: And you can take it up with a 12 Judge. And if we want to continue going back and 13 forth and bantering, not allowing the witness to 14 answer the question — we're here for you today, 15 for you to ask the questions and for you to get 16 answers. But if you continue to banter with the 17 witness and interrupt the witness, I will adjourn 18 the deposition. This is not proper and we 19 certainly can take it up with the Judge. So that's 20 the second warning, Mr. Scarola. Please — 21 MR. SCAROLA: How many do I get? 22 MR. PIKE: Inn not sure yet today. 2 3 MR. SCAROLA: Okay. 24 MR. PIKE: Okay? 25 MR. SCAROLA: Good. Then let's move on. Page 23 1 answer that question based on my Fifth Amendment, 1 2 Sixth Amendment and 14th Amendment Right. 2 BY MR. SCAROLA: 3 4 Q. Did Brad Edwards do anything that he shouldn't 4 have done that forms the basis of your lawsuit against 5 6 him? 6 MR. PIKE: Form. 7 8 THE WITNESS: Yes, many things. 8 9 BY MR. SCAROLA: 9 10 Q. List them forme, please. 10 11 A. He has — he has gone to the media out of, I 11 12 believe, in an attempt to gin up these allegations. Ho 12 13 has contacted the media. He has used the media for his 13 14 own purposes. He has brought discovery — he has 14 15 engaged in discovery proceedings that bear no 15 16 relationship to any case filed against me by any of his 16 17 clients. 17 18 His firm, which he's the partner of, has been 18 19 accused of forging a Federal Judge's signature. 19 20 Q. I want to know what Mr. Edwards — 20 21 MR. PIKE: One second. 21 22 THE WITNESS: Excuse me. I'm answering. 22 23 BY MR. SCAROLA: 23 24 Q. I %nut to know what Mr. Edwards did. I'm not 24 25 asking you about allegations concerning his law firm. 25 Page 25 MR. PIKE: But I can tell you one thing: On a professional nature, just because you are interrupting the witness and bantering with me, I will adjourn the deposition. BY MR. SCAROLA: Q. Besides having gone to the media in an attempt to, quote, gin up, unquote, these allegations and engaged in what you contend to be irrelevant discovery proceedings, what else did Mr. Edwards, personally, do that forms the basis for this lawsuit? A. Mr. Edwards, personally, engaged with his partners, Scott Rothstein, who sits in a Federal jail cell, potentially for the rest of his life, he shared information, what I've been told and — excuse me — what I've read in the newspapers, 13 boxes of information that had my name on it, with other attorneys at his fum Ho counseled his clients to maintain a position alleging multi-million dollar damages in order for them to scam local investors out of millions of dollars. He and his — many of his other partners already under investigation by the FBI and the U.S. Attorney have been accused by the U.S. Attorney of running a criminal enterprise. PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 7 (Pages 22 to 25) 1 ddcfb84-b3244437-a670-765e29067145 EFTA01076618 Page 26 1 Q. Anything else? 2 MR. PIKE: Form. 3 THE WITNESS: Not I can think of at the 4 moment. 5 BY MR. SCAROLA: 6 Q. Okay. What media did Mr. Edwards go to? 7 A. I am aware of at least the Daily News in New 8 York City. 9 I have been told by other people that there 10 were other media, local media. 11 I've been told that the -- his investigator 12 was sent to California to harass people representing 13 his — Brad Edwards' investigator -- representing 14 fictitiously, fraudulently that he was a FBI agent to 15 try to gather information for Mr. Edwards' claims. 16 Q. Does that have something to do with going to 17 the media? 18 MR. PIKE: Form. 19 THE WITNESS: I've answered your question. 20 BY MR. SCAROLA: 21 Q. Does the investigator going to California to 22 do something have something to do with the media? 23 A. I believe I've also told that you that he's 24 gone to the Daily News, sir, is that coned? 25 MR. PIKE: Form. Mischaracterizes the Page 28 1 Q. Do you understand the question you're supposed 2 to be answering, Mr. Epstein? 3 MR. PIKE: And Fm going to instruct you not 4 to answer that question right now because as your 5 Counsel I cannot let you answer that question until 6 I understand what question is on the table. 7 There's been a lot of bantering back and 8 forth, so, Mr. Scarola, if you would respectfully 9 repeat the question and then you may be able to ask 10 him whether or not he understands the question. 11 But I cannot allow him to answer a question that I 12 don't understand is on the table. 13 BY MR. SCAROLA: 14 Q. What does an investigator going to California 15 have to do with Mr. Edwards allegedly going to the media 16 in an attempt to, quote, gin up, unquote, these 17 allegations? 18 MR. PIKE: Please answer the question. 19 THE WITNESS: Good. It's part of Mr. Edwards' 20 scheme to involve people who have nothing to do 21 with any of his cases in order to, in fact, go back 22 to the media and gin up his stories and make false 23 allegations of people that have sexually charged 24 nature cases in order to attempt to fleece 25 investors, local investors out of millions of Page 27 1 witness' testimony as well. 2 BY MR. SCAROLA: 3 Q. Do you understand the question that you're 4 supposed to be answering? S MR. PIKE: Well, let's go ahead and repeat it. 6 MR. SCAROLA: No, let's get an — let's get an 7 answer to that question. a BY MR. SCAROLA: 9 Q. Do you understand the question you're supposed 10 to be answering? 11 A. When - 12 MR. PIKE: I'm confused. Wait one second. 13 THE WITNESS: Sony. 14 MR. PIKE: I'm confused as to what question is 15 on the table. 16 MR. SCAROLA: And when your deposition is 17 being taken, your confusion is relevant and 18 material. 19 MR. PIKE: Right. And it's — 20 MR. SCAROLA: When Mr. Edwards' — excuse 21 me — when Mr. Epstein's deposition is being taken, 22 I'm concerned with whether he understands the 23 question being asked. 24 MR. PIKE: Right. So... 25 BY MR. SCAROLA: Page 29 1 dollars. 2 His firm has been accused by the U.S. Attorney 3 of manipulating the media, by hiring investigators, 4 by illegal wire taps, by illegal methods of 5 eavesdropping in order to go to the media and 6 generate cases. 7 BY MR. SCAROLA: 8 Q. When did Mr. Edwards go to the Daily News? 9 A. I don't know. 10 Q. How did he go to the Daily News? 11 A. I don't know. 12 Q. What did he say to the Daily News? 13 A. I believe Mr. Edwards knows that. I don't 14 know exactly what he said. 15 Q. What is the source of your information that he 16 went to the Daily News at all, ever? 17 MR PIKE: To the extent you can answer that 18 question without violating any attorney/client 19 privileges, you can answer the questions. 20 THE WITNESS: It's attorney/client 21 BY MR. SCAROLA: 22 Q. You said you were told by other people that he 23 went to other media representatives? 24 A. Yes, sir. 25 Q. Who are the other people that told you that? A......e..14A4, PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 8 (Pages 26 to 29) 1datb84-b324.4437-8670-765e29067146 EFTA01076619 Page 30 Page 32 1 A. I don't recall at the moment- 2 Q. What did these other people who you don't 3 remember tell you Mr. Edwards did with respect to other 4 media representatives besides the Daily News? S A. Again, the question again? 6 Q. What did these other people tell you 7 Mr. Edwards did with respect to going to other media? 8 MR. PIKE: Form. 9 THE WITNESS: Mr. Edwards went to the media to 10 gin up his cases in order that the Rothstein firm 11 could generate profits, falsely taking in 12 investors, creating false stories to the local 13 medial and making statements to local press 14 regarding false claims made by his clients in order 15 that Scott Rothstein, who currently sits in jail, 16 could defraud, along with his other partners of his 17 fimi, local Florida investors, Mr. Scarola, out of 18 millions of dollars. 19 BY MR. SCAROLA: 20 Q. When did these other people whose identity you 21 can't remember tell you these things that Brad Edwards 22 did? 23 A. Sometime in the past year. 24 Q. How many other people were there who told you 25 these things about Mr. Edwards? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 themselves or were these anonymous callers? MR. PIKE: Form. 1 THE WTINESS: Sitting here today, Mr. Scarola, I don't recall with specificity. BY MR. SCAROLA: Q. What specifically did Mr. Edwards allegedly communicate to the Daily News to, quote, gin up these allegations, unquote? A. The newspapers have quoted Mr. Edwards -- not quoted Mr. — newspapers have made allegations referred to as Mr. Edwards' statements. MR. SCAROLA: Would you read the question back, please, Sandy? (Pending question was read.) MR. PIKE: Did he answer your question? MR. SCAROLA: No. MR. PIKE: Are you asking him again? THE WITNESS: So you're asking the question again? BY MR. SCAROLA: Q. Yes. THE WITNESS: Sony. Could you repeat the question again? (Pending question was read.) THE WITNESS: He alleged that third parties Page 31 1 A. I don't recall with specificity. 2 Q. Well, do you recall in any degree how many 3 there were? 4 A. I would say, probably five to ten. 5 Q. Where were you when these conversations took 6 place that you can't -- the identity of whose 7 participants you can't remember? 8 MR. PIKE: So we're clear, within the last 9 year -- correct? — timewise? 10 MR. SCAROLA: Well, that's what your client 11 said. I don't believe a word he says, but that's 12 what he said. 13 MR. PIKE: Form. Objection. Overbroad. 14 THE WITNESS: Again, sir? 15 BY MR. SCAROLA: 16 Q. Yes, sir. Where did these conversations with 17 these five to ten people take place whose identity you 18 can't remember? 19 MR. PIKE: Form. 20 THE WITNESS: On the telephone. 21 BY MR. SCAROLA: 22 Q. Who initiated the phone calls? 23 A. Sir, these questions, l have no -- I don't 24 have any recollection. 25 Q. Did the people who were on the phone identify 1 2 3 4 5 6 8 9 10 11. 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 33 had already been involved in some allegations to do with sexual misconduct. BY MR. SCAROLA: Q. Which third parties? A. 1 don't recall sitting here today. Q. Involved how? MR. PIKE: Form. THE WITNESS: If 1 recall with specificity, if I had the articles in front of me, l would be able to recall. Maybe next time. BY MR.. SCAROLA: Q. What does "gin up these allegations' mean? MR. PIKE: Form. THE WITNESS: It means craft allegations of multi-million dollar cases; in fact, alleging in case damages of $50-million, settlements in order for Scott Rothstein and the rest of Mr. Edwards' partners to fleece unsuspecting investors out of millions and millions of dollars based on cases that didn't exist or alleged cases that I had settled. Can I take a break? VIDEOGRAPHER: Going off video record, 10:50. (Brief recess.) VIDEOGRAPHER: We're now on video record at 9 (Pages 30 to 33) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 ddcfb84-b324.4437-a670-765e29067145 EFTA01076620 Page 34 1 10:57 a.m. 2 BY MR. SCAROIA: 3 Q. Was your reference to, quote, gin up these 4 allegations, unquote, a reference to allegations made 5 against you? 6 MR. PIKE: Form. 7 THE WITNESS: As part of the vast conspiracy 8 of the Rothstein firm and Mr. Edwards' 9 participation in it, it has been alleged that many 10 cases were fraudulently brought — alleged that 11 have been brought; ginned up, meaning, crafted, 12 multi-million dollar numbers put on cases in order 13 to fleece investors, where his partner, Scott 14 Rothstein, currently sits in jail for just those 15 purposes, Mr. Scarola. 16 BY MR. SCAROLA: 17 Q. My question to you is: Did the reference to, 18 quote, gin up these allegations refer to allegations 19 against you? 20 A. Reported in the newspaper the answer is, yes. 21 And others, but specifically me, yes, by the newspaper 22 reports. 23 Q. Specifically what are the allegations against 24 you which you contend Mr. Edwards ginned up? 25 A. I would like to answer that question. A, many Page 36 1 Q. I want to know whether when you use the phrase 2 "gin up" and the word "crafted," which you have told us 3 is synonymous with gin up, -- 4 A. Yes. 5 Q. -- you mean fabricated? 6 A. I'm sorry. On advice of Counsel, sir, and 7 I've answered that question before, but if you didn't 8 hear me the first time, I must assert my Fifth, Sixth 9 and 14th Amendment Right. 10 Q. What specific discovery proceedings did 11 Mr. Edwards engage in which you contend form the basis 12 for your lawsuit? 13 A. The discovery proceedings of bringing my 14 attorneys to various people that had nothing to do with 15 any of his clients or these lawsuits. 16 Q. Which various people? Who? 17 MR. PIKE: Form. 18 THE WITNESS: For example, he tried to depose 19 Bill Clinton, strictly as a means of getting 20 publicity so diat he and his firm could 21 fraudulently steal, craft money from unsuspecting 22 investors in South Florida out of millions of 23 dollars. 24 BY MR. SCAROLA: 25 Q. Who else besides Bill Clinton is included in Page 35 1 of the files and documents that we've requested from 2 Mr. Edwards and the Rothstein firm are still 3 unavailable. With respect to anything that I can point to 5 today, I'm, unfortunately, going to have to take the 6 Fifth Amendment on that, Sixth and 14th. 7 Q. You seemed to be defining ginned up as 3 crafted; is that correct? 9 A. That's correct. 10 Q. Does ginned up or crafted mean fabricated? 11 MR PIKE: Form. 12 THE WITNESS: I'm sorry, Mr. Scarola. 13 understand that you are trying to back door your 14 way into a waiver of my Fifth Amendment. But 15 respect to that question, I'm going to have assert 16 my Fifth Amendment, Sixth Amendment and 14th 17 Amendment Right. 18 BY MR. SCAROLA: 19 Q. So you are asserting your Fifth Amendment, 20 Sixth Amendment and 14th Amendment Right to remain 21 silent about what you mean when you use the words "gin 22 up" and "crafted;" is that correct? 23 A. I don't believe that was your question. 24 Q. Yes, sir, that's exactly my question. 25 A. Would you repeat the question for me? Page 37 1 your reference to various people? 2 A. There are people in California There are 3 people in New York. 4 Q. Would you name them for us, please? 5 A. I'm sony. Sitting here today, Mr. Scarola, 6 Fm going to have to assert my Fifth Amendment, Sixth 7 Amendment and 14th Amendment Right. 8 Q. Let's then talk about Bill Clinton, by whom ! 9 assume you mean fonner President Clinton; is that 10 correct? 11 A. That's correct. 12 Q. All right. Do you know former President 13 Clinton personally? 14 A. I'm sorry. As I sit here today, though Id 15 like to answer that question, on advice of my Counsel, 16 at least today, I'm going to have to take the Fifth, 17 Sixth and 14th Amendment. 18 Q. You said something about Mr. Edwards sharing 19 13 boxes of information with somebody — 20 A. Yes. 21 Q. — as forming part of the basis for your 22 lawsuit against Mr. Edwards, correct? 23 A. Correct. 24 Q. All right. With whom did Mr. Edwards share 25' these 13 boxes of infomartion? PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 10 (Pages 34 to 37) 1thIcfbt14-b324-4437-a670-765e29067145 EFTA01076621 Page 38 1 A. It has been reported in the Scherer Complaint 2 that he shared those boxes with the partners of his firm 3 that was then formally accused by the U.S. Attorney, 4 sir, of being a criminal enterprise. 5 MR. PIKE: And just for purposes -- 6 BY MR. SCAROLA: 7 Q. Do you remember my question? 8 A. You asked me who he shared it with? 9 Q. Yes. 10 A. The partners of his firm, sir. 11 Q. Okay. So part of the basis of your lawsuit is 12 that Mr. Edwards allowed members of his own law firm to 13 see 13 boxes of information; is that correct? 14 A. No. that's not correct. My claim is that the 15 13 boxes of information that wore shown to investors by 16 Mr. Edwards' partners, 13 boxes that we've been told by 17 the press contain multiple cases, fraudulently -- and if 18 you like the word -- fabricated in order to fleece 19 investors out of money. The 13 boxes were shared with 20 investors, Mr. Edwards, Mr. Edwards' partners and some 21 of those partners currently under inditement, the others 22 already sitting in jail. 23 Q. I had asked you earlier whether ginned up and 24 crafted meant fabricated and you asserted your Fifth 25 Amendment privilege. Page 40 1 Amendment Right, sir. 2 Q. Your Complaint also makes reference to a claim 3 on behalf of Jane Doe, referred to as Jane Doe versus 4 Epstein, case number 08-CIV-80893, a case pending in the 5 United States District Court for the Southern District 6 of Florida. 7 Is it your contention that the claim on behalf 8 of Jane Doe is a fabricated claim? 9 A. Sir, though I'd like to answer that question, 10 as well as every one of your other questions here today, 11 today I'm going to have to assert my rights as under the 12 Constitution of the Fifth, Sixth and 14th Amendment. 13 Q. Do you blow the real name of the person 14 referred to as Jane Doe in that case? 15 A. i don't know which — I5n sorry, sir. Ho 16 not, sitting here today. 17 Q. Did you ever have personal contact with the 18 person referred to by the name Jane Doe in that lawsuit? 19 A. I'm sorry, sir. Sitting here today, I'm going 20 to have to assert my Fifth, Sixth and 14th Amendment 21 Right. 22 Q. When did you first meet the person referred to 23 as Jane Doe? 24 A. Sir, though I'd like to answer each and every 25 one of your questions here today, at least with respect Page 39 1 Are you now telling us that there were claim 2 against you that were fabricated by Mr. Edwards? 3 A. I'm going to again assert my Fifth, Sixth and 4 14th Amendment Right, sir. 5 I would respond that the newspapers are very 6 clear that the cases were fabricated. 7 Q. Which newspaper said which case was fabricated? 9 A. Bob Norman's blog said most of the eases were 10 fabricated, to my best recollection. 11 The Scherer Complaint alleged many fabricated 12 cases, sir. 13 Q. Well, which of Mr. Edwards' cases do you 14 contend were fabricated? 15 A. Again, we've requested most of the -- 16 information from the bankruptcy trustee. We've been 17 unable — Mr. Edwards has not given us the total file, 18 but respect to any individual, I would have -- at the 19 moment I would have to assert my Fifth, Sixth and 14th 20 Amendment claim, sir. 21 Q. So you will not answer questions about whether 22 the claim on behalf of.. was fabricated; is that 23 correct? 24 A. I believe I've already answered that, but, if 25 again, have to assert my Fifth, Sixth and 14th Page 41 1 to that question, I'm going to have to assert my rights 2 under the Sixth Amendment, 14th Amendment and Fifth 3 Amendment. 4 Q. Where did you first meet the person referred 5 to as Jane Doe? 6 A. Sir, though I'd like to answer that question 7 here today, at least today on advice of Counsel, I'm 8 going to have to assert my Fifth Amendment, Sixth 9 Amendment and 14th Amendment Right 10 Q. How many times have you been in the physical 11 presence of the person referred to as Jane Doe? 12 A. The person referred to as Jane Doe? 13 Q. Yeah. How many times have you been in her 14 physical presence? 15 MR. PIKE: Form. 16 THE WITNESS: At least -- at least sitting 17 here today, Mr. Scarola, I'm going to have to 18 assert my Fifth Amendment, Sixth Amendment and 14th 19 Annulment Right 20 BY MR. SCAROLA: 21 Q. Dld you ever have any physical contact with 22 'arse Doe? 23 MR. PIKE: Form. 24 THE WITNESS: Now, for this purposes, you're 25 assuming this Jane Doe is somebody I know? 1 don't PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 11 (Pages 38 to 41 MIIIIIIIIIIIII lddcfb8443324-4437-8670-765o29067145 EFTA01076622 Page 42 1 think so, since this question makes no sense to me. 2 BY MR. SCAROLA: 3 Q. You have alleged in your Complaint that there 4 is a claim on behalf of Jane Doe versus Epstein pending 5 in the Federal District Court of the Southern District of Florida. 7 I would like to 'mow whether you ever had any a physical contact with the person referred to as Jane Doe 9 in that Complaint? 10 A. Ah, that lane Doe. Pm sorry. But sitting 11 here today, Mr. Scuola, I'm going to have to refuse to 12 answer that question based on the Fifth Amendment, Sixth 13 Amendment and 14th Amendment. 14 Q. Did you ever exchange any money or gifts with 15 Jane Doe? 16 A. Again, Mr. Scarola, sitting here today, fm 17 going to have to on advice of Counsel assert my Sixth 18 Amendment, Fifth Amendment and 14th Amendment Right. 19 Q. Your Complaint makes reference to a case 20 stylec=aetsus Epstein, case number 21 502008CA028058XXXXMBAB, a case pending in the Circuit 22 Court of Pahn Beach Cot Florida. 23 Do you know who MI. is? 24 A. Sitting here today, Mr. Scarola, I'm going to 25 have to assert my rights as under the Fifth, Sixth and 1 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 94 to as M.? A. I believe it is Q. How long have you known A. Well, with respect to that question, Mr. Scarola, I'm going to have to assert my Fifth, Sixth and 14th Amendment Rights, though rd like to answer every, single question you have about Q. How many times have you been in the physical presence of.? A. I'd like to answer every question about.. that you have today, Mr. Scarola; however, on advice of Counsel, Fm going to have to assert my Fifth, Sixth and 14th Amendment Right. Q. How old is M.? A. I don't know. Q. How old was she when you met her? A. Mr. Scarola, Fm going to have to assert my rights under the Fifth, Sixth and 14th Amendment on advice of Counsel, though I would like to answer every one of these questions. Did you ever have any physical contact with A. Mr. Scarola, once again, I would like to answer each one of your questions here today, but on advice of Counsel rm going to have to assert my Fifth, Page 43 1 14th Amendment. 2 Q. Have you ever learned the real name of.'" 3 A. Yes, sir. 4 Q. Did that person whose real name you learned 5 ever spend any time in your physical presence? 6 A. Sir, at least sitting here today, I would like 7 to answer each and every one of your questions regarding 8 your ft and — are we not allowed to use the names of 9 these people, sir? 10 MR. PIKE: In the past — in the past cases 11 the names of these individuals have been utilized 12 for deposition purposes. 13 Brad Edwards, sitting here today, knows that 14 we have used; however, any documents that are filed 15 with the Court will redact those names. 16 So the answer to the question is, yes, for 17 purposes of this deposition, to the extent you know 18 the names of individuals, you can utilize them with 19 agreement of Mr. Edwards. 20 MR. EDWARDS: 1 have no problem with that. 21 THE WITNESS: I think to avoid conflision, so 22 there's not — I know who you're talking about. 23 That's all. 24 BY MR. SCAROLA: 25 Q. What is the real name of the person referred 1 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 45 Sixth and 14th Amendment Right. Q. Did you ever exchange any money or gifts with A. Sir, Tel like to answer every question you have about..; however, today, on advice of Counsel Pm going to have to assert my Fifth, sixth and 14th Amendment Right. Q. Did you ever cause any money or gifts to be delivered to..? A. Mr. Scarola, as I've answered most of your IL questions here today regarding I would like to answer every question regarding ; however, today, on advice of Counsel, I'm going to have to assert my Fifth, Sixth and 14th Amendment Right because though I would choose to do so, I've been told that if I do so, I risk losing my Counsel's representation. Q. What is the actual value that you contend the claim of.. against you has? MR. PIKE: Form. Relevance. THE WITNESS: _ i riS_though I'd like to answer every question about M. and her claims and the claims of your other people, on advice of Counsel here today, I cannot do so. I must assert my rights under the Sixth, Fifth and 14th Amendment. BY MR. SCAROLA: PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 12 (Pages 42 to 45) lcidcfb84-b324-4437-a670-765e29067145 EFTA01076623 ?aye 46 Would your answer be the same with regard to and to Jane Doe? MR. PIKE: Fm going to instruct you if your 4 answer is the same, to invoke in full. 5 THE WITNESS: With respect to, I believe, Janc o Doe — and who is the other person? Fm sorry. 7 BY MR. SCAROLA: 3 Q. 9 A. Thmigh I'd lthe to answer your claims 10 with respect to all three of Mr. Edwards' clients, on 11 advice of Counsel, at least today, I'm going to have to 12 invoke my Fifth, Sixth and 14th Amendment Rights. 13 Though I'd prefer to answer the question, I've been told 14 that if I choose to do so, I risk losing their 15 representation. 16 Q. Among those items listed by you as wrongdoing 17 on the part of Mr. Edwards forming the basis for this 18 lawsuit is that he, quote, counseled his clients to make 19 multi-million dollar claims against you; is that 20 correct? 21 MR. PIKE: Form. Document speaks for itself. 22 THE WITNESS: Doctnnent speaks for itself. 23 BY MR. SCAROLA: 24 Q. I'm not asking about a document. I'm asking 25 you about the list of wrongdoing that you gave us during Page 48 1 A. No. I answered that question, which is, I'd 2 like to know. 3 Q. Yes. But that isn't an answer to my question. 4 My question is: By whom was Mr. Edwards 5 employed at the time that he initiated litigation 6 against you? Do you know the answer to that question? 7 A. I'd have no way of knowing the answer to that 8 question, sir. 9 Q. Among the allegations of wrongdoing against 10 Mr. Edwards which you contend form the basis of this 11 lawsuit is something having to do with sending an 12 investigator to California. 13 Would you tell me, please, more specifically 14 what it is that Mr. Edwards did with regard to sending 15 an investigator to California which you contend 16 justifies a legal claim against Mr. Edwards. 17 MR. PIKE: Form. And also mischaracterizes 18 the witness' testimony. 19 THE WITNESS: Reported widely in the 20 newspapers is the use of illegal activities, wire 21 taps, and methods by the Rothstein firm while 22 Mr. Edwards had basically been bringing these 23 24 The investigator, Mr. Fisten, who's mentioned 25 in the Complaint, represented himself as an FBI Page 47 1 the course of this deposition, which you allege form the 2 basis for your claim against Mr. Edwards. 3 is it your contention that among those things 4 Mr. Edwards did that form the basis for your lawsuit is 5 to have counseled his clients to make multi-million 6 dollar claims against you? 7 MR. PIKE: Form. 8 THE WITNESS: What the newspapers have said 9 that the claims purported to have been made by the 10 Rothstein firm and its partners allege 11 multi-million dollar claims where no claims exist. 12 However, respect specifically to my claim 13 today, I'm going to have assert my Fifth, Sixth and 14 14th Amendment Right. 15 MR. PIKE: Also, the question mischaracterizes 16 the witness' testimony. 1 7 BY MR. SCAROLA: 18 Q. By whom was Bradley Edwards employed when 19 initiated litigation against you? 20 A. I would like to bow the answer to that 21 question. 22 Q. So the answer to that question is, i don't 23 ►snow? 24 A. I would like -- 25 Q. Correct? is he Page 49 1 agent, falsely represented himself as an FBI agent. 2 BY MR. SCAROLA: 3 Q. Do you have any personal knowledge of anything 4 that Mr. Fisten did while Mr. Fisten was in California? 5 MR. PIKE: To the extent that you can answer 6 that question without disclosing my conversation or 7 my firm's conversation or any of your attorneys' 8 conversations with you, you can answer the 9 question. 10 THE WITNESS: Pm sorry. Based on 11 attorney/client privilege, I can't answer. 12 BY MR. SCAROLA: 13 Q. is it your contention that Mr. Edwards was 14 involved in an illegal wire tap? 15 A. It was widely reported in the newspaper 16 Q. I'm not asking it was reported — 17 A. Excuse me. 18 Q. — in the newspaper. 19 A. Excuse me. 20 Q. I want to know whether your contention is that 21 Mr. Edwards was involved in an illegal wire tap. 22 MR. PIKE: Try once again to answer that 23 question. 24 THE WITNESS: It's been widely reported in the 25 newspaper that his firm and his partners were 11:47stakt.-ylearta 1....}}rapaenetwaeS, PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 13 (Pages 46 to 49) lddctb84-b324-4437-a670-7650 29067145 EFTA01076624 Page 50 1 involved in illegal wire taps, eavesdropping, hired 2 former FBI and law enforcement officials in order 3 to fabricate cases of a sexually charged nature 4 against me and other& 5 BY MR. SCAROLA: 6 Q. Do you have any personal knowledge of 7 Mr. Edwards ever having engaged in any illegal wire tap? A. I have no personal knowledge; however, what I 9 read in the newspapers and is widely reported is that 10 his firm, and I believe Mr. Sakowitz went to the FBI 11 after he was told that the firm was engaged in illegal 12 wire taps and his partners were engaged in illegal wire 13 taps. 14 The FBI, the U.S. Attorney has accused his 15 firm of RICO, being the largest criminal fraud 16 enterprise in South Florida's history and engaged in 17 illegal wire taps. But the answer specifically to your 18 question about personal knowledge, sir, no. 19 Q. Do you have any personal knowledge of 20 Mr. Edwards ever having been involved in any illegal or 21 improper eavesdropping? 22 A. Ifs been widely reported in the newspapers in 23 South Florida that Mr. Edwards' firm, his partners were 24 involved in illegal wire taps, illegal fact gathering, 25 using what the newspapers quoted as sophisticated Page 52 1 Jeffrey Epstein, separate and apart from the 2 allegations of fraud by his partners, I cannot 3 answer that question because of attorney/client 4 privilege. 5 BY MR. SCAROLA: 6 Q. Do you have any personal knowledge that 7 Bradley Edwards was involved in any egregious civil 8 litigation abuses? 9 M:R. PUCE: Form. Confining. 10 THE WITNESS: It's widely reported in the 11 newspaper that Mr. Edwards' firm engaged in wild 12 discovery processes, illegal activities, illegal 13 eavesdropping in order to fleece unsuspecting 14 investors in South Florida out of millions in 15 dollars by crafting, fabricating malicious cases of 16 a sexually charged nature in order to perpetrate a 17 fraud. 18 BY MR. SCAROLA: 19 Q. Do you have any personal knowledge that 20 Bradley Edwards ever forged Federal Court Orders and/or 21 Opinions? 22 A. It's attomey/client privilege. 23 Q. Do you have any personal knowledge that 24 Bradley Edwards was over involved in the marketing of 25 non-existing Epstein settlements? Page 51 1 methods. Mr. Sakowitz, who was approached as an 2 investor, and Mr. Scherer, who's filed a Complaint, 3 alleges similar activities. But personal knowledge 4 myself, sir, no. Q. Do you have any personal knowledge that 6 Bradley Edwards was ever involved in obstructions of 7 justice? 8 MR. PIKE: To the extent that you can answer 9 that question without disclosing any 10 attorney/client communications with any of your 11 attorneys, you can answer that question. 12 THE WITNESS: It's attorney/client privilege, 13 I'm afraid. 14 BY MR. SCAROLA: 15 Q. Do you have any personal knowledge that 16 Bradley Edwards was ever involved in any actionable 17 frauds? 18 MR. PIKE: Same — same instruction, with any 19 of your lawyers. 20 THE WITNESS: Yes. Outside of the newspapers, 21 which have accused his firm of a monstrous fraud, 22 purported to be the largest fraud in South 23 Florida's history, accused by the U.S. Attorney 24 where his partner sits in jail -- excuse me -- 25 reported in the newspapers of boxes of material on 2 3 4 5 6 7 8 9 10 11 12 13 14 15 1e' 17 18 19 20 21 22 23 24 25 Page 53 MR. PIKE: Same instruction. THE WITNESS: I'm sorry. I would like to answer that question, but on attorney/client privilege I cannot today. BY MR. SCAROLA: Q. It is alleged in your Complaint that you were subject to, quote, abusive investigatory tactics. Other than those matters previously referred to in earlier questions, is it your contention that Bradley Edwards had any personal involvement in any other, quote, abusive investigatory tactics? MR. PIKE: Form THE WITNESS: It's been widely reported in the newspapers that Mr. Edwards' firm was engaged in widely — wildly abusive practices throughout the State of Florida in order to fleece unsuspecting investors out of millions of dollars. The U.S. Attorneys Complaint alleges his firm engaged in a corrupt criminal enterprise. Mr. Scherefs Complaint alleges monstrous amounts of fraud and discovery abuse. I have no personal knowledge, separate from the attorney/client privileged information, regarding Mr. Edwards. BY MR. SCAROLA: PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 14 (Pages 50 to 53) 1 ddcfbEl4,b324-4437-a670-765029067145 EFTA01076625 Page 54 1 Q. Do you have any personal knowledge that 2 Bradley Edwards ever filed legal papers that were 3 unsupportable? 4 MR. PIKE: I'm going to object to form. And to the extent you can answer that question 6 without disclosing any attorney/client communications with any of your attorneys, I'm going to allow you to answer that question. 9 THE WITNESS: I'm afraid it's attorney/client 10 privilege. 11 BY MR. SCAROLA: 12 Q. Do you have any personal knowledge that 13 Mr. Edwards was ever involved in any conduct that 14 quote, compromised the core values of both State and 15 Federal justice systems in South Florida? 16 MR. PIKE: Form. 17 THE WITNESS: Can you just ask can you 18 define for me what you mean by "personal 19 knowledge," sir? 20 BY MR. SCAROLA: 21 Q. Yes. Did you over see, hear, smell, taste, or 22 touch anything that communicated to you directly and not 23 through the report of some third person or newspaper 24 that Bradley Edwards was personally involved in 25 cot mon Hising the core values of both State and Federal 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 56 were adversely affected by the misconduct that is the subject of this Complaint," unquote. Who are those hardworking and honest lawyers that you are seeking to vindicate? MR. PIKE: Form. Give me a minute. What page of the Complaint are you referring to? MR. SCAROLA: Page 2. MR. PIKE: Give me one second. THE WITNESS: Can we go off the record just for a second? MR. PIKE: If it's okay with Mr. — THE WITNESS: It's a bathroom break. MR. PIKE: There's a question pending and usually — THE WITNESS: Sony. MR. PIKE: lust give me a second. Okay. THE WITNESS: Where is it? MR. PIKE: It's page 2 of the Complaint, which has my notes on it down here, the last sentence. And to the extent that you have knowledge and can answer that question, you can do so. THE WITNESS: Could you repeat the question for me, sir? Page 55 1 justice systems in South Florida? 2 MR. PIKE: Form. 3 Same instruction with regard to 4 attorney/client. 5 THE WITNESS: Yes. Are you suggesting that 6 anyone who told me specifically or things that I 7 might have read that specifically relate to him, is 8 not what you've been asking me for? 9 BY MR. SCAROLA: 10 Q. Yes, sir, that's exactly right. 11 A. You told me if I hear something, that's not 12 personal knowledge. 13 Q. Not if you hear it from somebody else. 14 A. Who else would I hear it from, besides 15 somebody else, sir? 16 Q. Well, if you heard it directly yourself. 17 A. From who? 18 , Q. Maybe Mr. Edwards. 19 A. Uh-huh. Is that the only person, sir? 20 Q. That's the only person, that's correct 21 A. Well, if it's the only person, separate from 22 attorney/client privilege, I cannot answer that. 23 Q. Your Complaint makes reference to a purpose in 24 filing this lawsuit to, quote, "vindicate the 25 hardworking and honest lawyers and their clients who Page 57 1 BY MR. SCAROLA: 2 Q. Yes, sir. Your Complaint makes reference to a 3 purpose in filing this lawsuit — 4 A. Yes. 5 Q. -- to vindicate the hardworking and honest 6 lawyers and their clients who were adversely affected by 7 the misconduct that is the subject of this Complaint 8 A. Yes, sir. 9 Q. Who are those hardworking and honest lawyers 10 on whose behalf you are bringing this Complaint? 11 MR. PIKE: Okay. Form. Mischaracterizes the 12 Complaint itself. 13 To the extent you understand that question, 14 you can attempt to answer, if you recall. 15 THE WITNESS: Yes. 16 The U.S. Attorney, sir, has accused the 17 Rothstein firm of misusing the entire legal system, 18 a level of abuse never seen before in the United 19 States history, of forging documents, an affront to 20 any decent lawyer, signing Judge's Orders, sending 21 false statements to other lawyers. The people who 22 have been — excuse me — the Complaint by the U.S. 23 Attorney, in fact, describes the behavior of the 24 law firm, as well as Mr. — my Complaint says, 25 Mr. Edwards being a part of that. PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 15 (Pages 54 to 57) lddcfb84-b324-4437-a670.766029067145 EFTA01076626 Page 58 Page 60 1 BY MR. SCAROLA: 2 Q. Now, before you answered that question, you . 3 reviewed a document, right? 4 A. The Complaint sir. S Q. I'd like to see it, please. 6 MR. PIKE: Definitely not, Mr. Scarola. 7 My notes are on that and that's 8 attorney/client. I allowed the witness to take a 9 look at the document and he did not write anything 10 on the document He looked at the document 11 That's my client. And you will certainly not be 12 looking at my notes, which are all over this 13 document. 14 MR. SCAROLA: He didn't look at everything. 15 He looked at one page. I would like that one page, 16 please. 17 MR. PIKE: Absolutely not, Mr. Scarola. 18 MR. SCAROLA: I would like that page marked as 19 an Exhibit to this deposition. 20 MR. PIKE: Absolutely not, Mr. Scarola. 21 MR. SCAROLA: I would state for the record 22 that it is my intention, since that page with 23 handwritten notations on it was reviewed by the 24 witness during the course of this deposition while 25 a question was pending, Iwant that page preserved 1 We have asked for Scott Rothstein's 2 deposition. We hopefully will get it. Maybe he will 3 give us some insight on how other lawyers have, in fact, 4 been handled and the abuses they've undergone, including 5 forging a Federal Judge's signature, sir. 6 Q. Now, was it your intention in this sentence to T say that you were trying to vindicate the hardworking 8 and honest lawyers and their clients? 9 A. It's attorney/client. I'm sorry. 10 Q. Your intention is attorney/client privileged? 11 MR. PIKE: Form. I'm not quite - 12 BY MR. SCAROLA: 13 Q. Is that what you're telling us? 14 MR. PIKE: Wait a second. I'm not quite sure 15 I understand the question. 16 THE WITNESS: What's the question? 17 BY MR. SCAROLA: 18 Q. Were you attempting to communicate in this 19 Complaint a desire on your part to vindicate hardworking 20 and honest lawyers and their clients? 21 MR. PIKE: Form. 22 THE WITNESS: In this Complaint, I intend to 23 get to the truth of Mr. Edwards' behavior and the 24 Rothstein firm, sir. 25 BY MR. SCAROLA: Page 59 1 so that the Court can make a determination as to 2 whether I am entitled to see it 3 MR. PIKE: I would object based upon 4 attorney/client and work product in that regard. 5 THE WITNESS: Now can we take a bathroom 6 break? 7 MR. SCAROLA: No, sir, because you still 8 haven't answered my question. 9 THE WITNESS: Okay. 10 BY MR. SCAROLA: 11 Q. I want to know who the, quote, "hardworking 12 and honest lawyers" are that are referred to in that 13 section of your Complaint. 14 A. My attorneys, at least, are honest 15 Q. Which ones? 16 A. All of them. 17 Q. And you say that you want to vindicate the 18 hardworking and honest lawyers and their clients? 19 A. That's correct. 20 Q. Which clients? 21 A. Me, some of the other clients, in fact, abused 22 by the Rothstein firm. I don't know the full extent. 23 Hopefully when we get to trial, we're going to find out 24 the extent of the people, the lawyers, the clients that 25 were abused by Mr. Edwards and the Rothstein finn. Page 61 1 Q. Well, what this sentence says is, quote, — 2 A. Yes. 3 Q. — "the Rothstein racketeering enterprise 4 endeavored to compromise the core values of both State 5 and Federal systems in South Florida and to vindicate 6 the hardworking and honest lawyers and their clients who 7 were adversely affected by the misconduct that is the 8 subject of this Complaint." 9 Is that what you meant to communicate? 10 A. It says what it says, sir. 11 Q. Well, I know it says what it says. I'm trying 12 to find out if that's what you meant to say; that is, 13 that the Rothstein racketeering enterprise endeavored to 14 vindicate the hardworking and honest lawyers and their 15 clients who were adversely affected by the misconduct 16 that is the subject of this Complaint. 17 MR. PIKE: Form. Mischaraeterizes the 18 language of the document 19 THE WITNESS: Yeah, I think you've misread 20 that again. You want to — I certainly didn't ask 21 for the Rothstein firm to vindicate the lawyers, is 22 what you've just — 23 BY MR. SCAROLA: 24 Q. Well, that's what I'm trying to find out, 25 whether you meant to say what you said in this 1101•••••••••10081...1 ,••••••Vshamil PROSE COURT REPORTING AGENCY, Electronically signed by Sandra Townsend (401M Electronically signed by Sandra Townsend (401 INC. 16 (Pages 58 to 6 1) ddclb84-b324-4437-a670-765090137145 EFTA01076627 Page 62 Page 64 1 Complaint. 1 Q. Knowingly part of a criminal enterprise? 2 Did you read the Complaint before it was 2 MR. PIKE: Form. 3 filed? 3 THE WITNESS: Attorney/client privilege. 4 MR. PIKE: Form. Move to strike. 4 MR. SCAROLA: You wanted to take a break and 5 THE WITNESS: Thank you, sir. 5 before I move on to another subject, we'll do that. 6 BY MR. SCAROLA: 6 But 1 mint — I want to observe for the record that 7 Q. Did you read the Complaint before it was 7 the last break was less than an hour ago. While I 8 filed? 8 want to try to make reasonable accommodations to 9 A. It was a while ago, yes, sir. 9 witnesses so as not to impose unnecessarily upon 10 Q. And did you approve the Complaint prior to its 10 their physical comfort, I will object to breaks 11 filing? 11 occurring at less than one-hour intervals during 12 A. Yes, sir. 12 the course of this deposition. 13 Q. And did you mean to say what this sentence 13 VIDEOGRAPHER: We're now off video record. It 14 says, "die Rothstein racketeering enterprise endeavored 14 is 11:34 am. 15 to vindicate the hardworking and honest lawyers and 15 (Brief recess.) 16 their clients, who were adversely affected by the 16 VIDEOGRAPHER: We are now back on video 17 misconduct that is the subject of this Complaint? 17 record. It Is 11:45 sm. and we are on media 18 MIL PIECE: Okay. I'm going to move to strike. 18 number two. 19 hfischaracterizes the language of the document. 19 BY MR. SCAROLA: 20 The document reads as follows, for purposes of 20 Q. What knowledge do you have of Brad Edwards 21 the record: "The Rothstein racketeering enterprise 21 ever having personally engaged in mail fraud? 22 endeavored to compromise the core values of both 22 A. Ifs been widely reported in the press — 23 State and Federal justice systems in South Honda 23 Q. I'm going to withdraw my question. 24 and to vindicate the hardworking and honest lawyers 24 What personal knowledge do you have of Bradley 25 and their clients who were adversely affected by 25 Edwards ever having been engaged in any mail fraud? Page 63 Page 65 1 the misconduct that is the subject of this 1 A. Will you describe what you mean by "personal 2 Complaint." 2 larowtedge," sir? 3 BY MR. SCAROLA: 3 Q. I mean direct observation through your senses 4 Q. Is that what you meant to say? 4 on your part. 5 A. What I meant to say, it is — seems to me 5 A. So are you asking me whether or not I've 6 somewhat unclear — is that the Rothstein firm, along 6 witnessed him sending something directly, putting 7 with Mr. Edwards, is part of a criminal enterprise, the 7 physically in the mail, sir? 8 largest — excuse me — the largest criminal enterprise 8 Q. I'm asking whether you have ever personally 9 in South Florida's history, forging Judges' signatures, 9 witnessed Bradley Edwards ever having engaged in mail 10 engaging in illegal wire taps, illegal behaviors. And 10 fraud. 11 part of this lawsuit should vindicate, which means, I 11 A. I'm not sure how that's possible for anybody 12 believe should set right. 12 to witness a mail fraud, so would you inform me how it's 13 And if it's not clear, the Rothstein firm 13 done? 14 compromised the core values of our legal justice system. 14 Q. So the answer to my question is, you don't 15 It abused every — many of the precepts, the most basic 15 know; is that correct? 16 values of the American justice system. 16 A. My answer to your question is — 17 And, in fact, I believe this lawsuit, part of 17 MR. PIKE: Form. Mischaracterizes the 18 the reason for filing this lawsuit, it will disclose the 18 witness' testimony. 19 various techniques of attorney/client privilege, abuse 19 THE WITNESS: I've asked for a clarification. 20 of technique, abuse of discovery, illegal wire taps, 20 BY MIL SCAROLA: 21 forging signatures engaged in by both Mr. Edwards and 21 Q. Have you ever personally witnessed Bradley 22 his firm. 22 Edwards engaging in mail fraud? 23 Q. So it is your contention that Ms. Edwards was 23 MR. PIKE: Form. 24 part of a criminal enterprise? 24 THE WITNESS: No, sir. 25 A. Yes, it is. 25 BY Wt. SCAROLA: PROSE COURT REPORTING AGENCY, INC. 17 (Pages 62 to 65 IIIIIIIIIIIIII Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 lddcfb84-b324.4437-a670-765029067146 EFTA01076628 Page 66 1 Q. Have you ever personally witnessed Bradley 2 Edward — Edwards engaged in wire fraud? 3 A. How would one — I'm not sure how anyone would 4 personal — have personal knowledge, witness someone 5 engaging in wire ftaud, unless they were simply sitting 6 over their computer looking at their bank accounts. So, 7 unfortunately, I would have to say, no, sir. 8 Q. Have you ever personally witnessed Bradley 9 Edwards engaged in money laundering? 10 MR. PIKE: Form. 11 THE WITNESS: Again, sir, the U.S. Attorney's 12 Complaint of the Rothstein firm alleges money 13 laundering, wire fraud, mail fraud, RICO claims of 14 Mr. Edwards' partners and his firm, calling the 15 film the largest criminal enterprise in South 16 Florida's history, accused of fabricating malicious 17 cases, sir, of a sexually charged nature in order 18 to fleece unsuspecting South Floridians out of 19 millions of dollars. 20 BY MR. SCAROLA: 21 Q. And I'm trying to find out, Mr. Epstein, 22 whether you have any evidence whatsoever that 23 Mr. Edwards ever personally participated in any of that 24 wrongdoing? 25 MR. PIKE: To that question, to the extent you Page 65 1 payout settlement? 2 MR. PIKE: Form. 3 THE WITNESS: I'd like to answer that question 4 by saying that the newspapers have Nina icd that 5 his fiim was engaged in fraudulent structured 6 settlements in order to fleece unsuspecting Florida 7 investors. 8 With respect to my personal knowledge, I'm 9 unfortunately going to, today, but I forward 10 to at some point being able to disclose it, today 11 I'm going to have to assert the attorney/client 12 privilege. 13 BY MR. SCAROLA: 14 Q. Your Complaint alleges that Rothstein and 15 others in RRA were using RRA to market investments. 16 Who are the others referred to in the 17 Complaint? 18 A. From my understanding of the U.S. Attorney's 19 Complaint, from Mr. Scherefs Complaint, it is the 20 partners and people who held themselves out to be 21 partners of the Roth -- Scott Rothstein, including 22 Mr. Berger, Mr. Adler, Mr. Edwards and other people 23 associated with the fine like Mr. Fisten, Diane 24 Villegas, if that's how you pronounce her name, Russell 25 Adler, and many of the other partners of his firm Page 67 can answer it without violating attorney/client and 2 work product, you can answer the question. 3 THE WITNESS: I'm afraid it will be 4 attorney/client privilege, sir. BY MR. SCAROLA: o Q. Do you have any evidence knowledge of any 7 evidence whatsoever that Mr. Edwards ever participated 8 in any effort to market any kind of investment in 9 anything? 10 A. I would have to claim attorney/client 11 privilege on that, sir. 12 MR. PIKE: Font 13 BY MR. SCAROLA: 14 Q. Do you have knowledge of any evidence 15 whatsoever that Mr. Edwards was ever a participant in 16 devising a plan through which were sold purported 17 confidential assignments of a structured payout 18 settlement? 19 A. The newspapers and blogs have widely reported 20 that Mr. Edwards' firm crafted — would you repeat the 21 question for me, again, sir? I'm sorry. 22 Q. Yes, sir. I want to know whether you have any 23 knowledge of evidence that Bradley Edwards personal I> 24 ever participated in devising a plan through which were 25 sold imported confidential assignments of a structured Page 69 1 currently wider investigation by either the Florida Bar 2 or the U.S. Attorney or FBI or all of the above, sir. 3 Q. Which — which source of information 4 referenced in that answer specifically made reference to 5 Mr. Edwards? 6 A. !don't recall, sir. 7 Q. But you do have a recollection that one or 8 more of them did; is that correct? 9 A. I don't recall, sir. 10 Q. So you want to withdraw the earlier response 11 that you made and your real answer is, I don't know; is 12 that correct? 13 MR. PIKE: kfischaracterizes the witness' 14 testimony. Move to strike. 15 BY MR. SCAROLA: 16 Q. Your response, sir? 17 A. My answer stays the same, sir. 18 Q. Is it your contention that one or more 19 lawsuits was fabricated against you? 20 A. It's been widely reported in the newspapers — 21 Q. That% not my question. 22 A. Excuse me. I was answering. 23 MR. PIKE: Please let the witness answer the 24 question, Mr. Scarola. 25 BY MR. SCAROLA: • 1 , I El 18 (Pages 66 to 69) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 1 ddcfb84-b324-4437.a670-765e29067146 EFTA01076629 Page 70 1 Q. No, you're not answering my question. 2 MR. PIKE: lie's only said three words, so you 3 don't know whether he's answering your question or 4 not. 5 MR. SCAROLA: I didn't ask him anything about 6 newspapers. I asked him about his contention. I 7 don't know he's not answering my question. 8 BY MR. SCAROLA: 9 Q. But you can go ahead, Mr. Epstein, and you can 10 make your silly speech one more time. 11 MR. PIKE: Pm going to move to strike. 12 THE WITNESS: You wan to repeat the question? 13 BY MR. SCAROLA: 14 Q. Yes, sir. I would like to know whether it is 15 your contention that one or more lawsuits have been 16 fabricated against you. 17 A. My contention, sir, is that the firm of 18 Edwards' partners, Scott Rothstein, fabricated many 19 cases, reported by the press and the U.S. Attorney, 20 amongst people like me and others of a sexually charged 21 nature in order to fleece investors of South Florida out 22 of millions of dollars. 23 Do I have a — with respect to my individual 24 cases that Mr. Edwards has filed in these three cases, 25 rm unfortunately today, and only today at least, on 1 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 72 potential defendants could be, in essence, blackmailed. MR. PIKE: Would you identify for me, Mr. Scarola, what page? MR. SCAROLA: Page 8, paragraph 19. BY MR. SCAROLA: Q. Did anyone ever sift through your garbage looking for damaging evidence? MR. PIKE: One second. In light of clarity, Mr. Scarola, would you please read the entire paragraph so Mr. Epstein understands the tenor of the paragraph? MR. SCAROLA: No. I want to know whether anyone ever sifted through Mr. Edwards' garbage -- through Mr. Epstein's garbage. That's the pending question. MR. PIKE: To the extent you understand the question, you can answer. THE WITNESS: I think the question is poorly phrased. Did anyone ever sift through my garbage? What does that mean? BY MR. SCAROLA: Q. You don't know what sifting through garbage means? A. Does that mean the garbage man? Does that include the garbage man? I'm sure he sifted through my Page 71 1 advice of Counsel Fm going to have to assert my Fifth, 2 Sixth and 14th Amendment, sir. 3 Q. Okay. Well, I'm not limiting my question to 4 the three cases referenced in your Complaint. I want to S know whether you contend that any claim against you has 6 been fabricated? 7 MR. PIKE: Form. Overbroad and confusing and 8 its compound. 9 THE WITNESS: The question makes no sense to 10 me. Fm sure you could do better. 11 BY MR. SCAROLA: 12 Q. Is there any pending claim against you which 13 you contend is fabricated? 14 A. At least today, sir, I'm going to have to 15 respond by asserting my Fifth, Sixth and 14th Amendment 16 Right. 17 MR. PIKE: Form, also. 18 BY MR. SCAROLA: 19 Q. Is it your contention that Bradley Edwards was 20 ever personally involved in manufacturing false and/or 21 fraudulent Court Opinions or Orders? 22 A. Attorney/client privilege. 23 Q. Your Complaint makes reference to someone 24 sifting through a potential defendant's garbage looking 25 for damaging evidence to use with investors to show how Page 73 1 garbage. 2 Q. Which garbage man sifted through your garbage? 3 A. Pm sure people who go through garbage sift 4 through the garbage. I have no idea. 5 Q. Did anyone ever sift through your garbage 6 looking for damaging evidence? 7 A. It's been widely reported in the newspapers, 8 sir, that the Rothstein firm engaged in sifting through 9 many people's garbage in order -- in an attempt to 10 blackmail them. 11 Q. Yes. But I didn't ask you what some newspaper 12 is alleged to have reported. 13 What I did ask you is whether anyone ever 14 sifted through your garbage looking fa damaging 15 evidence. 16 And the answer to that question, I think, can 17 be either yes, no, or l don't !mow. 18 MR. PIKE: Move to strike. 19 BY MR. SCAROLA: 20 Q. Or you could refuse to answer it on the 21 grounds that it may tend to incriminate you. 22 A. I think you might — 23 MR. PIKE: Move to strike. 24 THE WITNESS: I would like to answer my own 25 questions. If you'd like to answer all my PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 19 (Pages 70 to 73) 1ddcfb841b324-4437-a670-165e29067146 EFTA01076630 Page 74 1 questions, Mr. Scamla, I'm more than happy to sit 2 hem end answer them. Would you like to continue? 3 BY MR. SCAROLA: 4 Q. Yes. N like to know what the answer to that 5 question is. Did anyone ever sift through your garbage 6 looking for damaging evidence? 7 MR. PIKE: Form. 8 THE WITNESS: I don't know. 9 BY MR. SCAROLA: 10 Q. Did you ever have damaging evidence in your 11 garbage? 12 A. What's damaging evidence, sir? 13 Q. Evidence tending to implicate you in criminal 14 conduct. 15 MR. PiKE: Form. 16 THE WITNESS: At least today, Mr. Scuola, 17 with these — with your questions and your claims 18 and your defeats* of Mr. Edwards and his firm, the 19 Rothstein film, while his partner sits in jail, 20 today I'm going to have to assert my Fifth, Sixth 21 and 14th Aowanent Right, sir. 22 BY MR SCAROLA: 23 Q. Did you ever have any evidence in your garbage 24 that would subject you to blackmail? 25 MR. PIKE: Form. Same — same objection. Page 76 1 You've been interchanging knowledge with personal 2 knowledge. And many of the objections to which i 3 am asserting an attorney/client and work product 4 privilege are based upon your malphrased question 5 and use of personal knowledge and knowledge 6 interchangeably with those questions. 7 So if you want to rephrase your question to 8 attempt to elicit a response -- let me finish- 9 then I have no objection to that. However, rim not 10 going to sit here and allow my client to waive 11 attorney/client and work product. 12 Now, to the extent you're saying Fm coaching 13 the witness, I object to that because I am 14 certainly not. The witness is here to answer your 15 questions and i believe has been answering your 16 questions today to the best of his ability. 17 MR. SCAROLA: i am saying you're coaching the 18 witless. 19 BY MR. SCAROLA: 20 Q. Could you answer the question? 21 MR.. PIKE: Same objection. 22 THE WITNESS: You'll have to repeat it. 23 BY MR. SCAROLA: 24 Q. Do you have any information indicating that 25 Bradley Edwards ever had any knowledge of anyone Page 75 1 THE WITNESS: Again, I'll respectfully answer 2 the question by asserting my Fifth, Sixth and 14th 3 Amendment Right. 4 BY MR. SCAROLA: 5 Q. Your Complaint in paragraph 21, page 9, says 6 that: "Upon information and belief, Rothstein, David 7 Roden, Debbie Villegas, Andrew Barnett, Michael Fistert 8 and Kenneth Jenne, all employees of RRA, through brokers 9 or middle men would stage regular meetings during which 10 false statements were made about the number of 11 cases/clients that existed or RRA had against Epstein 12 and the value thereof." 13 Do you have any knowledge that Mr. Edwards 14 ever knew about such meetings being conducted? 15 MR. PiKE: Form. 16 To the extent you understand the question and 17 it will not violate any attorney/client or work 18 product privilege information, you can answer that 19 question. 20 MR. SCAROLA: Mr. Pike, it has become evident 21 that that speaking instruction to your witness is 22 an instruction for him to assert an attorney/client 23 privilege, regardless of whether it is or is not 24 valid and I object to it. 25 MR. PIKE: Let me make the record clear. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 77 associated with the Rothstein firm holding meetings during which, quote, "false statements were made about the number of cases/clients that existed or RRA had against Epstein and the value thereof," unquote? MR. PIKE: Form. Same objection. THE WITNESS: My best recollection is the U.S. Attorney has accused the Rothstein firm of just those types of meetings where the partners got together, schemed to defraud local investors of millions of dollars by fabricating cases of a sexually charged nature. And whether Mr. Edwards personally participated, fm going to at least today, sir, have to assert the attorney/client privilege, but look forward to one day disclosing It MR. SCAROLA: Move to strike all unresponsive portions of the answer. BY MR. SCAROLA: Q. Paragraph 23 of your Complaint says that: "RRA, Rothstein and Edwards, claiming the need for anonymity with regard to existing or fabricated clients, they were able to effectively use initials," et cetera. Do you have any knowledge that Bradley Edwards fabricated a client to bring a claim against you? MR. PiKE: Form. PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 20 (Pages 74 to 77) lddclbB4-b324.4437-a670-765029067145 EFTA01076631 Page 78 Page 80 1 THE WITNESS: I believe Mr. Scherer's 1 MR. PIKE: then, please, -- 2 Complaint — 2 THE WITNESS: Yes. 1 BY MR. SCAROLA: 3 MR. PIKE: — answer Mr. Scarola's question. 4 Q. I'm not asking about Mr. Scherees Complaint 4 THE WITNESS: Separate from — I'm asking about any evidence that you have. 5 MR. SCAROLA: Objection. Coaching the MR. PIKE: The witness is basically been five 6 witness. words into his sentence and you're not allowing him 7 THE WTINESS: Separate from the communication to finish, once again. 8 I've had with my attorneys, I can't answer that 9 So if you recall the question, then please 9 question. 10 respond. 10 MR. PIKE: Mr. Scarola, I'm confused. I 11 THE WITNESS: Please repeat it back, please? 11 started objecting to form in the beginning of this 12 MR. PIKE: Madame Court Reporter, if you 12 deposition. You then instructed me, which is 13 would. 13 against the rules, Mr. Pike, I don't know what's 14 (Pending question was read.) 14 wrong with the form. I object to you objecting to 15 MR. PIKE: Form. 15 form. 16 THE WITNESS: The pleadings of Mr. Scherer and 16 Then I assert the attorney/client, work 17 his claim against the Rothstein finn for a massive 17 product, and now you're telling me I'm coaching the 18 fraud, as well as Mr. Sakowitz's claims to -- at 18 witness. 19 least in the — described in the public press, 19 So tell me, Mr. Scarola, what is the — what 20 because he went to the FBI, for fabricating cases 20 is the way that you would like me to object In this 21 that included initials. 21 deposition, and maybe I can conform that way for 22 With respect to anything specific with 22 you, which may or may not be consistent with the 23 Mr. Edwards, I'm going to have to claim the 23 Florida Rules of Civil Procedure. 24 attorney/client privilege today, sir. 24 MR. SCAROLA: Mr. Pike, — 25 BY MR. SCAROLA: 25 MR. PIKE: Yes, sir. Page 79 Page cc 1 Q. Do you have any -- do you have knowledge of 1 MR. SCAROLA: — if you don't know the 2 the existence of any evidence that Bradley Edwards knew 2 difference between a form objection and a privilege 3 that Rothstein was utilizing RRA as a front for a Ponzi 3 objection — 4 scheme? 4 MR. PIKE: Right 5 MR. PIKE: Form. 5 MR. SCAROLA: — then this deposition is not 6 THE WITNESS: That's attorney/client 6 the proper context in which for you to learn the 7 Privilege. 7 difference between a form objection and a privilege 8 BY MR. SCAROLA: 8 action. 9 Q. Do you have knowledge of any evidence that 9 MR. PIKE: Tm pretty clear on what a form 10 would indicate Bradley Edwards should have known that 10 objection is and what a privilege objection is and 11 Rothstein was utilizing RRA as a front for a Ponzi 11 I'm pretty knowledgeable on that. The problem — 12 scheme? 12 MR. SCAROLA: Then we don't need to engage in 13 MR. PIKE: Fount. 13 any further discussion. 14 THE WITNESS: At least today — 14 MR. PIKE: — I want to try to make the record 15 MR. PIKE: Wait 15 clear, because initially you didn't want me to 16 THE WITNESS: Sorry. 16 object to /ann. You wanted me to speak So I'm 17 MB. PIKE: Form. Same objections. Same 17 thinking you're conceding to that point 18 attorney/client, work product as to the last 18 What my question is, is: What's wrong with my 19 question. Same objections here, attorney/client 19 objecting to attomey/client, work product? So 20 work product. 20 guess Tm asking you what you were asking me 21 THE WITNESS: And today I'm going to have to 21 earlier on. What's wrong with the form? 22 assert the attorney/client privilege. 22 We can just move forward. 23 MR. PIKE: To the extent you can answer that 23 BY MR. SCAROLA: 24 question — 24 Q. In your Complaint you identify the RRA law 25 THE WITNESS: I understand. 25 firm, Rothstein and Edwards, as the, quote, "litigation • 21 (Pages 78 to 81) PROSE COURT REPORTING AGENCY, INC. IIIIMIIMIIIIII Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 1ddcfb84-b324-4437-a670-765e29067145 EFTA01076632 Page 82 1 team," unquote. 2 You then go on to say in paragraph 31 of your 3 Complaint at page 12 that: "Rothstein and the 4 litigation team" — 5 MR. PIKE: Wait a minute. Put that down for a 6 second. Hold on. 7 THE WITNESS: You can read it. 8 BY MR. SCAROLA: 9 Q. "Individually and in a concerted effort may 10 have unethically and illegally engaged in certain 11 specified conduct." 12 May we correctly conclude from that statement 13 that you don't have any knowledge as to whether the, 14 quote, "litigation team," including Mr. Edwards, engaged 15 in any unethical and illegal conduct? 16 MR PIKE: For now, while I'm reviewing the 17 document itself, I'm just going to just tell you to 18 hold off — 19 THE WITNESS: Sure. 20 MR. PIKE: — on answering that question. 21 You may want to go off the record, so we don't 22 have a lag in -- 23 MR. SCAROLA: No, I'd hie it on the record. 24 Thank you. 25 MR. PIKE: Mr. Scuola, did you bring an extra Page 84 1 Edwards, individually and personally, sold, allowed to 2 be sold and/or assisted with the sale of an interest in 3 non-settled personal injury lawsuits? 4 MR. PIKE: Before you answer that question, 5 Madame Court Reporter, will you please read that 6 question back tome? 7 (Pending question was read.) 8 MR. PIKE: To the extent you can answer that 9 question without divulging attorney/client or work 10 product information, you may answer that question. 11 MR. SCAROLA: Objection. Coaching. 12 THE WITNESS: You said, allowed to be sold. 13 I'm going to assert attorney/client privilege to 14 the answer, I'm afraid, but I'd like to answer that 15 question. 16 BY MR. SCAROLA: 17 Q. Do you have knowledge of any evidence 18 indicating that Bradley Edwards ever reached agreements 19 to share attorney's fees with non-lawyers? 20 MR PUCE: I'm sorry. Mr. Scarola, can you 21 tell me what page of the Complaint you're referring 22 to, if you are? 23 MR. SCAROLA: I'm not referring to any page of 24 the Complaint, although I will tell you that that 25 precise allegation is made in the Complaint. Page 83 1 copy of the Complaint that you're questioning 2 Mr. Epstein on for Mr. Epstein to look at? 3 MR. SCAROLA: No. 4 MR. PIKE: Okay. I'm going to have to go get 5 him a copy so he can — the paragaphs of this 6 Complaint are very long and the Complaint itself is 7 in excess of — It was approximately 35 pages, 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. SCAROLA: I'll withdraw the question. BY MR. SCAROLA: Q. Do you have any evidence that Brad Edwards sold, allowed to be sold and/or assisted with the sale of an Interest in non-settled personal injury lawsuits? MR. PIKE: Form. THE WITNESS: The newspapers have widely reported that the Rothstein firm engaged in illegal sPectuted settlements of cases of a sexual nature, including specifically, me. We have subpoenaed the documents from Mr. Edwards and his firm and we have not been able to get them as of yet. I am confident that once we do, I will be able to answer your questions with more specificity. BY MR. SCAROLA: Q. As you sit here today, do you have any evidence whatsoever to support an assertion that Bradley Page 85 1 THE WITNESS: In fact, Mr. Scarola, we have 2 subpoenaed Mr. Edwards' documents and documents 3 from his firm that I believe will, in fact, give me 4 more specificity with the answers to that question. 5 I'm looking forward to getting the -- that 6 specific evidence. With respect to what we 7 currently know, sitting here today, I'm 8 unfortunately going to have to claim my 9 attorney/client privilege. 10 BY MR. SCAROLA: 11 Q. Do you today have any evidence to support an 12 assertiraubat ar t dley Edwards ever used investor money 13 to pay , and/or Jane Doe up-front money, such 14 that they would refuse to settle civil actions? 15 MR. PUCE: Same instruction. 16 THE WITNESS: Youll have to get — I need to 17 hear the first part of the question. Do I have any 18 evidence? Do I have knowledge of evidence? I'm 19 sorry. What was the — 20 BY MR. SCAROLA: 21 Q. Do you have knowledge of any evidence to 22 support that assertion? 23 MR. PIKE: To the extent you can answer that 24 question without violating attorney/client, work 25 product, please do so. PROSE COURT REPORTING. AGENCY, INC. 22 (Pages 82 to 85) Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 lddcf b84-b324-4437-a670-765o29067145 EFTA01076633 Page 86 1 MR. SCAROLA: Objection. Coaching, 2 THE WITNESS: Fm going to have to assert the 3 attorney/client privilege, Tm afraid, though I'd 4 like to answer that question as well, sir. S BY MR. SCAROLA: 6 Q. Do you have arty evidence to support the 7 assertion that Bradley Edwards conducted searches, wire 8 taps or intercepted conversations in violation of State 9 or Federal laws and Bar rules? 10 A. Your question, once again, asked did Mr. — 11 was Mr. Edwards personally involved in the 12 eavesdropping? Did he walk to someone's house and sort 13 of put a bug in their house? Did he, personally, stand 14 outside? 15 The question is, did Mr. Edwards' firm engage 16 in this behavior in an attempt to defraud local 17 investors out of millions of dollars? The U.S. attorney 18 has filed a Complaint saying that they did. The 19 Complaints filed by Scherer saying that his firm did 20 The Scherer Complaint says my name and the 21 boxes of files that we've subpoenaed used my name, sir. 22 We have requested information, but up until 23 today have not received any. 24 To give you a more specific answer, Tm afraid 25 I cannot. Page 88 1 To the extent ybu can answer the question 2 without disclosing attorney/client or work product 3 information, do so. 4 THE WITNESS: The pleadings of Mr. Scherer 5 with respect to the largest Ponzi scheme in South 6 Florida's history engaged in by Mr. Edwards' firm 7 and Scott Rothstein, who currently sits in jail, 8 probably for the rest of his life for engaging in, 9 not only illegal wire taps and eavesdropping, but 10 an abuse of the entire legal system, I believe 11 speaks for itself. 12 Unfortunately, with respect to Mr. Edwards 13 today, I'm going to have to assert the 14 attorney/client, work privilege, sir. 15 BY MR. SCAROLA: 16 Q. Is it your contention that Mr. Scherer's 17 Complaint even contains the name Bradley Edwards? 18 A. I don't recall, sir. 19 Q. Did sexual assaults ever take place on a 20 private airplane on which you were a passenger? 21 MR. PIKE: Form. Relevance. 22 THE WITNESS: At least — I would like to 23 answer each and every, one of your questions here 24 today, Mr. Scarola. But at least today, I'm going 25 do have to assert my Fifth, Sixth and 14th Page 87 1 Q. Do you have knowledge of any evidence that 2 Bradley Edwards ever conducted searches, wire taps or 3 intercepted conversations in violation of State or 4 Federal laws and Bar mks? 5 MR PIKE: Same instruction. 6 THE WITNESS: The newspapers and the U.S. 7 Attorney's Complaint widely reported that 8 Mr. Edwards' firm and people hired by his firm, 9 investigators hired by his firm fraudulently 10 representing themselves as FBI agents engaged in 11 just those activities, sir. 12 BY MR. SCAROLA: 13 Q. Do you have any knowledge of any evidence that 14 Bradley Edwards was ever aware of any such activities? 15 A. I'm going to have to — 16 MR. PIKE: Same objection. 17 THE WITNESS: - assert the attorney/client 18 privilege to that, sir. 19 BY MR. SCAROLA: 20 Q Do you have any knowledge that Bradley Edwards 2.1 ever participated in or was aware of actions that 22 utilized the judicial process, including, but not 23 limited to, unreasonable and unnecessary discovery for 24 the sole purpose of furthering a Ponzi scheme? 25 MR. PIKE: Same objection. Page 89 1 Amendment Rights as provided by the U.S. 2 Constitution. 3 BY MR. SCAROLA: 4 Q. Does a flight log kept for a private jet used 5 by you contain the names of celebrities, dignitaries or . 6 International figures? 7 A. At least today, sir, I'm going to have to 8 respectfully decline to answer based on my Fifth, Sixth 9 and 14th Amendment Right, though I'd like to answer that 10 question. 11 Q. Have you ever had a personal relationship with 12 Donald Trump? 13 A. What do you mean by 'personal relationship," 14 sir? 15 Q. Have you socialized with him? 16 A. Yes, sir. 17 Q. Yes? 18 A. Yes, sir. 19 Q. Have you ever socialized with Donald Trump in 20 the presence of females under the age of 18? 21 A. Though I'd like to answer that question, at 22 least today I'm going to have to assert my Fifth, Sixth 23 and 14th Amendment Right, sir. 24 Q. Have you socialized with Alan Dershowitz? 25 A. Yes, sir. He's my attorney, as well as a PROSE COURT REPORTING Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 23 (Pages 86 to 89) AGENCY, INC. ldcleftgWb324-4437.a670-766029067145 EFTA01076634 Page 90 1 friend. 2 Q. Have you ever socialized with Alan Dershowitz • 3 in the presence of females tmder the age of 18? 4 MR. PIKE: Form 5 THE WITNESS: Sir, at least here today, I'm 6 going to have to assert my Fifth Amendment, Sixth 7 Amendment and 14th Amendment Rights. 8 BY MR. SCAROLA: 9 Q. Have you ever socialized with Tommy Mottola? 10 A. This is the type of questions where people who 11 have nothing to do with this case whatsoever have been 12 brought into the case by Mr. Edwards in an attempt to 13 simply imperil my relationships with social friends and 14 serves as an example of why this case has been brought 15 against Mr. Edwards and his firm, sir. 16 MR. PIKE: Form as well. 17 BY MR. SCAROLA: 18 Q. Well, do you know who brought those persons' 19 names into this lawsuit? 20 MR. PIKE: Form. 21 And just to be clear, what Mr. Scarola, I 22 believe, talking about this lawsuit, Epstein versus 23 RRA? 24 BY MR. SCAROLA: 25 Q. Yes, sir, that's the lawsuit I'm talking 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 92 this — just this type of behavior, the answer is, today, at least, I must assert my Fifth, Sixth and 14th Amendment Right, though I'd lie to answer each and every one of your questions, Mr. Scarola. BY MR. SCAROLA: Q. Have you had a social relationship with David Copperfield? A. Asa reaction to, once again, the abusive discovery process of bringing in names of people that have absolutely nothing to do with any of Mr. Edwards', Mr. Rothstein's or their clients' claims, by bringing in the names of friends of mine strictly in an attempt to stress my relationships, imperil my business relationships, I'm going to say, yes, I do know Mr. Copperfield. Q. Have you ever socialized with David Copperfield? A. Again, as — MR. PIKE: Form. THE WITNESS: Sony. It's a typical Edwards/Rothstein strategy of trying to involve well-known people in maliciously fabricated cases in order to fleece investors out of millions of dollars. They brought up names in attempts at abuse of discovery process to try and Page 91 about. The one in which your deposition is being taken 2 today. 3 Do you know who brought those persons' names 4 into this lawsuit? 5 A. As a reaction, and only as a reaction to total 6 misbehavior on Mr. Edwards' pan, and the Complaint was 7 obviously written by my attorneys, sir. 8 Q. So you know that those names are in your 9 Complaint, right? 10 A. Yes, sir. 11 Q. Okay. So because those names are in your 12 Complaint, Pm asking you about the people you named. 13 Have you had a social relationship with Tommy 14 Mottola? 15 A. The names in my Complaint are strictly as a 16 reaction to the abusive discovery process by 17 Mr. Edwards, his partners, Scott Rothstein, who sits in 18 jail, in an attempt to imperil my friendships. 19 But, yes, I have socialized with Mr. Mottola. 20 Q. Have you ever socialized with Mr. Mottola in 21 the presence of females under the age of 18? 22 MR. PIKE: Form. 23 THE WITNESS: At least today, the typical to 24 the Edwards contention of bringing cases of a 25 malicious nature where his partner sits in jail for 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 93 take discovery of people who have nothing to do with this case. Did I socialize with David Copperfield? The answer is, yes. BY MR. SCAROLA: Q. Did you ever socialize with David Copperfield in the presence of females under the age of 18? A. Pm sure, again, this question is a typical question of Mr. Edwards/Rothstein scheme to defraud investors, asking questions knowing it serves no purpose or relationship relevance to their case whatsoever. At least today, though I'd like to answer that question, on advice of my Counsel, and only on advice of my Counsel, Prn going to have to assert my Fifth. Sixth and 14th Amendment Right MR. PUCE: Form as well. BY MR. SCAROLA: Q. Have you ever had a social relationship with Bill Richardson, Governor of New Mexico and formerly U.S. Representative and Ambassador to the United Nations? MR. PIKE: Form. THE WITNESS: As is typical of the Edwards scheme, along with his partner, Scott Rothstein, who sits in jail, what they attempted to do was PROSE COURT REPORTING AGENCY, INC. 24 (Pages 90 to 93) Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401M1 1 ddcfb84-b324-4437-a670-765029067145 EFTA01076635 Page 94 1 bring in any celebrity I might have known, 2 well-known people, in an attempt to strictly 3 imperil my relationships with these people where 4 these people have no bearing whatsoever on any of S their claims or cases. 6 Yes, I do have a social relationship. 7 BY MR. SCAROLA: 8 Q. Have you ever socialized with Mr. Richardson 9 in the presence of females under the age of 18? 10 MR. PIKE: Font 11 THE WITNESS: Again, typical of the 12 Edwards/Rothstein scheme of bringing in well-known 13 people, asking them ridiculous questions, 14 ridiculous questions in an attempt strictly to 15 imperil my relationships with these people where 16 they have absolutely nothing to do with anything to 17 do with Edwards, Rothstein or any of their alleged 18 victims, the answer to your question is, yes, I 19 have socialized. 20 BY MR. SCAROLA: 21 Q. Yes, but that wasn't my question. 22 My question was: Have you ever socialized 23 with Mr. Richards in the presence of females under the 24 age of 18? 25 MR PIKE: Form. 1 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 96 question, I'm told by my Counsel that if I choose to do so, which is my preference, I risk losing their representation. BY MR. SCAROLA: Q How many children have you sexually abused? MR. PIKE: FOnn. And I just want to be clear on the record. These types of questions are argumentative and harassing. And, moreover, it's my contention that these types of questions are not related to this lawsuit by any stretch of the imagination. In this deposition, while I've been liberal in allowing these questions, are being utilized in an attempt to provoke a waiver of the Fifth Amendment Right. There has been an Order entered by, I believe, Judge Hafele regarding these types of questions. So with that caution, Mr. Scarola, I would ask you that you refrain from asking abusive and harassing questions that are not relevant to this case. MR SCAROLA: Well, ifs very interesting that you claim they're not relevant when they are directly taken from the allegations in your Complaint. And I agree with you that they are not Page 95 1 THE WITNESS: In response to your question, 2 again, my full answer was, typical of the 3 Edwards/Rothstein scheme to ask questions of a 4 sexual charged nature, crafted cases, the U.S. 5 Attorney has called his firm the largest fraud in 6 U.S. history, fleecing investors out of millions of 7 dollars by engaging in just these types of 8 questions. Though I would like to answer each and 9 every question about every one of these people, on 10 advice of my Counsel today, I must take — assert 11 my Fifth Amendment, Sixth Amendment and 14th 12 Amendment Right. Though I'd prefer to anew the 13 question, I was told that if I choose to do so, I 14 risk losing their representation, sir. 15 BY MR. SCAROLA: 16 Q. Have you ever sexually abused children? 17 MR. PIKE: Form. 18 THE WITNESS: On advice of Counsel, and only 19 upon advice of Counsel, though I'd like to answer 20 that question, as well as every other one of your 21 claims brought by Mr. Edwards and his partner, who 22 currently sits in jail, sir, I would like to answer 23 those questions. But today at least, I have to 24 assert my Sixth Amendment, 14th Amendment and Fifth 25 Amendment Right. Though I'd prefer to answer the Page 97 1 relevant because there is no basis whatsoever for 2 this claim against Mr. Edwards. But since you've 3 made these baseless allegations, I am obliged to 4 pursue the allegations by asking these questions. 5 So we'll move on from there. And whenever you 6 think it's appropriate to terminate this deposition 7 because you believe that I've acted 8 inappropriately, be my guest. 9 MR. PIKE: I appreciate your invitation, 10 Mr. Scarola 11 I'm going to move to strike. 12 The fact is, Mr. Scarola, is that, these types 13 of questions have already been ruled upon as being 14 argumentative and harassing. 15 If you want to direct some questions relevant 6 to your lawsuit, I invite you to do so. But 17 attempting to use this deposition process as a 18 mechanism to provoke a waiver of the Fifth 19 Amendment and to obtain information that is more or 20 potentially more relevant to Mr. Edwards' cases in 21 which he is lead Counsel on, I think is improper. 22. BY MR. SCAROLA: 23 Q. Did you have staff members that assisted you 24 in scheduling appointments with underage females; that 25 is, females under the age of 18? PROSE COURT REPORTING AGENCY, Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 25 (Pages 94 to 97) INC. 1ddcfb1144)324-4437-a670-7654,29067145 EFTA01076636 Page 98 A. So along with many of the other claims that the Rothstein firm crafted with malicious claims against 3 people like me and others of a sexually charged nature -1 in order to simply fleece investors out of millions of dollars in South Florida, those types of questions, though I'd like to answer today, at least this specific 7 question, Pm going to have to assert, unfortunately, my Fifth, Sixth and 14th Amendment Right, though I'd prefer 9 to answer the question. 10 BY MR. SCAROLA: 11. Q. Who are the others referred to in that 12 response? 13 A. Again, sir? 14 Q. You said you and others. Who are the others 15 that you were referring to? 16 A. You'll have to read my answer back. 17 MR. PIKE: I'm sorry. Madame Court Reporter, 18 would you please read the witness' answer back? 19 THE WITNESS: You'll have to I have to take 20 a bathroom break 2/ MR.. PIKE: Actually 1 don't ono second. 22 For the record, we're going on 12:30 now. Is 23 there — do you have a time frame as to when you — 24 MR. SCAROLA: About a half hour. 25 MR. PIKE: You have a half hour left? Page 100 1 reference in that response? You said, "me and others." 2 Who are the others? 3 A. Can you repeat where it says me and others? 4 Pm sony. 5 MR. SCAROLA: Read it back again, please, 6 Sandy. 7 (Answer was read.) 8 THE WITNESS: The others are people reported 9 in the press to be many people in South Florida who 10 were the victims of the Rothstein scam. 11 I'm glad — I'm happy to answer the others. 12 Pd Wm to know the others. In fact, we've 13 subpoenaed documents from the bankruptcy trustee of 14 Brad Edwards' rum in an attempt to find out more 15 details of the others that you've just asked about. 16 People — I believe the Attorney Scherer has 17 filed a Complaint for some of the others who have 18 been defrauded, as well as some of the investors 19 who were told about many others, sir. 20 BY MR. SCAROLA: 21 Q. So you don't know any names; is that comet? 22 MR. PIKE: Form. Move to strike. 23 Mischaraoterizes the witness' testimony. 24 THE WITNESS: Fm sure that's an — it's an 25 easy way of saying that as a response to the Page 99 1 MR. SCAROLA: Uh-buh. 2 MR. PIKE: Okay. Do you have an objection to 3 us taking a quick bathroom break and -- 4 THE WITNESS: just walk out and back in. 5 MR. SCAROLA: If Mr. Epstein needs to go to 6 the bathroom, Mr. Epstein needs to go to the 7 bathroom. 8 THE WITNESS: Thank you, sir. 9 MR. PIKE: Then we're off the record? 10 VIDEOGRAPHER: We're off the record. 11 (Brief recess.) 12 VIDEOGRAPHER: We are back on video record at 13 12:43 p.m. 14 BY MR. SCAROLA: 15 Q. I think when we went off the record you had 16 requested that the last answer that you gave and the 17 question asked of you based on that answer be read back, 18 so we'll start there. 19 MR. PIKE: Madame Court Reporter. 20 (Previous question and answer were read.) 21 THE WITNESS: Sounds like a complete runner to 22 me. 23 BY MR. SCAROLA: 24 Q. NO, Sir. My question to you following that 25 answer was: Who are the others to whom you made Page 101 1 questions and subpoenas we've asked Mr. Edwards to 2 produce so we can find out the specific names of 3 the others who have been — the U.S. Attorney has 4 claimed have been blackmailed and victims of the 5 Rothstein firm. 6 I'd be happy, and hopeffilly at the end of this 7 trial everyone will know some of the names of the 8 others, sir. 9 BY MR. SCAROLA: 10 Q. Do you know the names of any of the others? 11 A. No, sir, I do not. However, the U.S. 12 Attorney, we believe, is going to file more charges 13 against Mr. Roth — Mr. Edwards' partners. And 14 Mr. Scherer and us have subpoenaed the bankruptcy 15 trustee for the names of the others. 16 So sitting here today, I do not. Hopefully 17 sometime before trial we will have names of the others, 18 sir. 19 Q. Have you ever pled guilty to any criminal 20 wrongdoing? 2/ A. Yes, sir. 22 Q. What criminal wrongdoing did you plead guilty 23 to? 24 A. A solicitation of prostitution and procuring a 25 minor for prostitution, sir. iftltilm,...hmawmehweaLL.4.44.,..0w PROSE COURT REPORTING 26 (Pages 98 to 101 AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 lddcfb84-b324-4437-3670-765029067145 EFTA01076637 Page 102 Page 104 1 Q. On how many occasions did you solicit 2 prostitution? 3 A. Under — excuse me? Again? 4 Q. On how many occasions did you solicit 5 prostitution? 6 A. At least sitting here today, going to have 7 to, on advice of Counsel, assert my Fifth Amendment, 8 16th Amendment (sic) and Fourth (sic) Amendment Right. 9 Q. On how many occasions did you plead guilty to 10' soliciting prostitution? 11 A. Once, sir. 12 Q. How many acts of solicitation of prostitution 13 did you plead guilty to? 14 A. Three. 15 Q. What are the names of the individuals who you 16 pled guilty to soliciting as prostitutes? 17 A. 1 do not know. 18 Q. When did those acts occur? 19 A. I do not know. 20 Q. How many prostitutes have you solicited? 21 MR. PIKE: Fonn. 22 THE WITNESS: On advice of Counsel, at least 23 sitting here today, sir, I'd like to answer each 24 one of those questions. However, today Em going 25 to have to assert my Fifth, Sixth and 14th 1 MR. PIKE: Form. And relevance. 2 BY MR. SCAROLA: 3 Q. How many minors have you procured for 4 prostitution? 5 MR. PIKE: Fenn. 6 THE WITNESS: On advice of Counsel, sir, I'm 7 going to have to assert my Fifth, Sixth and 14th 8 Amendment Right, though I pled guilty to procuring 9 a single minor. 10 BY MR SCAROLA: 11 Q. Yes, but my question wasn't about what you 12 pled guilty to. I just want to know how many minors you 13 have procured for prostitution. 14 MR. PIKE: Asked and answered. 15 THE WITNESS: Again, at least with respect to 16 what I've pled guilty to, !pled guilty to 17 procuring a single minor. 18 With respect to the rest of your question, Fm 19 going to have to assert my Fifth, Sixth and 14th 20 Amendment Rights as provided by my Counsel. 21 BY MR. SCAROLA: 22 Q. When did you procure the minor for 23 prostitution as to which procurement you pled guilty? 24 MR. PIKE: Form. 25 THE WITNESS: i don't know. Page 103 1 Amendment Right. 2 BY MR. SCAROLA: 3 Q. Who are the minors who you solicited for 4 prostitution? 5 MR. PIKE: Form. 6 THE WITNESS: Who aro the — I pled guilty to 7 soliciting prostitution. There was no soliciting 8 minors charge, sir. 9 MR. SCAROLA: Could you read back the response 10 to the question about what Mr. Epstein pled guilty 11 to, please? 12 MR. PIKE: About four questions bark. 13 (Previous question and answer were read.) 14 MR. PIKE: And his answer? 15 MR. SCAROLA: That was his answer. 16 BY MK. SCAROLA: 17 Q. Who are the minors who you procured for 18 prostitution? 19 MR. PIKE: Form. 20 THE WITNESS: I believe if you — my answer 21 was procuring a minor, sir, not minors. 22 BY MR. SCAROLA: 23 Q. Who is the minor that you procured for 24 prostitution? 25 A. I do nor know. Page 105 1 BY MR. SCAROLA: 2 Q. Was there a time before you entered your 3 guilty plea when you knew the identity of the 4 prostitutes that you solicited? MR. PIKE: Form. 6 THE WITNESS: Again? 7 BY MR. SCAROLA: 8 Q. Was there a time before the entry of your 9 guilty plea when you knew the identity of the 10 prostitutes you solicited? 11 MR. PIKE: RIM 12 174E WITNESS: I don't recall. 13 BY MR. SCAROLA: 14 Q. Was there a time before the entry of your 15 guilty plea when you knew the identity of the minor that 16 you pled guilty to procuring for prostitution? 17 MR. PIKE Form. 18 114E WITNESS: 1 don't know. 19 BY MR. SCAROLA: 20 Q. Did you plead guilty because you were, in 21 fact, guilty? 22 MR. PIKE: Form. 23 That's attorney/client, work product 24 Attorney/client 25 MR. SCAROLA: I haven't asked anything about 27 (Pages 102 to 105) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 1 ildcf b84-b324-4437-a670-765029067145 EFTA01076638 Page 106 1 any communication. 2 MR. PIKE: It definitely could get into a 3 communication with Mr. Epstein's lawyers at the 4 time of the criminal proceeding. 5 MR. SCAROLA: No, sir, it can't. 6 BY MR. SCAROLA: 7 Q. I want to know whether you pled guilty because 8 you were, in fact, guilty. 9 A. I'm going to have to assert my Fifth, Sixth 10 and 14th Amendment, sin 11 Q. Do you understand the term John to be a slang 12 reference to the customer of a prostitute? 13 MR. PIKE: Form. 14 THE WITNESS: Yes, sir. 15 BY MR. SCAROLA: 16 Q. How many times were you one A% 17 customers? 18 MR. PIKE: Form 19 THE WITNESS: f.'s customers. 20 You'll have to rephrase the question, sir. 21 BY MR. SCAROLA: 22 Q. Your Complaint says — 23 MIL PIKE: What page were you reading from? 24 MR. SCAROLA: Page 22. 25 MR. PIKE: Thank you. Page 108 1 crafting cases of a sexual nature against people in 2 South Florida, me and others, the others yet to be 3 determined. However, today, though I'd like to 4 answer every one of his questions, on advice of 5 Counsel, at least today, I'm going to have to 6 assert my Fifth, Sixth and 14th Amendment Right. 7 BY MR. SCAROLA: 8 Q. How many times have you engaged in fondling 9 underage females? 10 MR PIKE: Form 11 THE WITNESS: This is relevance here at some 12 point? 13 MR. PIKE: To the extent you can answer the 14 question. 15 THE WITNESS: Again, as another one of the 16 irrelevant questions asked of this lawsuit with 17 respect as a client how I was abused by the 18 Rothstein firm for his — the practices, the abuse 19 of the legal system, the — hopefully, the ladies 20 and gentlemen of the jury will be able to see 21 through some of these ridiculous questions with 22 respect to questions that today, at least, l must 23 take the Fifth, Sixth and 14th Amendment, but I 24 believe are obvious to the ladies and gentlemen of 25 the jury what you're trying to do here, Page 107 1 BY MR. SCAROLA: 2 Q. Paragraph 46(a), last sentence: "Under the 3 circumstances, her claim for damages against Epstein, 4 one ofe.'s many Johns during that same period," et 5 cetera. 6 You have identified yourself in this Complaint 7 as one oft.'s many Johns, which you acimowledge to be 8 a reference to a customer of a prostitute. 9 How many times were you one 10 customers for purposes of prostitution? 11 A. Well, now that you've now put on the record 12 theta., I believe, in her deposition is an admitted 13 prostitute, I would like to answer that question, but on 14 advice of Counsel, sir, I'm going to have to 15 respectfully decline. But I am happy to hear you 16 finally admit it in your own questions that your... is 17 an admitted prostitute. 18 MR. SCAROLA: Move to strike. Unresponsive. 19 BY MR. SCAROLA: 20 Q. Have you ever coerced, induced or enticed any 21 minor to engage in any sexual act with you? 22 MR. PIKE: Penn. 23 THE WITNESS: A typical question from 24 Mr. Scarola representing Mr. Edwards and the firm 25 of Rothstein, who Scott Rothstein sits in jail for Page 109 1 Mr. Scarola. 2 MR. SCAROLA: Move to strike. Unresponsive. 3 MR. PIKE: No. That's fine. 4 BY MR. SCAROLA: 5 Q. How many times have you engaged in illegal 6 sexual touching of minors? 7 MR. PIKE: Form. Relevance. 8 THE WITNESS: Again, an irrelevant question to 9 this lawsuit, strictly as a continued attempt to 10 bring in irrelevant facts to the fact of what the 11 Rothstein firm has done to both me and others in 12 South Florida, defrauding investors of millions of 13 dollars, knowing that at least today I'm going to 14 have to with respect to that particular question 15 assert my Fourth excuse me — Fifth, Sixth and 16 14th Amendment Rights. 17 MR. SCAROLA: Move to strike as unresponsive. 18 MR. PIKE: Mr. Scarola, he's answering your 19 question. You're asking abusive and harassing 20 questions that are unrelated to this lawsuit. 21 If you can direct me to anywhere in the 22 Complaint that even remotely addresses your two 23 questions that you've just posed to Mr. Epstein, 24 I'd be happy to look at the section in the 25 Complaint. But moving to strike the witness' 28 (Pages 106 to 109) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401= Electronically signed by Sandra Townsend (401 1ddc1b84-b3244437-a670.766029067145 EFTA01076639 Page 110 1 answer when he's answering your abusive and 2 harassing questions is improper. 3 BY MR. SCAROLA: Q. How many times have you engaged in oral sex with females under the age of IS? o MR. PIKE: Objection. Relevance. Abusive and 7 harassing. Not reasonably calculated to lead to 8 discovery of admissible evidence in this case. 9 THE WITNESS: A typical question posed by 10 Mr. Scarola in an attempt to divert the attention 11 away from the wrongdoing of Bradley Edwards, his 12 partner, Scott Rothstein, who sits in jail for 13 defrauding investors of South Florida of millions 14 of dollars, by crafting malicious cases of a sexual 15 nature just in order to fleece investors, called by 16 the U.S. Attorney one of the largest frauds in 17 South Florida's history. 18 Mr. Scarola, as I would like to respond to the 19 questions regarding of your underage girls, the 20 fondling or the other questions you've asked me 21 here today, unfortunately, I cannot on advice of 22 Counsel answer those questions, so I must assert my 23 Filth, Sixth and 14th Amendment Rights, though 24 these questions are totally irrelevant to this 25 lawsuit. Page 112 1 Harassing. And not reasonably calculated to lead 2 to admissible evidence in this case. 3 THE WITNESS: One more of Mr. Scarola's 4 irrelevant questions designed nothing more to try 5 to harass me, to divert attention from the fact 6 that Mr. Edwards and his firm perpetrated one of 7 the largest frauds in South Florida's history by 8 using people like me and others in an attempt to 9 fleece South Florida investors out of millions of 10 dollars, where the U.S. Attorney has accused his 11 fin]] of being the largest militia& enterprise in 12 South Florida's history, where Mr. Edwards' partner 13 sits in prison, potentially for the rest of his 14 life. 15 IV like to answer all of your questions here 16 today, Mr. Scarola, even though they're irrelevant; 17 however, on advice of Counsel, at least today, I'm 18 going to have to assert my Fifth, Sixth and 14th 19 Amendment Right. 20 MR. SCAROLA: Move to strike as unresponsivc. 21 BY MR. SCAROLA: 22 Q. Your Complaint at page 27, paragraph 49, says 23 that: TRA and the litigation team took an emotionally 24 driven set of facts involving alleged innocent, 25 unsuspecting, underage females and a Palm Beach Page 111 1 MR. SCAROLA: Move to strike as unresponsive. 2 BY MR. SCAROLA: 3 Q. Do you have a personal sexual preference for 4 children? 5 MR. PIKE: Form. Relevance. Abusive. 6 Harassing. Not reasonably calculated to lead to 7 the discovery of admissible evidence in this case. 8 THE WITNESS: Mother totally irrelevant 9 question to this lawsuit, Mr. Edwards' behavior, in 10 an attempt to strictly divert attention from the 11 wrongdoing of the Rothstein firm in this matter by 12 asking sexually charged questions in a case where 13 the Rothstein firm has been charged by the U.S. 14 Attorney of fabricating claims of a malicious 15 nature, hiding behind attomey/client privilege, 16 forging documents excuse me but as with 17 respect to these questions designed for nothing 18 more than to harass me, Mr. Scarola, I'm going to 19 have to, unfortunately, take the Fifth, Sixth and 20 14th Amendment 21 MR. SCAROLA: Move to strike as unresponsive. 22 BY MR. SCAROLA: 23 Q. Have you ever acted on a sexual preference for 24 children? 25 MR. PIKE: Form. Irrelevant. Abusive. Page 113 1 billionaire, and sought to turn it into a gold mine," 2 end of quote. 3 Who is the Palm Beach billionaire referred to 4 in that sentence? 5 A. On advice of Counsel today, Mr. Scarola, 6 thought would like to answer each one of your 7 questions, I'm going to have to assert my Fifth, Sixth 8 and 14th Amendment Right. 9 Q. What is die emotionally driven set of facts to 10 which you make reference in that sentence? 11 A. It's the same set of facts that were used by 12 the Rothstein firm to fleece unsuspecting investors out 13 of millions of dollars, crafting, fabricating malicious 14 cases of a sexually charged nature with no fundamental 15 basis whatsoever, reported wildly by the press. The 16 U.S. Attorney has accused Mr. Edwards' partner of not 17 excuse me — Mr. Edwards' partner sits currently in 18 jail, pled guilty to some of these charges. There are 19 other members of his firm under investigation for just 20 these types of questions and fabrications. 21 But, however, today, though I'd like to answer 22 every one of your questions with specificity, on advice 23 of Counsel I'm not going to be able to, Mr. Sterols, and 24 respectfully decline based Fifth, Sixth 25 Amendment Right. 29 (Pages 110 to 113) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 1ddctb84-b324-4437-a670-765o29067145 EFTA01076640 1 2 . 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 114 Q. What day are you prepared to answer all these questions? MR. PIKE: Form. Attorney/client and work product. THE WITNESS: That's attorney I wish I could answer that question as well, but ifs attorney/client privilege, sir. BY MR. SCAROLA: Q. Your Complaint says that: "Rather than evaluating and resolving the cases based on the merits," open parens, "i.e., facts," close patens, "which included larowledgeable, voluntary and consensual actions by each of the claimants; et cetera. Who are the claimants that are referenced there? A. It's — I'm sorry. You have to repeat the question. Q. Yes, sir. Your Complaint says,: -- MR. PIKE: Page? Q. -- "rather than evaluating" -- MR. PIKE: Can you give me a page, sir? MR. SCAROLA: Page 27, paragraph 49, second sentence. BY MR. SCAROLA: Q. Quote, "rather than evaluating and resolving Page 116 1 and 14th Amendment. 2 Si What are the voluntary and consensual actions 3 by M. that you are referencing there? 4 A. Sir, though I'd like to answer each one of 5 your questions here today, I'm going to have to 6 respectfully decline based on advice of my Counsel, and 7 have to assert my Fifth, Sixth and 14th Amendment Right. 8 Q. What are the damages that you claim to have 9 suffered as a consequence of any wrongdoing on the part 10 of Bradley Edwards? 11 MR. PIKE: Fenn. 12 THE WITNESS: The cost of ridiculous 13 litigation, of having my attorneys prepare 14 responses to wildly Irrelevant discovery in various 15 locations at a minimum, sir. 16 BY MR. SCAROLA: 17 Q. Which lawyers? 18 A. Burman Critton, Jack Goldberger, and a bunch 19 of the others, sir. 20 Q. Which ones? Name them for me, please. 21 A. Specifically — !have so many lawyers 22 defending me here against Mr. Edwards, I can't sit 2 3 here — at the moment I can't recall it with 24 specificity. 25 Q. You don't remember any of your lawyers' names? Page 115 1 the cases based on the merits, that is, facts which 2 included knowledgeable, voluntary and consensual actions by each of the claimants." 4 A. Yes. Q. Who are the claimants that you're referencing 6 there? A. They're the prostitutes you referred to in the 8 past, sir. 9 Q. What are their names? 10 A. I think the prostitute? names were the 11 prostitute that you described before was M. 12 With respect to the others, Fm going to have 13 to claim the Fifth, Sixth and 14th Amendment, sir. 14 Q. So one of the individuals that you're 15 referencing there is is that correct? 16 A. It's — the individual I've referenced is a 17 person who filed a claim against me. 18 Q. hit ? 19 A. It is , as far as I 'mow from the claim, 20 sir. 21 Q. Okay. So one of the people that you're 22 referring to is who you've identified as ni; is 23 that correct? 24 A. With respect to that question, sir, on advice 25 of Counsel, I'm going to have to assert my Fifth, Sixth Page 117 1 A. Oh, I do. 2 Q. Besides Mr. — besides the Burman Critton firm 3 and Mr. Goldberger? 4 A. Are you asking me for the firm, sir, or are 5 you asking me for the names? 6 Q. I want as much information as you can give me 7 about this element of damage which you claim; and, that 8 is, the cost of legal services that you claim to be 9 damages in this case. 10 A. Okay. 11 MR. PIKE: Form. And move to strike. 12 THE WITNESS: Mr. Roy Black. 13 BY MR. SCAROLA: 14 Q. Okay. Who else? 15 A. Mr. Marty Weinberger. Mr. Alan Dershowitz. 16 Mr. Jay Lefkowitz. The firm of Bunnan Critton Luther. 17 That's it for the moment. 18 Q. How much have you paid the law firm of Burman 19 Critton and Luther which you claim is damages? 2 0 A. Hundreds of thousands of dollars, sir. 21. Q. How much? 22 A. I don't have that figure offhand. 23 Q. Can you give us any better figure than 24 hundreds of thousands of dollars? 25 A. No, not sitting here today. 30 (Pages 114 to 117) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 1ddefb84-b324-4437-a670-766.210067145 EFTA01076641 Page 118 1 Q. Are you paying them on an hourly basis? 2 A. Yes, sir. 3 Q. What is the hourly rate at which you are 4 compensating members of the law firm? 5 A They're ordinary rates. 6 Q. What are they? 7 A. I don't know. 8 Q. How much have you paid Mr. Goldberger? 9 A. I'm not aware total amount, sir. 10 Q. What is the hourly rate at which you're paying 1/. Mr. Goldberger? 12 A. His normal hourly rate. 13 Q. How much is that? 14 A I don% know. 15 Q. How much have you paid Mr. Black which you 16 claim as damages in this case? 17 A Hundreds of thousands of dollars. 18 Q. Are you paying him on an hourly basis? 19 A. I believe so. 20 Q. What is the hourly rate? 21 A. I'm not — 'do not know, sir. 22 Q. How much have you paid Marty Weinberg& 23 A I don't know the exact amount, sir. 24 Q. What's your best estimate? 25 A. More than a hundred thousand dollars. Page 120 1 A. I don't }mow. 2 Q. Does someone do that on your behalf? 3 A. I would guess so. 4 Q. Who? 5 A. I don't know. 6 MR. PIKE: Form. 7 BY MR. SCAROLA: Q. Who are the people who are authorized to make 9 payment on your behalf? 10 A. With respect to that question, I'm going to 11 have to assert the Fifth, Sixth and 14th Amendment, sir. 12 Q. Are there any other elements of damage, apart 13 from the money paid to lawyers? 14 A. Yes, sir. 15 Q. What? 16 A. The stress and emotional damage of imperiling 17 my friendships and business relationships with no 18 relevance whatsoever to these cases, brought by a rum 19 that whose partner sits in a Federal prison, who engaged 20 in discovery to harass my friends and social contacts 21 with no consideration or relevance to this case 22 whatsoever, in an attempt to simply fleece — partly 23 fleece investors In South Florida out of millions of 24 dollars, sir. 25 Q. What is the value of those losses? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. A. Q. A. Q. A. Q. A Page 119 Are you paying him on an hourly basis? I believe so. What's the hourly rate? I don't know, sir. How much have you paid Alan Dershowitz? Hundreds of thousands of dollars. A!e you paying him on an hourly basis? I believe so. Q. At what hourly rate? A I don't know, sir. Q. How much are you paying Jay — how much have you paid Jay Letkowitz? A. I'm not sure, sir. Q. Do you have any idea at all? A. More than a hundred thousand dollars. Q. Are you paying him on an hourly basis? A. Yes, sir. Q. What's the hourly rate? A I don't know. Q. What is the form of payment to your lawyers? How do you transfer money to them? A. I don't know, sir. MR. PIKE: Form. BY MR. SCAROLA: Q. Pardon me? Page 121 1 MR. PIKE: Form. 2 THE WITNESS: I'm not sure yet, sir. 3 BY MR. SCAROLA: 4 Q. Do you have any idea at all? 5 A Not sitting here today. 6 Q. More or less than $10? 7 MR. PIKE: Form. 8 THE WITNESS: I would guess it's more than 9 $10, sir. 10 BY MR. SCAROLA: 11 Q. More or less than a hundred? 12 I would guess it's quite an amount of money. 13 Is it more or less than a hundred? 14 Yes, sir. 15 More or less than a thousand? 16 I would say it's more than 150,000. 17 More or less than a million? 18 I don't Imow, sir. 19 So somewhere between 150,000 and a million? 20 No, sir. It's not — 21 MR. PIKE: Form. Mischaracterizes the 22 witness' testimony. 23 THE WITNESS: No, sir. That's not what I 24 said. I said, !did not know. 25 BY MR. SCAROLA: A Q. A Q- A Q. A A 31 (Pages 118 to 121) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (4011/1. 1ddcfb84-b324-4437-a670-765c29067145 EFTA01076642 Page 122 Page 124 1 Q. Maybe more than a million? 2 A. Maybe. 3 Q. More or less than a billion? 4 MR. PIKE: Fonn. 5 THE WITNESS: I don't know. 6 BY MR. SCAROLA: 7 Q. Maybe more than a billion? 8 A. Maybe more. 9 Q. How are you going to go about finding out what 10 the value of that loss is? 11 MR. PIKE: Attorney/client, work product. 12 To the extent you can answer without 13 disclosing our conversations or the conversations 14 with your other attorneys that you've delineated, 15 you can do so. 16 BY MR. SCAROLA: 17 Q. Or you can just take the signal and say, I 18 refuse to answer because it's attorney/client privilege. 19 A. I resent that 20 MR. PIKE: Move to strike. 21 THE WITNESS: But its okay. You can continue 22 to try to harass me, sir. It doesn't work. The 23 ladles and gentlemen of the jury, hopeftilly what 24 they see the deposition will recognize and see 25 these pile of ticks. The answer — 1 BY MR. SCAROLA: 2 Q. Do you attribute all of the damages that you 3 have described to Mr. Edwards' conduct? 4 MR. PIKE: Form. 5 THE WITNESS: As a participant — I don't know 6 how to proportion the conduct as opposed to 7 Mr. Edwards and his partner who sits in jail. I 8 guess the U.S. Attorney will also make a decision 9 to how much the conduct and proportion is relevant 10 to both damages and anything else he's done in this 11 case, sir. 12 BY MR. SCAROLA: 13 Q. But Pm not asking you about what the U.S. 14 Attorney's opinion is. 15 I want to know whether you hold Mr. Edwards 16 responsible for all of those elements of damage that you 17 have described to us. 18 A. It's a difficult question to answer, 19 Mr. Scarola. 20 Q. No, it's easy. Yes, no, or I don't know. 21 MR. PIKE: Mr. Scarola, you know as well as I 22 do, the witness is attempting to answer your 23 question. 24 MR. SCAROLA: I don't think so. I think he's 25 attempting to evade all of my questions. Page 123 1 MR. SCAROLA: Hopefully they will. 2 THE WITNESS: Yes. 3 MR. PIKE: Move to strike. THE WITNESS: I will respectfully decline to answer that. BY MR. SCAROLA: Q. On what basis? 8 A. Attorney/client privilege. MR. PIKE: And work product. 10 BY MR. SCAROLA: 11 Q. Any other elements of damage? 12 A. Not -- there might be, but sitting here today, 13 I can't think of them. 14 Q. Do you have written contracts with any of your 15 lawyers? 16 A. I don't know. 17 Q. Who does? 18 A. I don't know. 19 MR. SCAROLA: Let's take a short break. We 20 may be finished. 21 VlDEOGRAPHER: We are now off the record at 22 1:12p.m. 23 (Brief recess.) 24 VIDEOGRAPHER: We are back on video record at 25 1:18 p.m. 1 2 3 4 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 125 MR. PIKE: And I understand your contention. However, if you would, allow Mr. Epstein to finish his response. THE WITNESS: Could you repeat your question? BY MR. SCAROLA: Q. Do you hold Mr. Edwards responsible for all of the damages that you have described? MR. PIKE: Font THE WITNESS: It's difficult for me to proportion the damages that I have described between Mr. Edwards, his partner, who is currently in jail, his -- the other people named in the Complaint Hopefully a jury will do that. BY MR. SCAROLA: Q. Do you hold M. responsible for all of the damages you have described? MR. PIKE: Form. THE WITNESS: Again, these questions, these ambiguous questions, as opposed to who participated, I would let Mr. Edwards and his clients and his partners decide whose proportionate responsibility it is, sir. BY MR. SCAROLA: Q. So you defer to them? MR. PIKE: Fonn. deatat WCOJY.VataLolailC•SPILliraile•S•• PROSE COURT REPORTING AGENCY, Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 32 (Pages 122 to 125) INC. iddcfb84-b324-4437-8670-765e29067145 EFTA01076643 Page 126 1 THE WITNESS: As proportionate to the amount 2 of damages, I think Mr. Edwards played a vital 3 role. I believe his partners potentially played a 4 role. I've only had any contact with Mr. Edwards, 5 sir. 6 BY MR. SCAROLA: 7 Q. Which partners? 8 A. Beg your pardon? 9 Q. Which partners, besides Mr. Edwards and 10 Mr. Rothstein, do you claim engaged in conduct that 11 renders them liable to you? 12 A. I believe it's in the Complaint, sir. And 1 13 believe it's Mr. Adler, Mr. Berger. There's Mr. Jenne, 14 Mr. Fisten, but those are not partners. 15 So Mr. Berger, Mr. Adler — and I forgot the 16 mines of the others at the moment, sir, but it's in the 17 Complaint 18 Q. Why didn't you sue them? 19 MR. PIKE: Form. 20 THE WITNESS: Attorney/client privilege, sir. 21 MR. PIKE: Work product 22 MR. SCAROLA: I have no further questions. 23 MR. EDWARDS: I have three or four questions. 24 That's it. 25 MR. PIKE: Okay. I just want to be clear for 1 2 3 4 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 128 contention on the record. Okay. CROSS EXAMINATION BY MR. EDWARDS: Q. Mr. Epstein, is your sole basis for your claim against M. that she changed her testimony from the time she testified to the FBI id2007? MR. PIKE: Form. To the extent you can answer that question without invading attorney/client, work product, you can do so. THE WITNESS: Unfortunately, I'd like to answer that question, but I can't do so without invading attorney/client privilege. BY MR. EDWARDS: Q. Is there anything in Nis Complaint that was filed against you in September of 2008 which you contend to be false? MR. PIKE: Asked and answered. THE WITNESS: I recognize, Mr. Edwards, again, the concept of attempting me to get to waive my Fifth Amendment privilege; however, in this lawsuit I've answered questions with respect to your lawsuit. And with regard to the question you just asked, I'm going to have to, unfortunately, assert my Fifth Amendment, Sixth Amendment and 14th Page 127 1 the record. Mr. Scarola represents Mr. Edwards in 2 this case; is that correct, Mr. Scarola? MR. EDWARDS: That's correct. MR. SCAROLA: Yes. MR. PIKE: And in this particular case, a• • Epstein versus Rothstein, et al, Mr. Edwards, who 7 do you specifically represent? 8 MR. EDWARDS: M. MR. PIKE: Okay. I believe that if you follow 10 through with questioning, you have an 11 irreconcilable conflict with rItEd to the other 12 case in which you represent M. and M. 13 1 cannot stop you from asking any questions; 14 however, if you do move forward with asking 15 questions, I will take the appropriate action. 16 MR. SCAROLA: And on behalf— on behalf of my 17 client — 18 MR. PIKE: Yes, sir. 19 MR. SCAROLA: — we do not accept your 20 assessment of Mr. Edwards' ethical 21 responsibilities. 22 MR. PEKE: That is absolutely fine for you to 23 do that. I just wanted to put it on the record 24 that 1 am, by no means, going to prevent you from 25 questioning today. However, I wanted to put my Page 129 1 Amendment Right. 2 But I'm willing to listen to any other 3 questions you may have. 4 MR. EDWARDS: Finished. 5 MR. PIKE: 1 have a couple questions. 6 CROSS EXAMINATION 7 BY MR. PIKE: 8 Q. Mr. Epstein, earlier in the deposition 9 Mr. Scarola was reading from page 2 of the Complaint 10 filed in the Epstein versus Rothstein, Rosenfeldt and 11 Adler, et aL Do you recall that? 12 A. Yes, sir. 13 Q. And then I showed you page 2 of a Complaint 14 that I bad my notes on, correct? 15 A. Yes. 16 Q. Did you read the black type or did you mad 17 the handwritten notes in the corners of the Complaint, 18 that particular page that I showed you? 19 A. Unfortunately, my eyesight is not good enough 20 to read the notes. I only read the black letter. 21 Q. And it was that one sentence, correct? 22 A. It was two sentences, I believe, but, yes. 23 MR. PIKE: Thank you. 24 Well real. 2 5 REDIRECT EXAMINATION PROSE COURT REPORTING AGENCY, Electronically signed by Sandra Townsend (401 Electronically signod by Sandra Townsend (401 33 (Pages 126 to 129) INC. 1ddcfb84-b324-4437-8670-766029067145 EFTA01076644 D 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 130 BY MR. SCAROLA: Q. What is your eyesight? A. Sorry? Q. What is your eyesight? A. My eyesight? Q. Yes, sir. You said that your eyesight was not good enough to be able to read the handwritten notations. What is your eyesight? A. Are we on the record or off? Q. We're on the record. MR. PIKE: We're on the record. THE WITNESS: I need 3.5 glasses. BY MR. SCAROLA: Q. And you had those on when you were reading the Complaint, didn't you? A. But these aren't my 3.5s, sir. Q. What are they? A. I don't know. Q. Let's hand them over, if you would. Let's take a look at them. A. Sure. Do you see anything? Q. No. Is it your contention that those glasses were inadequate to enable you to read the handwritten 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 132 to read the handwritten notations; is that correct? MR. PIKE: Form. TEE WITNESS: In this particular instance, sir, these glasses did not. I'm not saying they cannot, but did not allow me to read the notes, that's correct MR. SCAROLA: I would hie those glasses marked as an Exhibit to this deposition. MR. PIKE: I don't think so. MR. SCAROLA: You're refusing to allow that to happen? MR. PIKE: I don't see how you can mark a set of glasses as an Exhibit to a deposition. The witness has already said that he did not read the handwritten notes in the corner or the corners of page 2 of the Complaint. MR. SCAROLA: The witness is a liar. The witness' testimony is totally incredible. The witness made up a response and I want to be able to demonstrate to the Court and jury that the witness lied when he said that those glasses did not correct his vision sufficiently to be able to read the handwritten notes. I want the glasses marked as an Exhibit. If you refuse to mark them, lam placing you Page 131 1 notations on the Complaint? 2 MR. PIKE: Form. Mischaracterizes testimony. 3 THE WITNESS: My testimony was, I only read 4 the black letter and partially because I cannot see thoroughly through these glasses, sir. 6 BY MR. SCAROLA: 7 Q. Is it your contention that those glasses did 8 not sufficiently correct your vision to be able to read 9 the handwritten notations on the papers that were handed 10 to you? 11 MR. PIKE: Form. 12 THE WITNESS: Again, we can play this game 13 back and forth. What ljust said, and I think I 14 was very clear, that I did not read the notes. 1 15 said 16 BY MR. SCAROLA: 17 Q. What you said was, you couldn't read the 18 notes? 19 MR. PIKE: Allow the witness to finish. 20 THE WITNESS: Let me fetish. And what I said 21 was, with these glasses it would be almost 22 impossible for me to read the notes on the page. 23 BY MR. SCAROLA: 24 Q. Yes, sir. So your contention is, that those 25 glasses do not adequately correct your vision to be able 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page on notice that they are relevant and material to issues involved in this lawsuit and need to be preserved. MR. PIKE: All right. We'll mark the glasses. We'll mark the glasses as an Exhibit. Okay? And I will keep them here in my office. MR. SCAROLA: Thank you. MR. PIKE: That's fine. VIDEOGRAPHER: This concludes today's videotaped deposition ofJeffrey Epstein. The time is 1:27. (Exhibit number I was marked for identification purposes and retained by Counsel le• Plaintiff.) (Witness excused.) (Deposition was concluded.) 34 (Pages 130 to 133) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 tddclb84-b324.4437-a670-765029067145 EFTA01076645 Page 134 Page 136 17 18 19 20 21 22 23 24 25 2 3 4 5 6 7 1 CERTIFICATE OF OATH STATE OF FLORIDA COUNTY OF PALM BEACH I, the undersigned authority, certify that JEFFREY EPSTEIN personally appeared before me and was 8 duly sworn on the 17th day of March, 2010. 9 10 11 12 13 14 15 Dated this 26th day of March, 2010. ciatchtetioast Sandra W. Townsend, Cant 16 Notary Public - State of Florida My Commission Expires: 6/26112 My Commission No.: DD 793913 Job #1358 1 DATE: March 26, 2010 2 TO JEFFREY EPSTEIN Job II358 do hficbad Pile. Esquire 3 303 Banyan Boulevard, Suite CO West Pabn Beach, Florida 33401 5 DIRE: Epatem vs, Edwards. etas CASEN02 502609CA0408003COCOABAG 6 Phase take ram that oc Wednesday, the 17th 7 of histch,20104ou gave your deposition, in the alxweiefened nutter. At that rune, you did not waive 9 signature. It is now neonatey that you sign your deposition. 9 Please call our office al the belesolisted number to schedule an semoitinnat brewed, the boos of 10 960 a.m. and 4:30 p.m_ Mondry &mash Pnday, at the Esquire office leered neared 11 If you do riot read and sign the deposition withal a reasonable time, the oeiginal. whet bas 12 already beta fonvuded to the cadet* adorn*, may be filed with the Oak of the Cows If you wish to want 13 you signature. sign your name in the blank at the bottom of this terra and serum it to us 14 15 16 17 Very truly met Sandra W Townsend, PPR PROSE COURT REFORM() AGENCY I a 150 Australia Awn" &ate 1500 17 West Pailltrida 33401 Flame I do haeby waive my nithamre. _2 JEI₹REY EPSTEIN I do hereby waive my signature: cc: Via tract* All Conned of Record; file copy 25 1 2 3 7 a 9 CERTIFICATE STATE OF FLORIDA COUNTY OF PALM BEACH I. Sandra W Townsend. Court Resume tied Wary Public in and for the Sue of florid, at Large, do hereby certify that the aforememioned wtneut wu by me first duly sum to testify the vobtie truth; that I wat nothorized to and did mood raid donation in nemtype, and that the foregoing pages numbered — to —inchanu, we a inn and correct transcription of my shorthand notes of said deposition I further °edify that said deposition was 10 lakes at the time and place hereinabace set forth and Out the taking of mid deposition nit commenced and II ethoploted as hereinalxec set out. 12 I (tether certify that I an not attorney or comet of any of the patios. nor am I a relative or 13 employee of nue attorney or counsel of patty connected with the action, nor am ! financially intetened in de 14 mean. 15 The fon:going certificatica of this transcript does not 4,ply to any reproduction of the sane by any 16 means unless wider the died control ands direction of the canning divot/ 17 19 19 20 21 22 23 24 25 Dated this 26th day of March, 2010. ~ 1 moult Stain W. Townsend, Court Reporter Job It WS Page 135 Page 1 3 7 1 CERTIFICATE 2 3 THE STATE OF FLORIDA 4 COUNTY OF PALM BEACH 5 I hereby certify that 'have read the 6 foregoing deposition by me given, and that the 7 statements contained herein are true and correct to the 8 best of my knowledge and belief, with the exception of 9 any corrections or notations made on the errata sheet, 10 if one was executed. 11 12 Dated this day of 13 2010. 14 15 16 17 18 19 JEFFREY EPSTEIN 20 Job #I358 21 22 23 24 25 35 (Pages 134 to 137) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 1 ddcfb84-b324-4437-a670-765e29067146 EFTA01076646 Page 138 1 ERRATA SHEET 2 IN RE: EPSTEIN VS. EDWARDS, ET AL at S. TOWNSEND 3 DEPOSITION OF: JEFFREY EPSTEIN 4 TAKEN: 3/17/10 10B740.: 1358 5 6 DO NOT WRITE ON TRANSCRIPT- ENTER CHANGES HERE 7 PAGE/ LINEN CHANGE REASON 9 :0 it 12 13 14 15 16 17 18 Please Reward the original signed errata sheet to this office so that copies may be distributed to SI parties. Under penalty of perjury, I declare that I have read my 20 deposition and that it is true and COMO subject to any changes in form or substance mitered here. 19 21 22 DATE: 23 24 S1ONATUREOF DEPONENT: 25 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401M Electronically signed by Sandra Townsend (401 36 (Page 138) iddclb844,324-44374670-765029067145 EFTA01076647