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efta-efta01089049DOJ Data Set 9OtherIN THE CIRCUIT COURT OF THE
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efta-efta01089049
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IN THE CIRCUIT COURT OF THE
15TH JUDICIAL CIRCUIT, IN AND
FOR PALM BEACH COUNTY, FLORIDA
CASE NO.: 502009CA040800XXXXMBAG
JEFFREY EPSTEIN,
Plaintiff,
vs.
SCOTT ROTHSTEIN, individually,
and BRADLEY J. EDWARDS,
individually,
Defendants.
VIDEOTAPE DEPOSITION CONT'D OF BRADLEY EDWARDS
VOLUME II OF II
PAGES 110 - 250
October 10th, 2013
10:00 A.M. - 2:30 P.M.
401 East Las Olas Blvd., Suite 1400
Fort Lauderdale, FL
Stenographically Reported By:
WENDY ROBERTS, RPR
Notary Public, State of Florida
Empire Legal Support, Inc.
Fort Lauderdale Office
Phone:
EFTA01089049
Bradley J. Edwards taken on 10/10/20 I 3
APPEARANCES:
ATTORNEY(S) FOR MR. EPSTEIN:
TONJA HADDAD COLEMAN, ESQUIRE
Tonja Haddad, PA
315 SE 7th St Ste 301
Fort Lauderdale, Florida 333013158
Phone:
Fax:
E-Mail:
FRED HADDAD, ESQUIRE
Fred Haddad PA
1 Financial Plz Ste 2612
Fort Lauderdale, Florida 333940061
Phone:
Fax:
E-Mail:
JACK GOLDGERGER, ESQUIRE
Atterbury Goldberger ■
Al
250 S Australian Ave Ste 1400
West Palm Beach, Florida 334015015
Phone:
Fax:
E-Mail:
ATTORNEY FOR BRADLEY EDWARDS:
WILLIAM KING, ESQUIRE
Searcy Denney Scarola ■
Al
2139 Palm Beach Lakes Blvd
West Palm Beach, Florida 334096601
Phone:
Fax:
E-Mail:
ALSO PRESENT: JEFF EPSTEIN, PLAINTIFF (telephonically)
DEBRA FEIN, LAW CLERK
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INDEX
WITNESS:
BRADLEY EDWARDS
Direct Examination cont'd by MR. HADDAD
EXHIBITS
Page
114
PLAINTIFF'S:
EXHIBITS:
Description
Page
Comp. No. 1 Response to RP#7 Correspondence between
BJE and US Government RE Epstein in BJE
Possession 66 pages
244
Comp No. 2
E-mail from Russell Adler to Bradley
Edwards RE: Oct. 28th depo, sent on
10/14/09 58 pages
244
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1
(Continued from Volume I dated May 15th, 2013.)
2
Videotape Deposition taken before Wendy Roberts,
3
Registered Professional Reporter and Notary Public in
4
and for the State of Florida at Large, in the above
5
cause.
6
_ _ _
7
THE VIDEOGRAPHER: We are now on the video
8
record. Today's date is October 10th, 2013. The
9
time is 10:15 A.M. Would counsel please state
10
their appearances for the record.
11
MR. KING: William King, Searcy Denney Scarola
12
Barnhart & Shipley for Mr. Edwards.
13
MR. GOLDBERGER: All right. Jack Goldberger,
14
Atterbury, Goldberger & Weiss, West Palm Beach, on
15
behalf of Jeffrey Epstein.
16
MR. INDYKE: Darren K. Indyke of Darren K.
17
Indyke, PLLC, on behalf of Jeffrey Epstein.
18
MR. HADDAD: I am Fred Haddad -- Fred Haddad
19
on behalf of Jeff Epstein.
20
MS. COLEMAN: Tonja Haddad Coleman, Tonja
21
Haddad, PA, on behalf of Jeffrey Epstein.
22
MS. FEIN: Debbie Fein of Tonja Haddad, PA, on
23
behalf of Jeffrey Epstein.
24
MR. HADDAD: This is a continuation of the
25
deposition of, I guess it was a couple months ago
Empire Legal Support. Inc..
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1
that we stopped.
2
Thereupon:
3
BRADLEY EDWARDS
4
having been previously duly sworn or affirmed, was
examined and testified as follows:
6
DIRECT EXAMINATION (Cont'd)
7
BY MR. HADDAD:
8
Q
And Mr. Edwards, since the deposition of last
9
time, I guess some discovery has been provided, correct?
10
A
Right.
11
Q
All right. And those would be in response to
12
request for production No. 7, I guess, correspondence,
13
and I think that's what that means R4P, correspondence
14
between BJE and U.S. Government regarding Epstein, that
15
was in your possession, correct?
16
A
Okay.
17
Q
That's what this appears to be. I think that
18
came from Scarola, if I'm not mistaken. Under response
19
to request to produce, or Scarola, Searcy Denney, II al.
20
A
Okay. It looks like correspondence between
21
myself and the United States --
22
Q
All right.
23
A
-- Attorney's Office.
24
Q
All right. And that would comp
comprise
25
all of the correspondence that was actually gauged
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1
between yourself and either, what's his name,
, or
2
Miss
3
to call her?
4
5
6
7
, whatever you want
A
That's my understanding.
Q
All right. Well, this all came from your
files and from your records, correct, e-mails, whatever
you call those things where you store e-mail servers or
8
whatever there?
9
10
11
12
A
You sent a request, I did whatever searches
that I could to come up with all of the documents
between us and I turned them over to my attorney who
turned them over to you.
13
Q
All right. And I don't know if that request
14
contained anything regarding any memorandums of
15
conversations that you might have had, telephonic
16
conversations or in-person conversations. Did any of
17
those exist?
18
A
Not to my recollection.
19
Q
Okay. So --
20
A
I think that's everything.
21
Q
That's what I'm asking, everything that there
22
is, correct?
23
A
I believe so.
24
Q
All right. And this would take -- some of
25
it's not numeric -- not numerically -- not --
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1
A
Chronological?
2
Q
Chronological, thanks for the word,
3
chronologically presented. But I note the first thing I
4
have is to
and it states something about
5
October 9, 2008, regarding some potential false
6
statements the Government made in a sworn declaration
7
with the above-captioned case. That was you writing to
8
them, correct?
9
A
What I'm looking at right now appears to be on
10
my letterhead from back then, so I would say yes.
11
Q
All right. And whatever it says, it says --
12
A
That's my signature.
13
Q
Okay. And that would be the same with all of
14
these? Let me -- let me just go through them. Let me
15
see which ones I'm going to ask.
16
MR. KING: Take your time to look at them
17
MR. HADDAD: Yeah.
18
MR. KING: -- if you think you need to.
19
MR. HADDAD: What do you think, I altered
20
them?
21
MR. KING: No, no, no, no. Because I'll need
22
to take a look at them if you have any questions
23
about --
24
MR. HADDAD: I understand that.
25
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1
BY MR. HADDAD:
2
Q
Now, the letter here that I'm looking at on
3
March 15th from Wifredo Ferrer to Paul G. Cassell, and I
4
guess it was turned over by you in this discovery, and
5
that was on March 25th of 2011, I believe, correct?
6
A
It's dated March 15th, 2011.
7
Q
Oh, I'm sorry, my glass -- even with glasses,
8
I can't see that well. All right.
9
So that was March 15, 2011. Paul Cassell, I
10
take it, was your co-counsel who was some kind of law
11
professor and judge and all that stuff?
12
A
Right.
13
Q
All right. And he was co-counsel with you on
14
these cases?
15
A
Right.
16
Q
Does he still remain co-counsel with you on
17
these cases?
18
A
Well, the only case that is remaining is the
19
Crime Victims Rights Act case --
20
Q
Yeah.
21
A
-- and yes.
22
Q
But that's been -- that's in the 11th Circuit,
23
right, now
24
A
Right.
25
Q
-- in -- pending stayed or briefing, I don't
Empire Legal Support. Inc.
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1
know what, something is out there, correct?
2
A
It has been fully briefed. I think oral
3
argument is January, February, but yes.
4
Q
All right. And he's still on that case with
5
you, correct?
6
A
Yes.
7
Q
All right. Would this letter have been
8
sent -- when this letter was sent to Mr. Cassell, would
9
you have received a copy of it contemporaneously?
10
A
I can't -- I don't know.
11
Q
All right. But somehow it --
12
A
I either got it from Paul --
13
Q
Right.
14
A
-- or I got it from them and I don't really
15
remember. Am I copied on it?
16
Q
I don't see a CC to you. No.
17
A
Okay.
18
Q
So you are familiar with this though, it was
19
in your files?
20
A
Right, I -- I was involved in the whole
21
process, so, yeah, I'm familiar with it
22
Q
Yeah, I understand that but I
23
A
Yeah, I'm familiar with it.
24
Q
-- I don't want to speculate though.
25
A
No.
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Q
I want the answer from you.
2
All right. And then on September 29th,
3
2011 -- on September 29th, 2011, there is another letter
4
to the United States Attorney, Mr. Ferrer, and it's a
5
follow-up on Jeffrey Epstein by the same Mr. Cassell,
6
correct?
7
A
That's what it appears to be.
8
9
Q
All right. There is a carbon copy to
and
, correct?
10
A
Okay.
11
12
13
Q
Okay doesn't answer. Yes or no? I need
A
That's what it appears to be.
Q
Yeah, but -- yeah, I know. I am just asking
14
you --
15
A
I mean, I didn't send the letter. I'm looking
16
at the same thing you are looking at.
17
Q
I know.
18
A
Paul signed it and then he copied
19
and
20
Q
Do you know how you received a copy of this?
21
A
I don't remember right now.
22
Q
But it is in your records?
23
A
Yes.
24
Q
And would you have read it at the time it came
25
in?
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Bradley J. Edwards taken on 10/10/2013
1
MR. HADDAD: Where is that thing of hers?
2
MR. GOLDBERGER: Chill. Chill.
3
MR. HADDAD: Chill, I always chill.
4
THE WITNESS: What is your question?
5
MR. HADDAD: I don't remember.
6
A
I think -- I think it was whether or not I
7
received it at the time that it was sent, and I don't --
8
I don't know exactly the timing of when I received this
9
letter. But it would have been close in time to when it
10
was sent. I don't know exactly.
11
BY MR. HADDAD:
12
Q
So you could -- you all were working these
13
together, correct?
14
A
Yeah, right.
15
Q
And whatever is in these documents speaks for
16
themselves, correct?
17
A
Exactly.
18
Q
Would they have engendered by you any
19
follow-up calls to the U.S. Attorney or to anyone in the
20
U.S. Attorney's Office?
21
A
No.
22
Q
All right. Things such as -- at the same
23
time, this -- Rule 26 disclosures, and Jane 1 -- and
24
Jane Doe 1 and Jane Doe 2, those are your CRVA {SIC}
25
cases, correct?
Empire Legal Support. Inc.
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1
A
Just tell me what your question is. I'm not
2
sure that--
3
Q
I said CR -- John Doe 1 and 2 your CRVA cases?
4
A
Right.
5
Q
All right. And then this is the --
6
A
That's the case number for it.
7
Q
Okay. And what I'm asking you is, this is a
8
document sent by Farmer, Jaffe, Weissing, Edwards,
9
Fistos, and then what, you emulate Searcy and Denney to
10
have as many names as they do? I guess. Any rate, this
11
is on your letterhead and it's sending the United States
12
Attorney's Office a list of, I guess, discovery; is that
13
correct?
14
A
Well, no, I think that we were just complying
15
with the 26(a) witness disclosures in that case. There
16
has always been a -- a -- I don't want to say
17
disagreement because I don't think anybody actually
18
knows whether this case falls under the civil rules of
19
procedure or criminal, but an abundance of caution, if
20
it fell under the civil rules, we felt that those
21
disclosures were necessary.
22
Q
All right. But let me ask you this: Was this
23
in response to a request to produce by the Government or
24
was this a voluntary disclosure of what you thought you
25
had as evidence? That is, I mean, was there a civil --
Empire Legal Support. Inc.
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1
2
you know, I'm not that adept at the rules of civil
procedure, but I understand that before you respond to
3
something, there is usually a request to produce,
4
request to disclose, interrogatories, something like
5
that.
6
7
8
A
Right.
Q
But you can make a voluntary disclosure at
times if you wish to -- to have litigation go forward
9
faster, as it were. I don't know the proper term --
10
A
Right.
11
Q
-- they use in civil litigation.
12
A
All right, I will tell you a couple things.
13
One is, the only thing that -- that I'm a little uneasy
14
about right now is that we are getting into work product
15
not on this case, we are not on the underlying case, but
16
on the Crime Victim's Rights Act case that is still
17
actively being prosecuted. However, to the extent that
18
I can answer this question, the purpose of this was
19
solely because Judge Marra, I believe, was of the
20
mind-set that this fell into a civil category rather
21
than criminal, and therefore, Rule 26 disclosures would
22
need to be made. And so in hopes that the Government
23
would reciprocate, we provided our witnesses and
24
expected for them to do the same.
25
Q
All right, but I understand what you are
Empire Legal Support. Inc.
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1
saying there. The simple thing -- my simple question is
2
this. Were you in the litigation status that you needed
3
to produce this or was this a voluntary production for
4
purposes of hoping the Government would respond to you?
5
A
We felt it was necessary.
6
Q
That's not my question.
7
A
I understand that.
8
Q
Was this -- okay
9
A
I don't know the answer to your question,
10
though.
11
Q
You are an attorney, you are fairly bright and
12
we went through that last time, I don't want to have to
13
go through that again, how smart you are. This was --
14
you're saying here, if you are correct that the civil
15
rules apply, that's
, then both sides of the
16
case are obligated to make voluntary initial disclosures
17
under Rule 26(a). We are writing to make our initial
18
disclosures and ask that you promptly do the same,
19
correct?
20
A
We felt it was our obligation.
21
Q
I can read what it says here.
22
A
Okay.
23
Q
We are making our initial disclosures and ask
24
you to do the same, voluntary initial disclosures, okay?
25
A
Right.
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Q
You felt it was necessary, it wasn't required
2
by rule, by anything, it was a voluntary thing you are
3
doing, as you are say in your own words, correct?
4
A
Correct.
5
Q
Did you get a response from the Government?
6
A
I don't remember.
7
Q
Okay.
8
A
This is something from March of 2011, I just
9
don't remember.
10
Q
You don't remember whether or not the
11
Government provided you a list of their discovery, their
12
evidence, their witnesses or anything, whatever there is
13
in response to Rule 26 that they are required to comply
14
with?
15
A
I can tell you they've provided us very
16
little, much less than we wanted. Have they provided us
17
nothing? I don't know that that's true.
18
Q
Well, they provided you a letter saying you
19
have no business being in this thing, but besides that,
20
have they done anything in here?
21
A
I don't remember that.
22
Q
Okay.
23
A
The -- the dockets on PACER will speak for
24
itself though, if they've made those disclosures, I
25
think --
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Q
I don't know how to open an e-mail, as you
2
well know. I am asking you a simple question. Do
3
you --
4
A
I'm trying, Fred.
5
Q
I understand you are trying, Brad, I
6
appreciate that. We all try. A little harder at my age
7
than yours but we all try. I had to get one age joke in
8
there.
9
All right. Now, correspondence has been going
10
on since 2008 -- 2008 regarding this CRVA, correct?
11
A
That's correct.
12
Q
My -- excuse me, I don't want to stutter.
13
With everything you produced, I'm at a loss to find
14
anything that was produced while you were with
15
Rothstein; is that correct?
16
A
That may be correct.
17
Q
I would like you to look through that because
18
I really want to know whether or not anything was
19
produced while you were with -- and Rothstein would be
20
Rothstein, Rothstein and Adler?
21
A
Right.
22
Q
No, Rothstein from --
23
MS. COLEMAN: Rosenfeldt.
24
BY MR. HADDAD:
25
Q
Rosen -- Rosenfeldt and Adler, your former
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partnership.
2
A
Was anything produced between
3
Q
Yeah, did you -- a CRVA --
4
A
-- April and October 2009?
5
Q
Yeah, when you --
6
A
Right.
7
Q
-- were with that firm, was there anything
8
going on between you and the Feds while you were with
9
A
Well, what you are asking though is, was
10
anything produced in the Crime Victims' Rights Act
11
while -- between --
12
Q
Okay. Let me put it this way, I mean in the
13
way of pleadings, in the way of pleadings or any type of
14
correspondence with the Federal Government. You were
15
there five months?
16
A
Five or six months.
17
Q
During those six months, let's give it six
18
months.
19
A
Fine.
20
Q
Okay. That you were with -- in this building?
21
A
Correct.
22
Q
The building that Scott built, the house that
23
Scott built. Is that like The House That Ruth Built or
24
something?
25
At any rate, at any time, were there any
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correspondence between the Federal Government and
2
Bradley Edwards' partner, Rothstein, Rothstein and
3
Adler, as the way you signed off -- or Bradley
4
Edwards -- anything?
5
A
Come on, come on. You're going to have to go
6
back in the bag and grab a question that I can actually
7
answer.
8
Q
Look through all of this and tell me if this
9
is everything you have, if there is one thing during the
10
period of time you were with Rothstein?
11
A
In this?
12
Q
In -- well, that's everything you own, you
13
said, regarding the -- that -- that request to produce
14
regarding the CRVA, as well as the correspondence.
15
A
All right. Correspondence.
16
MR. GOLDBERGER: I think you are one letter
17
away.
18
MR. HADDAD: Oh, what difference does it make,
19
he knew what I was talking about. Crime Rights,
20
Victims, Crime Victim Rights, okay. ASPCA, the
21
same thing.
22
THE REPORTER: Counsel, do you want that on
23
the record?
24
MR. HADDAD: You can type it, I don't care.
25
(Thereupon, a discussion was had off the
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record.)
2
A
I don't see anything.
3
BY MR. HADDAD:
4
Q
All right. Thank you.
5
MR. GOLDBERGER: Wait, let --
6
MR. HADDAD: What?
7
MR. GOLDBERGER: I want to make sure the
8
question is answered, Fred, before you jump on the
9
next one.
10
THE WITNESS: I was going to say --
11
MR. HADDAD: I don't have a next one to jump
12
onto yet. I just dug into a few things here this
13
morning when I got up getting my kid ready for
14
school. I just dog-eared a few things this morning
15
when I woke up, get my kid ready for school.
16
A
You were going to ask me how to do that? Oh.
17
BY MR. HADDAD:
18
Q
I have been doing it for 40-something years.
19
I have here, I forget where they came from, a
20
whole bunch of e-mails you turned over.
21
A
Okay.
22
Q
Since the last time we met, or since -- yeah,
23
since after that deposition, correct? These are e-mails
24
that were given over in discovery to Miss Coleman, I
25
believe, or somebody, to Mr. Indyke, is that -- huh?
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MR. INDYKE: To Fowler.
2
MR. HADDAD: To Fowler?
3
MR. INDYKE: Yes.
4
MR. HADDAD: Oh, how come we didn't -- okay.
5
A
Right, this predates the last deposition.
6
BY MR. HADDAD:
7
Q
All right. I -- well, did they ask you about
8
these, I don't think they would have?
9
A
They would only be you, and I don't know if
10
you have or not.
11
Q
I never saw them before. Well, I mean, you
12
can object. I'm going to ask. I don't see -- I didn't
13
see any questions or answers regarding any e-mails.
14
A
I don't remember.
15
MR. KING: At the last deposition?
16
BY MR. HADDAD:
17
Q
At the last deposition. In the first
18
deposition, Mr. Scarola didn't last -- let anybody ask
19
anything, so I'm not going to be long with these and
20
rather than go through a whole hearing, I mean, if am
21
out of order, okay, that is not unusual.
22
A
What else is new, right?
23
Q
That -- that -- yeah, I mean, this is just a
24
simple discovery depo. All I want to do is these, is
25
I've got a stack of Bates stamped things, I guess we
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found or somebody found, I don't know, of --
2
A
If you found them, I turned them over.
3
Q
I -- I understand that. I just want
4
A
I just don't want the record to make it seem
5
like they were floating around on the street.
6
Q
Brad, no one is doubting your bona fides as
7
far as discovery is concerned. When I
if I did that,
8
I would say it right out, I don't
9
A
I know.
10
Q
-- I don't hint around, you know that. All
11
right.
12
Look at -- but these would be dep -- these
13
would be e-mails that were actually during the course of
14
your time actually at --
15
MS. COLEMAN: Can I mark this as an exhibit?
16
BY MR. HADDAD:
17
Q
Rothstein, Rosenfeldt and Adler, I believe.
18
They are all in 2009, from June until -- actually,
19
think the last one is October 29th or 30th. Just look
20
through these, just for purposes -- I am not going to
21
sit here and ask you questions about everything or
22
and many of them, because, you know, they speak for
23
themselves, but I just want to make sure we are accurate
24
in what we have there, and those things would have been
25
things that you would have produced.
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Bradley J. Edwards taken on 10/10/2013
1
MS. COLEMAN: While he is looking at that,
2
just so the video is clear, the request to produce
3
regarding the Government exhibits, I have attached
4
as Exhibit 1 to the deposition that he just went
5
over and those will be Exhibit 2.
6
MR. HADDAD: Oh, okay. I don't know how to do
7
that.
8
MR. GOLDBERGER: Yes. Yes, that's what we
9
want to do.
10
MS. COLEMAN: I'm the token civil lawyer in
11
the room. I thought I would just throw that out
12
there.
13
MR. HADDAD: Token woman in the room too.
14
MR. KING: So the Rule 26 disclosures to the
15
Government will be Exhibit 1; is that right?
16
MR. GOLDBERGER: Yes.
17
MS. COLEMAN: No, no --
18
MR. GOLDBERGER: It will be part of it.
19
MS. COLEMAN: -- those -- those were
20
provided
those -- the Exhibit 1 is responsive to
21
Request No. 7 on the Schedule A, to which
22
Mr. Edwards objected prior to the last deposition.
23
So they were responsive.
24
MR. KING: All I want to know is what is being
25
marked as Exhibit 1.
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Bradley J. Edwards taken on 10/10/2013
1
MS. COLEMAN: It's all -- that's it.
2
MR. KING: This document --
3
MR. GOLDBERGER: Your resp -- Edwards'
4
response.
5
MR. KING: Got it.
6
MS. COLEMAN: This is off the record.
7
(Thereupon, a discussion was had off the
8
record.)
9
A
You want me to read through these?
10
BY MR. HADDAD:
11
Q
Just look at them and see -- you know, you
12
don't have to read every word of -- word of them, I'm
13
not going to -- if I have one I'm going to ask you
14
something about, I will tell you. I am not here to try
15
to trick you yet.
16
(Thereupon, a discussion was had off the
17
record.)
18
THE VIDEOGRAPHER: The time is 10:36 A.M. We
19
are now coming off the video record.
20
(Thereupon, a discussion was had off the
21
record.)
22
THE VIDEOGRAPHER: The time is 10:40 A.M. We
23
are now back on the video record.
24
BY MR. HADDAD:
25
Q
All right. So did you have the ability in the
Empire Legal Support. Inc.
EFTA01089071
Bradley J. Edwards taken on 10/10/2013
1
last couple of minutes to read through these e-mails,
2
correct?
3
A
Yeah.
4
Q
Do you recognize them?
5
A
Some of them.
6
Q
And some of them you do not recognize?
7
A
Well, some of them, I'm on the e-mail --
8
Q
Right.
9
A
-- some of them I'm not, so I do not recognize
10
the e-mail.
11
Q
All right. The ones that you are not on,
12
obviously, you don't know if you've seen them before?
13
A
Correct.
14
Q
Okay. Do you know whether or not you saw them
15
at the time they were produced?
16
A
Definitely not. I don't normally see them.
17
Q
Oh, excuse me, produced for discovery. Did
18
you review these before they were produced in response
19
to discovery demand by, who is it, Greenberg?
20
MR. INDYKE: It was Fowler, I believe.
21
A
Fowler White maybe.
22
MR. HADDAD: Oh, Fowler White.
23
MR. INDYKE: On demand by Fowler, yes.
24
MR. HADDAD: Yeah.
25
A
I re -- I reviewed what I think was 25,000
Empire Legal Support. Inc.
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Bradley J. Edwards taken on 10/10/2013
1
page -- pieces of paper, so I -- at some point in time,
2
I think I have probably seen them.
3
BY MR. HADDAD:
4
Q
Well, let -- let me just take one of these and
5
obviously
who's Bill -- William J. Berger?
6
A
He was an attorney at RRA, formerly a judge in
7
Palm Beach County.
8
Q
All right. Who's Pat Carter?
9
A
I don't know who Pat Carter is.
10
Q
Who's Brad Edwards?
11
A
That's me.
12
Q
Who's Grace Torres?
13
A
I don't know.
14
Q
Who's Jackie Johnson?
15
A
She was a secretary at --
16
Q
For whom?
17
A
RRA.
18
Q
Any particular, a floater or whatever they
19
call those?
20
A
She was mine for some period of time, a short
21
period of time, and maybe somebody else's, I don't
22
remember.
23
Q
All right. And this one I'm looking at,
24
Berger, is Pat -- just checking, it looks like it should
25
go to Brad Edwards -- oh, go to Brad Edwards. Brad, see
Empire Legal Support. Inc.
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Bradley J. Edwards taken on 10/10/2013
1
the attached check from Searcy, they should go into
2
trust account, you should keep your own running account
3
of checks in and out.
4
A
It is an e-mail from Bill Berger to Pat
5
Carter, who, by this, I would say the e-mail is at RRA,
6
so it is probably his secretary.
7
Q
All right.
8
A
That is what I would assume.
9
Q
Okay. But it's saying it would go to you,
10
Brad Edwards is you, this and any other others like it
11
should go to Brad Edwards. And then it says Brad. So
12
see, it says to Brad Edwards --
13
A
Right.
14
Q
-- also. Brad, see attached check from
15
Searcy.
16
A
Right.
17
Q
They should go into trust account.
18
A
Right.
19
Q
The trust account that they were going into --
20
this is dated October 26, 2009. The trust account they
21
are going into, I suppose, is RBA's trust account; would
22
that be correct?
23
A
I don't know.
24
Q
Well, it's -- they are telling you to put
25
stuff into a trust account. The only trust -- did you
Empire Legal Support. Inc..
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Bradley J. Edwards taken on 10/10/2013
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
have your own separate Brad Edwards PA trust account?
A
No. No.
Q
The only trust account you would have had was
the RRA trust account, right?
A
I didn't have an RRA trust account.
Q
The trust account that was in existence for
when you were with RRA would have been the RRA trust
account, right?
A
I don't know, I was never --
Q
Well --
A
-- part of any trust account.
Q
Well, if you received a check and it was
directed that you should put this into a trust account,
where would you put it?
A
I didn't do any of those things. Here's what
happened. All of the law firms, it was myself, Bob
Josefsberg, Jack Scarola, and Sid Garcia, Ted Leopold,
I'm missing -- Adam Horowitz or Jeff Herman or somebody,
everybody
Q
agreed or forensic accountants.
Okay.
And sent checks to the firm. I never
Q
To your firm?
A
-- asked for the firm. To RRA.
Q
Yeah.
A
I never actually saw any of the checks, so the
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Bradley J. Edwards taken on 10/10/2013
1
checks all came to one place. Somebody took possession
2
of those checks and made sure that it was, you know, all
3
pulled together for this purpose.
4
Q
Okay, let me just -- let me
5
A
It was not me though.
6
Q
That's me. Okay. It says here, they -- these
7
should go into a trust account. That's the direction to
8
you.
9
A
I know.
10
Q
I'm just asking, you know, I'm just asking
11
what it says, simple English, these should go into the
12
trust account. Did you do anything in response to that
13
ques -- that directive?
14
A
No.
15
Q
Was he some kind of superior to you, this guy,
16
Berger?
17
A
Not necessarily, I mean.
18
Q
Well, was he in the litigation division you
19
were in or was he helping run stuff? He is a judge, he
20
probably can't do too much.
21
A
He wasn't actually in this office. He worked
22
out of the Boca office.
23
Q
Oh, you guys have a Boca office too?
24
A
I think it was only him in it.
25
Q
Okay. All right. You should keep your own
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Bradley J. Edwards taken on 10/10/2013
1
running account of all checks in and out, that's a
2
directive to you from Berger. Did you keep a running
3
account of all checks in and out?
4
A
No, and I didn't take directions from Berger,
5
so the fact that he is sending me one is totally
6
meaningless to me.
7
Q
Did you ever respond to why is this numbered
8
different than the ones I have seen before and what does
9
it mean, why is it there?
10
A
I know the answer to that question, but this
11
is --
12
Q
Well, good, then tell me.
13
A
-- but this is just him -- this is just
14
evidence that he was kind of oblivious. What everybody
15
agreed to was, let's say that I represented three people
16
and Horowitz represented 10 and Bob Josefsberg
17
represented 20, the amount that you paid for the
18
forensic accountants would be pro rata based on the
19
number of clients that you represent. So if Searcy
20
Denney represented one or two, their amount would be
21
smaller than somebody who represented 10 clients. And
22
so that's what I'm -- that's why I know what Bill is
23
talking about. Why he doesn't know the answer to that
24
just means he is oblivious to how the formula was
25
working with -- amongst the various plaintiff firms that
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EFTA01089077
Bradley J. Edwards taken on 10/10/2013
1
were prosecuting the case against Jeffrey Epstein.
2
Q
And all of the money was being put into,
3
without doubt, RRA?
4
A
I don't know. I don't know if it was being
5
6
7
8
9
put into RRA or anything. All of the money came in --
Q
All right. Well, let me put it very simply.
Let's say that you were working with all these guys,
Josefsberg and the rest of these guys
A
That's true.
10
Q
-- trying to come up with $5,000 to pay the
11
forensic accountant.
12
A
Yeah.
13
Q
It came out of your trust account, correct?
14
A
I don't know.
15
Q
You don't know? Who manned the trust account,
16
who did all the -- who took all the monies out of that?
17
A
I don't know.
18
Q
You don't know anything about trust accounts?
19
A
I am assuming now what everybody knows,
20
including yourself, is that Scott Rothstein is the only
21
person that ran a trust account.
22
Q
All right.
23
MR. HADDAD: I'm so glad you can anticipate
24
everything that I'm going to ask in a few minutes.
25
Sorry.
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EFTA01089078
Bradley J. Edwards taken on 10/10/2013
1
BY MR. HADDAD:
2
Q
All right. Now, this is on October 26, 2009,
3
this is probably the last days you had trust accounts,
4
so you don't know what
what was told to Berger to
5
talk about these trust accounts, correct?
6
A
Correct.
7
Q
You don't know whether or not he was in
8
contact with Rothstein and whether Rothstein, who was
9
always looking for money was looking for money into the
10
trust accounts?
11
A
I have no idea.
12
Q
All right. You don't know whether or not
13
Josefsberg, Scarola or Searcy Denney or any of these
14
other lawyers, Herman or any of them had money in the
15
Scott Rothstein RRA trust account that was lost?
16
A
I don't -- I don't know, but in -- in -- I do
17
believe that they sent the checks. Now, what happened
18
with the checks and who accumulated the checks and where
19
the checks went to fund the forensic accounting project,
20
to determine what to do from that aspect against Jeffrey
21
Epstein, I really -- I have no idea.
22
Q
So the forens --
23
A
I didn't accept the checks, personally.
24
Q
All right. The forensic accountants were
25
going to be for what, because you were not in civ --
Empire Legal Support. Inc.
EFTA01089079
Bradley J. Edwards taken on 10/10/2013
1
were you in civil litigation, you were trying to plan a
2
depo, I guess, and have forensic account determine the
3
net worth of Epstein?
4
A
No, the idea was that it was the cumulative
5
belief of the plaintiff attorneys that Mr. Epstein was,
6
at that point in time, nearly dead in the water as it --
7
in respect to liability, and that the damages was going
8
to be extraordinary and that his only real defense
9
remaining was probably to use his experience in finances
10
to ship money offshore, hide money. And so the forensic
11
accountants were going to try to determine where he was
12
shipping money and hiding money.
13
Q
Through what vehicle?
14
A
I don't know. I'm not a
15
Q
Well, forensic accountants don't have any
16
ability to get anything unless they are presented
17
documentation and that be would the lawyer's job to
18
present the documentation, what documentation and what
19
method of production, as this was in October of 2009,
20
when you are imploding, were you guys planning on using,
21
do you know?
22
A
No, they didn't tell me.
23
Q
All right. Did --
24
A
It was only an idea between myself, Jack
25
Scarola and Bob Josefsberg, and here, let's hire
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Bradley J. Edwards taken on 10/10/2013
1
2
forensic account and see what they come up with.
Q
Okay, wait, wait, let me see if I understand
3
this. You are telling me that as you're planning all
4
these things, Scarola was involved in the conversations
5
6
7
8
on how to obtain these things?
A
Of course.
Q
Your lawyer? I'm just asking the question --
A
All of the lawyers that were prosecuting cases
9
against Jeffrey Epstein, we were all involved in all of
10
these decisions, yes.
11
Q
I understand, I just have to make it clear for
12
the record. Josefsberg was involved?
13
A
Yeah, of course.
14
Q
All right. As
as how you are going to do
15
this, right?
16
A
Of course.
17
Q
And he was your co-counsel and -- with
18
codefendants -- co-plaintiffs, Scarola, as well as
19
Josefsberg and others, correct?
20
A
Right.
21
Q
And you were pooling your thoughts, your
22
abilities and your monies?
23
A
Right.
24
Q
To go after these cases? Okay.
25
A
Exactly.
Empire Legal Support. Inc.
EFTA01089081
Bradley J. Edwards taken on 10/10/2013
1
Q
All right. Now, Bradley Edward, from Bradley
2
Edwards to Jackie Johnson, October 22nd, 2009, please
3
look at the following schedules, see if you can book a
4
conference room for many to attend as the following
5
group of people for tomorrow, 10 days before, eight
6
days -- well, not -- eight days before you guys fell
7
apart. Please look at the following schedules and see
8
if you can book a conference room for as many -- for as
9
many as can attend from the following group of people
10
for tomorrow: Jenne, Adler, Berger, Stone, Wheeler,
11
Holmes, Bruschel {SIC}, Fi
Fiston and Jaffe. Do you
12
know what that's about? Do you know why you were having
13
a conference? Obviously, from the names, it had
14
something to do with Epstein, I would imagine?
15
A
Yeah, the subject is Epstein meeting.
16
Q
Yeah. Do you know?
17
A
We would -- we would frequently have meetings
18
on cases, including this one, to brainstorm about what
19
to do with the various issues that were going on in the
20
case.
21
Q
Well, you had no other -- did you have other
22
cases while you were at RRA, besides these? I'm not
23
saying that pejoratively, I mean did you have other
24
cases?
25
A
Yeah, of course I did.
Empire Legal Support. Inc.
EFTA01089082
Bradley J. Edwards taken on 10/10/2013
1
Q
All right.
2
A
I brought with me many cases.
3
Q
I didn't -- okay, I didn't know that. Nobody
4
asked you anything about other cases pretty much, they
5
only asked you about this case. You had other cases you
6
were working on?
7
A
Right.
8
Q
Did you settle any while you were there?
9
A
I don't remember.
10
Q
Okay.
11
MR. HADDAD: Yes?
12
MR. GOLDBERGER: I just --
13
BY MR. HADDAD:
14
Q
There was one I wanted to ask you about -- you
15
know, there was one I really wanted to ask you about
16
and, of course, I'm sure I lost it. Okay. Can I have
17
one second since I haven't taken a second? I should
18
have had it dog-eared but-.-.-.
19
When was it that you first met with Josefsberg
20
and -- and Scarola and all those about pooling your
21
resources, was that before you went with RRA? I'm not
22
getting into any conversations you had, I don't want to
23
violate your --
24
A
I don't remember the exact timing.
25
Q
-- you are going to assert anyhow so.
Empire Legal Support. Inc.
EFTA01089083
Bradley J. Edwards taken on 10/10/2013
1
What did -- well, do you recall if you ever
2
met with -- I mean, Josefsberg is easy to remember, did
3
you meet with him? Did you meet with him prior to going
4
with Rothstein?
5
A
Yes.
6
Q
Okay. And it was about those cases?
7
A
It was about those cases. I don't know if it
8
was about the finances aspect.
9
Q
All right. No, just about the cases, I am not
10
going to ask you
11
A
Oh, yeah, we
12
Q
All right.
13
A
-- we were meeting as a group once or twice a
14
month from 2008 on.
15
Q
All right.
16
A
Through the end.
17
Q
And excuse my ignorance, but in criminal law,
18
when we do things like that we have what we call joint
19
defense agreements, we share stuff, we share expenses,
20
we make sure no one stabs each other in the back,
21
which -- II cetera. It's not even worth the paper it's
22
written on half the time. Did you have any sort of
23
joint agreement with these lawyers, a shared
24
responsibility agreement, a shared agreement, a written
25
agreement of any kind, without going into anything that
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Bradley J. Edwards taken on 10/10/2013
1
it says, I don't want to invade any privilege here, did
2
you have any written agreements with these lawyers?
3
MR. KING: Hold on one second. Let's take a
4
break, discuss privilege.
5
MR. HADDAD: Five minutes, so I can look for
6
what I'm trying to find.
7
MR. KING: Okay, that's fine.
8
MR. HADDAD: I've got the bomb question. Oh,
9
no, I don't, but I'm trying to find one.
10
THE VIDEOGRAPHER: The time is 10:52 A.M. We
11
are now coming off the video record.
12
(Thereupon, a discussion was had off the
13
record.)
14
THE VIDEOGRAPHER: The time is 11:00 A.M. We
15
are now back on the video record.
16
MR. HADDAD: All right.
17
MR. KING: Let me --
18
MR. HADDAD: Yeah.
19
MR. KING: -- assert an objection as to this
20
line of questioning. If you are going off of it,
21
great, but any further communications or
22
conversations relating to communications that
23
Mr. Edwards had with the other lawyers, there are
24
motions that were pending and may have been
25
granted, I don't know, by at least two lawyers to
Empire Legal Support. Inc..
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Bradley J. Edwards taken on 10/10/2013
1
preclude any disclosure of work product information
2
that they would have a right to assert. And so
3
we're -- in honor of that, of those motions or the
4
order, if it was entered, and I apologize for not
5
knowing that, we would -- we would object to any
6
questions relating to communications that occurred
7
that would fall within a work product doctrine that
8
would be owned by those other lawyers.
9
MR. HADDAD: I -- I -- I don't think that's
10
what I was doing. In fact, I thought I made it
11
specifically clear I am not trying to invade any
12
privilege. I just asked whether or not there was a
13
written -- an agreement among the lawyers, and I
14
don't think that would be privileged. Shared
15
information among the lawyers would not be -- I
16
mean, I'm not going to put you in bad position
17
because not -- you're -- you're not the lawyer that
18
should -- that, like I said, should have been here,
19
but you are not the lawyer that is more familiar
20
with this, so I don't want to put -- my usual
21
expression would be something else, so I will just
22
leave it there and we will take it up with the
23
Judge, okay.
24
MR. KING: Very good.
25
MR. HADDAD: Because I just want to know if
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Bradley J. Edwards taken on 10/10/2013
1
2
there's a written -- like -- just like the lawyers
have a -- a -- what do we call that, a joint
3
defense agreement. Whether it's a plaintiff's
4
5
6
agreement -- a sharing
you can assert -- you
objected, I will leave it at that. I don't want
to -- as I said, I don't want to cause any --
7
MR. GOLDBERGER: Just identify the specific
8
question you are asking that Mr. King is telling
9
his client not to answer.
10
MR. HADDAD: Specifically, I already asked
11
him, whether or not there was any specific
12
agreement among the lawyers to share information
13
and share expenses, because we already know they're
14
sharing checks into a pooled account, which --
15
which already gave us the answer to that when there
16
was a joint agreement about sharing information and
17
work -- and workload and so forth, without ever
18
discussing what -- what their work product was. I
19
mean, the end result was to sue Epstein and get as
20
much money as we can, we know that. But as to any
21
other thing, I just want to know whether they had a
22
formalized agreement saying that we will e-mail
23
each other on some secret e-mail account, or what
24
do you call that thing in the sky that Adler said
25
he invented, Qtask, any of that stuff, that's what
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1
the question is. I will respect your objection and
2
I think it's a fair objection, particularly since
3
you weren't, you know, the attorney handling all of
4
this and we will take it up at another time.
5
If I can proceed?
6
A
Go ahead.
7
8
9
BY MR. HADDAD:
Q
Okay. Thank you. I got this in a list of
e-mails and this is from Debra Villegas. I don't have
10
her prison number right now, but it's to Scott
11
Rothstein. At any rate, Ken Jenne advised that we need
12
these documents for depo as early as next week, are you
13
familiar with that e-mail?
14
A
No.
15
Q
Okay. And you have no idea why Beth would be
16
looking for financial documents, police reports, arrest
17
reports, call logs, all information of a -- a copy of
18
Epstein's counsels' client list, all the rest of that
19
stuff?
20
A
You said Beth did what?
21
Q
No, it's Debra Villegas to Scott Rothstein,
22
forward inventory, Ken Jenne. Ken Jenne was the guy
23
that was in your meeting that you called with all those
24
guys that I showed you the -- the thing before,
25
remember, Berger wanted to have you, Adler, I think one
Empire Legal Support. Inc..
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Bradley J. Edwards taken on 10/10/2013
1
of those-.-.-.
2
A
We are going to mark this, right, so it's
3
accurately --
4
Q
Everything is going to be there, of course.
5
A
All right. So there is an e-mail from Lee
6
Caplan, I don't know who that is, to several other
7
people that does not include me.
8
Q
Umm-hmm, I am just asking you if you saw it
9
before?
10
A
I don't remember ever seeing this but it has a
11
Bates stamp number, which means that we turned it over.
12
So going through 26,000 pieces of paper, I must have
13
seen it at some point in time during this case, well
14
of -- you know, sometime in 2011, I would guess. I
15
don't remember seeing it.
16
Q
The date of the e-mail, I'm going to get to it
17
in a minute, but that date of that e-mail is
18
October 30th, the day before Scott got the G5 and left,
19
correct?
20
MS. COLEMAN: You say it well.
21
A
October 30th, 2009.
22
BY MR. HADDAD:
23
Q
All right. All right, now this one I like,
24
because this is something, like me, Brad Edwards to Ken
25
Jenne, August 19th, 2009, the paperless world really
Empire Legal Support. Inc.
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Bradley J. Edwards taken on 10/10/2013
1
scares me in this case. This is about Edwards, isn't
2
it?
3
A
That's me.
4
Q
There is so much pape -- not Edwards, I -- I'm
confusing you guys now, Epstein. There is so much paper
and so many motions and dates and times of everything,
so important, so many motions, I think we need an
5
6
7
8
organized paper file in this case. That's you talking
9
about Epstein's case, correct?
10
A
It sounds like it, yes.
11
Q
Okay. And organized paper file would mean
12
like a war room, I think, in fact, you have an e-mail
13
where you asked for a war room.
14
A
Right in there.
15
Q
Is it in this one? It said war room there?
16
Oh, yeah. I just thought I was -- great memory, sorry.
17
Okay.
18
So on October 19th, Ken Jenne to Epstein.
19
Subject: Epstein. To Ken from Bradley J. Edwards. I
20
know you are aware of the urgency, and Russell and I
21
have discussed the various necessary witnesses in the
22
case and the urgent need to speak them. We have a
23
discovery deadline coming up and four crucial witnesses
24
are in California. And you are talking about Fiston
25
going out there. That's in relation to what coming up,
Empire Legal Support. Inc.
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Bradley J. Edwards taken on 10/10/2013
1
2
3
4
5
6
7
8
9
discovery deadline in the cases that you had before you
settled them, if you --
A
Uh, from memory --
Q
Yeah, I'm not --
A
-- the case was a -- the Jane Doe v. Epstein
case was initially set for trial in November of 2009, so
I think the discovery deadline was coming up and we had
some more witnesses to talk to before that.
Q
All right. Who's Pat Diaz?
10
A
He's an investigator.
11
Q
Okay. Let me -- let me -- yeah, this one,
12
probably just because it intrigued me, is from Bill
13
Berger to Edwards, Adler, Jaffe, Weissing, Farmer,
14
May 19th, 2000. It was mostly your partners now. You
15
are invited to attend our three P.M. conference room, 22
16
floor conference room, interview of Amy Swan, a
17
psychologist, who you are considering as a damage expert
18
in Epstein cases. Even if you are not working on the
19
case, if you can attend, I would appreciate your input.
20
What -- what -- what was she, like a child psychologist
21
or something?
22
A
Right.
23
Q
Is she here in Broward?
24
A
I don't remember.
25
Q
Okay.
Empire Legal Support. Inc.
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Bradley J. Edwards taken on 10/10/2013
1
A
Local though, tri-county, I don't remember.
2
Q
All right. And that was for purposes of
3
potential witness in your cases if you went to trial,
4
correct?
5
A
Correct.
6
Q
Okay. And would Edward -- but the rest of
7
your partners were invited, your present partners were
8
invited, do you know why they were invited?
9
A
No.
10
Q
Okay. Did they actually have work on-.-.-.
11
A
Not at all.
12
Q
Okay.
13
A
I will finish the question first. Work on
14
Epstein's case
15
Q
That's okay, we both know what we are talking
16
about.
17
How come you turned over Scott's schedule for
18
the July 26 call from Governor Barbour, lunch with David
19
Shope, Alonzo Mourning charity breakfast?
20
A
I didn't have access to my e-mails. These
21
e-mails were turned over to me by the trustees.
22
Q
Okay.
23
A
When they were turned over to me, I turned
24
them over to you.
25
Q
And let me ask, Epstein conference 3:30, Brad
Empire Legal Support. Inc.
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Bradley J. Edwards taken on 10/10/2013
1
Edwards, Steve Jaffe, Ken Jenne.
2
A
Until these were turned over to me by the
3
trustee, I had never seen them before.
4
Q
Oh, so you don't know, okay.
5
A
I have no idea.
6
Q
I guess Scott's not on the charity board for
7
Alonzo Mourning anymore?
8
A
I would hope not.
9
Q
Did you get to go to Mo's Dinner Event at The
10
Palms Grill?
11
A
Did not.
12
Q
Do you know who Mo is?
13
A
Do not.
14
Q
The cigar guy, that gave all the cigars for
15
all the charities?
16
A
No.
17
Q
Okay. Do you know who Micki Cummings is that
18
he was interviewing for the second time?
19
A
No.
20
Q
The divorce lawyer who tried to become a
21
judge?
22
A
Michele Cummings?
23
Q
You don't keep up with divorce lawyers?
24
A
I try not to. I know you do.
25
Q
That's for sure. Nice. Touché.
Empire Legal Support. Inc.
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Bradley J. Edwards taken on 10/10/2013
1
I assu -- is this one on your Web site or is
2
this just here, "Florida Lawyer Ruffles Feathers in High
3
Society With His Pesky Subpoenas," did you post that
4
one?
5
A
I don't think so.
6
Q
You should, it's a pretty good article for
7
you. Okay --
8
9
10
11
12
13
A
Send it to me again and I will post it.
Q
All right. I -- I think -- I don't know if I
have any more of these on these e-mails, but -- but at
some point or another, these all -- were either
recognized by you, came -- or were produced by you,
correct?
14
A
They came to me by -- from the trustee,
15
sometime --
16
Q
Yeah.
17
A
-- in 2011 and then I forwarded them on to you
18
guys.
19
Q
All right.
20
Were you deposed at all in any clawbacks or
21
anything?
22
A
No.
23
Q
Okay.
24
A
This is my third deposition in this case and
25
that's it.
Empire Legal Support. Inc.
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Bradley J. Edwards taken on 10/10/2013
1
Q
Well, I understand that. I don't understand
2
how you get to take more than one deposition because you
3
don't in criminal, but we are doing it. Maybe I can
4
invite you back again in a few months.
5
A
I'm hoping for today to be the last time that
6
we are meeting under this circumstance.
7
Q
I'm enjoying it so much.
8
A
I know.
9
Q
Just so long as you're -- I have never taken a
10
deposition this long in a first-degree murder. Of
11
course, this is much more serious.
12
Let me ask you, this is a document
13
MR. HADDAD: Yeah, you got to mark all of
14
those, I guess. Do we have copies?
15
MR. GOLDBERGER: Do you want to sanitize this
16
and make sure it's all good?
17
MR. HADDAD: Go ahead, you going to take my
18
dog-ears off, I need them -- yeah, whatever.
19
MR. GOLDBERGER: That's Exhibit 2.
20
MS. COLEMAN: Quarter-million-dollar education
21
and I am --
22
MR. HADDAD: Do you want -- did you want a
23
copy, Bill, did you a copy right here?
24
MS. COLEMAN: No, this is 2 because 1 is
25
the --
Empire Legal Support. Inc.
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Bradley J. Edwards taken on 10/10/2013
1
MR. HADDAD: Do want us to make a copy of the
2
ones that we saved or -- okay, I didn't know if you
3
needed extra.
4
MR. KING: I just want to have -- I assume
5
that you are going to mark that entire package.
6
MR. GOLDBERGER: Composite exhibit.
7
MR. HADDAD: Is that what they call those?
8
BY MR. HADDAD:
9
Q
All right. I guess in response to a recent --
10
I think it's recent, after objections and all that other
11
stuff, you produced your time records?
12
A
Okay.
13
Q
Could you say yes or no. Okay means okay, did
14
I, I don't know, maybe somebody else produced them. I
15
need a yes or no so I can -- and I am not trying to be a
16
jerk.
17
A
I produced them based on my attorney telling
18
me to produce them.
19
Q
Well, I understand that, but okay doesn't
20
answer that. You can -- you get into court, you are a
21
smart lawyer, okay means who came from, you know that.
22
You were a prosecutor, you knew what to do.
23
Is this -- this what you produced?
24
What time is it, almost lunchtime?
25
(Thereupon, a discussion was had off the
Empire Legal Support. Inc.
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Bradley J. Edwards taken on 10/10/2013
1
record.)
2
THE WITNESS: Do you know if these Bate stamps
3
were put there by me or by you?
4
MS. COLEMAN: They are by you.
5
THE WITNESS: By me?
6
MR. HADDAD: How would I know, I don't know
7
how -- I don't have a Bates stamp machine.
8
A
Then, yes. Then, yes.
9
BY MR. HADDAD:
10
Q
I don't think you need these. Thanks.
11
A
These appear to be my time records from this
12
case.
13
Q
And when this Edwards versus Epstein, when
14
these time records, just so at least I'm somewhat clear,
15
is this the time for the Epstein loss, not
not the
16
claims that were occasioned by your --
17
A
Right.
18
Q
-- plaintiff's cases, this is solely involved
19
in this litigation that we're presently taking your
20
deposition for?
21
A
Only for the defense of the lawsuit that
22
Epstein filed against me and it should end at the time
23
when that lawsuit was dismissed against me.
24
Q
Which would have been August 20th, 2012?
25
A
And I kept only those time records.
Empire Legal Support. Inc..
EFTA01089097
Bradley J. Edwards taken on 10/10/2013
1
Q
Okay.
2
If -- do you remember approximately when you
3
were served with the complaint?
4
A
2009.
5
Q
I understand that. I see here channel --
6
channel -- December 7th, rather prophetic, 2009, you
7
were with hit with the initial complaint, correct?
8
It -- it say here you -- initial complaint, review and
9
research.
10
A
Then that sounds accurate to me.
11
Q
Okay. And did you retain -- did you -- you
12
didn't know it was coming, obviously?
13
A
Right.
14
Q
You were only involved at that time in the
15
Jane Doe, let me just call them Jane Doe, whatever you
16
want to call them, II ■, II, whatever you call them,
17
civil suits and it's GVRA?
18
A
CVRA.
19
Q
CVRA stuff, correct?
20
A
As it related to Jeff Epstein.
21
Q
Right. So that when you -- when got sued,
22
this was a blanket new civil litigation that you were
23
getting involved in.
24
A
That's correct.
25
Q
And that's before the counterclaim and all
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Bradley J. Edwards taken on 10/10/2013
1
that, this was just a brand my new piece of civil
2
litigation
3
A
Right.
4
Q
where you got sued? Okay, and the first
5
complaint for a number of comps.
6
A
Right.
7
Q
Correct?
8
All right. When was it that you -- what
9
approximate date did you hire Mr. Scarola?
10
A
I don't remember.
11
Q
Approximately. The day you got served? I
12
mean, you were already friends with him, I guess.
13
A
Right. Um, I -- I can say with pretty good
14
certainty that it was before the end of that year 2009.
15
Q
Okay. Because I'm
I am seeing here --
16
A
Sometime in the month of December, I think.
17
Q
All right. Because you got 12/7/2009, initial
18
complaint, review and research, 8.1 hours. What did he
19
send you, War and Peace?
20
A
Basically.
21
Q
Oh, okay. Exhibit 2, seven
point sev
22
what's .7 hours translate to, I don't
I don't --
23
A
42 minutes.
24
Q
Okay. All right. 12/10, let -- letter
25
confirming registration. What would that mean? What
Empire Legal Support. Inc.
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Bradley J. Edwards taken on 10/10/2013
1
2
would a letter confirming regist -- representation
that -- that -- that you're confirming that
3
what's-his-name is going to represent you, Scarola, or
4
you are sending him a letter, this is to confirm our
5
6
7
8
9
conversation today that you will represent me?
A
It was -- it was time for our discussion and
then him sending me a letter confirming that he was
going to represent me, so that means that I must have
retained Scarola within three days, actually, of file
10
filing the complaint.
11
Q
Okay. So a letter -- it just says letter
12
confirming representation, 30 minutes?
13
A
Well, that would have included the
14
conversation as well --
15
Q
I see, I am just asking. That's --
16
A
-- that went into that letter.
17
Q
I know that you guys know how to bill. Us
18
poor guys have to work, we don't work by the hour so
19
we --
20
A
Just told me a story about billing $75,000 for
21
a traffic ticket.
22
Q
That wasn't a bill, that was a retainer. I
23
don't have -- I don't have that stuff. I would never do
24
that hourly work. Eight hours -- okay, so did you ever
25
add up with what the hours are in this thing
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Bradley J. Edwards taken on 10/10/2013
1
approximately, I'm sure you must?
2
A
Probably a thousand hours, I don't know. I
3
mean, it was a ridiculous amount of time.
4
Q
Yeah, letter to Mr. Akerman --
5
A
And a lot of that time was a consequence of
6
being dumped 26,000 e-mails on me, so, but, yes, I think
7
that there is a total somewhere.
8
Q
All right. I don't have it here.
9
A
Okay.
10
MS. COLEMAN: It's on the last page at the
11
bottom.
12
MR. HADDAD: It's on the last page?
13
MS. COLEMAN: Yeah.
14
MR. HADDAD: Oh, total time 1,351 hours .8?
15
THE WITNESS: I was pretty close.
16
MR. HADDAD: Anybody got a calculator? Just
17
for my edification, can somebody divide that by 40.
18
Do you have a -- I don't --
19
MR. GOLDBERGER: Yeah, I can do that for you,
20
Fred.
21
MR. HADDAD: Thanks. Just out of curiosity.
22
I'm not -- I was going to go through this page by
23
page with you so we could spend some quality time
24
together.
25
THE WITNESS: That would be so much fun, Fred.
Empire Legal Support. Inc.
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Bradley J. Edwards taken on 10/10/2013
1
MR. HADDAD: Huh?
2
THE WITNESS: That would be so much fun.
3
(Thereupon, a discussion was had off the
4
record.)
5
MR. HADDAD: So a couple months a year.
6
MR. GOLDBERGER: No.
7
BY MR. HADDAD:
8
Q
Letter from Nurik re depo of Rothstein. What
9
would that have to do with this case? Just -- just -- I
10
am just trying to figure out why that would have
11
something to do with this case.
12
A
What?
13
Q
It says here, you know, 35 minutes, Marc Nurik
14
couldn't write a letter that lasted 35 minutes. A
15
letter from Nurik re depo of Rothstein. He was in my
16
office. He is not able to write that well.
17
A
So --
18
Q
Well, how did you -- what does that have to do
19
with this case? I mean just -- just looking through --
20
A
Out of context, that's a tough question for me
21
to answer. But I know that in your recent pleadings,
22
you have discussed certain things that Scott Rothstein
23
testified to in other cases that included me, and so I
24
would have read those portions of that deposition and
25
that's what I am presuming that that is.
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Bradley J. Edwards taken on 10/10/2013
1
Q
Whoa, whoa, whoa, whoa. The pleadings that
2
they -- you have not -- this is -- this is within a few
3
months of the initial complaint and -- and -- and I
4
don't want to be real argumentative with you, because
5
there is no jury here, but it says here, 4/14/2010,
6
letter from Nurik, re depo of Rothstein. The depo of
7
Rothstein wasn't for another three months. Why would
8
you bill Epstein -- what's four-tenths, is what,
9
25 minutes?
10
MS. COLEMAN: Umm-hmm.
11
BY MR. HADDAD:
12
Q
25 minutes to read a letter from Nurik. Dear
13
Brad, I'm going to be taking the deposition of
14
Rothstein, do you have any input, is about the most that
15
Nurik could get out of a sentence.
16
A
I don't -- I don't think that that's what that
17
means though.
18
Q
Okay, well what -- you are the one who wrote
19
it.
20
A
We would have to look at the docket of this
21
particular --
22
Q
Okay.
23
A
-- case to see what was going on --
24
Q
So -- so we --
25
A
-- in this particular case.
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Bradley J. Edwards taken on 10/10/2013
1
2
Q
All right. So we can assume then that
everything on here is not necessarily accurate and to be
3
taken as it's written here because you don't even know
4
what this means?
5
6
7
A
Out of context, I don't know what every single
entry --
Q
Well, I didn't -- I didn't write it, you are
8
the one who put the context there, Brad, correct?
9
10
11
A
From 2010?
Q
Oh, okay. I'm just asking, I'm just asking.
A
There are certain things you could give me to
12
refresh my recollection, so I could give you an accurate
13
accounting.
14
Q
Edward -- Edward's motion 57.105, somebody
15
screwed up and you want attorney's fees. I learned that
16
one one time. 4/15/2010. For an hour and a half, an
17
hour and something minutes to write a 457.101 motion?
18
You have been a -- you have been a lawyer for 15 years,
19
how did -- how did it take you that long?
20
A
Well, I have to read what is the basis for the
21
motion.
22
Q
So we don't know? So we would have to get all
23
of this correspondence to find out the accuracy of what
24
you are saying?
25
A
You would probably just have to give me the
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Bradley J. Edwards taken on 10/10/2013
1
docket so that I could tell you, based on what was going
2
on in the case right now, what -- what exactly each
3
entry had entailed.
4
Q
Prep -- preparation of deposition of Michael
5
Fiston. What -- what did Michael Fiston have to do with
6
this case for a deposition in 2010?
7
A
You are the one who set him for deposition.
8
Not you, but it was one of Epstein's 20 attorneys, so
9
you would have to tell me that.
10
Q
He only had 13 at the time.
11
A
I think it was attorney No. 12 served him for
12
depo.
13
Q
All right. So you are saying you prepped the
14
depo. You had a lawyer though too, didn't you?
15
A
What's your question?
16
Q
Did you have a -- well, this deposition, you
17
have 1.1 hours here and another .7 hours here --
18
A
Right.
19
Q
-- for the deposition of Michael Fiston at --
20
on Third Avenue.
21
MR. HADDAD: Could you guys stop talking, I
22
can hear you, it's my only good ear, for one
23
second.
24
BY MR. HADDAD:
25
Q
Did you have Scarola represent you at the
Empire Legal Support. Inc.
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Bradley J. Edwards taken on 10/10/2013
1
time?
2
A
Scarola did represent me at the time.
3
MR. GOLDBERGER: He did.
4
MR. HADDAD: Okay.
5
BY MR. HADDAD:
6
7
8
Q
And Scarola attended this deposition?
A
It was never taken, it was canceled.
Q
Okay. Did you meet with Scarola for the
9
deposition, no discussions you -- between you and
10
Scarola, did you prepare him notes, did you do
11
something, send them to him?
12
A
I met with Mike Fiston.
13
Q
Okay. So you prepared the witness for the
14
deposition?
15
A
I talked to the witness about the deposition,
16
yes, prepared him for the deposition, yes.
17
Q
For one point -- for almost two hours?
18
A
No, for 1.1 hour.
19
Q
1.1 and .07?
20
A
But that's a different deposition.
21
Q
Oh, Fendi, I'm sorry, I can't read.
22
Okay. So you prepped two people for
23
depositions that day?
24
A
Right.
25
Q
Okay. To be taken by one of Epstein's
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Bradley J. Edwards taken on 10/10/2013
1
multiple lawyers and to be attended by your lawyer?
2
A
Right.
3
Q
Okay. So you are acting as an adjunct to the
4
law firm but you won't tell me whether you already had a
5
cooperation agreement with when they were prepping
6
depositions --
7
MR. HADDAD: Well, change it now. You want to
8
do that?
9
THE VIDEOGRAPHER: The time is 11:22 A.M. We
10
are now coming off the video record. This is the
11
end of Tape No. 1.
12
(Thereupon, a discussion was had off the
13
record.)
14
THE VIDEOGRAPHER: So the time is 11:23 A.M.
15
We now back on the video record. This is the start
16
of Tape No. 2.
17
BY MR. HADDAD:
18
Q
Could -- could you explain to me -- and I'm
19
sorry, maybe it's your shorthand, 5/5/2010, not
20
attending, notice of hearing, motion to enlarge time to
21
respond to discovery. Two-tenths is what, 12 minutes?
22
A
Right.
23
Q
What does that mean, not attending, notice of
24
hearing, you got to read the -- it took 12 minutes to
25
read a notice of hearing?
Empire Legal Support. Inc..
EFTA01089107
Bradley J. Edwards taken on 10/10/2013
1
2
3
A
And then communicate with my attorney about
whether or not I was attending that particular hearing.
Q
What do you have a translator to take
4
10 minutes to say, I'm not going to be attending? I'm
5
6
7
8
just blowing smoke up your butt.
A
Okay. No.
Q
All right. I'm sorry for the sarcasm, it's
just
just sitting so close to you brings it out in
9
me.
10
A
You are like an insurance company going
11
through the bills.
12
Q
All right. And -- oh, this I could see taking
13
10 minutes, notice of appearance, Goldberger for
14
Epstein, probably took 10 minutes to understand the
15
notice of appearance, Hi, I'm Jack Goldberger, I'm
16
filing an appearance. Okay. Let me see if anything
17
else stands out.
18
All right. But at any rate, this is pretty
19
much continuing. When you have Internet, internal
20
e-mail with attorneys on 2/15/11, there's four or five
21
of them, what would that mean, but I don't want to get
22
into what you talked about, who you talked about, but
23
what would Internet e-mail --
24
A
Let's say I e-mail my partners, they send an
25
e-mail back, then we have an e-mail discussion as to
Empire Legal Support. Inc.
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Bradley J. Edwards taken on 10/10/2013
1
some certain issue. That's basically what that is.
2
Q
But we don't know what part of this case it
3
might be related to, correct?
4
A
Based on that, we don't.
5
Q
All right. And correspondence with counsel
6
would be letters -- eight letters to Scarola on two --
7
A
Or e-mails.
8
Q
Well, you have internal e-mail and
9
correspondence. Correspondence would mean a regular
10
e-mail --
11
A
It could be.
12
Q
-- as opposed to an internal e-mail?
13
A
All right. I'm not that technical myself
14
15
Q
Okay. Review correspondence from Carney and
16
letter to Mr. Akerman from J. Carney. Are you talking
17
about Rob Carney?
18
A
Right.
19
Q
Okay. And
oh, he was a general mast
20
appointed a master or something in this case?
21
A
I don't really remember what his role was,
22
but --
23
Q
Okay.
24
A
-- something along those lines.
25
Q
2/16/2011, hearing re privilege log at Jack
Empire Legal Support. Inc.
EFTA01089109
Bradley J. Edwards taken on 10/10/2013
1
Scarola's office, West Palm Beach with Judge Carney,
2
6.1 hours. Would that be your atten
3
A
Probably longer than that, but yes.
4
Q
Okay. That would be your attendance there?
5
A
Right.
6
Q
Did you participate in that at all or --
7
A
Yes.
8
Q
-- did Carn -- did Scarola do it?
9
A
We all did.
10
Q
What do you mean, we all did, what did you do
11
at that hearing, Scarola let you talk and argue?
12
A
Yes.
13
Q
Okay. All right.
14
A
And I think everybody had some input as to
15
what the process was going to be. It was a complicated
16
process related to e-mails.
17
Q
2/17/2011, 4.1 hours, Edwards hearing on
18
Edwards motion to compel Judge Crow, 4.1 hours.
19
A
It takes three hours just to get back and
20
forth, so yes, I mean --
21
Q
Well, I'm just asking what this is. So you
22
are charging for your time. Did you testify at it?
23
A
I don't remember.
24
Q
All right. Motion to compel are generally not
25
testimony, it's usually a hearing, correct?
Empire Legal Support. Inc.
EFTA01089110
Bradley J. Edwards taken on 10/10/2013
1
A
I don't remember what my role was at that
2
particular hearing.
3
Q
Well, you were co-counsel for all of this
4
crap, right?
5
A
Yeah. Yeah.
6
Q
For all of this stuff?
7
A
Yeah.
8
Q
Okay. And you were billing for all of your
9
time as well as the time, whether it was duplicated by
10
Mr. Scarola or not, correct?
11
A
I don't have Mr. Scarola's bills, so I was
12
billing for all of my time.
13
Q
Okay. Well, I mean, if Jack called you up and
14
said, hey, Brad, what about this or that, it was
15
discussing the case, you would bill for it?
16
A
Right.
17
MR. HADDAD: What? Excuse me, yes.
18
MR. GOLDBERGER: Is this the good ear?
19
MR. HADDAD: Yes.
20
(Thereupon, a discussion was had off the
21
record.)
22
BY MR. HADDAD:
23
Q
Okay. I'm ending with this so we're going
24
to -- you know, it's getting close to lunchtime. I
25
don't know, if there is something more important, I will
Empire Legal Support. Inc.
EFTA01089111
Bradley J. Edwards taken on 10/10/2013
1
have to wait for it. I -- I like -- you are unable to
2
give any of these details, but on 10/15/2011, the detail
3
of your 9 hours spent reviewing transcripts is
4
incredible. Was that for shock benefit or was that just
5
something that you managed to completely --
6
A
This was internally in my office so if it was
7
for shock benefit, to benefit
to shock myself? I
8
mean, this is --
9
Q
I don't know, you probably knew you were going
10
to have to produce this some day.
11
A
I didn't.
12
Q
Brad.
13
A
I thought that would have to produce hours
14
but the details, I didn't.
15
Q
All right, 9 hours to review transcripts for
16
whom?
17
A
For, it says, lies told by Epstein --
18
Q
I know what it was for there. I am saying for
19
whom, for whose benefit? If you have a lawyer, are you
20
being deposed, is that what it was for, do you remember
21
what it was for where you spent 9 hours looking at
22
something?
23
A
When was my first deposition? No, it was
24
after that. It wasn't about my deposition.
25
Q
Okay. Do you know what it was for?
Empire Legal Support. Inc.
EFTA01089112
Bradley J. Edwards taken on 10/10/2013
1
A
Yes. I mean, it --
2
Q
I know what you did. I mean, I know what you
3
said.
4
A
Well, it seems like the amended counterclaim
5
6
7
8
was the next day, so it was for whatever input --
Q
Your -- your counterclaim --
A
-- that related to that malicious prosecution.
Q
-- your
what was your ammend
I'm sorry.
9
MR. KING: Hold on, hold on a second.
10
11
12
MR. HADDAD: I -- I apologize, Mr. King, we
were cutting each other off.
Go ahead Mr. Scaro -- Edwards.
13
A
A malicious counterclaim -- or the count that
14
Epstein filed against me, I was reviewing all of those
15
things in preparation for our amended counterclaim,
16
which was a count for malicious prosecution.
17
BY MR. HADDAD:
18
Q
All right. Let me ask you this. I understand
19
that. And it was drafted by Mr. Scarola, correct, or
20
did you do the drafting of the documents and he signed
21
them?
22
A
It's been different on different pleadings.
23
Q
All right. I mean --
24
A
For that one, I -- I don't really remember.
25
Q
So would it be fair to say that you, at times,
Empire Legal Support. Inc.
EFTA01089113
Bradley J. Edwards taken on 10/10/2013
1
2
3
4
5
6
7
would prepare pleadings, send them to Scarola and he
would sign them?
A
Fair.
Q
Pardon?
A
That's fair.
Q
All right. Now, on 10/18, after you've
already filed your -- or prepared your amended
8
counterclaim, which took an hour, your motion for 57 0
9
105 attorney fees, you should have those rote, don't you
10
11
12
have those you send out with everything, they are all
the same? I mean, you just have to hit a button and say
print, no?
13
A
Is that how it works in your office?
14
Q
I don't -- we don't do civil. I only do them
15
once
every once in a great while. The last one I
16
had, we just mediated out with Judge Crow.
17
Review depositions again, all pleadings, all
18
offers and pending motions in preparation for conference
19
with counsel regarding strategy for defense and also in
20
preparation for prosecution of counterclaim, 11 hours,
21
which is a little over a day.
22
You've been a -- well, let -- let -- let me
23
just ask you. What all offers were you having that you
24
had to review, what offers were there?
25
A
It would have been all offers that Mr. Epstein
Empire Legal Support. Inc.
EFTA01089114
Bradley J. Edwards taken on 10/10/2013
1
had ever made to the girls.
2
Q
What did that have to do with your
3
counterclaim?
4
A
Okay.
5
Q
Just educate me.
6
A
I'm going to try --
7
Q
-- because I have to get this case.
8
A
I'm going to try.
9
Q
Thanks a lot.
10
A
So Mr. Epstein files a complaint against me
11
alleging that I am a fraud and I am part of some RICO
12
enterprise, and the basis for his claims were that I
13
conducted discovery that could not have possibly been
14
relevant to any legitimate claims I was prosecuting,
15
such as, I took depositions of pilots, I included that
16
one of the girls gave him oral sex when it was actually
17
different underage girls that gave him oral sex, and so
18
forth and so on.
19
Q
Okay.
20
A
So I reviewed those things to make sure that I
21
have all of the, what I'll call lies, in order that
22
would support the basis of my malicious prosecution
23
claim and prove that since he drafted and -- and made
24
allegations that he knew to be false, that is the proof
25
that there was no good faith basis, and the proof that
Empire Legal Support. Inc.
EFTA01089115
Bradley J. Edwards taken on 10/10/2013
1
it was done with malice and with an intent to extort me.
2
Q
But you remember -- you already
you had
3
already filed your amended counterclaim.
4
A
Okay.
5
Q
So that's post. So you filed a pleading then
6
you look for the proof?
7
A
I filed the pleading.
8
Q
Yeah.
9
A
And then it says: In preparation for a
10
conference with counsel regarding strategy for defense.
11
Q
Yeah. Oh, okay. Two days of -- one day after
12
the counterclaim is filed. Okay.
13
A
Is there a problem with that timing, I -- I
14
just don't understand?
15
Q
Well, we will find that out later.
16
Uh, what's page -- what's Scarola re Facebook,
17
did you become friends and you are charging for that,
18
hit the friend button?
19
A
No, I think there was a -- a letter from
20
Mr. Scarola about -- about social media.
21
Q
Regarding Edwards or regarding you guys?
22
A
I think that that would violate the
23
attorney-client privilege.
24
Q
Oh, okay. Well, not if it's social, if it's
25
you and he becoming Facebook friends.
Empire Legal Support. Inc.
EFTA01089116
Bradley J. Edwards taken on 10/10/2013
1
A
It's not that.
2
Q
Are you Facebook friends with him?
3
A
No.
4
Q
Do you go on Facebook?
5
A
No.
6
Q
Okay. Are you getting hot?
7
A
No.
8
Q
I should say mad, that doesn't come out too
9
good.
10
A
I do have -- I do have a Facebook account but
11
I don't go on Facebook.
12
Q
All right. I could look through this all day.
13
I had some others that stood out but I'm -- wait for
14
later. All right. Let me just have a minute.
15
MR. HADDAD: Do you want to talk, do you got
16
something? Go ahead.
17
MR. GOLDBERGER: Anything constructive?
18
MR. HADDAD: Yeah, I mean, let me see. I'm
19
sorry, I have got to go to my mentor's now.
20
What?
21
MS. COLEMAN: Well, i wanted to know why he
22
talked about Epstein hiring me for an hour and a
23
half, that's my favorite part of the time sheet.
24
(Whispering)
25
MR. HADDAD: Oh, I know that. Okay. I didn't
Empire Legal Support. Inc..
EFTA01089117
Bradley J. Edwards taken on 10/10/2013
1
see if there was anything else there.
2
BY MR. HADDAD:
3
Q
This all -- all of this preparation, this
4
document, why did you talk for an hour and a half about
5
hiring Tonja? Well, you did charge an hour and a half
6
for that.
7
A
I probably talked longer than that about that
8
fact.
9
Q
Oh, did that upset you?
10
A
Yeah.
11
Q
Okay.
12
A
I told her that, she knows it upset me.
13
MS. COLEMAN: We worked it out. You had to
14
know.
15
MR. HADDAD: Huh?
16
BY MR. HADDAD:
17
Q
All right. What did you use to prepare this?
18
I mean, do you have just a running computer table?
19
A
No, I would just write it out --
20
Q
Yeah, I know that.
21
A
-- I would give it to the secretary, somebody
22
would type it in.
23
Q
What do you, you bill like a lot of lawyers,
24
you look at the clock and say, okay? I don't have
25
billing sheets, I have never billed a time in my life so
Empire Legal Support. Inc.
EFTA01089118
Bradley J. Edwards taken on 10/10/2013
1
2
3
I don't know how you do it.
A
I grab a piece of paper, I look at the clock
on the computer, finish doing what I'm doing with it,
4
write review correspondence point whatever that is
5
6
7
closest to a sixth and pass the piece of paper on.
Q
Let me ask you this. To -- to -- and if you
delineated what you actually did during this time, I
8
suppose it would take as much time to write what you did
9
10
11
as it is to do what you did. So there must be -- do you
have any kind of like on a computer where you can hit on
a pro -- do you -- do you have a billing program? They
12
do make billing programs where you have certain codes
13
where can you hit like No. 1, talked to client, No. 4?
14
A
We do.
15
Q
Make up a couple hours?
16
A
We -- we have one. We have a billing program.
17
Q
All right. And --
18
A
I can't say that the attorneys are all that
19
familiar with it. But, you know, the entries are done
20
by the staff.
21
Q
You are.
22
A
I write it on -- I write it by hand. I still
23
know how to do things.
24
Q
Yeah, do you still have those notes?
25
A
No. I write it, it gets entered --
Empire Legal Support. Inc.
EFTA01089119
Bradley J. Edwards taken on 10/10/2013
1
Q
Were you a policeman at one time, get rid of
2
the rough notes?
3
A
No. I would have paper to the ceiling if I
4
kept all those notes.
5
Q
All right. I think that's where we ended off
6
the last depo and I'm -- I don't even want to go into
7
I'm not going to bother you with it. Um --
8
A
Go ahead, bother me, I want this to be my last
9
time being bothered.
10
Q
You're not
I'm -- I'm not bringing you back
11
unless you get arrested, then you will have to hire me,
12
but I would have a conflict.
13
A
You are going to admit a conflict, I doubt
14
that.
15
Q
Me, never. If I get paid, there could be a
16
conflict.
17
A
I understand that rule very well.
18
MR. HADDAD: That's criminal law rule No. 1.
19
Right, Jack?
20
MR. GOLDBERGER: Um-hmm.
21
BY MR. HADDAD:
22
Q
Okay. Let me see if there is anything else.
23
Q
Okay. We went -- anything change on your
24
damages? I -- where were we with damages, I just
25
remember, that just came to me because --
Empire Legal Support. Inc.
EFTA01089120
Bradley J. Edwards taken on 10/10/2013
1
2
3
4
5
6
A
We discussed it.
Q
Yeah, I know, we discussed it before --
A
Has anything change --
Q
-- total time lost, time --
A
-- since the last time until now?
Q
Yeah, I mean, have you gotten any more awards
7
or anything?
8
9
A
Not that I remember.
Q
You haven't been speaking at any more places?
10
You get asked to speak a lot now, don't you?
11
A
Right. Yeah.
12
Q
You are getting more and more famous all the
13
time. What?
14
A
Is that a question?
15
Q
No, I'm just asking, I mean, your practice is
16
growing, how many people you got in your office now?
17
A
Seven attorneys.
18
Q
Okay. How many support staff and everything?
19
A
Around 10, maybe a little more.
20
Q
Okay. You are updated still on Best Lawyers
21
and all that other stuff?
22
A
I learned that from you.
23
Q
Not from me.
24
A
I think so.
25
Q
You -- okay, you still getting all of those
Empire Legal Support. Inc.
EFTA01089121
Bradley J. Edwards taken on 10/10/2013
1
other things that you don't have to pay for, they really
2
think you are okay?
3
A
I think so.
4
Q
Okay. Let me ask you, how many cases do you
5
carry?
6
A
I usually try to stay around the 40-case mark.
7
Q
Okay. And that's 40 intentional
8
A
All litigation.
9
Q
-- 40 tort cases?
10
A
Right.
11
Q
You don't do anything else, right?
12
A
That's it.
13
Q
I don't mean that pejoratively, but you are
14
tort lawyer.
15
A
Basically. I mean, I do --
16
Q
Okay.
17
A
-- I do have some commercial cases but they
18
usually involve some form of criminal act where I am
19
representing somebody that I perceive to be a crime
20
victim in the case.
21
Q
Okay.
22
MR. HADDAD: Anybody got anything?
23
A
Well, I know that you have a pending motion
24
about certain objections to work product privilege that
25
were stated in the first deposition --
Empire Legal Support. Inc.
EFTA01089122
Bradley J. Edwards taken on 10/10/2013
1
BY MR. HADDAD:
2
Q
Yeah.
3
A
-- and since, those cases are no longer being
4
litigated. And to the extent that I have injected
5
certain things into this litigation to prove why I did
6
certain things during discover, I'll answer whatever
7
questions you have in that regard.
8
Q
I didn't even look at it.
9
MS. COLEMAN: I didn't either.
10
A
I just want to make sure this is the last time
11
I'm coming back, so I saw your motion, I'm here until
12
we're not here.
13
MS. COLEMAN: Can we go off the record for
14
minute?
15
MR. HADDAD: No, leave it on the record. If
16
he is going to withdraw his objection, I am not
17
I am not prepared to proceed on that anyhow.
18
MS. COLEMAN: Yeah, we don't have it with us.
19
MR. HADDAD: I don't even have -- I don't even
20
have the prior deposition.
21
MR. GOLDBERGER: Well, let's get on the record
22
that he is withdrawing them so that we don't have
23
to --
24
MR. HADDAD: Well, yeah. I mean, if you are
25
withdrawing everything, we don't even have to go
Empire Legal Support. Inc.
EFTA01089123
Bradley J. Edwards taken on 10/10/2013
1
forward with a hearing, we just see where it is,
2
you can ask him in trial or see where we go from
3
there. I'm --
4
MR. GOLDBERGER: No, no, I think we want to
5
redepose on it but-.-.-.
6
MR. HADDAD: Well, I don't -- no, let's --
7
MR. KING: Hold -- hold on a second, hold on a
8
second. That's -- that is not appropriate. He's
9
here, this is his third time. He is prepared to
10
answer questions --
11
MR. HADDAD: Fine, so take a -- let's take a
12
lunch break and I'll come back after lunch and --
13
MR. KING: We'll get the documents.
14
MR. HADDAD:
-- we'll go. See you at one
15
o'clock, 1:30. Is that good?
16
MR. GOLDBERGER: Yeah, one -- how about 1:15,
17
can we do 1:15? It's a quarter of 12.
18
MR. HADDAD: Well, I -- I would like to take
19
my time.
20
MR. KING: Okay.
21
MR. HADDAD: Who took the first -- who took
22
the last depo, Chritton? Who took the depo we
23
invoked on, Chritton?
24
MS. COLEMAN: The first one, yeah.
25
MR. HADDAD: That was 200 pages -- well, there
Empire Legal Support. Inc..
EFTA01089124
Bradley J. Edwards taken on 10/10/2013
1
was only 12 questions asked. The rest of it was
2
Scarola objecting to everything.
3
MS. COLEMAN: Can we go off the record?
4
MR. GOLDBERGER: Yeah, we are off the record.
5
MR. KING: Off the record.
6
THE VIDEOGRAPHER: The time is 11:40 A.M. We
7
are now coming off the record.
8
(Thereupon, a discussion was had off the
9
record.)
10
(Thereupon, a luncheon recess was taken from
11
11:45 A.M. - 1:15 P.M.)
12
THE VIDEOGRAPHER: The time is 1:19 P.M. We
13
are back on the video record.
14
MR. HADDAD: Is Epstein on the phone?
15
MR. EPSTEIN: Yes.
16
MR. HADDAD: Okay, good. I'm still reeling
17
from lunch, excuse me.
18
BY MR. HADDAD:
19
Q
At any rate, I just saw this and I just
20
thought I would ask. Your lawyer and your law firm
21
filed a amended expert witness list of Bradley J.
22
Edwards, through his undersigned attorney hereby amends
23
his witness list for trial as follows. Experts include
24
all attorneys listed in the prosecution of civil claims
25
against Jeffrey Epstein arising out of your usual crap
Empire Legal Support. Inc.
EFTA01089125
Bradley J. Edwards taken on 10/10/2013
1
about serial abuse and stuff. Did you -- are you
2
familiar with this document?
3
A
No.
4
Q
And it says here, you are listing all
5
attorneys involved in the prosecution of civil claims,
6
who would that be, who would the experts be that are
7
involved in the civil claims, which attorneys do you
8
know that to be?
9
A
Which attorneys were involved in the civil
10
claims?
11
Q
Well, your experts --
12
MR. GOLDBERGER: Ask him what
what he
13
what his lawyer means by that, those words?
14
MR. HADDAD: Jack.
15
MR. GOLDBERGER: I'm sorry.
16
MR. HADDAD: Thanks, I wouldn't figure that
17
out on my own. Let me stumble through four or five
18
questions.
19
BY MR. HADDAD:
20
Q
Did you understand Goldberger's question?
21
A
Between the two of you, I think there is a
22
question in there somewhere.
23
Q
This is going to be frick and frack trying the
24
case in there.
25
All right, so you listed -- what it boils down
Empire Legal Support. Inc.
EFTA01089126
Bradley J. Edwards taken on 10/10/2013
1
to is every frickin' civil lawyer that had a claim,
2
you're listing as an expert witness, which would be
3
Josefsberg --
4
A
Josefsberg.
5
Q
Horo --
6
A
Adam Horowitz.
7
Q
Horowitz, all of them?
8
A
Ted Leopold.
9
Q
Yeah. So you are listing them all as expert
10
witnesses, which would waive any claim of privilege
11
right now, if they are going to be witnesses for you, if
12
they are going to testify about your claims and about
13
everything involved in the claims. So let's go back to
14
my other question is, did you have a joint -- joint
15
agreement with any of these guys?
16
MR. KING: Objection to the form.
17
MR. HADDAD: Okay.
18
MR. KING: Also reassert the same objection I
19
had before.
20
MR. HADDAD: Okay. Form objections don't mean
21
much, because you know the question.
22
MR. KING: It's only the -- only the preface
23
to the question.
24
MR. HADDAD: Well, I understand that.
25
Empire Legal Support. Inc.
EFTA01089127
Bradley J. Edwards taken on 10/10/2013
1
BY MR. HADDAD:
2
Q
Here it is. You -- you've listed -- Scarola
3
has listed all these people as attorneys -- as -- as --
4
as witnesses now, so my preparatory question to you is:
5
Are you aware that he did it?
6
A
I am.
7
Q
Okay. The second question is: If these are
8
all listed witnesses, they must have some material
9
knowledge to be expert witnesses, correct?
10
A
Right.
11
Q
Number 3, speaking of expert witnesses, did
12
you happen to read Mr. Scarola's expert witness
13
deposition to Bill Sheer in the Rothstein Ponzi scheme
14
clawback thing?
15
A
No.
16
Q
Were you aware that Mr. Scarola was listed as
17
an expert witness?
18
A
In what?
19
Q
In -- in the clawback scheme, he is an expert
20
witness for Sheer on punitive damages.
21
A
No.
22
Q
Would you share Mr. Ep -- with Mr. Scarola's
23
comments that he would never believe a single word that
24
Scott Rothstein said?
25
A
Would I do what?
Empire Legal Support. Inc.
EFTA01089128
Bradley J. Edwards taken on 10/10/2013
1
Q
Would you adopt the statement of your lawyer,
2
Mr. Scarola, in his deposition, that he would never
3
believe a word Scott Rothstein said?
4
A
Show me the statement and the context in which
5
he said it and I will tell you whether or not I agree
6
with it.
7
Q
Well, would you believe a word, anything Scott
8
Rothstein said?
9
A
I listened to Scott's deposition in this case.
10
Q
All right.
11
MR. GOLDBERGER: Did we have the dep of him?
12
MR. HADDAD: Huh? I don't have it here. I --
13
I'll -- I'll save it for trial, that will be more
14
funny anyhow.
15
BY MR. HADDAD:
16
Q
All right. So now these experts are -- they
17
will testify based upon their background, training,
18
experience as civil litigants and their personal
19
involvement that each adverse prosecuting claims against
20
Jeffrey Epstein about the legal and ethical propriety of
21
the actions taken by Bradley Edwards in fulfilling his
22
obligations to the victims of Epstein's assaults.
23
A
Okay.
24
Q
You must have had helped him prepare that.
25
A
I didn't prepare that one.
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Q
All right. So this is -- these persons, these
2
lawyers are going to be testifying to everything they
3
did in conjunction with you. My question comes back to
4
what we asked before the luncheon break. Did you
5
gentlemen have what would be considered in essence a
6
joint agreement for purposes of prosecuting claims
7
against Edwards?
8
MR. KING: The same objection.
9
A
I am Edwards.
10
BY MR. HADDAD:
11
Q
Huh?
12
A
I am Edwards.
13
Q
I mean against Epstein.
14
MR. KING: The same objection we had before.
15
MR. HADDAD: All right. And are you going to
16
instruct him not to answer so I can get it there
17
quicker?
18
MR. KING: Yes.
19
MR. HADDAD: All right. That makes it very
20
simple. Okay.
21
MR. KING: And you under -- you understand
22
there --
23
MR. HADDAD: I understand what --
24
MR. KING: -- are pending motions or motions
25
that were resolved that were filed by those lawyers
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and so, you know, in an abundance of caution we --
2
MR. HADDAD: Bill, I have no problem, we will
3
take care of it, I want to make sure I cover the
4
record so that I can get it out at some point in
5
time.
6
A
I just can't waive their privilege, that's it.
7
BY MR. HADDAD:
8
Q
I -- I am not asking for privilege, I'm asking
9
you whether you had agreement. There is no privilege to
10
an agreement.
11
MS. COLEMAN: Once they filed it, they waive.
12
MR. KING: No, no, if there was a filed
13
agreement, I would agree, it -- it would be a
14
public record, but most joint agreements --
15
MS. COLEMAN: What I am saying is, by placing
16
them on the record as expert witnesses --
17
MR. HADDAD: I understand that.
18
MR. KING: I understand your position, I
19
would --
20
MR. HADDAD: They waived it. We understand
21
what waiver is.
22
MR. KING: They waived it.
23
MR. HADDAD: Why am I arguing with you, you
24
are on my side?
25
MR. KING: That's right.
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Bradley J. Edwards taken on 10/10/2013
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MS. COLEMAN: Have it.
2
MR. HADDAD: See, I -- I can't -- you're like
3
a little wife.
4
MS. COLEMAN: Because I look like my mother.
5
MR. HADDAD: I could always slap you. All
6
right. The only one not laughing is Brad, why, we
7
are all having a good time here, enjoy the show.
8
BY MR. HADDAD:
9
Q
All right. The other thing is -- the other
10
thing we're here on is Epstein's motion to overrule
11
objection, all that stuff. You said that you are going
12
to withdraw your objections to the questions that were
13
asked that were set for a hearing on November.
14
MR. KING: Man -- many of those. Let me
15
just --
16
MR. HADDAD: Well, yeah, we'll --
17
A
Ask the question and I'll give you an answer.
18
BY MR. HADDAD:
19
Q
Yeah, that's fine.
20
MR. KING: Right, because, just as -- for
21
example, the financial questions, Judge has already
22
ruled, so those would -- those would still be
23
asserted. The other ones were in the list that
24
you -- that you've put in here, a number of them
25
were answered so-.-.-.
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MR. GOLDBERGER: Why don't we just ask every
2
question.
3
MR. HADDAD: Yeah, here's the simple thing.
4
I'm easy, as you know, I don't get mad, I don't
5
worry about -- just say you don't do -- you know,
6
whatever.
7
THE WITNESS: Fire away.
8
BY MR. HADDAD:
9
Q
In this particular instance associated with
10
Mr. Epstein, what investigators worked on Epstein's
11
cases during the time you were at RRA?
12
A
I communicated directly with Mike Fiston.
13
Other investigators that worked on the case were Pat
14
Roberts.
15
Q
Okay.
16
MR. GOLDBERGER: Wait for the answer.
17
A
And I think Pat Diaz.
18
BY MR. HADDAD:
19
Q
Would you consider Ken Jenne, our great
20
illustrious lawyer sheriff to be an investigator?
21
A
Yes.
22
Q
I mean, he did some work on --
23
A
In some general way.
24
Q
Yeah. All right. So that answers the whole
25
first set of questions, I think.
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Bradley J. Edwards taken on 10/10/2013
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2
3
4
5
6
7
Did Fistein
Fiston interview an individual
by the name of Michael Friedman?
A
I think so.
Q
And who's Michael Friedman?
A
A former housekeeper of Jeffrey Epstein.
Q
All right. Did you obtain a written statement
from him or written investigative file or anything that
8
you are aware of?
9
A
No, I don't think so.
10
Q
Okay. Who was the first investigator that you
11
believe involved -- who cares.
12
Who was the first investigator that you
13
believe was involved in this, who took this depo?
14
MS. COLEMAN: Not me, don't look at me.
15
MR. GOLDBERGER: Just ask the questions.
16
MR. HADDAD: I'm sitting here astounded.
17
BY MR. HADDAD:
18
Q
Who was the first investigator to work on
19
these cases?
20
A
That I had anything to do with?
21
Q
Yeah. Work product, instruct you not to
22
answer, okay. Work product.
23
Who was it, Fiston?
24
A
Wayne Black.
25
Q
Okay. Wayne Black, and I saw some stuff.
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2
3
4
5
6
That's the same Wayne Black that in the e-mails we
looked at earlier this morning --
A
Right.
Q
-- was referenced by Ken Jenne and stuff?
A
That's right.
Q
Okay. You already answered this pretty much.
7
MR. GOLDBERGER: You don't need to look to me
8
for approval, just ask the questions.
9
10
11
MR. HADDAD: Well, apparently you are telling
me I'm asking him wrong when I don't ask right.
BY MR. HADDAD:
12
Q
Did -- did you ever direct investigators to go
13
through Epstein's trash?
14
A
No.
15
Q
Okay. Here, I -- I -- I have to ask it again
16
a second time, I guess these guys can't ask a question
17
15 different ways. With regard to your investigators,
18
you gave direction regarding the Epstein cases during
19
the time which you were at RRA, did you ever tell them
20
or direct them to go through Mr. Epstein's trash?
21
A
No.
22
Q
Did you conduct surveillance of Epstein's
23
property?
24
A
No.
25
Q
Did you direct anyone to conduct -- let me do
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Bradley J. Edwards taken on 10/10/2013
1
it my way, I get the right answer.
2
Did you ever direct anyone to go to Epstein's
3
property and conduct surveillance?
4
A
No.
5
Q
Did you tell police to put up pole cams over
6
there?
7
A
No.
8
Q
Did you ask the police if they had pole cams
9
over there? This is my own question now.
10
A
I don't think so.
11
Q
Did you ever ask whether or not the City of
12
Palm Beach actually had cameras that they use for all
13
the streets that you could get surveillance from?
14
A
Me, personally, no.
15
Q
No, direct anyone else to do that.
16
A
No.
17
Q
Because civil lawyers aren't smart enough to
18
ask these questions.
19
A
No.
20
Q
Okay.
21
MR. HADDAD: No offense, Mr. King, you are.
22
BY MR. HADDAD:
23
Q
Have you ever instructed -- no, that one's
24
same one.
25
Have you ever authorized employ --
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Bradley J. Edwards taken on 10/10/2013
1
investigators, either employees from a firm, blah, blah,
2
blah, to walk around the perimeter of Mr. Scarola's --
3
Mr. Scarola -- Mr. Epstein's home on or the same time
4
that -- March 17 of 2010?
5
A
No.
6
MR. HADDAD: What are you trying to show me?
7
MR. GOLDBERGER: I am just sending you a
8
message from your client.
9
MR. HADDAD: Oh.
10
BY MR. HADDAD:
11
Q
Who paid for -- who paid for the
12
investigators, it just came out of RRA funds as part of
13
employment?
14
A
Who paid for the investigators I just told you
15
about?
16
Q
Yeah.
17
A
Mike Fiston and all that?
18
Q
Yeah.
19
A
To my knowledge, they were employees of RRA.
20
Q
Okay. But you don't know whether or not
21
Scarola and everybody else's money jointly went in to
22
pay for all these guys, because that would have been
23
done by the trust department, which you didn't know?
24
A
Yeah, and it didn't. It didn't. I mean, they
25
were employees of RRA.
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1
Q
Okay.
2
MR. GOLDBERGER: You are okay.
3
BY MR. HADDAD:
4
Q
All right. Let me ask you this: Did you
5
auth -- were any informants, comma, did you authorize
6
your investigator to hire informants?
7
A
I don't even know what that means.
8
Q
Neither do I, but I am just asking the
9
question.
10
A
Like a mole inside Epstein's house?
11
Q
I think so.
12
A
How could I possibly mean that? No, I did
13
not. Regardless, the answer is no.
14
Q
I don't know, maybe you went to the Sunrise
15
Police Department, it's in the news now, and got one of
16
their informants to go out and hire somebody.
17
A
I didn't have that idea.
18
MR. GOLDBERGER: Does he -- does he know if
19
they went through the --
20
MR. HADDAD: Huh?
21
MR. GOLDBERGER: Does he -- does he know if
22
they went through the --
23
BY MR. HADDAD:
24
Q
Does anybody -- did anybody go through the
25
trash?
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Bradley J. Edwards taken on 10/10/2013
1
A
The police went through his trash.
2
Q
Well, I know the police did, I read that.
3
A
Right, that's all I -- and that's why I know
4
it.
5
Q
Okay. Did the police hand you some of the
6
stuff they found in his trash?
7
A
I got it the same way everybody else did, it
8
was in the State Attorney's file, FOIA request,
9
et cetera, I got the stuff from his trash.
10
Q
A four-year request?
11
A
Freedom of Information --
12
Q
Oh, FOIA.
13
MS. COLEMAN: FOIA, F-O-I-A.
14
BY MR. HADDAD:
15
Q
I thought you said four-year request. My bad
16
ear.
17
A
But, no.
18
Q
Okay.
19
A
Nobody that I know went through his trash.
20
Q
Let me ask, did you authorize any
21
investigators to trespass on Epstein's property?
22
A
No.
23
Q
I guess March 17th must be a big day because
24
there is 15 questions regarding March 17th, what was
25
that day, besides St. Patrick day?
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Bradley J. Edwards taken on 10/10/2013
1
A
Other than St. Patrick's day, no idea.
2
Q
Okay. Question: Did he, Mr. Roberts, ever
3
perform investigative work on any of the Epstein files?
4
A
Yes.
5
Q
Okay. And who's Roberts?
6
A
Pat Roberts, he was --
7
Q
He's an investigator.
8
A
-- the other investigator that was working at
9
RRA.
10
Q
Yeah. And Rick Fandy, Rich Fandy, Fandray
11
perform any work on the Epstein files, any
12
investigation?
13
A
I'm not sure.
14
Q
Okay.
15
A
He wasn't an RRA employees but they contracted
16
extra work out to certain people and Rick was one of
17
those people.
18
Q
Okay. Outside contractor?
19
A
Right.
20
Q
Were those the ones that protected Scott when
21
he took all the money to the airport to flee the
22
country?
23
A
No. Those were the actual police.
24
Q
Did you ever authorize or direct Ken Jenne to
25
perform any investigation on the Epstein files?
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1
2
3
A
No. This is what I understand --
MR. GOLDBERGER: Answer the question.
A
This is what I understand Ken Jenne's role to
4
have been. I -- I communicated directly with Mike
5
6
7
Fiston. Ken Jenne had something to do with locating
forensic accountants to deal with the money aspect of --
related to Epstein. I didn't direct Ken Jenne, I don't
8
think, to do anything.
9
10
11
12
13
14
15
16
Q
All right. Ken Jenne, of course, had been a
lawyer for many years, State attorney -- State attorney.
MR. GOLDBERGER: Sure.
MR. HADDAD: And then a sheriff.
THE WITNESS: I know that --
MR. HADDAD: He was a State attorney for
years.
BY MR. HADDAD:
17
Q
Okay. He was -- he was actually the first
18
economic investigator, a State attorney prosecutor. Did
19
you know anything about that?
20
A
No.
21
Q
Okay. Were you advised of his abilities in
22
the economic field?
23
A
No.
24
Q
All right. Did you know whether or not he was
25
partners with, what's that guy's name we are talking
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about, Sheer?
2
MS. COLEMAN: Bill Sheer.
3
BY MR. HADDAD:
4
Q
Bill Sheer, did you know he was partners with
5
Sheer before he went with Rothstein?
6
A
I know that now. I did not know that then.
7
Q
Do you know whether or not Sheer actually used
8
Rothstein as an attorney?
9
A
I think I have heard that since, but I didn't
10
know that then.
11
Q
Okay. What is the existence of an entity
12
called Blueline Research and Development, do you know
13
what that is?
14
A
No. I think that there is a similar title,
15
Blueline is a private investigation --
16
Q
Okay.
17
A
-- firm of some sort.
18
Q
But did you ever use them, because that is
19
probably what they are talking about?
20
A
During the time I was at RRA, I am assuming?
21
Q
Yeah.
22
A
No.
23
Q
I think all these questions were about when
24
you were at RRA.
25
A
Right, I just -- I just wanted to clarify
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that.
2
3
4
5
6
7
Q
Okay. Now, your -- your assoc -- the next
subject of the matter is on the motion that -- that
turned to Mr. Edwards interac -- reported interactions
with anyone associated with the Epstein case and the
first question is -- excuse me -- during the time that
you were with RRA -- excuse me, somebody else's
8
handwriting -- and had investigation done on
9
Mr. Epstein, was any of your investigation that you
10
performed turned over to any person outside of RRA or
11
your clients?
12
A
No.
13
Q
You understood that?
14
A
I think that you were asking, did I do
15
investigation, get evidence and then turn it over to
16
somebody outside of the firm.
17
Q
That -- that's what the attempt of that
18
question was. The answer is no?
19
A
Right.
20
Q
Okay. And any of the directions that you ever
21
gave to the investigators, did you ever put that in the
22
form of memo, that is, would you give them written
23
directions?
24
A
I would just talk to Mike.
25
Q
The discussion turns to the matter -- manner
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in which cases were handled while Edwards was a partner
2
at RRA. The one meeting that you had in Mr. Rothstein's
3
office with Russell Adler and some persons unknown --
4
some unknown person on the phone, were you given any
5
direction at that time that certain discovery should be
6
done or tactics should be used with regard to
7
prosecuting the Epstein cases?
8
A
No.
9
Q
Okay. At the meetings that you -- at the
10
meetings that occurred with these various lawyers,
11
Berger, Adler, Stone, Rob Buschel were present and
12
Epstein was discussed, was the discovery that --
13
discovery and/or investigation regarding Mr. Epstein
14
ever discussed?
15
A
I -- I would assume so.
16
Q
Well, I --
17
A
In meetings, that we were talking about, was
18
Epstein discussed?
19
Q
Yeah, I -- I -- I assume, based upon the --
20
what we saw in the e-mails today, that is exactly the
21
purpose of the meeting, correct?
22
A
Exactly, that was the purpose of the meeting.
23
MR. INDYKE: Discovery I think was the purpose
24
of the question.
25
MR. HADDAD: I'm sorry?
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MR. INDYKE: I think the question related to
2
discovery that you were doing at the time.
3
MR. KING: Actually, the way the question
4
reads, it says, discovery and/or investigation.
5
MR. HADDAD: Yeah, didn't I read that?
6
MR. KING: Yes.
7
MR. HADDAD: Yeah, okay.
8
MR. KING: And I think he's answered.
9
BY MR. HADDAD:
10
Q
Mr. Edwards, were you involved in discussions
11
regarding the deposing of any of the people -- excuse
12
me, I apologize for what I have to read because I am
13
trying to make sense out of it. Mr. Edwards, were you
14
involved in the discussions regarding the deposing of
15
any of the people of these individuals, Mr. Trump, that
16
is, in discussions with any of the other lawyers in your
17
law firms including Scott Rothstein?
18
A
If you can make sense out of that question,
19
ask it your way, I'll try to answer it
20
Q
All right.
21
A
-- I have to idea what it means.
22
Q
But simple thing is, were you involved in the
23
discussions of the desired -- deposed Trump, Clinton,
24
all those people?
25
A
Yeah.
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2
3
4
5
6
7
Q
And of course, Dershovitz, the other one is
Amber Wexner, David Copperfield, all the rest of them,
correct?
A
Yes.
Q
Okay. And there is no question about that,
it's in all the rest of the discovery we got afterwards?
A
I was involved in the decision to take
8
anyone's deposition that was --
9
Q
And -- and I think there is an e-mail that we
10
saw yesterday, we better do this to put pressure, an
11
e-mail or something, it seems like yesterday, I guess it
12
was this morning.
13
Okay. Did you have any discussions within
14
your firm regarding the taking of the depositions of
15
several -- of celebrities or famous people who were
16
purportedly on Mr. Epstein's plane, so that they could
17
be deposed such that would be an inducement to
18
Mr. Epstein to settle his lawsuit?
19
A
Was I involved in a discussion?
20
Q
Yeah, well, you know, what this question is
21
asking, did you guys decide to take some depositions so
22
you could induce him to settle the lawsuit, that is,
23
almost like pressure. I guess inducement means
24
pressure, doesn't it, lure, pressure?
25
A
Do you want the short answer or the long
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answer?
2
3
4
5
Q
Probably the short answer first.
MR. KING: The right answer.
A
The correct answer is this. What we knew at
the time was that --
6
BY MR. HADDAD:
7
8
Q
This is going to be the long answer.
A
It is going to be. It is going to be, but to
9
be complete, I have no other choice. What we knew at
10
the time is that Jeffrey Epstein was molesting children
11
literally every day. So we tried to take his deposition
12
and he took the fifth. We tried to take his various
13
co-conspirators' depositions and they took the fifth.
14
We tried to take the next tier of people that we knew
15
information about him molesting these children and they
16
had lawyers who were paid for by Jeffrey Epstein or they
17
had lawyers paid for by Jeffrey Epstein and said they
18
were leaving the country forever. The next level of
19
people that we were attempting to take the deposition
20
Q
Or his father?
21
A
Right.
22
Q
Okay.
23
A
The next level of people that we were
24
attempting to take the deposition of were people that we
25
thought Epstein could not directly control, and people
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who were in his presence in places where we knew the
2
criminal molestation of children had had happened.
3
Those people, some of them were high-profile or
4
celebrity-type people. So in addition, did we think
5
that that could induce him to settle cases? Some people
6
thought that. I don't think he personally cares about
7
anybody, so I never adopted that, but that train of
8
thought was discussed and we took -- and we elected that
9
those were the next people in line whose deposition
10
should be taken.
11
Q
Well, without being argumentative, that is the
12
way every civil case works.
13
A
Yeah.
14
Q
You try to pressure people in to sue. I mean,
15
it is no different in this case than in any other case.
16
You've got people who will settle the case rather than
17
put up with a bunch of crap and you were hoping that
18
this is what happened. Somebody was hoping that's what
19
would happen in this case.
20
MR. KING: Objection to form, compound.
21
MR. HADDAD: Oh, okay. I can't even read it.
22
Okay, I will do that in a little bit, okay. Can
23
you just print it a little better so I can read it?
24
I don't -- I don't mean to be rude, but I --
25
MR. INDYKE: That's fine, Fred.
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MR. HADDAD: -- have a tough time reading it
2
period.
3
MR. GOLDBERGER: Period?
4
MR. HADDAD: Huh?
5
MR. GOLDBERGER: Hard time reading, period?
6
MR. HADDAD: Period.
7
THE WITNESS: He intentionally reads the
8
sentence.
9
MR. HADDAD: I mean, to quote -- to quote
10
blazing saddles, that's -- that's like American
11
gibberish. No offense, Darren.
12
MR. INDYKE: None taken.
13
BY MR. HADDAD:
14
Q
Did Mr. Jenne, did you direct -- I don't know
15
why it's back up again -- did you direct Mr. Jenne to do
16
an investigation on his Ep -- on the Epstein cases?
17
A
Other than what I have otherwise --
18
Q
Yeah.
19
A
-- described already, no.
20
Q
Did Jenne do any investigate -- we've already
21
asked and answered that, I am not going through that
22
again.
23
Did you -- did you contact any persons who
24
were listed in the book that was eventually produced by
25
Mr. Rodriquez after he got arrested with the book and
Empire Legal Support. Inc.
EFTA01089149
Bradley J. Edwards taken on 10/10/2013
1
the book was made public? A relevancy objection by
2
Mr. King.
3
A
Did I contact any people?
4
Q
First good objection so far.
5
Does Scarola read these things?
6
A
I don't think so.
7
Q
Scarola doesn't read them or-.-.-.
8
A
I don't think so.
9
Q
Scarola doesn't read them?
10
A
I don't even know what question is on the
11
table right now.
12
MR. KING: I think you -- you directed that
13
last question to me.
14
MR. HADDAD: Yeah, I know.
15
BY MR. HADDAD:
16
Q
Did you -- did you have contact with any
17
persons who were listed in the book that was eventually
18
produced by Mr. Rodriquez after he got arrested and --
19
A
I don't remember.
20
Q
-- and the book was made public?
21
A
I don't remember.
22
Q
Were you
24
A
Yes.
25
Q
Okay. And that wasn't even here, but thanks.
Empire Legal Support. Inc.
EFTA01089150
Bradley J. Edwards taken on 10/10/2013
1
Well, along the lines that were taken the last
2
time with regard to whatever work product was involved,
3
that didn't take Inspector Clouseau to figure that out,
4
anyhow.
5
A
I don't think I am telling anybody anything
6
they don't already know.
7
Q
Yeah, I -- I know. I didn't want it to seem
8
like I was that smart but-.-.-.
9
Well, along the lines that were taken with
10
regard to whatever work product was involved in the
11
investigation in light of the current state of the case,
12
you know, who asked these questions? Even --
13
A
Is it a question?
14
Q
Never mind, I'm am reading Mr. King's
15
objection. That's not a question.
16
MR. KING: That's right.
17
MR. HADDAD: He didn't want
He
18
wanted the book. We will get to that later.
19
That's a good trial question.
20
MR. GOLDBERGER: Oh, I'm sorry.
21
MR. HADDAD: That's okay.
23
Right?
24
MS. COLEMAN: Or
25
MR. HADDAD: No,
Empire Legal Support. Inc.
EFTA01089151
Bradley J. Edwards taken on 10/10/2013
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
. This is a polite trial.
BY MR. HADDAD:
Q
Did you have any contact with Kendall Coffey
regarding propriety or ask him for an opinion of the
propriety of taking that book from Rodriguez?
MR. KING: We'll assert the attorney-client
privilege.
MR. HADDAD: Okay.
MR. KING: Instruct him not to answer.
MR. HADDAD: That's fine. I got to -- yeah,
that's got to be a motion anyhow.
BY MR. HADDAD:
Q
All right. If you were asked each of these
questions, transcript of deposition dated -- I'm not
going to -- the same objection, I don't even know what
that is. And then Mr. Goldberg objects.
MR. HADDAD: Jack, do you remember what you
were objecting to?
MR. GOLDBERGER: No, I don't.
MR. HADDAD: Of course. Let me just kind of
clean it up. Oh, and then add Coleman objects.
Everybody objects.
MS. COLEMAN: I didn't object, I was laying a
record and you don't have to ask all those
questions, it was for the purpose of the motion for
Empire Legal Support. Inc.
EFTA01089152
Bradley J. Edwards taken on 10/10/2013
1
the Court to know it was asserted a second time,
2
that's all.
3
MR. HADDAD: Oh, okay. Was that from my depo?
4
MS. COLEMAN: Umm-hmm. That was from your
5
depo last time.
6
MR. HADDAD: All right. Let me see if I got
7
anything on Edwards.
8
MS. COLEMAN: So we don't have to sit here for
9
nine hours.
10
MR. HADDAD: See, they took the -- they took
11
the conspiracy out, so I can't have Rothstein.
12
THE WITNESS: I know, I know.
13
MR. HADDAD: Oh, proper predicate, okay. Let
14
me read what these are. Edwards compensation at
15
RRA and the payment of expenses.
16
BY MR. HADDAD:
17
Q
Did you do any hourly billing yourself or were
18
you strictly a contingency fee person? I guess that
19
would be contingency fee basis, I guess.
20
A
While I was at RRA?
21
Q
Yeah. Well, you answered it, 90 percent
22
contingency, so why the hell am I asking the question
23
with no objection?
24
Oh, here we go. Where did you -- where did
25
you think that the expense money incurred in the Epstein
Empire Legal Support. Inc.
EFTA01089153
Bradley J. Edwards taken on 10/10/2013
1
2
3
4
5
6
7
8
9
10
11
12
13
14
cases was coming from, the source of the money to pay
the extensive bills that were being incurred on Epstein
and other cases?
A
The law firm.
Q
Okay. And that was based
MR. HADDAD: Jack, do you want
do you want
me to stop and take a break so you can tell me what
to follow up with?
MR. GOLDBERGER: No.
MR. KING: Just so -- just so you know, he did
answer that at the bottom but --
MR. HADDAD: Yeah.
MR. KING: -- in the last line.
MR. HADDAD: I saw it now. He said the law
15
firm.
16
A
Good.
17
BY MR. HADDAD:
18
Q
And -- and let me just ask you this. In
19
regards to the law firm at that time, and I know we have
20
been through this before, there was no perception of the
21
law firm being involved in anything other than legal
22
activity?
23
A
Of course not. And other than being involved
24
in legal activity.
25
Q
Legal activity, yeah, that was representing
Empire Legal Support. Inc..
EFTA01089154
Bradley J. Edwards taken on 10/10/2013
1
Sheer, had --
2
A
You were talking fast. It's -- I wanted to be
3
sure there wasn't an issue.
4
Q
I know, but I wasn't trying to sneak one in.
5
I did that with the other thing. But any rate, Sheer,
6
representing Sheer, it represented everybody in town, it
7
was repres -- it was -- you were -- you were playing
8
around with John McCain and all those right-wingers,
9
tea-party people and all that other -- not -- not you,
10
but you know what I mean, taking care of all of that,
11
right? So it gave the appearance of a legitimate law
12
firm?
13
A
Yeah, it was a le -- it was, to everybody
14
else, a legitimate law firm.
15
Q
Except for nobody in town, just you guys at
16
and the firm. But anyway --
17
A
You should have shared that with Russ Adler
18
before.
19
Q
I knew that was coming.
20
Okay, hourly billing confirmed, financial
21
privacy. Okay. These questions aren't too bad.
22
MR. HADDAD: Okay. Thanks, Darren.
23
THE WITNESS: You have another book over here.
24
MR. HADDAD: Oh, I know. I see there is
25
another book over there.
Empire Legal Support. Inc.
EFTA01089155
Bradley J. Edwards taken on 10/10/2013
1
BY MR. HADDAD:
2
Q
Did Rothstein ask you how much you were making
3
at the time or how much you had made in the preceding
4
year, 2008? Answer: I believe so. Question: What did
5
you tell him?
6
MR. KING: Well, I think these -- all these
7
questions and answers would fall within the ambit
8
of the Court's ruling of financial privacy --
9
MR. HADDAD: I don't remember what that was.
10
MR. KING: And --
11
MR. HADDAD: We don't need to -- if you don't
12
want to, just tell me and we'll take it from here.
13
MR. KING: Well, the one thing, I don't want
14
him to have to come back for another deposition
15
so --
16
MR. GOLDBERGER: Let him answer it.
17
BY MR. KING:
18
Q
You didn't make -- you made whatever you made.
19
I mean, I
20
A
Yeah, I don't remember.
21
Q
-- could get your tax returns.
22
MS. COLEMAN: No.
23
MR. HADDAD: Huh?
24
MS. COLEMAN: That's what we are not allowed
25
to have.
Empire Legal Support. Inc.
EFTA01089156
Bradley J. Edwards taken on 10/10/2013
1
MR. HADDAD: Why?
2
MS. COLEMAN: The Court said we can't have his
3
private tax returns, but if what he was making was
4
related to --
5
BY MR. HADDAD:
6
Q
Is you wife -- are you still married?
7
MS. COLEMAN: -- a claim, we could have it.
8
MR. HADDAD: Maybe I could get you divorced
9
and have it produced from her.
10
MR. GOLDBERGER: Just ask the question, how
11
much he was making.
12
MR. HADDAD: I will.
13
BY MR. HADDAD:
14
Q
How much were you making?
15
MS. COLEMAN: We are not precluded from the
16
questions, just the documentation.
17
BY MR. GOLDBERGER:
18
Q
You were -- you were -- you were a PI lawyer
19
at that time before you went there, right?
20
A
Right.
21
Q
And you just -- didn't you just settle a big
22
case with the church, just before you got pulled in
23
there?
24
A
I don't remember that.
25
Q
Oh, I thought you -- somebody said that you
Empire Legal Support. Inc.
EFTA01089157
Bradley J. Edwards taken on 10/10/2013
1
settled a big church case with one of those priests with
2
the Archdiocese?
3
A
No.
4
Q
Okay. So how much were you making?
5
MR. KING: The same objection, based on the
6
Court's rule.
7
MR. HADDAD: Okay. Then -- okay.
8
MR. KING: Let me -- let me just -- let me
9
just touch base with him on one
on one issue
10
relating to that.
11
MR. HADDAD: Yeah.
12
MR. KING: Because again, we don't want to
13
come back.
14
THE VIDEOGRAPHER: The time is 1:46 P.M. We
15
are now coming off of the video record. This is
16
the end of Tape No. 2.
17
(Thereupon, a discussion was had off the
18
record.)
19
MR. KING: Let me just tell you our position
20
on --
21
THE VIDEOGRAPHER: The time is 1:49 P.M. We
22
are now back on the video record. This is the
23
start of Tape No. 3.
24
MR. KING: Sorry.
25
THE VIDEOGRAPHER: No problem.
Empire Legal Support. Inc.
EFTA01089158
Bradley J. Edwards taken on 10/10/2013
1
MR. KING: Let me tell you what our position
2
is. These questions, to the extent I believe all
3
of them are directed for him to say
are asking,
4
what did you tell Rothstein about what you were
5
making and what did you tell Rothstein about what
6
you expected to make, we will let him answer those
7
questions.
8
MR. HADDAD: Okay.
9
MR. KING: I think those are the questions to
10
11
12
13
14
which the objections were made and I don't think it
goes beyond, and then -- but to the extent that
there are any questions about how much did you
make --
MR. GOLDBERGER: Right.
15
MR. KING: -- at any time, then it falls
16
within the Court's order. So let's --
17
MR. HADDAD: No.
18
MR. KING: -- let's -- if you want to go
19
that --
20
MR. HADDAD: Can you answer his question,
21
because I don't want to -- let him answer the
22
questions.
23
A
I don't remember what I told him either. What
24
I had previously made or what I expected, I don't
25
remember that cony -- that part of that conversation
Empire Legal Support. Inc.
EFTA01089159
Bradley J. Edwards taken on 10/10/2013
1
2
BY MR. HADDAD:
3
Q
Okay. Well, you would have been a contingency
4
fee lawyer there anyhow?
5
A
Right.
6
Q
Let me ask you this: Did you have an
7
agreement as to what percentage of the profits -- Well,
8
let me put it this way.
9
Let's say it settled for a million bucks, you
10
bring it into the firm, you are now a part of RRA, you
11
were not a separate LLC or a separate P.A., how much of
12
what you brought into the firm did you get to keep,
13
as -- if the firm settled -- if you settled and the firm
14
got 40 percent, I don't know if you get 40 percent
15
anymore, 33-1/3. At 33-1/3, one million came in, how
16
much of that would you keep to the firm, what would your
17
cut be?
18
MR. KING: Well, I believe that the Court's
19
order covers that.
20
MR. HADDAD: Oh, does that cover that? Okay,
21
then I -- I -- I don't understand financial orders.
22
You know, in my business we deal in cash. Cash
23
ain't income, so we don't have --
24
A
Cash ain't income, that's a good one, for the
25
record.
Empire Legal Support. Inc.
EFTA01089160
Bradley J. Edwards taken on 10/10/2013
1
MR. HADDAD: I said -- I tell you that -- I
2
said that one time when I was giving a -- asked to
3
talk at a criminal law seminar. I said it as a
4
joke,
5
MR. GOLDBERGER: No kidding. I am shocked.
6
MR. HADDAD: Huh?
7
MR. GOLDBERGER: I'm shocked.
8
MR. HADDAD: All right. I'm not even going to
9
get into the financial stuff. Let me get into some
10
of these other questions so we can get out of here.
11
BY MR. HADDAD:
12
Q
Did you hire Kendall Coffey in the Epstein
13
cases, hire, not any questions? Well, I think silence
14
would say yes, so-.-.-.
15
MR. GOLDBERGER: Well, he is waiting to see
16
whether his lawyer is --
17
MR. KING: No, I think the way -- I think the
18
way the question is asked, you could answer that.
19
A
No.
20
MR. HADDAD: Okay. It took that long to say
21
no, I thought you were going to say yeah. I deal
22
with them every day.
23
MR. KING: But privilege objection still
24
stands.
25
MR. HADDAD: I know. I understand that.
Empire Legal Support. Inc.
EFTA01089161
Bradley J. Edwards taken on 10/10/2013
1
MR. KING: Right.
2
BY MR. HADDAD:
3
Q
Okay. I am just going to -- how much -- how
4
much --
5
A
Do you read questions off your hand now?
6
Q
That's how I do everything. Okay. Did
7
anybody else hire Kendall Coffey, that you know of, on
8
any cases? It's not you, so it can't be privileged.
9
MR. KING: Well, because -- because we have
10
asserted the privilege, I -- I believe it is --
11
it's appropriate to inquire about why that
12
privilege was asserted.
13
MS. COLEMAN: I'm sorry, did you say which
14
privilege it was?
15
MR. KING: The attorney-client privilege. We
16
asserted attorney-client privilege to a previous
17
question.
18
MR. HADDAD: Well, that was about all the
19
different lawyers that were involved.
20
MR. KING: No, no. You had asked him whether
21
or not -- one of the questions in here was, did you
22
consult with -- with Kendall Coffey about a
23
subject.
24
MR. HADDAD: Oh, that was about whether he
25
consulted Kendall Coffey about the guy that --
Empire Legal Support. Inc.
EFTA01089162
Bradley J. Edwards taken on 10/10/2013
1
Rodriguez.
2
MR. KING: Right.
3
MR. HADDAD: The boy.
4
MR. KING: And we asserted the privilege --
5
MR. HADDAD: You asserted the privilege on
6
that, but this is just hiring without ever
7
consultation. Did any --
8
BY MR. HADDAD:
9
Q
Well, let me just ask it and then you can just
10
say what you want to.
11
Did any of the lawyer -- other lawyers who are
12
now listed as your expert witnesses ever hire Kendall
13
Coffey, to your knowledge, not consult, what they did
14
with him?
15
A
I don't know.
16
Q
You don't know.
17
What was your involvement with
in the Rodriguez case?
19
A
Nothing.
20
Q
Okay. Did -- did RRA ever hire Kendall
21
Coffey, to your knowledge?
22
THE WITNESS: I can answer?
23
MR. KING: Umm-hmm.
24
A
Yes.
25
Empire Legal Support. Inc.
EFTA01089163
Bradley J. Edwards taken on 10/10/2013
1
BY MR. HADDAD:
2
Q
Okay. And would that have been after the
3
implosion? Was Kendall Coffey called --
4
A
I think that they did hire him after the
5
implosion, but that had nothing to do with what I was
6
thinking about.
7
Q
All right. Well, what did you -- what were
8
you thinking about?
9
MR. KING: Well, be careful what you're
10
thinking about doesn't tread on -- on privilege.
11
A
I understand. I think that -- all right. I
12
feel comfortable saying this. RRA hired Kendall Coffey
13
to answer one specific issue. RRA was the client.
14
Kendall Coffey --
15
MR. KING: Well, I think that is getting too
16
far into it. The bottom line is, RRA hired Coff
17
Kendall Coffey and that was the basis for our
18
assertion of privilege earlier.
19
MR. HADDAD: Okay.
20
MR. KING: All right.
21
BY MR. HADDAD:
22
Q
Nothing to do with
23
A
No.
24
Q
In the Rodriguez's cases?
25
A
No.
Empire Legal Support. Inc.
EFTA01089164
Bradley J. Edwards taken on 10/10/2013
1
Q
Did -- well, did they ever show you the
2
running expenses, by the way, of what your cost is?
3
A
What they
4
Q
You know, whoever ran the books at RRA? I
5
mean Rothstein didn't know what was going, Adler was
6
just taking all the money.
7
A
At the time when I was at RRA, no.
8
Q
Okay.
9
A
Subsequently, yes.
10
Q
Subsequently?
11
A
Way after.
12
Q
But that would have been by the trustee and
13
bankruptcy or someone like that --
14
A
Right. That's how --
15
Q
-- corroborating whether or not the money was
16
valid, where it went, how it went and so forth?
17
A
Correct. And the total costs on all of the
18
cases was $203,000 for all the cases combined.
19
Q
That's what you said before.
20
A
I think that I said it was greater than that
21
before. But once we did the closeout sheets, the exact
22
number was $203,000.
23
Q
Let me ask you this, just for the hell of it.
24
How much did you spend before you went to RRA working up
25
these case, approximately?
Empire Legal Support. Inc.
EFTA01089165
Bradley J. Edwards taken on 10/10/2013
1
A
I don't know, but it was less than $25,000,
2
you were right in the last motion, I don't know exactly
3
what it was though.
4
Q
Okay. So at least not that they should, you
5
went with a big firm and they had the money to
6
produce -- the ability to prosecute these cases?
7
A
Any cases, right.
8
Q
Yeah, I mean, I understand, you didn't have
9
any other cases -- oh, yeah, you did.
10
A
Right, I did.
11
Q
Okay. Did you share info with
13
A
I shared public information with her.
14
Q
Is that that
15
A
Right.
16
Q
Because they didn't put down who it was and
17
I'm asking questions.
18
A
Right.
19
Q
Okay.
20
MR. GOLDBERGER: Well done, way to figure it
21
out.
22
MR. HADDAD: Huh?
23
MR. GOLDBERGER: Way to figure it out.
24
MR. HADDAD: I never met somebody named
25
unless she was dancing down in a place in
Empire Legal Support. Inc.
EFTA01089166
Bradley J. Edwards taken on 10/10/2013
1
Mexico when I was down there drinking. Okay.
2
Wasn't that
Cafe in -- down in
, town of
4
MS. COLEMAN: Yes.
5
MR. HADDAD: Marty Robbins -- beautiful --
6
yes. Okay.
7
BY MR. HADDAD:
8
Q
While you were there with RRA living the high
9
life, as it were, did you make political contributions
10
at all?
11
A
No.
12
Q
Okay. Did they make contributions in your
13
name? Did you ever become aware whether or not Scott
14
was making contributions in your name, because he made a
15
contribution in tons of people's names and covered it
16
up?
17
A
Not that I know of.
18
Q
Okay.
19
A
No one's ever told me that to this date.
20
Q
Because you look like a Republican, I thought
21
maybe that they would have done that. Did you have
22
contact with the U.S. Government in this -- Epstein
23
civil cases?
24
A
What?
25
MR. HADDAD: I don't understand the question,
Empire Legal Support. Inc.
EFTA01089167
Bradley J. Edwards taken on 10/10/2013
1
you ask it. I know it's only supposed to be one
2
witness, but I can't --
3
MR. GOLDBERGER: I can't.
4
MR. HADDAD: I can't answer them, I don't want
5
to ask that question.
6
All right, anybody got anything else?
7
Give me one second, because we can't have you
8
back.
9
MR. GOLDBERGER: Let me -- would it make it
10
easier, guys, if -- if you could just step out for
11
one second. I think that's going to end the depo,
12
I just need to have a consultation.
13
THE WITNESS: Anything that is going to end
14
the depo I will do.
15
MR. GOLDBERGER: I hear you. I hear you.
16
MR. HADDAD: Are you going to read?
17
THE VIDEOGRAPHER: The time is 1:57 P.M. We
18
are now coming off the video record.
19
(Whereupon, a break was taken.)
20
THE VIDEOGRAPHER: The time is now 2:00 P.M.
21
We are back on the video record.
22
MR. HADDAD: It's two o'clock. Your Rolex
23
doesn't keep very good time, Bill.
24
MR. GOLDBERGER: It is now two o'clock, 2:01.
25
MR. HADDAD: Oh, it was a sweep secondhand, I
Empire Legal Support. Inc.
EFTA01089168
Bradley J. Edwards taken on 10/10/2013
1
didn't see it that well.
2
BY MR. HADDAD:
3
Q
All right. You entered into settlement
4
agreements with various people that Epstein signed,
5
correct?
6
A
Right.
7
Q
Okay. Were any changes to the settlement
8
agreements ever made, as far as distributions after they
9
were signed, did the girls get what they said they were
10
going to get?
11
A
Right.
12
Q
The agreements were fulfilled?
13
A
Yes.
14
Q
In every single way?
15
A
In every single way. I don't understand the
16
question, but yes.
17
Q
I understand that.
18
A
Settlement agreements, what was said in the
19
settlement agreement.
20
MR. KING: Is somebody calling in?
21
MR. INDYKE: Hit the green button.
22
MR. GOLDBERGER: I got it. I got it.
23
BY MR. HADDAD:
24
Q
Go ahead.
25
MR. GOLDBERGER: We got you back now?
Empire Legal Support. Inc.
EFTA01089169
Bradley J. Edwards taken on 10/10/2013
1
MR. EPSTEIN: Yes.
2
MR. GOLDBERGER: Okay.
3
BY MR. HADDAD:
4
5
6
Q
Okay. So there were no changes to the
settlement agreements.
The other thing is, have you had any contact
7
with
lately in the last
8
year, say?
9
A
. Yes.
10
Q
And are you still maintaining contact with her
11
regarding the litigation?
12
A
What litigation?
13
Q
Well, the CVRA?
14
A
We have no choice, but we are engaged in
15
litigation with the Government and she is one of the
16
people that participated.
17
Q
All right. And so you maintain contact with
18
her regarding that litigation?
19
A
Right.
20
Q
All right. Are you meeting with her at all in
21
the possibility of prosecuting or re-prosecution and
22
discussing that with her, or just the --
23
A
That has never been discussed.
24
Q
Okay. Now, lastly --
25
MR. GOLDBERGER: Go ahead.
Empire Legal Support. Inc.
EFTA01089170
Bradley J. Edwards taken on 10/10/2013
1
MR. HADDAD: Go ahead. No, tell me.
2
(conferring). Oh.
3
BY MR. HADDAD:
4
Q
Have you discussed with her this case that you
5
are doing right now --
6
A
No.
7
Q
-- involved in this case?
8
A
I don't believe so.
9
Q
Do you know if she runs over to the Courthouse
10
to look at the docket, what do you call that, PACER?
11
That's Federal, whatever you call the docket.
12
A
I have no idea.
13
Q
All right. Let's go back to the last thing I
14
wanted to do and I had forgotten about it, was damages.
15
What are you -- what are you still claiming for damages,
16
other than the lost time, anything else?
17
A
It hasn't changed since last time.
18
Q
I don't remember what I asked you, I don't
19
remember what you said.
20
MR. KING: You got into a very detailed
21
reputation.
22
MR. HADDAD: Is he still -- he is not claiming
23
reputation anymore.
24
BY MR. HADDAD:
25
Q
You have a reputation better than ever. What
Empire Legal Support. Inc..
EFTA01089171
Bradley J. Edwards taken on 10/10/2013
1
are you claiming?
2
MR. KING: You asked the same question last
3
time.
4
MR. HADDAD: I don't remember it. I thought
5
the last time we said you -- taking time away from
6
your family and that stuff for economical --
7
MR. KING: He went -- but he went into great
8
detail, as you might recall, where he talked about
9
the fact that, you know, he would go to the -- he
10
would go over to the Courthouse and lawyers would
11
look at him, and his reputation was -- was impacted
12
by that and what -- what he was able to do to
13
truncate that later on.
14
MR. HADDAD: You're right.
15
BY MR. HADDAD:
16
Q
Do you still maintain that stuff?
17
A
As I said then, have I done a good job at
18
resurrecting whatever damage was done? Yes, I did. Is
19
there -- is there --
20
Q
What was the -- what was the impact to you
21
from supposed -- and I don't mean that pejoratively,
22
damage to your reputation by being sued for being with
23
Rothstein?
24
A
Uh, what -- for being falsely accused of
25
committing crimes I didn't accuse by Epstein.
Empire Legal Support. Inc.
EFTA01089172
Bradley J. Edwards taken on 10/10/2013
1
2
3
4
5
Q
You are not accused of committing a crime, you
were sued for -- in civil court.
A
I was sued for fraud, I was sued for RICO.
Q
Civil. That's civil. There's civil -- you
know what a civil RICO -- that's not a crime, it could
6
also be a civil --
7
8
A
Civil RICO is based on criminal violations.
Q
I'm not going to argue, of course it is.
9
MR. KING: Hold on, hold on, objection. It is
10
a nice colloquy to have with him, but he hasn't
11
answered your question yet.
12
MR. HADDAD: All right.
13
BY MR. HADDAD:
14
Q
What's your damages? What damages are you
15
maintaining today if we go to trial next week, two
16
weeks?
17
MR. KING: Objection, he has answered it
18
extensively in the last deposition.
19
But go ahead.
20
BY MR. HADDAD:
21
Q
Are you adopting -- let me put it this way,
22
we'll go from there.
23
Are you adopting the answers in your last
24
deposition as still being the damages that you maintain
25
today?
Empire Legal Support. Inc.
EFTA01089173
Bradley J. Edwards taken on 10/10/2013
1
A
Yes.
2
MR. HADDAD: Any -- all right.
3
MS. COLEMAN: You have any -- can I ask the
4
question?
5
MR. HADDAD: Yeah.
6
MR. GOLDBERGER: It will get us out of here
7
quicker if you let Tonya.
8
MS. COLEMAN: Okay.
9
CROSS-EXAMINATION
10
BY MS. COLEMAN:
11
Q
Do you have any documentation that would
12
support the claim of financial loss with respect to any
13
injury to your reputation or your emotional distress,
14
which you claimed previously?
15
A
I never made a claim for financial loss in
16
this case. And --
17
Q
Do you have any --
18
A
-- emotional distress is what I testified
19
about last time, is that it is a matter of who it is
20
that is suing me and the level of stress and anxiety
21
that has gone along with that is certainly extreme. And
22
I have been and remain to be in fear for my safety
23
because of him. So will that -- is that still the same?
24
Yes, it's the same now, was then, you know.
25
Q
How do you plan to quantify that?
Empire Legal Support. Inc.
EFTA01089174
Bradley J. Edwards taken on 10/10/2013
1
THE WITNESS: Should I answer this, I mean --
2
MR. KING: Hold on, hold on a second.
3
THE WITNESS: I can answer it with a question,
4
maybe.
5
MR. KING: No, no.
6
THE WITNESS: Okay.
7
MR. KING: Ultimately, the quantification is
8
up to a jury. But it's fair -- it would be fair to
9
inquire. He can't put a number on it and it's
10
unfair to ask witnesses to put a number on a matter
11
that a jury is going to respond to and I would
12
object if that's the intent of your question.
13
MS. COLEMAN: It is not.
14
MR. KING: If -- if there is a proper more
15
precise question, I will let him answer. But that
16
question calls for -- that's an inappropriate
17
question, in that it call -- it asks for what he
18
thinks the number might be or what a jury might
19
evaluate it to be. At least, arguably, it could be
20
construed that way.
21
MS. COLEMAN: I mean --
22
MR. KING: If you -- if the question is,
23
are -- are there any documents that you are
24
introducing, documentation to support a particular
25
claim, I believe he has already answered those
Empire Legal Support. Inc.
EFTA01089175
Bradley J. Edwards taken on 10/10/2013
1
questions last time and I believe that the
2
discovery was directed to that, but I could be
3
wrong on that. So within that -- within those
4
confines, if you want to restate the question, go
5
ahead.
6
BY MS. COLEMAN:
7
Q
We established last time that with respect to
8
your emotional distress and any kind of mental anguish
9
damages, you never
11
12
, correct?
A
It's still the same.
Q
So in forms of any type of evidence, physical
13
demonstrative evidence, other than testimony of other
14
people, do you have anything upon which you are relying
15
or asserting that claim of damages?
16
A
Outside of testimony, are there any documents,
17
no.
18
Q
The same holds true with injury to reputation.
19
You said last time that you listed people such as Russ
20
Adler, Earleen Cote and I believe a former judge, I
21
forget off the top of my head, as people who would
22
testify as to the injury of your reputation; is that
23
correct?
24
A
Right, I don't -- I don't know what you --
25
what you would mean by documentation to support that.
Empire Legal Support. Inc.
EFTA01089176
Bradley J. Edwards taken on 10/10/2013
1
If newspaper articles that were printed after the filing
2
of the claim against me is something that would support
3
that, then I guess to that extent, yes, but if you are
4
asking about medical documents or anything like that,
5
then the answer would be no. I'm not exactly sure what
6
you are getting at but I --
7
Q
Well, for example, you are claiming your
8
reputation was injured.
9
A
Right.
10
Q
And based on the elements of proof required to
11
prove injury to damage to reputation, there are certain
12
factors that you must meet.
13
A
Right.
14
Q
I'm asking if you have any physical
15
documentation or any
you've objected to all your
16
financial information, so I guess my question in plain
17
English is: How are you going to prove that you have
18
any kind of pecuniary -- pecuniary loss as a result of
19
an injury to your reputation if we don't have any
20
documents to back that up?
21
A
I have not claimed an economic loss as a
22
result of my reputation. I haven't. And the only thing
23
that I can say to answer your question is, I know who
24
has hired me. I will never know who would have hired me
25
but elected not to because of what it was that they
Empire Legal Support. Inc.
EFTA01089177
Bradley J. Edwards taken on 10/10/2013
1
read. So therefore, I have not had a phone call where
2
somebody has said, hey, Brad, I was going to hire you
3
but I read this and, so, therefore, I'm not, and I am
4
hiring some other person, which is the only context in
5
which that could ever arrive.
6
Q
But have you always advertised Jeffrey Epstein
7
on your firm Web site since you guys founded Farmer
8
Jaffe?
9
MR. KING: All right. Look, I'm going to
10
object. This is repetitious and now we are
11
getting -- we are getting to other lawyers asking
12
questions well beyond.
13
MR. HADDAD: All right, fine.
14
BY MR. HADDAD:
15
Q
When was the last time you talked to
, by
16
the way,
{SIC}?
17
A
I don't
I don't remember.
18
Q
Within the last month?
19
A
No.
20
Q
Okay. And I had one good question and it
21
escapes me.
22
A
It's on your hand.
23
Q
No, that wasn't the one that was on my hand.
24
Uh, It was on damages, I will worry about it later. One
25
second.
Empire Legal Support. Inc.
EFTA01089178
Bradley J. Edwards taken on 10/10/2013
1
MR. HADDAD: Huh?
2
MR. GOLDBERGER: The safety stuff, he says he
3
got some --
4
MR. HADDAD: Oh, yeah, yeah, yeah.
5
BY MR. HADDAD:
6
Q
How many bodyguards have you hired for your
7
safety?
8
A
I haven't hired bodyguards.
9
Q
Have you changed -- have you changed your
10
place of living, hiding in an apartment, in a
11
safe-house, witness protection?
12
A
Not in witness protection.
13
Q
Has anybody made any threats to you,
14
surveilled you, followed you?
15
A
Yes.
16
Q
Now, recently?
17
A
Well, I don't know about recently whether they
18
have or have not. I know that in the past, people did.
19
Q
For purposes of -- you don't know what
20
purposes for -- for preparing for litigation, like
21
people do, you know, with those videotapes like the guys
22
who said they got bad legs and they play golf when no
23
one is looking?
24
A
Right. There is a purpose behind that
25
surveillance.
Empire Legal Support. Inc.
EFTA01089179
Bradley J. Edwards taken on 10/10/2013
1
Q
Yeah.
2
A
If you are making a claim that somebody during
3
2009 was somehow conducting some bad discovery against
4
you and that forms the basis of a lawsuit, then how --
5
how in the world would performing the surveillance on
6
that person in 2010 go to proving that case? It's only
7
for the purposes of intimidation, that's it, period.
8
Q
Well, if -- if they are going to intimidate
9
you, they wouldn't be surveilling you surreptitiously so
10
that you are not --
11
A
I saw people.
12
Q
Saw people, you don't know who it is. It
13
might -- it might -- you know
do you know it was from
14
Epstein?
15
A
Oh, yeah.
16
Q
How?
17
A
Well, I told my investigator, hey, this is who
18
was following me. And within days, he was also followed
19
and he learned the identity of the investigator and it
20
was somebody that was used by Epstein.
21
Q
Who was the investigator?
22
A
Who was the investigator that I talked to?
23
Q
No. Who was the first -- the investigator,
24
probably somebody used by Epstein?
25
A
I don't -- I don't remember.
Empire Legal Support. Inc.
EFTA01089180
Bradley J. Edwards taken on 10/10/2013
1
Q
Well, I thought something might -- I might
2
remember if somebody was following you. Was it a
3
private investigator that was following you?
4
A
Yeah.
5
Q
Isn't that what private investigators do,
6
follow people?
7
A
At somebody else's direction, yes.
8
Q
Okay. I mean, it wasn't like he sent two
9
goons from East Mulberry Street down to follow you.
10
A
I don't know --
11
Q
You know where Mulberry Street is, don't you?
12
A
No.
13
Q
In little Italy.
14
A
Okay.
15
Q
Nobody from Little Italy -- I mean, you know,
16
Guido and his buddies didn't come and follow you, it was
17
just a private investigator? Yes?
18
A
To the best of my knowledge.
19
Q
Okay.
20
A
I don't know.
21
Q
I don't have anything else. Thank you.
22
MR. HADDAD: Anybody have anything? Can I
23
finish?
24
MR. GOLDBERGER: Yes, you can wrap it up.
25
MR. HADDAD: Thank you.
Empire Legal Support. Inc.
EFTA01089181
Bradley J. Edwards taken on 10/10/2013
1
MR. KING: Can we determine that this -- this
2
deposition is concluded?
3
MR. HADDAD: Yes.
4
MR. KING: All right. Thank you, sir.
5
THE VIDEOGRAPHER: The time is 12:00 P.M
We
6
are now coming off the video record. This is the
7
end of Tape No. 3.
8
(Thereupon, a discussion was had off the
9
record.)
10
THE REPORTER: Do you want to read this?
11
THE WITNESS: Oh, I can't wait.
12
MR. KING: Yeah, he will read. Do you want to
13
go back on the deposition. He will read.
14
THE REPORTER: And do you want one if this
15
ordered?
16
MR. HADDAD: I can't afford it.
17
MS. COLEMAN: I will take it.
18
THE REPORTER: Do you want a copy of the
19
transcript?
20
MR. KING: Yeah.
21
(Thereupon, a discussion was had off the
22
record.)
23
(Witness excused.)
24
(Thereupon, Plaintiff's Exhibit Nos. 1 and 2
25
were marked for identification.)
Empire Legal Support. Inc.
EFTA01089182
Bradley J. Edwards taken on 10/10/2013
(Deposition was adjourned at 2:30 P.M.)
AND FURTHER DEPONENT SAITH NOT
SIGNATURE OF WITNESS
STATE OF FLORIDA
BROWARD COUNTY
SUBSCRIBED AND SWORN to before me this
day of
, 2013 at Broward County,
Florida.
Notary Public, State of Florida at Large
Commission No:
My Commission Expires:
Empire Legal Support. Inc.
EFTA01089183
CERTIFICATE OF OATH
STATE OF FLORIDA
COUNTY OF BROWARD
I, the undersigned authority, certify that BRADLEY
EDWARDS personally appeared before me and was duly sworn
on the 10th day of October, 2013.
Witness my hand and official seal this 24th day of
October, 2013.
Wendy Roberts
Registered Professional Reporter
Notary Public, State of Florida at Large
Commission No.:
My commission expires: March 29, 2016
EFTA01089184
CERTIFICATE
STATE OF FLORIDA, )
COUNTY OF BROWARD. )
I, WENDY ROBERTS, Registered Professional
Reporter and Notary Public in and for the State of
Florida at Large, do hereby certify that the
foregoing testimony was taken before me; that the
witness was duly sworn by me; and that the foregoing
pages constitute a true record of the testimony
given by said witness.
I further certify that I am not a relative or
employee or attorney or counsel of any of the
parties, or a relative or employee of such attorney
or counsel, nor financially interested in the
action.
Under penalties of perjury, I declare that I
have read the foregoing certificate and that the
facts stated herein are true.
Signed this 24th day of October, 2013.
WENDY ROBERTS, Registered Professional Reporter
EFTA01089185
EMPIRE LEGAL SUPPORT, INC.
401 EAST LAS OLAS BOULEVARD, STE 1400
FORT LAUDERDALE, FL 33301
To: BRADLEY EDWARDS, ESQUIRE
Farmer Jaffe Weissing Edwards Fistos Lehrman
425 North Andrews Avenue, Suite 2
Fort Lauderdale, Florida 33301
Re: CASE NO.: 502009CA040800XXXXMBAG
Dear BRADLEY EDWARDS,
Your deposition taken in the above
entitled cause is now ready for signature.
Please come to this office and sign same; or
if you wish to waive the signing of the
deposition, please so advise.
If this deposition has not been signed
within 30 days of today's date, October 24th,
2013, we shall consider your signature waived.
Your prompt attention in this matter is
appreciated.
Sincerely,
Wendy Roberts, RPR
EFTA01089186
DEPOSITION ERRATA SHEET
Our Assignment No. 12217
Case Caption: JEFFREY EPSTEIN
vs. SCOTT ROTHSTEIN
DECLARATION UNDER PENALTY OF PERJURY
I declare under penalty of perjury
that I have read the entire transcript of
my Deposition taken in the captioned matter
or the same has been read to me, and
the same is true and accurate, save and
except for changes and/or corrections, if
any, as indicated by me on the DEPOSITION
ERRATA SHEET hereof, with the understanding
that I offer these changes as if still under
oath.
Signed on the
day of
, 2013.
BRADLEY EDWARDS
EFTA01089187
DEPOSITION ERRATA SHEET
Page No.
Line No.
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Reason for change:
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SIGNATURE:
BRADLEY EDWARDS
EFTA01089188
DEPOSITION ERRATA SHEET
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SIGNATURE:
BRADLEY EDWARDS
EFTA01089189
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View in Artifacts BrowserEmail addresses, URLs, phone numbers, and other technical indicators extracted from this document.
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